RECORD OF DECISION
OPERABLE UNIT 1
KERR-McGEE CHEMICAL CORPORATION SUPERFUND SITE JACKSONVILLE, DUVAL COUNTY, FLORIDA
PREPARED BY UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
PRO"
DECEMBER 2016 RECORD OF DECISION PARTI Declaration
Site Name and Location
Tliis Record of Decision (ROD) is for Operable Unit 1 (OUl) of the Ken-McGee Chemical Corporation (Ken-McGee) Superfund Site (Site) located in Jacksonville. Duval Count>. Florida. The United States Environmental Protection Agency (EPA) Site Identification Number is FLD039049101.
Statement of Basis and Purpose
Tliis decision document presents the Selected Remedy for OUl (Site soil, groundwater, sediment and suiface water from the St. Johns River) in accordance with the Comprehensive Environmental Response. Compensation and Liability .Act of 1980 (CERCE.A). as amended by the Supeiiund .Amendments and Reauthorization .Act (S.AR.A) of 1986. and. to the extent practicable, the National Oil ami Hazardous Substances Pollution Contingency Plan (NCR). 40 Code of Federal Regulations (CFR) Pail 300. as amended. Tliis decision is based on the .Administrative Record (.AR) for the Site, wliich was developed in accordance with Section 113(k) of CERCE.A. 42 United States Code Section 9613(d).
The .AR is available for review at the Jacksonville Public Eibraiv. Brown Eastside Branch in Jacksonville. Florida and at the EP.A Region 4 Records Center in .Atlanta. Georgia. Tlie State of Florida, as represented by the Florida Department of Environmental Protection (FDEP). has expressed its support for the Selected Remedy.
Assessment of the Site
The response action selected in tliis R(!)D is necessaiv to protect human health and the environment from actual or threatened releases of hazardous substances, pollutants or contaminants into the environment wliich ma\ present an imminent and substantial endangemient to public health or welfare.
Description of Selected Remedy
The Selected Remed\ is the final action to address potential human and ecological exposure to contaminants in soil and groundwater at the Site (on-propei1> and off-propeit> ). and sediment and suiface water in the St. .Tolins River. Tlie (!)U1 R(!)D will be implemented pursuant to the remedial authorities of CERCE.A. and will be the final response for this (!)perable Unit ((!)U).
The primaiy components of the Selected Remedy for contaminated soil include:
• Removal and off-site treatment disposal of Piincipal Tlueat W aste (PTW ) from former scmbber sludge pile and suiface impoundment:
• Removal and on-site consolidation of constmction debris and contaminated soil from the CSX Transportation (CSX) propeitx directh adjacent to the Kerr-McGee propei1> . Site-specific impacted soil on the Jacksonville Port .Authoritx (.T.AXP(!)RT) propei1> will be left in-place beneath the existing cap: • Constmction of a low-peiTneabilit> cap (with stoiTnwater management features) over the footprint of the Ken -McGee propert> : and
• Implementation of institutional controls (ICs) to ensure long-teiTn protectiveness of the remedy. Anticipated ICs include: Implementation of a soil management plan for each propei1> w here soil w ith Site-specific chemical of concern (C(!)C) concentrations above levels that w ill allow unrestricted use: implementation of restrictive covenants for commercial industrial land use (CSX and Kerr-McGee properties): maintenance of the existing cap on the JAXP(!)RT"s propeitx and the low peiTneabilitx cap on the Ken-McGee propei1> .
Primaiy components of the Selected Remedy for contaminated sediment include:
• Installation of an environmental bulkhead seaw all to contain contaminated sediment in-place in the St. Jolins River:
• Removal and on-site consolidation of concrete and other constmction debris from the St. Johns River along the environmental bulkhead perimeter:
• Excavation dredging and consolidation within the containment area of contaminated sediment outside the environmental bulkhead perimeter:
• Backfilling of the 2.5-acre area enclosed by the bulkhead:
• Implementation of ICs (maintenance of bulkhead seawall and containment area) to ensure long- teiTn protectiveness of the remed\ :
• Fish tissue sampling will be performed during the remedial design. The EP.A in collaboration with FDEP and the Florida Department of Health (FDOH) will evaluate the data collected during the sampling activities to deteimine whether or not a fish consumption advisoiv is necessaiv for the area of the St. Jolins River adjacent to the Site: and
• Development and implementation of a surface w ater LTM program to verifx and document that surface water cleanup levels have been acliieved. Surface water samples will be collected and anah zed for surface water C(!)Cs (DDD. gamma clilordane. aluminum, copper, iron, and mercuiv ) and several chemicals (alpha-BHC. beta-BHC. dieldrin. total PCBs. and lead) that were detected during the RI at levels above the surface water qualitx criteria in surface water or pore water samples, but were screened out tluough the ecological risk assessment process. .As a result, these chemicals are not identified as C(!)Cs for surface water. However, as requested In FDEP. these chemicals w ill be included as part of the surface w ater FTM.
Primaiv components of the Selected Remed\ for contaminated groundwater and surface water include:
• In-situ stabilization solidification (ISS) of contaminated, unsaturated and saturated soil in the vicinitx of the former Florida .Agricultural Supph Compan\ (F.ASC(!)). herbicide and sulfur grinding buildings as well as the former acid plant, where the liighest. Site-specific C(!)C concentrations have been obseived in soil and groundwater due to liistoric operations (i.e.. "source areas"). During the remedial design, additional investigation will be conducted to refine the lateral and vertical extent of the areas w here ISS w ill be implemented. In addition, bench and or pilot scale testing will be perfoiTned to identify the most effective ISS injection material and to refine the design parameters prior to full-scale implementation:
111 • Installation and operation of a groundwater pump and treat (P&T) s\ stem to prevent discharge of contaminated groundwater to the St. Jolins River and Deer Creek:
• Implementation of ICs. such as groundwater extraction well installation restrictions tluoughout the contaminated groundwater plume, to prevent human exposure to the contaminated groundwater:
• Development and implementation of a groundwater LTM plan to assess the effectiveness of the remed\ and to verifx that the residual dissolved groundwater plume is naturalK attenuating. .As pail of the LTM plan development, additional groundw ater monitoring w ells w ill be installed in the suificial aquifer on the CSX propeitx and groundwater samples will be collected and anah zed. The collected groundwater data will be utilized to evaluate the potential migration of site-specific C(!)Cs from the soil into the groundw ater. If the collected data indicate that soil C(!)Cs are migrating into the groundwater, additional soil sampling will be conducted on the CSX propertx to deteiTnine the extent of soil with C(!)C concentrations above site-specific leachabilitx criteria, wliich will be developed during the remedial design. Soil with C(!)C concentrations above these criteria will addressed via containment, excavation, or in-situ treatment.
StatutoiT Deteriiimatioiis
The Selected Remed\ is protective of human health and the environment, complies with federal and state requirements that are applicable or relevant and appropriate to the remedial action (unless justified In a waiver), is cost-effective, and utilizes peiTnanent solutions and alternative treatment teclinologies (or resource recoveiv ) to the maximum extent practicable. Tliis remedy also satisfies the statutoiy preference for treatment as a principal element of the remedy (i.e.. reduces the toxicitx. mobilitx. or volume of hazardous substances, pollutants, or contaminants as a principal element tluough treatment). Because tliis remedy will result in hazardous substances, pollutants, or contaminants remaining on-site above levels that allow for unlimited use and umestricted exposure, a statutoiv review will be conducted within five \ ears after initiation of remedial action to ensure that the remed\ is. or will be. protective of human health and the environment.
ROD Data Certification Checkfist
The following infoimation is included in the Decision Summan (Pail II) of this ROD. .Additional infoiTnation can be found in the .AR file for tliis Site.
• Identification of COCs and their respective concentrations (Section 5. 7: Table 7-1):
• Baseline risk represented by COCs (Section 7: Tables 7-2 tluough 7-23):
• Cleanup levels established for COCs and the basis for these levels (Section 8: Tables 8-1 tluough 8-5):
• How source materials constituting principal tlueats are addressed (Sections 5. 9. II. 12):
• Cunent and reasonabh anticipated future land use assumptions and cunent and potential future beneficial uses of groundwater used in the baseline risk assessment and the ROD (Sections 6 and 7):
• Potential land and groundwater use that will be available at the Site as a result of the Selected Remedy (Sections 6. 9. and 12):
IV Estimated capital, annual operation and maintenance (O&M), and total present worth costs; discount rate; and the number of years over which the remedy cost estimates are projected (Sections 10 and 12, Exhibits 3, 4 and 5, and Table 12-1); and
Key factors that led to selecting the remedy (i.e.. description of how the Selected Remedy provides the best balance of tradeoffs with respect to the balancing and modifying criteria, highlighting criteria key to the decision) (Sections 10 and 13; Table 10-1).
Authorizing Si£nature
Franklin E. Hill, Director Superfund Division Date Table of Contents
PART I Declaration
PART II Decision Summary
1.0 Site Location and Description 1
2.0 Site History and Enforcement .Activities 2 2.1 Histoiy of Site Operations 2 2.2 Enforcement Activities 3
3.0 Community Participation 4
4.0 Scope and Role of Response .Action 6
5.0 Site Characteristics 7 5.1 Site Setting and Topography 7 5.2 Suiface Water Hydrology 7 5.3 Site Geology 8 5.4 Site Hydrogeology 8 5.5 Nature and Extent of Contamination 9 5.5.1 Source Areas 9 5.5.2 Principal Tlueat Waste 10 5.5.3 Surface Soil 10 5.5.4 Subsuiface Soil 11 5.5.5 Groundwater 11 5.5.6 Groundw ater Natural Attenuation Lines of Evidence 13 5.5.7 Sediment 14 5.5.8 Suiface Water 15
6.0 Current and Potential Future Land and Resource Use 16 6.1 Cunent and Anticipated Future Land Use 16 6.2 Cunent and Anticipated Future Resource Use 16
VI 6.2.1 Groundwater 16 6.2.2 Surface Water 16
7.0 Summary of Site Risks 17 7.1 Summaiy of Human Health Risk .Assessment 17 7.1.1 Chemicals of Concern 17 7.1.2 Exposure .Assessment 17 7.1.3 Toxicitx .Assessment 19 7.1.4 Risk Characterization 20 7.1.5 Uncei1aint> 24 7.2 Ecological Risk .Assessment 25 7.2.1 .Assessment Endpoints and Chemicals of Potential Ecological Concern 26 7.2.2 Baseline Ecological Risk .Assessment Conclusions and Remedial Goal Options 28
8.0 Remedial .Action Objectives 29 8.1 Cleanup Levels 29
9.0 Description Of .Alternatives 31 9.1 Soil .Alternatives 31 9.1.1 Soil .Alternative SS-1: No .Action 31 9.1.2 Soil .Alternative SS-2: Removal of PTW: Installation of Low-Permeabilit> Cap: ICs 31 9.1.3 Soil .Alternative SS-3: Removal of PTW: Excavation and Off-Site Disposal of Contaminated Soil Posing a Direct Exposure Contact Risk (Exceeding Commercial Industrial CTLs): Installation of Low-PeiTneabilit> Cap: ICs 32 9.1.4 Soil .Alternative SS-4: Removal of PTW: Excavation and Off-Site Disposal of Contaminated Soil Posing a Direct Exposure Contact Risk (Exceeding Commercial Industrial CTLs) and a Risk to Groundwater via Leacliing (Exceeding Leachabilitx CTLs) 33 9.1.5 Soil .Alternative SS-5: Removal Of PTW: Excavation and Off-Site Disposal ofHot Spot Soil: Installation of Low-PeiTneabilit> Cap: ICs 34 9.1.6 Soil .Alternative SS-6: Removal of PTW: Excavation of Hot Spot Soil: Ex-Situ Stabilization On-Site Consolidation: Installation of Low-Permeabilit> Cap: ICs 35 9.1.7 Soil .Alternative SS-7: Removal of PTW: In-Situ Stabilization Solidification of Hot Spot Soil: Installation of Low-PeiTneabilit> Cap: ICs 36 9.2 Sediment .Alternatives SD-1 To SD-5 37 9.2.1 Sediment .Alternative SD-1: No .Action 37
vn 9.2.2 Sediment .Alternative SD-2: Sediment Dredging and Off-Site Disposal 37 9.2.3 Sediment .Alternative SD-3: Sediment Dredging and On-Site Disposal 38 9.2.4 Sediment .Alternative SD-4: Sediment Capping: ICs 38 9.2.5 Sediment .Alternative SD-5: Environmental Bulkhead Construction: ICs 39 9.3 Groundwater .Alternatives G\V-1 To G\V-9 39 9.3.1 Groundwater .Alternative GW -I: No .Action 39 9.3.2 Groundwater .Alternative GW -2: MN.A LTM: ICs 40 9.3.3 Groundwater .Alternative GW -3: In-Situ Treatment of Groundwater Losing ZA'I: MN.A LTM: ICs 40 9.3.4 Groundwater .Alternative GW -4: In-Situ Chemical Oxidation: MN.A LTM: ICs 41 9.3.5 Groundwater .Alternative GW -5: PeiTneable Reactive Banier: MN.A LTM: ICs 42 9.3.6 Groundwater .Alternative GW -6: Cut-Off Wall with P&T for Containment: MN.A LTM: ICs 43 9.3.7 Groundwater .Alternative GW -7: In-Situ Stabilization Solidification of Groundwater: MN.A LTM: ICs .44 9.3.8 Groundwater .Alternative GW -8: Hvdraulic Containment bv P&T: ICs 45 9.3.9 Groundwater .Alternative GW -9: Groundwater P&T: MN.A LTM: ICs 45
10.0 Summary Of Comparative .Analysis Of .Alternatives 47 10.1 Tlueshold Criteria 47 10.LI Overall Protection of Human Health and the Environment 47 10.1.2 Compliance with .Applicable or Relevant and .Appropriate Requirements 48 10.2 Balancing Criteria 49 10.2.1 Long-TeiTn Effectiveness and PeiTnanence 49 10.2.2 Reducing Toxicitx. Mobilitx or A'olume Tluough Treatment 50 10.2.3 Shoi1-TeiTn Effectiveness 51 10.2.4 Implementabilitx 51 10.2.5 Cost 52 10.2.6 Modifx ing Criteria 53
11.0 Principal Threat Waste 55
12.0 Summary Of Selected Remedy 56 12.1 Selected Remedy 56 12.2 Rationale for the Selected Remedv 57
vin 12.3 Selected Remedy Cost 57 12.4 Expected Outcomes of Selected Remedy 58
13.0 Statutory Determinations 59 13.1 Protection Of Human Health and the Environment 59 13.2 Compliance with ARARs 59 13.3 Cost Effectiveness 60 13.4 PeiTnanent and .Alternative Treatment Solutions 60 13.5 Preference for Treatment as a Principal Element 61 13.6 Five-A'ear Review Requirements 61
14.0 Documentation of Significant Changes 62
PART III RESPONSIVENESS SLTVIMARV
References
List of Exhibits
Exliibit 1 Overall Summaiy of Potential Risks and Hazards for COPCs
Exliibit 2 Baseline Ecological Risk .Assessment Summaiy
Exliibit 3 Present \\"oilh Costs for Soil .Alternatives
Exliibit 4 Present \\"oilh Costs for Sediment .Alternatives
Exliibit 5 Present \\"oilh Costs for Groundwater .Alternatives
IX List of Tables
Tab e 7-1 Chemicals of Concern Summaiy Table
Tab e 7-2 Exposure Point Concentration Summan for Cunent Future Scenario in Surface Soil
Tab e 7-3 Exposure Point Concentration Summan for Future Scenario in Subsuiface Soil
Tab e 7-4 Exposure Point Concentration Summan for Cunent Future Scenario in Groundwater
Tab e 7-5 Exposure Point Concentration Summan for Fish Tissue (via Sediment)
Tab e 7-6 Cancer Toxicitx Data - Oral Dermal
Tab e 7-7 Cancer Toxicitx Data - Inlialation
Tab e 7-8 Non-Cancer Toxicitx Data - Oral Dermal
Tab e 7-9 Non-Cancer Toxicitx Data - Inlialation
Tab e 7-10 Summan of Receptor Risks and Hazards for COPCs - Current Maintenance Worker
Tab e 7-11 Summan of Receptor Risks and Hazards for COPCs - Cun ent Trespasser
Tab e 7-12 Summan of Receptor Risks and Hazards for COPCs - Current Off-Site Resident Adult
Tab e 7-13 Summan of Receptor Risks and Hazards for COPCs - Cun ent Off-Site Resident Cliild
Tab e 7-14 Summan of Receptor Risks and Hazards for COPCs - Future Industrial Worker
Tab e 7-15 Summan of Receptor Risks and Hazards for COPCs - Future Constmction Worker
Tab e 7-16 Summan of Receptor Risks and Hazards for C(!)PCs - Future Adult Groundw ater User
Tab e 7-17 Summan of Receptor Risks and Hazards for C(!)PCs - Future Cliild Groundw ater Use
Tab e 7-18 Adult Fead Methodology Modeling Results
Tab e 7-19 Chemicals of Ecological Concern and Risk Calculation for the Green Heron (St. Jolins River)
Tab e 7-20 Chemicals of Ecological Concern and Risk Calculation for the Raccoon (St. Jolins River)
Tab e 7-21 Chemicals of Ecological Concern and Risk Calculation for the .American Robin
Tab e 7-22 Chemicals of Ecological Concern and Risk Calculation for the Feast Slu ew
Tab e 7-23 Chemicals of Ecological Concern and Risk Calculation for Piscivorous Fish (St. Jolins River)
Tab e 8-1 Suiface Soil Remedial Cleanup Fevels List of Tables (Continued)
Table 8-2 Subsurface Soil Remedial Cleanup Levels
Table 8-3 Groundwater Remedial Cleanup Levels
Table 8-4 Sediment Remedial Cleanup Levels
Table 8-5 Suiface Water Remedial Cleanup Levels
Table 8-6 Chemical-Specific ARARs
Table 8-7 Location-Specific ARARs
Table 8-8 Action-Specific .\RARs
Table 10-1 Comparative Analysis of Remedial Alternatives
Table 12-1 Selected Remedv Cost Estimate
List of Figures
Figure 1-1 Site Location Map
Figure 1-2 Site Map with Former Features
Figure 5-1 Conceptualized Site Cross Section
Figure 5-2 Shallow Zone Potentiometric Suiface Map - August 2015
Figure 5-3 Intermediate Zone Potentiometric Suiface Map - August 2015
Figure 5-4 Approximate Extent of Surface Soil with C(!)C Concentrations Exceeding Commercial Industrial CTLs
Figure 5-5 Approximate Extent of Subsuiface Soil with C(!)C Concentrations Exceeding Commercial Industrial CTLs
Figure 5-6 Approximate Extent of Soil with C(!)C Concentrations Exceeding Commercial Industrial CTLs
Figure 5-7 Approximate Extent of Soil with C(!)C Concentrations Exceeding Leachabilitx CTLs
Figure 5-8 Alpha-BHC Concentrations in the Shallow Groundwater Zone
Figure 5-9 Alpha-BHC Concentrations in the Inteimediate Groundwater Zone
Figure 5-10 Approximate Extent of Contaminated Sediment
XI List of Figures (Continued)
Figure 7-1 Human Health Conceptual Site Exposure Model
Figure 7-2 Ecological Conceptual Site Exposure Model
Figure 12-1 Conceptual Layout of Selected Remedy
List of Appendices
Appendix A Responses to Comments
Appendix B Proposed Plan Public Meeting Transcript
xn List of Acronyms and Abbreviations
AECOM AECOM Teclinical Seivices. Inc. AR Administrative Record ARARs Applicable or Relevant and Appropriate Regulations AR(;)D R(;)D Amendment ATSDR Agency for Toxic Substances and Disease Registn BERA Baseline Ecological Risk Assessment BHC Benzene Hexacliloride bis below land suiface CERCLA Comprehensive Environmental Response. Compensation, and Liabilitx Act of 1980 CFR Code of Federal Regulations CIP Community Involvement Plan C(!)C Chemical of Concern COPC Chemical of Potential Concern COPEC Chemical of Potential Ecological Concern CSEM Conceptual Site Exposure Model CSF Cancer Slope Factor CSX CSX Transpoilation CTLs Cleanup Target Levels ODD Diclilorodiphen\ldicliloroethane DDE Diclilorodiphen\ldicliloroeth\ lene DDT Diclilorodiphen\ltrichloroethane EPA United States Environmental Protection Agenc\ EPCs Exposure Point Concentrations ESD Explanation of Significant Differences ES\'s Ecological Screening \'alues F.A.C. Florida Administrative Code FASCO Florida Agricultural Supply Company FDEP Florida Department of Environmental Protection FDOH Florida Department of Health FS Feasibilitx Study GCTL Groundwater Cleanup Target Level gpm gallons per minute GW" Groundwater HHRA Human Health Risk Assessment HI Hazard Index HQ Hazard Quotient ICs Institutional Controls lELfBK Integrated Exposure Uptake Biokinetic ISCO In-Situ Chemical Oxidation ISS In-Situ Stabilization Solidification .TAXP(9RT .Tacksonville Port Authoritx Kerr-McGee Kerr-McGee Chemical Coiporation LDRs Land-Disposal Restrictions LTM Long-Tenri Monitoring MCE Maximum Contaminant Level mg kg milligrams per kilogram mg L milligrams per liter MNA Monitored Natural Attenuation
xm List of Acronyms and Abbreviations (Continued)
M\V Monitoring Well NCP National Contingency Plan NPDES National Pollutant Discharge Elimination System NPL National Priorities List O&M Operation and Maintenance OU (!)perable Unit P&T Pump and Treat PCBs Polychlorinated Biphenyls pCi g picocuries per gram POTW PublicK -(!)wned Treatment Works PRB Permeable Reactive Banier PRP Potentially Responsible Part> PTW Principal Tlireat Waste RAOs Remedial Action (!)biectives RCRA Resource Conseivation and Recoveiv Act RfCs Reference Concentrations RfDs Reference Doses RI Remedial Investigation RI FS Remedial Investigation Eeasibilitx Study RME Reasonable Maximum Exposure ROD Record of Decision SARA Supeiiund Amendments and Reauthorization Act Site Ken-McGce Chemical Coiporation Supeiiund Site S\"OCs Semi-\'olatile Organic Compounds TBC To Be Considered TCE Tricliloroethene TENORM Teclinically Enlianced Naturally Occurring Radioactive Material Tronox Tronox Incoiporated TR\"s Toxicitx Reference \'alues Pg tlL micrograms per deciliter Pg micrograms per kilogram PgL micrograms per liter nc Underground Injection Control \ "OCs \'olatile Organic Compounds Z\I Zero-\'alent Iron
\1V RECORD OF DECISION PART II Decision Summary 1.0 Site Location and Description
Tliis Record of Decision (ROD) is for Operable Unit 1 (OUl) of the Ken-McGee Chemical Corporation (Ken-McGee) Supeiiund Site (Site) located in Jacksonville. Duval Count>. Florida. The Site is located at 1611 Talleyrand Avenue in .Tacksonville. Duval Count> . Florida (Figure 1-1) and the geograpliic coordinates are 30° 20"35.3455"N. 81° 37"31.8818"\V.
The 31-acre Site is situated on the west bank of the St. Jolins River in the predominanth industrial port area of Jacksonville. The Site is bordered to the north In the Jacksonville Port .Authority (J.AXP(!)RT) propei1> (cunently leased by .TM Family Enteiprises. Inc. Southeast Toyota Distributors (.fNIFE) for staging and distributing automobiles), to the south In a wooded, undeveloped propeit> owned In CSX Transportation (CSX), to the west In Talle\ rand .Avenue, and to the east b\ the St. Jolins River (Figure 1- 2). Currenth . the Site is unoccupied, undeveloped, and covered with low vegetation, with a small grove of trees on the east-central portion of the Site. Foundations and slabs of four former buildings (Florida .Agricultural Supply Company [F.ASCO]. herbicide, sulfur grinding, and the macliine shop) are located in the northern and eastern portions of the propert> . The Site perimeter is enclosed with a 6-foot chain-link fence to prevent unauthorized access.
The United States Environmental Protection .Agency (EP.A) is the lead agency for the Site, and the Florida Department of Environmental Protection (FDEP) is the supporting agency. The EP.A Site Identification Number is FLD039049I0I. The Site is listed on the National Priorities List (NPL). Site remediation will be conducted and funded by the Greenfield Environmental Multistate Tmst LLC. not individually but solely in its representative capacity as Tmstee of the Multistate Environmental Response Trust (the Multistate Tmst). as specified in the Tronox Incoiporated (Tronox) bankmptcy settlement agreement. 2.0 Site Histon and Enforcement Activities
2.1 Histon of Site Operations
The propei1> was used for the manufacturing of various feililizers and pesticides herbicides for 85 \ ears. The first recorded owner of the propeit> was W ilson and Toomer Compan\. a manufacturer of feililizers (1893). Pesticide fonnulation operations were added in the 1950s. In the late 1950s, the propeit> was sold to Plymouth Cordage wliich operated the facilit> until it was sold to the Emhail Coiporation in 1965. Emliail sold the plant to Ken-McGee in 1970. and Ken-McGee continued the manufacturing and formulation operations until 1978. Numerous chemicals were used or produced in the manufacturing process, including organoclilorine pesticides (pesticides), metals, sulfuric acid, and volatile organic compounds (\'(!)Cs). wliich contaminated on- and off-propert> soil and groundwater, as well as sediment and suiface water in the St. .Johns River and Deer Creek.
The pesticide plant operations consisted of foimulation. blending, and distribution. The fertilizer portion of the facilit> manufactured supeiphosphate and both standard grade and specialt> grade nitrogen, phosphate, and potash agricultural fertilizers. The sulfuric acid that was used in the manufacture of the supeiphosphate was produced on-site in the acid plant. GeneralK. raw materials and finished products for the pesticide and fertilizer operations were stored in warehouses. Dmms containing pesticide products w ere temporarih stored east of the foimer office building (Figure 1-2). Ken -McGee conducted dmm reconditioning at a location south of the pesticide storage warehouse. Residual pesticide w astes were rec\ cled reclaimed when possible. The remaining waste materials were containerized and transported off- site for disposal.
.As reported in the remedial investigation (Rl) report (Shaw Environmental. Inc. [Shaw]. 2006a). a suiface impoundment, approximately 75 feet by 100 feet, w as located north of the F.ASCO building and seived as a holding pond to contain wash-down water and spills from the buildings used for pesticide and herbicide formulating and packaging. W astewater (process water and wash water generated during nighth equipment cleaning) was also directed to the suiface impoundment. In addition, the suiface impoundment reportedh received discharges of product formulation residues from the pesticide and herbicide buildings.
In the earh 1940s (Shaw. 2006a). an area of the northeastern portion of the Site was bermed and used as a dredge fill area to div the sediment dredged from the St. .Tolins River around the former docks associated with the facilitx. Tlie dredge fill area and the surface impoundment have been filled and are now overgrown with grass and weeds.
.A small area of the north-central portion of the Site was reportedh used as a bum area (Figure 1-2). The alleged burn pit was used to bum the facilitx "s excess papers. Tliis area was excavated and backfilled in .July 1996. One of the reports suggested the pit measured approximately 4.650 square feet (ft").
W hen Ken-McGee operated the facilitx . there were tluee discharge points into the St. .Tolins River. Outfalls 001 and 002 (Figure 1-2) and a 24-inch diameter concrete culvert pipe in the central area of the Site. StoiTnwater mnoff from the fertilizer plant and scmbber water from supeiphosphate manufacturing and granular production was discharged tluough Outfall 001 (Burlington Environmental. Inc.. 1993). In addition to stoimwater from the pesticide plant, sanitaiv wastewater from both the F.ASC(!) plant and the fertilizer plant and non-contact cooling water from the acid plant were discharged tluough (!)utfall 002. The facilitx was issued a National Pollutant Discharge Elimination System (NPDES) pemiit and a temporaiv discharge peimit in September 1974 and .April 1976. respectiveh. In the Florida Department of Environmental Regulation (FDER) for the discharge of w astew ater from the supeiphosphate scmbbers. As discussed previously, manufacturing operations at the Site ceased in 1978. All aboveground stmctures were subsequenth demolished, except for the foundations and slabs of four foiTner buildings (FASC(!). herbicide, sulfur grinding, and the machine shop) located in the northern and eastern portions of the propei1> . Tlie propei1> is cunenth undeveloped and unoccupied. .A 6-foot liigh chain-link fence prevents unauthorized access.
2.2 Eiiforceiiieiit -\cti\ ities
In March 2000. EP.A assumed lead responsibilitx for the Site under an .Administrative Order on Consent .Agreement with Ken-McGee. the Potentially Responsible Paitx (PRP) to conduct a RI and Feasibilitx Stud\ (FS) for the Site under EP.A Region 4 Supeiiund .Alternative .Approach. In 2005. Tronox Incoiporated (Tronox). a successor to Ken-McGee. was created and Kerr-McGee transfened all of its contaminated sites into Tronox without the necessaiy funding to peifoiTn the environmental cleanups. Unable to finance its environmental liabilities. Tronox. a PRP. filed for bankmptcy in .Tanuaiy 2009. In March 2010. the EP.A added the Site to the NPL.
In Febmaiy 2011. Tronox entered into an agreement wherein, the Multistate Environmental Response Tmst (Multistate Tmst) was created for the puipose of taking ow nership of the former Tronox properties, managing the cleanup funds, cleaning up sites using available funds, and facilitating safe redevelopment and long-teiTn stew ardsliip of the sites. For the Ken -McGee Site in .Tacksonville. Florida, the Multistate Tmst has a fiduciaiy dutx to the tw o Site beneficiaries - the United States and the State of Florida, represented b\ EP.A and the FDEP. respectiveh . The Multistate Tmst funds can onl\ be used for Site cleanup activities that are approved In EP.A in consultation with FDEP. 3.0 Community Participation
The Communis Involvement Plan (CIP) for the Site was developed and approved in March 2000. EPA implemented the plan by involving the communit> in work being conducted at the Site. EP.A issued fact sheets and letters, communicated tluough paid, published notices in the largest local daih newspaper {The Florida Times-Union), and held public availabilit> sessions to ensure the public was infoiTned and allowed to participate in the process. Tlie following summarizes the major communit> relations activities:
• March 2000 - EP.A approved the Final CIP. The plan was placed in the public libraiv repositoiv. The ke\ objectives of the CIP include coordinating with a local nonprofit organization on Site infoiTnation. actively engaging communit> stakeholders, and encouraging public participation.
• October 2000 - EP.A and Tronox conducted a Remedial Investigation Feasibilitx Study (RI FS) Kick-Off Meeting with the community to discuss the activities that would occur under the RI FS.
• March 2001 - EP.A issued an RI FS Fact Sheet to update the community on the progress of the RI FS.
• March 2002 - EP.A issued an RI FS Fact Sheet to further update the community on the progress oftheRIFS.
• March 2002 - EP.A conducted a public meeting to update the communitx on the progress of the RI FS and address communitx concerns.
• .Tanuaiy 2003 - Florida Department of Health (FDOH) and the .Agency for Toxic Substances and Disease Registiy (.ATSDR) issued a Public Health .Assessment for the Site.
• Febmaiy 2003 - FDOH conducted a public meeting to infoiTn the community of the findings of the Public Health .Assessment.
• November 2003 - EP.A issued an Updated RI FS Fact Sheet summarizing the status and progress oftheRI FS.
• .Tanuaiy 2004 - EP.A and Fresh Ministries conducted a public meeting to discuss the status of the RI FS and to address the community "s questions and concerns.
• The RI FS Report and Proposed Plan for the Site were made available to the public in .Tune 2008. The notice of the availabilitx' of these documents was published in The Florida Times-Union on .Tune 26. 2008. .A public meeting was held on .Tune 30. 2008 to present the Proposed Plan to the local communitx . .An initial public comment period was held from .Tune 16. 2008 to .Tuly 16. 2008 and then extended to .August 27. 2008. EP.A considered the comments received during tliis public comment period, and these comments were addressed in the Final FS for the Site issued in .August 2016 and in the 2016 version of the Proposed Plan.
• November 2008 - EP.A met with the Citizens Planning .Advisoiy Committee of .Tacksonville.
• .April 2010 - EP.A issued a fact sheet that included an update on the Site status following the listing of the Site on the NPF. • March 2011 - EPA issued a fact sheet that included an update on the Site status and involvement of the Multistate Tmst. EPA and the Multistate Trust hosted a meeting on March 16. 2011 to update the community on the status of the project.
• A public meeting in August 2011 provided information regarding the cun ent status of the cleanup and solicited public comments regarding prefened future use alternatives. Stakeholders at the meeting identified preliminaiy goals that included the following: generate funding to support Site cleanup, increase jobs and tax base, provide a local economic communitx benefit, and provide public access to the water or other community benefit.
• Since 2011. EP.A and the Multistate Tmst have maintained frequent contact with and met periodically with several key stakeholders including the Eastside Environmental Council. .T.AXPORT. .TM Family Enterprises. Inc.. the FDOH. and the St. .Johns River Water Management District (S.TRWMD).
• May 2012 - EP.A met with community leaders to discuss the status of the revised FS report.
• May 2014 - EP.A and the Multistate Trust issued a Fact Sheet updating the public on the status of the Site activities.
• .July 2015 - EP.A and the Multistate Trust issued a Fact Sheet updating the public on the status of the Site activities.
• In September 2016. EP.A issued the Proposed Plan. The notice of availabilitx of the documents was published in The Florida Times-Union on September 12. 2016. .A public meeting was held on September 28. 2016 to present the Proposed Plan to the local community . During the meeting. EP.A and Multistate Tmst representatives answered questions about the Site and the prefened remedial alternatives. .An initial Public Comment Period was held from September 12. 2016 to October 12. 2016. .After an extension was requested, the comment period was extended to November 11. 2016. .A notice of the extended comment period was published in The Florida Times-Union on October 21. 2016. EP.A's responses to the comments received during this Public Comment Period are included in .Appendix .A of tliis R(!)D.
The documents mentioned previoush can be found in the .Administrative Record (.AR) file and the infoiTnation repositoiy located at the EP.A Region 4 Records Center and the .Jacksonville Public Libraiy. Brown Eastside Branch. 1390 Hanison Street. .Jacksonville. Florida. 4.0 Scope and Role of Response Action
The EPA often divides large and complicated sites into separate OUs to facilitate and manage investigations and cleanups. For tliis Site. EPA has organized the work into t\vo (!)Us:
• Operable Unit 1: Contamination of Site soil and groundwater, as w ell as sediment and suiface water in the St. .Tohns River. GUI also addresses contaminated soil and groundwater associated with historic Site operations but located on the CSX and .T.AXP(!)RT properties.
• Operable Unit 2: Site-related sediment and suiface water contamination in Deer Creek.
The (!)U1 remed\. which is the subject of tliis R(!)D. will address contaminated soil and suificial aquifer groundwater (on-propeit> and off-propeit> ). wliich under Florida's regulations, is classified as a potential source of drinking water (G-II). Tlie (!)U1 remed\ will also address sediment and suiface water contamination in the St. .Tolins River. The puipose of this action for (!)U1 is to prevent cun ent and or future exposure to soil, sediment, groundwater, and suiface water contamination that pose an unacceptable risk to human and ecological receptors. The (!)U1 R(!)D will be implemented pursuant to the remedial authorities of the Comprehensive Environmental Response. Compensation, and Liabilitx .Act of 1980 (CERCL.A). and will be the final response for tliis OU.
OU2 will be addressed separately, as additional infoiTnation is necessaiy to complete the assessment of the contamination in Deer Creek. Dividing the Site into separate OUs allows the EP.A to address the impacted soil, groundwater, and sediment in the St. .Tolins River in a timeh manner, wliich will in turn facilitate and expedite the propeitx disposition and redevelopment. 5.0 Site Characteristics
BeUveen 1984 and 2015. extensive soil and groundwater sampling was conducted at the Site and adjacent properties. Sediment, pore water, and suiface water samples were collected from the St. .Johns River and Deer Creek. Laboratoiy analysis confmned that numerous chemicals used or produced at the Site, including pesticides, metals, sulfuric acid, and \ DCs. had contaminated Site soil and groundwater, as well as sediment and surface water in the St. .Tolins River and Deer Creek. The investigation analytical results are presented in the Final Remedial Investigation Report (Shaw. 2006). PCB Investigation and Delineation Report 2007). Pore Water and Sediment Sampling Report 2008a). and the Additional Sediment Sampling Report (ENSR. 2008b). The infoiTnation presented below is a summaiv' of the data presented in these reports.
5.1 Site Setting and Topography
The Site occupies approximately 31 acres in a heavily industrialized port area of Duval Countx. witliin the citx limits of .Jacksonville. Florida. Tlie eastern end of the Site is bounded by the St. .Johns River and the western end In Tallex rand .Avenue. The propeilx to the north is owned In .J.AXP(!)RT and is cunenth leased In .JAIFE for staging and distributing new automobiles. The propeilx to the south is an undeveloped w ooded strip of land (approximateh 8 acres) ow ned In CSX. Deer Creek is located to the south of the Site and flow s tlu ough the CSX propeilx .
The Site lies at an elevation of 2 feet to 16 feet above mean sea level, with the highest elevations present along the northern and southern boundaries. Tlie land cunenth slopes from the northern and southern boundaries tow ard a sw ale that mns nearh the entire length and tlu ough the middle of the Site in an east- west direction. The Site drops off about 6 feet to 7 feet to the river along the far eastern side of the Site. StoiTnwater mnoff from the Site appears to collect in the swale in the central portion of the Site and drains east toward the St. .Joluis River. Tlie Site ground cover consists of grassx areas, with a small grove of trees in the east-central portion of the Site. Foundations and slabs of four fonuer buildings (F.ASCO. herbicide, sulfur grinding, and the macliine shop) are located in the northern and eastern portions of the propeilx.
5.2 Surface \\ ater Hydrology
Based on a review of the United States Geological Suivex' '.5 Minute Topographic Quadrangles for Arlington and Jacksonville. Florida (United States Geological Suivex'. 1981 and 1993). suiface drainage in the general vicinitx of the Site is to the east and south, tow ard Deer Creek and the St. .Jolins River. .As previoush discussed, txvo outfalls were identified as releasing mnoff from the Site to the St. .Jolins River. Outfall 001 (see Figure 1-2) was located at the end of a drainage ditch that foiTnerly ran parallel to the southern wall of the fertilizer building. The ditch was filled in 1978 during Site demolition activities. Outfall 002 (see Figure 1-2) w as located at the northeastern corner of the Site, and w as believed to collect suiface w ater mnoff from the northern end of the Site.
The majoritx of the Site is witliin the 500-year floodplain (Ecology & Environment. Inc. [F&F]. 1999). The southern and eastern portions of the Site are w itliin the 100-\ ear floodplain.
The St. .Jolins River, bordering the Site to the east, is tidalh influenced but generalK flows to the north. Daily w ater level fluctuation of 2 feet to 2.5 feet w as obseived in the vicinitx of the Site during the R1 (Shaw. 2006). Suiface water in the St. .Jolins River and in the lower reaches of Deer Creek is distinctly brackish (Shaw. 2005c). Deer Creek, a minor tributan of the St. .Tolins River, mns tlu ough the CSX propei1> to the south of the Site. Tlie creek drains an industrial area beginning west of the 20th Street Expressw a\ bet\veen 8th Street on the north and the Mathew s Bridge on the south. Deer Creek is tidalh influenced in the vicinit> of the Site. The National Wetlands Inventoiy (U.S. Fish and Wildlife Seivice. 2016) indicates the presence of wetlands along Deer Creek. .A small section of these wetlands extends onto the Site at its southeast comer adjacent to the St. .Tolins River.
5.3 Site Geolog}
The Site geolog\ was investigated to a depth of 75 feet below land surface (bis) during the RI. Tluee contrasting lithologies were obseived tluoughout the Site: elastics near the suiface underlain, in turn. b\ limestone, and a phosphatic calcareous silt.
The most common litholog\ obseived in the upper soils (elastics) was fine-grained sand, wliich ranged in color from tan to dark brown. In some locations, especialh along the southern boundaiv. this sand was mixed with concrete, bricks, lime rock, or organic debris. Peat was obseived in the shallow subsurface near the w estern end of the Site, and cla\ lenses less than 4 feet tliick w ere scattered tlu oughout the area of investigation.
.A \ ellow -brow n-gra\ friable (upper) limestone underlies the sand unit, the top of w liich w as encountered at an average depth of 35 feet bis. Tlie upper limestone unit is betiveen 2 feet and 8 feet tliick and is interbedded w ith cla\ in the northw estern portion of the Site.
.Across the Site, the upper limestone unit is underlain In hard. green-gra\ silt with abundant phosphate nodules t> pical of the upper portion of the Haw thorne Group. Tliis silt is interbedded with tliin limestone and sand beds to a depth of at least 75 feet.
Figure 5-1 presents a conceptual cross-sectional sketch of the Site geology.
5.4 Site Hydrogeolog}
Tluee principal hydrogeologic units underlie the Site vicinitx : the suiTicial aquifer system, the inteiTnediate aquifer s\ stem, and the Floridan aquifer s\ stem. These units correspond respectiveh with the upper Miocene to Recent sediments, the Hawthorne Group, and the (!)cala Fimestone .Avon Park Fimestone Lake Citx Limestone geologic foirnations.
The surficial aquifer is comprised of unconsolidated elastics and partly consolidated carbonates. Tlie aquifer is characterized In thin peirneable zones interla\ ered with tliin confining units. The peirneable zones are generalh comprised of porous limestones or unconsolidated sands, and the confining units are comprised of cla\ e\ sand or sand\ cla\.
The inteiTnediate aquifer occurs in more peirneable units of the Haw thorne Group. In the vicinitx of the Site, the Hawthorne Group is approximately 400 feet tliick (Scott. 1988). Tlie fine-grained clastic portions of the Haw thorne Group seive as a confining unit betw een the suificial aquifer and the underh ing Floridan .Aquifer (Leve. 1966). w liich is a ma jor drinking w ater source in the state of Florida.
Groundwater in the surficial aquifer occurs under unconfmed conditions and is present in three primaiv. water-bearing zones (shallow. inteiTnediate. and deep). Tlie shallow zone extends from the water table (2 feet to 10 feet bis) to the top of the limestone unit at an average depth of 35 feet bis. Tlie inteiTnediate zone is present from the top of the limestone to a depth of about 45 feet bis. Tlie deep zone consists of sand and tliin limestone beds that extend from the bottom of the limestone (approximately 45 feet bis) to the depth of investigation at 75 feet bis. Although hydraulic conductivity is variable witliin each zone, the three zones are generally hy draulically connected. Figures 5-2 and 5-3 present the potentiometric suiface maps for shallow and inteiTnediate zones, respectively.
Groundwater elevation measurements collected during the RI. and during the 2015 groundwater sampling event, indicated that groundwater in the shallow and intermediate zones generally flows to the east, toward the St. .Johns River, and south, toward Deer Creek. In the deep zone, the groundwater primarily flows to the north towards the .T.AXP(!)RT propeily . Hy draulic conductivities ranging from 42 feet to 86 feet per day w ere estimated based on results of slug and pumping tests conducted from monitoring w ells installed within the deep zone (45 feet to 75 feet bis).
Groundwater pumping tests conducted during the RI showed a slight downward vertical gradient bet\veen the shallow and inteiTnediate zones of the suiiicial aquifer. How ever, a strong upw ard gradient w as obseived bet\veen the intermediate and deep zones, and the difference in groundwater flow direction indicates the presence of an effective confining unit between the upper limestone unit and the calcareous silt.
5.5 Nature and Extent of C'ontaniination
From 1984 to 2015. RI activities were conducted at the Site and at the .T.AXPORT and CSX properties. During these investigations, test pits were excavated, soil borings were advanced, and groundwater monitoring wells were installed throughout the Site. .Aquifer performance testing and well suivey s (inventoiy ) were also conducted. .Approximately 280 soil samples. 43 sediment samples (several with associated pore water and surface water samples) and groundwater samples from 60 locations were collected and analyzed to define the nature and extent of contamination.
.Analytical results of the collected samples identified the presence of various Site-related chemicals including pesticides. A DCs. semi-volatile organic compounds (SA DCs), polyclilorinated biphenyls (PCBs). radionuclides, and metals in the soil, groundwater, sediment, pore water, and surface water samples at concentrations above the federal Maximum Contaminant Levels (MCLs). Baseline Ecological Risk .Assessment (BER.A) identified sediment Ecological Screening A alues (ESA s). FDEP Soil Cleanup Target Levels (CTLs) and Groundwater Cleanup Target Levels (GCTLs). and FDEP Surface Water Quality Criteria (SWQC). .A summaiy of the data collected during these investigations is presented in the following subsections.
5.5.1 Source-Areas
Source .Areas are areas where contaminants act as a "source" for direct exposure to human or ecological receptors and or as a "reseiv oir" or "source" of contaminant migration to groundw ater, surface w ater and or air. Source .Areas identified at the Site include:
• The scmbber sludge pile, due to potential radiologic hazards, and the former surface impoundment, wliich contains soil and a green sludge with veiy high concentrations of pesticides:
• Surface and subsurface soil liiglily contaminated with pesticides and metals that are concentrated in the vicinity of the foiTner F.ASCO. herbicide and sulfur grinding buildings, as w ell as in the former acid plant area on the eastern side of the Site: and
• The foiTner burn area located in the north-central area of the Site. Pesticides and metals exceeding their respective Leachabilitx Based on Groundwater Criteria (Chapter 62-777. Florida Administrative Code [F.A.C.]. Contaminant Cleanup Target Levels) were generally detected tluoughout the Site in the suiface and subsuiface soil. "Flot spots" as potential continuing sources of groundw ater contamination w ere identified using soil concentrations that exceeded values of 100 times the FDEP default leachabilitx -based criterion for pesticides and 10 times the FDEP default leachabilitx -based criterion for metals. Tliese areas are primarily in the vicinitx of the former F.ASCO. herbicide and sulfur grinding buildings, the foiTner acid plant on the eastern side of the Site, and the former bum area located in the noilh-central portion of the Site. Contaminated soil in the source areas up to 5 feet bis is estimated to comprise approximately 31.550 cubic yards.
5.5.2 Prmcipal Threat \\ aste
Principal Tlueat W aste (PTW ) is source material considered to be liiglil\ toxic or highh mobile and that generalK cannot be reliabh contained and or. in the event of exposure, w ould pose a significant risk to human health or the environment, should exposure occur. Two limited areas of PTW" were identified in the RI FS. These include the aforementioned scmbber sludge pile (about 1.400 cubic yards) located on the southeast comer of the propei1> because of potential radiologic hazard to human health and the environment: and green sludge material (1.350 cubic yards) in the suiface impoundment because of its potential mobilitx . These areas are discussed in more detail in Section 11.
5.5.3 Suiface Soil
During the RI. soil samples were collected at various depths and were grouped into two categories: suiface (0 to 1 feet bis) and subsuiface (greater than 1 feet bis). It should be noted that when developing costs in the FS report, suiface soil was characterized as soils ranging from the ground surface to a depth of 2 feet bis (as opposed to I foot bis used in the RI). Subsurface soil was identified as unsaturated soils at depths ranging from 2 feet bis to the water table (approximateh 8 feet bis).
The collected soil samples were analyzed for pesticides, metals. PCBs. dioxin. and radionuclides. Numerous chemical contaminants were identified in Site soils, but the primaiy contaminants included benzene hexacliloride isomers (BHCs). dichlorodiphenyldicliloroethane (ODD). dichlorodiphen\ ltrichloroethane (DDT), chlordane. and arsenic.
Suificial pesticide contamination is present across most of the Site, and extends onto the .T.AXPORT propei1> to the north: concentrations of these contaminants on the .T.AXP(!)RT propeitx w ere onl\ slightK above their respective Direct Exposure Commercial Industrial CTLs (Chapter 62-777. F..A.C.). Pesticide concentrations were detected above leachabilitx criteria across the Site.
The liighest concentrations of pesticide contaminants included alpha-BHC (920 milligrams per kilogram: mg kg). beta-BHC (320 mg kg). gamma-BHC (130 mg kg), and DDT (1.100 mg kg) wliich were detected in boring SB-8-0 under the slab of the foiTner herbicide building. The liighest concentrations of DDD (250 mg kg) were obseived in soil samples collected from SB-5-0 located at the north-central edge of the Site. These concentrations are one to tluee orders of magnitude above the screening levels. (!)ther pesticides, including aldrin. dieldrin. heptachlor. and toxaphene. were also detected in surface soil at concentrations above the screening criteria.
The maximum arsenic concentrations (5.100 mg kg) were detected in soil sample SB-2-0 collected from the northw estern comer of the Site. These concentrations are tw o orders of magnitude above the 12 mg kg screening level for this chemical. .Arsenic impacts were also located in the northern edge, southwestern comer, and northwestem comer of the Site, to the north of the fomier F.ASC(!) building, and under the former herbicide buildins slab.
10 PCBs (Aroclor 1254: maximum concentrations 12 mg kg) were also found at a limited area adjacent to the former Power House and Locker Room in the middle of the Site. These concentrations are above the 2.6 mg kg screening level for this compound.
Results of the radionuclide investigation indicated that maximum concentrations for radium-226 [50.6 picocuries per gram (pCi g)] and uranium-238 (51.5 pCi g) were detected in sample RD-13 near the central portion of the scrubber sludge pile area.
Figure 5-4 presents the horizontal extent of contaminated suiface soil above commercial industrial CTLs for pesticides and metals. The total volume of suiface soil exceeding the commercial industrial CTLs is estimated to be approximately 28.000 cubic yards.
5.5.4 Subsuiface Soil
The liighest concentrations of pesticides in subsurface soil generalK occur around the edges of the former suiface impoundment. bet\veen the foimer F.ASC(!) building and the northern Site boundaiv. under the former herbicide building, and to the south of the foimer F.ASC(!) building to the former pesticide storage warehouse. The maximum concentrations of alpha-BHC (4.300 mg kg) and beta-BHC (1.300 mg kg) w ere detected in sample SB-8-2 located under the slab of the foimer herbicide building. Gamma-BHC (1.800 mg kg) and DDT (12.000 mg kg) were detected at a maximum concentration in sample SB-52-6. collected from the northw estern comer of the foimer suiface impoundment. The maximum DDD concentration in subsuiface soil w as found in the northern edge of the foimer surface impoundment at 5.100 mg kg. Other pesticides, including aldrin. diclilorodiphenyldichloroethylene (DDE), dieldrin. endosulfan 1. and toxaphene. were also detected in subsuiface soils. Pesticides were detected in subsuiface soil up to t\vo orders of magnitude above screening levels.
The maximum arsenic concentration (1.400 mg kg) in subsuiface soil was detected in sample SB-44-4 collected near the center of the Site, above the screening level of 47 mg kg.
The PCB .Aroclor 1254 and the metals chromium and thallium were also found up to one order of magnitude above screening levels in subsuiface soil samples.
Figure 5-5 presents the horizontal extent of contaminated subsuiface soil above commercial industrial CTLs for pesticides and metals. Tlie estimated volume of subsuiface soil (above the w ater table) represented by Figure 5-5 is approximately 75.000 cubic yards.
Figure 5-6 presents the horizontal extent of combined suiface and subsuiface soil above commercial industrial CTLs for pesticides and metals, and Figure 5-7 depicts the extent of surface and subsuiface soil exceeding leachabilitx criteria.
5.5.5 Groundwater
To characterize the Site groundwater, direct push teclinolog\ (DPT) boreholes were advanced and groundw ater monitoring w ells w ere installed w itliin the shallow , inteimediate. and deep zones of the suificial aquifer.
Groundwater samples were collected and analyzed for pesticides. A DCs. SA DCs. metals, radionuclides, and other inorganics (i.e.. ammonia). .Analytical results of the collected groundwater samples have confiiTned the presence of pesticides. A DCs. SA DCs. metals, and ammonia at concentrations above screening levels in Site groundwater. The primaiv contaminants detected in the collected samples included BHCs. DDD. dieldrin. benzene, tricliloroethene (TCE). and arsenic. The most widespread
11 parameter exceeding screening values was alpha-BHC. detected in 33 of the 59 sampled w ells during the 2015 groundwater sampling event. The results of the 2015 groundwater sampling event are discussed in more detail below.
Shallow Zone (2 feet to 35 feet bis)
The liighest concentrations of pesticide contaminants, including alpha-BHC in the shallow zone (120 micrograms per liter [pg L] in monitoring well-(M\V-)5T. 32 pg L in well M\V-12T). were obseived in the noilh-central portion of the propei1> . The highest concentrations of endrin ketone (2 pg L) and aldrin (1.3 pg L) were detected in shallow well M\V-4T located north of the foiTner herbicide building. Tlie liighest concentrations of beta-BHC (11 pg L). gamma-BHC (45 pg L) and heptaclilor (1.1 pg L) were obseived in well M\\"-5T in the shallow zone just north of the foiTner herbicide building. (!)ther pesticide contaminants were less widely distributed but still present at maximum concentrations above screening levels, including ODD (5.1 pg L in well M\V-12T). dieldrin (3.4 pg L in well M\V-4T). alpha-chlordane (0.93 pg L in MW-l IT), gamma-clilordane (0.91 pg L in MW-llT). and heptaclilor epoxide (1.3 pg L in M\\"-4T). Pesticide compounds were detected in shallow zone groundwater at concentrations up to four orders of magnitude above the screening levels.
The liighest benzene concentration detected in the shallow zone was 6.9 pg L. in well M\\"-5T. north of the former herbicide building. The highest TCE concentration (54 pg L) was detected in well M\\"-24T on the .TAXP(9RT propei1> .
The liighest arsenic concentration (880 pg L) was detected in M\V-4P east of the foniier herbicide building. Sampling results indicated elevated lead concentrations in shallow zone wells M\V-14P (11 pg L) located near the St. .Tolins River and M\V-27T (located on the .T.AXPORT propei1> ). .Additional metals detected above screening levels include: aluminum, antimony, barium, beiv Ilium, cadmium, cluomium. cobalt, copper, iron, manganese, nickel, selenium, silver, thallium, vanadium, and zinc. Several of these, including barium, cadmium, cluomium and copper, were elevated onl\ in well MW - 27T. .Ammonia was also detected at elevated levels, with the highest concentration in the shallow zone found in well M\V-14T (540 milligrams liter [mg L]) located along the southern propeitx boundaiv. Metals w ere detected in shallow zone groundw ater at concentrations that w ere t\vo orders of magnitude above the screening levels.
Since alpha-BHC was the most prevalent contaminant in groundwater. alpha-BHC concentrations were used to estimate the horizontal extent of the Site groundwater contamination. Tlie horizontal extent of groundw ater contamination in the shallow zone of the suiTicial aquifer is presented in Figure 5-8. During the RI in 2005. the contaminated surficial groundwater plume in the shallow zone occupied an area of approximately 1.800.000 ft\ whereas by 2015 the area had decreased to approximately 1.100.000 ft". .As discussed in Section 5.6. liistorical data that demonstrates a clear and meaningful trend of decreasing contaminant mass and or concentration over time is one of the three tiers of Site-specific infoimation or "lines of evidence" that indicate that groundwater natural attenuation is occuning at the Site.
Intemiediate Zone (35 feet to 45 feet bis)
Impacts in the intermediate zone are much less extensive than in the shallow zone. .Alpha-BHC concentrations are lower, with a localized liigh of 0.97 pg L in well M\\"-10TD. located near the former pesticide storage warehouse. The liighest concentrations of ODD (0.099 pg L). beta-BHC (0.32 pg L). dieldrin (0.0092 pg L). and aldrin (0.12 pg L) were also found in M\V-10TD. Maximum heptaclilor and heptaclilor epoxide concentrations (0.0022 pg L and 0.0059 pg L. respectiveh ) were obseived in monitoring well M\V-15T. located near the southern portion of the Site. Pesticides were detected in
12 inteiTnediate zone groundwater at concentrations that are t\vo orders of magnitude above the screening levels.
The maximum TCE concentration of 54 ^g L was detected in M\\"-24TD on the JAXP(!)RT propertx. above the screening level of 34 pg L. The liighest arsenic concentration in the intermediate zone (210 pg L) was found in the sample collected from well M\V-1TD at the eastern edge of the Site.
The arsenic plume underlies the Site from the former F.ASC(!) building to the St. Jolins River. Lead was detected above the 15 pg L screening level in only one intermediate zone well (M\V-2TD: 93 pg L in 2002). .Ammonia was also detected near the southern propeilx boundaiv in the intermediate zone with the liighest concentration (200 mg L) obseived in monitoring well M\V-30TD.
The horizontal extent of alpha-BHC contamination in the intermediate zone of the suiTicial aquifer is presented in Figure 5-9. Similar to that obseived in the shallow zone, the area of intermediate zone contamination decreased from 1.908.000 ft" during the RI to 625.000 ft" in 2015. providing further evidence that natural attenuation is occuning at the Site.
Deep Zone (45 feet to 75 feet blst
Laboratoiv anah sis of groundw ater samples collected from the deep zone w ells in 2015 resulted in concentrations below the screening levels.
5.5.6 Groundwater Natural .Attenuation Luies of Exidence
.A groundwater monitored natural attenuation (NIN.A) evaluation was conducted during the FS to assess the potential effectiveness of NIN.A as a remedial alternative to address the Site groundwater contamination in accordance with the EP.A guidance titled "Use of Monitored Natural .Attenuation at Supeiiund. Resource Conseivation and Recoveiv .Act (RCR.A) Conective .Action, and Underground Storage Tank Sites." dated .April 21. 1999. .A copy of this evaluation is included in .Appendix F of the FS Report. The guidance la\ s out a tluee-tiered approach to evaluate the potential effectiveness of NIN.A as a remedial alternative. The tluee tiers of site-specific information or "lines of evidence" are:
• Historical data that demonstrate a clear and meaningful trend of decreasing contaminant mass and or concentration over time.
• H\ drogeologic and geochemical data that indirecth demonstrate that NIN.A processes are occuning at the Site, and the rate at wliich such processes will reduce contaminant concentrations to required levels.
• Data that directh demonstrate the NIN.A process at the Site and its abilitx to degrade the chemicals of concern (C(!)Cs).
The guidance also states that NIN.A max be most appropriate when used in conjunction with, or as a follow-up to. other active remediation measures such as source control.
Geochemical data evaluated during the FS indicate that natural attenuation is occurring at the Site. C(!)C concentrations in the "source areas" and witliin the groundwater plume are either stabilizing and or decreasing over time. Tliis is supported by analytical data (see Section 5.5.5) reflecting decreases in concentrations and in shallow and inteiTnediate zone plume sizes. Geochemical data also indicate that bacteria known to naturallx degrade clilorinated compounds (including pesticides and TCE) are present in groundwater and that NIN.A processes are active at the Site. The evaluation concluded that NIN.A would
13 be a potential remedial technolog\ if combined with source treatment or if considered in the development of the remedial alternatives.
Geochemical parameters collected during RI FS indicate that groundwater is moderateh anaerobic. Tlie feiTous iron values ranged up to 65 mg L with the highest concentrations near the middle of the Site. The maximum sulfide concentration (9.4 mg L) was detected in the sample collected from well M\V-4T near the noilhem Site boundaiv . Dissolved methane concentrations ranged from 0.34 mg L in well M\V-1T at the eastern edge of the Site to 2.500 mg L in well M\\"-9T in the southwestern comer of the Site. These data indicate that various levels of reducing conditions exist in groundwater at the Site. Total organic carbon concentrations ranged from 3.3 mg L in well M\\"-22T in the southwestern comer of the .T.AXPORT propertx to 57 mg L in the samples from wells M\V-5T and M\V-12T. Low total organic carbon concentrations are likely supporting creation of anaerobic conditions conducive to anaerobic biodegradation (reductive declilorination) of pesticides and chlorinated \ DCs. In addition. Dehalococcoides spp.. bacteria responsible for declilorination of pesticides and clilorinated \ DCs. w ere also found in Site groundwater.
Review of the geochemical water qualitx data listed above indicated that natural attenuation is likely occuning in groundwater at the Site: the groundwater contains sufficient levels of fen ous iron, carbon, and methane to suggest anaerobic biodegradation is likely occuning. Tliis line of evidence is further supported In obseived decreases in groundwater plume size in the shallow and intemiediate zones of the suificial aquifer, as discussed in Section 5.5.5.
5.5.7 Sedinient
During the RI. sediment samples were collected from the St. .Tolins River and anah zed for clilorinated pesticides, metals, and PCBs. During the Febmaiy 2008 sediment investigation (ENSR. 2008a). nine suiface (0 feet to 0.8 feet) and subsuiface sediment samples (3.5 feet to 6 feet) sediment samples were collected from sediment cores and were analyzed for pesticides, metals, and PCBs. .Additional sampling w as peifoiTned in .August 2008 to further delineate the lateral extent of impacted shallow sediments (ENSR. 2008b). and to further evaluate background (i.e.. reference) concentrations of clilorinated pesticides, metals, and PCBs. The estimated area of contaminated sediment is presented on Figure 5-10.
Pesticides
.Analytical results indicate that pesticides alpha-BHC. beta-BHC. gamma-BHC. delta-BHC. gamma- clilordane. DDD. DDE. DDT. dieldrin. endosulfan I. and heptachlor epoxide exceeded their respective screening levels in one or more sediment samples in the St. .Tolins River. Tlie primaiy pesticide contaminants include alpha-BHC (up to 4.900 micrograms per kilograms [pg kg]). DDD (up to 590 pg kg). DDT (up to 3.300 pg kg), and aldrin (up to 490 pg kg). The liighest pesticide contamination was obseived in the northern half of the impacted sediment area betiveen the .T.AXP(!)RT seaw all and east of the former fertilizer building pad. Maximum pesticides concentrations were ranging up to two orders of magnitude above the screening levels.
Metals
Results indicated that barium (up to 88.3 mg kg), cadmium (up to 7.23 mg kg), copper (up to 350 mg kg), iron (up to 54.300 mg kg), lead (up to 830 mg kg), mercuiy (up to 0.696 mg kg), and zinc (up to 630 mg kg), exceeded their respective screening levels in one or more sediment samples collected east of the Site in the St. .Tolins River. Maximum concentrations were no more than zero orders of magnitude above screenins levels.
14 PCBs
Two PCBs (Aroclor 1254 and Aroclor 1260) exceeded screening levels in 7 and 25 of the sediment samples, respectively. Sample SD-19 had the highest concentration of Aroclor 1254 (13 mg kg) and Aroclor 1260 (7.7 mg kg). PCBs were detected in sediment at concentrations up to one order of magnitude above the screening levels.
5.5.8 Surface \\ ater
In 2007 and 2008. 10 sediment pore water samples and 3 surface water samples were collected in the St. .Tolins River and anah zed for pesticides, metals and PCBs. (!)ne or more pore water sample results exceeded their respective surface water qualitx criteria. The maximum C(!)Cs concentrations detected in pore water samples include: DDD at 0.20 pg L. copper at 31.2 pg L. aluminum at 3.060 pg L. iron at 3.590 pg L. and mercuiy at 0.125 pg L. These concentrations are up to one order of magnitude above their respective surface water qualitx criteria.
15 6.0 Current and Potential Future Land and Resource Use
6.1 Current and Anticipated Future Land l^se
The cun ent land use of the Site is commercial industrial. Tlie Site is located witliin the Enteiprise Redevelopment .\i ea (Cit> of Jacksonville. 2016). .As shown in Figure 1-2. the Site is primarily suiTounded by industrial and commercial propeilies. West of Talleyrand .Avenue is a Cit> of .Tacksonville wastewater pump station, a concrete rec\ cling facilit>. and a petroleum wastewater rec\ cling facility. Immediately to the east of the Site is the St. .Tolins River, a commercial and recreational navigable watenva\ . Land immediateh south of the Site is owned In CSX and is cunenth an undeveloped, w ooded strip of land on w liich Deer Creek flow s from w est to east. The area immediateh south of the CSX propeit> is .Tones Chemical and Crow ley Marine (a port maritime facility ). North of the Site is the .T.AXP(!)RT propei1>. wliich is cun enth leased b\ .TMFE for staging and distributing automobiles.
The 2030 Comprehensive Plan for the Cit> of .Tacksonville classifies future land use at the Site as Water Dependent-Water Related. Tlie plan indicates that tliis categoiv is primarih intended for industrial land uses that require deeded water access to the St. Jolins River. In addition, the Site is included in the Industrial Sanctuan (Cit> of .Tacksonville. 2016).
Reasonabh anticipated future land use of the Site and properties to the south, west and north of the Site is expected to remain commercial and or industrial. Tliis is primarih due to the location (easy access to rail and the St. .Tolins River), and the increasing value of industrial and commercial properties along Talle\ rand .Avenue.
6.2 Current and Anticipated Future Resource l^se
6.2.1 Groundwater
The groundwater beneath the Site and the sunounding area is classified as a potential drinking water aquifer (Class G-II) by the State of Florida. Cun enth. the groundw ater is not used as a drinking w ater supph. Drinking w ater for the surrounding area is provided In the Citx of .Tacksonville and is draw n from the Floridan .Aquifer.
.A potable well sui've\ perfoiTned during the RI identified 47 wells witliin a 2-mile radius of the Site (Shaw. 2006). The majoritx of the wells were inigation wells and were shown to be drawing water at depths ranging from 600 feet to approximateh 800 feet bis. Tlie closest drinking water production well is located approximateh one mile w est-southw est of the Site and is draw ing w ater at a depth of approximateh 1.300 feet bis.
6.2.2 Surface \\ ater
W ater bodies associated with the Site are the St. Jolins River to the east and Deer Creek located on the southern adjacent propeitx. The St. Johns River is tidalh influenced with daih fluctuations in the water level ranging from 4.9 feet at the mouth of the river to 1.9 feet near Palatka approximateh 54 miles upstream. The river is liiglil\ commercialized with heavv sliip traffic near the Site. Deer Creek, wliich will be addressed in (!)U2. is a minor tributaiv of the St. Jolins River. Tlie creek drains an industrial area beginning west of the 20th Street Expresswa\ betiveen 8th Street North and the Mathew s Bridge to the South. Tlie creek is also tidalh influenced. Tlie St. .Tolins River is a designated Heritage River, and it supports active commercial and recreational fisheries. The S.TRWMD has developed a Suiface W ater Improvement and Management plan for this river. Tlie plan concluded that the St. Jolins River will continue to be used for commercial and recreational puiposes in the foreseeable future.
16 7.0 Summan of Site Risks
Preparation of a human health risk assessment (HHRA) is specified in the National Contingency Plan (NCP) which states that the lead agency for a Supeiiund site shall conduct a site-specific HHRA as pail of the RI process (40 Code of Federal Regulations [CFR] 300.430). .An FIFIR.A w as conducted for the Site in 2005 (Shaw. 2005a) and a BER.A was conducted in 2013 (.AECOM. 2013). .Although the HHR.A was comprehensive, since 2005. exposure parameters, exposure factors, and toxicitx values for certain chemicals have been updated. Therefore, an HHR.A .Addendum was prepared to evaluate potential cunent and future risks to human health that ma\ exist at the Site using both soil data collected during the RI fieldwork from 2000 tluough 2005 and groundwater results from 2015. supplemented b\ results from 2004 and 2012 (for wells that were inaccessible in 2015). Risks were recalculated using cunent EP.A protocols and presented in the 2016 Final FIFIR.A AJJemlum (.AECOM. 2016a). Tliis section summarizes the results of the HHR.A .Addendum and the BER.A.
7.1 SunuiiaiT of Human Health Risk .Assessment
.A four-step HHR.A process was used for assessing Site-related cancer risks and non-cancer health hazards. Tlie four-step process is comprised of Hazard Identification. Exposure .Assessment. Toxicitx .Assessment, and Risk Characterization. The HHR.A estimates w hat risks the Site poses if no action w ere taken. .An HHR.A provides a basis for taking remedial action and identifies contaminants and exposure pathwa\ s that need to be addressed In remedial action.
7.1.1 Chemicals of Concern
.A preliminaiv screening process was used to identify Site-related contaminants that are present in environmental media at concentrations that exceed initial screening criteria identified in the RI. Tliese contaminants are refened to as chemicals of potential concern (COPCs). Risk estimates were then calculated for individual COPCs for the complete exposure pathways associated with each media.
In accordance with Risk .Assessment Guidance for Supeiiund (R.AGS). A'olume I. Human Health Evaluation Manual (Parts .A. B. D. E. and E) (EP.A. 1989. 1991c. 2001. 2004. and 2009) and the Region 4 Human Health Risk .Assessment Supplemental Guidance (EP.A. 2014). a COC is a COPC that significantly contributes to: (a) a cumulative Site cancer risk for a given receptor that exceeds 1x10'^ or (b) a non-cancer hazard index (HI) that exceeds 1. Chemicals are not considered significant contributors to risk and are not included as C(!)Cs if their individual contribution to tliis total cancer risk is less than 1x10'^ and their non-cancer hazard quotient (HQ) is less than 0.1. Therefore. COPCs determined to contribute significantly (chemical-specific risk of 1x10'^ or greater) to a total cumulative risk greater than 1x10'^ or to contribute significantly (HQ of 0.1 or greater) to a target organ HI greater than 1 were identified as COCs. Table 7-1 presents a summaiy of the COCs by media. The receptors with a total cumulative risk greater than 1x10'^ and or an HI greater than 1 are the fisher, future industrial worker, future constrtiction worker, and future groundwater user.
7.1.2 Exposure-Assessment
.An exposure assessment identifies pathwa\ s In which receptors ma\ be exposed to Site contaminants and estimates the frequency, duration, and magnitude of such exposures. Exposure assessment involves:
1) Characterization of the physical setting of the area
2) Identification of potential receptors and exposure pathw a\ s
17 3) Identification of exposure point concentrations and doses
4) Identification and discussion of uncertainties
The foundation of an exposure assessment is the Human Health Conceptual Site Exposure Model (CSEM: depicted in Figure 7-1). Tlie CSEM integrates infoiTnation on potential chemical sources, release mechanisms, affected media, potential exposure pathwa\ s. and known receptors to identify complete exposure pathwa\ s.
A pathwa\ is considered complete if:
1) There is a source or chemical release from a source
2) There is an exposure point where contact can occur
3) There is a route of exposure (oral, dermal, or inhalation) at the contact point tlu ough which the chemical may be taken into the body
As discussed in Section 6. the Site has been zoned Water Dependent-Water Related (Citx of .Tacksonville. 2016) industrial, and the reasonably foreseeable future use of the Site is expected to remain industrial.
(!)n-site suiface and subsuiface soil, groundwater, and fish tissue were the media evaluated in the HHR.A. Cunent and future receptors in contact with soil were assumed to be exposed through incidental ingestion of soil, dermal contact w ith soil, and inhalation of volatile compounds from soil and fugitive dust emissions. Groundwater at the Site is cunenth not accessible to human receptors and has no cunent beneficial use: therefore, exposure to groundwater contamination was not considered a complete cunent exposure pathwa\ . However, future development on-site and off-site could include constmction activities that expose the groundwater and the installation of groundwater extraction wells. Therefore, future constmction workers could be exposed to contaminants via ingestion, inlialation. and deimal contact of vapors during constmction. and future groundwater users could potentialh access groundwater for potable puiposes exposing them to contaminants via ingestion, inhalation, and deiTnal contact. Based on cun ent and potential future use of the Site, the HHR.A identified cun ent and future receptors and exposure pathwa\ s.
The cunent land use scenarios include the following exposure pathwa\ s and populations:
• Maintenance Workers (adult): direct exposure to surface soil through ingestion and deimal absoiption. as w ell as inlialation of fugitive dust and external radiation.
• Trespassers (adult cliild): direct exposure to suiface soil tluough ingestion and dermal absoiption. as w ell as inlialation of fugitive dust and external radiation.
• (!)ff-site Residents (adult child): exposure to fugitive dust derived from suiface soil and transported off-site.
• Fishers: insestion of fish tissue.
18 The future land use scenario includes the following exposure pathwa\s and populations:
• Industrial W orker (adult): inlialation of volatiles from shallow groundwater through indoor air: direct exposure to surface soil through ingestion and deimal absoiption. as well as inlialation of fugitive dust and external radiation.
• Constiuction W orker: exposure to soil (to a depth of 8 feet) through ingestion, deimal absoiption. inhalation of fugitive dust, and external radiation: exposure by direct contact with shallow groundwater and In inlialation of chemicals volatilized from shallow groundwater during subsuiface constiuction activities.
• Groundwater User: exposure based on a residential scenario in wliich the Site groundwater is used as potable (tap) water.
Exposure point concentrations (EPCs) were estimated to represent the reasonable maximum exposures (RMEs) that are expected to occur at the Site. EPCs were estimated using available monitoring data for each exposure area. For each COPC and exposure medium. 95 percent upper confidence limits (UCLs) on the mean w ere calculated for use as the EPC in the risk calculations. If the UCL exceeded the maximum detected concentration, the maximum detected concentration was used as the EPC. Exposure equations used in the HHR.A were consistent with standard equations shown in the Risk .Assessment Guidance for Supeifund (EP.A. I99Ic and EP.A. 2002).
Given the absence of buildings on the Site, the .Tolinson and Ettinger Model for Subsuiface A'apor Intiusion into Buildings (EP.A. I99Ib) was used to estimate indoor air concentrations that potentially could result from volatilization of C(!)PCs from groundwater and their migration to the indoor air of a hypothetical building. Tlie EPCs used for calculating the risk from inhalation of chemicals volatilized from groundwater during constiuction activities were calculated using the A'irginia Department of Environmental Qualitx (A'DEQ) model for volatiles in a constiuction utilitx trench (A'DEQ. 2015). Tlie concentrations of soil particulates in air were calculated by applying the particulate emission factor of 1.36x10'' m'^ mg (EP.A. 2015) to the exposure concentrations identified forsuiface soil (cunent and future) and subsuiface soil (future). EPCs in fish tissue were estimated by using modeling to calculate: (I) a Site-specific dilution factor (DF) for groundwater discharging to suiface water. (2) a food-chain model for transfer of contaminants from suiface water to fish tissue, and (3) a food-chain model for transfer of contaminants from sediment to fish tissue.
The EPCs for each exposure area and medium are summarized in Tables 7-2 tluough 7-5.
7.1.3 Toxicity-Assessment
The estimation of potential human health impacts due to exposure to Site-related contamination utilizes various toxicity values derived b\ EP.A or approved In EP.A for use in HHR.As. Tliese values are developed based on infoiTnation derived from direct exposure of animals or from human epidemiological studies.
Based on EP.A guidance (EP.A. 2003). the most current toxicitx values (slope factors, inlialation unit risks, reference doses [RfDs]. and reference concentrations [RfCs]) were obtained from the following liierarcln of sources: (I) EP.A Integrated Risk InfoiTnation System. (2) EP.A Provisional Peer-Reviewed Toxicitx A'alues Database, and (3) California Environmental Protection .Agency values. Health Effects .Assessment
19 Summan Tables. ATSDR Minimal Risk Levels, and other peer-reviewed sources. Toxicit> values used in the 2016 HHRA Addendum (AECOM. 2016a) are included on Tables 7-6 tluough 7-9.
7.1.4 Risk Characterization
The final step of the HHR.A is risk characterization. Tliis section provides a characterization of the human health risks associated with the potential exposures to chemicals in indoor air. groundwater, soil, and fish tissue at the Site and the sunounding community. Tlie results of the risk characterization are discussed below. Potential risks (carcinogenic and non-carcinogenic) for individual chemicals detected in the various media were estimated using excess lifetime cancer risk (for carcinogenic effects) and EP.A's HI approach (for non-carcinogenic health effects).
Carcinogenic Risk - Tlie incremental risk of developing cancer from exposure to a chemical at the Site is defined as the additional probabilitx that an individual exposed will develop cancer during liis or her lifetime (assumed to be 70 years). Tliis value is calculated from the lifetime average daily dose (L.ADD) and the route-specific cancer slope factor (CSE) for the chemical as follows (EP.A. 1989):
Risk = LADD x CSE
Non-Carcinogenic Risk - The risk of adverse non-carcinogenic effects from chemical exposure is expressed in teiTns of the HQ. Tlie HQ is the ratio of the estimated dose (daily intake [.ADD]) that a human receives to the RfD. the estimated dose below which is unlikeh to cause adverse health effects for even sensitive populations. Tlie HQ is calculated as follows (EP.A. 1989):
HQ = ADD - RfD
Where:
HQ = Hazard Quotient (unitless) .ADD = .Average DaiK Dose (mg kg da\ ) RfD = Reference Dose (mg kg day)
.All the HQ values for chemicals within each exposure pathwa\ are totaled to \ ield the HI. Each pathwa\ HI witliin a land use scenario (e.g.. future resident) is summed to yield the total HI for the receptor. If the value of the total HI is less than 1. it is interpreted to mean that the risk of non-carcinogenic injuiy is low . If the total HI is greater than 1. it is indicative of some degree of non-carcinogenic risk or effect.
Risk estimates were calculated for individual C(!)PCs for the complete exposure pathwa\ s associated with each receptor and exposure medium and are shown on Tables 7-10 through 7-17. COPCs contributing to a cancer risk of greater than 1x10'^ or an HI for non-cancer effects greater than 1 w ere identified as C(!)Cs for human health. Table 7-1 presents a summaiy of the human-health and ecological C(!)Cs by medium. The calculated risks and hazards for each receptor under both cun ent and future scenarios are summarized in Exliibit 1.
20 Exhibit 1 0> eriill Suniniarx of Potentiiil Risks and Hazards for COPCs Carcinogenic Non-carcinogenic Media Scenario Receptor Risk Hazard Index Maiuteuauce Worker 4x10 • 0.1 Trespasser 1x10^ 1 C urrent Siirtiice Soil (DtT-Site .Adult Resident 8x10 " 0.02 (DtT-Site Cliild Resident 2x10 " 0.02
Future ludiLstrial Worker 5xl(k-' 2* Subsurtiice Soil Future Construction Worker 1x10^ 6 •Adult Fisher (Modeled troiii Groiuidwater) 2x10 " 0.001 Current Cliild Fisher (Modeled troiii Groiuidwater) 2x10 " 0.003 Industrial Worker (\'apor lutriLsiou) 3x10 " 0.0^^0 Groundwiiter Coiistnictioii Worker 1x10^ 1080 Future •Adult Groiuidwater User 1x10' 510 Cliild Groiuidwater User 4x10- 916 •Adult Fisher (Modeled troiu Sediiueiit) 4x10"' 6 Sediment** C urrent Cliild Fisher (Modeled troiu Sediuieut) ixlO"* 17 Notes: Bold iiidit iites \'iiliie iibo\'e the iicceptuble risk range or \'aliie. "After e\';iliuitioii of target organ hazards, no non-carcinogenic C'(DC's were identified in surface soil. ""Poteiiti a! health risks to the .Adult C'liild Fisher are based on coiisiunption of fish tissue.
Cunent Scenarios
Maintenance Worker - The excess lifetime cancer risk for maintenance worker exposure to suiface soil tluough ingestion, dermal contact, and particulate inlialation is 4xl0 "\ and for radionuclide ingestion, inlialation. and external exposure risk is 2x10'^. for a total cumulative risk of 4xl0"\ Tliis is within the EPA acceptable risk range for total risk to a receptor of 1x10'^ to 1x10'^. Therefore, no C(!)Cs were identified in suiface soil under tliis scenario.
The total cumulative non-cancer HI for the maintenance worker is 0.1: therefore, no non-carcinogenic C(!)Cs were identified for the maintenance worker based on exposure to suiface soil.
Trespasser - The excess lifetime cancer risk for trespasser exposure to suiface soil tlu ough ingestion. deiTnal contact, and particulate inlialation is 1x10'^. and for radionuclide ingestion, inlialation. and external exposures is 2x10'^. for a total cumulative risk of 1x10'^. Tlierefore. no C(!)Cs were identified in suiface soil under this scenario.
The total cumulative non-cancer HI for the trespasser is 1. equal to the EP.A's acceptable non-cancer HI. Therefore, no non-carcinogenic C(!)Cs were identified for the cunent trespasser scenario based on exposure to COPCs in suiface soil.
21 Off-Site Residents - The excess lifetime cancer risks for exposure to suiface soil particulates are similar for both adult (6x10" ) and cliild (2x10" ) off-site residents. Tlie risk associated with radionuclides is 3x10" for adult and 4x10'^ for cliild off-site residents. Tlie total cumulative risks are 8x10" (adult) and 2x10" (cliild). Tlie total cumulative non-cancer His for the adult (0.02) and cliild (0.02) off-site resident are less than EP.A's acceptable HI of 1. Therefore, no C(!)Cs were identified for the off-site resident based on exposure to Site suiface soil.
Fisher - For fish tissue concentrations modeled from groundwater, the excess lifetime cancer risks for both adult (2x10" ) and cliild (2x10" ) fishers are less than the EP.A's acceptable risk range of 1x10'^ to 1x10'^ for total risk to a receptor. Tlie total cumulative non-cancer His for the adult (0.001) and child (0.003) fisher are less than the acceptable HI of 1. No chemical-specific risk or hazard exceeds 1x10'^ or 0.1. respectively. Tlierefore. no C(!)Cs were identified for the cunent fisher scenario based on exposure to C(!)PCs in fish tissue modeled from groundwater to suiface water.
For fish tissue concentrations modeled from sediment, the excess lifetime cancer risks for both adult (4x10"^) and cliild (3x10"^) exceeded the EP.A target risk range of 1x10"^ to 1x10"^ for total risk to a receptor. Ten C(!)Cs w ere identified in sediment based on tliis scenario of fish tissue bioaccumulation and ingestion, including eight pesticides and the PCBs .Aroclor 1254 and .Aroclor 1260. Tlie total non-cancer His for the adult (6) and child (17) fisher indicated that adverse non-cancer health effects are likely based on the exposure concentrations in fish tissue modeled from sediment. Six non-carcinogenic C(!)Cs were identified in sediment under tliis scenario, including five pesticides and .Aroclor 1254.
Future Scenarios
Industrial Worker - Tlie excess lifetime cancer risk for future industrial worker exposure to suiface soil tluough ingestion, deniial contact, and particulate inlialation is 5x10'^. wliich is above the EP.A acceptable risk range of 1x10'^ to 1x10'^. The risk associated with radionuclides is 2xl0'\ Sixteen C(!)Cs were identified in suiface soil under tliis scenario, including pesticides. .Aroclor 1254. dioxins and furans toxicitx equivalence concentration, the inorganics arsenic and cluomium. and the radionuclides radium- 226 and uranium-238.
The total non-cancer HI for the industrial worker exposure to surface soil is 2. Tliis is greater than the EP.A acceptable non-cancer HI of 1. indicating that adverse non-cancer health effects could potentially occur based on the exposure concentrations in suiface soil. How ever, after evaluation of target organ hazards, no additional C(!)Cs were identified in surface soil.
Risk associated with inlialation of indoor air. based on vapor intmsion from shallow groundwater, is 3x10" and the non-cancer HI is 0.09. No groundwater C(!)Cs were identified for the future industrial worker.
Construction Worker - The excess lifetime cancer risk for future constmction worker exposure to subsuiface soil tluough ingestion, deniial contact, and particulate inlialation is 1x10'^. The risk associated with radionuclides is 9x10" . Risk associated with exposure to groundwater in a construction utilitx trench tluough ingestion, deirnal contact, and inlialation of vapors is 1x10'^. The total cumulative risk from soil and groundwater for the future construction worker is 2x10'^. Therefore. 12 C(!)Cs were identified in subsuiface soil under tliis scenario, including pesticides. .Aroclor 1254. dioxins and furans toxicitx equivalence concentration. Twelve C(!)Cs were also identified in groundwater under tliis scenario, including: 1.4-diclilorobenzene. naphthalene, pesticides. .Aroclor 1254. pentaclilorophenol. beiv Ilium, and cluomium. The total non-cancer HI for the constmction worker exposure to subsurface soil is 6. indicating that adverse non-cancer health effects could potentialh occur based on the exposure concentrations in subsuiface soil. Therefore. 11 non-carcinogenic C(!)Cs were identified in subsuiface soil under tliis scenario, and 4 of these (endosulfan sulfate, endrin aldehyde. Aroclor 1254. and thallium) were not included on the cancer risk-based C(!)C list mentioned above.
The total non-cancer HI for the constmction worker exposure to groundwater is 1.080. Tliis is much greater than the EP.A's acceptable non-cancer HI of 1. indicating that adverse non-cancer health effects are likeK based on the exposure concentrations in shallow groundwater. .A total of 20 non-carcinogenic C(!)Cs were identified in groundwater under this scenario, including: A DCs. SA DCs. pesticides. .Aroclor 1254. inorganics, and ammonia.
Grouiulwater L^ser - Cancer risk associated with exposure to groundwater via its use as potable water, tlu ough ingestion. deiTnal contact, and inhalation of vapors, is 1x10 ' for the adult and 4x10 " for the cliild. wliich are above the EP.A acceptable risk range of 1x10'^ to 1x10'^. .A total of 26 C(!)Cs were identified in groundwater under tliis scenario, including A DCs. SA DCs. pesticides. .Aroclor 1254. pentaclilorophenol. and inorganics.
The total non-cancer HI for exposure to groundwater as potable water is 510 for the adult and 916 for the cliild. both exceeding EP.A's acceptable non-cancer HI of 1. indicating that adverse non-cancer health effects are likeK based on the exposure concentrations in groundwater. .A total of 40 non-carcinogenic C(!)Cs were identified in groundwater under this scenario, including: A DCs. SA DCs. pesticides. .Aroclor 1254. pentaclilorophenol. inorganics, and ammonia. In addition, as discussed below, lead was identified as a C(!)C in groundwater for the future groundwater user (cliild).
Lead Modeling - Carcinogenic and non-carcinogenic toxicitx values are not available for lead. The EP.A considers lead a special-case chemical. The EP.A evaluates human exposure to lead by the use of blood lead modeling to relate soil lead intake to blood lead concentrations. For the HHR.A .Addendum, lead was evaluated using the EP.A approach to assessing risks associated with child exposures to lead based on blood lead levels and adult exposures to lead based on blood levels in the fetus of a pregnant female worker. Tlie EP.A has identified a childhood and fetal blood lead concentration of 10 micrograms per deciliter (pg dL) as the level of concern above which health risks would occur, and has adopted a lead risk reduction policy to limit the probabilitx of a cliild's or fetus's blood lead concentration exceeding 10 pg dL to 5 percent or less (EP.A. October 2015b).
The .Adult Lead Methodolog\ model was used to estimate blood lead concentrations that ma\ result from exposure to surface soil for the trespasser and industrial worker and from exposure to subsuiface soil for the construction worker at the Site.
The results of the modeling, summarized in Table 7-18. indicate that the probabilities of a fetal blood lead level exceeding the target blood lead level are 0.008 percent for the trespasser. 0.04 percent for the industrial worker, and 0.4 percent for the constmction worker, all below 5 percent. Therefore, lead in soil at the Site does not pose significant risk to the health of these receptors.
The Integrated Exposure Uptake Biokinetic (lEL^K) Model was used to calculate blood lead levels for a future groundwater user (cliild) and to calculate the probabilitx that the child's blood lead level would exceed the target, based on aritlimetic mean lead concentrations in groundwater. Blood lead levels predicted b\ the model for the child groundwater user scenario, from exposure to Site-specific groundwater concentrations, are 8.6 pg dL to 13.7 pg dL. .All except one of these blood lead levels are greater than the 10 pg dL target. Tlie probabilitx risk that a resident cliild would have a blood lead level exceeding 10 pg dL was calculated as 68 percent, wliich is greater than the 5 percent criterion. The results
23 of the lEL^K model indicate that potential exposure of the future child groundwater user to groundw ater at the Site would likeK result in adverse effects, and lead was selected as a C(!)C for groundwater.
7.1.5 Uiiceitamty
W itliin the Supeiiund process, baseline quantitative risk assessments are peifoimed in order to assess the potential human health impacts of a given site under currently existing conditions and potential future land use. The assessments are performed in order to provide project and risk managers with a numerical representation of the severity of contamination present at a site, as w ell as to provide an indication of the potential for adverse public health effects. Tliere are man\ inlierent and imposed uncertainties in the risk assessment methodologies, and each stage of the risk assessment process includes a degree of uncertaintx.
Data Evaluation and COPC Selection - Risk may have been underestimated or overestimated for the following reasons:
• Sample locations - since sampling was concentrated more in areas believed to be contaminated based on past operations and Site investigations, the potential for underestimating risk using the available data set was minimal.
• Contaminant identification - low uncertaintx because sampling protocols generally target analytes based on historical infoiTnation and guidance, and chemicals excluded are those detected at concentrations below conseivative risk-based screening levels based on the most cunent EP.A guidance.
• Lack of risk-based screening levels for some of the analytes - increases the uncertaintx because the use of sunogate screening values from chemicals with similar stmctures and toxicological effects may overestimate or underestimate risk.
• Elevated detection limits - a few anah tes in groundwater were not detected above elevated detection limits in groundwater and were eliminated from the data set. There is the possibilitx that some chemicals thus eliminated may be present at levels above screening levels. The risk may have been underestimated if a greater concentration w as present but not detected.
• Lack of background dataset - may have overestimated actual Site-related risk attributable to upgradient sources.
Exposure .Assessment- Factors that contribute to uncertaintx in the exposure assessment include the identification of exposure pathways, assumptions for scenario development, intake parameters, and EPCs.
• Identification of potential exposure pathways and receptors - based on Site-specific, plausible, cunent and h\ pothetical future land use scenarios. Tlie exposure parameters are generalh based on conseivative assumptions and would tend to overestimate rather than underestimate risk.
• .Assumptions for scenario development - conseivative default assumptions, such as unlimited access to the Site and no vegetation to prevent fugitive dust. Professional judgment is used to modifx the assumptions as required, but the conseivatism is retained. Estimated risks were based on an assumed industrial land use. In the unlikely event that the land use was to change, the health risks would need to be further assessed.
• Intake parameters - default assumptions used for tliis risk assessment were the EP.A RME factors. Site-specific factors were used where appropriate. The chemical intakes represent the maximum
24 exposure that could reasonabh be expected for the given pathwa\ s. The chemical concentrations were assumed to be constant with time. Tliis assumption ma\ have resulted in overestimating the risk w here the concentrations of chemicals have decreased and w ill continue to decrease over time.
• Modeling - used to estimate the transfer of contaminants from one medium to another for indoor air concentrations resulting from vapor intmsion from groundwater, and for vapor concentrations in a constmction utilitx trench resulting from migration from groundwater in contact with the trench. Modeling was also used as the basis for evaluating exposure to fish tissue concentrations. The use of modeling ma\ overestimate or underestimate risk.
Toxicity .Assessment - The estimation of potential human health impacts due to exposure to Site-related contamination utilizes various toxicitx constants derived or approved by EP.A. Extrapolations used in deriving these values ma\ result in inherent en ors that increase the unceilaintx in estimates of potential effect. Modifi ing factors and unceilaintx factors are inserted, and they intentionally increase the risk estimates in order to ensure the protection of human health.
The inteipretation of the results of the animal studies upon wliich the initial toxicitx evaluation is founded can be difficult, and guidelines demand extremely conseivative inteipretations. The uncertainty that tliis builds into the estimates of toxicity is acknowledged, but tliis conseivative approach provides a level of protection for the potentially exposed individuals.
The toxicity factors for some chemicals were not available. .As such, these chemicals were evaluated using toxicity factors for similar chemicals. Tliis approach could potentially lead to the over- or underestimation of the calculated risk.
Risk Characterization - Uncertainties in the exposure and toxicity assessments are reflected in the quantitative risk estimates developed for the COPCs in the risk characterization. Some of the procedures used and uncertainties inlierent in the process may tend to underestimate potential risk. (!)verall. however, the numerous conseivative assumptions built into the assessment, including dose additivity for multiple substance exposure and the combining of risk across pathw ay s. are considered more likely to overestimate rather than underestimate potential risks.
Uncertainties in the toxicity assessment are compounded under the assumption of dose additivity for multiple substance exposure. Tliis assumption ignores possible synergisms and antagonisms among chemicals. The use of target organ His to identify C(!)Cs instead of summing HQs for all COPCs regardless of critical effect reduces the uncertainty . In addition, the use of modeling to evaluate risk due to exposure to lead in soil and groundwater and to estimate fish tissue concentrations may overestimate or underestimate risk.
7.2 Ecological Risk .Assessnient
.An initial Screening-Level Ecological Risk .Assessment for the Site was peifomied from 2001 to 2005. To further assess evaluate risk to ecological receptors, a BER.A was completed in 2013 (.AECOM. 2013).
The data used in the final BER.A included suiface soil samples collected bet\veen 2000 and 2006: sediment samples collected from the St. .Tolins River in 2001. 2002. and 2008: suiface water samples collected from the river in 2007: and sediment pore water samples collected from the river in 2007 and 2008. Suiface soil, sediment, surface water, and pore water samples were analy zed for pesticides. PCBs. and metals. Suiface soil samples were also analyzed for A DCs. SA DCs. and dioxins and furans. Reference concentration data were collected for sediment at 10 upstream locations on the St. .Tolins River
25 in Jacksonville. Tliese data were used to deteiTnine Site-related concentrations of pesticides. PCBs. and metals for evaluation in step 3 of the final BERA. Results from the refinement screenings of the data and consideration of other available lines of evidence w ere evaluated to identify final chemicals of potential ecological concern (COPECs) for each of the assessment endpoints.
7.2.1 Assessment Endpomts and Chemicals of Potential Ecological Concern
Witliin Step 3 of the BERA. assessment endpoints were identified and data were screened to refine estimates of risk to the assessment endpoints. Figure 7-2 presents the potentially complete exposure pathwa\ s for the limited ecological receptors that could occur at the Site and that were evaluated in the BER.A. Tlie assessment endpoints and receptors evaluated were the following:
• .Abundance and diversitx of the communitx of bentliic invertebrates in the St. Jolins River near the Site.
• .Abundance and diversitx of the communitx of aquatic organisms in the St. .Tohns River near the Site.
• Sustainabilitx of populations of native birds that utilize the shoreline habitat of the study area.
• Sustainabilitx of populations of native mammals that utilize the shoreline habitat of the study area.
• Sustainabilitx of populations of native birds that utilize the tenestrial habitats on the Site.
• Sustainabilitx of populations of native mammals that utilize the terrestrial habitats on the Site.
The representative receptors and measurement endpoints evaluated for each of the assessment endpoints are summarized in Tables 7-19 tluough 7-23. .As described in the BER.A. concentration- and dose-based refinement screenings were perfoiTned to refine the list of preliminaiv C(!)PECs. and additional screening was peifoiTned to identify the final COPECs.
For the bentliic and the aquatic assessment endpoints. maximum and average concentrations were screened against conseivative and alternative ESA's to calculate a range of HQs for each analyte. The HQs were used to identifi final COPECs. The aquatic assessment endpoint also was evaluated by assessing potential risk to liigher-tropliic-level. predatoiv fish tlu ough the use of food-chain modeling.
For the wildlife assessment endpoints and predatoiv fish, food-chain modeling was used to estimate exposure doses based on maximum and average concentrations. The doses calculated for birds and mammals, and the tissue residues estimated for predatoiv fish, were compared to conseivative and alternative toxicitv reference values (TRA's) to calculate a range of HQs for each COPEC and receptor. Conseivative TRA's were based on no-obseived-adverse-effect levels and lowest-obseived-adverse-effect levels. Tlie HQs were used to identifv final COPECs. Tlie final COPECs identified as having the potential to pose risk to each assessment endpoint are summarized, as follows. In media and receptors representing the assessment endpoints.
Bentliic Invertebrate Community - Sediment (Bentliic Invertebrates)
The final COPECs identified in sediment of the St. .Tolins River near the Site included 13 pesticides (ODD. DDT. aldrin. alpha-BHC. beta-BHC. delta-BHC. gamma-BHC [lindane], chlordane. alpha-
26 clilordane. gamma-chlordane. dieldrin. endosulfan I. and heptaclilor epoxide). 2 PCBs (Aroclors 1254 and 1260). and 6 metals (barium, cadmium, copper, lead, mercuiy. and zinc).
The final COPECs identified in sediment pore water of the St. .Tolins River near the Site include nine pesticides (DDD. DDE. alpha-BHC. beta-BHC. delta-BHC. gamma-BHC [lindane], alpha-clilordane. gamma-clilordane. and dieldrin). one PCB (.Aroclor 1260). and four metals (copper, iron. lead, and mercuiy). .All except t\vo of these (DDE and iron) also were identified as final COPECs in bulk sediment. Thus, a substantial similaritx was found between potential toxicity to the bentliic inveilebrate community predicted on the basis of bulk sediment screening and on the basis of pore w ater screening.
.Aquatic Organism Community - Surface Water (Fish and Other .Aquatic Organisms)
The screening of suiface water concentrations from the St. .Tolins River against ESA's protective of aquatic organisms identified five chemicals as final COPECs: DDD. gamma-chlordane. copper, iron, and mercuiv . .All five were identified as final C(!)PECs because the\ exceeded a Florida and or a Federal suiface water qualitx criterion.
For upper-tropliic-level. piscivorous fish exposed to potentialK bioaccumulative suiface water contaminants tlu ough the food chain along the shoreline of the St. .Tolins River, aluminum and mercun were identified as final C(!)PECs in suiface water.
Shoreline Birds - Sediment and Food Chain Pathwa\ s (Green Heron)
For a green heron exposed to sediment contaminants tluough the food chain and incidental ingestion of sediment, the final COPECs identified in sediment were dieldrin. .Aroclor 1254. .Aroclor 1260. and lead were identified as final COPECs in sediment.
Shoreline Mammals - Sediment and Food Chain Pathwavs (Raccoon)
For a raccoon exposed to sediment contaminants tluough the food chain and incidental ingestion of sediment, the final COPECs identified in sediment were alpha-BHC. dieldrin. .Aroclor 1254. .Aroclor 1260. and lead.
Tenestrial Birds - Suiface Soil and Food Chain Pathwavs (.American Robinl
For a robin exposed to soil contaminants through the food chain and incidental ingestion of soil on the Site, the final COPECs identified in suiface soil were: 17 pesticides (DDD. DDF. DDT. aldrin. alpha- BHC. beta-BHC. delta-BHC. gamma-BHC [lindane], alpha-clilordane. gamma-clilordane. dieldrin. endosulfan sulfate, endrin. endrin aldehyde, endrin ketone, heptaclilor. and toxaphene). 2 PCBs (.Aroclors 1254 and 1260). 15 dioxin and furan congeners (2.3.7.8-substituted). and 4 metals (arsenic, copper, lead, and thallium).
Tenestrial Mammals - Suiface Soil and Food Chain Pathwavs (Feast Sluew )
For a least slu ew exposed to soil contaminants tlu ough the food chain and incidental ingestion of soil on the Site, the final COPECs identified in suiface soil were: 18 pesticides (DDD. DDF. DDT. aldrin. alpha- BHC. beta-BHC. delta-BHC. gamma-BHC [lindane], alpha-clilordane. gamma-clilordane. dieldrin. endosulfan sulfate, endrin. endrin aldeln de. endrin ketone, heptaclilor. heptaclilor epoxide, and toxaphene). 3 PCBs (.Aroclors 1248. 1254. and 1260). 15 dioxin and furan congeners (2.3.7.8- substituted). and 4 metals (arsenic, copper, lead, and thallium).
27 7.2.2 Baseline Ecological Risk Assessment Conclusions and Remedial Goal Options
Step 3 of the BERA identified multiple COPECs in sediment, surface water, and soil. Based on the numbers of final C(!)PECs and the magnitude of their HQs. these C(!)PECs w ere detennined to w an ant identification as ecological C(!)Cs. Tlie BERA identified and Exhibit 2 summarizes the assessment endpoints at risk from C(!)Cs in tluee media:
• Sediment of the St. .Tolins River along the shoreline of the Site: pesticides. PCBs. and metals pose risk to benthic invertebrates as well as birds and mammals that forage in shoreline habitats and feed on bentliic invertebrates.
• Suiface water of the St. .Tolins River along the shoreline of the Site: pesticides and metals pose risk to fish and other aquatic organisms.
• Suiface soil on the Site: pesticides. PCBs. dioxins and furans. and metals pose risk to birds and mammals that forase in tenestrial habitats on the Site.
Exhibit 2 Baseline Ecological Risk .Assessment Summarx
Media Receptor COPECs Drix ing Ecological Risk Seduiient in St. Joluis Bentliic iiu'ertebrates Ri\'er along Site Birds and nianinials that tdrage on shoreline and or teed on Pesticides. PCBs. and metals Shoreline bentliic iiu'ertebrates Pesticides (DDD and clilorduie). Pore Water in Sediment Bentliic iiu'ertebrates. fish and other aqiuitic organisnis ahiniiniuii. copper, iron, and Near Site Shoreline merciuu' Surtace Water in St. Pesticides (DDD and clilorduie). Joluis Ri\'er along Site Fish and other aqiuitic organisnis ahiniiniuii. copper, iron, and Shoreline mercuiu' Pesticides. PCBs. dioxiiis and Surtace Soil Birds and nianinials that forage in terrestrial habitats tiirans. and metals
The response action selected in tliis R(!)D is necessaiv to protect the public health or welfare or the environment from actual or tlu eatened releases of hazardous substances, pollutants, or contaminants from this Site wliich ma\ present an imminent and substantial endangerment to public health or welfare or to the environment. 8.0 Remedial Action Objectives
Remedial Action (!)biectives (RA(!)s) were developed for the puipose of identify ing and evaluating remedial teclinologies capable of addressing the Site contamination. Based on infoimation regarding cunent and potential future land use of the Site, the following RA(!)s were established to protect human health and the environment:
• Prevent human exposure to soil with C(!)C concentrations above levels that are protective for commercial and industrial use.
• Prevent C(!)C migration from contaminated soil to groundwater that ma\ result in concentrations above levels that are protective for drinking water use.
• Prevent human exposure to groundwater with C(!)C concentrations above levels that are protective for drinking water use.
• Restore contaminated groundwater to levels that are protective for a G-II aquifer as a source of drinking water witliin a reasonable timeframe.
• Prevent exposure to soil with C(!)C concentrations above levels that are protective of tenestrial ecological receptors.
• Reduce migration of groundw ater w ith C(!)C concentrations above levels that are protective of ecological receptors into the St. .Tolins River and Deer Creek.
• Prevent exposure to sediment in the St. .Tolins River with C(!)C concentrations above levels that are protective of ecological receptors.
• Prevent human exposure to fish tissue with C(!)C concentrations above levels that are protective for consumption In working with the FD(!)H to evaluate the need for fish consumption advisories.
8.1 Cleanup Levels
Cleanup levels are concentrations of contaminants in environmental media that, w hen attained, are protective and acliieve the R.A(!)s. In general, cleanup levels are established with consideration of the following:
• Protection of human receptors from adverse health effects.
• Protection of the environment from detrimental impacts from Site-related contamination.
• Compliance with federal and more stringent state, chemical-specific .Applicable or Relevant and .Appropriate Requirements (.AR.ARs).
EP.A has adopted the preliminaiv remediation goals identified in the Proposed Plan as the final cleanup levels for (!)U1. Cleanup levels for the Site are based on .AR.ARs and. for those chemicals that do not have a standard, cleanup levels are based on an excess cancer risk of 10'^ or a non-cancer risk HI of 1. The cleanup levels for this Site are presented in Tables 8-1 tluough 8-5.
29 ARARs are those substantive cleanup or control standards or environmental protection requirements, criteria, or limitations, promulgated under federal environmental or more stringent state environmental or facilit> siting laws and regulations, wliich are either:
• Directly "Applicable" to the contaminants, proposed remedial action, location, or other circumstances found at a particular CERCLA site, or:
• Are "Relevant and Appropriate" for use at a CERCLA site because the\ address problems or situations sufficiently similar to those encountered at the site such that their use is well suited to the site.
The NCR identifies tluee categories of ARARs: chemical-specific, location-specific, and action-specific. The federal and state .AR.ARs identified for the Site in each of these tluee categories are presented in Tables 8-6 tluough 8-8.
Suiface soil cleanup levels w ere deteimined for the suiface soil C(!)Cs in consideration of Florida's CTLs for commercial industrial exposure scenarios. For subsuiface soil. Site-specific cleanup levels were calculated based on risk to the constmction worker.
Groundw ater cleanup levels w ere established based on protection of human health from direct exposure to contaminated groundwater and compliance with .AR.ARs. W ith few exceptions, the cleanup levels for groundwater C(!)Cs are based on the EP.A MCLs or the FDEP GCTLs MCLs. wliichever value is values are most conseivative. For C(!)Cs with GCTLs based on secondaiv MCLs. which are not health based. Site-specific human health-based cleanup levels were calculated.
The sediment cleanup level for each C(!)C represents the low est of the chemical-specific remedial goal options (those for bentliic invertebrates) established in the BFR.A (.ALCOM. 2013). Tliese are based on FDEP Sediment Qualitx .Assessment Guidelines (SQ.AG) and FP.A-accepted sources (such as EP.A and National (!)ceanic and .Atmospheric .Administration publications) where FDEP values were not available.
Suiface water cleanup levels established for suiface water during the BFR.A (.AFCOM. 2013) are based on the Florida Suiface W ater Qualitx Criteria (SW QC: Chapter 62-302. F..A.C.. Suiface W ater Qualitx Criteria for Class IIL Predominantly Marine waters) for the suiface water COPFCs identified for aquatic orsanisms.
30 9.0 Description of Alternatives
The FS (AECOM. 2016b) evaluated media-specific remedial teclmologies capable of addressing soil, including PTW". groundwater, suiface water, and sediment contamination, tluough remediation of soil, groundwater and sediment. Suiface water-specific remedial alternatives were not evaluated in the FS because the selected remedy w ould consist of a combination of soil-, groundw ater-, and sediment-specific alternatives that would directh or indirecth address the surface water contamination. .A long-teiTn suiface water sampling and monitoring program will be developed and implemented to assess suiface water qualit> . The data collected during these sampling events will be used to evaluate whether suiface water cleanup levels have been achieved.
Teclmologies that most effectiveh address the contaminants and provide a range of cleanup options w ere evaluated together with sufficient infoimation to adequately compare alternatives using the prescribed NCP evaluation criteria.
.A brief description of each alternative evaluated for remediating soil, sediment, and groundw ater, along with estimated costs for capital, operation and maintenance ((!)&M). and total present woilh are provided in Sections 9.1 tluough 9.3 (except for .Alternatives SS-1. SD-1. and G\V-1 - No .Action alternatives wliich have no associated costs). Tlie following sections summarize the alternatives that were evaluated for remediating soil, sediment, and groundwater at the Site.
9.1 Soil-Alternatives
9.1.1 Soil -Alternative SS-1: No -Action
Estimated Capital Cost: SO Estimated O&M Cost: SO Estimated Total Present Worth Cost: SO Estimated Time to Design and Construct: .\ot Applicable Estimated Time to Achieve R.\Os: >30 Years
.Alternative SS-1 (No .Action) is required by the NCP as a baseline for comparison to other alternatives. Under this alternative, the Site would remain as is. and no measures would be taken. Tliis alternative would not be protective of human health and the environment, and attainment of the R.A(!)s or cleanup levels would not be acliieved within a reasonable timeframe.
9.1.2 Soil -Alternati\ e SS-2: Renio\ al of PTW ; Installation of Low-Pernieability Cap; ICs
Estimated Capital Cost: S12,599,600 Estimated O&M Cost: SIJ 19,800 Estimated Total Present Worth Cost: Sl-4,319,-400 Estimated Time to Design and Construct: 2-3 Years Estimated Time to Achieve R.\Os: 5 Years
.Alternative SS-2 consists of the following components:
• Excavation and off-site treatment disposal of PTW.
• Removal and consolidation of constmction debris and contaminated soil on CS.X propei1> directh adjacent to the Site. Tlie material would be excavated and consolidated on-site beneath the low-peiTneabilit> cap. Contaminated soil on the .T.A.XP(!)RT propeitx would be left in-place beneath the existing cap.
31 • Construction of the low-peiTneabilit> cap over the entire Site to prevent exposure to human and ecological receptors, reduce infiltration of precipitation leaching C(!)Cs to groundwater from vadose zone soil, and control erosion of contaminated soil. Tlie Site (approximately 31 acres) would be capped with a cap designed to be consistent with a Subtitle D landfill cap (EPA. 1991d). During the FS. for cost estimating puiposes. it was assumed that the cap system would consist of a plastic liner. 18-inch clay layer, and 6-inch soil cover (topsoil and hydroseeding). Cap s\ stem design requirements will be deteiTnined during remedial design and specified in the design documents.
• Following demolition of the existing on-site building foundations, removal of PTW. and consolidation of off-site constmction debris and contaminated soil from the CSX propei1> directh adjacent to the Site, the Site would be graded to control drainage. .An on-site stoimwater retention basin would be installed to capture and store suiface water mnoff and control discharge into the St. .Tolins River under a NPDES permit. .An off-site discharge from a CFRCF.A site to suiface water requires obtaining an NPDES peiTnit and meeting both the substantive and the administrative NPDES requirements (EP.A. 1990a). The size and location of the retention basin would be finalized in the remedial design. Excess soil resulting from excavation and grading activities would be characterized and transported off-site for disposal.
• Implementation of institutional controls (ICs) to ensure long-teiTn protectiveness of the remedy. .Anticipated ICs include: Implementation of a soil management plan for each propei1> w here soil with Site-specific C(!)C concentrations above levels that will allow unrestricted use: implementation of restrictive covenants for commercial industrial land use (CSX and Kerr- McGee properties): maintenance of the existing cap on the .T.AXP(!)RT"s propeitx and the low peiTneabilitx cap on the Ken-McGee propertx .
• O&M activities would encompass annual cap inspections and maintenance (i.e.. periodic retention basin repairs, and signage replacement).
Tliis alternative would inliibit infiltration, provide erosion control, and protect against future human and ecological exposure to the contaminated soil.
9.1.3 Soil Alternative SS-3: Removal of PTW; Excavation and Off-Site Disposal of Containmated Soil Posing a Direct Exposure/Contact Risk (Exceedmg Coininercial/Industrial CTLs); Installation of Low-Permeability Cap; ICs
Estimated Capital Cost: 527,181,000 Estimated O&M Cost: 51,705,500 Estimated Total Present Worth Cost: 528,886,500 Estimated Time to Design and Construct: 2-J years- Estimated Time to Achieve R.\Os: 5 Years
.Alternative SS-3 consists of the following components:
• Excavation and off-site treatment disposal of PTW.
• Removal and consolidation of constmction debris and contaminated soil on CSX propei1> directh adjacent to the Site. Tlie material would be excavated and consolidated on-site beneath
32 the low-peiTneabilit> cap. Contaminated soil on the JAXP(!)RT propeit> would be left in-place beneath the existing cap.
• On-site suiface soil (0-2 feet bis) from areas where Site concentrations exceed the FDEP's CTLs for commercial industrial use would be excavated and disposed off-site. .Alternative SS-3 includes removing contaminated soil from former process areas, including the areas to the north and east of the foiTner F.ASC(!) and herbicide buildings, and removing contaminated soil and sludge located underneath the foiTner suiface impoundment, north of the fertilizer building pad. along miscellaneous areas in the central and eastern portions of the Site, and beneath the herbicide building foundation. Contaminated soil would be characterized and transported off-site for disposal. ConfiiTnatoiy sampling of excavated areas w ould be peifoimed prior to backfilling to confinn that targeted contaminated soil has been removed.
• Excavation w ould be follow ed In backfilling, grading the Site to match the grade of the suiTounding properties, and installation of a low-peiTneabilit> cap with stormwater retention basin (described in Section 9.1.2) across the Site's 31 acres to cover the remaining contaminated soil.
• Implementation of ICs to ensure long-teiTn protectiveness of the remedy. .Anticipated ICs include: Implementation of a soil management plan for each propeitx where soil with Site-specific C(!)C concentrations above levels that w ill allow um estricted use: implementation of restrictive covenants for commercial industrial land use (CSX and Kerr-McGee properties): maintenance of the existing cap on the .T.AXP(!)RT"s propeitx and the low peiTneabilitx cap on the Ken-McGee propei1>.
• O&M activities would encompass annual cap inspections and maintenance (i.e.. periodic retention basin repairs, and signage replacement).
Tliis alternative would remove soil with C(!)C concentrations above the commercial industrial CTLs. inliibit infiltration, provide erosion control, and protect against future human and ecological exposure.
9.1.4 Soil Alternative SS-4: Removal of PTW; Excavation and Off-Site Disposal of Containmated Soil Posing a Direct Exposure/Contact Risk (Exceedmg Coininercial/Industrial CTLs) and a Risk to Groundwater xia Leacliing (Exceeding Leachability CTLs)
Estimated Capital Cost: $39,60-4,-400 Estimated O&M Cost: $1,705,500 Estimated Total Present Worth Cost: $-41,309,900 Estimated Time to Design and Construct: 3 years- Estimated Time to Achieve R.\Os and Cleanup Levels: 5 Years
.Alternative SS-4 consists of the following components:
• Excavation and off-site treatment disposal of PTW.
• Suiface and subsuiface soil above the water table that exceeds leachabilitx CTLs (Chapter 62- 777. F..A.C.) would be excavated, characterized and transported off-site for disposal. ConfiiTnation sampling of excavated areas prior to backfilling w ould be peifonned to confirm that tarseted contaminated soil has been removed.
33 • Excavation would be followed In backfilling and grading the Site to match the grade of the suiTounding properties. Tlie Site would be graded to control drainage across the Site, and vegetated to prevent erosion.
• Construction debris and contaminated soil on CSX propeitx immediately adjacent to the Site would be removed and disposed off-site. Contaminated soil on the .T.AXP(!)RT propei1> would be left in-place beneath the existing cap.
• Soil ICs will be implemented on the .T.AXP(!)RT propertx where site contamination remains above cleanup levels to ensure long-teiTn protectiveness of the remed\ and land use consistent with the R.AOs. .Anticipated ICs include: maintenance of the existing cap on the .T.AXPORT propeitx to prevent exposure to C(!)C concentrations above cleanup levels.
• O&M activities would include general Site maintenance.
Tliis alternative entails removal of the majoritx of soil, w liich w ould obviate the need for capping of the Site since unsaturated soil w ill no longer be a source of groundw ater contamination.
9.1.5 Soil Alternative SS-5: Removal of PTW; Excavation and Off-Site Disposal of Hot Spot Soil; Installation of Low-Pernieabilitv Cap; ICs
Estimated Capital Cost: S26,760,-100 Estimated 0,&.MCost: SI, 705,500 Estimated Total Present Worth Cost: $28,465,900 Estimated Time to Design and Construct: 2-J years- Estimated Time to Achieve R.\Os: 5 Years
.Alternative SS-5 consists of the following components:
• Excavation and off-site treatment disposal of PTW.
• Removal and on-site consolidation of constmction debris and contaminated soil on CSX propertx directh adjacent to the Site. Tlie material would be excavated and consolidated on-site beneath the low-peiTneabilit> cap. Contaminated soil on the .T.AXP(!)RT propeitx would be left in-place beneath the existing cap.
• Hot spots (areas where pesticide concentrations exceed 100 times and or metal concentrations exceed 10 times their respective leachabilitx-based CTLs: see Section 5.5.1) suiface and subsuiface soil would be excavated to approximately 5 feet bis. Hot spot soils are primarily located in the following Site areas: adjacent to the foiTner F.ASCO building, north of the fertilizer building pad: under the herbicide building foundation: the former suiface impoundment: and the former acid plant area. Excavated soil would be characterized and transported off-site for disposal. Prior to backfilling, post-excavation sampling would be conducted to confmn that the contaminants in the remaining soil are below the excavation criteria.
• The Site would be backfilled and graded to match the sunounding properties. .A low-permeabilit> cap with a stoimwater retention basin (described in Section 9.1.2) would be installed across the Site's 31 acres to cover the remaining contaminated soil.
• Implementation of ICs to ensure long-teiTn protectiveness of the remedy. .Anticipated ICs include: Implementation of a soil management plan for each propeitx where soil with Site-specific C(!)C concentrations above levels that w ill allow um estricted use: implementation of restrictive
34 covenants for commercial industrial land use (CSX and Kerr-McGee properties): maintenance of the existing cap on the JAXP(!)RT"s propeitx and the low peiTneabilitx cap on the Ken-McGee propei1>.
• O&M activities would encompass annual cap inspections and maintenance (i.e.. periodic retention basin repairs, and signage replacement).
Tliis alternative would remove soils where pesticide concentrations exceed 100 times and or metal concentrations exceed 10 times their respective leachabilitx-based CTLs. inliibit infiltration, provide erosion control, and protect against future human and ecological exposure.
9.1.6 Soil Alternative SS-6: Removal of PTW; Excavation of Hot Spot Soil; Ex-Situ Stabilization/On-Site C onsolidation; Installation of Low-Penneability Cap; ICs
Estimated Capital Cost: 520,198,-100 Estimated O&M Cost: 51,705,500 Estimated Total Present Worth Cost: 521,903,900 Estimated Time to Design and Construct: 2-3 years- Estimated Time to Achieve R.\Os: 5 Years
.Alternative SS-6 includes the following components:
• Excavation and off-site treatment disposal of PTW.
• Removal and on-site consolidation of constmction debris and contaminated soil on CSX propertx directh adjacent to the Site. Tlie material would be excavated and consolidated on-site beneath the low-peiTneabilit> cap. Contaminated soil on the .T.AXPORT propei1> would be left in-place beneath the existing cap.
• Hot spot soil would be excavated and stabilized ex-situ. and then consolidated on-site under the low-peiTneabilit> cap. Instead of off-site disposal, the excavated contaminated soil would be stabilized on-site with activated carbon, zero-valent iron (ZA'I). Portland cement, fly ash. or other agents selected from bench-scale studies during remedial design. Sampling and analysis of the stabilized material would be peifoiTned to verifx that the remed\ peifoiTnance objectives had been acliieved. The stabilized material would be backfilled and consolidated on the Site in selected areas.
• The Site would be graded to match the grade of the sun ounding properties and the low- peiTneabilitx cap with a stoimwater retention basin (described in Section 9.1.2) would be installed across the Site's 31 acres to cover the remaining contaminated soil.
• Implementation of ICs to ensure long-teiTn protectiveness of the remedy. .Anticipated ICs include: Implementation of a soil management plan for each propeitx where soil with Site-specific C(!)C concentrations above levels that w ill allow um estricted use: implementation of restrictive covenants for commercial industrial land use (CSX and Kerr-McGee properties): maintenance of the existing cap on the .T.AXP(!)RT"s propeitx and the low peiTneabilitx cap on the Ken-McGee propei1>.
• O&M activities would encompass annual cap inspections and maintenance (i.e.. periodic retention basin repairs, and signage replacement).
Tliis alternative would remove and stabilize soils where pesticide concentrations exceed 100 times and or
35 metal concentrations exceed 10 times their respective leachabilitx-based CTLs. inliibit infiltration, provide erosion control, and protect against future human and ecological exposure.
9.1.7 Soil Alternative SS-7: Removal of PTW; Iii-Situ Stabilization/Solidification of Hot Spot Soil; Installation of Low-Permeability Cap; ICs
Estimated Capital Cost: $18,217,900 Estimated O&MCost: $1,705,500 Estimated Total Present Worth Cost: $19,923,400 Estimated Time to Design and Construct: 2-3 years- Estimated Time to Achieve R.\Os: 5years
Alternative SS-7 includes the following components:
• Excavation and off-site treatment disposal of PTW. • Removal and consolidation of constiuction debris and contaminated soil on CSX propei1> directh adjacent to the Site. Tlie material would be excavated and consolidated on-site beneath the low-peiTneabilit> cap. Contaminated soil on the .T.AXP(!)RT propeitx would be left in-place beneath the existing cap. • Hot Spot Soil would be stabilized and solidified via in-situ stabilization solidification (ISS). ISS is a commercially available teclinology used to immobilize and reduce contaminant leachabilitx in the fill material matrix. The key difference bet\veen tliis alternative and .Alternative SS-6 is that contaminated soil would be stabilized in-situ. thus eliminating the need to excavate soil. Bench- scale studies would be performed to select appropriate stabilizing agents during the remedial design. The ISS process is accomplished by delivering the agent into the soil matrix and in-situ mixing with rotating augers within overlapping treatment zones or with trencliing equipment (track hoe). Tlie addition of the stabilization agent txpically increases total matrix volume in the treatment zone. The monolith tx picalh cures to a In draulic conductivitx approacliing 10'^ centimeters per second or lower. Samples of the stabilized solidified material would be cured and collected for analysis to deteiTnine physical and chemical properties, including unconfined compressive strength and leachabilitx characteristics for pesticides and metals. • .After stabilization is complete, the Site would be graded to match the grade of the sun ounding properties and the low-peiTneabilit> cap with a stoimwater retention basin (described in Section 9.1.2) would be installed across the Site's 31 acres to cover the remaining contaminated soil.
• Implementation of ICs to ensure long-teiTn protectiveness of the remedy. .Anticipated ICs include: Implementation of a soil management plan for each propeitx where soil with Site-specific C(!)C concentrations above levels that w ill allow um estricted use: implementation of restrictive covenants for commercial industrial land use (CSX and Kerr-McGee properties): maintenance of the existing cap on the .T.AXP(!)RT"s propeitx and the low peiTneabilitx cap on the Ken-McGee propei1>.
• O&M activities would encompass annual cap inspections and maintenance (i.e.. periodic retention basin repairs and signage replacement).
Tliis alternative would treat soils where pesticide concentrations exceed 100 times and or metals concentrations exceed 10 times their respective leachabilitx-based CTLs. inliibit infiltration, provide erosion control, and protect against future human and ecological exposure.
36 9.2 Sedinient Alteriiari\es SD-1 to SD-5
9.2.1 Sedinient Alternative SD-1: No Action
Estimated Capital Cost: SO Estimated O&M Cost: SO Estimated Total Present Worth Cost: SO Estimated Time to Design and Construct: .\ot Applicable Estimated Time to Achieve R.\Os: >30 Years
As required In the NCR this alternative was evaluated to compare to other sediment alternatives. Under tliis alternative, no action would be taken, and contaminated sediment would remain in its cunent condition. Tliis alternative does not address risks associated with sediment contamination.
9.2.2 Sedinient -\lternati\e SD-2: Sedinient Dredgmg and Off-Site Disposal
Estimated Capital Cost: S10,317,800 Estimated O&M Cost: S437J00 Estimated Total Present Worth Cost: S10J55,100 Estimated Time to Design and Construct: 2-3 Years Estimated Time to Achieve R.\Os: 5 Years
.Alternative SD-2 includes the following remed\ components:
• Concrete and other debris would be removed from the shoreline area of the St. .Tolins River.
• .Approximately 2.5 acres of C(!)C-contaminated sediment along the St. .Tohns River shoreline would be dredged, dewatered and disposed off-site. The total dredged depth will be deteiTnined during remedial design following additional investigation. .A debris sui've\ would be perfoiTned. and the identified debris would be removed from the impacted area to provide a stable subgrade. Removed debris would be temporarih staged on-site, and then transported to an off-site disposal facilitx . Slabs of concrete or similar debris might be cmshed and retained on-site for backfill. Debris removal w ould be follow ed In mechanical dredging of the sediment and dew atering In gravitx . .Additional dewatering using a div ing agent, such as cement kiln dust or cement. ma\ be required, and then the sediment would be transported off-site for disposal at a licensed facility. .Additional characterization would be required in the remedial design to finalize the extent and depths of sediment requiring remediation.
• Turbiditx curtains would be placed around the contaminated sediment to control turbiditx during sediment remedial actions.
• W ater from dewatering would be treated and discharged under peiTnit or transported off-site for disposal.
• .A suitable sand la\ er (tliickness to be determined during design) would be placed over the dredged area to manage dredge residuals.
• The embankment (approximately 700 linear feet of shoreline) w ould be straightened and protected with a riprap s\ stem to prevent erosion. Tlie shoreline protection material would tie into the existing .T.AXPORT bulkhead located in the northeast comer of the Site and extend along the St. .Tolins River shoreline to the southeast comer of the Site.
37 • O&M activities include maintenance of the riprap as needed, to avoid compromising the integrit> of the protection system.
Because tliis alternative includes full removal of contaminated sediments, long-term contaminant monitoring is not necessan.
9.2.3 Sedinient -\lteriiati\e SD-3: Sedunent Dredgmg and Oii-Site Disposal
Estimated Capital Cost: SI1,785,200 Estimated 0,&.MCost: S-fJ7,J00 Estimated Total Present Worth Cost: $12,222,500 Estimated Time to Design and Construct: 2-J years- Estimated Time to Achieve R.\Os: 5 Years
Alternative SD-3 is identical to Alternative SD-2 except that the contaminated sediment would be stabilized and consolidated on-site in a specific containment area rather than taken off-site for disposal.
9.2.4 Sedinient -\lternati\e SD-4: Sedunent C'appuig; ICs
Estimated Capital Cost: $5,818,-400 Estimated O&M Cost: $1,716,300 Estimated Total Present Worth Cost: $7,534,700 Estimated Time to Design and Construct: 2 Years- Estimated Time to Achieve R.\Os: 5 Years
.Alternative SD-4 consists of the follow ing remed\ components:
• Contaminated sediment would be capped with a reactive material (e.g.. ZA'I) intended to increase the design-life of the cap (i.e.. the time it takes for the C(!)Cs to break through the cap). The reactive material might be mixed with granular material or deplo\ ed in the fonn of a penneable composite consisting of reactive material(s) encapsulated in a non-woven core matrix bound bet\veen two geotextiles. Treatabilitx studies would be required in the design phase to select appropriate reactive material. Tlie cap would be overlain with armoring to minimize erosion. Tliickness and composition of cap material would be determined during remedial design. In addition, studies to select the appropriate annoring would also be conducted during the remedial design.
• Turbiditx curtains would be placed around the contaminated sediment to control turbiditx during sediment remedial actions.
• The embankment (approximately 700 linear feet of shoreline) w ould be straightened and protected with a riprap s\ stem to prevent erosion. Tlie shoreline protection material would tie into the existing .T.AXPORT bulkhead located in the northeast comer of the Site and extend to along St. .Tolins River shoreline to the southeast comer of the Site.
• ICs will be employed to ensure long-tenn protectiveness of the remedy including maintenance of the cap to ensure continued protectiveness.
• (!)&M activities include maintenance of the riprap and armoring as needed, to avoid compromising the integrity of the protection system.
38 9.2.5 Sedinient Alteriiati\e SD-5: Eii\1roiiiiieiital Bulkliead Construction; ICs
Estimated Capital Cost: $11,965,900 Estimated O&MCost: $2,933,400 Estimated Total Present Worth Cost: $14,899,300 Estimated Time to Design and Construct: 5 years- Estimated Time to Achieve R.\Os: 5years
Alternative SD-5 consists of the following remecK components:
• An environmental bulkhead w ould be installed along the perimeter of the contaminated sediment. Limited areas outside the perimeter would be dredged. Tlie dredged material would be placed witliin the containment area. Backfill material would be placed beliind the bulkhead to match the grade of the low-permeabilit> cap installed on the Site and will be sloped to allow for management of stoimwater mn-off. Tlie bulkhead is estimated to be approximately 1.000 feet long and 60 feet high and w ould follow the general outline of the contaminated sediments adjacent to the shoreline. The bulkhead would be constmcted in accordance with applicable regulations. The design will be finalized during the remedial design, but for costing puiposes in the FS. the bulkhead was estimated to be a minimum of 2 feet above the cunent waterline and extend below the river bed approximateh 25 feet. .Along the approximateh 200-foot-wide section of bulkhead betw een the shoreline and the noilh-to-south portion of the bulkhead, the w all w ould decrease gradualh in height as it traversed from the 30-foot deep water toward the shoreline. For costing purposes in the FS. the bulkhead w as assumed to be constmcted of sheet pile, w ith I- beams steel pipe supports and tie-backs used as necessan. Final constmction material and support requirements will be deteiTnined during remedial design. Debris removal along the bulkhead location will be perfoiTned before bulkhead installation.
• Turbiditx curtains would be placed around the contaminated sediment to control turbiditx during sediment remedial actions.
• ICs will be employed to ensure long-teiTn protectiveness of the remedy including maintenance of the bulkhead and the area enclosed b\ the bulkhead to ensure continued protectiveness.
• O&M activities w ould include maintaining the integritx of the bulkhead.
9.3 Groundwater Alteriiati\es G\\ -1 to G\\ -9
9.3.1 Groundwater -\lteriiati\e G\\ -1: No .Action
Estimated Capital Cost: $0 Estimated O&M Cost: $0 Estimated Total Present Worth Cost: $0 Estimated Time to Design and Construct: .\ot Applicable Estimated Time to Achieve R.\Os and Cleanup Levels: >100 Years
.As required In the NCP. this alternative was evaluated to compare to other groundwater alternatives. Lender tliis alternative, no action would be taken and contaminated groundwater would remain in its cunent condition. Tliis alternative does not provide protection from the risks associated with groundwater contamination.
39 9.3.2 Groundwater Alternative G\V-2: MNA/LTM; ICs
Estimated Capital Cost: SO Estimated O&M Cost: $2,175,400 Estimated Total Present Worth Cost: $2,175,400 Estimate Time to Design and Construct: 0 years- Estimated Time to Achieve R.\Os and Cleanup Levels: >100 Years
Alternative G\V-2 consists of the following components:
• NINA Long-teiTn monitoring (LTM) will be performed by monitoring well sampling and analysis for C(!)Cs and geochemical parameters until RA(!)s and cleanup levels are achieved. The objective of the NINA LTM program would be to document C(!)C concentrations in groundwater and verif> the natural attenuation mechanisms that would decrease dissolved C(!)Cs and stabilize or shrink the plume (e.g.. dispersion, dilution, soiption. volatilization, and intrinsic biodegradation). (!)ccurrence and rate of natural attenuation would be deteiTnined In monitoring spatial and temporal changes in C(!)C concentrations, the presence of contaminant degradation and end products, changes in microbial respiraton reactants and products, and groundwater geochemistiv. to confinn that conditions remain favorable for biodegradation. Tlie actual LTM plan would be finalized in the remedial design. Groundwater fate and transport modeling would be peifoiTned during the remedial design to further evaluate MN.A processes and improve the monitoring program.
• ICs. such as groundwater extraction well installation restrictions tluoughout the contaminated groundwater plume, will be implemented to prevent human exposure to the contaminated groundwater.
• .A surface water LTM program will be developed and implemented to verifx and document that surface water cleanup levels have been acliieved.
Groundwater would not be suitable for potable use until cleanup levels are reached, wliich would take in excess of 100 years with tliis remedy.
9.3.3 Groundw ater -\Iteriiati\ e G\\ -3: Iii-Situ Treatment of Groundw ater usuig Z\T; MNA/LTM; ICs
Estimated Capital Cost: $18,348,400 Estimated O&M Cost: $2,075,100 Estimated Total Present Worth Cost: $20,423,500 Estimated Time to Design and Construct: 2-3 Years- Estimated Time to Achieve Cleanup Levels: >30 Years
.Alternative G\V-3 consists of the following components:
• ZA'I w ould be applied in-situ in portions of the plume w ith liigh concentrations of clilorinated solvents, pesticides, and metals (arsenic, chromium, lead, nickel, and copper). In .Alternative G\V- 3. powdered ZA'I would be applied in on-site source areas where soil and groundwater concentrations are significantly higher than cleanup levels. .As identified based on previous sampling at the site, these areas are located around the source areas of the foiTner operation including the F.ASC(!) building and the pesticide storage warehouse. In addition, an area on the eastern portion of the Site in the vicinitx of the foiTner acid plant also exliibits soil and groundwater concentrations that significantK exceed cleanup levels. The final treatment area w ould be determined during the remedial design. Implementation of this remedial approach w ill 40 address the source areas tluough active remediation and reh on NINA for the remainder of the contaminated groundwater in on-site and off-site areas outside active treatment zones.
• G\\"-3 assumes that NINA will address all remaining on- and off-site C(!)Cs in groundwater, including contamination on the .TAXPORT propeit>.
• ICs. such as groundwater extraction well installation restrictions tluoughout the contaminated groundwater plume, will be implemented to prevent human exposure to the contaminated groundwater.
• NIN.A LTM of the groundwater will be peifoimed to verifx and document that decreases in dissolved C(!)Cs and stabilization shrinking of the plume are occuning. Monitoring w ells w ill be sampled and analyzed for C(!)Cs and geochemical parameters in accordance with an MN.A LTM plan until R.A(!)s and cleanup levels are acliieved.
• .A suiface water LTM program will be developed and implemented to verifx and document that suiface water cleanup levels have been acliieved.
9.3.4 Groundwater Alteriiati\e G\\ -4: Iii-Situ Gheiuical Oxidation; MNA/LTM; It's
Estimated Capital Cost: $26,888,900 Estimated O&M Cost: $2,391,700 Estimated Total Present Worth Cost: $29,280,600 Estimate Time to Design and Construct: 3-4 Years Estimated Time to Achieve Cleanup Levels: >30 Years
.Alternative G\V-4 includes the following components:
Portions of the plume w ith elevated concentrations of pesticides and metals w ould be treated using in-situ chemical oxidation (ISCO). ISCO would be applied in on-site source areas including areas adjacent to the foiTner F.ASC(!) building, the foiTner pesticide storage warehouse, and the former acid plant, as described in Section 9.3.3. Implementation of ISCO would require both bench and pilot-scale studies prior to full-scale design and implementation activities to estimate the most effective oxidant activator pair and the dosage rate required to acliieve acceptable reductions in target COCs. The pilot-scale study would be utilized to verifx oxidant injection rates and required injection point spacing prior to full-scale implementation. Following completion of these studies, a full-scale design detailing the specific oxidant activator pair, areas, zones, and injection points would be completed.
• ICs. such as groundwater extraction well installation restrictions tluoughout the contaminated groundwater plume, will be implemented to prevent human exposure to the contaminated groundwater.
• MN.A LTM of the groundw ater w ill be peifoiTned to verifx and document that decreases in dissolved C(!)Cs and stabilization shrinking of the plume are occuning. Monitoring w ells w ill be sampled and analyzed for C(!)Cs and geochemical parameters in accordance with an MN.A LTM plan until R.A(!)s and cleanup levels are acliieved.
• .A suiface water LTM program w ill be developed and implemented to verifx and document that suiface water R.A(!)s have been acliieved.
G\\"-4 assumes that MN.A will address all remaining on- and off-site C(!)Cs in groundwater, including contamination on the .T.AXP(!)RT propeitx. 41 9.3.5 Groundwater Alteriiati\e G\\ -5: Peniieable Reacti\e Barrier; MNA/LTM; ICs
Estimated Capital Cost: $19,018,500 Estimated O&M Cost: $8,697,200 Estimated Total Present Worth Cost: $27,715,700 Estimated Time to Design and Construct: 3-4 Years Estimated Time to Achieve Cleanup Levels: >100 Years
Alternative G\V-5 includes the following components:
• A peiTneable reactive banier (PRB) system utilizing Z\'I mixed with sand and or granular activated carbon would be installed on the downgradient. eastern and or southern boundaries of the Site along the St. Jolins River and or Deer Creek to treat the contaminated groundwater. NIN.A LTM would be implemented for the remainder of the contaminated on-site and off-site groundw ater. To treat all of the C(!)Cs identified in the Site groundw ater, a minimum of t\vo PRBs with different media would be required. The PRB s\ stem location and depth would be deteiTnined during the remedial design to optimalh intercept the flow of groundw ater in the shallow and intermediate zones towards the St. .Tohns River and or Deer Creek. Tlie conceptual design of the PRB system used for cost estimating puiposes in the FS entails installing two approximateh 650-foot long. 50-foot deep trenches along the eastern propertx boundaiv into the top of the limestone. The trenches w ould provide in-situ treatment of the contaminated groundw ater plume. .An air-sparge curtain w ould also be installed as pail of the PRB s\ stem to treat the ammonia at the Site.
• Groundwater flow and fate and transport models would be required to properK design the PRB system. .A treatabilitx study and column testing would also be completed during remedial design to deteiTnine the PRB mix ratios and the required tliicknesses.
• ICs. such as groundwater extraction well installation restrictions tluoughout the contaminated groundwater plume, will be implemented to prevent human exposure to the contaminated groundwater.
• NIN.A LTM of the groundwater will be peifoiTned to verifx and document that decreases in dissolved C(!)Cs and stabilization shrinking of the plume are occuning. Monitoring w ells w ill be sampled and analyzed for C(!)Cs and geochemical parameters in accordance with an MN.A LTM plan until R.A(!)s and cleanup levels are achieved.
• .A suiface water LTM program will be developed and implemented to verifx and document that suiface water cleanup levels have been acliieved.
• O&M for G\V-5 would include evaluation of the condition and potential replacement of the PRB.
G\V-5 assumes that MN.A will address remaining on- and off-site COCs in groundwater outside the active PRB treatment zones, including contamination on the .T.AXPORT propeitx.
42 9.3.6 Groundwater Alteriiati\e G\\ -6: Cut-Off \\ all with P&T for Contaiiinient; MNA/LTM; K s
Estimated Capital Cost: 56,991,600 Estimated O&M Cost: 511,677,000 Estimated Total Present Worth Cost: 518,668,600 Estimated Time to Design and Construct: 2-J years- Estimated Time to Achieve Cleanup Levels: >100 Years
Alternative G\V-6 consists of the following components:
• Groundw ater w ould be contained In installing a cut-off w all potentialK around the entire perimeter of the Site to maintain h\ draulic control and to isolate and prevent discharge of contaminated groundwater to the St. Jolins River and Deer Creek. Groundwater levels inside the cut-off w all w ould be In draulicalh controlled through a P&T s\ stem. The final cut-off w all design would be deteiTnined during remedial design, but for costing puiposes. it was estimated to be 2 feet tliick. 5.000 feet long and 50 feet deep and constmcted of a soil-bentonite mixture. .A bench-scale treatabilitx stud\ might be required to develop a proper design mix for the sluriv wall, wliich ma\ include cement or other strengthening agents as needed to protect the stabilitx of adjacent stmctures. In addition, during the remedial design, geoteclinical investigations (boring and geoteclinical anah sis of soil) would be required along the alignment of the proposed wall to better understand the geolog\ and ph\ sical properties of the soil, and to deteiTnine the depth of installation. The final location of the cut-off w all w ould be deteiTnined tlu ough modeling during design. If installation near the northern propertx boundaiv is required, additional evaluation of the minimum setback from the existing stmctures on the .T.AXP(!)RT propeitx would also be required during design.
• The P&T s\ stem would maintain In draulic control witliin the containment structure: pumping rates and recoveiv well locations would be deteiTnined during remedial design. For costing puiposes in the FS. the s\ stem was assumed to recover up to 20 gallons per minute (gpm) to maintain the groundwater level. Recovered groundwater would be treated through an aboveground treatment s\ stem prior to discharge to the publicK-owned treatment works (P(!)T\\") under a peimit issued In the P(!)T\\".
• ICs. such as groundwater extraction well installation restrictions tluoughout the contaminated groundwater plume, will be implemented to prevent human exposure to the contaminated groundwater.
• NIN.A LTM of the groundwater will be peifoiTned to verifx and document that decreases in dissolved C(!)Cs and stabilization shrinking of the plume are occuning. Monitoring w ells w ill be sampled and analyzed for C(!)Cs and geochemical parameters in accordance with an MN.A LTM plan until R.A(!)s and cleanup levels are achieved.
• .A suiface water LTM program will be developed and implemented to verifi and document that suiface water R.A(!)s have been acliieved.
• O&M activities would encompass cut-off wall inspections and maintenance and P&T system maintenance.
G\\"-6 assumes that MN.A will address all remaining on- and off-site C(!)Cs in groundwater, including contamination on the .T.AXP(!)RT propeitx.
43 9.3.7 Groundwater Alteriiati\e G\\ -7: Iii-Situ Stabilization/Solidification of Groundwater; MNA/LTM; ICs
Estimated Capital Cost: 520,983,700 Estimated O&M Cost: 52,075,100 Estimated Total Present Worth Cost: 523,058,800 Estimated Time to Design and Construct: 2-3 years- Estimated Time to Achieve R.\Os and Cleanup Levels :> 30 Years
Alternative G\V-7 consists of the following components:
• Saturated soil considered to be the source of C(!)C-loading to groundwater will be treated with ISS in the vicinit> of the fonuer FASCO and fertilizer buildings, former herbicide building and the former acid plant. Tliis alternative would stabilize saturated soil in the active remediation areas, immobilizing groundwater contaminants and preventing exposure In human and ecological receptors. ISS is a commercially-available teclinology and is specifically aimed at reducing the abilitx of groundwater to leach contaminants from the stabilized zone. .Appropriate stabilizing agents would be selected based on bench-scale studies to be completed during remedial design. Sampling and anah sis of the stabilized material w ould be perfoiTned to verifi that the performance objectives had been acliieved. Tlie ISS process is accomplished In delivering and vigorousK mixing the agent into the soil matrix using a track hoe or similar equipment at shallow depths. For deeper areas, the use of large diameter augers (likely 12 feet) would be employed to acliieve contact by the stabilizing agent with the saturated soil. .Additional investigation during the remedial design will define the treatment areas. The addition of the stabilization agent t> pically increases total matrix volume in the treatment zone. The monolith t> pically cures to a In draulic conductivity approaching 10'^ centimeters per second or low er. Samples of the stabilized solidified material would be cured and collected for analysis to detenuine physical and chemical properties, including unconfined compressive strength and leachability characteristic for pesticides and selected metals.
• ICs. such as groundwater extraction well installation restrictions tluoughout the contaminated groundwater plume, will be implemented to prevent human exposure to the contaminated groundwater.
• NIN.A LTM of the groundwater will be peifoiTned to verify and document that decreases in dissolved C(!)Cs and stabilization shrinking of the plume are occuning. Monitoring w ells w ill be sampled and analyzed for C(!)Cs and geochemical parameters in accordance with an MN.A LTM plan until R.A(!)s and cleanup levels are acliieved.
• .A surface water LTM program w ill be developed and implemented to verify and document that surface water cleanup levels have been acliieved.
G\\"-7 assumes that MN.A will address all remaining on- and off-site C(!)Cs in groundwater, including contamination on .T.AXPORT.
44 9.3.8 Groundwater Alteriiati\e G\\ -8: Hydraulic Contauunent by P&T; ICs
Estimated Capital Cost: $3,255,800 Estimated O&M Cost: $13,160,500 Estimated Total Present Worth Cost: $16,416,300 Estimated Time to Design and Construct: 2-3 years- Estimated Time to Achieve R.\Os and Cleanup Levels: >100 Years
Alternative G\V-8 consists of the following components:
• A P&T s\ stem w ould be installed to prevent discharge of contaminated groundw ater to the St. Jolins River and Deer Creek. Tlie P&T s\ stem would need to be robust enough to prevent continued discharge of groundw ater to the St. Johns River and Deer Creek, but w ould not be designed to fulK treat the contaminated groundwater plume. Groundwater modeling would be conducted during the remedial design to deteimine the appropriate extraction rates and other design parameters. Recovered groundwater would be treated tluough an aboveground treatment s\ stem prior to discharge to the P(!)T\\" tluough a discharge peiTnit issued In the P(!)T\\".
• ICs. such as groundwater extraction well installation restrictions tluoughout the contaminated groundwater plume, will be implemented to prevent human exposure to the contaminated groundwater.
• NIN.A LTM of the groundwater will be peifoiTned to verifx and document that decreases in dissolved C(!)Cs and stabilization shrinking of the plume are occuning. Monitoring w ells w ill be sampled and analyzed for C(!)Cs and geochemical parameters in accordance with an MN.A LTM plan until R.A(!)s and cleanup levels are achieved.
• .A suiface water LTM program will be developed and implemented to verifx and document that suiface water cleanup levels have been acliieved.
• O&M activities associated with the P&T system would be significant. In particular, iron concentrations in Site groundwater indicate that the iron fouling of the equipment will likely require continual management. Options for minimizing the impacts include a full-time treatment plant operator, refurbisliing of the recoveiv w ells each \ ear. and a more frequent change-out of treatment media than might be expected based on COC concentrations alone.
• (!)&M would also include sampling required for P(!)T\\" peiTnit compliance.
G\\"-8 assumes that MN.A will address all remaining on- and off-site C(!)Cs in groundwater, including contamination on the J.AXP(!)RT propeitx.
9.3.9 Groundwater Alteriiati\e G\\ -9: Groundwater P&T; MNA/LTM; IC s
Estimated Capital Cost: $4,139,550 Estimated O&M Cost: $26,412,850 Estimated Total Present Worth Cost: $30,552,400 Estimated Time to Design and Construct: 2-3 Years- Estimated Time to Achieve R.\Os and Cleanup Levels: >30 Years
.Alternative G\\"-9 consists of the follow ing remed\ components:
• .A P&T s\ stem w ould be installed to treat source areas of the groundw ater plume and to prevent discharge of contaminated groundwater into the St. Johns River and Deer Creek. Tlie extracted 45 contaminated groundwater would be treated prior to discharge to the P(!)T\\" tluough a permit issued In the P(!)T\\". The P&T s\ stem for G\\"-9 would be more robust and extensive than because in addition to h\ draulic containment control, source area treatment would also be accomplished with the implementation of G\\"-9. Although the treatment s\ stem design will be deteiTnined during remedial design, preliminaiy estimates used for cost estimating in the FS indicate that a 65-gpm [total] system may be required to operate for 30 years to meet the cleanup objectives.
• ICs. such as groundwater extraction well installation restrictions tluoughout the contaminated groundwater plume, will be implemented to prevent human exposure to the contaminated groundwater.
• NIN.A LTM of the groundwater will be peifoiTned to verifx and document that decreases in dissolved C(!)Cs and stabilization shrinking of the plume are occuning. Monitoring w ells w ill be sampled and analyzed for C(!)Cs and geochemical parameters in accordance with an MN.A LTM plan until R.A(!)s and cleanup levels are acliieved.
• .A suiface water LTM program will be developed and implemented to verifx and document that suiface water R.A(!)s have been acliieved.
• O&M activities associated with the P&T system would be significant. In particular, iron concentrations in Site groundwater indicate that the iron fouling of the equipment will likely require continual management. Options for minimizing the impacts include a full-time treatment plant operator, refurbisliing of the recoveiv w ells each \ ear. and a more frequent change-out of treatment media than might be expected based on COC concentrations alone.
• (!)&M would also include sampling required for P(!)T\\" peiTnit compliance.
G\V-9 assumes that MN.A will address off-site COCs in groundwater, including contamination on the .T.AXP(!)RT propem.
46 10.0 Summary of Comparative Analysis of Alternatives
The media-specific remedial alternatives were evaluated in accordance w ith the requirements of the NCP. CFR (40 CFR Part 300.430[e] [9] iii). CERCLA. and factors described in the GuiJance for ConJucting R1FS unJer CERCL4 (EPA. 1988).
The nine evaluation criteria include the following:
Threshold Criteria
• (!)verall protection of human health and the environment • Compliance with ARARs
Balancing Criteria
• Short-teiTn effectiveness • Long-teiTn effectiveness and penrianence • Reduction of mobilit>. toxicit>. or volume tluough treatment • Implementabilit> • Cost
Modifying Criteria
• State acceptance • Community acceptance
A comparative analysis of the alternatives based on the nine criteria is presented in the following sections. The objective of this anah sis is to compare and contrast the alternatives and to support the selection of a remedy to address the Site contamination. Table 10-1 presents a summan of the comparative analysis. Additional details regarding the comparative anah sis of the remedial alternatives are provided in Section 5 of the FS report.
10.1 Threshold Criteria
10.1.1 0\ eraU Protection of Huinan Health and the En\ironnient
(!)verall protection of human health and the environment addresses whether the alternative provides adequate protection of human health and the environment, and describes how risks posed tluough each exposure pathwa\ are eliminated, reduced, or controlled, tlu ough treatment, engineering controls, and or ICs.
Soil Alternatives
All soil alternatives, w ith the exception of the No Action alternative, w ould be protective of human health and the environment. SS-4 would reduce leacliing of C(!)Cs into groundwater and eliminate exposure to human and ecological receptors In removing the largest volume of contaminated soil and reducing stortuwater infiltration into contaminated soil. Alternatives SS-2. SS-3. SS-5. SS-6 and SS-7 would also reduce leaching and eliminate direct contact exposure by use of the low-penueabilitx cap and ICs.
47 Sediment Alternatives
All sediment alternatives, with the exception of the No Action alternative, are protective of human health and the environment by removing (SD-2 and SD-3) or isolating (SD-4 and SD-5) contaminated sediment in the St. .Tohns River.
Groumhvater Alternatives
Groundwater alternatives G\\"-5. G\\"-6. G\\"-8. and G\\"9 implemented alone would be protective of human health and the environment. How ever, implementation of groundw ater alternatives G\\"-2. G\\"-3. G\\"-4. and G\\"-7. individualh . would not prevent the discharge of residual groundwater contamination into the St. .Tolins River.
Because the No .Action alternatives (soil, sediment, groundwater) would not be protective of human health and the environment, the No .Action alternatives were not canied over for fuilher anah sis.
10.1.2 C'onipliance with .Applicable or Rele\ aiit and .Appropriate Requireinents
Section 121(d) of CERCL.A and the NCR §300.430(f)(l)(ii)(B) require that remedial actions at CERCL.A sites at least attain legalh applicable or relevant and appropriate federal and state requirements, standards, criteria, and limitations, wliich are collectiveK refened to as ".AR.ARs." unless such .AR.ARs are waived under CERCL.A § 121 (d)(4). .Applicable requirements are those cleanup standards, standards of control, and other substantive requirements, criteria, or limitations promulgated under federal environmental or state environmental or facilitx siting laws that specifically address a hazardous substance, pollutant, contaminant, remedial action, location, or other circumstance found at a CERCL.A site. Relevant and appropriate requirements are those cleanup standards, standards of control, and other substantive requirements, criteria, or limitations promulgated under federal environmental or state environmental or facilitx siting laws that, wliile not "applicable" to a hazardous substance, pollutant, contaminant, remedial action, location, or other circumstance at a CERCL.A site, address problems or situations sufficiently similar to those encountered at the CERCL.A site that their use is well-suited to the particular site.
(!)nl\ those state standards that are identified In a state in a timeh manner and that are more stringent that federal requirements ma\ be applicable. In accordance with 40 CER 300.400(g). EDEP and EP.A have identified specific .AR.ARs for the Selected Remedy. In addition, per 40 CER 300.405(g)(3). other advisories, criteria, or guidance may be considered in deteiTnining remedies (known as To Be Considered [TBC]). .AR.ARs identified for the Site are presented in Tables 8-6 tluough 8-8.
Soil Alternatives
.Alternatives SS-2 tluough SS-7 comply with chemical-specific and action-specific .AR.ARs. The State of Elorida direct exposure CTLs for commercial industrial applications (Chapter 62-777. E..A.C.. Contaminant Cleanup Target Levels) are the primaiy chemical-specific .AR.ARs for soil. SS-2 would rely on natural attenuation to meet chemical-specific .AR.ARs because contaminated soil would not be removed or treated.
Sediment Alternatives
.Alternatives SD-2 tluough SD-5 would comply with .AR.ARs (alternative or conseivative ESA's). CERCL.A activities that potentially impact navigable waters of the United States (U.S.) are required to compK with Clean W ater .Act regulations relating to discharges of dredge-and-fill materials into surface waters (EP.A. 1990a). Therefore. peiTnits from the U.S. .AiTn\ Coips of Engineers would be required for
48 sediment alternatives that include dredging, capping, and the bulkhead installation. Alternative SD-5 would also require State of Florida approval under the Sovereignt> Submerged Lands program. Lender the Clean W ater .Act. dew atering of sediment removed during dredging might also require an NPDES peimit to discharge the treated water off-site and back into the St. .Tolins River (EP.A 1990a).
Groumhvater Alternatives
.Alternatives GW -2 tluough GW -9 would compK with chemical- and action-specific .AR.ARs for MCLs GCTLs (Federal Primaiy and Secondaiy Drinking W ater Standards and State of Florida groundwater target cleanup levels [Chapter 62-777. F..A.C.. Contaminant Cleanup Target Levels]), well constmction abandonment and L^nderground Injection Control (LlC) requirements for injection. In addition, for GW -8 and GW -9. a peiTnit with the local P(!)TW" would be required under the Clean W ater .Act because an\ discharge from a CERCL.A site to a P(!)TW" is considered an off-site activit> subject to both the substantive and administrative requirements of the national pretreatment program, and to all applicable state and local pretreatment regulations (EP.A. 1990a).
10.2 Balancmg C riteiia
10.2.1 Long-Term Effecti\ eiiess and Pennanence
Long-teiTn effectiveness and pennanence refers to expected residual risk and the abilitx of a remed\ to maintain reliable protection of human health and the environment over time until the cleanup levels are met. Tliis criterion includes the consideration of residual risk that w ill remain on-site follow ing remediation and the adequacy and reliabilitx of controls.
Soil Alternatives
.Alternatives SS-2 tluough SS-7 would eliminate risk of contact with contaminated soil by human and ecological receptors. .Alternatives SS-3. SS-4 and SS-5 are more effective and peimanent (compared to .Alternatives SS-2. SS-6. and SS-7) because they entail removal of contaminated soil from the Site. Except for .Alternative SS-4. a low-permeabilit> cap would be used to prevent suiface water infiltration and the resultant leacliing of the remaining C(!)C-contaminated soil. The long-teiTn effectiveness of these alternatives would depend on proper maintenance of the low-peiTneabilit> cap. Because SS-4 would remove the majoritx of contaminated soil from the Site, it ranks liighest for long-teiTn effectiveness and pennanence. .Alternatives SS-2 tluough SS-7 includes removal of PTW".
Sediment Alternatives
.Alternatives SD-2 tluough SD-5 would provide long-teim effectiveness and peimanence. SD-5 would be more effective than SD-4 due to liigh cun ent of the St. .Toluis wliich would potentialh require extensive maintenance of the sediment cap. Because SD-2 w ould remove contaminated sediment from the Site completely, it ranks liighest for long-teim effectiveness and peimanence.
Groumhvater Alternatives
Groundwater alternatives GW -5. GW -6. GW -8. and GW"9 implemented alone would be protective of human health and the environment. How ever, implementation of groundw ater alternatives GW -2. GW -3. GW -4. and GW -7. individualh . would not prevent the discharge of residual groundwater contamination into the St. .Toluis River.
49 AnaK sis of the long-term effectiveness and peiTnanence of the groundwater alternatives includes the following:
• G\V-2 relies solely on NINA, and it is estimated that it would take more than 100 years to acliieve the RA(!)s and cleanup levels. However, alternatives G\\"-4. G\\"-7. and G\\"-9. wliich include active source area treatment, would acliieve RA(!)s and cleanup levels in approximateh 30 years.
• G\\"-5. G\\"-6. G\\"-8 and G\\"-9 prevent discharge of contaminated groundw ater to the St. .Tolins River by containing the plume.
• G\\"-5 relies on passive treatment of groundw ater prior to be discharged into the St. .Tolins River and therefore relies on NIN.A for source area treatment, which would take more than 100 \ ears to acliieve the R.AOs and cleanup levels.
• G\\"-9 ranks liighest for long-temi effectiveness and pemianence. Under G\\"-9. source area treatment and residual contaminated groundwater discharge into the St. .Tolins River are acliieved via P&T.
10.2.2 Reducmg Toxicity, Mobility or Volume through Treatment
Reduction of toxicitx. mobilitx. or volume tlu ough treatment refers to the anticipated peifomiance of the treatment teclinologies that may be included as part of a remedy.
SoU Alternatives
.All of the soil remedies w ould remove PTW" w liich w ould be treated, if required, prior to disposal to meet RCR.A land-disposal restrictions (LDRs). In addition, for soil alternatives SS-3 tluough SS-5. contaminated soil would be excavated and transported off-site for disposal. Tliese soils would also be required to meet RCR.A LDRs. For alternatives SS-6 and SS-7. contaminated soil would be treated on-site via in-situ or ex-situ stabilization and solidification. Therefore, alternatives SS-6 and SS-7 would be more effective in reducing toxicity. mobilitx or volume tlu ough treatment when compared to SS-2 through SS- 5. Reduction of toxicitx. mobilitx or volume tluough treatment would not be achieved under SS-2 since the contaminated soil would be contained in-place.
Sediment Alternatives
SD-2 and SD- 3 remove sediment, but of the t\vo. onl\ SD-3 calls for treatment of the sediment tlu ough stabilization. SD-4 would provide some reduction in toxicitx. mobilitx and volume of C(!)Cs through the use of a reactive material in the cap that w ould treat the contaminants and prevent breaktlu ough. SD-3 ranks liighest in this categon as it treats the largest volume of sediment.
Groumhvater Alternatives
In-situ treatment for alternatives G\\"-3 tluough G\\"-9 would reduce the toxicitx. mobilitx and or volume of C(!)Cs in groundwater tluough treatment either in-situ or through groundwater recoveiv and treatment. However, alternatives G\\"-3. G\\"-4. G\\"-7 and G\\"-9 rank liigher because the\ provide for the most reduction In activeh treating the areas where liigh C(!)C-impacted groundwater was obseived.
50 10.2.3 Shoi*t-Tenii Effecti\ eiiess
Shoi1-term effectiveness addresses the period of time needed to implement the remed\ and an\ adverse impacts that ma\ be posed to workers, the community , and the environment during constmction and operation of the remed\ until cleanup levels are acliieved.
SoU Alternatives
Appropriate safeguards and health and safet> protocols would be implemented for all soil alternatives to protect Site workers and the nearln communit> . Engineering controls would be used to manage truck traffic, minimize dust, manage stoimwater and control odors. Because contaminated soil must be disposed off-site, alternatives SS-3. SS-4 and SS-5 rank lower than the containment or treatment alternatives due to traffic impacts, although traffic control plans would be adopted to minimize such impacts. Remediation would be limited to on-site and neighboring properties for alternatives SS-2. SS-6. and SS-7. wliich would limit traffic impact on local roads. Treatment and containment alternatives would have less impact than the removal alternatives. SS-2 ranks liighest for these criteria.
Sediment Alternatives
.Alternatives SD-2 tluough SD-5 would be implemented with appropriate health and safet> protocols for Site workers. SD-2 would have the most significant impact on the community due to tmck traffic associated with off-site disposal. .Alternatives SD-4 and SD-5 would be the least disruptive to the community. SD-4 would take the least time to implement. SD-5 would take the longest time to implement. .All alternatives would include the use of turbidit> curtains and other measures to minimize impacts to the St. .Tolins River.
Groumhvater Alternatives
For all groundwater alternatives, proper health. safet>. engineering controls and traffic management measures would be used to prevent exposure to groundwater C(!)Cs In Site workers and or exposure to the communitx during implementation of the groundwater remed\. .Alternatives G\\"-2. G\\"-5. G\\"-8 and G\\"-9 rank liighest for short-teiTn effectiveness because the\ are less dismptive and have lower exposure time frames. In addition, operations of heavy equipment under these alternatives may be less extensive, therein reducing the risk of injuiv to Site workers.
10.2.4 Iinplenientability
Implementabilitx addresses the teclinical and administrative feasibilitx of a remedy from design through construction and operation. Factors such as availabilitx of seivices and materials, administrative feasibilitx . and coordination with other government entities are also considered.
Soil Alternatives
Remedial technologies for all soil alternatives are well established and have been implemented at many sites with readily available equipment, teclinical specialists, contractors, and materials. .Alternatives SS-6 and SS-7 would require selection of appropriate reagents and specialized mixing equipment. On-site containment and treatment alternatives (SS-2. SS-6 and SS-7) rank liigher than off-site disposal alternatives (SS-3. SS-4 and SS-5) because they require less tmck traffic on nearby streets and reduced landfill coordination. SS-2 ranks highest for implementabilitx.
51 Sediment Alternatives
Remedial teclinologies for dredging and capping alternatives (SD-2. SD-3. and SD-4) are well established and have been implemented at many sites of similar or greater size and complexity. Because of off-site disposal requirements. SD-2 would have the most impact on local roads. Administrative requirements associated with obtaining required peiTnitting. under the Clean W ater Act. from the U.S. .Army Coips of Engineers and State of Florida approval under the Sovereignty Submerged Lands program could delay or impede installation of the bulkhead (SD-5).
Groumhvater Alternatives
Remedial technologies for all groundwater alternatives are well established and have been implemented at many sites of similar or greater size and complexity. Remedy peifoimance would be evaluated by periodic groundwater monitoring. Florida LlC program peiTnits would be required for alternatives GW -3 tluough GW -5 and GW -7. P&T alternatives (GW -6. GW -8 and GW -9) would require a peiTnit from the .Tacksonville Electric .Authority to discharge treated groundwater to the P(!)TW" as well as provisions to address expected iron fouling of treatment equipment, especially for GW -8 and GW -9. wliich rank lowest for implementability.
10.2.5 Cost
Cost estimates for all remedial alternatives (using an effective discount rate of 7 percent) were developed durins the FS and are summarized In media in Exliibits 3 tluoush 5.
Exliibit 3 Present Worth Costs for Soli .Alternate es
Soil .Alternative Capital Cost O&M Cost Total Cost
SS-2 - Renio\'al of PTW": Installation of Low-Permeability S12.5^^^UoOO S1.'UU800 S14.31A400 Cap: ICs SS-3 - Remo\'al of PTW": E\ca\'ation and (OtY-Site Disposal of Contaminated Soil Posing a Direct Exposure Contact Risk S2'.181.000 SI.'05.500 S28.88o.500 (Exceeding Commercial Industrial CTLs): Installation of Low- Penneability Cap: ICs SS-4 - Remo\'al of PTW": Exca\'ation and (OtY-Site Disposal of Contaminated Soil Posing a Direct Exposure Contact Risk S3^Uo04.400 SI.'05.500 S4L30A^^00 (Exceeding Commercial Industrial CTLs) and a Risk to Groiuidwater \ia Leacliins (Exceedins Leachabilir\' CTLs) SS-5 - Remo\'al of PTW": Exca\'ation and (OtY-Site Disposal of S2o.'o0.400 SI.'05.500 S28.4o5.^^00 Hot Spot Soil: Installation of Low-Penneability Cap: ICs
SS-o - Remo\'al of PTW": Exca\'ation of Hot Spot Soil: Ex-Situ Stabilization (On-Site Consolidation: Installation of Low- S20.U^8.400 SI.'05.500 S21.'•^03.^^00 Penneability Cap: ICs SS-" - Remo\'al of PTW": In-Situ Stabilization Solidification of S18.21'.^^00 SI.'05.500 S1A^^23.400 Hot Spot Soil: Installation of Low-Penneability Cap: ICs Notes: Costs are rounded to the nearest Si 100. Present worth costs are shown in 2015 U.S. Dollars (S). .A discount rate of" percent is applied to the estimated costs
52 Exliibit 4 Present Worth Costs for Sediment .Alternate es
Sediment .Alternative Capital Cost O&M Cost Total Cost
SD-2 - Sediment Dredging and (Dff-Site Disposal SI 0.31".800 S43T300 S10."55.100 SD-3 - Sediment Dredsins and (Dn-Site Disposal SI 1."85.200 S43T300 S12.222.500 SD-4 - Sediment Capping: ICs S5.818.400 Sl."lo.300 S".534."00 SD-5 - En\'ironmental Bulkhead Coiistniction: ICs Sll.^HxN^^OO S2.^U\^.400 S14.8^^A300 Notes: Costs are rounded to nearest S100. Present worth costs are shown in 2015 U.S. Dollars (S). .A discount rate of" percent is applied to the estimated costs.
Exliibit 5 Present Worth Costs for Groundwater .Alternatri es
Groundwater .Alternative Capital Cost O&M Cost Total Cost
G\V-2-MN.ALTM:lCs SO S2.1 "5.400 S2.1"5.400 G\\'-3 - In-Situ Treatment of Groundwater iLsins Z\'l: SI 8.348.400 S2.0"5.100 S20.423.500 MN.ALTMilCs G\\'-4 - In-Sim Chemical (Oxickition: MN.A LTM: ICs S2o.888.^^00 S2.3^N."00 S2^U280.o00 G\\'-5 - Penneable Reacti\'e Barrier: MN.A LTM: ICs S FLO 18.500 S8.(.w^".200 S2"."15."00 G\\'-o - Cut-(l)ff\\'all with P&T for Containment: MN.A LTM: So.^^^M.oOO SI Lo"".000 S18.oo8.o00 ICs G\\'-" - In-Situ Stabilization Soliditication of Groundwater: S20.^^83."00 S2.0"5.100 S23.058.800 MN.A LTM: ICs
G\\'-8 - H\ draulic Containment b\- P&T: ICs S3.2 55.800 S13.lo0.500 Slo.41o.300
GW-'-t - Groiuidwater P&T: MN.A LTM: ICs S4.13Ao00 S20.412.800 S30.552.400
Notes: Costs are rounded to nearest Si 100. Present worth costs are shown in 2015 U.S. Dollars (S). Discount rate of" percent is applied to the estimated costs.
10.2.6 Moclifjiiig Criteria
State Acceptance
The State of Florida, as represented In FDEP. has been activeh involved in the development and review of the FS report and the Proposed Plan. FDEP has expressed its support for the Selected Remed\ .
Conununity Acceptance
EPA conducted a public meeting on September 28. 2016 to present the Proposed Plan to the public. The prefen ed remed\ in the Proposed Plan and presented at the public meeting w as the combination of Soil .Alternative SS-2. Sediment .Alternative SD-5. and Groundwater .Alternatives G\\"-7 and G\\"-8.
53 The communis indicated support for the prefened alternatives during the meeting. W ritten comments were received during the public comment period, and were considered during preparation of tliis R(!)D. A cop\ of the comments and w ritten responses is included as Appendix A of this R(!)D.
54 11.0 Principal Threat Waste
The NCP establishes an expectation that EPA will use treatment to address the principal tlueats posed In a site wherever practicable (40 CFR §300.430(a)(l)(iii)(A)). IdentifSing PTW combines concepts of both hazard and risk. In general. PTW" are those source materials considered to be higlil\ toxic or liiglil\ mobile which generally cannot be contained in a reliable manner or would present a significant risk to human health or the environment should exposure occur. Converseh . non-PTW" are those source materials that generalh can be reliabh contained and that would present onl\ a low risk in the event of exposure. Tlie manner in which principal threats are addressed generalh w ill deteiTnine whether the statuton preference for treatment as a principal element is satisfied.
PTW" has been identified in t\vo areas at the Site. Tlie scmbber sludge pile located along the Site boundaiv with the CSX propei1> and consisting of teclinicalh enlianced naturalh occuning radioactive material (TENORNI) was identified as PTW" because of the potential radiologic hazard it poses to human health and the environment. The radiological suivey indicated an area of approximately 12.700 square feet where radioactive levels exceeded the background levels. .An estimated pile depth of 3 feet \ ields approximately 1.400 cubic yards of radiological material to be managed as PTW".
The approximate 750 cubic \ ards of green sludge identified in the foiTner suiface impoundment w as also identified as PTW" because, it has characteristics consistent with a semi-liquid and the potential to be "liiglily mobile." W liile the sludge volume is estimated at 750 cubic yards, the 4.500-square-foot footprint of the foiTner suiface impoundment (75 feet by 60 feet) is likely contaminated and is planned for removal as PTW". Investigations have identified sludge material as deep as 13 feet bis. which equates to 1.350 cubic \ aids over the impoundment footprint.
.As discussed in Section 12. PTW" materials at tliis Site will be addressed through excavation and off-site disposal. Depending on the characteristics of the PTW". off-site treatment to meet RCR.A LDRs might be required prior to disposal at a RCR.A Subtitle C or D facilitx .
55 12.0 Summary of Selected Remedy
12.1 Selected Remedy
Based on the combined media-specific alternatives evaluated in the FS. the EPA-Selected Remedy consists of the following components to address the Site contamination.
Soil - Alternative SS-2: Removal ofPTW; Installation of Low-Permeability Cap; ICs
• Removal and off-site treatment disposal of PTW" from foiTner scmbber sludge pile and suiface impoundment:
• Removal and on-site consolidation of constmction debris and contaminated soil from the CSX propertv directh adjacent to the Ken-McGee propeitv. Site-specific impacted soil on the JAXP(!)RT propeitv will be left in-place beneath the existing cap:
• Constmction of a low-peiTneabilit> cap (with stoimwater management features) over the footprint of the Ken -McGee propertv : and
• Implementation of ICs to ensure long-teiTn protectiveness of the remedy. .Anticipated ICs include: Implementation of a soil management plan for each propeitx where soil with Site-specific C(!)C concentrations above levels that w ill allow um estricted use: implementation of restrictive covenants for commercial industrial land use (CSX and Kerr-McGee properties): maintenance of the existing cap on the J.AXP(!)RT"s propeitx and the low peiTneabilitx cap on the Ken-McGee propei1>.
Sediment - .Alternative SD-5: Environmental Bulkhead Construction; ICs
• Installation of an environmental bulkhead seaw all to contain contaminated sediment in-place in the St. Jolins River:
• Removal and on-site consolidation of concrete and other constmction debris from the St. Johns River along the environmental bulkhead perimeter:
• Excavation dredging and consolidation within the containment area of contaminated sediment outside the environmental bulkhead perimeter:
• Backfilling of the 2.5-acre area enclosed by the bulkhead:
• Implementation of ICs (maintenance of bulkhead seawall and containment area) to ensure long- teiTn protectiveness of the remed\ :
• Fish tissue sampling will be performed during the remedial design. The EP.A in collaboration with FDEP and FD(!)H will evaluate the data collected during the sampling activities to deteimine whether or not a fish consumption advison is necessaiv for the area of the St. Jolins River adjacent to the Site: and
• Development and implementation of a surface w ater LTM program to verifx and document that surface water cleanup levels have been acliieved. Surface water samples will be collected and analyzed for surface water C(!)Cs (ODD. gamma clilordane. aluminum, copper, iron, and mercuiv ) and several chemicals (alpha-BHC. beta-BHC. dieldrin. total PCBs. and lead) that were
56 detected during the RI at levels above the surface water qualit> criteria in suiface water or pore water samples, but were screened out tluough the ecological risk assessment process. As a result, these chemicals are not identified as C(!)Cs for surface water. However, as requested b\ FDEP. these chemicals w ill be included as pail of the surface w ater LTM.
Groundwater - .Alternatives G\V-7 In-SItu Stablllzatlon of Groundwater and G\V-8 Hydraulic Containment with P&T; MN.A/LTM; ICs
• ISS of contaminated, unsaturated and saturated soil in the vicinitv of the former F.ASCO. herbicide and sulfur grinding buildings as well as the former acid plant, where the liighest. Site- specific C(!)C concentrations have been obseived in soil and groundwater due to liistoric operations (i.e.. "source areas"). During the remedial design, additional investigation will be conducted to refine the lateral and vertical extent of the areas where ISS will be implemented. In addition, bench and or pilot scale testing will be performed to identify the most effective ISS injection material and to refine the design parameters prior to full-scale implementation:
• Installation and operation of a groundw ater P&T s\ stem to prevent discharge of contaminated groundwater to the St. .Johns River and Deer Creek:
• Implementation of ICs. such as groundwater extraction well installation restrictions tlu oughout the contaminated groundwater plume, to prevent human exposure to the contaminated groundwater: and
• Development and implementation of a groundwater LTM plan to assess the effectiveness of the remed\ and to verifx that the residual dissolved groundwater plume is naturalK attenuating. .As part of the LTM plan, additional groundwater monitoring wells will be installed in the surficial aquifer on the CSX propeitx and groundwater samples will be collected and anah zed. Tlie collected groundw ater data will be utilized to evaluate the potential migration of site-specific C(!)Cs from the soil into the groundw ater. If the collected data indicate that soil C(!)Cs are migrating into the groundwater, additional soil sampling will be conducted on the CSX propertx to determine the extent of soil w ith C(!)C concentrations above site-specific leachabilitx criteria, wliich will be developed during the remedial design. Soil with C(!)C concentrations above these criteria will addressed via containment, excavation, or in-situ treatment.
.As required In the NCP. Five-A'ear review s w ill be conducted to ensure the effectiveness of the Selected Remedy. .A conceptual layout of the Selected Remedy is presented on Figure I2-I.
12.2 Rationale for the Selected Remedy
The Selected Remed\ was chosen over the other alternatives because of its overall potential effectiveness and efficienc\ in addressing the soil, sediment, groundwater, and surface water contamination and peiTnanenth reducing long-term risk. .As discussed above. PTW" materials will be excavated and disposed off-site, following treatment to meet LDRs as required, and contaminated groundwater source areas will be stabilized. These actions will significantly reduce the volume, mobilitx. and toxicity of the residual contamination. The Selected Remedy will provide for peimanent long-term risk reduction. In addition, as discussed in Section 10.2.4. the Selected Remedy will result in the least traffic disruptions, and thereby less inconvenience to the sunounding community.
12.3 Selected Remedy Cost
The estimated total present worth cost for the Selected Remed\ is approximateh S69 million, and a
57 summan of the cost estimate is provided in Table 12-1. The cost estimate is based on the best available infoiTnation regarding the anticipated scope of the remedial action and includes a discount rate of 7 percent. Changes in the cost elements are likely to occur as a result of new infoiTnation and data collected during the remedial design.
Major cost changes may be documented in the foiTn of a memorandum to the .AR. an Explanation of Significant Differences (ESD) or a ROD amendment (.AROD). The projected cost is based on an order-of- magnitude engineering cost estimate that is expected to be witliin +50 or -30 percent of the actual project cost. Costs are based on the conseivative estimate of a 30-year timeframe until all the cleanup levels are met.
12.4 Expected Outcomes of Selected Remedy
The Selected Remed\ w ill provide protection of human health and the environment In eliminating, reducing, or controlling risks at the Site tluough removal, treatment, containment, and the implementation of ICs. Tlie Selected Remedy also meets the statutoiy preference for treatment of PTW materials to the extent practicable. Depending on the characteristics of the PTW. off-site treatment to meet RCR.A LDRs might be required prior to disposal at a RCR.A Subtitle C or D facilitx.
.After the remed\ has been implemented, the Site will be suitable for general commercial and industrial use. Tliis land use is consistent with the Citx' of .Tacksonville's Comprehensive Plan (Citx' of .Tacksonville. 2016) in which the propeitx is designated in the industrial land-use categoiv "Water Dependent-Water Related." Tliis categoiv is intended for industrial land uses that require deep water access to the St. .Johns River and located within the "Industrial Sanctuaiv ." The Site would be available immediately upon completion of the low-peiTneabilitv cap. in an estimated 5 years.
Implementation of the Selected Remedy and ultimate achievement of the final cleanup levels w ill accomplish the R.AOs for the Site. Immediately upon completion of constmction and implementation of the ICs. potential exposure to Site contamination w ill be eliminated, thus ensuring protection of human health and the environment. The time required to actualK achieve the Site groundwater cleanup levels w ill be developed follow ing collection of additional groundw ater monitoring data and completion of the groundwater modeling during the remedial design. Tliis infoiTnation will be presented in the Five-A'ear Review report, which will be added to the .AR. During treatment, groundwater beneath the Site will not be suitable for an\ use. However, following completion of cleanup, the groundwater will be suitable for use as a drinking water source. The cleanup levels for the Site are presented in Tables 8-1 through 8-5.
58 13.0 Statuton Determinations
EPA believes the Selected Remed\ meets the threshold criteria and provides the best balance of tradeoffs among the other alternatives with respect to the balancing and modif> ing criteria. EPA expects the Selected Remedy to satisfx the following statutoiy requirements of CERCLA 121(b): (1) be protective of human health and the environment: (2) comply with ARARs (or justifx a waiver): (3) be cost-effective: (4) utilize peiTnanent solutions and alternative treatment teclinologies or resource recoveiy teclinologies to the maximum extent practicable: and (5) satisfx the preference for treatment as a principal element to the extent practical. The following sections discuss how the Selected Remedy meets these statutoiy requirements.
13.1 Protection of Human Health and the En\ ironinent
Tlie Selected Remed\ satisfies the statutoiv requirement for protection of human health and the environment b\ reducing eliminating exposure pathwa\ s associated with soil, sediment, groundwater, and suiface water containing Site-specific C(!)Cs with concentrations above the cleanup levels. Tliis is accomplished by implementing all the components of the Selected Remedy as presented in Section 12 of tliis R(!)D. To mitigate the groundwater exposure pathwa\ . suiTicial groundwater with C(!)Cs exceeding cleanup levels will be encapsulated b\ ISS containment witliin source areas. In addition, the low permeabilitx cap. wliich will be installed over the Site, will prevent migration of C(!)Cs from soil into the groundw ater. .A P&T s\ stem w ill also be installed to prevent fuilher migration of the residual contaminated groundwater into the St. .Tolins River and Deer Creek. ICs will also be implemented to protect human health and the environment.
13.2 C'ompliaiice with AR.\Rs
Section 121(d) of CERCLA and the NCR §300.430(0(1 )(ii)(B) require that remedial actions at CERCLA sites at least attain legalh applicable or relevant and appropriate federal and state requirements, standards, criteria, and limitations wliich are collectiveh refened to as ".AR.ARs." unless such .AR.ARs are waived under CERCLA § 121(d)(4).
.Applicable requirements are those cleanup standards, standards of control, and other substantive requirements, criteria, or limitations promulgated under federal environmental or state environmental or facilitx siting laws that specifically address a hazaidous substance, pollutant, contaminant, remedial action, location, or other circumstance found at a CERCL.A site. Relevant and appropriate requirements are those cleanup standards, standards of control, and other substantive requirements, criteria, or limitations promulgated under federal environmental or State environmental of facilitx siting laws that, wliile not "applicable" to a hazardous substance, pollutant, contaminant, remedial action, location, or other circumstance at a CERCL.A site, address problems or situations sufficiently similar to those encountered at the CERCL.A site that their use is well-suited to the particular site.
(!)nl\ those state standards that are identified In a state in a timeh manner and that are more stringent that federal requirements ma\ be applicable or relevant and appropriate.
In accordance with 40 CFR 300.400(g). FDEP and EP.A have identified specific .AR.ARs for the Selected Remedy. In addition, per 40 CFR 300.405(g)(3). other advisories, criteria, or guidance may be considered in determining remedies (known as TBC).
The Selected Remedy is expected to comply with all .AR.ARs. The chemical-specific, location-specific, and action-specific .AR.ARs identified for the Site are presented in Tables 8-6 tluough 8-8.
59 13.3 Cost Effecti\ eiiess
In EPA's judgment, the Selected Remedy is cost-effective and represents a reasonable value for the mone\ to be spent. In making this deteiTnination. the following definition was used: A remed\ shall be cost-effective if its "costs are proportional to its overall effectiveness" (40 CFR §300.430(0(I)(ii)(D)). The EPA evaluated the overall effectiveness of those alternatives that satisfied the tlu eshold criteria In assessing tluee of the five balancing criteria in combination. Those tluee criteria are: (I) long-teiTn effectiveness and peiTnanence. (2) reduction in toxicity , mobilitx . and volume tluough treatment, and (3) short-term effectiveness. (!)verall effectiveness was then compared to costs to deteiTnine cost- effectiveness. The relationship of the overall effectiveness of tliis remedial remed\ w as deteimined to be proportional to its costs: therefore, tliis remed\ represents a reasonable value for the mone\ to be spent. The estimated present worth total cost of the Selected Remedy is S69 million (see Table I2-I).
The Selected Remedy consists of a combination of media-specific alternatives evaluated in the FS Report that effectively and efficiently meets the R.AOs. Installation of the low-peiTneabilit> cap was the lowest cost alternative for soil and provides adequate protection of human and ecological receptors. In addition, the backfill w ill prevent further contamination of groundw ater through infiltration. Wliile construction of the environmental bulkhead was not the least expensive of the sediment remedies, it will result in fewer environmental impacts (such as potential resuspension redistribution of contaminated sediment) and less dismption to the neighboring facilities than the dredging alternatives. In addition, the environmental bulkhead will address potential scouring issues resulting from the St. .Tolins River cunent and sliip traffic.
The groundwater alternatives chosen for the Selected Remed\ (G\\"-7 and G\\"-8) represent the combination of alternatives that provide the most cost-effective solution to meeting the R.AOs. G\V-7 provides source treatment with greater certaintx than might be expected from the other source treatment options since it does not rely on chemical reactions of the treatment media with the site contaminants. G\\"-8 is the low est cost alternative for providing containment of the plume and preventing the discharge of contaminated groundwater to the St. .Tolins River and Deer Creek. The anticipated efficienc\ of G\\"-8 improves significantly with the installation of the environmental bulkhead (SD-5). by enliancing the potential for groundwater recoveiv. and limiting the potential for brackish water infiltration into the system.
13.4 Periiiaiieiit and -\lteniati\ e Treatment Solutions
The EP.A has deteimined that the Selected Remed\ represents the maximum extent to wliich peimanent solutions and treatment technologies can be utilized in a practicable manner at the Site. Of those alternatives that are protective of human health and the environment and comph with .AR.ARs. the EP.A has deteiTnined that the Selected Remed\ provides the best balance of trade-offs in teims of the five balancing criteria, while also considering the statutoiy preference for treatment as a principal element, and considering State and communitx acceptance.
The Selected Remed\ satisfies the criteria for long-teiTn effectiveness In removing PTW" from the Site and treating disposing of it off-site and In removing exposed contaminated soil from the CSX propei1> and consolidating it beneath the low-peiTneabilit> cap.
Installation of the low-peiTneabilit> cap protects human health and the environment by: isolating contaminated soil to prevent exposure to human and ecological receptors: preventing infiltration of rain w ater tlu ough contaminated soil and inliibiting the leacliing of contaminants from the soil into the groundw ater: and preventing migration of contaminated stoimwater from the Site onto the CSX propertx and into the St. .Toluis River.
60 Installation of the environmental bulkhead to contain contaminated sediment in-place in the riven and backfilling the 2.5-acre area enclosed In the bulkhead will protect human health and the environment b\ : isolating contaminated sediment within the bulkhead and preventing exposure of fish and other marine organisms in the St. Jolins River to contaminated sediment.
Implementation of ISS in the source areas and installation of a groundw ater P&T system w ill protect human health and the environment In : providing treatment of the areas w here the liighest Site-specific concentrations have been obseived in soil and groundwater: preventing C(!)C migration from contaminated soil to groundwater that ma\ result in concentrations above levels that are protective for drinking w ater: protecting fish and other marine organisms In preventing the discharge of contaminated groundwater to the St. Jolins River: and restoring contaminated groundwater to levels acceptable for future beneficial use as a drinking water resource.
Implementation of ICs ensures: future land uses are consistent with and protective of the remedy: long- teiTn maintenance of the low -peiTneabilit> cap and bulkhead is conducted: Site groundw ater is not used until cleanup levels have been acliieved: and exposure tluough fish tissue consumption does not put fishers at risk.
.A long-teiTn suiface water sampling and monitoring program will be implemented to assess the effectiveness of the remed\ in addressing the suiface w ater contamination.
13.5 Preference for Treatment as a Principal Element
The Selected Remedy utilizes a combination of excavation and off-site treatment disposal of PTW. PTW identified at the Site includes TEN(!)RM found near the southern propeitx boundan and the sludge material located at the fonner suiface impoundment. In both cases, the PTW" will be removed from the Site. (!)ff-site treatment to ensure compliance to LDR requirements, if necessan . will be conducted prior to final disposal. The Selected Remedy uses ISS of vadose and saturated soils in source areas of the Site and groundwater recoveiv and treatment to satisfx the statuton preference for treatment as a principal element.
13.6 Fi\ e-Vear Re\ iew Requirements
Section 121(c) of CERCL.A and the NCP §300.430(f)(5)(iii)(C) provide the statutoiy and legal bases for conducting Five-A'ear reviews. The Selected Remed\ is expected to result in hazardous substances, pollutants, or contaminants remaining on-site above levels that allow for unlimited use and unrestricted exposure. Tlierefore. statutoiv reviews will be conducted within five \ ears of initiation of remedial action for the Site to ensure that the remed\ is. or will continue to be. protective of human health and the environment. ICs and Five-A'ear reviews will be required until all soil, sediment, groundwater, and suiface water cleanup levels are acliieved.
61 14.0 Documentation of Significant Changes
To fulfill the CERCLA §117(b) and the NCP §300.430(f)(5)(iii)(B) and §300.430(f)(3)(ii)(A). the ROD must document and discuss the leasons for an\ significant changes made to the Selected Remed\ from the time the Proposed Plan was released for public comment to the final selection of the remed\ . The Selected Remed\ for the Site outlined in tliis R(!)D is the same as the preferred remed\ released in the Proposed Plan for public comment. Following review of all the comments received duiing the comment peiiod from September 12 to November 11. 2016. no substantial changes were made.
62 RECORD OF DECISION PART III Responsiveness Summary
The Responsiveness Summaiv for the Site has been prepared in accordance with the Comprehensive Environmental Response. Compensation, and Liability Act of 1980 (CERCLA). as amended by the Supeifund Amendments and Reauthorization Act (SARA), and the National Contingency Plan (NCR). 40 CFR §300.430(0- EPA's responses to comments received on the Proposed Plan during the public comment period are included in Appendix A.
The Proposed Plan for the Site was issued on September 12. 2016. .A public meeting was held on September 28. 2016 at the Matthew \V. Gilbert Middle School located at 1424 Franklin Street. .Tacksonville. Florida. .A written transcript from the meeting is included .Appendix B of tliis R(!)D and in the .AR file The original 30-day public comment period started on September 12. 2016 and ended on (!)ctober 12. 2016. .A request to extend the comment period was received and granted In EP.A. Tlie comment period ended on November 11. 2016. EP.A's responses to comments are included in .Appendix .A. Several questions were asked during the public meeting b\ the attendees after the presentation. EP.A's responses to these questions are documented in the meeting transcript, wliich is included in .Appendix B.
63 References
AECOM. 2013. Final Baseline Ecological Risk Assessment. Ken-McGee Chemical LLC Site. 1611 Talleyrand Avenue. .Tacksonville. Florida. May 2013.
.AECOM. 2016a. Final Human Health Risk .Assessment .Addendum. Ken-McGee Chemical Corporation Supeiiund Site. .Jacksonville. Florida. .August 2016.
.AECOM. 2016b. Final Feasibilit> Study. Ken-McGee Chemical Corporation Supeiiund Site. .Jacksonville. Florida. .August 2016.
Cit> of .Jacksonville. 2016. 2030 Comprehensive Plan. Future Land Use Element. .Jacksonville Planning and Development Department. .Jacksonville. Florida. Revised .July 2016.
FNSR. 2008a. Pore Water and Sediment Sampling Report. Ken-McGee Chemical LLC Site. .Jacksonville. Florida. .June 2008.
FNSR. 2008b. .Additional Sediment Sampling Report. Kerr-McGee Chemical LLC Site. .Jacksonville. Florida. December 2008.
FP.A. 1988. Guidance for Conducting Remedial Investigations and Feasibility Studies under CFRCL.A. Interim Final. FP.A 540 G-89 004. OSWFR Directive 9355.3-01. October 1988.
FP.A. 1989. Risk .Assessment Guidance for Superfund (R.AGS): A'olume 1 - Human Health Evaluation Manual (Part .A). Interim Final. Office of Emergency and Remedial Response. Washington. DC. FP.A 540 1-89 002. December 1989.
FP.A. 1990a. CFRCL.A Compliance with the CW.A and SDW.A. Office of Solid Waste and Emergency Response. Publication 9234.2-06 FS. Febmaiy 1990.
FP.A. 1991a. .A Guide to Principal Tlueat and Low Level Tlueat Wastes. (Office of Solid Waste and Emergency Response. Hazardous Site Control Division OS-220W. November 1991.
FP.A. 1991b. Tlie .Jolinson and Fttinger Model for Subsuiface A'apor Intmsion Into Buildings. 1991.
FP.A. 1991c. Risk .Assessment Guidance for Supeiiund A'olume 1: Human Health Evaluation Manual (Part B. Development of Risk-based Preliminaiy Remediation Goals). Interim. PB92-963334. Office of Emergency and Remedial Response. Wasliington. DC. 1991.
FP.A. 1991d. Solid Waste Disposal Facility Criteria: Final Rule. Part II. Federal Register. 40 CFR. Parts 257 and 258. U.S. Environmental Protection .Agency. Washington. DC. October 1991.
FP.A. 1994. U.S. Environmental Protection .Agency. Title 40: Protection of Environment. Part 300— National Oil and Hazardous Substances Pollution Contingency Plan. 59 FR 47416. September 15. 1994.
FP.A. 1997. Ecological Risk .Assessment Guidance for Supeifund: Process for Designing and Conducting Ecological Risk .Assessments. Interim Final. Wasliington. DC. FP.A 540-R-97-006. .June 1997.
FP.A. 1999. Use of Monitored Natural .Attenuation at Supeifund. RCR.A Coll ective .Action, and Underground Storage Tank Sites. .April 21. 1999.
64 References (Continued)
EPA, 2000. Administrative Order On Consent between EPA Region 4 and Kerr-McGee Chemical Corporation LLC for Conducting Remedial Investigation/Feasibility Study, March 31.
EPA, 2004. Risk Assessment Guidance for Superfund: Volume, Human Health Evaluation Manual (Part D, Standardized Planning, Reporting, and Review of Superfund Risk Assessments), Final, Pub. 9285.7- OlD, Office of Emergency and Remedial Response, Washington, DC, December 2004.
EPA, 2004. Risk Assessment Guidance for Superfund, Volume 1: Human Health Evaluation Manual (Part E, Supplemental Guidance for Dermal Risk Assessment), Final, EPA/540/R/99/005, Office of Emergency and Remedial Response, Washington, DC, July 2004.
EPA, 2009. Risk Assessment Guidance for Superfund, Volume I: Human Health Evaluation Manual (Part F, Supplemental Guidance for Inhalation Risk Assessment), Final, EPA-540-R-070-002, Office of Superfund Remediation and Technology Innovation, Washington, DC, January 2009.
EPA, 2014. Region 4 Human Health Risk Assessment Supplemental Guidance, Draft Final, Technical Services Section, Superfund Division, EPA Region 4, Atlanta, Georgia, January 2014.
EPA, 2014a. Radionuclide Preliminary Remediation Goals (PRG) Summary Table (TR=lE-6). Available online at: https://epa- prgs.oml.gov/radionuclides/download/summarv rprg table run pCi 25NOV14.pdf. November 2014.
EPA, 2014b. Radionuclide Preliminary Remediation Goals (PRG) User's Guide. Available online at: https://epa-prgs.ornl.gov/radionuclides/prg guide.html, November 2014.
EPA, 2015. Regional Screening Table User's Guide. Available online at: http://www2.epa.gov/risk/regional-screening-table-users-guide-iune-2015, June 2015.
FDEP, 2005. Final Technical Report: Development of Cleanup Target Levels (CTLs) for Chapter 62-777, F.A.C., Prepared by the Center for Environmental & Human Toxicology, University of Florida, Gainesville, Florida, Febmary 2005.
Geraghty & Miller (Arcadis), 1993. Contamination Assessment Report, CSX Talleyrand Avenue Site.
Leve, Gilbert W., 1966. Groundwater in Duval and Nassau Counties, Florida. Florida Geological Survey Report of Investigations No. 43.
Scott, Thomas M., 1988. The Lithostratigraphy of the Hawthom Group (Miocene) of Florida, Florida Geological Survey, Bulletin No. 59.
SERDP, 2009. Anaerobic Biostimulation for the In-situ Precipitation and Long-Term Sequestration of Metal Sulfides, SERDP Project ER-1373.
Shaw, 2005a. Human Health Risk Assessment, Kerr-McGee Chemical LLC Site, 1611 Talleyrand Avenue, Jacksonville, Florida, November 2005.
Shaw, 2005b. Ecological Risk Screening Evaluation, COPEC Refinement, Tronox LLC, 1611 Talleyrand Avenue, Jacksonville, Florida, December 2005.
65 References (Continued)
Shaw. 2006. Final Remedial Investigation Report. Tronox LLC Site. 1611 Talleyrand Avenue. .Tacksonville. Florida. .Tanuaiy 2006.
Shaw. 2007. PCS Investigation and Delineation Report. 1611 Talleyrand .Avenue. .Tacksonville. Florida. March 2007.
L^nited States Geological Suivey. 1981. 7.5 Minute Topograpliic Quadrangle Map for the .Arlington. Florida Quadrangle.
L^nited States Geological Suivey. 1993. 7.5 Minute Topograpliic Quadrangle Map for the .Tacksonville. Florida Quadrangle.
66 Tables Table 7-1 Chemicals of Concern (COCs) Summary Table Medium Conslilueni Subsurface Surface Soil Groutulwaler Sediment Surface Water Soil 1-Meiliylniipliilialene \ 1.2.4-Trimeiliylbenzene \ 1.2-Dicliloropropane \ 1.3.5-Trimeiliylbenzene \ 1.4-Diclilorobenzene \ 2-Meiliylnapliilialene \
2.3.7.8-TCDD (Total Equivalence) X \ 2.4-Dicliloroplienol \ 4-Cliloroaniline \ 4.4'-DDD \ \ \ \ \ 4.4'-DDE \ \ \ \ 4.4'-DDT \ \ \ Acenapliiliene \ .•M drill \ \ \ \ alpha-BHC \ \ \ \ alplia-Clilordane \ .•Mil nil mini \ \ .•Mimionia \ .•Miiimony \ .•Moclor 1254 \ \ \ \ .•Moclor 1260 \ .•Msenic \ \ \ Barium \ \ Benzene \ Beryllium \ beia-BHC \ \ \ \ Cadmium \ \ Clilordane (Total) \ \ Clilorobenzene \ Clilorometliane \ Cliromium \ \ \ cis-1.2-Dicliloroetliene \ Cobalt \ Copper \ \ \ delta-BHC \ Dibenzofuran \ Dieldrin \ \ \ \ Ethylbenzene \ Endrin \
Pii^-e I of 2 Table 7-1 Chemicals of Concern (COCs) Summary Table Medium Conslilueni Subsurface Surface Soil Groutulwaler Sediment Surface Water Soil Endosulfan I X X
Enclrin aldehyde X X
Endrin ketone X
Fluorene X ganinia-BHC (Lindane) X X X X ganinia-Chlordane X X
Hepiachlor X X
Hepiachlor epoxide X X
Hexachlorobenzene X
Iron X X X
Lead X X
Manganese X
Merciny X X
Naphthalene X
Nickel X
Nitrate X
Pentaclilorophenol X
Ra-226 X
Selenium X
Silver X
Tliallium X X
Toxaphene X X
Trichloroethene X
U-238 X
Vanadium X
Vinyl chloride X
Zinc X X
PiJi'C 2 of 2 Table 7-2 Exposure Point Concentration Summarx for Current/Future Scenario in Surface Soil Reasonable Maximum Exposure Scenario Timeframe: Current/Future Medium: Surface Soil Exposure Medium: Surface Soil Receptors: Maintenance Worker, Trespasser, Off-Site Resident, Industrial Worker Maximum Chemical of •Arithmetic Exposure Point Concentration Exposure Point Units 95®/o I'CL'" Concentration Potential Concern Mean'" (Distribution) (Qualifier) \'alue Units Statistic Rationale
Surface Soil Pesticides 4.4'-DDD mg kg 12.'o 3o.o" '-'>5®© Cheb\she\'( Mean. Sd) UCL 250 d 3o.o' mg kg '•U^®© UCL Eootnote (2) 4.4'-DDE mg kg 5.445 20.1' ^U^®© KM ChebvshevUCL 230 d 20.1' mg kg '•U^®© UCL Eootnote (2) 4.4'-DDT mg kg 38.23 115.2 ^U^®© KM Chebvshev UCL 1100 bd 115.2 mg kg '•U^®© UCL Eootnote (2) .Al drill mg kg 2.312 3."3 ^U^®© KM Chebvshev UCL 3^^ jd 3."3 mg kg '•U^®© UCL Eootnote (2) alpha-BHC mg kg 53.23 103.^^ ^U^®© KM Chebvshev UCL ^GO d 103.^^ mg kg '•U^®© UCL Eootnote (2) beta-BHC mg kg 13.3'-^ 34.00 osoo KM Chebvshev UCL 320 d 34.'-^'-^ mg kg '•U^®© UCL Eootnote (2) gamma-BHC (Lindane) mg kg 12.^^ 15.'1 ^U^®© KM ChebvshevUCL 130 d 15.'1 mg kg '•U^®© UCL Eootnote (2) Dieldrin mg kg 3.03^^ 8.ol 1 ^U^®© KM Chebvshev UCL '-Hi id 8.011 mg kg '•U^®© UCL Eootnote (2) Heptaclilor mg kg 5.304 10.84 '-T^®© •Approximate Gamma KM-UCL o3 d 10.84 mg kg '•U^®© UCL Eootnote (2) Toxaphene mg kg 304.O 200 8 OSOQ Approximate Gamma KM-UCL 2200 jd 200 8 mg kg '•U^®© UCL Eootnote (2) PCBs .Aroclor-1254 mg kg 1.'45 1.832 '-T^®© •Adjusted Gamma KM-UCL 12 1.832 mg kg '•U^®© UCL Eootnote (2) Dioxins and Furans TEQ mg kg 0.000108 0.0002'8 ^U^®© Smdent's-t UCL 0.00031 0.0002'8 mg kg '•U^®© UCL Eootnote (2) Inorganics •Arsenic mg kg 115.3 40'.' ^U^®© KM Chebvshev UCL 5100 dj 40'.' mg kg '•U^®© UCL Eootnote (2) Clirominm mg kg 30.23 4o.2^^ ^U^®© KM (t) UCL d j 40.2'-^ mg kg '•U^®© UCL Eootnote (2) Radionuclides Ra-22o pCi g NA 50.0 50.0 pCi g Max Eootnote (3) U-238 pCi g NA 51.5 51.5 pCi g Max Eootnote (3)
Notes: (1) .Aritluiietic mean and Upper Coiilklence Limit (UCL) were calculated iLsiiig EPA's ProUCL X'ersioii 5.0.00 statistical software package. Method used to compute selected UCL is shown. K.M - Kaplan-Meier (2) - Statistic: MiLximnm Detected \'alue (Max): UCL UCL). (3) - The '-U^®© UCL either could not be calculated or exceeded the maximiuu concentration: the maximum \'alne was selected as the exposure point concentration. NC - Not calculated
Pag.e I of I Table 7-3 Exposure Point Concentration Sum mart for Future Scenario in Subsurface Soil Reasonable Maximum Exposure Scenario Timeframe: Future Medium: Subsurface Soil Exposure Medium: Subsurface Soil Receptors: Construction Worker Maximum Chemical of •Arithmetic Ex'posure Point Concentration Exposure Point Units 95®/o I'CL'" Concentration Potential Concern Mean'" (Distribution) (Qualifier) \'alue Units Statistic Rationale
Snbsnrtace Soil Pesticides 4.4'-DDD mg kg 108.8 2'0.2 05®© KM Chelnshev UCL 5100 d 2'0.2 mg kg ^U^®©UCL Eootnote (2) 4.4'-DDE mg kg 41.48 130.2 05®© KM Chelnshev UCL 4o00 d 13'-'>.2 mg kg ^U^®©UCL Eootnote (2) 4.4'-DDT mg kg 152.'-t 411.5 05®© KM Chelnshev UCL 12000 d 411.5 mg kg ^U^®©UCL Eootnote (2) .Al drill mg kg '-T383 12.34 05®© KM Chelnshev UCL 350 d 12.34 mg kg ^U^®©UCL Eootnote (2) alpha-BHC mg kg 154.2 23' 05®© KM Chebyshev UCL 4300 d 23' mg kg ^U^®©UCL Eootnote (2) beta-BHC mg kg 28.02 53.2 05®© KM Chebyshev UCL 1300 d 53.2 mg kg ^U^®©UCL Eootnote (2) gamma-BHC (Linckme) mg kg o4.4 '3.1o 05®© KM Chebyshev UCL 1800 d '3.1o mg kg ^U^®©UCL Eootnote (2) Dieldrin mg kg o.ool 15.8' 05®© KM Chebvshev UCL 250 d 15.8' mg kg ^U^®©UCL Eootnote (2) Endosnltan 1 mg kg ro NC Too Eew Detections 340 d 340 mg kg Max Eootnote (3) Endrin .Aldelnde mg kg 20.'4 lo 05®© KM Chebyshev UCL 380 d lo mg kg ^U^®©UCL Eootnote (2) T oxaphene mg kg lOol 810.' 05®© KM Chebyshev UCL 20000 d 810.' mg kg ^U^®©UCL Eootnote (2) PCBs .Aroclor-1254 mg kg 2.ri 1.013 05®© •Approximate Gamma KM-UCL lo nm \P\3 mg kg ^U^®©UCL Eootnote (2) Dioxins and Furans TEQ mg kg 0.00021 0.000485' 05®© Smdent's-t UCL 0.00102 0.000485' mg kg ^U^®©UCL Eootnote (2) Inorganics •Arsenic mg kg 85.51 185.1 05®© KM Chelnshev UCL 5100 dj 185.1 mg kg ^U^®©UCL Eootnote (2) Clirominm mg kg 130.0 55o.8 05®© KM Chelnshev UCL 3o00 55o.8 mg kg ^U^®©UCL Eootnote (2) ThaUinm mg kg 3.804 2.155 05®© KM (t) UCL 12 nm 2.155 mg kg ^U^®©UCL Eootnote (2)
Notes: (1) .Aritluiietic mean and Upper Coiilklence Limit (UCL) were calculated using EPA's ProUCL X'ersion 5.0.00 statistical software package. Method used to compute selected UCL is shown. K.M - Kaplan-Meier (2) - Statistic: MiLximiuu Detected \'alue (Mioc): '-'>5®o UCL UCL). (3) -The UCL either could not be calculated or exceeded the miLximum concentration: the miLximnm \'alne was selected as the exposure point concentration. NC - Not calculated
Plioc } of I Table 7-4 Exposure Point Concentration Summarx for Current/Future Scenario in Groundwater Reasonable Maximum Exposure
Scenario Tunefraine: Current/Future Medium: Groundwater Exposure Medium: Groundwater Receptors: Construction Worker. Groundwater I'ser Maximum Chemical of Arithmetic Ex'posure Point Concentration Exposure Point I'nits 95%IICL"' Concentration Potential Concern Mean (Distribution) (Qualifier) \'alue Units Statistic Rationale
Groiuidwiiter \OCs 1.2.4-Trinietlnlbeiizene iig L 11.83 30.'-^ Stndent's-t UCL 20 20 iig L MILX Footnote 3) 1.2-Dicliloropropane iig L 5.532 "5.4o Adjusted Ganinia UCL -)-) iig L MILX Footnote 3) 1.3.5-Trinietlnlbeiizene 1.4-Diclilorobeiizene iig L 10.42 4^X28 '-U^®© Cheb\she\' (Mean. Sd) UCL 130 4^L28 ng L ^U^®©UCL Footnote 2) Benzene iig L 2PAA 4.545 '-U^®© Smdent's-t UCL 4..M5 ng L ^U^®©UCL Footnote 2) Clilorobenzene iig L 11'.3 2^^0.5 '-U^®© Cheb\she\' (Mean. Sd) UCL 510 2^^0.5 ng L ^U^®©UCL Footnote 2) Cliloroniethane iig L 1" NC Too Few Samples Detectioiis 1" 1" ng L MILX Footnote 3) cis-1.2-DicliJoroethene iig L 54.2' 80.48 '-U^®© Smdent's-t UCL loO 80.48 ng L ^U^®©UCL Footnote 2) Etlnibenzene iig L 2.0o' 3.28o '-U^®© Smdent's-t UCL 2.0 2.0 ng L MILX Footnote 3) 1 1
Tricliloroetlnlene iig L 10.00 o '-U^®© .Adjusted Gamma UCL 54 o ng L ^U^®©UCL Footnote 2) \'in\l Cliloride iig L 1.013 4.225 '-U^®© Smdent's-t UCL 3.4 3.4 ng L MILX Footnote 3) .S I OCs 1-Metlnlnaphthalene iig L "1 NC Too Few Samples Detectioiis "1 "1 ng L MILX Footnote 3) 2.4-Diclilorophenol iig L 2.833 o.^M3 '-U^®© Smdent's-t UCL 5.0 IJ 5.0 ng L MILX Footnote 3) 2-Meth\ljuiphthalene iig L 110 NC Too Few Samples Detectioiis 110 110 ng L MILX Footnote 3) 4-CliJoroaniline iig L 2.5 NC Too Few Samples Detectioiis 3.^^ J 3.'-'> ng L MILX Footnote 3) Acenaphtliene iig L 110 NC Too Few Samples Detectioiis 110 110 ng L MILX Footnote 3) Dibenzofiiran iig L 20 5 NC Too Few Samples Detectioiis 4o 4o ng L MILX Footnote 3) Flnorene iig L ol NC Too Few Samples Detectioiis ol ol ng L MILX Footnote 3) Naphtluilene iig L 120.^^ 38o.^^ '-U^®© Smdent's-t UCL 4o0 38o.^^ ng L ^U^®©UCL Footnote 2)
Pag.e I of3 Table 7-4 Exposure Point Concentration Summarx for Current/Future Scenario in Groundwater Reasonable Maximum Exposure Scenario Tunefraine: Current/Future Medium: Groundwater Exposure Medium: Groundwater Receptors: Construction Worker. Groundwater I'ser Maximum Chemical of Arithmetic Ex'posure Point Concentration Exposure Point I'nits 95%IICL"' Concentration Potential Concern Mean (Distribution) (Qualifier) \'alue Units Statistic Rationale Groiuidwiiter Pesticides 4.4'-DDD iig L 0.81O 2.050 Cheb\she\' (Mean. Sd) UCL 5.1 2.050 ng L ^U^®©UCL Eootnote 2) 4.4'-DDE iig L 0.4'1 1.0' Stndent's-t UCL O.'l O.'l ng L MILX Eootnote 3) .AJ drill iig L 0. loo 0.511 '-U^®© Cheb\she\'( Mean. Sd) UCL 1.3 0.511 ng L ^U^®©UCL Eootnote 2) alplui-BHC iig L 10.O5 30.88 '-U^®© Cheb\she\'( Mean. Sd) UCL 120 30.88 ng L ^U^®©UCL Eootnote 2) betii-BHC iig L 1.480 3.25 '-U^®© .Adjusted Ganinia UCL 11 3.25 ng L ^U^®©UCL Eootnote 2) ganiniii-BHC (LindiUie) iig L 11.51 3'.'8 '-U^®© Stndent's-t UCL 45 3'.'8 ng L ^U^®©UCL Eootnote 2) alpha-CliJordiine iig L 0.O28 1.045 '-U^®© Smdent's-t UCL OP?' OP? ng L MILX Eootnote 3) ganinia-CliJordiine iig L 0.558 O.^M8 '-U^®© Smdent's-t UCL 0P\ 0P\ ng L MILX Eootnote 3) Dieldrin iig L 0.32^^ 1.101 '-U^®© Cheb\she\'( Mean. Sd) UCL 3.4 1.101 ng L ^U^®©UCL Eootnote 2) Endrin iig L 0.^^2 NC Too Eew Samples Detectioiis 0.^^2 0.^^2 ng L MILX Eootnote 3) Endrin aldelnde iig L 5 00 NC Too Eew Samples Detectioiis 5.00 £ 5 00 ng L MILX Eootnote 3) Endrin Ketone iig L 1.15 1 .^^08 '-U^®© Smdent's-t UCL "} 1.^^08 ng L ^U^®©UCL Eootnote 2) Heptaclilor iig L 0.111 O.5O0 '-U^®© Cheb\she\'( Mean. Sd) UCL 1.1 O.5O0 ng L ^U^®©UCL Eootnote 2) Heptaclilor Epoxide iig L 0.238 0.08^^ '-U^®© .Adjusted Gamma UCL 1.3 0.08^^ ng L ^U^®©UCL Eootnote 2) Hexaclilorobenzene iig L 0.0o23 0.108 '-U^®© Stndent's-t UCL 0.21 IJ 0.108 ng L ^U^®©UCL Eootnote 2) PCBs .Aroclor-l 254 iig L 0.10^^ NC Too Eew Samples Detectioiis 0.2 0.2 ng L MILX Eootnote 3) Herbicides Pentaclilorophenol iig L O.IK^ NC Too Eew Samples Detections O.r l.Q J 0.1' ng L MILX Eootnote 3)
Pag.e 2 of3 Table 7-4 Exposure Point Concentration Summarx for Current/Future Scenario in Groundwater Reasonable Maximum Exposure
Scenario Tunefraine: Current/Future Medium: Groundwater Exposure Medium: Groundwater Receptors: Construction Worker. Groundwater I'ser Maximum Chemical of •Arithmetic Ex'posure Point Concentration Exposure Point Units 95®/OIICL"' Concentration Potential Concern Mean (Distribution) (Qualifier) \'alue Units Statistic Rationale
Groiuidwater Inorganics .Aliuninum ug L 52113 l'54'l '-U^®© Cheb\she\'( Mean. Sd UCL .^00000 I'.M'l ug L ^U^®©UCL Footnote 2) •Ammonia as N ug L l.Nt.^04 '-U^®© Cheb\she\' (Mean. Sd) UCL .MOOOO 153504 ug L ^U^®©UCL Footnote 2) .Antimon\' ug L 4".' 2311 '-U^®© Cheb\she\'( Mean. Sd UCL 3400 2311 ug L ^U^®©UCL Footnote 2) 1 1 o o •Arsenic ug L ^N.'o cc '-U^®© Cheb\she\' (Mean. Sd) UCL 880 cc ug L ^U^®©UCL Footnote 2) Barium ug L 34000 NC Too Few Samples Detectioiis 34000 34000 ug L MILX Footnote 3) Beixlliiun ug L 2o.o3 00.^-^2 '-U^®© Student's-t UCL 54 54 ug L MILX Footnote 3) Cadmiiun ug L 18 5o.45 '-U^®© Student's-t UCL o~ 5o.45 ug L ^U^®©UCL Footnote 2) Cliromium ug L 2028 oogo '-U^®© Cheb\she\'( Mean. Sd UCL 42000 oogo ug L ^U^®©UCL Footnote 2) Cobalt ug L "2.25 232." '-U^®© Cheb\she\'( Mean. Sd UCL o80 232." ug L ^U^®©UCL Footnote 2) Copper ug L 4483 14305 '-U^®© Student's-t UCL I'OOO 14305 ug L ^U^®©UCL Footnote 2) Iron ug L 10'501 305o'-'>5 '-U^®© Cheb\she\'( Mean. Sd UCL loOOOOO 305o'-'>5 ug L ^U^®©UCL Footnote 2) Lead ug L 3'05 143.X1 '-U^®© Student's-t UCL 11000 11000 ug L MILX Footnote 3) Manganese ug L l'2o 32o' ^U^®© H-UCL I'OOO 32o' ug L ^U^®©UCL Footnote 2) o o o r
Nickel ug L 2^M1 14145 '-U^®© Cheb\she\'( Mean. Sd UCL 1 14145 ug L ^U^®©UCL Footnote 2) Nitrate as N ug L 13oo' 4U^01 '-U^®© Student's-t UCL 33000 33000 ug L MILX Footnote 3) Selenium ug L 134." 4o3.8 '-U^®© Student's-t UCL 3o0 3o0 ug L MILX Footnote 3) Sih'er ug L 11 NC Too Few Samples Detectioiis 11 IJ 11 ug L MILX Footnote 3) ThaUiiun ug L 2.3'-'> 5.'31 '-U^®© Student's-t UCL 4.0 4.0 ug L MILX Footnote 3) 1 1
\'anadiiun ug L 444 o '-U^®© Cheb\she\'( Mean. Sd UCL .xtOO o ug L ^U^®©UCL Footnote 2) 1 1
Zinc ug L 34^^03 o '-U^®© Student's-t UCL 130000 o ug L ^U^®©UCL Footnote 2) Notes: (1) .Aritluiietic mean and Upper Coiil'idence Limit (UCL) were calculated iLsiiig EPA's ProUCL X'ersioii 5.0.00 statistical software package. Method used to compute selected UCL is shown. (2) - Statistic: MiLximiuii Detected \'alue (Mioc): UCL UCL). (3) - The '-T^®© UCL eitlier could not be calculated or exceeded the nuLximiuu concentration: the miLximnm \'alue was selected as the exposure point concentration. NC - Not calculated
Pag.e 3 of3 Table 7-5 Exposure Point Concentration Summary for Fish Tissue (via Sediment)
Scenario TInierranie: Current/Future Medium: Fish Tissue Exposure Medium: Fish Tissue Receptors: Fisher
Sediment Concentrations Concentration in Chemical of Fish Tissue PotentiaJ Concern .Arithmetic Mean Maximum 95'T I'CL (mg/kg) (mg/kg) (mg/kg) (mg/kg) and Distribution
Peslicides 4,4'-DDE 0.05^) 0.24 0.0815 95'.t KM Chebvshev L'CL 0.63 4,4'-DDT 0.468 3.3 0.747 95'.t KM Chebvshev L'CL 5.8 •Aldrin 0.428 3 0.627 95'.t KM Chebvshev L'CL 1.1 alpha-BHC 0.451 4.^) 0.687 95'.t KM Chebvshev L'CL 1.2 beia-BHC 0.15^) 1.8 0.255 95'.t KM (Cliebvshev) L'CL 0.46 Chlordatie 0.248 1.2 0.234 95''.t .Adjusted Gamma KM-L'CL 1.1 Dieldrin 0.072 0.66 0.1 95''.t .Adjusted Gamma KM-L'CL 0.18 Hepiachlor Epoxide 0.026^) 0.11 0.0165 95'.t KM (1) L'CL 0.030 PCBs .Aroclor-1254 4.36 13 .843 95'.t KM (1) L'CL 3.4 •Aroclor-l 260 1.677 7.7 2.725 95'.t KM (Cliebvshev) L'CL 5.0
Notes: (1) .Ariihmeiic mean, maximum, and L'pper Confidence Limii (L'CL) were calculated using EPA's ProL'CL Version 5.0.00 statistical software package. Method used to compute selected L'CL is shouii. KM - Kaplan-Meier (2) Fish tissue exposure point concentration calculation is shown on Appendix ,1. Table ,1-2 of the HHRA Addendum (AECOM. 2016a). Tlie fish lissu concentration shown was modeled based on the f)5''.t L'CL concentration in sediment as discussed in the footnotes to Appendix ,L Table ,1-2 of the HHR.A .Addendum (.AECOM, 2016a).
Pil^-e I nf I Table 7-6 Cancer Toxicitv Dala — Oral/Dermal Oral Absorption Absorbed Cancer Slope VVeight ofEsidence Oral Cancer Slope Factor C'henilcal orPolenllal Oral Cancer Slope Factor (1) Emclenc) for Dermal Factor for Dermal (3) Cancer Guideline Mutagen(4) Date(s) (6) Concern Soiirce(s) (5) \'alue I'nils (2) \'alue I'nits DescriptJon (MM DD VVVV)
I OCs 1.1-Dic[iloroelli\ lene ND ND ND ND ND e' IRIS 1(1 (Id 2()I5 1.2.4-TritTielli\ Ibeiizent ND ND ND ND ND ND ND ND 1.2-Diclilorobetizeiie NA NA NA NA NA D IRIS (I (Id 2 1.2-Dicliloropropaiie .v6nE-n2 (ingTg-day I' 1 .v6nE-n2 (ingTg-day I' Cal EPA I (Id 2 1.3-Diclilorobetizeiie NA NA NA NA NA IRIS I (Id 2 1.4-Diclilorobetizeiie 5.4nE-n3 (ingTg-day I' 1 5.4nE-iB (ingTg-day I' Cal EPA I (Id 2 Benzene 5.5nE-n2 (ingTg-day I' 1 5.5nE-n2 (ingTg-day I' A IRIS I (Id 2 Clilorobenzene NA NA NA NA NA D IRIS I (Id 2 ClilorotTielliane NA NA NA NA NA D IRIS I (Id 2 cis-1.2-Dic[iloroelliene ND ND ND ND ND Inadequate IRIS I (Id 2 Elli\ Ibenzene l.l()E-()2 (ingTg-day I' 1 l.l()E-()2 (ingTg-day I' D Cal EPA; IRIS I (Id 2 Isoprop\ Ibenzene NA NA NA NA NA D IRIS I (Id 2 Tricliloroelln lene 4.6nE-n2 (ingTg-day I' 1 4.6nE-n2 (ingTg-day I' Known Yes IRIS I (Id 2 \'inyl Cliloride ".2()E-()1 (ingTg-day I' 1 ".2()E-()1 (ingTg-day I' A Yes IRIS (I (Id 2 SI OCs 1-Melli\ Inaplillialene 2.dnE-n2 (ingTg-day I' 1 2.dnE-n2 (ingTg-day I' Suggesli\ e PPRT\' )I 102 2.4-Dicliloroplienol ND ND ND ND ND ND ND ND 2-Melli\ inaplillialene ND ND ND ND ND Inadequate IRIS (I (Id 2 4-Cliloroaniline 2.()()E-nl (ingTg-day I' 1 2.nnE-nl (ingTg-day I' Suggesti\ e PPRT\' Id 30 2 Acenaplilliene ND ND ND ND ND ND ND ND Dibenzofuran NA NA NA NA NA D IRIS 0 (Id 2 Fluorene NA NA NA NA NA D IRIS 0 (Id 2 Naplillialene 1.2()E-()1 (ingTg-day I' 1 1.2()E-()1 (ingTg-day I' C Cal EPA; IRIS 0 (Id 2 DitJAi/is and Furans JEO 1.3nE+n5 (iiieTe-davi' 1.3nE+n5 (iiieTe-davi' Cal EPA 10 (Id 2015 Table 7-6 Cancer Toxicitv Dala — Oral/Dermal Oral Absorption Absorbed Cancer Slope VVeight ofEsidence Oral Cancer Slope Factor C'henilcal orPolenllal Oral Cancer Slope Factor (1) Emclenc) for Dermal Factor for Dermal (3) Cancer Guideline Mutagen(4) Date(s) (6) Concern Soiirce(s) (5) \'alue I'nils (2) \'alue I'nits DescriptJon (MM DD VVVV) Pexticidei 4.4'-DDD 2.4()E-()I (ingLg-day) I 2.40E-0I (ingLg-day) IRIS od 2 4.4'-DDE o.4()E-()I (ingLg-day) I .v4oE-oI (ingLg-day) IRIS od 2 4.4'-DDT 0.4.)E-()I (ingLg-day) I .v4oE-oI (ingLg-day) IRIS od 2 Aldrin 1."()E+()I (ingLg-day) I I."oE+oI (ingLg-day) IRIS od 2 alplia-BHC 6.o()E+()() (ingLg-day) I d.ooE+oo (ingLg-day) IRIS od 2 bela-BHC I.8()E+()() (ingLg-day) I I.80E+00 (ingLg-day) IRIS od 2 (lella-BHC NA NA NA NA NA IRIS od 2 gaiTitTia-BHC (Lindane I.I()E+()() (ingLg-day) I I.loE+oo (ingLg-day) Cal EPA od 2 alplia-Clilordane o.5()E-()I (ingLg-day) I -v5oE-oI (ingLg-day) IRIS od 2 gainma-Clilordane o.5()E-()I (ingLg-day) I -v5oE-oI (ingLg-day) IRIS od 2 Clilordane o.5()E-()I (ingLg-day )-I I -v5oE-oI (ingLg-day )-I IRIS od 2 Dieldrin I.6()E+()I (ingLg-day)' I I.doE+oI (ingLg-day)' IRIS od 2 Endosulfan I ND ND ND ND ND ND ND ND Endosulfan II ND ND ND ND ND ND ND ND Endosulfan Sulfate ND ND ND ND ND ND ND ND Endrin NA NA NA NA NA D IRIS od 2( Endrin aldehyde NA NA NA NA NA D IRIS od 2( Endrin Ketone NA NA NA NA NA D IRIS od 2( Heptachlor 4.5()E+()() (ingLg-day )' 4.50E+00 (ingLg-day)' IRIS od 2( Heptachlor Epoxide d.loE+nn (ingLg-day)' d. loE+oo (ingLg-day)' IRIS od 2( Hexachlorohenzene I.6()E+()() (ingLg-day)' I.doE+oo (ingLg-day)' IRIS od 2( Toxaphene I.I()E+()() (ingLg-day)' I.IoE+oo (ingLg-day)' IRIS od 2( Herbicides Pentachlorophenol 4.()()E-()I (ingLg-day)' 4.()()E-()I (ingLg-day) Known IRIS od 2( PCBs Aroclor-lolft ".()()E-()2 (ingLg-day)' ".()()E-()2 (ingLg-day)' IRIS lo 2( Aroclor-1221 2.()()E+()() (ingLg-day)' 2.()()E+()() (ingLg-day)' IRIS od 2( Aroclor-I2o2 2.()()E+()() (ingLg-day)' 2.()()E+()() (ingLg-day)' IRIS od 2( Aroclor-1242 2.()()E+()() (ingLg-day)' 2.()()E+()() (ingLg-day)' IRIS od 2( Aroclor-1248 2.()()E+()() (ingLg-day)' 2.()()E+()() (ingLg-day)' IRIS od 2( Aroclor-1254 2.()()E+()() (ingLg-day)' 2.()()E+()() (ingLg-day)' IRIS od 2( Aroclor-I26() 2.()()E+()() (ineLe-dav)' 2.()()E+()() (ineLe-dav)' IRIS od 2( Table 7-6 Cancer Toxicitv Data — Oral/Dermal Oral Absorption Absorbed Cancer Slope VVeight ofEsidence Oral Cancer Slope Factor Chemical orPolenllal Oral Cancer Slope Factor (1) EITiciencs for Dermal Factor for Dermal (3) Cancer Guideline Mutagen(4) Date(s) (6) Concern Source(s) (5) \'alue I'nils (2) \'alue I'nits DescriptJon (MM DO VVVVI Inorganici Alutiiinutii ND ND ND ND ND Inadequate PPRT\' In 23 2006 AtTitTionia as N ND ND ND ND ND ND ND ND AniitTiony ND ND ND ND ND ND ND ND Arsenic 1.5()E+()() (iTigLg-day)' 1 1.5()E+()() (iTigLg-day)' A IRIS In op 2nl5 BariiuTi NA NA NA NA NA D IRIS In op 2015 Ber\ IliutTi 8.4()E+()() (iTigLg-day)' ().()()" 1.2()E+()o (iTigLg-day)' BI Cal EPA; IRIS lo op 2015 Boron ND ND ND ND ND Inadequate IRIS lo op 2015 CadiTiiutTi - Soil ND ND ND ND ND BI IRIS lo op 2015 CaciiTiiutTi - GVV ND ND ND ND ND BI IRIS lo op 2015 ClirotTiiutTi 5.()()E-()1 (iTigLg-day)' n.nlo o.85E+()l (iTigLg-day)' A - iiilialation. D - oral NJ; IRIS 06 2015 Cobalt ND ND ND ND ND ND ND ND Copper NA NA NA NA NA D IRIS lo op 2015 C\ anide NA NA NA NA NA D IRIS lo op 2015 Iron ND ND ND ND ND Inadequate PPRT\' op 11 2006 Lead ND ND ND ND ND B2 IRIS lo op 2015 Manganese NA NA NA NA NA D IRIS lo op 2015 Mercury NA NA NA NA NA D IRIS lo op 2015 Nickel ND ND ND ND ND ND ND ND Nitrate as N ND ND ND ND ND ND ND ND SeleniuiTi NA NA NA NA NA D IRIS lo op 2015 SiKer NA NA NA NA NA D IRIS lo op 2015 ThalliuiTi ND ND ND ND ND Inadequate IRIS lo op 2015 \'anadiiuTi ND ND ND ND ND ND ND ND Zinc ND ND ND ND ND Inadequate IRIS lo op 2015 Table 7-6 Cancer Toxicitv Dala — Oral/Dermal
Notes: Derinllions: (1) (;)ral cancer slope factor and vveiglil ore\ idence for llie rollovv ing clieiTiicais used as surrogates: Cal EPA = Caiifoniia Ein ironiTiental Protection Agency [iexa\ alent cliroiTiiuiTi used for total chroiTiiuiTU low-risk PCBs used for Aroclor-lnlP; IRIS = Integrated Risk Inlontiation Systeiti chlordane used for alpha- and gaiTUTia-chlordane; and higli-risk PCBs used for all otlier Aroclors. NA = Not Applicable (2) (Itral to dential adJustiTient factors (gastrointestinal absori)tion factors) are from L'SEPA (July 2()()4). ND = No Data (0) Absorbed Cancer Slope Factor for Dennal = ((Itral SF) ((Itral Absori)tion ElTiciency). NJ = New Jersey Department of En\ ironmental Protection (4) Identilled as ha\ing a mutagenic mode of action for carcinogenesis (L'SEPA. February 2()Io). PPRT\' = Professional Peer-Re\ iewed Toxicity \'alue (5) For hexa\ alent chromium, source of (Itral Cancer Slope Factor is New Jersey; source of VVeiglit of E\ idenceis IRIS L'SEP.A = L'nited States En\ ironmental Protection .Agency (6) For Cal EP.A \ alues. tlie date C.AL EP.A was searched. For IRIS \ allies, tlie date IRIS w as searched. For PPRT\' \ allies, tlie issue date of tlie paper. VVeighl of Exidence Classincallon. as per Guidelines for Carcinogen Risk .Assessment (L'SEP.A. September 1986): .A - Human carcinogen B2 - Probable human carcinogen C - Possible human carcinogen D - Not classillable as a human carcinogen Weight of Exidence Ciassirication. as per Guideiines for Carcinogen Risk .Assessment (L'SEP.A. March 2nn5): Inadequate - inadequate inlbnnation to assess carcinogenic potential Likely - likely to be carcinogenic to humans Suggestix e - suggestix e e\ idence to be carcinogenic to animals Known - carcinoeenic to humans Table""
Cancer Toxidly Data — InhaJalion
I'nil Risk (I) Weiahl or Evidence I'nil Risk Chenilral of Polendal Concern Cancer Guideline Mulasen (2) Date(S) (4) Value I'nils Descripdon Sources(s) (i) (MlMDOVyTV)
\OCi l.l-Dicli)oroelJiylene ND ND C IRIS 10 GO 2015 1.2.-1-TrinielJiylbeii2ene ND ND ND ND ND 1.2-Dicli)oroberi2eiie NA NA D IRIS 10 00 2015 1.2-Dicli)orq)ropajie l.OOE-05 (ugni.M ' — Cal EPA 10 00 2015 U.5-TrinielJiylbeii2ene ND ND ND ND ND 1.3- Dich 1 oroberizeii e NA NA D IRIS 10 00 2015 1 .-1- Di ch 1 oroberizeii e l.lOE-05 (ugni.M ' — Cal EPA 10 00 2015 Acelone ND ND Inadeqjate IRIS 10 14 2015 Benzene ".80E-06 dig ni.M' A IRIS 10 00 2015 Carbon disiilllde ND ND ND ND ND Clilorobenzene NA NA D IRIS 10 00 2015 CliloronieUiane NA NA D IRIS 10 00 2015 d>-1.2-DichloroelJiene ND ND Inadeqjate IRIS 10 00 2015 Elliylbenzene 2.50E-06 (ugni.M ' D Cal EPA; IRIS 10 00 2015 I>o|)ro|)\lbenzene NA NA D IRIS 10 00 2015 MeUiyl EUiyl Ketone ND ND Inadeqjate IRIS 10 14 2015 n-Prq)ylbenzene ND ND ND ND ND 0-Xylene ND ND Inadeqjate IRIS 10 14 2015 p-I>q)rq)ylloluene ND ND ND ND ND >ec-Butylbenzene ND ND ND ND ND lran>-1.2-Dlcli) oroeUiene ND ND Inadeqjate IRIS 10 14 2015 Tricli) oroeUiylene -1.10E-06 (ugni.M ' Known Yes IRIS 10 00 2015 \ lnyl Clilorkle -1.-10E-06 (ugni.M ' A Yes IRIS 10 00 2015 Xylene dotal) ND ND Inadeqjate IRIS 10 14 2015 slua l-MetliylnaphtJialene ND ND ND ND ND 2.-1-Dichlorq)henol ND ND ND ND ND 2-C1il orq)henol ND ND ND ND ND ND 2-MetliylnaphtJialene ND ND Inadeqjate IRIS 10 00 2015 -1-Clil oroaniline ND ND ND ND ND AcenaphtJiene ND ND ND ND ND Dibenzofuran NA NA D IRIS 10 00 2015 Fluorene NA NA D IRIS 10 00 2015 Naphthalene .V-10E-05 (ugni.M ' C Cal EPA; IRIS 10 00 2015 Dhxim and Furam TEG .V80E+01 nip niM ' - Cal EPA 10 00 2015 Table""
Cancer Toxidiv Data — InhaJalion
I'nil Risk (I) Weiahl or Evidence Chenilral of Polendal Concern Cancer Guideline Mulasen (2) Date(S) (4) Descripdon Sources(s) (i) (MIMDDY^TV) PaHcidfs 1.2J.4-Telrachlorobeiizeiie ND ND ND ND ND 1.2.4.5-Telrachlorobeiizeiie ND ND ND ND ND 4.4'-DDD 6.<)0E-05 lua ni.^ Cal EPA; IRIS 10 00 2015 4.4'-DDE <)."0E-05 Ilia ni.^ Cal EPA; IRIS 10 00 2015 4.4'-DDT <)."0E-05 lua ni.^ IRIS 10 00 2015 .Aldrin 4.<)0E-0.^ (ua ni.^ IRIS 10 00 2015 a)pha-BHC 1.80E-0.^ (ua ni.^ IRIS 10 00 2015 bela-BHC 5..WE-04 (ua ni.^ IRIS 10 00 2015 (lella-BHC N.A NA IRIS 10 00 2015 aanuiia-BHC (Lindajie) .VlOE-04 (ua ni.^ Cal EPA 10 00 2015 a)pha-C1i) ordane l.OOE-04 lua ni.^ IRIS 10 00 2015 aanuiia-Clilordajie l.OOE-04 lua ni.^ IRIS 10 00 2015 Clilordajie l.OOE-04 lua ni.M-1 IRIS 10 00 2015 d>-Nonacli)or ND ND ND ND ND Irans-Noiiachlor ND ND ND ND ND Dieldrin 4.60E-0.^ lua ni.M ' B2 IRIS 10 00 2015 Endosiill'an I ND ND ND ND ND Endosiill'an D ND ND ND ND ND Endosiill'an Siill'ale ND ND ND ND ND Endrin N.A NA D IRIS 10 00 2015 Endrin aldehyde NA NA D IRIS 10 00 2015 Endrin Kelone NA NA D IRIS 10 00 2015 Heplaclilor l..WE-0.^ luani.M ' IRIS 10 00 2015 Heplaclilor Epoxide 2.60E-0.^ luani.M ' IRIS 10 00 2015 Hexaclilorobenzene 4.60E-04 lua ni.M ' IRIS 10 00 2015 Ocychlordane ND ND ND ND ND Penlaclilorobenzene NA NA D IRIS 10 14 2015 Toxaphene .V20E-04 lua ni.M ' IRIS 10 00 2015 H^rbkidfi Penlaclilorqihenol luani.M ' Cal EPA; IRIS PCBs .ArocI or-1016 2.00E-05 luani.M ' IRIS .ArocI or-1221 5."0E-04 luani.M ' IRIS 10 GO 015 .ArocI or-12.^2 5."0E-04 lua ni.M ' IRIS 10 00 015 .ArocI or-1242 5."0E-04 luani.M ' IRIS 10 00 015 .ArocI or-1248 5."0E-04 luani.M ' IRIS 10 00 015 .ArocI or-1254 5."0E-04 lua ni.M ' IRIS 10 00 015 .ArocI or-1260 5."0E-04 lua ni.M ' IRIS 10 00 015 Table""
Cancer Toxidly Data — InhaJalion
I'nil Risk (I) Weiahl or Evidence I'nil Risk Chenilral of Polendal Concern Cancer Guideline Mulasen (2) Date(S) (4) Value I'nils Descripdon Sources(s) (i) (ISDSIDDYATV) Inorganics o o o .Aliuiiiniuii ND ND Inade(|ijale PPRTS' Ov .Ajiinioiiia as N ND ND ND ND ND .Ajilinioiiy ND ND ND ND ND .Arsenic -1..WE-03 dig ni.M' A IRIS 10 GO 2015 Bariiuii N.A N.A D IRIS 10 00 2015 Beryllliun 2.-10E-0A (ugni.M ' B1 Cal EPA; IRIS 10 00 2015 Boron ND ND Inade(|ijale IRIS 10 00 2015 Cadniliun 1.80E-0A (ugni.M ' B1 IRIS 10 00 2015 Cliroinliun 1.20E-02 (ugni.M ' .A - Inhalalion. D - oral IRIS 10 00 2015 Coball O.OOE-OA dig ni.M ' Likely PPRTS' 08 25 2006 Co|)()er N.A N.A D IRIS 10 00 2015 CVani Noles: Dennitions: (1) Uriil risk ajid weisJil of evidence Ifoni die I'ollowna chemicals were used as siirroaales: xv lenes used Cal EP.A = California Fnvironmenlal Prolecdon .Agency xxlenes used for o-x\ lene; clilordane used for alpha- and aanuna-chlordane; low-risk PCBs used for IRIS = Inlegraled Risk Inl'onnadon Svslem Aroclor-1016; liiah-risk PCBs used for all olJier .Aroclors; and hexav aleni chroiniiun used for cliromiiun N.A = Nol .Applicable (die luiil risk re()resenls a conibinadon of divaleni and hexavaleni chroiniiun). ND = No Dala (2) Idendlied as having a mulaaenic mode of acdon for carcinogenesis (USEP.A. Febnian 20LM. PPRTA' = Provisional Peer-ReviewedToxicity \ alue (.M Soiuce of Unil Risk : source of Weigh! of Evidence Cancer Guideline Descripdon. USEP.A = United States Fnviroiunental Protection .Aaencv (d) For Cal EP.A v alues, die dale C.AL EP.A was searched. For ERJS values, die dale ERJS was searched For PPRTA' v alues, ihe issue dale of die paper. Weigh! of Evidence Clasdnratlon. as per Guidelines Tor Carcinogen Risk .Assessment d'SElP.A. September l9S6i: .A - Hiunan carcinogen B2 - Probable luunan carcinogen C- Possible human carcinogen D - Nol classiliable as a human carcinogen Weight or Evidence ClassUlcation. as per Guideiines for Carcinogen Risk .Assessment d'SElP.A. March 200?i: Inade<|uale - inadequale informalion lo assess carcinogenic polendal Likely - likely lo be carcinogenic lo luunans Known - carcinoaenic lo humans Table 7-8 Non-Cancer Toxiclt> Data — Oral/Dermal RfD: Target Organ(s) Chemical of Potential Chronic/ Oral RID (1) Oral Absorption Absorbed RfD for Dermal (3) Primary Target C ombined I'ncertaintyV Date(s) (5) Concern Subchronic Efficiency for Dermal (2) Organ(s) Modify ing Factors (4) Source(s) S'alue I'nits S'alue I'nits (MM/DDA YYY) 1 OCs 1.1 -Dicliloroetlnlene C'lironic 5.00E-02 nig kg-cla\' 1 5.00E-02 nig kg-da\' Li\'er 100 IRIS 10 0^^ 2015 1.2.4-Truiieth\lbeiizene C'lironic ND ND 1 ND ND ND ND ND ND 1.2-Diclilorobeiizene C'lironic ^\00E-02 nig kg-cla\' 1 ^\00E-02 nig kg-da None Reported ND IRIS 10 0^^ 2015 1.2-Dicliloropropane C'lironic ^\00E-02 nig kg-cla\' 1 ^\00E-02 nig kg-da Li\'er ND ATSDR 12 1.3-Diclilorobeiizene C'lironic '.OOE-02 nig kg-cla\' 1 '.OOE-02 nig kg-da Li\'er 100 ATSDR 08 200o 1.4-Diclilorobeiizene C'lironic '.OOE-02 nig kg-cla\' 1 '.OOE-02 nig kg-da Li\'er 100 ATSDR 08 200o Benzene C'lironic 4.00E-03 nig kg-cla\' 1 4.00E-03 nig kg-da Blood 300 IRIS 10 0^^ 2015 C'lilorobenzene C'lironic 2.00E-02 nig kg-cla\' 1 2.00E-02 nig kg-da Li\'er 1000 IRIS 10 0^^ 2015 C'liloronietlume C'lironic ND ND 1 ND ND ND ND ND ND cis-1.2-Dicli]oroethene C'lironic 2.00E-03 nig kg-cla\' 1 2.00E-03 nig kg-da Kidnec' 3000 IRIS 10 0^^ 2015 Etlnlbenzene C'lironic l.OOE-01 nig kg-cla\' 1 l.OOE-01 nig kg-da Li\'er. K.idne\' 1000 IRIS 10 0^^ 2015 Isoprop\lbenzene C'lironic l.OOE-01 nig kg-cla\' 1 l.OOE-01 nig kg-da Kidnec' 1000 IRIS 10 0^^ 2015 Tricliloroetlnlene C'lironic 5.00E-04 nig kg-cla\' 1 5.00E-04 nig kg-da Eetiis. Tln niiis. hiiniiine S\ steni 10:100:1000 IRIS 10 0^^ 2015 \'in\ l C'liloride C'lironic 3.00E-03 nig kg-cla\' 1 3.00E-03 nig kg-da Li\'er 30 IRIS 10 0^^ 2015 S I OCs 1-Metlnlniiphthiilene C'lironic '.OOE-02 nig kg-cla\' 1 '.OOE-02 nig kg-da\' Respirator\' S\ steni 1000 ATSDR 08 2005 2.4-Diclilorophenol C'lironic 3.00E-03 nig kg-cla\' 1 3.00E-03 nig kg-da\' hnniiuie S\steni 100 IRIS 10 0^^ 2015 2-Meth\lniiphthiilene C'lironic 4.00E-03 nig kg-cla\' 1 4.00E-03 nig kg-da\' Respirator\' S\ steni 1000 IRIS 10 0^^ 2015 4-C'liloroaniline C'lironic 4.00E-03 nig kg-cla\' 1 4.00E-03 nig kg-da\' hnniiuie S\steni 3000 IRIS 10 0^^ 2015 Acenaphthene C'lironic o.OOE-02 nig kg-cla\' 1 o.OOE-02 nig kg-da\' Li\'er 3000 IRIS 10 0^^ 2015 Dibenzofiiran C'lironic l.OOE-03 nig kg-cla\' 1 l.OOE-03 nig kg-da\' ND ND PPRT\' App Oo 11 200' Flnorene C'lironic 4.00E-02 nig kg-cla\' 1 4.00E-02 nig kg-da\' Blood 3000 IRIS 10 0^^ 2015 Naphthalene C'lironic 2.00E-02 nig kg-cla\' 1 2.00E-02 nig kg-da\' Bod\- Weight 3000 IRIS 10 0^^ 2015 Dioxins and Fiirans TEQ C'lironic '.OOE-10 nig kg-cla\' 1 '.OOE-10 nig kg-da\' Reprodiictii'e S\steni 30 IRIS 10 0^^ 2015 Pnsie I of 3 Table 7-8 Non-Cancer Toxiclt> Data — Oral/Dernial RfD: Target Organ(s) Cheinlcal of Potential Chronic/ Oral RfD (1) Oral Absorption Absorbed RfD for Dermal (3) Primarj Target C ombined I'ncertaint^/ Date(s) (5) Concern Subchronic Efflcleno for Dermal (2) Organ(s) ModifS ing Factors (4) Source(s) \'alue I'nits \'alue I'nits (MM/DDA YYY) Pesticides 4.4'-DDD C'lironic ND ND I ND ND ND ND ND ND 4.4'-DDE C'lironic ND ND I ND ND ND ND ND ND 4.4'-DDT C'lironic 5.00E-04 nig kg-da\' I 5.00E-04 nig kg-da\' Li\'er too IRIS 10 0^^ 2015 •AJclrui C'lironic 3.00E-05 nig kg-da\' I 3.00E-05 nig kg-da\' Li\'er 1000 IRIS 10 0^^ 2015 alplui-BHC C'lironic 8.00E-03 nig kg-da\' I 8.00E-03 nig kg-da\' Li\'er too .ATSDR 0^^ 2005 betii-BHC C'lironic ND ND I ND ND ND ND ND ND deltii-BHC C'lironic ND ND I ND ND ND ND ND ND ganiniii-BHC (Linckme) C'lironic 3.00E-04 nig kg-da\' I 3.00E-04 nig kg-da\' Kidne\'. Li\'er 1000 IRIS 10 0^^ 2015 alpha-C'lilordane C'lironic 5.00E-04 nig kg-da\' I 5.00E-04 nig kg-da\' Li\'er 300 IRIS 10 0^^ 2015 ganinia-C'lilordiine C'lironic 5.00E-04 nig kg-da\' I 5.00E-04 nig kg-da\' Li\'er 300 IRIS 10 0^^ 2015 C'lilordane C'lironic 5.00E-04 nig kg-da\' I 5.00E-04 nig kg-da\' Li\'er 300 IRIS 10 0^^ 2015 Dieldrin C'lironic 5.00E-05 nig kg-da\' I 5.00E-05 nig kg-da\' Li\'er too IRIS 10 0^^ 2015 Endosiilfan I C'lironic o.OOE-03 nig kg-da\' I o.OOE-03 nig kg-da\' Bod\' w eight. Kidne\'. Circiilatoix' S\ steni too IRIS 10 0^^ 2015 Endosiilfan II C'lironic o.OOE-03 nig kg-da\' I o.OOE-03 nig kg-da\' Bod\' w eight. Kidne\'. Circiilatoix' S\ steni too IRIS 10 0^^ 2015 Endosiilfan Sulfate C'lironic o.OOE-03 nig kg-da\' I o.OOE-03 nig kg-da\' Bod\' w eight. Kidne\'. Circiilatoix' S\ steni too IRIS 10 0^^ 2015 Endrin C'lironic 3.00E-04 nig kg-da\' I 3.00E-04 nig kg-da\' Li\'er. Ner\'oiLs S\steni too IRIS 10 0^^ 2015 Endrin aldelnde C'lironic 3.00E-04 nig kg-da\' I 3.00E-04 nig kg-da\' Li\'er. Ner\'oiLs S\steni too IRIS 10 0^^ 2015 Endrin Ketone C'lironic 3.00E-04 nig kg-da\' I 3.00E-04 nig kg-da\' Li\'er. Ner\'oiLs S\steni too IRIS 10 0^^ 2015 Heptaclilor C'lironic 5.00E-04 nig kg-da\' I 5.00E-04 nig kg-da\' Li\'er 300 IRIS 10 0^^ 2015 Heptaclilor Epoxide C'lironic I.30E-05 nig kg-da\' I I.30E-05 nig kg-da\' Li\'er 1000 IRIS 10 0^^ 2015 Hexaclilorobenzene C'lironic 8.00E-04 nig kg-da\' I 8.00E-04 nig kg-da\' Li\'er too IRIS 10 0^^ 2015 Toxaphene C'lironic ND ND I ND ND ND ND ND ND Herbicides Pentaclilorophenol C'lironic 5.00E-03 nig kg-da\' I 5.00E-03 nig kg-da\' Li\'er 300 IRIS 10 0^^ 2015 PCBs •ArocIor-IOIo C'lironic '.OOE-05 nig kg-da\' I '.OOE-05 nig kg-da\' De\'eIopnientaI too IRIS 10 0^^ 2015 •Aroclor-1221 C'lironic ND ND I ND ND ND ND ND ND •Aroclor-1232 C'lironic ND ND I ND ND ND ND ND ND •Aroclor-1242 C'lironic ND ND I ND ND ND ND ND ND .-\rocIor-I248 C'lironic ND ND I ND ND ND ND ND ND .Aroclor-1254 C'lironic 2.00E-05 nig kg-da\' I 2.00E-05 nig kg-da\' E\es. Skin. Ininiiuie S\steni 300 IRIS 10 0^^ 2015 •Aroclor-12oO C'lironic ND ND I ND ND ND ND ND ND Pasie 2 of Table 7-8 Non-Cancer Toxiclt> Data — Oral/Dernial RfD: Target Organ(s) Chemical of Potential Chronic/ Oral RfD (1) Oral .Absorption •Absorbed RfD for Dermal (3) Primarj Target C ombined Uncertainty/ Date(s) (5) Concern Subchronic Efficieno for Dermal (2) Organ(s) Modify ing Factors (4) Source(s) X'alue Units X'alue Units (MM/DDA YYY) Inorganics •Aliuniniun Clironic l.OOE+00 mg kg-dav' 1 l.OOE+00 mg kg-dav' Nervous Sv stem 100 PPRTV 10 23 200o •Anunonia as N Clironic ND ND 1 ND ND ND ND ND ND •Antimonv' Clironic 4.00E-04 mg kg-dav' 0.15 o.OOE-05 mg kg-dav' Longevitv; Blood 1000 IRIS 10 0^^ 2015 •Arsenic Clironic 3.00E-04 mg kg-dav' 1 3.00E-04 mg kg-dav' Cardiovascular Svstem. Skin 3 IRIS 10 0^^ 2015 Bariiun Clironic 2.00E-01 mg kg-dav' 0.0' 1.40E-02 mg kg-dav' Kidnev' 300 IRIS 10 0^^ 2015 BervTliiun Clironic 2.00E-03 mg kg-dav' 0.00' 1.40E-05 mg kg-dav' Small intestine 300 IRIS 10 0^^ 2015 Boron Clironic 2.00E-01 mg kg-dav' 1 2.00E-01 mg kg-dav' Developmental 00 IRIS 10 0^^ 2015 Cadmiiun - Soil Clironic l.OOE-03 mg kg-dav' 0.025 2.50E-05 mg kg-dav' Kidnev' 10 IRIS 10 0^^ 2015 Cadmiiun - GW Clironic 5.00E-04 mg kg-dav' 0.05 2.50E-05 mg kg-dav' Kidnev' 10 IRIS 10 0^^ 2015 Cliromiiun Clironic 3.00E-03 mg kg-dav' 0.013 3.^^0E-05 mg kg-dav' None Reported 1000 IRIS 10 0^^ 2015 Cobalt Clironic 3.00E-04 mg kg-dav' 1 3.00E-04 mg kg-dav' Thvroid 3000 PPRTV 08 25 2008 Copper Clironic 4.00E-02 mg kg-dav' 1 4.00E-02 mg kg-dav' Gastrointestinal — HEAST O'Ol Cvanide Clironic O.30E-04 mg kg-dav' 1 O.30E-04 mg kg-dav' Reproductive Svstem 3000 IRIS 10 0^^ 2015 Iron Clironic '.OOE-01 mg kg-dav' 1 '.OOE-01 mg kg-dav' Gastrointestinal 1.5 PPRTV 0^^ 11 200o Lead Clironic ND ND 1 ND ND ND ND ND ND Manganese Clironic 2.40E-02 mg kg-dav' 0.04 ^ToOE-04 mg kg-dav' Nervous Sv stem 3 IRIS 10 0^^ 2015 Mercnrv' Clironic ND ND 1 ND ND ND ND ND ND Nickel Clironic 2.00E-02 mg kg-dav' 0.04 8.00E-04 mg kg-dav' Bodv' Weight, organ weight 300 IRIS 10 0^^ 2015 Nitrate as N Clironic l.oOE+00 mg kg-dav' 1 l.oOE+00 mg kg-dav' Blood 1 IRIS 10 0^^ 2015 Seleniiun Clironic 5.00E-03 mg kg-dav' 1 5.00E-03 mg kg-dav' Selenosis 3 IRIS 10 0^^ 2015 SOver Clironic 5.00E-03 mg kg-dav' 0.04 2.00E-04 mg kg-dav' Skin 3 IRIS 10 0^^ 2015 Thalliiun Clironic l.OOE-05 mg kg-dav' 1 l.OOE-05 mg kg-dav' Skin 3000 PPRT\' App 10 25 2012 X'anadiiun Clironic 5.00E-03 mg kg-dav' 0.02O 1.30E-04 mg kg-dav' Hair 100 IRIS 10 13 2015 Zinc Clironic 3.00E-01 mg kg-dav' 1 3.00E-01 mg kg-dav' Blood 3 IRIS 10 0^^ 2015 Notes: Definitions: (1) (Dral RtTD. target organ, and iuicertaint\' nioditXing factors troni the following chemicals were used as surrogates: ATSDR = Agenc\' for Toxic Substances and Disease Registry' clilordane used for alpha- and gamnia-clilordane: endosiilfan used for endosnlfan 1. endosiilfan 11. and endosiiltan sulfate: Cat EPA = California Environmental Protection Agencv' endrin used for endrin aldeh\ de and endrine ketone: he\a\'alent clironiinni used for total clirominni: and HEAST = Health Effects Assessment Siunmarv'Tables In clrogen c\ anide and c\ anide salts used for c\ anide. IRIS = Integrated Risk Information Svstem (2) (Dral to dennal adjustment factors (G1 absori^tion factors) are from USEPA. Jiil\' 2004. ND = No data (3) Absorbed RtTD for Dennal = ((Dral RtTD) \ ((Dral AbsoriMion EtTTcienc\ ). PPRT\' = Provisional Peer-Reviewed Toxicity- X'ahie (4) Represents Uncertaint\' Eactor \ ModitXing Eactor. USEPA = United States Enviromnental Protection Asencv (.'^) Eor ATSDR \'ahies. the date of the ATSDR dociunent. Eor Cat EPA and IRIS \'ahies. the date CAE EPA or IRIS were searched. Eor HE AST \'ahies. tlie date of HE AST. Eor PPRT\' \'ahies. the issue date of the paper. Pnsie J of 3 Table 7-9 NoD-Cancer Toxidiv Dala — iDhalalioD RfC; Target Orgamsi Cbeiulcal of Poleorial Chronic/ InbalalloD RfC il i Combioed I'Dcertaioty/ Mediuiu Primary Target Orgamsi Dateisi i3i C'oncero SubchroDlc Modifying Factors i2i Sourceisi Value I'liils iMM/DDA AATi VOCs 1.1 Dichloroeihylene GW Clu^on c : KlE+clJ ug/ni> Liver >cl IRIS lii/i O/Jiil.S l.-\4 Truiietliylbenzene GW \T Clu^on c 7 iciE+cm ug/ni> Blood mc 1 PPRT\' iWll/Ji'C 1.J Die hlorobe nz Body Weight pmci HEAST ,17/1007 1.J Die hloropropa ne GW \T Clu^on c 4 iciE+cm ug/ni> Respiratory System >Clll IRIS 1,1/, iC)/7,ii.s l.\S Truiietliylbenzene Clu^on c 7 iciE+cm ug/ni> Blood mc 1 PPRT\' iWll/Ji'C l.> DkTilorobenzene \T Clu^on c S KlE+clJ ug/ni> Liver im IRIS 1,1/, iC)/7,ii.s 1.4 DkTilorobenzene GW \T Clu^on c S KlE+clJ ug/ni> Liver im IRIS 1,1/, iC)/7,ii.s .Acetone Clu^on c > I'lE+'M ug/ni> Nervous System im ATSDR CD/1004 Benzene GW Clu^on c > "lE+ol ug/ni> Blood >Clll IRIS 1,1/, iC)/7,ii.s Carbon disuilide Clu^on c 7 KlE+clJ ug/ni> Nervous System >cl IRIS livU/Jiilo Oilorobenzene GW \T Clu^on c .s "lE+ol ug/ni> Kidney. Liver pmci PPRT\' 1,1/17/J, 1,1,, Oiloronietliane GW Clu^on c C) "lE+ol ug/ni> Nervous System pmci IRIS 1,1/, iC)/7,ii.s cij IJ Dichloroetliene GW Clu^on c ND ND ND ND ND ND Etliylbenzene GW Clu^on c 1 i(iE+ci> ug/ni> Fetus >Clll IRIS 1,1/, iC)/7,ii.s Ifopropylbenzene GW Clu^on c 4 KlE+clJ ug/ni> Endocrine System. Kidney pmci IRIS 1,1/, iC)/7,ii.s Metliyl Ethyl Ketone Clu^on c .s i(iE+ci> ug/ni> Developmental >Clll IRIS livU/Jiilo n Propylbenzene Clu^on c 1 i(iE+ci> ug/ni> Developmental >Clll PPRT\' .App ,i_V, 14/7,1,10 0 Xylene Clu^on c 1 KlE+clJ ug/ni> Nervous System >Clll IRIS liVl4/7iilo p Ijopropyltoluene Clu^on c 4 KlE+clJ ug/ni> Endocrine System. Kidney pmci IRIS 1,1/, io/7,ii.s sec Butylbenzene Clu^on c ND ND ND ND ND ND trans 1J Dich loroetliene Clu^on c ND ND ND ND ND ND Trichloroetliylene GW \T Clu^on c : iciE+i'i ug/ni> Fetus. Thymus 1,1, Ici IRIS 1,1/, io/7,ii.s Vitiyl Oiloride GW \T Clu^on c 1 KlE+clJ ug/ni> Liver >ii IRIS 1,1/, io/7,ii.s •iVOCs 1 Metliylnaphtlialene GW Clu^on c ND ND ND ND ND ND -\4 Dichlorophenol GW Clu^on c ND ND ND ND ND ND J Oilorophenol Clu^on c ND ND ND ND ND ND J Metliylnaphtlialene GW Clu^on c ND ND ND ND ND ND 4 Oiloroaniline GW Clu^on c ND ND ND ND ND ND .Acenaphtliene GW Clu^on c ND ND ND ND ND ND Dibenzoluran GW Clu^on c ND ND ND ND ND ND Fluorene GW Clu^on c ND ND ND ND ND ND Naphtlialene GW \T Clu^on c > iciE+i'i ug/ni> Nel^ous System. Respiratory System >1 III1 IRIS 1,1/, iO/7,ii.s Xylene itotab Clu^on c 1 KlE+clJ ug/ni> Nervous System >iiii IRIS livl4/7iilo Dio.xins iiml Fiinins Liver. Reproductive Svsteni. Developmental. TEQ (_ woinc 4 c'lE ii.S ug/ni> C.ALEP.A 1,1/, io/7,ii.s Endocrine Svsteni. Resoiratorv Svsteni. Blood Table 7-9 NoD-Cancer Toxidiv Dala — iDhalalioD RfC; Target Orgamsi Cbeiulcal of Poleorial Chronic/ InbalalioD RfC il i Combined Uncertainty/ Mediuiu Primary Targel Orgamsi Dateisi i3i C'oncero Subchronic Modifying Factors i2i Sourceisi Value LIQIIS iMM/DDAAATi Ppsliriilps l.-\ \4 Teirachlorobenzene Clu^oti c ND ND ND ND ND ND l.-\4.S Teirachlorobenzene Clu^oti c ND ND ND ND ND ND 4.4' DDD GW SS SSS Clu^oti c ND ND ND ND ND ND 4.4' DDE GW SS SSS Clu^oti c ND ND ND ND ND ND 4.4' DDT Clu^oti c ND ND ND ND ND ND Aldrm GW SS SSS Clu^oti c ND ND ND ND ND ND alpha BHC GW SS SSS Clu^oti c ND ND ND ND ND ND beta BHC GW SS SSS Clu^oti c ND ND ND ND ND ND delta BHC GW SS SSS Clu^oti c ND ND ND ND ND ND gatiuiia BHC > Lmdatie i GW SS SSS Clu^oti c ND ND ND ND ND ND alpha Oilordatie GW SS SSS Clu^oti c TmE-ciI Ug/tll> Liver pmci IRIS l(l/( O/Xll.S gatiuiia Oilordatie GW SS SSS Clu^oti c TmE-ciI Ug/tll> Liver pmci IRIS l(l/( O/Xll.S Oilordane Clu^oti c TmE-ciI Ug/tll> Liver pmci IRIS l(l/( O/Xll.S cij Nonachlor Clu^oti c ND ND ND ND ND ND trans Nonachlor Clu^oti c ND ND ND ND ND ND Dieldrui GW SS SSS Clu^oti c ND ND ND ND ND ND Endosullan I Clu^oti c ND ND ND ND ND ND Endosullan II Clu^oti c ND ND ND ND ND ND Endosullan Sullate Clu^oti c ND ND ND ND ND ND Endrui GW ss sss Clu^oti c ND ND ND ND ND ND Endrui aldehyde GW ss sss Clu^oti c ND ND ND ND ND ND Endrui Ketone GW SS SSS Clu^oti c ND ND ND ND ND ND Heptachlor GW SS SSS Clu^oti c ND ND ND ND ND ND Heptachlor Epoxide GW SS SSS Clu^oti c ND ND ND ND ND ND Hexach lorobetizetie GW Clu^oti c ND ND ND ND ND ND Oxyvhiordane Clu^oti c ND ND ND ND ND ND Petitachlorobetizetie Clu^oti c ND ND ND ND ND ND Toxaphetie Clu^oti c ND ND ND ND ND ND Hprbiriilps Petitachlorophetiol GW Clu^otiic ND ND ND ND ND ND PCBs .Aroolor pilo Clu^oti c ND ND ND ND ND ND .Aro^ lor i::i Clu^oti c ND ND ND ND ND ND .Aroo lor 12 > J Clu^oti c ND ND ND ND ND ND .Aroo lor IJ4 J Clu^oti c ND ND ND ND ND ND .Aroolorl-MS Clu^oti c ND ND ND ND ND ND .Aro.- lor 1204 GW ss sss Clu^oti c ND ND ND ND ND ND .ArcxIorlJ"" Clu^oti ND ND ND ND ND ND Table 7-9 NoD-Cancer Toxidiv Dala — iDhalalioD RfC; Target Orgamsi Cbeiulcal of Poleorial Chronic/ InbalalloD RfC il i Combioed Uocertaioty/ Mediuiu Primary Target Orgamsi Dateisi i3i Concero SubchroDlc Modifying Factors i2i Sourceisi Value Unils iMM/DDAVVTi Inorgiinirs .Aluminum GW SS SSS Clu^onic ,s (KiE+i" ug/m> Nervous System >Clll PPRTV Id/JVJi'io .Anunonia as N GW \T Clu^onic 1 i"iE+iO ug/m> Respiratory System >cl IRIS Id/c "O/JclI.S .Antimony GW SS SSS Clu^onic ND ND ND ND ND ND Developmental. Cardiovascular System. .Arsenic GW SS SSS Clu^onic 1 oi'E '0 ug/m> C.ALEP.A Id/c "O/JclI.S Nervous System. Respiratory System. Skiti Barium GW SS SSS Clu^onic .SHOE "I ug/m> Fetus pmci HEAST o7/I«'7 Beryllium GW Clu^onic jooE'C ug/m> Itiunutie System. Respiratory System 1" IRIS Id/c "O/JclI.S Boron GW Clu^onic J (KlE+Ol ug/m> Respiratory System b" HEAST o7/I«'7 Cadmium GW SSS Clu^onic 1i"E '0 ug/m> Kidtiey 0 ATSDR cO/joi: Ou^omium GW SS SSS Clu^onic 1 i"E "I ug/m> Respiratory System >Clll IRIS Id/c "O/JclI.S Cobalt GW SS SSS Clu^onic (XllE ug/m> Respiratory System >Clll PPRTV iWJO/Ji'iS Copper GW SS SSS Clu^onic ND ND ND ND ND ND Cyan ide SS SSS Clu^onic tiOOE "I ug/m> Endocritie System mc 1 IRIS hvU/Jolo Iron GW SS SSS Clu^onic ND ND ND ND ND ND Lead GW SS SSS Clu^onic ND ND ND ND ND ND Manganese GW SS SSS Clu^onic ,S (iiE lO ug/m> Nervous System pmci IRIS Id/c "O/JclI.S Mercury SS SSS Clu^onic >ooEol ug/m> Nervous System >cl IRIS Id/c "O/JclI.S Nickel GW SSS Clu^onic OdiiE iij ug/m> Respiratory System >cl .ATSDR 10/2'' 10 Niu-ate as N GW Clu^onic ND ND ND ND ND ND Selenium GW Clu^onic J (KlE+Ol ug/m> Liver. Cardiovascular System. Nervous System C.ALEP.A Id/c "O/Jcllo Silver GW SSS Clu^onic ND ND ND ND ND ND Tlialliuni GW SS SSS Clu^onic ND ND ND ND ND ND Vanadium GW SS SSS Clu^onic 1 i"E "I ug/m> Respiratory System >cl .ATSDR cO/joi: Zinc GW SSS Clu^onic ND ND ND ND ND ND Noles; DeQolrioas 111 RIC. largei orgaji. ajid unc dichlorobenzene, 1J.4 iruiietliylbenzene used lor l.>4^ iruiietliylbenzene, ifopropylbenzene used lor c'll EF.A = c'llil' 1fill Efi'-U' 'ririr rii il F r, 'IT'"!!' 'fi .Agrri'"" p ijopropylioluene, xylene? used lor o xy lene, chlordajie used lor alpha ajid ganuna chlordane, and hydrogen cyanide used lor cyanide HE.AST = Health Elle<.ts .Assessment Sununary Tables IJ I Represents Uncertainty Factor x Moditying Factor IRIS = Integ*rated Risk Inlormation System I U For .ATSDR values, the date ol the .ATSDR document ND = No data For Cal EP.A and IRIS values, the date C.AL EP.A or IRIS were searched PPRT\' = Provisional Peer Reviewed Toxicity Value For HEAST values, tlie date ol HE.AST USEP.A = United States Environmental Protection .Ai-encv For PPRTV values, tlie issue date ol tlie paper Table 7-10 Suiiiniary of Receptor Risks and Hazards for COPCs - Current Maintenance Worker Scenario TIniefranie: Current Receptor Population: Malnteiuince Worker RecentorAge: Adult Carcinogenic Risk Non-Carcinogenic Hazard Quotient Exposure Exposure Chemical of Medium Medium Point Potential Concern Exposure Primars Exposure Ingestion Inlialation Dermal Ingestion Inlialation Dermal Routes Total Target Organ(s) Routes Total Surface Soil Surface Soil Surface Soil Pesticides 4.4'-DDD lE-0' - 5E-08 2E-0' ND -- - - 4.4'-DDE lE-0' - 4E-08 lE-0' ND -- - - 4.4'-DDT oE-0' - 'E-08 oE-0' Li\'er 0.00^^ - 0.001 0.01 •AJclrui ^^E-0' - 4E-0' 1 E-Oo Li\'er 0.005 - 0.002 0.00' alphii-BHC lE-05 - 4E-0O lE-05 Li\'er 0.0005 - 0.0002 0.0008 betii-BHC ^^E-0' - 4E-0' 1 E-Oo ND -- - - deltii-BHC ---- ND -- - - ganiniii-BHC (Linckme) 3E-0' - 4E-08 3E-0' Kidnec; Li\'er 0.002 - 0.0004 0.003 alpha-C'lilordane oE-08 - lE-08 'E-08 Li\'er 0.001 - 0.0002 0.001 ganinia-C'lilordane oE-08 - lE-08 'E-08 Li\'er 0.001 - 0.0002 0.001 Dieldrin 2E-0O - 8E-0' 3E-0O Li\'er 0.00' - 0.003 0.01 Bod\' w eight. Kidne\'. Endosultan Sultate ---- 0.0000^^ - 0.00004 0.0001 Circiilatoix' S\ steni Endrui ---- Li\'er. Ner\'ons S\steni O.OOOo - 0.0003 0.000^^ Endrui .AJdelnde ---- Li\'er. Ner\'ons S\steni 0.0008 - 0.0003 0.001 Endrui Ketone ---- Li\'er. Ner\'ons S\steni 0.0003 - 0.0001 0.0004 Heptaclilor 'E-0' - 3E-0' 1 E-Oo Li\'er 0.000^^ - 0.0004 0.001 Heptaclilor Epoxide 4E-08 - 2E-08 5E-08 Li\'er 0.000^^ - 0.0004 0.001 Toxaphene 5E-0O - 2E-0O 'E-Oo ND -- - - PCBs .-\roclor-1248 8E-0^^ - 5E-0^^ lE-08 ND -- - - .Aroclor-12 54 5E-08 - 3E-08 ^^E-08 E\es. Skin. Inunnne S\steni 0.004 - 0.002 O.OOo .-\roclor-12oO 3E-08 - 2E-08 5E-08 ND -- - - Dioxins and Furans TEC 5E-0' - 'E-08 oE-0' Reprodncti\'e S\steni 0.02 - 0.002 0.02 Inorganics •AJiuniniun ---- Ner\'oiLs S\steni O.OOOo - - O.OOOo •Antinioin' ---- Longe\"it\'. Blood 0.002 - - 0.002 •Arsenic 5E-0O - lE-Oo 'E-Oo Cardio\'asciilar S\ steni. Skin 0.03 - 0.00' 0.04 Barinni ---- Kidne\' 0.0001 - " 0.0001 Cliroininni 3E-0' -- 3E-0' None Reported O.OOOo - " O.OOOo Cobalt ---- Tlnroid 0.0005 - " 0.0005 Copper ---- Gastrointestinal 0.0003 - " 0.0003 CAanide ---- Reprodncti\'e S\steni 0.0001 - " 0.0001 Iron ---- Gastrointestinal 0.005 - " 0.005 Lead ---- ND -- " - Manganese ---- Ner\'oiLs S\steni 0.0002 - " 0.0002 Merciux' ---- ND -- " - Thalliiun ---- Skin 0.02 - " 0.02 X'anadiiun ---- Hair 0.0004 - " 0.0004 Chemical Total 3E-05 - ^^E-Oo 4E-05 0.1 - 0.02 0.1 ExDosure Point Total 4E-05 0.1 ExDosure Medium Total 4E-05 0.1 Pnsie I of 3 Table 7-10 Suiiiniary of Receptor Risks and Hazards for COPCs - Current Maintenance Worker Scenario TIniefranie: Current Receptor Population: Malnteiuince Worker RecentorAge: Adult Carcinogenic Risk Non-Carcinogenic Hazard Quotient Exposure Exposure Chemical of Medium Medium Point Potential Concern Exposure Primars Exposure Ingestion Inlialation Dermal Ingestion Inlialation Dermal Routes Total Target Organ(s) Routes Total Surface Soil Air Particulates Pesticides 4.4'-DDD - 'E-12 - 'E-12 ND -- - - 4.4'-DDE - oE-12 - oE-12 ND -- - - 4.4'-DDT - 3E-11 - 3E-11 ND -- - - •AJclrui - 5E-11 - 5E-11 ND -- - - alphii-BHC - 5E-10 - 5E-10 ND -- - - betii-BHC - 5E-11 - 5E-11 ND -- - - deltii-BHC ---- ND -- - - ganiniii-BHC (Linckme) - lE-11 - lE-11 ND -- - - alpha-C'lilordane - 4E-12 - 4E-12 Li\'er - 0.0000001 - 0.0000001 ganinia-C'lilordane - 4E-12 - 4E-12 Li\'er - 0.0000001 - 0.0000001 Dieldrin - lE-10 - lE-10 ND -- - - Endosultan Sultate ---- ND -- - - Endrui ---- ND -- - - Endrui .AJdelnde ---- ND -- - - Endrui Ketone ---- ND -- - - Heptaclilor - 4E-11 - 4E-11 ND -- - - Heptaclilor Epoxide - 2E-12 - 2E-12 ND -- - - Toxaphene - 3E-10 - 3E-10 ND -- - - PCBs .-\roclor-1248 - 4E-13 - 4E-13 ND -- - - .Aroclor-12 54 - 3E-12 - 3E-12 ND -- - - .-\roclor-12oO - 2E-12 - 2E-12 ND -- - - Dioxins and Furans Li\'er. Reprodncti\'e S\steni. De\'elopniental. TEC - 3E-11 - 3E-11 - O.OOOOOOOo " O.OOOOOOOo Endocrine S\steni. Respirator\' S\steni. Blood Inorganics •AJiuniniun ---- Ner\'oiLs S\steni - 0.00002 - 0.00002 •Antinioin' ---- ND -- - - De\'elopniental. Cardio\'ascnlar S\steni. •Arsenic - 5E-0^^ - 5E-0^^ - 0.0002 " 0.0002 Ner\'ons S\steni. Respiratoiy S\steni. Skin Barinni ---- Eetns - 0.00001 - 0.00001 Cliroininni - 2E-0^^ - 2E-0^^ Respiratoiy S\steni - 0.000004 - 0.000004 Cobalt - ^^E-11 - ^^E-11 Respiratoiy S\steni - 0.000005 - 0.000005 Copper ---- ND -- - - CAanide ---- Endocrine S\steni - 0.00000002 - 0.00000002 Iron ---- ND -- - - Lead ---- ND -- - - Manganese ---- Ner\'oiLs S\steni - 0.00002 - 0.00002 Merciux' ---- Ner\'oiLs S\steni - 0.00000003 - 0.00000003 Thalliiun ---- ND -- - - X'anadiiun ---- Respiratoiy S\steni - 0.000004 - 0.000004 Chemical Total - 8E-0^^ - 8E-0^^ - 0.0003 - 0.0003 Ex'posure Point Total 8E-0^^ 0.0003 lEx'posure Medium Total 8E-0^^ 0.0003 Surface Soil Total 4E-05 0.1 Receptor Total 4E-05 0.1 Pasie 2 of Table 7-10 Suiiiniary of Receptor Risks and Hazards for COPCs - Current Maintenance Worker Scenario TIniefranie: Current Receptor Population: Malnteiuince Worker Receptor Age: Adult Carcinogenic Risk Non-Carcinogenic Hazard Quotient Exposure Exposure Chemical of Medium Medium Point Potential Concern Exposure Primars Exposure Ingestion Inlialation Dermal Ingestion Inlialation Dermal Routes Total Target Organ(s) Routes Total Notes Target Organ HI per Medium - Not Appliciible ND - No Diitii Organ Surface Soil Surface Soil Blood 0.002 Total Blood HI 0.002 Bod\-Weight 0.0001 Total Bod\- Weight HI 0.0001 C'ardio\'iisciilar S\ steiii 0.04 Total Cardio\'asciilar S\steiii HI 0.04 C'irciilatoiy S\ steiii 0.0001 Total Circiilator\' S\steiii HI 0.0001 De\'elopiiieiital 0.0002 Total De\'elopiiieiital HI 0.0002 Eiidociiiie S\^teiii 0.00000008 Total Eiidocritie S\steiii HI 0.00000008 E\es O.OOo Total E\es HI O.OOo Eetiis 0.00001 Total Eetiis HI 0.00001 Gastrouitestuial 0.005 Total Gastrouitestuial HI 0.005 Hair 0.0004 Total Hair HI 0.0004 Iiminuie S\^teiii O.OOo Total hiuiuuie S\steiii HI O.OOo K.id]ie\' 0.003 Total Rid]ie\- HI 0.003 Li\'er 0.04 Total Li\'er HI 0.04 Loiige\"it\' 0.002 Total Loiige\"it\' HI 0.002 Ner\'oiLs S\^teiii 0.003 Total Ner\'oiLs S\steiii HI 0.003 None Reported O.OOOo Total None Reported HI O.OOOo (Drgaii Weight 0 Total (Organ Weight HI 0 Reprodiicti\'e S\ steiii 0.02 Total Reproducti\'e S\steni HI 0.02 Respiratoiy S\^teiii 0.0002 Total Respirator\' S\steni HI 0.0002 Seleiiosis 0 Total Selenosis HI 0 Skill O.Oo Total Skin HI O.Oo SiiiaU iiitestuie Total SniaU uitestine HI Tlniinis 0 Total Tlniiius HI 0 Tlnroid 0.0005 Total Tlnroid HI 0.0005 Pnsie J of 3 Table 7-11 Suiiiniary of Receptor Risks and Hazards for COPCs - Current Trespasser Scenario TIniefranie: Current Receptor Population: Trespasser Receptor Age: Adolescent Carcinogenic Risk Non-Carcinogenic Hazard Quotient Exposure Exposure Chemical of Medium Medium Point Potential Concern Ex'posure Primars Ex'posure Ingestion Inlialation Dermal Ingestion InliaLation Dermal Routes Total Target Organ(s) Routes Total Surface Soil Surface Soil Surface Soil Pesticides 4.4'-DDD 4E-0' - 3E-0' 'E-0' ND ---- 4.4'-DDE 3E-0' - 2E-0' 5E-0' ND ---- 4.4'-DDT 2E-0O - 3E-0' 2E-0O Li\'er 0.0' - 0.01 0.0^^ •AJclrui 3E-0O - 2E-0O 5E-0O Li\'er 0.04 - 0.03 0.0' alphii-BHC 3E-05 - 2E-05 5E-05 Li\'er 0.004 - 0.003 0.00' betii-BHC 3E-0O - 2E-0O 5E-0O ND ---- deltii-BHC ---- ND ---- ganiniii-BHC (Linckme) 8E-0' - 2E-0' lE-Oo Kidne\'. Li\'er 0.02 - 0.004 0.02 alpha-C'lilordaiie 2E-0' - 5E-08 2E-0' Li\'er 0.008 - 0.002 0.01 ganinia-C'lilordane 2E-0' - 5E-08 2E-0' Li\'er 0.008 - 0.002 0.01 Dieldrin oE-Oo - 4E-0O lE-05 Li\'er 0.05 - 0.04 0.0^^ Bod\' w eight. Kidnec; Endosultan Sultate -- " - 0.000' - 0.0004 0.001 Circulator\' S\steni Endrui -- - - Li\'er. Ner\'oiLs S\ steni 0.005 - 0.003 0.008 Endrui .AJdelnde -- - - Li\'er. Ner\'oiLs S\ steni O.OOo - 0.004 0.01 Endrui Ketone -- - - Li\'er. Ner\'oiLs S\ steni 0.002 - 0.002 0.004 Heptaclilor 2E-0O - 1 E-Oo 4E-0O Li\'er 0.00' - 0.005 0.01 Heptaclilor Epoxide lE-0' - 'E-08 2E-0' Li\'er 0.00' - 0.004 0.01 Toxaphene lE-05 - lE-05 2E-05 ND ---- PCBs .-\roclor-1248 2E-08 - 2E-08 5E-08 ND ---- .Aroclor-12 54 2E-0' - 2E-0' 3E-0' E\es. Skin. Inuniuie S\steni 0.03 - 0.03 O.Oo .-\roclor-12oO lE-0' - ^^E-08 2E-0' ND ---- Dioxins and Furans TEC 2E-0O - 3E-0' 2E-0O Reproducti\'e S\steni 0.1 - 0.02 0.2 Inorganics .AJiunituun -- - - Ner\'ous S\steni 0.005 -- 0.005 •Ajitinioin' ---- Longevity; Blood 0.01 -- 0.01 •Arsenic 2E-05 - 5E-0O 2E-05 Cardio\'ascular S\steni. Skiti 0.3 - 0.08 0.3 Bariuni ---- Kidne\' 0.001 -- 0.001 Cliroininni 1 E-Oo -- lE-Oo None Reported 0.005 -- 0.005 Cobalt -- - - Tlnroid 0.004 -- 0.004 Copper -- - - Gastrouitestuial 0.002 -- 0.002 CAanide -- - - Reproducti\'e S\steni 0.001 -- 0.001 Iron -- - - Gastrouitestuial 0.04 -- 0.04 Lead -- - - ND ---- Manganese -- - - Ner\'ous S\steni 0.001 -- 0.001 Merciux' -- - - ND ---- Thalliiun -- - - Skiti 0.1 -- 0.1 X'anadiiun -- - - Hair 0.003 -- 0.003 Chemical Total 8E-05 - 5E-05 lE-04 0.^^ - 0.2 1 Ex'posure Point Total lE-04 1 1 Exijosure Med um Total lE-04 1 Pnsie I of 3 Table 7-11 Suiiiniary of Receptor Risks and Hazards for COPCs - Current Trespasser Scenario TIniefranie: Current Receptor Population: Trespasser Receptor Age: Adolescent Carcinogenic Risk Non-Carcinogenic Hazard Quotient Exposure Exposure Chemical of Medium Medium Point Potential Concern Ex'posure Primars Ex'posure Ingestion Inlialation Dermal Ingestion InliaLation Dermal Routes Total Target Organ(s) Routes Total Surface Soil Air Particulates Pesticides 4.4'-DDD - 3E-12 - 3E-12 ND ---- 4.4'-DDE - 2E-12 - 2E-12 ND ---- 4.4'-DDT - lE-11 - lE-11 ND ---- •AJclrui - 2E-11 - 2E-11 ND ---- alphii-BHC - 2E-10 - 2E-10 ND ---- betii-BHC - 2E-11 - 2E-11 ND ---- deltii-BHC ---- ND ---- ganiniii-BHC (Linckme) - oE-12 - oE-12 ND ---- alpha-C'lilordaiie - 2E-12 - 2E-12 Li\'er - 0.0000002 - 0.0000002 ganinia-C'lilordane - 2E-12 - 2E-12 Li\'er - 0.0000002 - 0.0000002 Dieldrin - 5E-11 - 5E-11 ND ---- Endosultan Sultate -- - - ND ---- Endrui -- - - ND ---- Endrui .AJdelnde -- - - ND ---- Endrui Ketone -- - - ND ---- Heptaclilor - 2E-11 - 2E-11 ND ---- Heptaclilor Epoxide - ^^E-13 - ^^E-13 ND ---- Toxaphene - lE-10 - lE-10 ND ---- PCBs .-\roclor-1248 - 2E-13 - 2E-13 ND ---- .Aroclor-12 54 - lE-12 - lE-12 ND ---- .-\roclor-12oO - 8E-13 - 8E-13 ND ---- Dioxins and Furans Li\'er. Reproducti\'e S\steni. De\'elopniental. TEC lE-11 lE-11 O.OOOOOOOo O.OOOOOOOo - " Endocrine S\steni. Respiratoiy - - S\steni. Blood Inorganics .AJiunituun -- - - Ner\'ous S\steni - 0.00003 - 0.00003 •Ajitinioin' ---- ND ---- De\'elopniental. Cardio\'ascular S\steni. •Arsenic 2E-0^^ 2E-0^^ 0.0002 0.0002 - " Ner\'oiLs S\steni. Respiratoiy - - S\steni. Skin Bariuni -- - - EetiLs - 0.00001 - 0.00001 Cliroininni - 'E-10 - 'E-10 Respiratoiy S\ stein - 0.000004 - 0.000004 Cobalt - 4E-11 - 4E-11 Respiratoiy S\ stein - 0.000005 - 0.000005 Copper -- - - ND ---- CAanide -- - - Endocrine S\steni - 0.00000002 - 0.00000002 Iron -- - - ND ---- Lead -- - - ND ---- Manganese -- - - Ner\'ous S\steni - 0.00002 - 0.00002 Merciux' -- - - Ner\'ous S\steni - 0.00000003 - 0.00000003 Thalliiun -- - - ND ---- X'anadiiun -- - - Respiratoiy S\ stein - 0.000004 - 0.000004 Chemical Total - 3E-0^^ - 3E-0^^ - 0.0003 - 0.0003 Ex'posure Point Total 3E-0^^ 0.0003 lEx'posure Medium total 0.0005 Surface Soil iota! lE-04 1 Receptor Total lE-04 1 Pasie 2 of Table 7-11 Suiiiniary of Receptor Risks and Hazards for COPCs - Current Trespasser Scenario TIniefranie: Current Receptor Population: Trespasser Receptor Age: Adolescent Carcinogenic Risk Non-Carcinogenic Hazard Quotient Exposure Exposure Chemical of Medium Medium Point PotentLal Concern Ex^josure Primars Ex^josure Ingestion Inlialation Dermal Ingestion InliaLation Dermal Routes Total Target Organ(s) Routes Total Notes Target Organ HI per Medium - Not Appliciible ND - No Diitii Organ Surface Soil Surface Soil Blood 0.01 Total Blood HI 0.01 Bod\- Weight 0.001 Total Bod\-Weight HI 0.001 C'ardio\'iisciilar S\^teiii 0.3 Total Cardio\'asciilar S\^teiii HI 0.3 C'irciilatoiy S\^teiii 0.001 Total Circiilatoiy S\^teiii HI 0.001 De\'elopiiieiital 0.0002 Total De\'elopiiieiital HI 0.0002 Eiidocritie S\steiii 0.00000008 Total Eiidocritie S\i>teni HI 0.00000008 E\es O.Oo Total E\es HI O.Oo EetiLs 0.00001 Total EetiLs HI 0.00001 Gastrouitestuial 0.04 Total Gastrouitestuial HI 0.04 Hair 0.003 Total Hair HI 0.003 Iiiuiniiie S\^teiii O.Oo Total liiiimuie S\steni HI O.Oo Kjdiie\' 0.02 T otal Ridne\- H1 0.02 Li\'er 0.3 Total Li\'er HI 0.3 Loiige\"it\' 0.01 Total Longe\"it\' HI 0.01 Ner\'oiis S\steiii 0.03 Total Ner\'oiLs S\steni HI 0.03 None Reported 0.005 Total None Reported HI 0.005 (Drgaii Weight 0 Total (Organ Weight HI 0 Reprodiicti\'e S\ steiii 0.2 Total Reproducti\'e S\steni HI 0.2 Respiratoiy S\ steiii 0.0003 Total Respiratoiy S\steni HI 0.0003 Seleiiosis 0 Total Selenosis HI 0 Skiti 0.5 Total SkitiHl 0.5 SiiiaU uitestiiie Total SniaU intestitie HI TlniiiiLs 0 Total TlnniiLs HI 0 Tlnroid 0.004 Total Tlnroid HI 0.004 Pnsie J of 3 Table 7-12 Suniniar> of Receptor Risks and Hazards for COPCs - Current Off-Site Resident Adult Scenario Tiniefranie: Current Receptor Population: Off-Site Resident Receptor Age: Adult Carcinogenic Risk Non-Carcinogenic Hazard Quotient Exposure Exposure Chemical of Medium Medium Point Potential Concern Exposure Primars Ex^josure Ingestion Inlialatlon Dennal Ingestion InliaLation Dermal Routes Total Target Organ(s) Routes Total Surface Soil Air Particulates Pesticides 4.4'-DDD - 5E-10 - 5E-10 ND ---- 4.4'-DDE - 4E-10 - 4E-10 ND ---- 4.4'-DDT - 2E-0^^ - 2E-0^^ ND ---- .AJdrui - 4E-0^^ - 4E-0^^ ND ---- alphii-BHC - 4E-08 - 4E-08 ND ---- betii-BHC - 4E-0^^ - 4E-0^^ ND ---- deltii-BHC ---- ND ---- ganuiiii-BHC (Luidiuie) - 1E-0^^ - lE-0^^ ND ---- alpha-C'lilordane - 2E-10 - 2E-10 Li\'er - 0.00001 - 0.00001 ganuiia-C'lilordiine - 2E-10 - 2E-10 Li\'er - 0.00001 - 0.00001 Dieldrui - 8E-0^^ - 8E-0^^ ND ---- Endosiiltan Sultate ---- ND ---- Endrui ---- ND ---- Endrui .Aldelnde ---- ND ---- Endrui Ketone ---- ND ---- Heptaclilor - 3E-0^^ - 3E-0^^ ND ---- Heptaclilor Epoxide - lE-10 - lE-10 ND ---- Toxaphene - 2E-08 - 2E-08 ND ---- PCBs .-\roclor-1248 - 3E-11 - 3E-11 ND ---- .Aroclor-12 54 - 2E-10 - 2E-10 ND ---- .-\roclor-12oO - lE-10 - lE-10 ND ---- Dioxins and Furans Li\'er. Reprodncti\'e S\steni. De\'elopniental. TEQ - 2E-0^^ " 2E-0^^ - 0.000005 - 0.000005 Endocrine S\steni. Respiratoix' S\steni. Blood Inorganics .AJnininnni ---- Neix'ons S\steni - 0.002 - 0.0020' •Antinioin' ---- ND ---- De\'elopniental. Cardio\'asciilar S\steni. •Arsenic - 4E-0' - 4E-0' - 0.02 - 0.0RMo4 Ner\'oiLs S\steni. Respiratoix' S\steni. Skin Barinni ---- EetiLs - 0.001 - O.OOO^^^M C'liroiniiun - lE-0' - lE-0' Respiratoix' S\ steni - 0.0003 - 0.00032O Cobalt - oE-0^^ - oE-0^^ Respiratoix' S\ steni - 0.0004 - 0.00041 Copper ---- ND ---- CAanide ---- Endocrine S\steni - 0.000002 - 0.000002 Iron ---- ND ---- Lead ---- ND ---- Miuiganese ---- Neix'ons S\steni - 0.001 - 0.00145 Merciir\' ---- Neix'ons S\steni - 0.000003 - 0.000003 ThaUiiun ---- ND ---- X'anadiiun ---- Respiratoix' S\ steni ---- Chemical Total - oE-0' - oE-0' - 0.02 - 0.02 Exposure Point Total oE-0' 0.02 lEx'posure Medium Total oE-0' 0.02 Surface Soil To tal oE-0' 0.02 Receptor 1 otal oE-0" 0.02 Table 7-12 Suniniar> of Receptor Risks and Hazards for COPCs - Current Off-Site Resident Adult Scenario Tiniefranie: Current Receptor Population: Off-Site Resident Receptor Age: Adult Carcinogenic Risk Non-Carcinogenic Hazard Quotient Exposure Exposure Chemical of Medium Medium Point Potentbl Concern Exposure Primars Ex^josure Ingestion Inlialatlon Dennal Insesllon InliaLation Dermal Routes Total Target Organ(s) Routes Total Notes Target Organ HI per Medium - Not Appliciible ND - No Diitii Organ Surface Soil Surface Soil Blood 0.000005 Total Blood HI 0.000005 Bod\- Weight 0 Total Bod\-Weight HI 0 Cardio\'ascnlar S\steni 0.02 Total C'ardio\'asciilar S\^teiii HI 0.02 Circnlator\' S\steni 0 Total CirciilatoiA' S\^teiii HI De\'elopniental 0.02 Total De\'elopiiieiital HI 0.02 Endocrine S\steni 0.00000' Total Eiidociitie S\^teiii HI 0.00000" E\es 0 Total E\es HI 0 EetiLs 0.001 Total EetiLs HI 0.001 Gastrointestinal 0 Total Gastrouitestuial HI Hair 0 Total Hair HI hnnnine S\steni 0 Total liminuie S\^teiii HI Kidnec' 0 T otal Kjdiie\- H1 0 Li\'er 0.00003 Total Li\'er HI 0.00003 Longe\"it\' 0 Total Loiige\"it\' HI 0 Ner\'ons S\steni 0.02 Total Ner\'oiLs S\^teiii HI 0.02 None Reported 0 Total None Reported HI (Organ Weight 0 Total (Drgaii Weight HI 0 Reprodncti\'e S\ steni 0.000005 Total Reprodiicti\'e S\^teiii HI 0.000005 Respirator^' S\ steni 0.02 Total Respirator\' S\^teiii HI 0.02 Selenosis 0 Total Seleiiosis HI Skin 0.02 Total Skin HI 0.02 SniaU intestine 0 Total Sniall intestine HI TlnniiLs 0 Total TlnniiLs HI Tlnroid 0 Total Tlnroid HI Pasie 2 of 2 Table 7-13 Suniniar> of Receptor Risks and Hazards for COPCs - Current Off-Site Resident Child Scenario Tiniefranie: Current Receptor Population: Off-Site Resident Receptor Age: Cliild Carcinogenic Risk Non-Carcinogenic Hazard Quotient Exposure Ex^josure Chemical of Medium Medium Point Potential Concern Exposure Primars Exposure Ingestion Inhalation Dermal Ingestion Inlialation Dermal Routes Total Target Orsan(s) Routes Total Surface Soil Air Particulates Pesticides 4.4'-DDD - 2E-10 - 2E-10 ND - -- - 4.4'-DDE - lE-10 - lE-10 ND - -- - 4.4'-DDT - 'E-10 - 'E-10 ND - -- - •Alclrui - 1E-0^^ - 1E-0^^ ND - -- - alphii-BHC - lE-08 - lE-08 ND - -- - betii-BHC - 1E-0^^ - 1E-0^^ ND - -- - deltii-BHC ---- ND - -- - ganuiui-BHC (Lindane) - 3E-10 - 3E-10 ND - -- - alpha-C'lilordiiiie - 'E-11 - 'E-11 Li\'er - 0.00001 - 0.00001 ganuna-C'lilordane - 'E-11 - 'E-11 Li\'er - 0.00001 - 0.00001 Dieldrin - 2E-0^^ - 2E-0^^ ND - " - - Endosnltan Siiltate ---- ND - " - - Endrui ---- ND - " - - Endrui .AJdelnde ---- ND - " - - Endrui Ketone ---- ND - " - - Heptaclilor - ^^E-10 - ^^E-10 ND - " - - Heptaclilor Epoxide - 4E-11 - 4E-11 ND - " - - Toxaphene - oE-0^^ - oE-0^^ ND - " - - PCBs .Aroclor-1248 - ^^E-12 - ^^E-12 ND - " - - .Aroclor-12 54 - oE-11 - oE-11 ND - " - - .Aroclor-12oO - 4E-11 - 4E-11 ND - " - - Dioxins and Furans Li\'er. Reproducti\'e S\steni. De\'elopniental. TEQ - oE-10 - oE-10 - 0.000005 " 0.000005 Endocritie S\steni. Respiratoix' S\steni. Blood Inorganics •Aliuniniun ---- Neix'ons S\steni - 0.002 - 0.002 •Antinioin' ---- ND - -- - De\'elopnientaL Cardio\'ascular S\steni. •Arsenic - lE-0' - lE-0' - 0.02 " 0.02 Ner\'oiLs S\steni. Respirator\' S\steni. Skiti Bariiun ---- EetiLs - 0.001 - 0.001 C'liroininni - 3E-08 - 3E-08 Respiratoix' S\steni - 0.0003 - 0.0003 Cobalt - 2E-0^^ - 2E-0^^ Respiratoix' S\steni - 0.0004 - 0.0004 Copper ---- ND - -- - C\anide ---- Endocritie S\steni - 0.000002 - 0.000002 Iron ---- ND - -- - Lead ---- ND - -- - Manganese ---- Neix'ons S\steni - 0.001 - 0.001 Merciux' ---- Neix'ons S\steni - 0.000003 - 0.000003 Thalliiun ---- ND - -- - \'anadiiun ---- Respiratoix' S\steni - -- - Chemical Total - 2E-0' - 2E-0' - 0.02 - 0.02 1 Ex'posure Point Total 2E-0' 0.02 •Exposure Med um Total 2E-0' 0.02 Surface Soil 1 otal 2E-0" 0.02 Receptor Total 2E-0' 0.02 Pasie I of 2 Table 7-13 Suniniar> of Receptor Risks and Hazards for COPCs - Current Off-Site Resident Child Scenario Tiniefranie: Current Receptor Population: Off-Site Resident Receptor Age: Cliild Carcinogenic Risk Non-Carcinogenic Hazard Quotient Exposure Ex^josure Chemical of Medium Medium Point Potential Concern Exposure Primars Exposure Ingestion Inhalation Dermal Ingestion Inlialation Dermal Routes Total Target Organ(s) Routes Total Notes Target Organ HI per Medium - Not Appliciible ND - No Diitii Organ Surface Soil Surface Soil Blood 0.000005 Total Blood HI 0.000005 Bod\- Weight 0 Total Bod\- Weight HI 0 Cardio\'ascnlar S\steni 0.02 Total C'ardiowisciilar S\^teiii HI 0.02 Circiilator\' S\steni 0 Total C'irciilator\' S\^teiii HI De\'elopniental 0.02 Total De\'elopiiieiital HI 0.02 Endocrine S\steni 0.00000' Total Eiidociitie S\^teiii HI 0.00000" E\es 0 Total E\es HI 0 Eetns 0.001 Total Eetiis HI 0.001 Gastrointestinal 0 Total Gastrouitestiiial HI Hair 0 Total Hair HI hnnnine S\steni 0 Total liminuie S\^teiii HI Kidnec' 0 Total Kjdiie\- HI 0 Li\'er 0.00003 Total Li\'er HI 0.00003 Longe\"it\' 0 Total Loiige\"it\' HI 0 Ner\'ons S\steni 0.02 Total Ner\'oiLs S\^teiii HI 0.02 None Reported 0 Total None Reported HI (Organ Weight 0 Total (Drgaii Weight HI 0 Reprodncti\'e S\ steni 0.000005 Total Reprodiicti\'e S\steiii HI 0.000005 Respirator^' S\ steni 0.02 Total Respirator\' S\steiii HI 0.02 Selenosis 0 Total Seleiiosis HI Skin 0.02 Total Skin HI 0.02 SniaU intestine 0 Total Small intestine HI Tlnnnis 0 Total Tlnnnis HI Tlnroid 0 Total Tlnroid HI Pasie 2 of 2 Table 7-14 Suiiiniary of Receptor Risks and Hazards for COPCs - Future Industrial Worker Scenario TIniefranie: Future Receptor Population: Industrial Worker RecentorAge: Adult Carcinogenic Risk Non-Carcinogenic Hazard Quotient Exposure Exposure Chemical of Medium Medium Point Potential Concern Exposure Primarx Exposure Ingestion Inlialatlon Dermal Ingestion Inlialation Dermal Routes Total Target Organ(s) Routes Total Surtiice SoO Surtiice SoO Surtiice SoO Pesticides 4.4'-DDD lE-Oo - 1 E-Oo 2 E-Oo ND - -- - 4.4'-DDE lE-Oo - ^^E-0' 2 E-Oo ND - -- - 4.4'-DDT oE-Oo - lE-Oo 'E-Oo Li\'er 0.1 - 0.02 0.1 .AlclrOi lE-05 - 8E-0O 2E-05 Li\'er 0.05 - 0.04 0.1 alpha-BHC' lE-04 - 8E-05 2E-04 Li\'er O.OOo - 0.005 0.01 beta-BHC lE-05 - 8E-0O 2E-05 ND - -- - delta-BHC ---- ND - -- - gaiuiua-BHC' (LOiclaue) 3E-0O - ^^E-0' 4E-0O Kidne\'. Li\'er 0.02 - 0.00' 0.03 alpha-C'lOordaue 'E-0' - 2E-0' ^^E-0' Li\'er 0.01 - 0.003 0.01 gaiuiua-C'lOordaue 'E-0' - 2E-0' ^^E-0' Li\'er 0.01 - 0.003 0.01 DieldrOi 2E-05 - 2E-05 4E-05 Li\'er 0.0' - O.Oo 0.1 Bod\' w eight. Kidne\'. EiidosiOtau Sultate ---- 0.000^^ " 0.0008 0.002 Circnlatoix' S\ stem EiidrOi ---- Li\'er. Ner\'ons S\stem 0.00' - 0.005 0.01 EiidrOi .Aldelnde ---- Li\'er. Ner\'ons S\stem 0.008 - 0.00' 0.02 EiidrOi Ketone ---- Li\'er. Ner\'ons S\stem 0.003 - 0.003 O.OOo HeptaclOor 'E-Oo - oE-Oo lE-05 Li\'er 0.00^^ - 0.008 0.02 HeptaclOor Epoxide 4E-0' - 3E-0' 'E-0' Li\'er 0.00^^ - 0.008 0.02 Toxaphene 5E-05 - 4E-05 ^^E-05 ND - -- - PCBs .-\roclor-1248 8E-08 - lE-0' 2E-0' ND - -- - .Aroclor-12 54 oE-0' - 'E-0' 1 E-Oo E\es. Skin. Inunnne S\stem 0.04 - 0.05 0.08 .-\roclor-12oO 3E-0' - 4E-0' 'E-0' ND - -- - Dioxins and Furans TEQ ---- Reprodncti\'e S\stem 0.2 - 0.04 0.2 Inorganics .AJuinOuiiu ---- Ner\'oiLs S\stem O.OOo -- O.OOo •Autinioin' ---- Longe\"it\'. Blood 0.02 -- 0.02 •Arsenic oE-05 - 2E-05 8E-05 Cardio\'ascnlar S\ stem. Skin 0.3 - 0.1 0.5 Barium ---- Kidne\' 0.002 - " 0.002 C'liromiiuii 4E-0O -- 4E-0O None Reported 0.00' - " 0.00' Cobalt ---- Tlnroid 0.005 - " 0.005 Copper ---- Gastrointestinal 0.003 - " 0.003 CAanide ---- Reprodncti\'e S\stem 0.001 - " 0.001 Iron ---- Gastrointestinal 0.05 - " 0.05 Lead ---- ND - - " - Manganese ---- Ner\'oiLs S\stem 0.002 - " 0.002 Merciux' ---- ND - - " - ThaOiiun ---- Skin 0.2 - " 0.2 X'anadiiun ---- Hair - - " - Chemical Total 3E-04 - 2E-04 5E-04 1 - 0.4 •) Exposure PoOit Total 5E-04 •) Exposure Meclii uii Total 5E-04 •) Pnsie I of 3 Table 7-14 Suiiiniary of Receptor Risks and Hazards for COPCs - Future Industrial Worker Scenario TIniefranie: Future Receptor Population: Industrial Worker RecentorAge: Adult Carcinogenic Risk Non-Carcinogenic Hazard Quotient Exposure Exposure Chemical of Medium Medium Point Potential Concern Exposure Primarx Exposure Ingestion Inlialatlon Dermal Ingestion Inlialation Dermal Routes Total Target Organ(s) Routes Total Surtiice SoO .Air Particulates Pesticides 4.4'-DDD - 2E-10 - 2E-10 ND - -- - 4.4'-DDE - lE-10 - lE-10 ND - -- - 4.4'-DDT - 'E-10 - 'E-10 ND - -- - •Alclriti - lE-0^^ - 1E-0^^ ND - -- - alpha-BHC - lE-08 - lE-08 ND - -- - beta-BHC - lE-0^^ - 1E-0^^ ND - -- - delta-BHC ---- ND - -- - gaiiinia-BHC (Liticlaiie) - 3E-10 - 3E-10 ND - -- - alpha-C'lilordaiie - 'E-11 - 'E-11 Li\'er - 0.000003 - 0.000003 gaiiinia-C'lilordaiie - 'E-11 - 'E-11 Li\'er - 0.000003 - 0.000003 Dieldriti - 2E-0^^ - 2E-0^^ ND - -- - Eiidosultaii Sultiite ---- ND - -- - Eiidriti ---- ND - -- - Eiidriti .Aldelnde ---- ND - -- - Eiidriti Ketone ---- ND - -- - Heptaclilor - 8E-10 - 8E-10 ND - -- - Heptaclilor Epoxide - 4E-11 - 4E-11 ND - -- - Toxaphene - oE-0^^ - oE-0^^ ND - -- - PCBs .Aroclor-1248 - ^^E-12 - ^^E-12 ND - -- - .Aroclor-12 .^^4 - oE-11 - oE-11 ND - -- - .Aroclor-12oO - 4E-11 - 4E-11 ND - -- - Dioxins and Furans Li\'er. Reprodncti\'e S\steni. De\'elopniental. TEQ 0.000001 0.000001 ---- Endocrine S\steni. Respiratoiy - " S\steni. Blood Inorganics .Aliuiiituuii ---- Ner\'oiLs S\steni - 0.000.^ - 0.000.^ .Ajitinion\' ---- ND - " - - De\'elopniental. Cardio\'ascnlar S\steni. •Arsenic - lE-0' - lE-0' - 0.00.^ " 0.00.^ Ner\'ons S\steni. Respirator\' S\steni. Skin Barinin ---- Eetns - 0.0002 - 0.0002 C'liroiniiun - 3E-08 - 3E-08 Respiratoiy S\steni - 0.00008 - 0.00008 Cobalt - 2E-0^^ - 2E-0^^ Respiratoiy S\steni - 0.0001 - 0.0001 Copper ---- ND - " - - CAanide ---- Endocrine S\steni - 0.0000004 - 0.0000004 Iron ---- ND - " - - Lead ---- ND - " - - Manganese ---- Ner\'oiLs S\steni - 0.0003 - 0.0003 Merciux' ---- Ner\'oiLs S\steni - 0.000000' - 0.000000' ThaUiiun ---- ND - " - - X'anadiiun ---- Respiratoiy S\steni - " - - Chemical Total - 2E-0' - 2E-0' - O.OOo - O.OOo lExposure Pouit Total 2E-0' O.OOo txposure Mecliiuii lotal 2E-0" O.OOo Surtiice Soil Total .^E-04 •) Pasie 2 of Table 7-14 Siuiimary of Receptor Risks and Hazards for COPCs - Future Industrial Worker Scenario Timeframe: Future Receptor Population: Industrial Worker RecentorAge: Adult Carcinogenic Risk Non-Carcinogenic Hazard Quotient Exposure Exposure Chemical of Medium Medium Point Potential Concern Exposure Primarx Exposure Ingestion Inlialation Dermal Ingestion Inlialation Dermal Routes Total Target Organ(s) Routes Total Grouiidwiiter \'apors Itidoor .Air from \'ia 1 OCs ShaUow \'apor liitriLsioi 1.2.4-Trimeth\ibeiizeiie ---- Blood - 0.004 - 0.004 Groiuidwater 1.3-Diclilorobeiizeiie ---- Li\'er - 0.00003 - 0.00003 1.4-Diclilorobeiizeiie - 2E-0' - 2E-0' Li\'er - 0.0000' - 0.0000' Clilorobeiizeiie ---- Kjdne\'. Li\'er - 0.00' - 0.00' Tricliloroetlnieiie - 8E-08 - 8E-08 Eetiis. TlmiiiLs - 0.03 - 0.03 \'iit\ l Cliloride - 4E-08 - 4E-08 Li\'er - 0.0002 - 0.0002 Inorga/iics .Ammonia as N ---- Respiratoiy S\stem - 0.0.^ - 0.0.^ Chemical Total - 3E-0' - 3E-0' - 0.0^^ - 0.0^^ lExposiire Pouit Total 3E-0' 0.0^^ Itxposiire Mediiuii lotal 3E-0" O.Od Groiuidwiiter Total 3E-0' 0.0^^ IReceptor Total .^E-04 Notes Target Organ HI per Medium - Not Appliciible Surface Soil ND - No Diitii Organ Surface Soil Groundwater and Groundwater Blood 0.02 0.004 Total Blood HI 0.02 Bod\-Weight 0.002 0 Total Bod\- Weight HI 0.002 Cardio\'asciilar S\ stem 0..^ 0 Total Cardio\'ascnlar S\stem HI 0.5 CircnlatoFN' S\stem 0.002 0 Total Circiilator\' S\stem HI 0.002 De\'elopmeiital 0.00.^ 0 Total De\'elopmental HI 0.005 Endocrine S\stem 0.000002 0 Total Endocritie S\stem HI 0.000002 E\es 0.08 0 Total E\es HI 0.08 Eetns 0.0002 0.03 Total Eetns HI 0.03 Gastrouitestinal O.Oo 0 Total Gastrouitestinal HI O.Oo Hair 0. 0 Total Hair HI 0. Immune S\stem 0.08 0 Total Immiuie S\stem HI 0.08 Kidnec' 0.03 0.00' Total Ridne\-HI 0.04 Li\'er 0..^ 0.00' Total Li\'er HI 0.5 Longe\"it\' 0.02 0 Total Longe\"it\' HI 0.02 Ner\'ons S\stem 0.0.^ 0 Total Ner\'ous S\stem HI 0.05 None Reported 0.00' 0 Total None Reported HI 0.00' (Organ Weight 0 0 Total (Organ Weight HI 0 Reprodncti\'e S\ stem 0.2 0 Total Reproducti\'e S\stem HI 0.2 Respirator\' S\stem 0.00.^ 0.05 Total Respiratoiy S\stem HI 0.05 Selenosis 0 0 Total Selenosis HI 0 Skiti 0.8 0 Total SkitiHl 0.8 SmaU uitestuie 0 0 Total SmaU intestuie HI 0 TlmniLs 0 0.03 Total TlmniLs HI 0.03 Tlnroid 0.00.^ 0 Total Tlnroid HI 0.005 Pnsie J of 3 Tahle 7-lS Su/iuiiar) "f ReoephT Risks and Hazards T^r CO PCs - Future C^nst rui'ti"n Worker Seenari" Tinierratne: Future Receptor P"pulati"n: C"nstruili"n Worker Reeepliir Age: Adult CiTcixiogeiiic Ri*k N«n'Circixi"g«'iic HiZird 'Ju^Uoil E»p..»iire E»p.»ur ChemiciJ "f Medium P-im potential Concern Exp...iir« Prinui7 E»p.»ure Inge^lJo U--ulfs Rouiet Total Al.ln;, ilfhi EH' E' Ki'Jtc^/, 'rir.ijlii' r/ ii, Ki'Jtc^/, 'Tir. ijl )!• r/ ii, Ki'Jtc^/, 'Tir. ijl )!• r/ • EF' --IJ^ • ptic'til I •stt/ Furans 'Jij. fnor^ti L' ti^^viiy. El' • .J ? iT'J !• V).. IJIiT ."y. ."ku N' ti" r.*T' '"'"•J r.^TT' 'jij. Tahle 7-lS Su/iuiiar) "f ReoephT Risks and Hazards T^r CO PCs - Future C^nst rui'ti"n Worker Seenari" Tinierratne: Future Receptor P"pulati"n: C"nstruili"n Worker Reeepliir Age: Adult CiTcixiogeiiic Ri*k N«n'Circixi"g«'iic HiZird 'Ju^Uoil E»p..»iire E»p.»ur ChemiciJ "f Medium P-im potential Concern Exp...iir« Prinui7 E»p.»ure Ingestion U--ulfs Rouiet Total Al.ln;, ilfhi EH' E HC ' L Ui'J iti-1 ilfh I "hi' rJifi- [•I'l.ln;, • EF' --IJ^ •stt/ Furans L w^. r.-f f' 'jij. • pic^il ll, I'^11, r.-. f i; )!• r/ 111. El • .J lahle /-I? Su/iuiiar) "f ReoephT Risks and Hazards T^r CO PCs - Future C^nst rui'ti"n Worker Seenari" Tinierratne: Future Receptor P"pulati"n: C"nstruili"n Worker Rei'enliir Aoe' AHiill CiTcixiogemc Ri*k N«n'Circixi"g«'iic HiZird 'Ju^Uoil E»p..»ure E»p.»ure ChemiciJ "f Medium Medium P"im potential Concern E»p..»ure Prinui7 E»p.»ure Insertion Intublion [)emu 1 lnh^U**n [termd Routes TotaJ Tirvrt Urvants) Rouiet Total jije. ii;( i.-- il Ai'lJiiUiilJii N-r/' ij. ."y.I'^ii ,-JilUlr liV NC' C-'V-I' il, '? iT'J !• V). JJ1 iT ."v. l-tli, IE 1 E N'T"/' IJ. ."y.r.-.f iTii' r/ •y."kui F-iij. "I'l/iiMjrii "E 1 1 "E 1 1 •riiT' riiiij/ii TE TE r.-. r If >'• r/ ."y. ii^ii 1- ill 'E 1 1 'Ell r.-. r i;)!• r/ ."y. ii^n NC' "viriij' EJI'J' .rui- ."y. ii^ii 1 1 If' Il NC' L-iJ NC' Miri;ji'.' N-r/' IJ. ."y.ii^ii M-r. 'IT,' N-r/' IJ. ."y.ii^ii Ni.k'l IE 1 1 1 E 1 1 r.-. r If ii' r/ ."y. ii^ii .•ilvfl NC' Tti IIIMJIII NC' iji ijMCli r.-. r If ii' r/ ."y. ii^ii Zui. NC' •rti-riii. 11 !• 1 il IE "T 1 E "T t-p' -UT' f' Uil 1 • III 1 t "T :-,r' -UT' !• 1,1 rijr.url,.-:' il !• 1,1 1 1 E "J Tahle 7-lS Su/iuiiar) "f ReoephT Risks and Hazards T^r CO PCs - Future C^nst rui'ti"n Worker Seenari" Tinierratne: Future Receptor P"pulati"n: C"nstruili"n Worker Reeepliir Age: Adult CiTcixiogeiiic Ri*k N«n'Circixi"g«'iic HiZird 'Ju^Uoil E»p..»iire E»p.»ur ChemiciJ "f Medium P-im potential Concern E»p.. Prinui7 E»p.»ure Ingestion IniublJon [)emul Rouiet Total iCi'J^k 1 • Trfli.h •,-J Truii-itivle^^Li'^i'' • f-T' H-J F-1IJ., Thviiiij., ItiJill ,•,-1 flK N ifhih Al.lnii ilfhi EH' •J'li, EH" Ev-., jk Ji, IIIJill lahle /-I? Su/iuiiar) "f ReoephT Risks and Hazards T^r CO PCs - Future C^nst rui'ti"n Worker Seenari" Tinierratne: Future Receptor P"pulati"n: C"nstruili"n Worker Rei'enliir Aoe' AHiill Carcin' 'euic Ri^k N'n-Carcixi"gemc Hazard tJuoUenl E»p..»ure E»p.»ure ChemiciJ "f Medium Medium poim pi'lenli^l Concern E»p..»ure Primary E»p.»ure Insertion Intublion [)emia 1 Inge^lJ' in Inhablion [termaJ Routes ToiaJ Tarrel (Trrant*) Roulet Tola! ijtiJ\k ii*T ijtij\k ii*T ij/ij-j, ,1't Al'lJiiUiilJii N-r/' ij. _"v.i-iii II III 111 IJ • TrfliJi. ,-jijir rm 1. N N[' ,-JilUlr liV L' riC'vnv, ET • J ,-J.flil. 'E "" JE "" „E M- •? ill !• Vi.. IJ 1 iT _"v. l-lli, jkui Mil,.. II 1 Eiriij/ii Ki'Jiii^.' II III II 1 ii_ EI^/IIMJIII JE "" JE JE Jill ill Uil-.lUi- E' !• Ii [••"-/-I' riiii'iii 11 1 •ri'l;iiiijrii Ki'Jiii^.' II III ll_ ii_ •riiT' riiiij;ii TE "" N' III- f.iT' n-J II lU -•i-ili IliVT' ij Mill 1. If' Uil-. lUi |I If' Ii 1. If' Uil-. lUi |I L-iJ N[' Miri;i;i'.' N-r/' IJ. _"v.i-iii II 1 ii_ Ni.k'l E' JyV-Vizlii, • rziii '.k'izlii II lU Nii/ii' 1. N ET • J 1 .-'kiiijii, .•'kr.i. .•ilvfl Ekui Til illiijrii Ekui II III iji ilMCii Hii; II lU 1 1 Zui. ET • J II lU •rti-riii. 11 T' 1 il JE IE "J 1 E "J 1 1 1 I: :-,r' -UT' !'• Uii !• Ill 1 E "J I: E-,f' .IJT' !• Ill 1 E "J I: lahle /-I? Su/iuiiar) "f ReoephT Risks and Hazards T^r CO PCs - Future C^nst rui'ti"n Worker Seenari" Tinierratne: Future Receptor P"pulati"n: C"nstruili"n Worker Rei'enliir Aoe' AHiill Carcin' 'euic Ri;k N'n-Carcixi"gemc Hazard tJuoUenl E»p..»ure E»p.»ure ChemiciJ "f Medium Medium poim potential Concern E»p..;ure Primary E»p.;ure Insertion Intublion [)emia 1 Inge^lJ' in Inhablion [termaJ Routes ToiaJ Tarrel t.trrani;) Route; Tola! ijtiJ\k ii*T •••if.r. iT.r,, VOCs rt' rii IIIIILIIII' ri 1,1 Jl. Ill' !• flJivlfli' Livhf :i, ill' 'vk • Trfli.li. 1 _,J Tri;iiflliv!e»iL;»ii' E!" 'J "J "J IJtl'Jkk ll*T l_ ['l.lil' !• E' 'JvV.Vi;l,i l_ ['1.1,1' rrrTCi' .E "T . E "T [.-. r i;ii' r.' _"v. i-in 1 _ T ri;iiflliv!e»iL;»ii' E!'"J "J "J 1. ['l.lil' !• Livhf 1 ,J ['l.lil' f' t-ncn,' JE JE Livhf M M| o o| If N-r/' ij. IV.i-iii 1 1 Eflii'ii' TE "T TE "T E!" 'J M ,l_' o ,l_' •:,re' ii 'JI.IJIII'J' N-r/' IJ. IV.i-iii 1 1 •:ii!' !• Ki'lji'v. Livr 1 1 •:ii!' !• rii'aiiri' N-r/' IJ. _"v.ii^ii " 1 " 1 . 1. 1 ['l.lil' r"-ai'ri' N[' EiJiv!i-'rL;>ii' TE "" TE "" F'lij. I.TrTvle-n:',,' EJI'J' . rui- jv.ii^ii. Ki'Jri*^.' M'aiv! Eaiv! Kt' If ['•"-/-I' riii'Tii 11 r, [TTvle-n:^,- ['•"-/-I' riiii'iii 11 ' Xvl^i' N-r/' ij. JV.ii^ii ,, ,u M ,U r 1.' rf' rvli' lij-ri- EJI'J' . rui- J V. ii^ii. Ki'Jri*^.' .1. Eijiyli-ii;',!' N[' 1/ill. 1 ['1.Ii 1' T'•'iJi-ri- N[' Tn. Ill' f' 'iJiv!»ii' TE "" TE "" F-iij., TtivTiiiJ. •••uivl .III' ri'J' IE "" 1 E "" Livhf M ,l_' O ,l_' Xvlfli"!' I,!' N-r/' ij. J V. ii^ii ,, ,u M ,U stoa .••riil' r Fli^i'l N[' _• NMIivl/iirliiJi il'ii' N[' ,^..-„,Fl,il,^,- N[' ['le-TL;' hi;ill N[' Flij' rhii' N[' N-r/' IJ. J V. 11^11. [.-. F i;i'' r.' NiFliiliilhii' JE JE 1 1 "v. i-rii lahle /-I? Sujiuiiar) < Carcin' 'enic Ri^k N'n-Carcixiogemc Hazard tJuoUent E),p..»iir« E^v^ur, C*h«niicaJ "f M«diiini M«dj 11X11 P-inl pi'lenli^l Concern Espo^ure Primary Esp.nire Ingestion Inhabtion [temia 1 lnge)U' in InhabUon [terniaJ Routes Total Jarre) t.trrani)) Route) Tola! •.')p r. rr.ri, P.iririd.i rT' til IIIIILIIII' ri 1 _.-.J Tifi. hi' f' i-'rL;»ii' N[' :t, )!!• • Trfli.h. 1 _.J.- Tifi. hi' f' i-'rL;»ii' N[' ' .Jjiji,' r,i, N F.i-. r IT ii' 1-.' _"v. itii |io" |io" •"hTliI ,1 T' 1,1 .'E .'Elf III,... III,... t-p' .'U' b' Uil 1 • III .'t II- III,... l-XT' JiT- M-'jMi/li T' 1)1 .'E If . Target t.trgan H1 per Medium " N' 1 >4"^li. ii"!- Suh)urbce S'U NC' N' [•)!) t.trgan Suh)urbce S'U (jfoundwa ter and (jroundwater E!" 'J M ,C J !• 1,1 El' ' 'J HI J E' 'JyV-'-i^hi II 1 T 1,1 E' 'JyV-'-i;!,! HI •? iT'J 1' Vi.. ij 1 iT V.ltli II 1 !• i,l':,r'Ji y,..ijl,r _"y.i-tn HI •rir.ijlii' r.'_"v.i-iii II 1 T'l,!'? .|j!,i' r,- ."y.iTii HI II 1 [•'v-l' pii-iii i! M ,C !• 1 I ['t;»|' pii^ni,! HI EJI'J' .rui' .'V. i»iii 1 !• 1,1 Eji'J'..rui':v.i'ri, HI Ev. 1 !• 1,1 Ey. HI 1 Ft ij. !• 1,1 Ftij. HI 1. If' Uii-. lui i! II 1 II 1 !• 1, •" ,.!/• Uil'.IUu! HI Hii; 1 !• 1,1 H,i; HI 1 Ijiiriiiiji'' jv. i-iii 1 T'l, Ijiiriiijji' ."y.iTii HI 1 Ki'liit,' !• 1,1 Kl'ljity HI Livt !• 1,1 Liyt HI L' M ,C !• 1,1 L' HI N-r/' IJ. _"v.It! !• 1,1 Nt-y IJ. ."v.iTii HI N' ri' r.»p' ntj !• 1 I N' fi' F.f' IT'J HI 'IT^III V-'^l^hl M ,C ,1 'FT;,:, V-'-I;!,! HI F.-pf' 'Jij. iiv- i-rii 1 !• 1,1 F.f!• ' 'Jij.iiy ."y. iTii HI 1 F.-. f i;ii' r.' _"v. i-rii ||fT !• 1,1 F.' f i; ,1' r.- _"y. i-tn HI lifT .-'It,'.!. !• i,!:'!tr .1. HI Ekj, 1 1 !• 1,1 ."kui HI Tahle 7-lS Su/iuiiar) "f ReoephT Risks and Hazards T^r CO PCs - Future C^nst rui'ti"n Worker Seenari" Tinierratne: Future Receptor P"pulati"n: C"nstruili"n Worker Reeepliir Age: Adult CiTcixiogeiiic Ri*k N«n'Circixi"g«'iic HiZird 'Ju^Uoil E»p..»iire E»p.»ur ChemiciJ "f Medium P-im potential Concern Exp...iir« Prinui7 E»p.»ure Insetlion U--ulfs Tarc^ Orcan(») Rouiet Total Ttiviiiij. I Tlivimj. HI TliVT' |.J I TlivT' i.J HI Table 7-16 Suniniar> of Receptor Risks and Hiizards for COPCs - Future Adult Groundwater l^ser Scenario TIniefranie: Future Receptor Population: Hypothetical Groundwater l^ser Recentor Age: Adult Carcinogenic Risk Non-Carcinogenic Hazard Quotient Exposure ExTjosure Chemical of Medium Medium Point Potential Concern Exposure Prima r> Exposure Ingestion Inlialation Dermal Ingestion Inlialation Dermal Routes Total Target Organ(s) Routes Total Groundwiiter Groundwiiter Groundwiiter 1 OCs l.l-DicliJoroeth\lene ---- Li\'er 0.00.^ - O.OOOo 0.005 1.2.4-T rinietlnlbenzene ---- ND - - - - 1.2-DicliJorobenzene ---- None Reported 0.03 - 0.02 0.04 1.2-DicliJoropropiine 'E-Oo - oE-0' 'E-Oo Li\'er 0.00' - 0.000' 0.008 1.4-DicliJorobenzene 2E-0O - 2 E-Oo 4E-0O Li\'er 0.02 - 0.01 0.04 Benzene 2E-0O - 3E-0' 2 E-Oo Blood 0.03 - 0.00.^ 0.04 ClUorobenzene ---- Li\'er 0.4 - 0.1 O.o ClUoroniethane ---- ND - - - - cis-1.2-DicliJoroethene ---- Kidne\' 1 — 0.2 1 Eth\lbenzene 3E-0' - 2E-0' 4E-0' Li\'er. Kidne\' 0.000^^ - 0.000.^ 0.001 Isoprop\lbenzene ---- Kidne\' 0.0008 - 0.000^^ 0.002 TricliJoroeth\lene oE-05 - ^^E-Oo 'E-05 EeUis. Th\inus. hnnuine S\steni 1 " 0.2 \'in\l Cliloride lE-04 - lE-05 2E-04 Li\'er 0.03 - 0.003 0.04 S I OCs 1-Metlnlnuphthiilene 2E-05 - 2E-05 4E-05 Respiratoiy S\ steni 0.03 - 0.04 0.0' 2.4-DicliJorophenol ---- hnnuine S\^teni O.Oo - 0.02 0.0' 2-Meth\lniiphthiilene ---- Respiratoiy S\ steni 0.8 - 1 4-CliJoroiiniline 'E-Oo - 4E-0' 'E-Oo hnnuine S\^teni 0.03 - 0.002 0.03 Acenuphthene ---- Li\'er 0.0.^ — 0.0' 0.1 Dibenzotliran ---- ND 1 - 4 Fluorene ---- Blood 0.0.^ - 0.08 0.1 Naphthalene 4E-04 - 2E-04 oE-04 Bod\- Weight O.o - 0.4 Pesticides 4.4'-DDD oE-Oo - oE-05 oE-05 ND - - - - 4.4'-DDE 2E-0O - 4E-05 4E-05 ND - — - — .AJdrin 'E-05 - 1E-03 1 E-03 Li\'er 0..^ - 0 10 alpha-BHC 2E-03 - 2E-03 4E-03 Li\'er 0.1 - 0.1 0.2 beta-BHC 5E-05 - 4E-05 ^^E-05 ND - - - - delta-BHC ---- ND - - - - gainnia-BHC (Lindane) 4E-04 - 2E-04 oE-04 Kidne\'. Li\'er 4 - 3 0 alpha-CliJordane 3E-0O - 5E-0O 8E-0O Li\'er O.Oo - 0.1 0.2 gainnia-CliJordane 3E-0O - 5E-0O 8E-0O Li\'er 0.0.^ - 0.1 0.2 Dieldrin 2E-04 - 3E-04 4E-04 Li\'er 0.' - 1 -) Endrin ---- Li\'er. Ner\'ous S\^teni 0.0^^ - 0.2 0.3 Endrin aldeh\de ---- Li\'er. Ner\'ous S\^teni O.o - O.o 1 Endrin Ketone ---- Li\'er. Ner\'ous S\^teni 0.2 — 0.2 0.4 HeptacliJor 2E-05 - lE-04 2E-04 Li\'er 0.03 - 0.2 0.3 HeptacliJor Epoxide 5E-05 - oE-05 lE-04 Li\'er - 3 HexacliJorobenzene lE-Oo - lE-05 lE-05 Li\'er 0.004 - 0.03 0.04 PCBs .Aroclor-1254 3E-0O - 'E-05 8E-05 E\es. Skin. Innnune S\steni 0.3 - 0 - Herbicides Pentaclilorophenoi oE-0' - 2 E-Oo 3E-0O Li\'er 0.001 " 0.004 0.005 Pnsie I of -I Table 7-16 Suniniar> of Receptor Risks and Hiizards for COPCs - Future Adult Groundwater l^ser Scenario TIniefranie: Future Receptor Population: Hypothetical Groundwater l^ser Recentor Age: Adult Carcinogenic Risk Non-Carcinogenic Hazard Quotient Exposure ExTjosure Chemical of Medium Medium Point Potential Concern Exposure Prima r> Exposure Ingestion Inlialation Dermal Ingestion Inlialation Dermal Routes Total Target Organ(s) Routes Total Groundwiiter Groundwiiter Groundwiiter Inorganics .AJuniinuni ---- Ner\'oiLs S\steni 5 — 0.03 5 .Ajiinioiiiii us N ---- ND - - - - .Aiitinioiw ---- Longe\"it\'. Blood r3 - 0 •Arsenic 3E-03 - lE-05 3E-03 CardioN'ascular S\ steni. Skin 21 - 0.1 21 Bariiuii ---- Kidnec' 5 - 0.4 5 Beixlliuni 4E-03 - 3E-03 'E-03 Small intestine 0.8 - O.o 1 Boron ---- De\'elopniental 0.4 - 0.002 0.4 Cadniiiuii ---- Kidnec' 3 - 0.3 4 Clironiiuni 4E-02 - 2E-02 oE-02 None Reported 100 - 3" 13' Cobalt ---- Tlnroid 23 - 0.0.^ 23 Copper ---- Gastrointestinal 11 - 0.0.^ 11 Iron ---- Gastrointestinal 13 — O.Oo 13 Lead ---- ND - - - - Manganese ---- Ner\'oiLs S\steni 4 - 0..^ 5 Nickel ---- Bod\' Weight, organ weight 21 - 0..^ Nitrate as N ---- Blood O.o - 0.003 O.o Selenium ---- Selenosis - 0.01 Sih'er ---- Skin 0.0' — 0.00.^ 0.0' Thalliiuii ---- Skin 14 - 0.0' 14 X'anadiuni ---- Hair 12 - 1.^ Zinc ---- Blood 11 - 0.03 11 Chemical Total 5E-02 - 2E-02 8E-02 43.^ - "5 .MO 1 Exposure Point Totul 8E-02 .MO 1 Exposure Media 11T otal 8E-02 .MO Pasie 2 of -I Table 7-16 Suniniar> of Receptor Risks and Hiizards for COPCs - Future Adult Groundwater l^ser Scenario TIniefranie: Future Receptor Population: Hypothetical Groundwater l^ser Recentor Age: Adult Carcinogenic Risk Non-Carcinogenic Hazard Quotient Exposure ExTjosure Chemical of Medium Medium Point Potential Concern Exposure Prima r> Exposure Ingestion Inlialation Dermal Ingestion Inlialation Dermal Routes Total Target Organ(s) Routes Total Groundwiiter Wipors Water \'apors at Showerhead (1) 1 OCs l.l-DicliJoroeth\lene ---- Li\'er - 0.000003 - 0.000003 1.2.4-T rimetlnlbenzene ---- Blood - 0.0003 - 0.0003 1.2-DicliJorobenzene ---- Bod\- Weight - 0.00003 - 0.00003 1.2-DicliJoropropane - oE-04 - oE-04 Respiratoiy Sc stem - 0.000.^ - 0.000.^ 1.4-DicliJorobenzene - 1E-03 - 1 E-03 Li\'er - 0.00000.^ - 0.00000.^ Benzene - ^^E-O.^ - ^^E-O.^ Blood - 0.00001 - 0.00001 ClUorobenzene ---- Kjclnec; Li\'er - 0.000.^ - 0.000.^ ClUoroniethane ---- Ner\'oiLs Scstem - 0.00002 - 0.00002 cis-1.2-DicliJoroethene ---- ND - " - " Eth\lbenzene - 2E-0.^ - 2E-0.^ EeUis - 0.0000002 - 0.0000002 lsoprop\lbenzene ---- Endocrine Scstem. Kidnec' - 0.000000.^ - 0.000000.^ TricliJoroeth\lene - 2E-0.^ - 2E-0.^ EeUis. Th\mus - 0.000^^ - 0.000^^ \'in\l Cliloride - 4E-0O - 4E-0O Li\'er - 0.000003 - 0.000003 S I OCs 1-Metlnlnaphthalene ---- ND - " - " 2-Meth\lnaphthalene ---- ND - " - " Acenaphthene ---- ND - — - — Dibenzofiiran ---- ND - " - " Eluorene ---- ND - " - " Ner\'ous S\stem. Respiratoiy Naphthalene - 3E-02 - 3E-02 - 0.01 - 0.01 S\stem Pesticides 4.4'-DDE - 2E-04 - 2E-04 ND - " - " .AJdrin - oE-03 - oE-03 ND - " - " alpha-ClUordane - 2E-04 - 2E-04 Li\'er - 0.0001 - 0.0001 gamnia-CliJordane - 2E-04 - 2E-04 Li\'er - 0.0001 - 0.0001 HeptaclUor - 2 E-03 - 2 E-03 ND - " - " HeptaclUor Epoxide - .^E-03 - .^E-03 ND - — - — HexaclUorobenzene - lE-04 - lE-04 ND - " - " PCBs .Aroclor-1254 - 3E-04 - 3E-04 ND - " - " Inorganics .Ammonia as N ---- Respiratoiy Sc stem - 0.1 - 0.1 Chemical Total - .^E-02 - .^E-02 - 0.1 - 0.1 Exposure Point Total .^E-02 0.1 Exposure Medium Total .^E-02 0.1 Groundwiiter T otiil lE-01 510 Receptor Totiil lE-01 510 Pnsie J of -/ Table 7-16 Suniniar> of Receptor Risks and Hiizards for COPCs - Future Adult Groundwater l^ser Scenario TIniefranie: Future Receptor Population: Hypothetical Groundwater l^ser Receptor Age: Adult Carclnosenic Risk Non-Carcinogenic Hazard Quotient Exposure ExTjosure Chemical of Medium Medium Point Potential Concern Exposure Prima n» Exposure Ingestion Inlialatlon Dermal Ingestion Inlialatlon Dermal Routes Total Target Organ(s) Routes Total Notes Target Organ HI per Medium (1) (DiiJ\' Groundwiiter C(DPCs considered \'oliitile are e\'aliuited for inJuilation wliile showering. - Not Applicable Organ Groundwater Groundwater ND - No Data Blood Total Blood HI Bod\- Weight Total Bod\-Weight HI Cardio\'ascnlar S\ stein Total Cardio\'asciilar S\steni HI Circnlatoiy S\steni Total Circiilatoiy S\steni HI De\'elopniental 0.4 Total De\'elopniental HI 0.4 Endocrine S\steni 0.0000005 Total Endocrine S\steni HI 0.0000005 E\es Total E\es HI EetiLs Total Eenis HI Gastrointestinal 24 Total Gastrointestinal HI 24 Hair Total Hair HI hnnuine S\steni Total hnnnine S\steni HI Kidnec' Total Ridne\- HI Li\'er Total Li\'er HI Longe\"it\' Total Longe\"it\' HI Ner\'ons S\steni Total Ner\'oiis S\steni HI None Reported 13" Total None Reported HI 13" (Drgan Weight Total (Organ Weight HI Reprodncti\'e S\ stein Total Reprodiicti\'e S\steni HI Respiratoiy S\ steni Total Respiratoiy S\ stein HI Selenosis Total Selenosis HI Skin 41 Total Skin HI 41 Sinall intestine Total Small intestine HI Th\iniis Total Tlniinis HI Th\Toid Total Thcroid HI 2t Pnsie -I of -I Table 7-17 Suniniar> of Receptor Risks and Hazards for COPCs - Future Child Groundwater l^ser Scenario Tiniefranie: Future Receptor Population: Hypothetical Groundwater l^ser Recentor Age: Child Carcinogenic Risk Non-Carcinogenic Hazard Quotient Exposure ExTjosure Chemical of Medium Medium Point Potential Concern Exposure Prunary Exposure Ingestion Inlialation Dermal Ingestion Inlialation Dermal Routes Total Target Organ(s) Routes Total Groiuidwiiter Groiuidwiiter Groiuidwiiter IOCS 1.1 -Dicliloroetlnieiie --- - Li\'er 0.008 - 0.001 0.00^^ 1.2.4-T rinietlnlbeiizeiie — — — - ND - — -- 1.2-Diclilorobeiizeiie --- - None Reported 0.04 - 0.04 0.08 1.2-Dicliloropropaiie 3E-0O - 4E-0' 4E-0O Li\'er 0.01 - 0.001 0.01 1.4-Diclilorobeiizeiie lE-Oo — lE-Oo 2E-0O Li\'er 0.04 — 0.03 0.0' Benzene lE-Oo - 2E-0' 1 E-Oo Blood O.Oo - 0.01 0.0' Clilorobenzene --- - Li\'er 0." - 0.3 1 Cliloroniethane — — — - ND - — -- cis-1.2-Dicli]oroethene --- - Kidne\' - 0.3 Etlnibenzene lE-0' - lE-0' 2E-0' Li\'er. Kidne\' 0.001 - 0.001 0.002 Isoprop\lbenzene — — — - Kidne\' 0.001 — 0.002 0.003 Tricliloroetlnlene 4E-0O " ^^E-0' 5E-0O Eetiis. TlnniiLs. Inumuie S\ steni " 0.4 3 \'in\i Cliloride lE-05 — lE-Oo lE-05 Li\'er O.Oo — O.OOo O.Oo S I OCs 1-Metlnlnaphthalene ^^E-Oo - 2E-05 2E-05 Respiratoiy S\steni 0.05 - 0.0^^ 0.1 2.4-Diclilorophenol — — — - Inumuie System 0.0^^ — 0.04 0.1 2-Meth\lnaphthalene --- - Respiratoiy S\steni 1 - 4 4-Cliloroaniline 3E-0O - 3E-0' 4E-0O Inumuie System 0.05 - 0.004 0.05 Acenaphthene — — — - Li\'er 0.0^^ — 0.2 0.2 Dibenzofiu'an --- - ND - 5 - Flnorene --- - Blood 0.08 - 0.2 0.3 Naphthalene 2E-04 — 2E-04 4E-04 Bod\- Weight 1 — 0.8 -) Pesticides 4.4'-DDD 3E-0O - 4E-05 4E-05 ND - - -- 4.4'-DDE lE-Oo — 3E-05 3E-05 ND - — -- .AJ drill 4E-05 - 8E-04 ^^E-04 Li\'er 0.8 - 20 alpha-BHC lE-03 - lE-03 2E-03 Li\'er 0.2 - 0.2 0.5 beta-BHC 3E-05 — 2E-05 5E-05 ND - — -- delta-BHC --- - ND - - -- ganuna-BHC (Lindane) 2E-04 - 2E-04 3E-04 Kidne\'. Li\'er 0 - 0 12 alpha-Clilordane lE-Oo — 3E-0O 5E-0O Li\'er 0.0^^ — 0.2 0.3 ganuna-CliJordane lE-Oo - 3E-0O 5E-0O Li\'er 0.0^^ - 0.2 0.3 Die!drill 8E-05 - 2E-04 2E-04 Li\'er 1 - -) 4 Endrin — — — - Li\'er. Ner\'ons System 0.2 — 0.3 0.5 Endrin aldelnde --- - Li\'er. Ner\'ons System 1 - 1 Endrin Ketone --- - Li\'er. Ner\'ons System 0.3 - 0.5 0.8 Heptaclilor lE-05 — ^^E-05 lE-04 Li\'er 0.05 — 0.5 0.5 Heptaclilor Epoxide 3E-05 - 4E-05 'E-05 Li\'er 3 - 4 - Hexaclilorobenzene 'E-0' - 8E-0O ^^E-Oo Li\'er 0.00' - 0.0' 0.08 PCBs .Aroclor-1254 2E-0O - 5E-05 5E-05 E\es. Skin. Inumuie S\steni 0.5 - 14 14 Herbicides Pentaclilorophenoi 3E-0' " 1 E-Oo 2 E-Oo Li\'er 0.002 " 0.008 0.01 Pasie I of 2 Table 7-17 Summary of Receptor Risks and Hazards for COPCs - Future Child Groundwater l^ser Scenario Timeframe: Future Receptor Population: Hypothetical Groundwater l^ser Recentor Age: Child Carcinogenic Risk Non-Carclnogenic Hazard Quotient Exposure Ex^josure Chemical of Medium Medium Point Potential Concern Exposure Prunary Exposure Ingestion Inlialatlon Dermal Ingestion Inlialatlon Dermal Routes Total Target Organ(s) Routes Total Groiuidwater Groiuidwater Groiuidwater Inorganics •Aliuniniuii --- - Ner\'oiLs S\steni 0 - 0.0' 0 •Anuiionia as N --- - ND - - -- •Antinioin' --- - Longe\"it\'. Blood 288 - lo 304 •Arsenic lE-03 - lE-05 1E-03 Cardio\'asciilar S\ steni. Skin 35 - 0.3 35 Bariiuii --- - Ridne\' 8 - 1 0 Ber\ilinni 2E-03 - 2E-03 4E-03 Sniall intestine 1 - 3 Boron --- - De\'elopniental 0." - O.OOo 0.' Cadniiiuii --- - Ridne\' 0 - 0.^^ - Clu'oniiiuii 2E-02 - lE-02 3E-02 None Reported loo - 104 2'0 Cobalt --- - Tlnroid - 0.1 Copper --- - Gastrointestinal 18 - 0.1 18 Iron --- - Gastrointestinal - 0.2 Lead --- - ND - - -- Manganese --- - Ner\'oiLs S\steni - - 1 8 Nickel --- - Bod\' Weight, organ weight 35 - 1 3" Nitrate as N --- - Blood 1 - 0.008 1 Seleniiuii --- - Selenosis 4 - 0.03 4 Sih'er --- - Skin 0.1 - 0.01 0.1 Thalliiuii --- - Skin 23 - 0.2 23 \'anadiiuii --- - Hair 21 - - Zinc --- - Blood 18 - 0.0^^ 18 Chemical Total 3E-02 - 2E-02 4E-02 '24 - H^2 ^Mo lExposiu'e Point Total 4E-02 ^Mo lExposiu'e Mediiuii Total 4E-02 ^Mo Groiuidwater T otal 4E-02 ^Mo Receptor Total I 4E-02 ^Mo Notes Target Organ HI per Medium - Not Appliciible ND - No Diitii Organ Groundwater Groundwater Blood Total Blood HI Bod\-Weight 38 Total Bod\'Weight HI 38 C'ardio\'iisciiliir S\ steiii ts Total Cardio\'asciilar S\steni HI Is CirciiliitoiA' S\ steiii Total Circnlator\' S\steni HI De\'elopiiieiital Total De\'elopniental HI Eiidociiiie S\steiii Total Endocrine S\steni HI E\es 14 Total E\es HI 14 EetiLs Total Eenis HI Gastrouitestuial 40 Total Gastrointestinal HI 40 Hair Total Hair HI Iiiuinuie S\steiii Total hnnnuie S\steni HI Kjdiie\' 30 Total Ridne\' HI 30 Li\'er 4'-^ Total Li\'er HI 4^^ Loiige\"it\' 304 Total Longe\'it\' HI 304 Ner\'oiLs S\^teiii Total Ner\'oiLs S\steni HI None Reported Total None Reported HI (Drgaii Weight Total (Organ Weight HI Reprodiicti\'e S\^teiii Total Reprodncti\'e S\steni HI Respirator^' S\'steiii Total Respirator\' S\steni HI Seleiiosis Total Selenosis HI Skin Total Skin HI Sniall intestine Total Sniall intestine HI TlniniLs Total TlniniLs HI Tlnroid to Total Tlnroid HI to Pasie 2 of 2 Table 7-18 Adult Lead Methodology Modeling Results GSD! and PbBo from .Analysis of NH.ANES 199-2004 \'arlable Description of \'arlable I'nits Future Future Current Industrial Construction Trespasser Worker Worker PbS Soil lead concentration ng g or ppm 318..M .MS..M .^"2..'^() Petal maternal PbB ratio " 0.9 0.9 BRSE Biokinetic Slope Factor ng dL per ug da\' 0.4 0.4 0.4 GSD, Geometric stanckird deviation PbB " 1.8 l.S l.S PbB,, Baseline PbB ug dL 1.0 1.0 1.0 Soil ingestion rate (including soil-derived IR;; g dii\' 0.1 o.o.s o.lo indoor dust) Total ingestion rate of outdoor soil and g dii\' " " " indoor dust Weighting tactor: traction of IR; +E. " " " " ingested as outdoor soil Mass traction of soil in dust " " " " Absori^tion traction (same for soil and AF,.:. 0.12 0.12 0.12 dust) " Exposure trequencv' (same for soil and EE,.:, da\ s \T 52 2.'^() 12.*^ dust) AT,„ Averaging time (same for soil and dust) da\ s \T 3o.^ .Vj.S \'5 PEB j.jiiit PbB of adult w orker, geometric mean ug dL 1.2 \.5 23 '-U'^th percentile PbB among fetiLses of adult PEBH,.,.-., ng dL 2.0 .T6 5.A workers Target PbB level ofconceriKe.g.. 10 PbB, ug dL 10.0 1 0.0 lo.o ug dL) Probabilitv' that fetal PbB PbB,. P(PbBn,,i PbB,) 0.008% 0.04% 0.4% assiuning lognonnal distribution Source: U.S. EPA (1 ). Reconuiiendiitions of the Tecluiical Re\'iew Workgroup for Lead for an Interim Approach to Assessing Risks Associated w ith Adult Exposures to Lead in Soil Pnsie I of I Table 7-19 Chenilcals of Ecologlcal Concern and Risk Calculatlon for the Green Heron (St. .Johns Rher) Dose-B;ised Reflnenient Screening - Sedlnient and Food Chain Patlmays Exposure Dose Conser>atl>e TR\' Conser>atl>e HQs Alternative TRY Alternative HQs COEC (mg/kg BW/day) (mg/kg BW/dav) (mg/kg BW/dav) Maxiniuni .A>erage Maximum .A>erage Maximum .A>erage Pesticides Dieldrin O.43E-01 5.1 lE-02 O.O'l ^T1 0.'2 0.1'^^ 3.0 0.2^^ PCBs .Aroclor-1254 4.54E+00 4.03E-01 0.18 25 2.2 1.8 2.5 1 •Aroclor-l 2oO 2.85E+00 4.'8E-01 0.18 lo 2.7 1.8 1.0 p p Metals Lead 4.0'E+OO 5.^T^E-01 1.03 2.0 0.3' l.^N 2.4 0.31 Notes: (1) Prelinunar\- C'(DPEC's in sediment were identified on Table 4-2 of the BER-A (AEC'(DM. 2013) and C'(l)EC's were selected based on risk results. (2) Exposure dose troin Table 4-10 of the BER.A (.AEC'(1)M. 2013). (3) C'onser\'ati\'e TR\'s (toxicity- reference \'alnes) are based on NtO.AELs (no-obser\'ed-ad\'erse-etTect le\'els) tfoin Table 4-14 of the BER-A (AEC'(1)M. 2013). (4) H(^ (hazard quotient) = exposure dose TR\'. (5) .Alteniati\'e TR\'s (toxicity- reference \'alnes) are based on L(l).AELs (lowest-obser\'ed-ad\'erse-etTect le\'els) tfoin Table 4-14 of the BER-A (AEC'(1)M. 20131 BW = bod\' weight C'(1)EC' = chemical of ecological concent C'tOPEC = chemical of potential ecological concern N\' = No \'alne a\'ailable — = Not a\'ailable not applicable Pnsie I of I Table 7-20 Chenilcals of Ecologlcal Concern and Risk Calculatlon for the Raccoon (St. .Johns Rl>er) Dose-Based Reflnenient Screening - Sedlnient and Food Chain Patlmays Exposure Dose Conser>atl>e TR\' Conser>atl>e HQs Alternative TRY Alternative HQs COEC (mg/kg BW/day) (mg/kg BW/dav) (mg/kg BW/dav) Maxiniuni .A>erage Maximum .A>erage Maximum .A>erage Pesticides alpha-BHC 1.4oE+00 4.23E-02 0.014 104 3.0 0.14 10 0.30 Dieldrin o.lOE-01 4.8.^E-02 0.01.^ 41 3.2 0.03 20 1.0 PCBs .Aroclor-12.'^4 4.33E+00 3.84E-01 O.O08 o4 O.08 0.4 O.-'^o •Aroclor-l 2oO 2.'2E+00 4..X1E-OI O.O08 40 0." O.08 4.0 O.o' Metals Lead o.'OE+OO 8.01E-01 4.'0 1.4 o.r 5 1.3 O.lo Notes: (1) Prelinunar\- C'(DPEC's in sediment were identified on Table 4-2 of the BER-A (AEC'(DM. 2013). and C'(l)EC's were selected based on risk results. (2) Exposure dose troin Table 4-11 of the BER.A (.AEC'(1)M. 2013). (3) C'onser\'ati\'e TR\'s (toxicity- reference \'alnes) are based on N(l).AELs (no-obser\'ed-ad\'erse-etTect le\'els) tfoin Table 4-1.^^ of the BER.A (.AEC'(1)M. 2013). (4) H(^ (hazard quotient) = exposure dose TR\'. (.Alteniati\'e TR\'s (toxicity- reference \'alnes) are based on L(l).AELs (lowest-obser\'ed-ad\'erse-etTect le\'els) tfoin Table 4-1.^^ of the BER.A (.AEC'(1)M. 2013i BW = bod\' weight C'(1)EC' = chemical of ecological concent C'tOPEC = chemical of potential ecological concern N\' = No \'alne a\'ailable. — = Not a\'ailable not applicable Pnsie I of I Table 7-21 Cheniictils of Ecologicol Concern ;ind Risk ColcuLitlon for the Anierlcon Robin Dose-B;ised Refinenient Screening - Soil and Eood Chain Patlmavs Exposure Dose Conser>iiti>e TR\' Conser>ati>e HQs .Alternative TRY .Alternative HQs COECs'" (mg/kg BW/diiy) (mg/kg BW/diiv) (mg/kg BW/dav) Moxiniuni A>eriige Maximum A>erage Maximum .A>erage Pesticides 4.4-DDD 1.38E+01 1.3^^E+00 0.22' ol 0.1 0.281 4^^ 5.0 4.4-DDE ^\18E+01 3.21E+00 0.22' 404 14.1 0.281 32' 11.4 4.4-DDT 2.45E+02 1.20E+01 0.22' 1081 53 0.281 8'4 43 .AJdrin '.80E+01 2.0OE+OO 0.5 15o 5.2 5 lo 0.52 alplui-BHC l.ooE+03 5.51E+01 0.5o 2.%1 ^^8 5.0 2% ^\8 betii-BHC 5.'oE+02 1.84E+01 0.5o 102^^ 33 5.0 103 3.3 deltii-BHC l.OOE+02 4.55E+00 0.5o 1'^^ 8.1 5.0 18 0.81 ganuiiii-BHC (lindane) 2.34E+02 8.o^^E+00 2.0 11' 4.3 20 12 0.43 alpha-cliJordiine lA^'E+02 '.O^^E+00 2.14 02 3.3 10.' 18 O.oo ganuna-cliJordiine lA^OE+02 '.25E+00 2.14 8^^ 3.4 10.' 18 O.08 Dieldrin 5.42E+02 1.31E+01 O.O'l '.o32 185 0.1'^^ 302' "3 Endosnltan siiltate 1.35E+02 5.13E+00 1.0 135 5.1 10 13.5 0.51 Endrin l.OOE+02 4.'oE+00 0.01 10.03' 4'o 0.1 1004 48 Endrin aldelnde l.O'E+02 4.55E+00 0.01 10.o'8 455 0.1 IO08 45 Endrin ketone 4.'2E+01 1.8^^E+00 0.01 4.'18 18^^ 0.1 4'2 1^^ HeptacliJor 1.24E+02 3.08E+00 2.08 oO 1.5 20.8 o.O 0.15 HeptacliJor epoxide O.04E+00 1>A^E-01 2.08 2.0 O.O^A^ 20.8 0.2^^ O.OO^A^ Toxaphene 4.25E+03 2.38E+02 0.01 425.0o2 23.84' 0.1 42..^0o 2.385 PCBs .-\roclor-1248 5.3'E-Ol l.o'E-01 0.18 3.0 0.^^ 1.8 0.30 O.O^A^ .Aroclor-l 254 2.43E+01 2.O2E+00 0.18 135 15 1.8 13 1.5 •Arocior-l 2oO '.2^^E+00 1.48E+00 0.18 40 8.2 1.8 4.0 0.82 Pasie I of 2 Table 7-21 Cheniic;ils of Ecologicol Concern ;ind Risk ColcuLitlon for the Anierlcon Robin Dose-B;ised Refinenient Screening - Soil and Eood Chain Patlmavs Exposure Dose Conser>iiti>e TR\' Conser>ati>e HQs Alternative TRY Alternative HQs COECs'" (mg/kg BW/diiy) (mg/kg BW/diiv) (mg/kg BW/dav) Moxiniuni A>eriige Maximum A>erage Maximum A>erage Dioxins and Furans Total Congeners l.loE-03 3.o'E-04 0.000014 83 2o 0.00014 8.3 2.0 Metals •Arsenic l.OlE+02 2.53E+00 2.24 45 1.1 3.55 28 O.'l Copper 4.00E+01 o.4^^E+00 4.05 0 0 1.0 4.o8 8.0 1.4 Lead l.'4E+02 1.1 lE+01 1.03 10' 0.8 l.^M ^^0 5." Thallium 4.31E-01 l.l^^E-01 0.028 15 4.2 0.28 1.5 0.42 Notes: (1) Reflned C'(DPEC's in soil were identifled on Tuble 4-5 of the BER.A (.AEC'tDM. 2013). and C'(l)EC's were selected based on risk results. (2) Exposure dose troiii Table 4-12 of the BER.A (.AEC'(1)M. 2013). (3) C'ouser\'ati\'e TR\'s (toxicity- reference \'alues) are based on N(l).AELs (no-obser\'ed-ad\'erse-etrect le\'els) tfoin Table 4-14 of the BER.A (.AEC'(1)M. 2013). (4) H(^ (hazard quotient) = exposure dose TR\'. (5) .Altenuiti\'e TR\'s (toxicity- reference \'alues) are based on L(l).AELs (lowest-obser\'ed-ad\'erse-etTect le\'els) tfoin Table 4-14 of the BER.A (.AEC'(1)M. 20131 BW = bod\' weight C'(1)EC' = chemical of ecological concern C'tOPEC = chemical of potential ecological concern Pasie 2 of 2 Table 7-22 Cheniicols of Ecologicol Concern ;ind Risk Colcukitlon for the Leost Shrew Dose-B;ised Reflnenient Screening - Soil and Eood Chain Pathways Exposure Dose Conser>iitl>e TR\' Conser>atl>e HQs Alternative TRY Alternative HQs COEC (mg/kg BW/diiy) (mg/kg BW/diiv) (mg/kg BW/dav) Moxiniuni A>eriige Maximum A>erage Maximum .A>erage Pesticides 4.4-DDD o.o"E+00 o>^^^E-01 0.14' 45 4.8 0.2'4 24 2.0 4.4-DDE 4.'4E+01 l.o'E+00 0.14' 323 11.3 0.2'4 1'3 0.1 4.4-DDT I.20E+O2 O.21E+00 0.14' 85o 42 0.2'4 45^^ 23 .AJdrin 4.0'E+Ol I.30E+OO 0.2 203 0.8 1.0 41 1.4 alplui-BHC 8.O4E+02 2.8'E+Ol 0.014 ol.'43 2.051 0.14 0.1'4 205 betii-BHC 3.00E+02 ^\o0E+00 0.4 '51 24 2.0 1.^0 4.8 deltii-BHC 5.24E+01 2.3'E+OO 0.014 3.'40 I'O 0.14 3'4 1' ganuiiii-BHC (lindane) 1.22E+02 4.53E+00 0.014 8.0^^8 324 0.14 8'0 32 alpha-cliJordiine 1.03E+02 3.'0E+00 4.0 •) •) 0.80 02 11 0.40 ganuna-cliJordiine ^\^ME+01 3.'8E+00 4.0 •) •) 0.82 02 11 0.41 Dieldrin 2.83E+02 O.85E+00 0.015 18.8o4 45' 0.03 '-'>432 228 Endosnltan siiltate '.05E+01 2.0'E+OO 0.15 4'0 18 15 4.' 0.18 Endrin 5.23E+01 2.48E+00 0.0^^2 5oO •) - 0.^^2 5" 3 Endrin aldelnde 5.5'E+Ol 2.3'E+OO 0.0^^2 o05 2o 0.^^2 ol 3 Endrin ketone 2.40E+OI ^\83E-01 0.0^^2 2o' 11 0.^^2 -) - 1.1 HeptacliJor 0.4'E+Ol l.oOE+00 0.1 o4' lo 1 o5 1.0 HeptacliJor epoxide 3.15E+00 l.OlE-01 0.1 31 1.01 1 3.1 0.10 Toxaphene 2.22E+03 1.24E+02 0.' 3. loo 1'8 31' 18 PCBs .-\roclor-1248 2.80E-01 8.'0E-02 0.01 28 8.' 0.1 2.8 0.8' .Aroclor-l 254 1.2'E+Ol 1.3'E+OO O.O08 I80 20 O.08 l'^ 2.0 •Arocior-l 2oO 3.80E+00 '.'3E-01 O.O08 5o 11 O.08 5.0 1.1 Pasie I of 2 Table 7-22 Cheniicols of Ecologicol Concern ;ind Risk Colcukitlon for the Leost Shrew Dose-B;ised Reflnenient Screening - Soil and Eood Chain Pathways Exposure Dose Conser>iitl>e TR\' Conser>atl>e HQs Alternative TRY Alternative HQs COEC (mg/kg BW/diiy) (mg/kg BW/diiv) (mg/kg BW/dav) Moxiniuni A>eriige Maximum A>erage Maximum A>erage Dioxins and Furans Total Congeners 3.^C^E-04 l.loE-04 0.000010 12 0.00001 12 Metals •Arsenic 4.12E+01 l.O'E+00 0.25 lo5 4.3 1.2o 33 0.85 Copper l.^ME+01 3.1 lE+00 5.0O 3.4 0.55 0.'^^ 2.8 0.4o Lead '.(.w^E+01 5.0'E+00 4.'0 lo 1.1 5 15 1.0 Thallium 2.I0E-OI 5.^ME-02 0.00'4 20 8.0 0.0'4 2.0 0.80 Notes: (1) Reflned C'(DPEC's in soil were identifled on Tuble 4-5 of the BER.A (.AEC'tDM. 2013). and C'(l)EC's were selected based on risk calculations. (2) Exposure dose troiii Table 4-13 of the BER.A (.AEC'(1)M. 2013). (3) C'onser\'ati\'e TR\'s (toxicity- reference \'alues) are based on N(l).AELs (no-obser\'ed-ad\'erse-etrect le\'els) tfoin Table 4-15 of the BER.A (.AEC'(1)M. 2013). (4) H(^ (hazard quotient) = exposure dose TR\'. (5) .Altenuiti\'e TR\'s (toxicity- reference \'alnes) are based on L(l).AELs (lowest-obser\'ed-ad\'erse-etTect le\'els) tfoin Table 4-15 of the BER.A (.AEC'(1)M. 20131 BW = bod\' weight C'(1)EC' = chemical of ecological concern C'tOPEC = chemical of potential ecological concern Pasie 2 of 2 Table 7-23 Chenilcals of Ecologlcal Concern and Risk Calculatlon for PIscborous Fish (St. .Johns Rl>er) PIschorous Elsh Modeled Tissue Maxiniuni .A>erage Concentration In TR\ Detected BCF Conser>atl>e .Alternathe Cone. In FCM PIscb orous Elsh (mg/kg wet weight tissue) COEC'" Cone. In (L/*ig) Log K,„ ' " HQ '' HQ ' ' Surface Units (trophic le\el 4)'^' (nig/kg wet weight) Surface Water'" Water Maximum .Average Conservative'^'" .Alternative'^' Maximum .Average Maximum .Average Pesticides 4.4'-DDD 0.0018 - ng L 43o0 O.02 lo.3.^ 0.13 ~ O.oO 2.1' 0.21 - 0.0.^^^ - ganuna-clilordiine 0.002' - ng L 2O.800 0.22 20.2o 1.4' ~ 1.38 3.18 1.1 - 0.4o - Metals .Alnmimun 1320 o'l ng L .^00 - 1 ooO 33o 8.0 20.0 83 42 33 1' Copper 4.38 2.3 ng L 200 - 1 0.8' 0.4o Iron l.MO '8o ng L 200 — 1 302.0 \y Mercinx' O.O^^'o 0.03' ng L 1000 - 10.4 1.02 0.38 0.2 0.38 .\1 \P •) - 1.0 Zinc ^\4.^ .^.8 ng L 1000 - 1 ^\4.^ 12 23.1 0.'^^ 0.48 0.41 0.2.^ Notes: (1) Prelinunar\ C'(DPEC's were those that were detected in siirtace water samples (Table 4-3 trom the BER.A (AEC'(DM. 2013)) and ha\'e a significant potential tor bioacciunnlation based on their BC'E exceeding 300 (see Table 4-8 of the BER-A (AEC'(1)M. 2013)). C'(l)EC's were selected in the BER-A based on ftirther e\'ahuition. (2) A\'erage concentrations are based on detected concentrations and the use of 1 2 the quantitation limit as a surrogate concentration for non-detects. Surrogate concentrations for nondetects were omitted tfom the data set if the\' exceeded the maximum detected concentration. A\'erage concentrations are not a\'ailable for chemicals with a single detection. (3) Log tfom Table 4-8 tfom the BER-A (.AEC'(DM. 2013). (4) EC'M = food chain multiplier for tropliic le\'el 4 tfom EPA (March Bt'-t?) based on log Row. (In the absence of a log Row. assumed an EC'M of 1.) EC'M for mercnr\- was obtained tfom .ATSDR (2001). (.'^) Modeled tissue concentration in pisci\'orons fish = (measured concentration in snrtace water) x BC'E x EC'M x 0.001 (unit con\'ersion factor: ng to mg) (0) Basis and sources forTR\'s are shown in Table 4-lo from the BER.A (.AEC'C)M. 2013). The TR\' for total DDX was used as a surrogate \'ahie for 4.4'-DDD. The TR\' for gamma-BHC (lindane) was used as a surrogate \'ahie for alpha-, beta-, and delta-BHC. The TR\' for total clilordane was used as a surrogate \'ahie for gamma-clilordiine. (oa) C'onser\'ati\'e TR\'s (toxicity'reference \'ahies) are based on NC).AELs (no-obser\'ed-ad\'erse-etrect le\'els) from Table 4-lo ofthe BER.A (.AEC'C)M. 2013). (ob) .Alteniati\'e TR\'s (toxicity- reference \'ahies) are based on LC).AELs (lowest-obser\'ed-ad\'erse-etrect le\'els) tfom Table 4-lo ofthe BER.A (.AEC'C)M. 2013). (") H(3 = (fish tissue concentration) C'onser\'ati\'e or .Altenuiti\'e TR\' Plioc } of I Tiible 8-1 Surface Soil Remedial Cle anup Le>els Cleanup Level Chemical of Concern Basis of Cleanup Level (milligrams per kilogram) 2.3C.8-TCDD (Total Eqiu\'alence) 0.00003 EDEP SCTL - Direct Exposure 4.4'-DDD EDEP SCTL - Direct Exposure 4.4'-DDE 15 EDEP SCTL - Direct Exposure 4.4'-DDT 15 EDEP SCTL - Direct Exposure .Aldrin 0.3 EDEP SCTL - Direct Exposure alpha-BHC O.o EDEP SCTL - Direct Exposure .Aroclor 1254 2.0 EDEP SCTL - Direct Exposure •Arsenic 12 EDEP SCTL - Direct Exposure beta-BHC 2.4 EDEP SCTL - Direct Exposure Cliromiiun 4'0 EDEP SCTL - Direct Exposure Dieldrin 0.3 EDEP SCTL - Direct Exposure gamnia-BHC (LindiUie) 2.5 EDEP SCTL - Direct Exposure Heptaclilor 1 EDEP SCTL - Direct Exposure Toxaphene 4.5 EDEP SCTL - Direct Exposure 5 pCi L abo\'e natural Ra-22o EP.A Guidance \'alne background U-238 820 EDEP SCTL for nraninin salts - Direct Exposure Notes: FDEP - Floridii Department oFEnNiroiunental Protection EPA - En\"iroiunental Protection Agenc\' pC'i L - picocnries per liter SCTL - Soil Cleanup Target Le\'el. Elorida Administrati\'e Code o2- Pnsie I of I Tiible 8-2 Subsurfiice Soil ReniedLiI Cle;inup Le>els Cleanup Level Chemical of Concern Basis of Cleanup Level (milligrams per kilogram) 2.3.".8-TC'DD (Total Equi\'aleiice) 0.00035 C'oiistniction Worker: Cancer risk = 1\ 0 ' or HQ = 1 4.4'-DDD 15o Coiistniction Worker: Cancer risk = 1\ 0 ' or HQ = 1 4.4'-DDE 110 Coiistniction Worker: Cancer risk = 1\ 0 ' or HQ = 1 4.4'-DDT 133 Coiistniction Worker: Cancer risk = 1\ 0 ' or HQ = 1 •Al drill Coiistniction Worker: Cancer risk = 1\ 0 ' or HQ = 1 alpha-BHC o.O Coiistniction Worker: Cancer risk = 1\ 0 ' or HQ = 1 .Arocior 1254 Coiistniction Worker: Cancer risk = 1\ 0 ' or HQ = 1 •Arsenic 4' Coiistniction Worker: Cancer risk = 1\ 0 ' or HQ = 1 beta-BHC 21 Coiistniction Worker: Cancer risk = 1\ 0 ' or HQ = 1 C'lironiiuni 00 Coiistniction Worker: Cancer risk = 1\ 0 ' or HQ = 1 Dieldriii 2.4 Coiistniction Worker: Cancer risk = 1\ 0 ' or HQ = 1 Eiidosultaii I 32 lo Coiistniction Worker: Cancer risk = 1\ 0 ' or HQ = 1 Eiidriii aldeln de lol Coiistniction Worker: Cancer risk = 1\ 0 ' or HQ = 1 ganuiia-BHC (Lindane) 40 Coiistniction Worker: Cancer risk = 1\ 0 ' or HQ = 1 Thalliiun ".1 Coiistniction Worker: Cancer risk = 1\ 0 ' or HQ = 1 Toxaphene 34 Coiistniction Worker: Cancer risk = 1\ 0 ' or HQ = 1 Notes: H(^ - Hiizard (Quotient Pnsie I of I Table 8-3 Groundwater Remedial Cleanup Le> els Cleanup Level Chemical of Concern Basis of Cleanup Level (micrograms per liter) 1-Meth\lniiphthiilene 28 EDEPGCTL 1.2.4-Trinieth\lbeiizene 10 EDEPGCTL 1.2-Dicliloropropane MCL 1.3.5-Trinieth\lbeiizene EDEPGCTL 1.4-Diclilorobeiizene MCL 2-Meth\lniiphthiilene 28 EDEPGCTL 2.4-Diclilorophenol 0.3 EDEPGCTL 4-C'liJoroamline 28 EDEPGCTL 4.4'-DDD 0.1 EDEPGCTL 4.4'-DDE 0.1 EDEP GCTL Acenaphthene 20 EDEP GCTL .AJdrin 0.002 EDEP GCTL alpha-BHC O.OOo EDEP GCTL .AJuniinuni 10802 Calculated: Cancer risk = 1x10" or H(^ = .Aiiuiioiiia 2800 EDEPGCTL •Aiitinioin' 0 MCL .Aroclor 1254 0.5 MCL •Arsenic 10 MCL Bariiuii 2000 MCL Benzene 1 MCL Ber\lliiun 4 MCL beta-BHC 0.02 EDEPGCTL C'adiniuni MCL C'liJordane. Total MCL C'liJorobenzene 100 MCL C'liJoroniethane - EDEP GCTL C'liroiniiun 100 MCL cis-1.2-DicliJoroethene '0 MCL Cobalt 140 EDEP GCTL Copper 1300 EP.A .Action Le\'el Dibenzofiiran 28 EDEP GCTL Dieldrin 0.002 EDEP GCTL Etlnlbenzene '00 MCL Endrin MCL Endrin aldeh\de MCL (for Endrin) Endrin ketone MCL (for Endrin) Eliiorene 280 EDEP GCTL gainnia-BHC (LindiUie) 0.2 MCL HeptacliJor 0.4 MCL HeptacliJor epoxide 0.2 MCL Hexaclilorobenzene 1.0 MCL Pasie I of 2 Tiible 8-3 Groundwater Remedial Cleanup Le> els Cleanup Level Chemical of Concern Basis of Cleanup Level (micrograms per liter) Iron 13'-'>25 Calculated: Cancer risk = 1x10" or H(^ = 1 Lead 15 EPA Action Le\'el Manganese 400 Calculated: Cancer risk = 1x10" or H(^ = 1 Naphthalene 14 EDEPGCTL Nickel 100 EDEPGCTL Nitrate 10000 MCL Pentaclilorophenol 1 MCL Selenium 50 MCL Sih'er Calculated: Cancer risk = 1x10" or H(^ = 1 Thallium -) MCL Tricliloroethene 3 MCL \'anadinm 4^^ EDEPGCTL \'in\l cliloride 1 MCL Zinc 508" Calculated: Cancer risk = 1x10" or H(^ = 1 Notes: FDEP - Floridii Department orEn\'ironmental Protection GCTL - Groiuidwater Cleanup Target Le\'el. Elorida Administrati\'e Code o2-' H(^ - Hazard (Quotient MCL - MiLxiinnin Contaminant Le\'el. Elorida Administrati\'e Code o2-550 Pasie 2 of 2 Tiible 8-4 Sediment Remedial Cleanup Le>els Cleanup Level Chemical of Concern Basis of Cleanup Level (milligrams per kilogram) 4.4'-DDD O.OO'Sl .-\lteniati\'e ES\' 4.4'-DDE 0.3'4 .-\lteniati\'e ES\' tor C(1)PEC in pore water onl\' 4.4'-DDT 0.004" .-\lteniati\'e ES\' .Aldrin O.OO^C^ .-\lteniati\'e ES\' alpha-BHC O.OOo Conser\'ati\'e ES\' alpha-Clilordane 0.004'^^ .-\lteniati\'e ES\' .Aroclor 1254 0.18^^ .-\lteniati\'e ES\' •Aroclor 12oO 0.18^^ .-\lteniati\'e ES\' Barium 48 .-\lteniati\'e ES\' beta-BHC 0.005 Conser\'ati\'e ES\' Cadmium 4.2 .-\lteniati\'e ES\' Clilordiiiie (total) 0.004'^^ .-\lteniati\'e ES\' Copper 108 .-\lteniati\'e ES\' delta-BHC 0.005 Conser\'ati\'e ES\' Dieldrin 0.0043 .-\lteniati\'e ES\' Endosnltan 1 0.002^^ Conser\'ati\'e ES\' gamma-BHC (LindiUie) 0.000^^^^ .-\lteniati\'e ES\' gamma-Clilordane 0.004'^^ .-\lteniati\'e ES\' Heptaclilor epoxide O.Olo .Alternati\'e ES\' Iron 24800 Sediment reference \'alne tor C(1)PEC in pore water onl\' Lead 112 .Alternati\'e ES\' Merciir\' 0." .Alternati\'e ES\' Zinc 2'1 .Alternati\'e ES\' Notes: C'(DPEC' - Contaminant of Potential Ecological Concern ES\' - Ecolosical Screenins X'aliie Pnsie I of I Table 8-5 Surface Water Remedial Cleanup Le> els Cleanup Level Chemical of Concern Basis of Cleanup Level (micrograms per liter) 4.4'-DDD 0.003 EDEP SWQC gamnia-cliJordiine (ClUordane. Total) 0.004 (iiiiLX) EDEP SWQC .AJnminnin 1.^00 EDEP SWQC Copper 3." EDEP SWQC Iron 300 EDEP SWQC Merciir\' 0.02.^ EDEP SWQC Notes: FDEP - Floriclii Department oFEnNiroiunental Protection S\\'(^C' - Snrtace Water (^iuilit\- Criteria. Eloricki .Administrati\'e Code o2-302..'^30. Pnsie I of I Table 8-6 Chemical-Specific ARARs ActioD/Media ReqiiiremeDt Prereqiiisile CitutioD Classil'icalinn nl'grnuiklwaler .Ail gruuiklwater of tlie state is classifie*.] accnaling to tlie ilesignate*.] uses atkl incluiles tlie Groutid w ater w itliin the state of Florida - F.A.C. 62-520.411) fnUuwing: .Applicable Class G-I - Putable w ater use. gruutklwater in sitigle snua-e aciuifers w liich has total ijissn]ve«.j soliilscnntent oflessthan }.()()() nig/l. Class G-II - Potahle water use. gruutklwater in single suuae aijuifers which has total ilissulve«.l suliils content ofless than ID.DDI) mg/1. unless otherwise classifie«.l hy the Florida Environtiiental Regulation Comtiiission. Reslnralinn nl'grnuiklwaler as a pnienli^iJ .All gruutklwater le.xcept for Class G-r\') shall tiieet the tiiitiitiuitii criteria for groundwater Groutid water witliin the state of Florida with F..A.C. 62-52t).4t)t) Minitiiutii Irinking water sniia-e specifie«.l in F..A.C. 62-52ti.4titii 1 )ia)-if). designate«.l beneficial useis) of Class G -I or Class Criteria for Groundw ater G-II - Relevant and .Appropriate Class I atkl Class D groundwater shall tiieet the pritiiary drinking water statidaals liste«.l in F.A.C. 62-520.42011) F..A.C. 62-55i)..Mti for puhlic water systetiis. e.xcept as otherwise specifie«.l. Statidaals for Class - I and Class - II Groundwater Shall not e.\cee«.l the tiiaxitiiutii contatiiinant level iMCL) liste«.l in TaWe 1 INtilRG.ANIC Supply of w ater to public water systetii. as F.A.C. 62-550.510 Pritiiary COMPOlfNDS atkl Tahle 4 VOLATILE ORG.ANIC CONT.AMIN.ANTS. define«.l in F..A.C. 62- Drinkitig Water Statidaals iTIiese statidaals may also apply as groundw ater ciuality statidaals as reference«.l in Chapter 55i).2t)t) 117) - Relevant and .Appropriate 62-521). F.A.C.) Reslnralinn nl'gruuiklwaler as a puienli^i] Specifies Groundw ater Cleanup Target Levels iCTLs) for site rehahilitation. F..A.C. 62- Rehabilitation li.e.. retiieiliatioii) of site F.A.C. 62-750.150i5) Irinking water sniia-e 777.171) Tahle I lists the default Groundwater Criteria. contatiiinated groutidwater - Relevant and F..A.C. 62- 777.170i 1 )ia) See Rt;)D TaWe 5-5 Gruutklwater Retiieiiial Cleanup Levels for list of the COCs and .Appropriate correspoikiitii; GCTL Prutectinn of surface water .-Ml surface waters of the State shall at all places and at aU titiies Iv free from: Presence of pollutant in Waters of the State of F.A.C. 62-502.5001l)ia)l-6 ui) Domestic, industrial, agricultural, or other tiian-itkluce«.l nun- themial components of Florida asdefine«.l in Section 4t)5.t)5h 15). F.S. - Minimum Criteria for Surface discharges, w liich. alone or in comhination w ith other suhstances or in comhination with Relevant atid .Appropriate Waters othercomponents of discharges iwhether themial or nun- themial): 1. Settle to fomi putrescent deposits or otherwise create a nuisance: or 2. Float as dehris. scutii. oil. or other tiiatter in such atiiounts as to fomi nuisances: or 5. Produce color, odor, taste. turt"'idity. or other coikiitions in such a degree as to create a nuisance: or 4. .Are acutely to.xic: or 5. .Are present in concentrations which are caa'inogenic. tiuitagenic. or teratogenic to hutiian heings or to significant. locaUy occurring, wildlife or aciuatic species, unless specific statidaals are established for such components in subsection 62-5t)2.5i)i)i2) or Rule 62-5t)2.5.^i). F..A.C.: or 6. Pose a serious danger to the public health, safety, or welfare. Shall not e.\cee«.l the surface water ciuality criteria for the pollutants listed in Table entitle«.l Presence of pollutant in Waters of the State of F.A.C. 62-502.550 Surface Waier Qiiatiiy SiaiulanL"!. Florida asdefine«.l in Section 4t)5.i)5h 15). F.S. - Surface Water ijuality Criteria. See Rt;)D Table 5-5 Surface Water Retiie«.lial Cleanup Levels for list of site-related Relevant atid .Appropriate Ci;)Cs and the respective water ijualitv criteria. Retiiuv^i] uf cuntatiiinateil siiiface soil fur Specifies Default Soil Cleanup Target Levels iCTLs) for site rehabilitation. F..A.C. 62-777 Rehabilitation li.e.. retiieiliatioii) of site F.A.C. 62-777. Table 0 Co 111 niea'i ai/I tkl u st riai u se Table D lists the cleanup levels for Comtuea'ial/Industrial Direct E.xposure. contatiiinated soil and seilitiient Soil Cleanup Target Levels See Rt;)D Table 5-1 Surface Soil Retue«.lial Cleanup Levels for list of the COCs and - Relevant atid .Appropriate corresnoikiitii; CTL F-i.-, 1 Table 8-6 Chemical-Specific ARARs ActioD/Media Requirement Prerequisite CitatioD Removal] ol'conlnniiiuileil siihsiirface soil Reijuires llinl n lifetime excess cancer risk level of 1 .i)E-6 aiiil a hazaal iialex of 1 or less Establishtiient of .-Mtemative cleanup target levels F.A.C. 62-750.651), Dal) for Commea'i^il/Iniluslri^il use simll Fe used in eslaWishing ^illemalive contaminant cleanup target levels for groutidwater iCTLs) forcontatiiinants of concern at the Site or soil. - Relevant atid .Appropriate See RtitD Table 5-2 Subsurface Soil Retue«.li^il Cleanup Levels for list of tlie CtitCs and corresfoikiini; ^iltemative site-specific CTL Nitles .-\R.-\R = nppljcnl"'le "/• relevnni niul nppruprinle re>.|uiremenl CFR = Cuile nl'Fe«.lera] RegiiJniinns COCi = cnnlniiiiiuinls nl'cuncem CTL = cleanup inrgel level F.A.C. = Fluriih) Ailmiiiislralive Cuile. Chnplers ns specil'ieil F.S. = Fluriih) Sinlules Ri;)D = Recnal of Decision TBC = To Be Cnnsiilere«.l siuiilnnce F.;.-, : Table 8-7 Locallon-Speciric .AR.ARs and TBC Location Requirement Prerequisite Citation Presetice of Floodphdns designated as such Shall take acdon to reduce the risk of flood loss, to minmiize the unpact of floods on Fedend acdons that involve potentiid impacts to. E.vecutive Order 11088 on a map' human Sidety. he Shall consider idtemadves to avoid, to the e.vtent possible, adverse effects and E.vecutive Order 11088 iticompadble development in the floodphdn. Design or modify its acdon in order to Secdon 2.(a)(2) FInndplain mitiimize potentiid harm to or witliin the floodphdn Mana'^emeni Wliere possible, an agency shall use nattind systems, ecosystem processes, and nature- E.vecutive Order lobOO based approaches when developing idlernalives forconsideradon. Secdon 2 (c) Presetice of floodphdn designated as such The .•\gency shall design or motlify its actions so as lo mindidze" hann lo or witliin the Fedend acdons idfecdng or idfected by 44 CFR §0.11(lM(l) on a map floodphdn. Floodphdn as defined in 44 CFR § 0.4 - Relevant Miii'^aiinti and .'Appropriate The .•\geticy shall restore and presene naltind and Ivneficiid floodphdn Vidties. 44 CFR §0.11(lM(5) Miii'^aiinti The .•\geticy shall minimize: 44 CFR §0.11(0(1) • Poienliid harm lo lives and the investment at risk from base flood, or in the case of and(5) criticid acdons" from the 500-year flood; Minimizaiinn pmvisinns • Potentiid adverse impacts that acdon may have on floodphdn Vidties. ' Under 44 CFR § y.7 Deienninaiinn "f prnpnsed aciion's Incai'mn . PiiTa^aph (c) Rood plain deiernii nation. One should consult the FEM.'\ Rood Insurance Rate Map (FIRM), the Rood Botindan Roodwav Map (FBFM) and the Flood Instiratice Study (FIS) to deterniine il" the .•\geticy proposed action is witliin the hase floodphdn. " Mitunuze means to reduce to smallest iunount or de^ee possible. See 44 C.F.R. § d.4 Definiiinns . ' See 44 C.F.R. § d.4 Definiiinns. Critical aciimi. Criticid acdons iticltide. but are not Idiuted to. those wluch create or e.\tend the useful life of structures or facilities such as those that produce, use or store liighly volatOe. tliuiimable. e.\plosive. to.Kic or water-reacdve materiids. f'oec I ofli Table 8-7 Locallon-Speciric AR.ARs and TBC Location Requirement Prerequisite Citation Presence of W'etlaiuls ShidJ lake action to niinmuze the tlesiruclion. loss or tle^atlalion of wetlaiuis aiui to Federal actions that involve potentiid unpads to. E.vectilive Order 1 IddO presene aiul enhance heneficiaJ values of wetlaiuis. or take place w ithin, wetlands - To Be Section l.(a) Pmieciinn "f Considered Winliiriils Shall avoid undertaking construction located in wetlands unless: (1) there is no E.vecutive Order 1 IddO. practicaWe altenuitive to such construction, and (2) that the proposed action includes all Section 2.(a) Pmieciinn nf practicaWe measures to minimize harm to wetlands w hich may result from such use. Weikmds Presence of Wetlands (as defined in The .•\gency shall minimize"' the destruction, loss or degradation of w etlands. Fetleral aciintis affeciitv^ nr affecied by Weihinds 44C.F.R. 11(h)(2) 44C.F.R. Sd.4) The .•\gency shall presene and enhance the natural and heneficial wetlands Vidties as defined in 44 C.F.R. § d.4 - Relevant and and (h)(4) Mitigation .•appropriate The .•\gency shall minimize: 44 C.F.R. 11(c)(0) Potentiid adverse impact the action may have on wetland Vidties. Minimiziiii"" prnvisinns .•iteration of w etlands Must comply with the foUowingcotulilions to he covered under the Genend Pennit: Sod removid activities . including instadation of F.A.C. h2--C-i0.ho5 (a)- (a) Removid of contiuninated sod is luuited to no more than a totid of 5 acres of wells and work in wetlands and other surface (d) wetlands. W aters necessary to perfonn sod remediation - General Pennii fnr Snil (h) Temporary fill and materiids for equipment access shall he removed munediately Relevant and .•appropriate Remediaiinti foUowing completion of the remetliation work. (c) .•\ny wetland area idfected hy the work shall he restored to pre-construction wedand elevations witliin oO days foUowing completion of the work, using setlimenls consisting of the siune sod te.vttind materiid as the origitud pre-construction sod materiid that is idso free of vegetated dehris. rehar and any other sodd waste materiids. (d) .•\ny muck removed from wetlands forconstruction of temporary fill roads shad he stockpded in uplands and used in restoring the idfected area to wetland cotulitions and preconstruction wetland elevations, unless tliis materiid is required to he removed as part of the remediation plan. XOTE: Ahknif^h penniis are rmi required per CERCL\ Seciimi I2I{ei{ I i. cnsuliaiinn wiih ihe FDEP recninmended in deiennine wheiher any adverse impacis rmi cvered by ihe pennii ihai may require miii'^aiinn. Such miii'^aiinn wnuid be perfnrmed as pan nf ' Minimize means to reduce to snndlest imiount or degree possible. 44 C.F.R. § d.4 Definitions. " Tliis includes construction, idteration. operation, and removid of a temporary access road for access to conduct tliis work. Pane 2 of Si Table 8-7 Locallon-Speciric AR.ARs and TBC Location Requirement Prerequisite Citation .•Mlemtion of wellaiuls (e) W'illiin 7 days of completion of construction. alJ wetland areas shall he restored to pre Sod removid activities . including installation of F.-'^.C. h2-oo0.ho5 (e) construction wetland elevations and re-vegetated with native wetland species endemic to weUs and work in wetlands and other surface adjoining, undistiirhed wetlands or the underlying wetland conuniinity type historically W aters necessary lo perfonn sod remediation - occurring at the site. Relevant and .•appropriate The restored wetland areas shall he niidntidned and planted as necessary to ensure that at least 00 percent cover of planted or naturally reestahlished nadve wetland plant species is appropriate for the wetland conuniinity type within 18 months of compledon of authorized work. E.\odc invasive species, incliitling hut not limited to: Schinus lerebinihif'iliiis. Melaleuca quinquenen'ia. Casuarina spp.. Ly4"diuin spp.. and nuisance species Typha spp.. and LudwP^ia peruviana shall he controUed at densides not e.vceetling the densities of these species in uiulisturhed portions of the wetland. XOTE: Alth"U'^h penults are wt required per CERCLA Secii'm I2I{ei{ I i. cmsuhaii'm with the EDEP reciiniiiended t" detennine whether any adverse impacts ma cvered by the permit that may lequire mitiyiti'm. Such mitiyiti'm wnuid be performed as pan "f the lemediai action. Location encompassing aquatic ecosystem E.vcept as provided under [C\\'.'\] section 404(h)(2). no discharge of tiredged or fid .•\ction that involves the discharge of tlredged or Clean Water .'^ct Regulations as defined in 40 materiid shad he pemdtted if there is a practicable idternative to the proposed discharge fid materiid into waters of the United States, Secdon 404(h) Giiidednes C.F.R. 2S0.MC) w liich would have less adverse dnpact on the aquatic ecosystem, or d" it wid cause or including jurisdictionid wedands - .•\ppdcahle 40 Part 2oO. 10(a) and (C) con tribute to si^ndicant deoudadon of the waters of the United States. No discharge of tlredged or fid materiid shad he permitted d" it: 40 C.F.R. Part (1) Causes or contributes, after consideradon of tlisposid site tldiition and dispersion, to 2oO. 10(b) violadons of any appdcahle State water qiiadty standard; (2) Violates any appdcahle to.vic effluent standard or prohibition under section SOI of the CW.^; (o) leopardizes the continued e.vistence of species dsted as endangered or tlu'eatened under the Endangered Species .•^ct of 107o. as amended, or results in dkedhood of the destruction or adverse moddication of a habitat w luch is determined by the Secretary of Interior or Conunerce. as appropriate, to he a criticid habitat under the Endangered Species .•^ct of ld7o. as amended, d" an e.vemption has been granted by the Endangered Species Committee, the tenns of such e.vemption shad apply in deii of this subparagraph; (4) Violates any requirement dnposed by the Secretary of Conunerce to protect any marine sanctuary designated under title 111 of the Marine Protection. Research, and Sanctuaries .•^ct of ld72. Pii9eS of Si Table 8-7 Location-Specific ARARs and TBC Location Requirement Prerequisite Citation Except as provided under [CWA] section 404(b)(2), no discharge of dredged or fill Qean Water Act Regulations - material shall be permitted unless appropriate and practicable steps [in accordance with Section 404(b) Guidelines 40 C.F.R. 230.70 et seq. 40 C.F.R. 230.10(d) Actions To Minimize Adverse Effects] have been taken which will minimize potential adverse impacts of the discharge on the aquatic ecosystem. Location encompassing aquatic ecosystem Must comply with the substantive requirements of the NWP 38 General Conditions, as On-site CERCLA action conducted by Federal Nation Wide Permit as defined in 40 C.F.R. 230.3(c) appropriate, any regional or case-specific conditions recommended by the Corps District agency that involves the discharge of dredged or ("381 CleanuD of Engineer, after consultation. fiU material into waters of the United States, Hazardous and Toxic Waste including jurisdictional wetlands - Relevant and [33 C.F.R. 323.3(b) NOTE: Although permits are not required per CERCLA Section 12](e)(]), consultation Appropriate requires EPA to obtain with the USAGE recommended to determine whether any adverse impacts not covered authorization under general by the permit that may require mitigation. Such mitigation would be performed as part permit] of the remedial action. Alteration of upland stormwater system Construction, alteration, and operation shall not: Construction and maintenance of swales in F.A.C. 62-330.051 Exempt 1. Adversely impound or obstruct existing water flow, cause adverse impacts to existing accordance with Section 403.813(l)(j), F.S. - Activities, Section (7) surface water storage and conveyance capabilities, or otherwise cause adverse water Relevant and Appropriate Maintenance and Restoration, quantity or flooding impacts to receiving water and adjacent lands; Paragraph (e) 2. Cause an adverse impact to the minimum flows and levels established pursuant to Section 373.042, F.S. 3. Cause adverse impacts to a Work of the District established pursuant to Section 373.086, F.S.; 4. Adversely impede navigation or create a navigational hazard; 5. Cause or contribute to a violation of state water quality standards. Turbidity, sedimentation, and erosion shall be controlled during and after construction to prevent violations of state water quality standards, including any antidegradation provisions of paragraphs 62-4.242(l)(a) and (b), subsections 62-4.242(2) and (3) and Rule 62- 302.300, F. A.C., and any special standards for Outstanding Rorida Waters and Outstanding National Resource Waters due to construction-related activities. Erosion and sediment control best management practices shall be installed and Construction and maintenance of swales in State of Florida Erosion and maintained in accordance with the guidelines and specifications described in the State of accordance with Section 403.813(l)(j), F.S. and Sediment Control Designer Florida Erosion and Sediment Control Designer and Reviewer Manual (Rorida F.A.C. 62- and Reviewer Manual Department of Environmental Protection and Rorida Department of Transportation, 330.051 - To Be Considered June 2007), incorporated by reference herein (•httDs://www.flrules.or?/Gatewav/reference.asD?No=Ref-02530). and the Florida Florida Stormwater Erosion Stormwater Erosion and Sedimentation Control Inspector's Manual (Rorida and Sedimentation Control Department of Environmental Protection, Nonpoint Source Management Section, Inspector's Manual Tallahassee, Rorida, July 2008), incorporated by reference herein (•httDs://www.flrules.or?/Gatewav/reference.asD?No=Ref-02531'). Page 4 of 8 Table 8-7 Locallon-Speciric AR.ARs and TBC Location Requirement Prerequisite Citation .•Mlemtion of surface waters of the Stale of Musi provide reasonaWe assurance that the construction, idteration. operation, Construction, alteration, operation, maintenance, F.-'A.C. h2--C-i0.o01 (1) Florida niidntenance. reinovid. or ahandonnient of the projects regulated under tliis chapter: repair. removiU. and al^andotunenl of a project in Conditions for Issuance of (a) W'iU not Cause adverse water quantitv unpads to receiving waters and adjacent lands; surface Waters of the State of Rorida - Relevant Individual and Conceptual (In Will not Cause adverse flootling to on-site or off-site property; and .'Appropriate Approval Permits. (c) WiU not Cause adverse unpads to e.Kisting surface water storage and conveyance capahilities; (d) Will not adversely unpad the Vidtie of functions provided to fish and wdtUife and listed species hy wetlands and other surface waters; (e) Will not adversely idfect the quality of receiving waters such that the state water quality statul;u-ds set forth in Chapters b2-4. b2- o02. b2-520. and b2-550. F..'\.C.. including the antidegradation provisions of pimigraphs b2-4.242( l)(a) and (in. F.-'^.C.. stihsedions b2-4.242(2) and (o). F-'^.C.. and Rule b2-o02.o00. F-'^.C.. and any speciid statuliu'ds for Outstatuling Rorida Waters and Outstanding National Resource Waters set forth in suhsections b2-4.242(2) and (o). F-'^.C.. wiU he violated; (f) WiU not Cause adverse secondiuv unpads to the water resources. (g) WiU not adversely impact the maintenance of surface or groundwater levels or surface Water flows estahUshed pursuant to Section o7o.042. F.S. (h) WUl not Cause adverse unpads to a Work of the Disuict estal^Ushed pursuant to Section o7o.08h. F.S. XOTE: penniesi are required under CERCL\ I2I{eHl i: hnwerer. must empty with the substantive tequirements. criteria nr limitati'ms otherwise tequired in a peniiit. Paec > otAi Table 8-7 Locallon-Speciric AR.ARs and TBC Location Requirement Prerequisite Citation .•Mlemtion of surface waters of the Stale of In adtiition lo the cotuiilions in Rule b2-oo0.o01. F.A.C.. lo olMidn an itulividtiid or Constnicdon. idteradon. operadon. niidntenance. F..A.C. b2--V-i0.o02(l) Florida concepltiid approvid perniil under lids chapter, an applicant inust provide reasonable repair, removid. and abandotunenl of a project in Additional Conditions for assurance that the construction, idteration. operadon. niidntenance. repair, reinovid. and surface Waters of the State of norida - Relevant fssuance of Individual and abandonnient of a project: and .'Appropriate Conceptual Approval Permits. (a) Located in. on. or over wetlands or other surface waters wiU not be contrarv to the public interest, or if such activides sigtdficandy decade or are within an Outstanding Florida Water, are cle XOTE: penniesi are required under CERCL\ I2I{eHl i: hnwerer. must empty with the substantive tequirements. criteria nr limitati'ms otherwise tequired in a peniiit. .•Alteradon of surface w aters of the State of Barges or other work vessels used to conduct in-water acdvides shall be operated in a Constnicdon. idteradon. operadon. niidntenance. F..A.C.b2--V-i0.405(L-i) Florida manner that prevents unauthorized tlredging, water quality violations, and diunage to repair, removid. and abandotunenl of a project in General Conditions for .Ml submerged aqtiadc conuntmides. surface Waters of the State of Rorida - Relevant General Permits and .'Appropriate The construction, idteration. or use of the authorized project shall not adversely impede F..A.C.b2--V-i0.405(14) tiaviiadon orcreate a naviiatiotud hazard in the water bodv. E.vcept w here specifically authorized in a genend permit, activities must not: F..A.C.b2--V-i0.405(15) (a) Impound or obstruct e.Kisdng water flow , cause adverse impacts to e.Kisdng surface Water storage and conveyance capabilities, or otherwise cause adverse water qtmndty or flooding impacts to receiving w ater and iidjacent lands; XOTE: Xo permitlsi are required under CERCL\ I2I{eHl i: however, must comply with the sub.':tantive tequirements. criteria or limitations otherwise tequired in a peniiit. Paecf) otAi Table 8-7 Locallon-Speciric AR.ARs and TBC Location Requirement Prerequisite Citation Thremened and Endatfjered Species Presence of Threalened aiul Eiulangered Federal agency shall, in consultation with and with the assistance of the Secretary, .•\geticy action that niay jeopardize listed wOtUife lb U.S.C. §15ob(a)(2) Wikilife listed in 50CFR 17.11(h) - or insure that any action authorized, funded, orcarried out hy such ageticy is not likely to species, or destroy or adversely inotlify critical - or Section 7(a)(2) of the crilicid haWlal of such species jeopardize the continued e.Kistence of any etulatigered species or tlireatened species or habitat - .'Applicable Endatf^ered Species Act "f result in the destruction or adverse inotlification of haWtat of such species w liich is i97S deterniined hy the Secretary of Interior, after consultation as appropriate with affected States, to he critical, unless such ageticy has heen granted an e.\eniption for such action hy the Conmiittee pursuant to subsection (h) of this section. SOTE: Despite that cinsultati'm iiuiy he cnsidered an adininistfatiye tequirenient. it sh"uld he peif'Tined t" ensuie activities ate in cmpliance with suhstantive pf"visi"ns "f the Endatf^eted Species Act and re^pilati'ms. Presence of Threatened and Etulatigered It is titilawful to take tlireatened or etulatigered wOtUife in the Utiited States. .•Action that may jeopartlize listed wOdlife species 50CFR Part 17.21(c) Wikllife listed in 50CFR 17.11(h) - .Applicable 50CFR Part 17.-M(a) XOTE: Under >0 CER 10.12 Definiti'ms. the term "take" means t" pursue, hunt. sh""t. 50CFR Part 17.42(a)(2) wound, kill. tiap. captute. or collect, or attempt to pursue, hunt, shoot, wound, kill, tiap. captute. or collect. Presence of protected Marine MiUiimals It is titilawful to take any marine numimal in waters or on lands under the jurisdiction of .Action that may jeopartlize protected marine Marine Mammal Protection the Utiited States. niiUiimids (e.g.. manatee.) - .Applicable .\ct. lb U.S.C. §lo72 Section 102 (a)(2)(.A) Shall comply with the foUowing: .Action perfomied in waters accessible to F..A.C.b2-550.405(18) a. .'All vessels asstviated with the project shall operate at "Idle Speed/No Wake" at all federally- or state- listed aquatic species, such as General Conditions for .Ml times w liile in the work area and w here the tlraft of the vessels provides less than a four- manatees, marine ttirdes. snialltooth sawfish, and General Permits foot clearatice from the bottom. .•All vessels will foUow routes of deep water whenever Gulf sturgeon. - .Applicable possible. b. .All deployed siltation or turbitlity barriers shall be properly secured, motiitored. and niidntidtied to prevent entatiglement or entrapment of listed species. c. .All in-water activities, iticltuling vessel operation, must be shutdown if a listed species conies witliin 50 feet of the work area. .Activities shall not resume tmdl the atiiniid(s) has moved beyond a 50-foot radius of the in-water work, or until 50 minutes elapses sitice the last sightitig witliin 50 feet. .Atiiniids must not be herded away or harassed into leaving. .All on-site project personnel are responsible for obsenitig water-related activities for the presence of listed species. Paec 7 of Si Table 8-7 Locallon-Speciric AR.ARs and TBC Location Requirement Prerequisite Citation Presetice of Mi^atorv Birds listed in 50 No person may take, possess, import. e.\port. transport. seU. ptirchase. Farter, or offer for .•\ction that have potentiid impacts on. or is likely Migratory Bird Treaty .•\ct. IF CFR 10.15 Side, ptirchase. or Farier. any minatory Fird. or the parts, nesls. or e^s of such Fird to result in a "take" (as defined in 50 CFR 10.12) U.S.C. §705(a) e.\cepl as may Fe permitted under the lenns of a valid pennil issued pursuant lo the of migratory Firds - .•\pplicaFle 50 CFR 21.11 provisions of this part and pari 15 of tliis chapter, or as permitted Fy regulations in tliis General Penult Requireinents part, or part 20 of tliis sulvhapter (the hunting regulations). .•\R.\R = ApplicalMe "/• Relevanl aiul Appropriate Rec|uirenienl C.F.R = Code "f Federal Re'^ulati"ns CWA = Clean Water Act F.A.C. = Florida Adiiiinistrative C"de. Chapters as specilied F.S. = noritia Stattites TBC = To Be Consitleretl USACE = Utiited States .Anin Corps of En^neers TiJpc.V of''i Table 8-8 Acllon-Speclflc AR.AR^s Action/Media Requirement Prerequiste Citation Gene ml C'msinicii'm Suindards — Ail Lnnd-dismrhin'e Aahiiies (i.e.. excmaii'm. clennu'e. •emdiu'e. etc. i C ontrol of slomnvaler runoff from soU Must comply \sitli the siihstantive provisions in the "Generic Pemht Stomnvater tlischiuges from huge and small F..A.C. d2-d21..W)(4 )(a) tlisliirlMng activities for Stomnvater Discharge from Laige and Small Construction constnicdon acdvides to surface waters of the State Generic Pennh Jbr Si'miiwaier Activities."" document numherh2-h21..^00(4)(a). issued hy the FDEP as defined in Section dO.vO.M. F.S. - .Appdcahle Discharge frnm Lanee and .Small and effective Fehniary 17. 2009. Requires development storm water C'lnsinicri'in Aciixiiies poUiition prevention plan and ijnplementation of hest management practices and erosion and setlimentation controls for stomnvater runoff to ensure protection of the surface waters of the state. SOTE Plan wuld be pan "fCERCLA dncumem such as Remedial Desben "/• Remedial Acri'm W'/ik Plan. C ontrol of stomnvater runoff from soU No dischaige from a stomnvater dischaige facility shall cause or Constnicdon acdvity (e.g.. idteration of land contours F..A.C. d2-25.025 tlistiirlMUg activities contrihiite to a violation of water quality standards in waters of the or land cleiuing) that results in creadon "/ Rmeulari"!! "f Sinrmwaier state. si'irmwaier mana'eemem s\'s!em as defined in F..AC. Discharge d2-25.020( 15) - .Appdcahle Erosion and sedunent control hest management practices shall he used F..A.C. d2-25.025 (7) as necessary during construction activity to retidn sedunent on site. These practices shall he designed hy an engineer or other competent professionid e.xperienced in the fields of sod conseiv adon or setliment control accortling to specific site coiulitions and shall he shown or noted on the plans of the stomnvater management syistem. SOTE Plan wmild be pan "fCERCLA dncumem such as Remedial Desben "/• Remedial Acri'm W"ik Plan. C ontrol of Fugitive Dust No person shall cause, let. permit, suffer or allow the emissions of Land distiirhing activity that has potendid for F..A.C. d2-2yd..^20(4)(C) unconfined piuliciilate matter from any acdvity . inclutling vehiciiliU" unconfined emissions of piuliciilate matter - Genend PoUiitant Emission Lmddng movement; transportadon of materiids; construction, idteration. .Appdcahle StandiU'ds demolition or wrecking; or industrially related activides such as loatling. unloatling. storing or handdng; without taking reasonable precautions to prevent such emissions. Gnnindwiiier M'mii'nin'e and Eximcri"!! Wells - Insuilluii'm. Openni'm. and Abandnnmem GroiiiuKvaterMonitoring WeU Installation Provides detidled guidance to assist in monitoring weU design and Installadon of groundwater monitoring weU to detect FDEP. Monitoring WeU Design and materiid specificadons for construe don of groundwater monitoring migradon of contiuninants - To Be Considered Constnicdon Guidance Maiuiid weU. (2COS) Construe tion and repair of groundwater Constnicdon of water weU shall he in accordance with the siihstandve Installadon of water weU as defined in F..A.C. d2-5.^2.500( 1) weU requirements specified in F..A.C. d2-5.^2.200 - Relevant and .Appropriate WeU Casing. Liner Pipe. CoiipUng F..A.C. h2-5.^2.500( 1 )(a) through(i) as appropriate. and WeU Screen Requirements WeUs shall he constructed to meet the foUoxsing constnicdon criteria F..A.C. d2-5.^2.500(.^) specified in F..A.C. d2- 5.^2.500(.^)(a). (h). (ei. (f). (g). (h) and (i) as WeU Constnicdon Criteria annronriale. filQC I of 11 Table 8-8 Acllon-Speclflc AR.AR^s Action/Media Requirement Prerequiste Citation WeU Covers aiKl L'pper Terniiniis WeUs shall he covered with a tiunper resistant cover when there is an F..A.C. b2-5.^2.500(4) interruption in work and meet the criteria specified in F..A.C. h2- Top of the WeU 5.^2.500(4)(a) and (b) as appropriate. Plugging aiul abaiKloiunenl of groiiiuKvaler .AH abandoned weUs shall be plugged by filling them from bottom to .Abandonment of water wed as defined in F..A.C. b2-5.^2.500(5) vveUs top with neat cement grout or bentonite and capped \sith a minimum of F..A.C. b2-5.^2.200 - Relevant and .Appropriate one foot of neat cement grout. .An idtemate method provitling ec|uiv;dent protection shall be approved by the Department and EP.A. In the abandonment of a water weU. caution shall be taken to minmiize F..A.C. b2-5.^2.500(.^)(f) the potentiid entrance of contimiinants into the bore hole and groundwater resource. Only Water from a potable water source shall be used in the F..A.C. b2-5.^2.500(.^)(g) abandoiunent of a water weU. GroiiiuKvaler Moniloring for Monilored .A minimum of two monitoring weUs is required: Groundwater monitoring as part of the remedy relying F..A.C. b2-7SO.byO(S)(a) NaliiraJ Alleniiation (MNA) remedy • .At least one weU shall be located at the downgratlient edge of the on iiatiind attenuation - Relevant and .Appropriate Natiind .Attenuation with plume; and Monitori ng • .At least one weU shall be located in the area(s) of highest groundwater contimiination or tlirectly adjacent to it if the area of liighest groundwater contimiination is inaccessible (for e.\imiple. under a structure). The designated monitoring weUs shall be siunpled for aindyises of Groundwater monitoring as part of the remedy relying F..A.C. b2-7SO.byO(S)(b) applicable contimiinants no more frec|uent than quarterly.' on iiatiind attenuation - Relevant and .Appropriate Water-level measurements in all designated weUs and piezometers Groundwater monitoring as part of the remedy relying F..A.C. b2-7SO.byO(S)(C) shall be made within 24 hours of initiating each simipling event.' on Iiatiind attenuation - Relevant and .Appropriate Opemri'iii nf Gr'nuuiwiner Treaiiiieiii System leoe.. Pump ami Treuii Operation and Moniloring of groundwater .A sepimite air pemiit will not be required if the totid idr emissions from Operation of an active renietliation system that emits F..A.C. b2-7S0.700(.^)(f)(.v) treatment system (e.g.. Pump and Treat) all on-site renietliation equipment systeni(s) do not e.xceed 5.51bs/day contimiinants into the idr - Relevant and .Appropriate for any single FLAP or Lv7 lbs/day for totid FLAPs. .S'oie : .Although penult not required under CERCL.A 121(e)( 1) for on- site response actions, the specified thresholds are relevant to •.•nnli,-..tinn nf ntfi.^r-..ir r.^niii filQC - of 11 Table 8-8 Action-Specific AR-AR^ Action/Media Requirement Prerequiste Citation Operation aiul Monitoring of groiiiuKvater L'nless othenvise provided in CERCLA Remedial/Removid Action Operation of an active remetiiation system - Relevant F..A.C. h2-7S0.700(l l)(a) treatment system iikiiitling groiiiuKvater Work Plan, the foUowing shall Iv olMidned or determined during the and .Appropriate throiiiih (e) monitoring weUs active remetiiation: • Water level data coUected from all designated weds, piezometers, and staff gauge locations each time monitoring and recovery weUs are Siunpled (Water-level measurements shall he made \sitlun 24- hour period) • Totid volume of any free product recovered and the thickness and horizontid extent of free product • Totid volume of groundwater recovered from each recovery weU • Concentrations of applicahle contimiinants hased on aindyises performed on the effluent from the groii ndwater treatment syistem • Concentrations of applicahle contimiinants hased on aindyises performed on the untreated groundwater from select recovery weUs Operation and Monitoring of groundwater L'nless othenvise provided in a CERCL.A Remetliid .Action Work Plan, Operation of an active remetiiation system iitiUzing F..A.C.h2-7S0.700(ll)(i)(l.) treatment system (e.g.. Pump and Treat) the foUowing shall he ohtidned or determined during the active activated caitxin off-gas treatment - Relevant and and (2.) remetiiation: .Appropriate • Concentrations of recovered vapors from a vacuum extraction system and post- treatment emissions .Adtlitiomd simipling may he perfonned hased upon the estimated time of hreaktliroiigh as foUows: 1. Concentrations of recovered vapors from iiulividiiid weds shall he detemiined using an oiganic vapor aiudyzer with a fliune ionization detector, or other applicahle field detection device in order to optimize airflow rate and contimiinant recovery ; 2. The influent and effluent siunples shall he coUected using appropriate air simipUng protocols and shaU he analy7ed using an analvtical method. Corrective action for leaks during operation If effluent concentrations or air concentrations e.xceed specified or Operation of an active remetiiation system - Relevant F..A.C. (12-780.700(1.^) of groundwater treatment system (e.g.. prescribed levels or plume migration occurs during remediation system and .Appropriate Pump and Treat) start-up of during operation of the treatment systems, then corrective actions shaU he taken. filQC ^ of 11 Table 8-8 Action-Specific AR-AR^ Action/Media Requirement Prerequiste Citation Posl-Active Remediation Monitoring for L'nless othenvise provided in CERCLA Remediid Action Work Plan, Operation of an active remetliation system - Relevant F..A.C. h2-7S0.750(4 )(a) groundwater treatment svstem the foUowing shall he perfonned as foUows: and .Appropriate throiiiih (c) • A minhnum of two monitoring weUs is required with at least one located at the downgradient edge of the plume; and at least one located in the area(s) of liighest groundwater contiunination or tllrectly adjacent; • Designated monitoring weUs shall he Siunpled quarterly for contiuninants that were present; • Water-level measurements in all designated weUs and piezometers shall he made within 24-hour of initiating each Siunpling event. Genend standards for process vents used in Select and meet the rec|uirements under one of the options specified Process vents as defined in 40 CFR h.\7y57 used in 40 CFR h.v7SS5(b) treatment of VOC contiuninated helow: site remetliation of metlia (e.g.. soU and groundwater) F..A.C.h2- 204.S00(ll)(b)(5y) groii ndwater • Control FLAP emissions from the affected process vents according to that could emit hazardous air poUiitants (FLAP) listed the applicable standards specified in h.v7SyO tliroiigh h.\7Sy.\ in Table 1 of Subpart GCiGGG of Part and vent • Detemrine for the remetliation material treated or managed hy the streiun flow e.xceeds the rate in 40 CFR process vented through the affected process vents that the average total ;ih.\7SS5(c)(l) - Relevant and .Appropriate volatile oigaiiic hazardous air poUiitant (VOH.AP) concentration, as defined in h.\7y57. of tliis material is less than 10 (ppmw). Determination of VOH.AP concentration \riU he made using procedures specified in h.\7y4.\ Control H.AP emissions from affected process vents suhject to another subpart underdo CFR pari hi or40 CFR pari in compliance with the standards specified in the applicable subpart. Emission limitations for process vents used Meet the requirements under one of the options specified below: Process vents as defined in 40 CFR h.C7y57 used in 40 CFR h.C7SyO(b)( 1 )-(4) n treatment of VOC contiuninated • Reduce from all affected process vents the totid emissions of the site remetliation of metlia (e.g.. soU and groundwater) F..A.C.h2- 204.S00(ll)(b)(5y) groii ndwater FLAP to a level less than 1.4 kilognuns per hour (kg/lir) and 2.S Mg/yr that could emit hazardous air poUiitants (FLAP) listed (.\0 pounds per hour (Ib/hr) and .vl tpyt; in Table 1 of Subpart GCiGGG of Part h.^ and vent • Reduce from all affected process vents the emissions of total streiun flow e.xceeds the rate in 40 CFR oigaiiic compounds (TOC) (minus methane and ethane) to a level h.C7SS5(c)( 1) - Relevant and .Appropriate below 1.4 kg/hr and 2.S Mg/yr (.CO Ib/lir and .CI tpy); • Reduce from all affected process vents the total emissions of the FLAP by y5 percent by weight or more; or • Reduce from all affected process vents the emissions of TOC (minus methane and ethane) by y5 percent by weight or more. filQC 4 of 11 Table 8-8 Action-Specific AR-AR^ Action/Media Requirement Prerequiste Citation Slaiuliirtls forclosed veni systems aiul For each closed vent system and control device you use to comply with Closed vent system and control devices as defined in 40CFR b.v7SyO(C) :ontrol devices used in treatment of VOC the requirements above, you must meet the operatitig lijiiit 40 CFR h.v7y57 that are used to comply with F..A.C.b2- 204.S00(ll)(b)(5y) contimiinated oroundwater requirements and work practice standards in Sec. h.v7y25(d) tlirotigh h.v7SyO(b) - Relevant and .Appropriate (j) that apply to the closed vent system and control device. SOTE EPA iipprnviii in use uhenuue work pnicrices under punik'niph (_/J in 40 CFR -i 6s. 7925 will be "biained in a CERCLA ,lnrinii,-iir Monitoritig of closed vent systems and Must motiitor and inspect the closed vent syistem and control device Closed vent system and control devices as defined in 40 CFR b.v7Sy2 control devices used in treatment of VOC accoalitig to the requirements in 40 CFR b.v7y27 that apply to the 40 CFR b.v7y57 that are used to comply with F..A.C.b2- 204.S00(ll)(b)(5y) contimiinated groundwater affected source. b.v7SyO(b) - SOTE Mniiiinriire prn^-nini will be develnped as pan "f the Relevant and .Appropriate CERCLA pmcess and included in an appmpriaie CERCLA dncumem. Wasiewaier Treamieni and Dispnsal — Cnniaminaied Gmundwaier Dischaige of treated groundwater to a .An indtistriid user shall not introduce into a Wastewater F..A.C.ility Discharge poUutants into a "Wastewater Facility"" as F..A.C.92-925.400(l)(a) Wastewater Facilitv (WWF) any poUutant wliich causes pass through or interference. defined in F..A.C. 62- 925.200(20) by an indtistriid Genend Proliibilions user (i.e.. source of dischiuve) - .Annlicable Dischaige of treated groundwater lo a The foUowing poUtilanls shall not be introduced into a W\\T: Discharge poUutants into a "Wastewater FacUity"" as F..A.C. 92-925.400(2 )(a)-(h) Wastewater Facilitv • PoUtilanls which create a fire or e.vplosion hazard in the W\\T defined in F..A.C. 92- 925.200(2y) by an indtistriid Specific ProliibiUons • PoUutants wliich wUl cause corrosive structtind dimmge to the user (i.e.. source of dischaige) - .AppUcable W\\T. but in nocase dischaiges with pH lower than 5.0. unless the W\\T is specUicaUy designed to accommodate such tlischaiges; • SoUd or viscous poUutants in imiounts wliich vsiU cause obstnicUon to the flow in the W\\T resulting in interference; • .Any poUutatil. including o.vygeti deniatulitig poUutants. released in a dischaige at a flow rate or poUutatil concentration wliich wUl cause interference with the W\\T; • Heat in iuiiounts wliich vsiU inliibit biologicid acUviry in the WWF restilUng in interference, but in no case heat in such qtiatiliUes that result in the tlischaige from the treatment plant having a temperature that e.vceeds 40~'C (F) unless the Department, upon request of the control authority, approves idteniate temperature limits in accordance vsith Rule 92- .^02.520. F..A.C.; • Petroleum oU. nonbiodegradable cutUtig oil. or products of niitiend oU origin in iuiiounts that wUl cause interference or pass tlirotigh; • PoUutants wliich result in the presence of to.vic gases, vapors, or fumes vsitliiti the W\\T in a qtiatiUly that vsiU cause acute worker heidth and Sidety problems; or • .Any trucked or hauled poUutants. e.vcept at tlischaige points Locid Limits: Where specUic prohibiUons or limits on poUutants or Discharge poUutants into a "Wastewater FacUity"" as F..A.C. 92-925.400(4) poUutatil pariuiieters are developed by a ptibUc utUity in accordance defined in F..A.C. 92- 925.200(20) by an indtistriid vsith F..A.C. 92- 925.400(.^). such limits shaU be deemed to be user (i.e.. source of dischaige) - .AppUcable liretreetment standards. fiipe .i 0111 Table 8-8 Acllon-Speclflc AR.AR^s Action/Media Requirement Prerequiste Citation Chuniaerizdri"!! - Piiimiiy (c.!,'., exc(n(i!e(i wasie und cmuiiiiimiied S"il, pm-^ed •^nniiidwuien and Secmdaiy (c.!,'., cinianiinaied equipnieni nr ireaniieni residualst ChiiTacieriZiilion o\ snlid waste (idJ priniiir\ Musi tieiennine if solid wasie is a hazardous wasie using ihe foUowing Generation of solid waste as defined in 40 CFR 2b 1.2 40CFR 2b2.11(a) and (b) iiiul secoiuiiiA Wiisies) melhod: - .Applicable F..A.C. b2-7.^0. IbO • Should firsi deiennine if wasie is excluded from regulation under 40CFR 2hl.4; and • Musi then determine if waste is listed as a hazardous waste under suhpart D40CFR Part 2hl. Must deiennine whether the waste is (characteristic waste) identified in Generation of solid waste witicit is not e.xcltided 40CFR 2b2.11(C) suhpart C of 40 CFR pan 2h Ihy either: tmder40CFR 2bl.4(a) - .Applicable F..A.C. b2-7.^0. IbO (1) Testing the waste accoaling to the methods set fonh in suhpart C of 40 CFR pan 2hl. or accoaling to an ec|uiv;dent method approved In the Administrator under 40 CFR 2h0.21; or (2) AppKing knowledge of the hazard characteristic of the waste in Must refer to Pans 2h 1. 2h2. 2h4. 2h5. 2hh. 2hS. and 273 of Chapter Generation of solid waste witicit is deterittitted to be 40 CFR 2b2.11(ti) 40 for possible exclusions or restrictions penidning to management of hazardous Waste - .Applicable F..A.C. b2-7.^0. IbO the snecific waste. ChiiTacierizalion of ha-j.ird"us waste Must obtidn a detaded chemicid and physicid amdyisis on a Generation of RCR.A hazardous waste for storage, 40 CFR 2b4. LVa)( 1) fiiU pruniiA aiul secoiuiiiA wasies) representative Siunple of the waste(s). which at a minuntim contidns all treatment or tlisposal - .Applicable F..A.C.b2-7.V).lS0(l) the infonnation that must be known to treat, store, or dispose of the Waste in accordance with pertinent sections of 40 CFR 2b4 and 2bS. Deienninalions for managemenl of Must deiennine each EP.A Hazardous Waste Number (waste code) Generation of hazardous waste for storage, treattttenl 40 CFR 2bS.y(a) haZiirtloiis wasie applicable to the waste in order to deiennine the applicable treatment or tlisposal - .Applicable F..A.C. b2-7.V).lS.^ standards tinder40CFR 2bS et seq. Note: litis detennination may be made concurrently with the hazardous Waste detennination required in Sec. 2b2.11 of litis chapter. Must detenttitte the underlying hazardous constituents [as defined in Generation of RCR.A characteristic hazardous waste 40 CFR 2bS.y(a) 40 CFR 2bS.2(i)] in the characteristic waste. (and is not DOOl nott - wastewaters treated by F..A.C. b2-7.V).lS.^ CMBST. RORGS. or POLVM of Section 2bS.42 Table 1) for storage, treatment or tlisposal - .Applicable Deienninalions for managemenl of Must detenttitte if the hazardous waste meets the treattttenl standards Generation of hazardous waste for storage, treatment 40 CFR 2bS.7(a) hazartloiis wasie in 40 CFR 2bS.40. 2bS.45. or or tlisposal - .Applicable F..A.C. b2-7.V).lS.^ 2bS.4y by testittg in accordattce with prescribed methods or use of generator kttowledge of waste. Note: litis detenttination can be made concurrently with the hazardous Must comply \sith the speciid requirements of 40 CFR 2bS.y in Generation of waste or soU that tlisplays a hazardous 40 CFR 2bS.7(a) adtlition to any applicable requirements in CFR 2bS.7. characteristic of ignitability. corrosivity. reactivity, or F..A.C. b2-7.V).lS.^ to.xicity for storage, treaunent or disposal - .Aniilicable filQC tj of 11 Table 8-8 Acllon-Speclflc AR.AR^s Action/Media Requirement Prerequiste Citation Si'ini'^e - Piiimiiy (c.!,'., exc(n(i!e(i wasie und cmuiiiiimiied snili and Seciukiiy (c.i,'., cmiaiiiiiiaied equip men! "/• irenmieni residuals t TemponiA on-sile storage of hazartloiis A generator may acctiintilale hazartlotis waste at the facility provitletl .Accumulation of RCR.A haZiirdotis waste on site as 40 CFR 2b2..M(ii); Waste iti cotitaitiers that: defined in 40 CFR 40CFR 2b2..M(ii)(l)(i); • Waste is placetl in containers that comply with 40 CFR 2h5.171 2bO. 10 - .Applicable 40CFR 2b2..M(ii)(2) and (.^) -17.V atitl F..A.C. b2-7.u;). IPO • the tlale upon which accumulation begins is clearly marked and visible for inspection on each contidner; • contidner is marked with the words "liazardous waste""; or • contidner may be niiirked with other words that identify the .Accumuladon of 55 gid. or less of RCR.A haZiirdotis 40CFR 2b2..M(C)(l) contents. Waste or one qtiiirl of acutely haZiirdotis waste listed F..A.C. b2-7.u;). IPO in 2bl..vVe) at or neiir any point of generation - .Applicable L'se atui iiiatiageiiietit of hazartlotis waste iti If contidner is not in good cotulidon (e.g. severe rusting, stnicttind Storage of RCR.A haZiirdotis waste in contidners - 40CFR 2b5.171 :otitai tiers defects) or if it begins to leiik must transfer waste from (Ids contidner .Applicable F..A.C. b2-7.u:).lS0(2) to a contidner that is in rood cotulidon. Must use contidner made or lined with niateriids compadble with waste 40 CFR 2b5.172 to be stored so that the ability of the contidner to contidn is not F..A.C. b2-7.u:).lS0(2) impidred. Contidtiers must be closed during storage, e.xcept when necessiiry to 40 CFR 2b5.17.Vii) and (b) F..A.C. adtl/remove waste. b2-7.^0.180(2) Contidner must not opened. hatuUed and stored in a manner that may nintiire the container or cause it to leak Storage of hazartlotis waste in conlainer .Area must have a contidtunenl system designed and operated in Storage of RCR.A haZiirdotis waste in contidners with 40 CFR 2b4.175(ii) iirea accordance with 40 CFR 2b4.175(b) tree liauids - .Annlicable F..A.C.b2-7.u:). 180(1) .Area must be sloped or othenvise designed and operated to tlridn liquid Storage of RCR.A-haZiirdous waste in contidners ihai 40 CFR 2b4.175(C)( 1) and (2) restildng from precipitadon. or d" H"! oniainp-ee liquids (other than F020. F021. F..A.C.b2-7.u:). 180(1) Contid tiers must be elevated or othenvise protected from contact with F022. F02.\F02b and F027) - .Applicable acciimiilateil liniiiil Closure of RCRA conlainer storage unit .At closure, idl haZiirdotis waste and haZiirdotis waste residues must be Storage of RCR.A haZiirdotis waste in contidners in a 40 CFR 2b4.178 removed from the contidnment syistem. Reniidning contid tiers, liners, unit with a contidtuiienl system - .Applicable F..A.C.b2-7.u:). 180(1) bases, and soils contidning orcontimiinated with haZiirdotis waste and haZiirdotis Waste residues must be decontimiinated or removed. [Comment: .At closure, as tliroughout the operating period, unless the o\Mier or operator can demonstrate in accordance with 40 CFR 2bl ..Vd) of (Ids chapter that the solid waste removed from the contid tunenl system is not a haZiirdotis waste, the owner or operator becomes a generator of haZiirdotis waste and must manage it in accordance with idl applicable requirements of piirts 2b2 tlirotigh 2bb of tliis chapter]. filQC -Ofll Table 8-8 Acllon-Speclflc AR.AR^s Action/Media Requirement Prerequiste Citation Storage aiui processing of non- haZiirtloiis No person shall store, prtvess. or tlispose of soliti waste e.xcept as Management and storage of sodd waste F..A.C. h2 701 ..^00( 1 )(a) and (h) Waste atilhorizetl at a perniilletl soliti waste nianagenient facilit\ or a facility - .Appdcahle e.\enipt from perniitting tituler this chapter. No person shall store, prtvess. or tlispose of soliti waste in a inanner or kvation that Causes air C|Uality statulartls to he violaletl or water C|Uality staiiilanls orcriteria of reivivino warers to he violateil Tied!men! and Dispnsd! - Priimiiy (c.i,'.. excduneii \eds!e and cnkimiikUeii snili and Secmddiy (c.i,'.. cmkimimned equipmem m- nedHiiein resiiiiidlsi Disposal of RCRA haZartlotis waste itl a May he latul tlisposetl if it meets the requirenients in the tahle Latul disposid. as defined in 40 CFR 2hS.2. of 40 CFR 2hS.40(a) latul-based titlit "Treatment Statulartls for Hazartlous Waste"" at 40 CFR 2hS.40 before restricted RCR.A waste - .Appdcahle F..A.C. h2-7.k:).lS.^ latul tlisposal. .All tituleriying hazartlous constituents [as tiefinetl in 40 CFR 2hS.2(i)] Latul disposal of restricted RCR.A characteristic 40 CFR 2hS.40(e) must meet the L'TS. fotitul in 40 CFR 2hS.4S Tahle L'TS prior to latul Wastes (DOOl -D04.^) that are not managed in a F..A.C. h2-7.k:).lS.^ tlisposal wastewater treatment system that is regulated under the CW.A that is CW.A equiv;dent. or that is injected into a Class I nonhazardotis injection wed - .Appdcahle Disposal of RCRA hdzdni'His \eds!e S"il in Must he irealetl accortling to the altenuitive treatment statulartls of 40 Latul disposal, as defined in 40 CFR 2hS.2. of 40 CFR 2hS.4y(h) a latul-based titlit CFR 2hS.4y(c) or accortling to the L'TSs specified in 40 CFR 2hS.4S restricted hazardous sods - .Appdcahle F..A.C. h2-7.k:).lS.^ applicable to the listed atui/orcharacterislic waste contimiinating the soil nrior to land disnosal Disposal of RCRA haZartlotis waste in a To detemiine whether a hazardous waste indentified in tliis section Latul disposal of RCR.A to.vicity characteristic wastes 40 CFR 2hS..M(f) [atul-hasetl unit e.Kceeds the applicable treatment standards of 40 CFR 2hS.40. the (DOOl -DOl 1) that are newly identdied (i.e.. wastes, F..A.C. h2-7.k:).lS.^ initiid generator must test a Siunple of the waste e.xtract or the entire sod. or debris identdied by the TCLP hut not the Waste, depetuling on whether the treatment standards are e.xpressed as E.xtraction Procedure) - .Appdcahle concentration in the waste e.xtract or waste, or the generator may use knowledge of the waste. If the Waste contidns constituents (including L'HCs in the characteristic Wastes) in e.xcess of the applicable L'TS levels in 40 CFR 2hS.4S. the Waste is proliihited from latul disposid. and ad requirements of part 2hS are appdcahle. e.xcept as othenvise specified. Disposal of RCRA haZartlotis waste tlehris Must he treated prior to latul tlisposid as provided in 40 CFR Latul disposid. as defined in 40 CFR 2hS.2. of 40 CFR 2hS.45(a) in a latul-hasetl unit (i.e.. latulfill) 2hS.45(a)(l)-(5) unless EP.A determines underdOCFR 2hl..Vf)(2) restricted RCR.A hazardous debris - .Appdcahle F..A.C. h2-7.k:).lS.^ that the debris no longercontimdnated with hazardous waste or the debris is treated to the waste -specific treatment standard provided in 40 CFR I'hS 40 for the waste contamiiiatino the ilehris Disposal of RCR.A characteristic .Are not proliihited. if wastes are treated for ptiqioses of the Latul disposal of hazardous wastewaters that are 40 CFR 2hS.4y(h) wastewaters in a POTW pretreatment requirements of Secdon .di7 of the CW.A. unless the hazardous only because they e.xliihit a characteristic F..A.C. h2-7.k:).lS.^ Wastes are subject to a specified method of treatment other than and are not othenvise proliihited under 40 CFR 2hS DFACT in 40 CFR I'hS 40 or are DOO^^ reactive cvaiiide - Annlicahle filQC S of 11 Table 8-8 Acllon-Speclflc AR.AR^s Action/Media Requirement Prerequlste Citation Capping' H in Place LaiulliU cover design and consiniclion LaiuUUls shidl have a fiHiU cover designed lo luinmiize inlUtraUon and Closure of a Class 1 soUd waste laiulfUl as defined in F..A.C. h2-701.h00(.^)(g)(l) erosion, wiiich siudl inciiuie a harrier layer consisUng of a soU layer, a F..A.C h2-701..M0(2)(a) - Relevant and .Appropriate geoniemhrane. or a comhinaUon of a geoniemhrane with a low penneahiUlv maleriiU. .AU geosynlheUc and soU componenls used in the fiiuU cover shidl meet F..A.C. h2-701.h00(.^)(g)(l) the [siihslanUve] slaiulards and specificalions conlidned in Sllhparagraphs 02- 701.4001.^)(d)l. and 2.. (.^)(d)5. -11.. paragraph (e). and (f). F..A.C. For iinUned Class 1 laiulfUls (i.e.. iinUned laiuifUls conlidning "Class 1 F..A.C. h2-701.h00(.^)(g)(l) Waste""), the harrier layer shaU have a penneahUily of 1 .\ 10 -7 cni/sec or less. "Class 1 waste"" means soUd waste that is not hazardous waste, and that is not prohibited from disposid in a Uned laiuifUl under Rule hl'^OI U)0 FAC SeeFAC hl'^OI I'OOd^i • U" the harrier layer consists only of sod. follow the design F..A.C. h2-701.h00(.^)(g)(2) specifications provided in F..A.C. 02- 701.h00(.^)(g)(2). through (4). • U" the harrier layer consists only of a Geosynthetic Clay Liner (CiCL). follow the design specUicaUons provided in F..A.C. 02- • U" a geomemhrane is used in the harrier layer, follow the design snei'ificalions nroviileil in F AC hl' ^OI hOO(^)(oiM) LaiuiliU cover design and consiniclion One may use an idternate design for the harrier layer or parts of the Closure of a Class 1 soUd waste laiulfUl as defined in F..A.C. h2-701.h00(.^)(g)(h) f.Allernale design) harrier layer, or for the protecUve soil layer, upon a demonstraUon that F..A.C h2-701..M0(2)(a) - Relevant and .Appropriate the idternate design wUl result in a siihstantiaUy eqiiivident rate of stomnvater infUtraUon tliroiigh the fiiud cover. SOTE Remedial Desi'en and Remedial Acrinn Wf/ik Plan will LaiuiliU cover design and consiniclion The closure design plan shaU demonstrate how the stomnvater Closure of a Class 1 soUd waste laiulfUl as defined in F..A.C. h2-701.h00(.^)(h) f Slornnvaler control) management systems shaU he operated and nudntidned as necessary to F..A.C h2-701..M0(2)(a) - Relevant and .Appropriate meet the rec|uirements of siihsecUon h2-701.400(9). F..A.C. SOTE Remedial Desi'en and Remedial Acrinn Wf/ik Plan will include LaiuiliU cover design and consiniclion The closure design plan shaU show how access to the closed laiulfill Closure of a Class 1 soUd waste laiulfUl as defined in F..A.C. h2-701.h00(i) t Access coniroi) shaU he restricted to prevent any future waste dumping or use of the F..A.C h2-701..M0(2)(a) - Relevant and .Appropriate F..A.C.iUty hy unauthorized persons. SOTE Remedial Desi'en and Remedial Acrinn Wf/ik Plan will include filQC Oof 11 Table 8-8 Acllon-Speclflc AR.AR^s Action/Media Requirement Prerequlste Citation LaiulliU cover design and consiniclion Concrete monuments shall he installed to mark the hoiindaries of the Closure of a Class 1 solid waste laiuifill as defined in F..A.C. h2-701.h00(h)(a) fBoiindarv markers) laiuifill propertv and other pennanent markers shall he installed to F..A.C h2-701 ..M0(2)(a) \sith a fimd elevation of less outline the genend waste fiUed areas. These markers shall he tied to than 20 feet above the natiind land surface - Relevant one or more of the houndarv markers hy a siiiv ey perfonned hy an and .Appropriate engineer or a Rorida Licensed Professiomd Siiiv eyor and Mapper. The location and elevation of all markers shall he shown on a site plan fded \sith the "Declaration to the Piihlic"" described in F..A.C. h2-701.h00(7) LaiuiliU Deed Notice Once closure construction has heen completed, the landfill owner or Closure of a Class 1 solid waste laiuifill as defined in F..A.C. h2-701.h00(7) operator shall file a declaration to the public in the deed records in the F..A.C h2-701..M0(2)(a) - Relevant and .Appropriate office of the county clerk of the county in wliich the laiulfiU is located. The declaration shall include a legid description of the property on which the landfill is located and a site plan specifying the area actually filled with solid waste. The declaration shall idso include a notice that any future owner or user of the site should consult with the FDEP prior to planning or initiating any activity involving the tlistiirl^ance of the laiuifill cover, monitoring syistem or other control structures. .A certified copy of the declaration shall he fded with the FDEP. LaiuiliU cover design and consiniclion The fimd cover shall he vegetated to control erosion and provide a Closure of a Class 1 solid waste laiuifill as defined in F..A.C. h2-701.h00(.^)(f)(2) tVegelalion and Grading) moisture infiltration se Transportation of hazardous waste Must comply \sith the generator standards of Part 2h2 including 40 Preparation and initiation of sliipment of hazardous 40CFR 2h2.10(h); "jj-siie CFR 2h2.20-2.^ for manifesting. Sect. 2h2..^0 for packaging. Sect. Waste off-site .Applicable F..A.C. h2-7.^0. IhO 2h2..M for labeling. Sect. 2h2..^2 for marking. Sect. Ibl-oo for nlacanlino filQC 111 of 11 Table 8-8 .Acllon-Speclflc .AR.AR^s .4ction/Me(lia Requirement Prerequiste Citation Transportation of lui:iiril"us materials Shad he suhject to and must comply \rith ad appdcahle provisions of .•\tiy person who. undercontract with a depiulment or 4yCFR 171.1(c) the HMT.^ and HMR at 49 CFR 171- ISO related to nnmkitig. lahedtig. ageticy of the fedend goveniment. transports "in placiu'ditig. packagitig. emeigeticy response, etc. conuiierce."" or causes to he transported or shipped, a hazardous material Annlicahle Transportation of siunples (i.e. .\re not suhject to any rec|uirements of 40 CFR Piuls 2hl tlirotigh 2hS SiUiiples of sodd Waste or a Siunple of water, soil for 40CFR 2d 1.4(d)( 1 )(i)-(iii) contiuninated sods and wastewaters) or 270 when: ptiqiose of condtictitig tesdng to determine its F.-^.C. d2-7.^0.0.^0 • the siunple is heitig transported to a lahoratoiy for the purpose of chimicterisdcs orcomposidon .Appdcahle testitig; or • the siunple is heitig transported hack to the siunple codector idter testitig • the siuiiple is heitig stored hy Siunple codector before transport to a lah for tesdng Notes .\R.\R = appliCiilMe "/• relevani and appropriate requirement CFR = Code of Fedend Regulations CWA = Clean Water Act F.A.C. = Rorida Administrative Code. Chapters as specified FDEP = Rorida Department of Envirotimentid Protection F.S. = Rorida Statutes 1-L\P = hazardous airpoUutant FIMTA = Hazardous Materiids Transportation Act HMR = Hazardous Materiids Regulations RCRA = Resource Consenation and Recovery Act TCLP = to.vicitv characteristic leacliing procedure L'HCs = tmderlyitig hazardous constituents L'SDW = L'ndeigrotind Sources of Dritikitig Water L'TS = L'tiiversid Treatment Standards VOC = volatde orgatiic compound i The designated ntimher of weds, siunplitig tune fnunes/freqtiency. and specific pimuneters for atudyses \riU he provided in a Motiitoritig Plan that is iticltided in a CERCLA post-ROD document prepimed as piul of the Remetliid Design or Remediid Action wliich is approved hy the EPA and the FDEP. f\l9C Ilotll Table 10-1 Comoarative Analysis of Remedial Alternatives Balancing Criteria Remedial Timeframes Reduction in Time to Design Remedial Alternatives Long-term Toxicity. Mobility Time to .Achieve Short-term Total Project and Construct (No Action Alternatives - not included) Effectiveness and or Volume Implementability RAOs and/or Effectiveness Cost (NPVi (Prevent Permanence through Cleanup Levels' Exposure) Treatment SS-2 - Rc-mnvnl nl'PTAV: Lisinlkiliun of Low- Meilium Low High High S14.310.4iX) 2-3 Ye^irs 5 yv^irs Pi:Tiivnbilit> Cnp: ICs SS-3 - Rc-mnvnl of PTAV: Exonvniinn ^UKI (;)Q-Sili:- Dispnsnl of CnnlniiiinnlrtI Soil Pusuig n Dirc-ol Expnsiirc-^Cnnlnol Meilium In High Meilium Lnw In Meilium Lnw In Meilium S2lS.lSlS6.5iX) 2-3 Ye^irs 5 yv^irs Risk (ExvVrtling CniiuiicToinl/lniluslrinI CTLsc Inslnlkilinn ni'Lnw-PcTmc-nbilily Cnp: ICs SS-4 - Rc-mnvnl nl'PTAV: Exonvniinn ml (;)1'1-Sili:- Dispnsnl of Cunlniiiinnlrtl Snil Pusing n Dirc-ol Expnsiirc-^Cnnlnol Risk (ExvVrtling CniiuiicToinl/lniluslrin! CTLsi ml n Risk High Meilium Lnw Lnw S41..X)0.0(X) 3 Ye^irs 5 yv^irs In GrniuklwsiicT \ in Lc-nohiiig lExiVrtling Lc-nohnbilily CTLs) SS-5 - Rc-mnvn! nl'PTAV: Exonvnlinn ml (lU'l'-Sili:- Dispnsn! of Hut Spni^ Soil: Lislniinlinn of Ln\v -PcTiivnbilit> Meilium In High Meilium Lnw In Meilium Lnw In Meilium S2!S.465.0(X) 2-3 Ye^irs 5 yv^irs Cnp: ICs SS-6 - Rc-mnvn! nl'PTAV: Exonvnlinn nl'Hui Spot Soil: Ex- Silu Slnbiiiznlinii/llln-sili:- Cnnsniiilnlinn: Meilium High Meilium Meilium S21.003.0(X) 2-3 Ye^irs 5 yv^irs Inslniinlinn ni'Lnw-PcTiiknbilily Cnp: ICs SS-7 - Rc-mnvn! nl'PTAV: Li-Sitii Slnbiliznlinn/Sniiilifionlinn of Hut Spot Soil: Lislniinlinn of Ln\v -PcTiivnbilit> Meilium High Meilium Meilium In High S10.023.4iX) 2-3 Ye^irs 5 yv^irs Cnp: ICs Sfdimfnt Allfriuilii'i's SD-2 - Srtliiikiil Drrtlgiiig ml (llff-Sili:- Dispnsnl High Meilium Lnw Meilium S10.755.1(X) 2-3 Ye^irs 5 yv^irs SD-3 - Srtliiikiil Drrtlgiiig ml (lln-Silc- Dispnsnl Meilium In High High Lnw In Meilium Meilium S12.222..^(X) 2-3 Ye^irs 5 yv^irs SD-4 - Srtliiikiil Cnpping: ICs Meilium Meilium Meilium Meilium S7.534.7(X) 2 Ye^irs 5 yv^irs SD-5 - En\ irnniikiilnl Bulklknd Cnnsliuolinn: ICs Meilium In High Low In Meilium Lnw In Meilium Lnw In Meilium S14.S00.3(X) 5 Ye^irs 5 w^irs I "t 2 Table 10-1 Comoarative .Analysis of Remedial .Alternatives Balancing Criteria Remedial Timeframes Reduction in Time to Design Remedial Alternatives Long-term Toxicity. Mobility Time to .Achieve Short-term Total Project and Construct (No Action Alternatives - not included) Effectiveness and or Volume Implementability RAOs and/or Effectiveness Cost (NPVi (Prevent Permanence through Cleanup Levels' Exposuret Treatment GroHiidwali'r AUi'riuitiyi'a G\V-2 -MN.A/LTM: ICs Low Low High High S2.17.=;.4 G\V-4 - In-Situ Che-mioil (Itxiihition: MN.-VLTM: ICs Meilium Meilium to High Low Meilium S20.2S0.6 G\V-5 - Pe-riiie-iible- Re-iictive- Bmie-ri MN.-VLTM: ICs Meilium Meilium Meilium to High Meilium S27.7L^.7(X) •M Years >1(X) Vem G\V-6 - Cut-(;)ff Will Willi PA;T for Contiiiniiie-nt: Meilium Meilium Low to Meilium Meilium S1S.66S.6 GW-S - Hyilniulic Contiiiniiie-nt by PA;T: ICs Low to Meilium Low to Meilium Meilium to High Low to Meilium S16.416..W) 2-.^ Years >1(X) Vem G\V-9 - Groiuklwiite-r PA;T: MN.A/LTM: ICs Meilium to High Meilium to High Meilium to High Low to Meilium S.X)..^.^2.4tX) 2-.^ Years >.^(4 veiirs Nnic-s: ' Soil nllcTiinliws Hililrc-ss siirhkv ml subsiirhkv li vnilusc- zuiic-i soils ml inoliklc- PTW rc-movnl (;)ff-sili:- soils on llic- J.-\.XP(;)RT ^topcTly will Iv iikUkigrtl using IC's on J.-\.XP(;)RT's property JAXPtltRT property niso hns ^in e-xisling low pe-rme-nbility siirl\kv llkil ^roviile-s e-rosion control, isokile-s iinpncle-il soils by inilignling inl'illnilion lluis re-ilucing llie- poie-nlini for le-nching of CtltCs in \sklose- zone- soils to ilie- groiukKvsiie-r. ml ^roie-cls ngninsi future- huiikin ml e-cologicnl e-xposure- ^ Hot Spot soil in llie- FS We-re- "iile-nlille-il using soil conce-nlinlions llkil e-xce-e-ile-il \s)lue-s of KX) liiiie-s le-nclkibilily bnse-il crile-rion for pe-slickle-s ml 10 liiiie-s le-nclkibilily bnse-il crile-rion for iiie-lnls" For soil ml Se-iliine-nl nlle-nkilive-s. e-sliiikile-il lime-lrame-s ^ire- for nchie-\ ing RAtlts ml e-liiniikiling risk to huiuiin he-nllli ml llie- e-n\ ironme-nl For groiuklwoie-r nlle-rikilive-s. llie- liine-frnme-s shown ^ire- for nchie-\ ing llie- cle-linup le-\ e-ls AR.AR = Applicable- or re-le-\sini ml iip^ro^riiile- re-c|uire-me-nl NPV = Ne-t ^re-Se-nt \rilue- CTLs = Cle-iinup liirge-l le-ve-ls (Eorkhi Ailminisliiilive- Cixle- 62-777) PTAV = Principal tlire-iit wiiste- ICs = Inslitulioikil controls RA(;)s = Re-iiie-iliiil miction obje-ctive-s JAXPtllRT = JiicLsoin ille- Port Authority ZA'I = Ze-ro-vnie-nt iron LTM = Long-te-rin monitoring NINA = Monitore-il ikitural iitte-nikition Pd^'f 2 "t 2 Table 12-1 Selected Remedy t'ost Estimate Capital Costs for Selected Remedy Components I'nit Ex tended Componenl Mediii Description Quantity I'nit Cost Cost 1.0 SoU Site Preparation and Controls 1. Concrete demolition and crushing 2.24S CV SI 32 5266.616 2. Site clearing and stormwater controls LS 562.(134 2.0 SoU Phosphate Sludge Pile (PTWD 2.787 CV S412 51.146.66(1 E.xcavation and iDff-Site Disposed of Fomier Surface Impoundment 3.0 SoU (PTW) 1. E.xcavation. shoring, dewatering. backfill and sampling 2.167 CV S1(I6 5236.(185 2. Transportation and Disposal - Subtitle D Landfill 1.246 CV S85 51(15.854 3. Transportation and Disposal - Subtitle C Lindfill 1.246 CV S426 5534.281 4.0 SoU Remove Debris from CSX Properly LS 5131.81(1 5.0 SoU Capping and Stomiwater Controls 1. 2'-)-acre Subtitle D cap with 3(i-mil HDPE liner and clay cover 14(1.582 SV S36 55.(186.617 2. InstaUation of a 1-acre stormwater pond . 6.5 feet deep 14.6(18 BCV 57.36 51(16.723 6.0 SoU Institutioiuil Controls LS 544.65(1 7.0 Sedinieni Pe miits/.Access 1. Pemiits/.Access LS 51(1(1.(1(1(1 2. Mobilization/Demobilization of ei|uipment LS 512(1.(1(1(1 s.o Sedinieni Site Preparation 1. Debris Sweep 1 acre 55(1.(1(1(1 55(1.(1(1(1 2. Dock Removal LS 575(1.(1(1(1 3. SUt Curtains/Monitoring 6(1(1 LF 51.266 51.136.4(1(1 4. SUt Curtain Maintenance LS 5186.64(1 5. -Access .Area/Staging .Area Preparation/Restoration •> acre 55(1.(1(1(1 51(1(1.(1(1(1 0.0 Sedinieni Environmental BuUdiead Constmction 1. SheetpUe Procurement and Placement 6(1.78(1 SF 55(1 53.(136.(1(1(1 2. Backfill Behind WaU 48.71(1 CV 525 51.217.75(1 3. E.vtend Low-permeability Cap to Environmental BuUdiead 12.167 SV 517 52(17.35(1 10.0 Sediment Shoreline Protection/Resoration LS 548(1.(1(1(1 11.0 SoU ISS with G.AC/Portland Cement 1. ShaUow ISS Blending 6(1.415 BCV 583 54.666.341 2. ShaUow/lntemiediate ISS Blending 51.582 BCV Sl(i8 55.557.661 3. G.AC and Portland Cement .Adder 111.667 BCV 523 52.552.668 12.0 Grou ndwater Monitoring WeU Replacement LS 531.3(1(1 13.0 Grou ndwater E.vtraction and Treatment LS 51.667.(1(1(1 14.0 Grou ndwater Institutioiuil Controls LS 544.65(1 Subtotal $30,331,650 Cnnlingency .Allowances (2o'f) 56.(166.33(1 Prnjecl Managenieni and Support (5'f) 51.516.583 lo'f Fee/Markup S3.(133.165 Engineering Design (S'r) and Construction Management (6'f) 54.246.431 Total Capital Cost $45,194,200 Fope I 01 2 Table 12-1 Selected Remedy t'ost Estimate Operatiim and Maintenance Ciist, Year .\o. Component Description I'nit Cost Incurred Years 1.0 Cap Maintenance .An nuaUy 3(1 S101.315 2.0 Envirnnnienlal BuUdiead Maintenance .An nuaUy 3(1 SlSo.ooo 3.0 Senii-annual Grniindwaler Sampling .An nuaUy 1.2 S165.6S2 4.0 .Annual Gruundwaler Satiipling .An nuaUy 3 - 3(1 S00.6SS 5.0 OLVM Gruundwaler Trealtiieni and Discharge (Year I-IO) .An nuaUy 1 - 10 Sl.032.701 6.0 OLVM Gruundwaler Trealtiieni and Discharge (Year 11-20) .An nuaUy 11-20 S374.123 7.0 .Annual Project Fee .An nuaUy 3(1 S241.S6S s.o .Annual Project Management Fee .An nuaUy 3(1 S120.034 5 Year Review - SoU. Groundwater. Sediment, and Surface Water 0.0 5. 10. 15. 20. 25. 3(1 6 S62.061 Report Preparation and Submittal Summani of Present Worth Analysis Discount Factor Present Year Capital Cost Annual O&M Cost Total Cost (7'2r> Worth 0 S45.104.200 S45.104.200 1.000 S45.104.200 1 S1.S42.500 S1.S42.500 0.035 S1.722.73S •> S1.S42.500 S1.S42.500 O.S73 S1.60S.503 3 SI.776.506 SI.776.506 0.S16 Sl.440.620 4 SI.776.506 SI.776.506 0.763 SI.355.474 5 S1.S3S.567 S1.S3S.567 0.713 S1.310.S0S 6 SI.776.506 SI.776.506 0.666 S1.1S3.153 7 SI.776.506 SI.776.506 0.623 SI.106.763 S SI.776.506 SI.776.506 0.5S2 Sl.033.026 0 SI.776.506 SI.776.506 0.544 S066.410 10 S1.S3S.567 S1.S3S.567 0.50S S033.002 11 S1.117.02S S1.117.02S 0.475 S531.016 12 S1.117.02S S1.117.02S 0.444 S406.360 13 S1.117.02S S1.117.02S 0.415 S463.040 14 S1.117.02S S1.117.02S 0.3SS S433.756 15 S1.170.0S0 S1.170.0S0 0.362 S427.156 16 S1.117.02S S1.117.02S 0.330 S37S.07S 17 S1.117.02S S1.117.02S 0.317 S354.3S3 IS S1.117.02S S1.117.02S 0.206 S330.007 10 S1.117.02S S1.117.02S 0.277 S300.666 20 S1.170.0S0 S1.170.0S0 0.25S S304.437 21 S743.S05 S743.S05 0.242 SlSo.ooi S743.S05 S743.S05 0.226 S16S.100 23•> S743.S05 S743.S05 0.211 S156.043 24 S743.S05 S743.S05 0.107 S146.530 25 SS05.S66 SS05.S66 0.1S4 S14S.270 26 S743.S05 S743.S05 0.172 S127.034 27 S743.S05 S743.S05 0.161 SI 10.753 2S S743.S05 S743.S05 0.150 Sill.571 20 S743.S05 S743.S05 0.141 S104.S77 30 SS05.S66 SS05.S66 0.131 S105.56S TOT.ALS S45.104.200 S36.SS6.744 SS2.oSo.044 $63^65.849 Total Present Worth Cost (2012 dollars) $63^65.849 Total Present Worth Cost (2itl? dollars) s 68,720,200 F'ape 2 of 2 Figures Path: \\orlando.na.aecomnet.com\Oriando\DCS\BD\ENV\PROPOSAL\2016\Greenfield Trust Jacksonville\GEOSPATIAL\mxd\Figure 1 Site Location Map ROD2016.mxd Kerr-McGee Chemical Corporation FIGURE 1-1 PREPARED FOR: Superfund Site SITE LOCATION MAP 1611 Talleyrand Avenue Greenfield Environmental Jacksonville. Florida Muitistate Trust LLC. Trustee of the Muitistate Project No.: 60314182 Environmental Response Trust Date: 09-21-2016 AECOfA EAST TALLEYRAND AYENUE ST. JOHNS RIVER MPACTED SEDIMENTS Kerr-McGee Chemical Corporation FIGURE 5-1 PREPARED FOR; Superfund Site CONCEPTUALIZED SITE CROSS-SECTION GREENFIELD ENVIRONMENTAL MULTISTATE TRUST LLC, TRUSTEE 1611 Talleyrand Avenue OF THE MULTISTATE Jacksonville, Florida ENVIRONMENTAL RESPONSE TRUST Project No.: 60439404 Date: 9/21/2016 RECORD OF DECISION A=COM 37 ZAST 8fh STKET TOYOTA WAREHOUSE •SB-67 JAXPORT PROPERTY • (TOYOTA AS TENANT) SB-I1I AS8-202 ASB-203 , ' . LSB-H3 1. SB-103 $B-206 AiNVVC-Ollj-. _ ^ S0-2O5A " A"" ASB-207 NWC-01^SB "'•"•sB-117 SB-51B SB-50 S0-5SB-49^ SB-47 ~rtr ni -^-wT I 5B-1 15 •p-OJ S8-I18 '' DFP-02 ^ SB97-o'l».. ' .A®SB97-02. , ; •SB-4 5B-4B,SB1S -118 5s-104/ss-t08® DREDGE/FILL -„„,M « _ —— " SB-5X * ^r—SS-*16sB-l36|i'e\p®"''' ' SB^S • AREA - NWC-04-NWC-03 SB-28. « SB-151- * SS-t1la '-W—T"S8-C SB-1484 ^ B-BB-88 SB-30^X-^SB-30»>^^ V X. / SULFUR 4SB-1 4 ( STORAGE )^?^O^BSB-32 \ \ TANKB-2/ V _, _ BSB-S^s LEGEND: SHAW SOIL SAMPLING LOCATION SEPTEMBER 2004 SHAW SOIL SAMPLING LOCATION OCTOBER/NOVEMBER 2000 AND MAY/JUNE 2002 HISTORICAL SOIL SAMPLING LOCATION PROPERTY BOUNDARIES FORCE MAIN CLEANUP TARGET LEVELS FORMER FACILITY FEATURES APPROXIMATE EXENT OF COCs IN SURFACE SOIL EXCEEDING COMMERCIAL/INDUSTRIAL CTU Kerr-McGee Chemical Corporation FIGURE 5-4 PREPARED FOR: Superfund Site APPROXiMATE EXTENT OF SURFACE SOIL GREENFIELD ENVIRONMENTAL MULTISTATE TRUST LLC, TRUSTEE 1611 Talleyrand Avenue WITH COC CONCENTRATIONS EXCEEDING OF THE MULTISTATE ENVIRONMENTAL RESPONSE TRUST 1"=250' Jaoksonville, Florida COMMERCIAL / INDUSTRIAL CTLs Project No.: 60439404 Date: 11/28/2016 RECORD OF DECISION AS/COM SEE DETAIL AT RIGHT APPROXIMATE LOCATION OF FORMER DOCKS / APPROXIMATE ^LOCATION OF FORMER DOCKS 180 LEGEND: A 2001 SEDIMENT SAMPLING LOCATION A 2002 SEDIMENT SAMPLING LOCATION SEDIMENT CORE SAMPLE SC-21 • (AUGUST 2008) SEDIMENT CORE SAMPLE (FEBRUARY 2008) MONITORING WELL SOURCE: POREWATER AND SEDIMENT SAMPLING ESTIMATED EXTENT OF REPORT (ENSR, JUNE 2008) AND ADDITIONAL CONTAMINATED SEDIMENT 350 SEDIMENT SAMPLING REPORT (ENSR. AUGUST 2008). 2001 AND 2002 SEDIMENT SAMPLING FORMER FACILITY FEATURES LOCATIONS WERE OBTAINED FROM THE REMEDIAL PROPERTY BOUNDARIES INVESTIGATION REPORT (SHAW, 2005) 1"=350' -EM. FORCE MAIN SEWER LINE Kerr-McGee Chemical Corporation FIGURE 5-10 PREPARED FOR: Superfund Site APPROXIMATE EXTENT OF GREENFIELD ENVIRONMENTAL MULTISTATE TRUST LLC, TRUSTEE 1611 Talleyrand Avenue CONTAMINATED SEDIMENT OF THE MULTISTATE Jacksonville, Florida ENVIRONMENTAL RESPONSE TRUST Project No.: 60439404 Date: 12/5/2016 RECORD OF DECISION AECOM PRIMARY SECONDARY PRIMARY RELEASE SECONDARY RELEASE SOURCES MECHANISM SOURCES MECHANISM PATHWAY RECB>TOR Current Future Exposure Routes Maintenance Worker Fisher Industrial Worker Offslte Resident Construction Worker Site Groundwater User 1 1 Wind ¥ •[Inhatalio^ :zx MM Ingestion X X X X Dermal Contact X X X X LL X 1 0 Soil Enosion Sedment Food Chain -P c Solution Ingestion in Dermal Contact Sur^ce Water Ingestion X Dermal Contact X vapor in Trench -»|lnhalaHon 1—r Volatilzation Indoor Air 1—r I I Wind Fugitive Oust -ettnhaiallon'" 1—r "n^T Incidental lr>gestion X Dermal Contact | X X PatlYwa/ considered complete for erahjatlon purposes. X* Pativkvay potentially complete txit not quantilalively evaluated. )f Pattvway not considered complete; howerer, scenario Included because groundrvater treneath the site Is classiiled as a potential drinking water souree Indoor air risk for Itks receptor Is tjased on exposure during use ol the groundwater, not trom a vapor rntrtjslon scenano. If Indoor air risk tor luture industrial worker is ttased on a vapor Inlrusion scenario. Kerr-McGee Chemical Corporation FIGURE 7-1 PREPARED FOR: Superfund Site HUMAN HEALTH CONCEPTUAL SITE GREENFIELD ENVIRONMENTAL MULTISTATE TRUST LLC, TRUSTEE 1611 Talleyrand Avenue EXPOSURE MODEL OF THE MULTISTATE Jacksonville, Florida ENVIRONMENTAL RESPONSE TRUST Project No.: 60439404 Date: 11/23/2016 RECORD OF DECISION A=COM SOURCE TRANSPORT EXPOSURE ASSESSMENT ENDPOINTS SOURCE MEDIUM MECHANISM MEDIUM Terrestrial Bird Populations Historic Surface Soil Industrial Site Soils Activities Uptake by Terrestrial Mammal Terrestrial Food Plants and Populations Cfiain Animals Aquatic Food Piscivorous Chain FIsfi Community Sfiorellne FIsfi Surfece Water Community Storm water Runoff 1 T Bentfilc Invertebrate Sediment Community Aquatic Food Shoreline Bird Cfiain Populations Shoreline Mammal Populations Kerr-McGee Chemical Corporation FIGURE 7-2 PREPARED FOR: Superfund Site ECOLOGICAL CONCEPTUAL GREENFIELD ENVIRONMENTAL MULTISTATE TRUST LLC, TRUSTEE 1611 Talleyrand Avenue SITE EXPOSURE MODEL OF THE MULTISTATE Jacksonville, Florida ENVIRONMENTAL RESPONSE TRUST Project No.: 60439404 Date: 10/31/2016 RECORD OF DECISION AECONi •Appendix A '^^^ponses to Comments Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response Clayton Smith, Letter, September 18, 2016 CS-1 As we have outlined before, and such should be in your The EPA appreciates your support of the Proposed Cleanup Plan. records of past meetings, which we have attended, we are not opposed to your remediation plans and any that you might During the remedial action, dust control measures will be choose is agreeable to us. However it appears that in every implemented to minimize the potential impacts on the instance as regards soil said soil must be disturbed in some neighboring businesses and the entire community. In addition, way in order to effect proper cleanup of the site including perimeter air sanq)ling and monitoring will be conducted to specifically hot spots indicated in your report. Said "hot spots" ensure off-site residents are not exposed to unacceptable are shockingly close to our facility located between 7^ and 8^ concentrations levels of site-specific contaminants. Street and bordered by Westcott and Danes. In addition to the hazards that first came to light some year ago our family has suffered mightily with disease which you have a copy of, but in the meantime (b) (6) (b) (6) (b) (6) . With no history anywhere in our families of (b) (6) we search for answers and it is entirely possible that the culprit lies just across the street from us. In any event we've had enough and will resist by all means legally to impede and prevent eve one spade of contaminated soil or the possibility thereof to be addressed until we (my firm and family) are relocated and compensation provided. We inform you once again of oiu: intentions and would look most unkindly if you were to attempt to proceed without alerting us in time to file legal action. Page 1 of 26 Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response Bill Eaton, email, September 28, 2016 BE-1 Around the herbicide "hot spots" what is the high and average There was no TCDD detected; however, dioxins and furans were 2378 TCDD concentrations? evaluated using toxicity equivalence concentrations (TEQ). Dioxins/furans were analyzed in 4 samples in surface soil and 7 in subsurface soil. The maximum and average TEQs were 309 nanograms per kilogram (ng/kg) and 108 ng/kg, respectively, in surface soil and 1018 ng/kg and 210 ng/kg, respectively, in subsurface soil. The sample locations representing the maximum TEQs are in the area just north of the FASCO building foundation and are proposed for ISS treatment. Adrian E. Brown, email, September 29, 2016 AB-1 Please provide a timeline for the collection and evaluation of The workplan for fish tissue sampling has been finalized. Field the fish tissue san^les from the adjoining St. Johns River. The sampling activities are planned to begin in January 2017. following was noted on page 10 of the Proposed Plan: "Fish Sampling data evaluation and reporting are scheduled to complete tissue sampling will be conducted to verify the risk levels. A by June 2017. fish advisory will be put in place if the results of the fish tissue sampling show that the risk levels are above the EPA acceptable risk range of 1x10'^ to 1x10"'^." AB-2 It did not appear that the Site was evaluated for liquefaction Comment noted. Liquefaction potential will be evaluated during potential. It is crucial for this analysis to be conducted. The the remedial design. Ohio EPA has very good guidance at: http://epa.ohio.gov/portals/34/document/guidance/gd 660 cha pter 5.pdf Page 2 of 26 Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response AB-3 Duval County, FL has had sinkhole occurrences and it was not During the remedial investigation (RI), boreholes were advanced clear if this was taken into account. Please see sinkhole details throughout the site. Review of the site boring logs does not in Duval County, FL at: indicate the presence of sinkholes. Additional investigation will http://fcit.usf.edu/florida/maps/pages/l 1100/fl 1124/fl 1124.ht be conducted during the remedial design. If sinkholes are m observed, their potential impacts on the remedy will be evaluated and measures will be implemented as necessary. AB-4 It is unclear how climate change impacts and rising siudace Climate change factors will be evaluated during the remedial water levels will intact the Proposed Plan, in particular, the design and remedial action (RD/RA). Potential rising surface placement of the pump and treat system(s). water levels will be considered when selecting the location of the groundwater pump-and-treat system. AB-5 The placement of the low permeability liner will increase The proposed retention basin will be lined. Therefore, the stormwater flow, and based on feedback received during the collected stormwater will not come in contact with the Public Meeting, it was my understanding that stormwater contaminated soil beneath the low permeability cap. collected in the proposed detention basin will be subject to It is anticipated that stormwater from the retention basin will be sampling with possible discharge to JEA for treatment. Will discharged to the St. Johns River in accordance with Federal, first flush be conducted? State, and local requirements. Jacksonville Port Authority (JAXPORT), Letter, October 12, 2016 JAXPORT-1 The Proposed Plan identifies soil contamination exceeding Comment noted. It is acknowledged that JAXPORT's commercial/industrial as well as leachability cleanup target concurrence with the selected remedy does not relieve the levels and proposes to allow such contaminated soil to remain Multistate Trust and the EPA of their responsibility to achieve the under a cap on JAXPORT Property. In addition, the Proposed remedial action objectives established for the site cleanup. Plan allows groundwater contamination in excess of both EPA's maximum contaminant levels and the Florida Department of Environmental Protection's (FDEP) groundwater cleanup target levels to remain on JAXPORT property. JAXPORT does not oppose the capping of contaminated soil or natural attenuation for groundwater as the Page 3 of 26 Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response main elements of the preferred remedial alternative. Moreover, JAXPORT appreciates that EPA and the Trust do not want to incur the significant business disruption expenses and severe economic duress that would be caused by intrusive soil and groundwater remediation at the JAXPORT Property and the operations of JM Family. This accommodation to JAXPORT and its tenant, JM Family, should not, however, relieve the Trust's responsibihty to achieve the EPA's Remedial Action Objectives (RAOs) for impacted media on the JAXPORT Property. JAXPORT-2 JAXPORT requests that language be incorporated into Section 2.1.6 of the Multistate Environmental Response Trust decision documents such as this Proposed Plan and the Agreement, entered into on February 14, 2011 by and between forthcoming Record of Decision requiring the Trust to the United States, twenty State governments, the Debtor (Tronox establish an escrow or reserve to remediate the soil and et al), and the Multistate Trustee, and approved by the United groundwater using the least intrusive remedial option to meet States Bankruptcy Court for the Southem District of New York RAOs in JAXPORT Property. That escrow or reserve should (Case No. 09-10156), states the following; not be less than $5,759,665. (See attachment A) "Each Multistate Trust Account may be divided into such number of trust subaccounts dedicated for specific uses as may be deemed necessary in the sole discretion of the Multistate Trustee [emphasis added] (each, a "Trust Subaccount") to con^ly with the terms of, and implement, the Settlement Agreement and this Agreement." The Multistate Trust has advised the EPA that establishing an escrow account (as requested by JAXPORT) would constitute a breach of its fiduciary duty to its beneficiaries (EPA and the State of Florida). The EPA recommends that JAXPORT to follow-up directly with representatives of the Multistate Trust if JAXPORT has questions about the Multistate Trust's authority, Page 4 of 26 Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response responsibilities and fiduciary duties. The EPA also notes that, in the event of a funding shortfall with respect to the Multistate Trust cleanup funds and/or funds from other potentially responsible parties, because the site is on the National Priorities List, it will be eligible to receive Superfund funds to help pay for future cleanup of the site. JAXPORT-3 We note that one of the RAOs is to "Restore inq)acted See response to comment JAXPORT-2 above. groundwater to levels that are protective for a G-II aquifer as a source of drinking water within a reasonable timeframe". In addition, remediation goals for some pesticides in groundwater located in JAXPORT's Property are three orders of magnitude lower than reported concentrations. Therefore, achieving the RAO for groundwater via natural attenuation may take decades or substantially longer than what may be considered "reasonable". Based on this, and the undefined timeframe considered to be "reasonable", the EPA may later determine that active remediation for both affected media on the JAXPORT Property is necessary to comply with one of the main objectives of the Con^rehensive Environmental Response, Condensation & Liability Act (CERCLA). That determination may be triggered by many events, including: (i) the decision by JM Family to relocated to another JAXPORT location or some other event making the JAXPORT Property available for more aggressive remediation, (ii) a Post Five- Year CERCLA Review determines that natural attenuation is not remediating the JAXPORT Property in a "reasonable timeframe" or (iii) construction on the JAXPORT Property that requires contaminated soil removal to avoid harm to human health or the environment. This escrow or reservation of funds would ensure that the financial resources of the Trust Page 5 of 26 Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response are available over an extended timeframe (beyond the 30-year Superfund site average lifecycle) to actively remediate the soil and groundwater contamination that exists at the JAXPORT Property if determined to be necessary by EPA. JAXPORT-4 The preferred remedial alternative in the Proposed Plan calls Comment noted. The EPA and FDEP will work with JAXPORT for the use of Institutional Controls to be utilized that would before in^lementing institutional controls (ICs) on JAXPORT's restrict future activities on the JAXPORT Property. As property. JAXPORT has previously stated to EPA, JAXPORT's business and long-range Strategic Master Plan contenq)lates utilizing the JAXPORT Property in perpetuity. Therefore, EPA's preferred remedial alternative requiring Institutional Controls such as Restrictive Covenants on the JAXPORT Property could unnecessarily limit the use of the JAXPORT Property. JAXPORT requests that EPA seek JAXPORT's approval for any proposed Institutional Controls over JAXPORT Property. JAXPORT-5 The preferred remedial alternative for contaminated media on At this time, the EPA does not anticipate any additional the JAXPORT Property included maintenance of the existing maintenance activities of the parking lot (cap) on the JAXPORT's parking lot (cap). Routine maintenance of the cap by property beyond the occasional removal and replacement of the JAXPORT may include occasional removal and replacement cap due to normal wear and tear. Therefore, the Trust is not of portions of the cap due to normal wear and tear. EPA and anticipated to bear any cap maintenance cost on JAXPORT's FDEP should discuss which routine cap maintenance actions property. EPA, FDEP and the Multistate Trust will coordinate by JAXPORT would be permissible, while meeting the with JAXPORT and provide sufficient advance notice if repairs preferred remedy's threshold and balancing criteria. are required. JAXPORT also requests that EPA and FDEP identify which specific property cap maintenance costs (beyond those cost routinely associated with a parking lot's normal wear and tear) would be borne by the Trust. Finally, should the EPA and/or FDEP determine that the cap, or potions thereof, require Page 6 of 26 Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response supplemental additions and/or modifieations to meet RAOs, JAXPORT must be given sufficient advance notice so as to minimize the impact to the business operations of JAXPORT's tenants. JM Family Enterprises, Inc. (JMFE), Letter, October 12, 2016 JMFE-1 JMFE is pleased to inform EPA that it approves and supports The EPA appreciates JMFE's support of the Proposed Cleanup the Proposed Cleanup Plan (PGP) as is and urges EPA to Plan. finalize it without modification, as the PGP is a viable remedy for the Site that considers the interests and concems of all stakeholders and affected parties. JMFE's concems identified in its March 14, 2016 comments related to the Feasibility Study (FS) have been addressed by the PGP. For your convenience, a copy of those comments to the FS is attached. Assuming there are no modifications to the PGP as presented, and it is finalized as is, JMFE supports it in its current form. However, should EPA modify the current PGP in a manner that would adversely affect JMFE's operations and associates at the facility, as well as other businesses, by reconsidering proposed remedial activities at the Site found in the FS, JMFE reiterates its objections to any such modifications to the PGP. City of Jacksonville (COJ), Letter, October 12, 2016 COJ-1 The City of Jacksonville requests the following: The EPA believes that the contamination at the site has been adequately delineated. However, during the remedial design, - That EPA further delineates the contamination north and additional investigation will be performed to further refine the south of the official boundaries of the Kerr-McGee site and in extent of the soil and sediment contamination from the GSX the St. Johns River for the purpose of identifying any property and the St. Johns River respectively. Additional additional areas where mitigation and remediation efforts contamination identified during this investigation will be would be warranted and where contaminates in the river would need to be impounded and capped. Page 7 of 26 Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response addressed accordingly in the remedial design and remedial action - That any seawalls/bulkheads constructed in the St. Johns (RD/RA). River by EPA for the purpose of impounding contaminated sediment be able to withstand the effects of a catastrophic During the RD/RA, the services of structural and/or marine windstorm engineering firm will be retained to design and to oversee the construction of the bulkhead/seawall. The design and performance requirements of the bulkhead/seawall will be established during the remedial design. These requirements will be set in accordance with all Federal, State, and local regulations and industry standards. COJ-2 That EPA develops and publishes a reasonable timeline for The EPA in consultation with FDEP and the Multistate Trust will completing the Deer Creek clean-up (Operable Unit 2). develop a schedule/timeline to con^lete the cleanup of Deer Creek (Operable Unit 2). The schedule will be shared with the community and stakeholders. St. Johns Riverkeeper (SJRK), Letter, October 12, 2016 SJRK-1 Uncertain Timing of Cleanup Plansfor the Entire Site The EPA in consultation with FDEP and the Multistate Trust will The proposed cleanup plan is only for a portion of the develop a schedule/timeline to con^lete the cleanup of Deer contaminated area, Operable Unit l(OUl). OUl plans to Creek (Operable Unit 2). The schedule will be shared with the address the site-contaminated soil, groundwater, sediment and community and stakeholders. surface water from the St. Johns. OU2 will address site-related sediment and surface water contamination in Deer Creek, a There are multiple other responsible parties whose operations tributary of the St. Johns. The National Oil and Hazardous have adversely impacted Deer Creek upstream with similar Substances Pollution Contingency Plan (NCP) defines an contaminants. The EPA believes that remediation of the section operable unit (OU) as a "discrete action that is comprises an of Deer Creek adjacent to the Site should be coordinated with the incremental step toward comprehensively addressing site cleanup of the upstream areas to prevent recontamination. FDEP problems." is the lead regulatory agency on these upstream Sites. The EPA will work with FDEP and the Multistate Trust to develop a A timeline was not given for the cleanup of Deer Creek strategy to adckess the contamination in Deer Creek. (OU2). This omission undermines the effectiveness of the Page 8 of 26 Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response proposed plan by not adckessing all contaminants in a timely Sediment sampling data collected during the RI show two distinct fashion. areas of contamination in the St. Johns River. The first along the eastern boundary of the property and the second at the mouth of - Please provide a timeline of the anticipated cleanup of OU2 the creek. Since these are discrete areas and considering the level - Please describe implementation of the OUl remediation of planning and coordination that will be required with FDEP, the activities and how they will interface and synchronize with the EPA believes that the Site remediation would be managed more 0U2 remediation activities. effectively by dividing the Site into two Operable Units (OU) where OUl will address the contaminated soil, groundwater, On page 14 of the September 2016 Kerr-McGee Superfund sediment and siurface water in the St. Johns Rive while OU2 Proposed Plan Fact Sheet (Fact Sheet), it states: would address the contaminated sediment and surface water in Deer Creek. "Surface water-specific remedial alternatives were not evaluated in the FS since it was anticipated that the preferred remedy for the Site would consist of a combination of soil-, groundwater-, and sediment specific alternatives, that directly or indirectly adckess the surface water contamination." However, this does not take into account the ongoing surface water contamination from Deer Creek that is not ciurently being considered for remediation. SJIlK-2 Lack of Critical Information During the RI/FS, the community and Site stakeholders actively It appears that critical information and assessment needed to participated in the review of Site documents. The EPA plans to fully understand the benefits and challenges of the proposed maintain active community involvement and participation cleanup plan are not currently available for public review or throughout the RD/RA phase of the project. During the design, decision making. the EPA in consultation with the community will develop a strategy to provide opportunities to the community to participate In the Fact Sheet, EPA commits to "during the design phase of in the development and/or review of the Site documents. the project, a long-term surface water sanq)ling and monitoring program will be developed to assess surface water quahty for DDD, gamma chlordane, aluminum, copper, iron Page 9 of 26 Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response and mercury. The data collected during these sampling events will be used to evaluate achievement of surface water remedial objectives." - Will there be the opportunity for the public to review sampling and monitoring programs before they are finalized? - Will there be an opportunity for stakeholders to submit technical comments? SJRK-3 In Figure 7, sediments sample site locations are not located Figure 7 of the Proposed Cleanup Plan is intended to show the beyond the extent of the identified plume limiting a full estimated extent of contaminated sediment that will be adchressed understanding of the extent of the contamination in the St. in OUl. Sediment sampling performed during the RI showed Johns. contaminated sediment in the St. Johns River at the mouth of Deer Creek. The contaminated sediment observed in this area will - Will additional sanq)ling be conducted to better understand addressed in 0U2. the extent of the plume in the river? Additional sediment sampling will be conducted during OUl remedial design to refine the extent of the sediment contamination directly adjacent to the Site. Moreover, additional sampling will be conducted to better define the extent of sediment impacts for OU2. SJRK-4 Please provide detailed information how the conceptual site Additional sediment sampling will be performed as part of the model will be refined and updated to fill the apparent data remedial design for OUl and the additional remedial gaps including: investigation for 0U2. The data collected during these sampling activities will be used to refine the extent of sediment - Incomplete assessment of the sediment in the St. Johns contamination for OUl and OU2. River and Deer Creek - Incomplete understanding of contamination issues North and South of site Page 10 of 26 Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response SJRK-5 How will the stormwater/surface water discharges be Stormwater/surface water discharge requirements will be regulated from the site? identified during the remedial design for OUl. SJRK-6 Please address infiltration and preferential flow via annual Stormwater infiltration will be addressed by the installation of the spaces and subsequent discharge of contaminated groundwater low permeability cap. The discharge of contaminated to the St. Johns River via the sewer and utilities between groundwater from the site into the St. Johns River will be JAXPORT and the Kerr-McGee site. addressed with the implementation of the punq)-and-treat system. SJRK-7 Inadequate Cleanup of the St. Johns River As documented in the FS report and the Proposed Cleanup Plan, EPA's preferred alternative for addressing approximately 2.5 five remedial alternatives were identified to address the acres of contaminated soil in the St. Johns is inadequate. contaminated sediment in the St. Johns River. These alternatives Capping the contamination behind a bulkhead creates were evaluated based on the criteria specified in the NCP. The unacceptable risk due to storm events and potential leaching. EPA believes that SD-5, which consists of the installation of the bulkhead/seawall and the cap system to contain the contaminated Design work has not been conducted to determine the sediment, is the most effective and efficient alternative to adcfress effectiveness of the proposed bulkhead/seawall. No the impacted sediment. information is provided as to how the sediment contamination behind the proposed bulkhead/seawall will be addressed. As specified the NCP, remedial design activities will be initiated Figure 8 shows surface water to the west of the subsequent to the completion of the record of decision (ROD). bulkhead/seawall while the narrative proposed a "cap" with no detail, only "Capping a 2.5-acres area enclosed by the During the RI/FS, the community and Site stakeholders actively bulkhead." participated in the review of Site documents. The EPA plans to maintain active community involvement and participation - At what point will citizens be able to review and comment throughout the RD/RA phase of the project. During the design, on details regarding the proposed cap and bulkhead/seawall the EPA in consultation with the community will develop a prior to the finalization of the plan? strategy to provide opportunities to the community to participate - Will the bulkhead/seawall and cap be designed to withstand in the development and/or review of the Site documents. a Category 5 hurricane? - What controls will be in place during the dredging of During the RD/RA, the services of structural and/or marine sediments to the East of the proposed bulkhead/seawall? What engineering firm will be retained to design and to oversee the construction of the bulkhead/seawall. The design and Page 11 of 26 Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response controls will be in place during the installation of the performance requirements of the bulkhead/seawall will be bulkhead/seawall and cap? established during the remedial design. These requirements will be set in accordance with all Federal, State, and local regulations and industry standards. As part of the Preferred Remedy, limited sediment dredging is planned to the east of the bulkhead/seawall. Engineering controls and best management practices (BMPs) such as the installation of turbidity curtains will be implemented during the dredging activities. Construction details including engineering controls and BMPs will be provided in the design documents. SJRK-8 On page 14 of the Fact Sheet, it states that Five-Year Reviews As required by the NOP, remedial actions which result in any will be required to verify the effectiveness, but does not hazardous substances, pollutants, or contaminants remaining at discuss remedies available if needed. the site be subject to a five-year review. The purpose of the five- - At what point will this be shared with stakeholders? year review is to evaluate the implementation and performance of a remedy to determine whether the remedy is or will be protective of human health and the environment. The EPA will notify the community during the initial planning stages of the five-year review process. The community and stakeholders will have the opportunity to participate in the five- year review process and the five-year review report will be available to the community. SIRK-9 Additional Public Engagement Necessary During the RI/ES, the community and stakeholders actively Recognizing that the proposed plan is currently a conceptual participated in the review of site documents. The EPA plans to site model, we expect many refinements and potentially maintain active community involvement and participation significant changes to the final cleanup design. throughout the RD/RA phase of the project. During the design, the EPA in consultation with the community will develop a - At what point will citizens be able to review and comment strategy to provide opportunities to the community to participate on critical data and design prior to the finalization of the plan? in the development and/or review of the site documents. Page 12 of 26 Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response As an example, on page 12 of the Fact Sheet, the following The Administrative Record, which includes the documents and comments elevate our concern: data the EPA utihzed to select the remedy for the site, is placed at the Jacksonville Public Library - Brown Eastside Branch, 1390 "It is EPA's current judgement that the Preferred Alternative Harrison Street, Jacksonville, Florida. The community is identified in this Proposed Plan, or one of the other active encouraged to review the Administrative Record and to provide measures considered in the Proposed Plan is necessary to comments and input throughout the cleanup process. protect human health or welfare or the environment.. The Proposed Cleanup Plan was made available to the pubhc on "Remedial Action Objectives (RAOs) are finalized and September 12, 2016. A pubhc comment period was held from documented in the Record of Decision (ROD)." September 12, 2016 through October 12, 2016. An extension was requested and the comment period was extended to November 11, "Based on consideration of factors during the nine criteria 2016. The EPA's responses to the comments received during the analysis and using the PRG (Preliminary Remediation Goals) pubhc comment period are presented in the Responsiveness as a point of departure, the final cleanup levels (to be included Summary, which is included in this ROD. in the Record of Decision(ROD)) may reflect a different risk level within the acceptable EPA risk range (1x10'^ to IxlO"'^ As stated above, the EPA plans to maintain active community for carcinogens) than the originally identified PRGs." involvement and participation throughout the RD/RA phase of the project. During the design, the EPA in consultation with the It is not clear what if any additional public engagement is community will develop a strategy to provide opportunities to the available. On page 24 of the Fact Sheet, the Community community to participate in the development and/or review of the Participation ends with the October 12 Pubhc Comment site documents. deadline. - What are the in the community engagement process between now and the publication of the ROD? And the implementation of the remediation plan? It is not clear what if any additional public engagement is available. On page 24 of the Fact Sheet, the Community Participation ends with the October 12 Pubhc Comment Page 13 of 26 Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response deadline. - What are the in the community engagement process between now and the publication of the ROD? And the implementation of the remediation plan? Please provide details for ongoing stakeholder participation during the design and inq)lementation process. Emhart Industries, Inc., letter, November 11, 2016 — The comment letter provided by Emhart Industries, Inc. is attached to this Responsiveness Summary. EI-1 1.0 Restoration of Aquifer to drinking water quality As stated in the FS, the Proposed Cleanup Plan, and the ROD, the Although groundwater at the Site is not currently used for groundwater at the site is classified by the State of Florida as a potable or non-potable purposes and it is not expected to ever potential source of drinking water (Class G-II). In addition, be used for potable purposes, EPA established the restoration groundwater data collected during the RI indicated that Site-wide of groundwater to chinking water standards as a remedial groundwater had total dissolved sohds levels ranging from 300 to action objective (RAO) for the Site. This RAO, as phrased, is 4,000 mg/L. Therefore, it's the EPA's opinion that the aquifer not appropriate for the Site given the existence of non must meet State-equivalent maximum contaminant levels contiguous source areas scattered across the property, the age (MCLs). In light of the State's Class II designation, a technical of the releases, the degree of contamination, and the presence impracticability (TI) waiver would be required to support the of co-contaminants (e.g., metals, pesticides, VOCs, etc.). That selection and implementation of any remedial approach that is is, these issues in aggregate are highly difficult to overcome, if inconsistent with the ultimate restoration of the aquifer to its not insurmountable, given the extremely stringent drinking beneficial use. Site data does not appear to support a TI waiver water standard. Specifically for a-BHC, restoration to drinking which is consistent with CERCLA TI waiver guidance. water standards would be impractical because it would require achieving a standard lower than laboratory practical The EPA has also contacted FDEP regarding the potential quantitation limits (PQLs). These cumulative factors warrant a reclassification of the aquifer. FDEP is of the opinion that risk-based mitigation approach regarding groundwater reclassification of the aquifer from Class G-II to Class G-III is impacts. very unlikely considering the characteristics of the aquifer. Italic Page 14 of 26 Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response Risk-Based Corrective Action (RBCA) is standard industry text below is FDEP's response to EPA's request to evaluate the practice commonly applied at con^lex sites, such as the Kerr- possibility of reclassification of the surficial aquifer at the Site. McGee Superfund Site, and is promulgated by states within EPA Region 4 in various regulatory frameworks (i.e., state As defined in Chapter 62-520.410, aquifers with a Total Dissolved lead, voluntary cleanup projects, Brownfields). In particular, Solids (IDS) of less than 10,000 mg/i ore classified as Class G-II Florida has expanded the use of RBCA under the "Global" aquifers and designed for potable use, unless otherwise classified RBCA rule (F.A.C. Ch. 62- 780) to apply to all contaminated by the Environmental Regulation Commission (ERC). To qualify sites when legal responsibility for site rehabilitation exists, as a G-lll aquifer, which is designedfor non-potable water use including the statutory directive that citizens be protected under Chapter 62-520.410, groundwater in an unconfined aquifer "under actual circumstances of exposiure." must have a TDS greater than 10,000 mg/i or a TDS of3000 to 10,000 mg/l and have been reclassified by the Commission (ERC) The Kerr McGee Site has been used for industrial purposes as having no reasonable potential as a future drinking water since 1893 (123 years), is and has been surrounded by industrial use, and is adjacent to brackish water to the east. All source. In addition, reclassification of groundwater shall be of these factors make potable use of groundwater at the Site adopted by the ERC only if the following criteria under Chapter relatively impossible. Despite this reality, the State of Florida 62-520.410(l}(d) are affirmed: 1} reclassification will establish has classified the groundwater at the Site as G-II, a potential the present and future most beneficial use of the future potable water source to which state drinking water groundwater; 2) reclassification is clearly in the public interest; standards apply. Although Florida provides for the use of and 3) the proposed designated use is attainable, upon RBCA, EPA considers the drinking water standards to be consideration of environmental, water quality, technological, ARARs at the Site. These standards and the concomitant RAO social, economic and institutional factors. to restore groundwater to these standards are not appropriate based on the following site specific characteristics; no on-site In our examination of the concept of reclassification at this site, or down-gradient potable supply wells, indefinite industrial the following was considered: end use accepted by stakeholders, proposed institutional controls (ICs) which prevent human exposures, available 1) Available site specific TDS groundwater data alternative remedies to address groundwater to sediment 2) Site specific groundwater contaminants of concern and pathway, and the presence of a brackish shallow aquifer with current exceedances of primary and secondary total dissolved solid (TDS) levels that are inconsistent with a groundwater standards and minimum criteria as defined potable water classification. in Chapter 62-520.400 Page 15 of 26 Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response As documented, drinking water receptors do not exist at the 3) Ongoing discharge of contaminated groundwater to Site and will not be present in perpetuity. The EPA further surface water and current surface water cleanup target acknowledges the lack of potential drinking water recq)tors by levels (SWCTL) exceedances in surface water and pore selecting two groundwater remedies that achieve ARARs in water in the St Johns River resulting from those 30 to greater than 100 years. Note that the chosen groundwater continued discharges remedies comprise institutional controls (ICs) and long-term monitoring (LTM) to evaluate natural attenuation for the As outlined below, the proposal for reclassification of the surficial duration of the post-remedy phase (timeframe to be aquifer at the Kerr McGee site to a Class G-lll aquifer does not determined). appear supportable, and would not eliminate the requirement While a technical inq)racticability (TI) waiver may not be that the groundwater meet Florida's GCTLs, even If it were supportable at this time, it is likely that over time, despite the accomplished. unnecessary aggressiveness of the selected remedy, contaminant levels will plateau and never reach drinking water 1) Existing TDS data In Site groundwater does not indicate standards. Under this scenario, an inordinate amount of money that the aquifer at the site qualifies as a Class G-lll will have been spent for naught. As an alternative to a TI aquifer. TDS levels in the majority of the 15 monitoring waiver, however, reclassification of the groundwater should be wells sampled are below 3000 mg/l. Of the several wells sought. where TDS is present above 3,000 mg/l, two wells are adjacent to the St Johns River and two are in the area of The shallow aquifer beneath the Site has been misclassified the former Fasco building/dredge and fill area and are based on the site-specific characteristics and information not considered representative of the overall aquifer presented above. It is generally accepted that a broad-brush, water quality at the site. macro-characterization of aquifers inherently prevents the identification of subset areal zones that, based on zoning, end 2) It would be difficult to establish that reclassification of use, finite geologic conditions, etc., would alternatively be the aquifer to less stringent criteria would be in the best classified differently than the major aquifer system in which interest of the public or the nearby surface water the property resides. EPA's own guidance on the role of State groundwater use determinations based on an EPA-endorsed environment. Any reclassification is required to be Comprehensive State Groimd Water Protection Program supported by findings that the change in classification: 1} (CSGWPP) recognizes that the CSGWPP should have will establish the present and future most beneficial use provisions allowing groundwater classifications to be Page 16 of 26 Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response determined at a specific site. [EPA, The Role of CSGWPPs in of the groundwater, and 2) is clearly in the public EPA Remediation Programs, OSWER Directive 9283.1-09, interest See Chapter 62-520.410(5)(d). April 4, 1997 (CSGWPP Directive).] In light of these factors, the EPA is confident that consistent with The shallow aquifer should be reclassified as G-III per FAC the NCP and existing CERCLA guidance, the groundwater at the 62-520 based on 1) the levels of total dissolved solids (4,000 Site is a future drinking water source. Therefore, identification of mg/L), 2) the fact that the shallow aquifer is not a single restoration of the aquifer to its beneficial use as a remedial action source aquifer (the Floridian aquifer is the local source), and objective for the Site is warranted. 3) the proximity of brackish water (St. Johns River) that would further render the shallow aquifer non-potable as a result of a The EPA recommends that Emhart Industries to follow-up pump and treat remedy (i.e., GW-8). A G-III designation directly with representatives of FDEP if Emhart Industries wants would provide the framework for the implementation of a risk- to fiirther pursue the reclassifieation of the aquifer. based groundwater remedial alternative that would provide a similar standard of care towards human health and the environment, in a more cost-effective manner consistent with the NCP statutes. According to EPA's CSGWPP Directive, which supersedes the NCP Preamble where the State has an EPA-endorsed CSGWPP, if the shallow aquifer was reclassified as G-III, the State's determination would prevail even if it differed from the use that would have been determined by EPA's classification scheme or was less stringent. The groundwater classification is not itself an ARAR, but leads to the determination of what may be an apphcable or relevant and appropriate requirement. Therefore, the requirement that a state standard must not only be promulgated, identified in a timely manner and more stringent than federal requirements, would generally not apply. [See 40 CFR §300.400(g)(4).] Further, FAC 62-520 recognizes that "social, economic, and environmental costs may, under certain circumstanees, outweigh the social, economic, and environmental benefits if the numerical criteria are enforced Page 17 of 26 Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response statewide. It is for that reason that the Commission provided for exemptions from the water quality criteria such as imder FAC 62-520.500 (Water Quality Criteria Exemptions for Installations Discharging into Class G-I or G-II Ground Water). Once the groundwater is reclassified for non-potable use, EPA will be relieved of the undue burden of trying to restore groundwater to potable use under circumstances where restoration is impracticable consistent with 40 CFR 300.430(a)(l)(iii)(F) and the NCP Preamble at 55 Fed. Reg. 8665,8734 (Mar. 8,1990). Further, the RAO for groundwater in the FS and PCP should be modified to more generally prevent human exposure to groundwater. This t)q)e of RAO for groundwater is part of several recent RODs at NPL sites in Florida. EI-2 2.0 Specific Issues and Alternatives to EPA's Selected As documented in the FS report and the Proposed Cleanup Plan, Remedies media-specific (soil, sediment, and groundwater) remedial The specific technologies that have been selected for soil and alternatives were identified to ad(fress the contamination at the sediment are not consistent with a thorough and reasoned Site. These alternatives were evaluated based on the criteria analysis of the primary balancing criteria under 40 CFR specified in the NCP. Considering the site characteristics and the 300.430(f). There is significant potential for cost effectiveness RAOs identified for the Site, the EPA beheves that the Selected while raising the standard for protection of human health and Remedies presented in the Proposed Cleanup Plan and the ROD the environment by selecting alternative remedies. The are the most effective and efficient alternatives to address the Site alternatives selected for groundwater should be modified to contamination. provide a site-wide, holistic approach that works in tandem with the revised soil and sediment remedies. Page 18 of 26 Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response EI-3 2.1 Sediment Remedy Table 5- 1 was generated in an effort to compare media-specific Table 5-1 of the 2016 FS provides a summary of various alternatives against each other. However, the advantages and technologies that were carried through to the con^arative disadvantages, the in^lementation of each alternative would analyses, including a relative ranking, by media, using a series present when combined with other alternatives to address the Site of symbols from low to high. The selected remedial contamination in a holistic approach, were not considered when alternative, SD-5 (environmental bulkhead construction), generating the table. ranked comparatively lower than SD-4 (sediment capping) in four of the five balancing criteria and was ranked equal to SD- JMFF/Southeast Toyota is not opposed to SD-5. Please see 4 in the fifth (long-term effectiveness and permanence). comment JMFF-1 above and the attached comment letter. Implementability of the SD-5 bulkhead ranks the lowest of the sediment remedies and will have to overcome unforeseen administrative hurdles with the Army Corp which are not incorporated in the cost estimate. For example, the PC? states that "SD-5 would take the most time to implemenf" and that "SD-4 ranks highest for implementability" while "administrative requirements could delay or inq)ede installation of the bulkhead (SD-5)". SD-5 ranks highest in cost, while SD-4 ranks lowest. POP at 20-21. Further, as FPA is already aware, JM Family Toyota is opposed to SD-5 and expressed a preference for SD-4 given that dredging and bulkhead construction could have a significant adverse effect on their operations, whereas SD-4 would have the least impact since it would take the least time to inclement. See POP at 20, FS at 5-4. Therefore, SD-5 should be replaced with SD-4 as the selected sediment remedy in accordance with 40 CFR 300.430(e)(9)(iii). Page 19 of 26 Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response EI-4 2.2 Soil Remedy As presented in the FS, SS-7 includes the excavation and disposal Soil remedy SS-2 (removal of PTW; installation of low of PTW; ISS of "Hot Spot Soil" to a depth of approximately 5 permeability cap with ICs) should be replaced by SS-7 feet below land surface; installation of low permeabihty cap. The (removal of PTW; in-situ stabilization of hot spot soils; EPA does not believe that implementation of SS-7 and installation of low permeability cap with ICs), despite the elimination of GW-7 would aehieve the Site RAOs. Therefore, increased investment. Both soil remedies incorporate the implementation of SS-7 in heu of SS-2 and GW-7 is not removal of principal threat waste (PTW); however, warranted. implementing SS-7 would in tum eliminate the need for groundwater remedy GW-7 (removal of PTW; in-situ stabilization of hot spot soils; installation of low permeability cap with ICs) as discussed below. Industry standard practice lends a larger resource allocation on soil hot spot remedies (i.e., source zones) as opposed to groundwater mitigation as a means towards achieving RAOs in a cost-effective manner. EI-5 2.3 Groundwater Remedies As specified in the NCP, the purpose of the RI is to collect the Sufficient data was not presented in the 2005 RI or 2016 FS to data necessary to adequately characterize the site for the purpose support the assunq)tion that groundwater needs to be of developing and evaluating effective remedial alternatives. The remediated at depths up to 20 feet in the shallow aquifer and EPA believes that the site sufficiently and adequately characterize 45 feet in the intermediate aquifer (multiple remedies). The FS to support the selection of a remedy. The EPA also acknowledges does not adequately identify the targeted zones of impacted that additional data will be necessary to further refine the lateral groundwater in regards to the selected remedy, GW-7 and vertical extent of the groundwater source area(s). These data (removal of PTW; in-situ stabilization of hot spot soils; will be collected during the remedial design (RD) phase of the installation of low permeability cap with ICs). The RI did not project. present cross-sectional plume maps that demonstrate the need to treat at the assumed depths. FS guidance requires the During the FS, for cost estimation purposes, it was assumed that volumes or areas of media to which general response actions GW-8 would consist of 15 recovery wells approximately 150 feet might be applied be identified, and this has not been from the shoreline of the St. Johns River. The exact number of adequately demonstrated for groundwater hot spots in Section recovery wells as well as their locations with respect to the 2.5.3 of the FS. In reviewing the comprehensive August 2015 shoreline of the St. Johns River will be determined during the RD. groundwater sampling results, it appears that MW-IOD is the It is also anticipated that groundwater modehng and groundwater focus of the intermediate aquifer target area based on a Page 20 of 26 Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response concentration of a-BHC of 0.97 |ig/L. However, the database pumping test (pilot test) will be performed during the RD prior to that is available as contained in the RI and FS only contains full scale implementation of the remedy. one other sampling event for this well, on November 29, 2000, when the concentration of this compound was estimated with a As with all remedial altematives evaluated in the FS, the EPA J qualifier at 0.010 pg/L. Abetter understanding of the nature acknowledges that there are potential technical uncertainties of the target area within the intermediate aquifer should be associated with the selected groundwater altematives (GW-7 and provided. This data gap directly affects effectiveness, GW-8). However, the EPA believes that GW-7 and GW-8 are the implementability, and cost [40 CFR 300.430(e)(9)] and most effective and efficient groundwater altematives presented in prevents an adequate evaluation and comparison of FS that are capable of achieving the RAOs established for the altematives. site. GW-8 (hydraulic containment with pump & treat and ICs) incorporates the installation of 15 recovery wells approximately 150 feet from the shoreline of the St. John's River. The FS does not reflect that EPA modeled the GW-8 remedy to ensure that brackish water from the river does not intrude upon the remediation system, and more importantly, the G-II aquifer designated as a future water supply. Salt water intrusion, caused by the punq) and treatment (P&T) system, would be counter-productive to the RAO of restoring groundwater to beneficial use since the remedy itself will diminish groundwater quality. Furthermore, the cost- effectiveness of GW-8 is unclear due to the fact that financial resources would be used to pun^) and treat an undetermined volume of captured water from the river, and replace damaged equipment at an expedited timeframe due to the presence of brackish water. An evaluation of the primary balancing criteria, principally permanence, inq)lementability, and cost, does not support the GW-8 remedy [40 CFR 300.430(f)]. Pilot aquifer pumping tests in proximity to the river should be performed in conjunction with modehng efforts prior to final Page 21 of 26 Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response selection of GW-8 so that GW-8 can be properly evaluated and compared to the other groundwater alternatives prior to the issuance of the Record of Decision (ROD). In addition to their technical uncertainties, remedies GW-7 and GW-8 in concert are grossly excessive in conjunction with the selected soil and sediment remedies. Targeting groundwater hot spots following 1) the removal of principal threat wastes (PTW) in soils (i.e., source material), 2) capping the site (prevention of infiltration), and 3) ehminating of the exposure pathway to river sediments is inconsistent with the balanced evaluation of effectiveness, implementability, and cost. [40 CFR 300.430(e)(7).] The preference for treatment and the need for treatment to complement MNA is already satisfied by the removal of PTW in the selected SS-2 remedy and implementation of SS-7 instead of SS-2 as described above would provide even more treatment in a more cost- effective manner that GW-7. Moreover, while much is made of the need for the in-situ stabilization (ISS) under GW-7 as "treatment," ISS only reduces mobility, not toxicity or volimie, and the contaminants remain onsite, just as they would with a cap or containment remedy. [See FS at 4-44 ("[GW-7] would reduce the mobility of COCs due to stabilization. This alternative would not reduce toxicity of COCs...").] Further, implementation of SD-4 (sediment capping) would eliminate die need for GW-8. [See FS at 6-3 ("based on.. .implementation schedule of the sediment remedy, it may be necessary to pair a treatment remedy with a containment remedy" implying that due to the length of time required to construct the bulkhead, the pump and hreat system will be needed as "interim" containment).] Finally, although Page 22 of 26 Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response the June 2016 Technical Memorandum on MNA by AECOM found that "MNA should be considered when source treatment or source control technologies are conducted to significant (sic) reduce the contaminant mass for achieving cleanup goals in a reasonable timeframe," the source treatment components of the soil and sediment remedial alternatives preclude the necessity of GW-8. EI-6 2.4 Underestimation of Remedial Budgets Cost estimates for all remedial alternatives were generated using The cost estimates for EPA's proposed remedial alternatives the Remedial Action Cost Engineering Requirements (RACER) provided in Appendix E of the 2016 FS do not incorporate all database. The EPA believes that the cost estimates presented in of the conq)onents required by the FS guidance. [EPA, A the FS are reasonable and are in compliance with the RI/FS Guide to Developing and Documenting Cost Estimates During guidance document(s). the Feasibility Study, OSWER Directive 9355.0-75, EPA 540- R-00-002, July 2000 (Cost Guidance).] As a result, the ISS and Pump-and-Treat are both well established and commonly estimated cost to implement the selected remedies is used remedial technologies. The level of uncertainty associated underestimated. with the implementation of these technologies are minimal. To mitigate these uncertainties, additional data will be collected In addition to clarification and/or incorporation of the above during the RD. In addition, groundwater modeling and cost estimate conq)onents, a sensitivity analysis may be groundwater pumping test (pilot test) will be performed during warranted with respect to the cost estimate for GW-7. the RD. The data collected during the RD will be used to refine According to EPA's Cost Guidance, a sensitivity analysis the cost estimates. should be considered for factors with a relatively high degree of uncertainty that with a small change in value could significantly affect the overall cost of the alternative, such as estimated volumes of contaminated media. [Cost Guidance at 5-15 — 5-16.] The cost of in-situ stabilization in saturated soil increases exponentially with depth. In order to fairly compare this alternative relative to the other groundwater alternatives as required by the NCP, this range in potential cost should be understood, especially because the FS does not provide sufficient data to support the approximated depth of 45 feet Page 23 of 26 Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response bgs. [See Cost Guidance at 2-5 - 2-6 (noting the importance of relative accuracy for comparative cost estimates so decisions between altematives can be appropriately considered).] Based on this potential for increased costs, it becomes imperative that the primary balancing criteria are evaluated equitably to ensure the fair consideration of implementability and cost effectiveness. EI-7 3.0 Treatability Studies and End User Considerations As stated above, ISS and Pump-and-Treat are both well Treatability investigations (i.e., bench scale, pilot scale) to established and commonly used remedial technologies. The level demonstrate the effectiveness of the selected groundwater of uncertainty associated with the implementation of these remedies with respect to 1) achieving drinking water ARARs technologies are minimal. To mitigate these uncertainties, below laboratory PQLs, and 2) the permanence and cost- additional data will be collected during the RD. In addition, effectiveness of a pun^ and treat remedy 150 feet from the St. groundwater modeling and groundwater pumping test (pilot test) John's River must be conducted. The presence of RI data gaps will be performed during the RD. Please note treatability and/or (analytical data at depth) and concems regarding the balanced pilot studies for ISS and Punq)-and-Treat are commonly evaluation of remedial altematives in accordance with 40 CFR conducted prior to or subsequent to remedy selection. Issuance of 300.430(e)(7) and (9) dictate that such testing be done prior to the ROD will not have any adverse impacts on the final remedy selection in the ROD. [EPA, implementation of the freatability and/or pilot testing. CERCLA/Superfund Orientation Manual, p. VII-7, EPA/542/R-92/005, October 1992 ("Treatability Studies should be performed as soon as it becomes apparent that the available information is insufficient to support the selection of a potential treatment technology").] Not only are the studies necessary for a meaningful evaluation of altematives, but it is also consistent with OSWER guidance recommending a phased approach to groundwater responses. [See, e.g., EPA Final Guidance, Presumptive Response Strategy and Ex-Situ Treatment Technologies for Contaminated Groundwater at CERCLA Sites at 5-6, OSWER Directive 9283.1-12, EPA 540/R-96/023, October 1996.] Conducting groundwater Page 24 of 26 Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response treatability studies prior to issuance of the ROD is warranted given the projected capital investment in full scale implementation (i.e., -$39M for GW-7 and GW-8). The information obtained from pilot testing will confirm the appropriateness of the selected remedies, demonstrate that non-selected altematives should be reevaluated, or support a potential technical inq)racticability (TI) groundwater waiver. Any of these results would be worth the time and cost to conduct the treatability study now to avoid the administrative burden of a future ROD amendment and the imnecessary expenditure of cost. While additional studies to support the groundwater remedy design will also be implemented following the ROD; treatability studies should be conducted prior to ROD issuance to enable a relative comparison of altematives and to help avoid the administrative burden associated with a ROD amendment should the results lead EPA to change course on the remedy. EI-8 4.0 Summary of Recommended Alternatives to EPA's The EPA believes that when combined, the selected altematives Preferred Remedy (SS-2; SD-5; GW-7; and GW-8) will provide the optimal In summary, and as articulated above, a more reasonable protectiveness for human health and the environment and cleanup plan that would, nevertheless, be protective of human achievement of the RAOs identified for the site in a cost effective health and the environment would be to replace SS-2 with SS- manner. The Altemative Plan proposed by Emhart Industries 7, thereby rendering GW-7 unnecessary, and replacing SD-5 includes SS-7, SD-4, and GW-2. When combined, these with SD-4, rendering GW-8 unnecessary, assuming SD-4 was altematives would result in a remedy less expensive than the implemented as quickly as anticipated. We have prepared the Selected Altematives. However, the RAOs identified for the site following summary of the recommended alternative will not be met under the in^lementation of the Altemative Plan combination for the cleanup plan, which would achieve a proposed by Emhart Industries. Therefore, consideration of the Page 25 of 26 Kerr Mc-Gee Chemical Corporation Superfund Site Jacksonville, Florida Responses to Public Comments Identifier Comment Summary Response better balance of the nine criteria for evaluation than the Alternative Plan as the Selected Remedy to address die site current combination of preferred alternatives: contamination is not warranted. PROPOSED PLAN ALTERNATIVE PLAN SS-2 $14,319,400 SS-7 $19,923,400 SD-5 $14,899,300 SD-4 $7,534,700 GW-7 $23,058,800 GW-2 $2,175,400 GW-8 $16,416,300 Total Cost $68,693,800 Total Cost $29,633,500 Difference in Total Cost = $39,060,300 Eastside Environmental, Letter, November 11, 2016 EEC-1 The Eastside Environmental Council appreciates the The EPA appreciates Eastside Environmental Council's support opportunity to comment on the September 28'^ 2016, proposed of the Proposed Cleanup Plan. Following the completion of the Kerr McGee site cleanup. ROD, EPA and Multistate Trust in consultation and coordination Thank you for proposing long overdue Kerr McGee site with the community will develop a training and placement cleanup plan that will help protect our community from program to promote local hiring while conducting site cleanup exposure of harmful and toxic pollutants. The Eastside activities. Environmental Council and community residents have waited nearly two decades to see the Kerr McGee legendary site cleaned-up. We are very pleased that EPA has made this site a priority. We also look forward to reviewing your plans to address contamination in Deer Creek. The Eastside Environmental Council is interested in a job creation program relating to Kerr-McGee site cleanup. The Eastside Environmental Council would like to work with EPA, FDEP and the Multistate Trust on setting up a program that can help train and employ local Eastside residents and college students to work on the cleanup of the Kerr McGee site. Page 26 of 26 KERR-McGEE CHEMIC^K CORPORATIONSUPERFUND SITE PITWI — 7J "-0.1 I 3'S>i:3(soNvniE Name ^ ^ C-L /\ly •f-d tJ ^ .jZ- 3£' Address/?^ Bd'^ Z, ^oinLitr/KM* CxN^AciKitNi/iLLC State Zip ? 1000 $6.47 30303 R2305M146172-08 "ji0Z •rr'^' H t-R J cr Robenson Joseph, Remedial Project Manager -0 3- U.S. EPA, Region 4 oi m Superfund Restoration and Sustainability Branch o Superfiind Division • • 61 Forsyth St., SW Q Atlanta, GA 30303 • m r- i-R m i-q • .—w=i ea j-urs"3 .]id.jiiliiiinii,ii|tiji|i|iiii.i>ti>llliiin|.iiidipiii)l^^ USE THIS SPACE TO WRITE YOUR COMMENTS Your input on the Proposed Plan for the Kerr-McGee Chemical Corporation Superfund Site is important in helping EPA to select a remedy for the Site. Use the space below to write your comments, then fold and maiL A response to your comment will be included in the Responsiveness Summary. /' Clayton Smith PO Box 3812 Jacksonville. FL 32206 Telephone: (904)354-3339 itifoa.icrofast.cniii Fax:^ 8759888716 9/18/2016 Robenson Joseph. Remedial Project Manager U.S. EPA. Region 4 Superfund Restoration and Suslainability Branch Superfijnd Division 61 Forsyth St.. SW Atlanta. GA 30303 Re: Comments on recommendations for remediating the Kerr-McGee Chemical Corporation Superfijnd Site Attn: EPA Dear Mr. Joseph. As we have outlined before, and such should be in your records of past meetings, which we have attended, we are not opposed to your remediation plans and any that you might choose is agreeable to us. However it appears that in every instance as regards soil said soil must be disturbed in some way in order to effect proper cleanup of the site including specifically hot spots indicated in your report. Said "hot spots" are shockingly close to our facility located between and S"' Street and bordered by Wesicott and Danese. In addition to the hazards that first came to light some years ago our family has suffered mightily with disease which you have a copy of, but in the meantime (b) (6) (b) (6) . With no history anywhere in our families of (b) (6) we search for answers and it is entirely possible that the culprit lies just across the street from us. In any event we've had enough and will resist by all means legally to impede and prevent even one spade of contaminated soil or the possibility thereof to be addressed until we (my firm and family) are relocated and compensation provided. We inform you once again of our intentions and would look most unkindly if you were to attempt to proceed without alerting us in time to file legal action. Warrqest and Highest l^ards, Clayton Smith Josegh^^obenson^ From: William C. Eaton I had a quick question about the site that I dichi't want to ask at the meeting to avoid panic/misconceptions with the attendees. Around the herbicide "hot spots" what is the high and average 2378 TCDD concentrations? Kind regar(^ Bill Eaton Director of US Operations Recuperesol Inc. www.recuperesol.com Sent from my Verizon, Samsung Galaxy smartphone Josegh^^obenson^ From: Adrian Brown (b) (6) Sent: Thursday, September 29, 2016 1:08 PM To: Joseph, Robenson Cc: Spencer, LTonya; cb.g-etg.com Subject: Comments for Kerr-McGee Jacksonville Superfund Site Dear Mr. Robenson Joseph: Please find written comments below as a follow-up to the Public Meeting yesterday for the Proposed Cleanup Plan for the Kerr-McGee Chemical Corporation (Kerr-McGee) Jacksonville Superfiind Site: 1) Please provide a timeline for the collection and evaluation of the fish tissue samples from the adjoining St. Johns River. The following was noted on page 10 of the Proposed Plan: "Fish tissue sampling will be conducted to verify the risk levels. A fish advisory will be put in place if the results of the fish tissue sampling show that the risk levels are above the EPA acceptable risk range of 1x10-6 to 1x10-4." 2) It did not appear that the Site was evaluated for liquefaction potential. It is crucial for this analysis to be conducted. The Ohio EPA has very good guidance at: http://epa.ohio.gov/portals/34/document/guidance/gd 660 chapter 5.pdf 3) Duval County, FL has had sinkhole occurrences and it was not clear if this was taken into account. Please see sinkhole details in Duval County, FL at: http://fcit.usf.edu/florida/maps/pages/l 1100/fl 1124/fl 1124.htm 4) It is unclear how climate change impacts and rising surface water levels will impact the Proposed Plan, in particular, the placement of the pump and treat system(s). 5) The placement of the low permeability liner will increase stormwater flow, and based on feedback received during the Public Meeting, it was my understanding that stormwater collected in the proposed detention basin will be subject to sampling with possible discharge to JEA for treatment. Will first flush be conducted? Thank you for the opportunity to submit comments on the Proposed Plan. Regards, Adrian E. Brown, P.E. P.S: My Linkedin professional profile can be accessed at: https://www.linkedin.com/in/adrian-e-brown-p-e- b8388220 JACKSONVILLE PORT AUTHORITY BLOUNT ISLAND MARINE TERMINAL • DAMES POINT MARINE TERMINAL • TALLEYRAND MARINE TERMINAL • JAXPORT CRUISE TERMINAL October 12, 2016 Via FedEx and Electronic Mail Robenson Joseph EPA Remedial Project Manager Atlanta Federal Center 61 Forsyth St. S.W. Atlanta, GA 30303 [email protected] Re: Kerr-McGee Chemical Corp. (Kerr-McGee) Jacksonville Superfund Site, Jacksonville, FL, Proposed Plan dated September 20,2016 Dear Mr. Joseph, The Jacksonville Port Authority (Jaxport) provides these comments to the Environmental Protection Agency's (EPA) Proposed Plan for the above referenced Superfund site (the "Site"). The Jacksonville Port Authority is a body politic and corporate created and existing under Chapter 2004-465 of the laws of Florida. Jaxport owns property immediately north of the Site (Jaxport Property) which is contaminated as a result of the activities on the Site. The Jaxport Property is currently leased to a long-valued tenant, JM Family Enterprises/Southeast Toyota (JM Family). JM Family imports and processes new Toyota vehicles and is a well-recognized economic engine in the Jacksonville community that provides numerous job opportunities to area residents. Jaxport appreciates its long-standing working relationship with the EPA related to the Site and numerous other interactions related to Jaxport's operations. Jaxport values that relationship and appreciates the EPA for accommodating several of Jaxport's preliminary requests relating to this Site. In addition, Jacksonville is fortunate that Greenfield Environmental Multistate Trust, LLC (the "Trust") is a financially viable trust created to fund all of the environmental remediation relating to contamination arising from the Site and other locations similarly situated. The Proposed Plan adequately addresses many contamination areas. EPA relies heavily on "natural attenuation" and "institutional controls" as the preferred remedial alternative for the soil and groundwater contamination on the Jaxport Site. Therefore, Jaxport has the following comments to the Proposed Plan: 1. The Proposed Plan identifies soil contamination exceeding commercial/ industrial as well as leachability cleanup target levels and proposes to allow such contaminated soil to remain under a cap on Jaxport Property. In addition, the Proposed Plan allows groundwater contamination in excess of both EPA's maximum contaminant levels and the 4839-0068-0761.4 P.O. Box 3005 • 283 I TALLEYRAND AVENUE • JACKSONVILLE, FL 32206-0005 October 12, 2016 Page 2 Florida Department of Environmental Protection's (FDEP) groundwater cleanup target levels to remain on Jaxport property. Jaxport does not oppose the capping of contaminated soil or natural attenuation for groundwater as the main elements of the preferred remedial altemative. Moreover, Jaxport appreciates that EPA and the Trust do not want to incur the significant business disruption expenses and severe economic duress that would be caused by intrusive soil and groimdwater remediation at the Jaxport Property and the operations of JM Family. This accommodation to Jaxport and its tenant, JM Family, should not, however, relieve the Trust's responsibility to achieve the EPA's Remedial Action Objectives (RAOs) for impacted media on the Jaxport Property. 2. Jaxport requests that language be incorporated into decision documents such as this Proposed Plan and the forthcoming Record of Decision requiring the Trust to establish an escrow or reserve to remediate the soil and groundwater using the least intrusive remedial option to meet RAOs in Jaxport Property. That escrow or reserve should not be less than $5,759,665. (See attachment A). We note that one of the RAOs is to "Restore impacted groundwater to levels that are protective for a G-II aquifer as a source of drinking water within a reasonable timeframe". In addition, remediation goals for some pesticides in groundwater located in Jaxport's Property are three orders of magnitude lower than reported concentrations. Therefore, achieving the RAO for groimdwater via natural attenuation may take decades or substantially longer than what may be considered "reasonable". Based on this, and the undefined timeframe considered to be "reasonable", the EPA may later determine that active remediation for both affected media on the Jaxport Property is necessary to comply with one of the main objectives of the Comprehensive Environmental Response, Compensation & Liability Act (CERCLA). That determination may be triggered by many events, including: (i) the decision by JM Family to relocate to another Jaxport location or some other event making the Jaxport Property available for more aggressive remediation, (ii) a Post Five-Year CERCLA Review determines that natural attenuation is not remediating the Jaxport Property in a "reasonable timeframe" or (iii) construction on the Jaxport Property that requires contaminated soil removal to avoid harm to human health or the environment. This escrow or reservation of funds would ensure that the financial resources of the Trust are available over an extended timeframe (beyond the 30-year Superfund site average lifecycle) to actively remediate the soil and groundwater contamination that exists at the Jaxport Property if determined to be necessary by EPA. 3. The preferred remedial altemative in the Proposed Plan calls for the use of Institutional Controls to be utilized that would restrict future activities on the Jaxport Property. As Jaxport has previously stated to EPA, Jaxport's business and long-range Strategic Master Plan contemplates utilizing the Jaxport Property in perpetuity. Therefore, EPA's preferred remedial altemative requiring Institutional Controls such as Restrictive Covenants on the Jaxport Property could unnecessarily limit the use of the Jaxport Property. Jaxport requests that EPA seek Jaxport's approval for any proposed Institutional Controls over Jaxport Property. 4. The preferred remedial altemative for contaminated media on the Jaxport Property includes maintenance of the existing parking lot (cap). Routine maintenance of the cap by Jaxport may include occasional removal and replacement of portions of the cap due to normal 4839-0068-0761.4 October 12,2016 Page 3 wear and tear. EPA and FDEP should discuss which routine cap maintenance actions by Jaxport would be permissible, while meeting the preferred remedy's threshold and balancing criteria. Jaxport also requests that EPA and FDEP identify which specific property cap maintenance costs (beyond those costs routinely associated with a parking lot's normal wear and tear) would be borne by the Trust. Finally, should the EPA and/or FDEP determine that the cap, or portions thereof, require supplemental additions and/or modifications to meet RAOs, Jaxport must be given sufficient advance notice so as to minimize the impact to the business operations of Jaxport's tenants. Jaxport appreciates the opportunity to provide EPA with these comments. Jaxport reserves the right to provide additional comment if necessary. As always, if you would like to discuss this matter further, please feel free to contact me. Sincerely, David Stubbs For David Kaufinan Sr. Director, Planning and Commercial Development 4839-0068-0761,4 Attachment A JAXPORT PROPERTY GROUNDWATER REMEDIATION Assumptions Use least intrusive technology: insitu biodegradation Approximately 200,000 sq. ft area of shallow aquifer contamination Use 50 ft radius of influence = 4,000 injection points Use a rate of 10 injection points a day at 7 days a week Approximately 5,000 sq. ft area of intermediate aquifer contamination Based on approved FS technology cost analysis Shallow Aquifer Remediation using Zero Valent Iron Unit of Material Equipment Description Quantity Measure Unit Cost Unit Cost Extended Cost 2,000 gallon tank EA 1,500 1,500 Direct Push Rig (includes Labor, Decon, Inj Tooling) 400 DAY 1,300 520000 Rig Mob 1 DAY 1,300 1300 Rig Demob 1 DAY 1,300 1300 Underground utility survey prior to injection. Use GPS radar 1 Event 10,000 10000 Pumping System 1 EA 2,500 2500 Project Engineer 400 HR 120 48000 Field Technician 3,000 60 180000 Injection point patch materials EA 10,000 10000 Emulsified Oil with Micron- Scale Zero Valent Iron 570,000 LB 1140000 Total Element Cost Shallow Aquifer 1,914,600 Intermediate Aquifer Remediation Using Zero Valent Iron Unit of Material Equipment Description Quantity Measure Unit Cost Unit Cost Extended Cost 2,000 gallon tank EA 1,500 0 1,500 Direct Push Rig (includes Labor, Decon, Inj Tooling) 20 DAY 1,300 26000 Rig Mob 1 DAY 1,300 1300 Rig Demob 1 DAY 1,300 1300 Pumping System 1 EA 2,500 2500 Project Engineer 100 HR 120 12000 Field Technician 400 HR 60 24000 Injection point cement patch materials 1 EA 5,000 5000 Emulsified Oil with Micron- Scale Zero Valent Iron 75,000 LB 150000 Total Element Cost Intermediate Aquifer 223,600 Total 1st Year Technology Cost 2,138,200 Groundwater Monitoring Well Replacement (10 wells) 40000 Total 1st Year Technology Plus Well Replacement 2,178,200 20% Contingency 217820 Project Management, Design, and Markup (15%) 326730 Total Design and Capital Cost 2,722,750 Following EPA's Guidance on Feasibility Studies under CERCLA (1985) Identify 08tM Costs Operation and Maintenance Costs Assumptions 1st year semiannual sampling. Years 2-5 annual. Years 5-30 biannual Total of 10 wells EPA Five Year CERCLA Reviews cost to be borne by Trust 15% Project Management and Profit Discount rate: 4% Item Description Quantity Unit Cost Extended Cost Five Year CERCLA Reviews Report Preparation and Submittal 50,000 300000 MNA Implementation Semiannual Sampling and Reporting @ end of Yr 1 1 75,000 75000 Annual Sampling and Reporting @ end of Yrs 2-5 4 40,000 160000 Biannual Sampling and Reporting Yrs. 7-30 12 30,000 360000 Subtotal 660000 Management Fee and Profit (15% of subtotal) 100,000 Total O&M Cost 760000 Total Present Worth Cost Total Design and Capital Cost 2,722,750 Present Worth of 5 Year Reviews 262,000 Present worth of Annual Sampling Years 2-5 145,000 Present worth of Annual Sampling Years 7-30 281,000 Present Worth of Management Fee and Profit 35,000 Total Present Worth In 2016 n $USD 3,445,750 In accordance with the U.S. EPA guidance on Feasibility Studies, the above total present worth cost is provided with an accurancy of-30 to +50 percent. No sensitivity analysis has been performed. Ref. "Guidance on Feasibility Studes Under CERCLA" US EPA/540/G85/003. June 1985 JAXPORT PROPERTY SOIL EXCAVATION Assumptions Excavate Soil exceeding leachability criteria (Fig. 1-12 of Feasibility Study) Approximately 75,000 sq. ft area Use 6 feet as depth of vadose zone. Assume buidlings demolition and no replacement No haz waste Based on approved FS costs Does not include buildings replacement Soil Excavation Via Conventional Means Unit of Material Equipment Description Quantity Measure Unit Cost Unit Cost Extended C( Buildings demolition and site prep inci lifting slabs and utility survey and disconnects/rerouting 1 EA 200,000 200000 Building debris disposal 1 EA 100,000 100000 Excavate and load, bank measure medium material. 3.5 yd3 bucket excavator 16,000 yd 3 2 32,000 Backfill for large excavation includes compaction 21000 yd 3 5 105000 Soil sampling pre-disposal 500 EA 20 10000 TCLP samples 200 EA 200 40000 Transport soil to non-haz landfill 16,000 yd3 4 64000 Landfill tipping fee 24,000 tons 45 1080000 Field Technician 250 hr 60 15000 OSHA officer 250 hr 75 18750 Project Engineer 100 hr 120 12000 Subtotal 1,676,750 20% contingency 335,350 Subtotal plus contingency 2,012,100 Project Management, Design, and Markup (15%) 301,815 Total Excavation Soil Exceeding Leachability 2,313,915 In accordance with the U.S. EPA guidance on Feasibility Studies, the above total cost is provided with an accurancy of -30 to +50 percent. No sensitivity analysis has been performed. Ref. "Guidance on Feasibility Studes Under CERCLA" US EPA/540/G85/003. June 1985 JAXPORT JACKSONVILLE PORT AUTHORITY BLOUNT ISLAND MARINE TERMINAL • DAMES POINT MARINE TERMINAL • TALLEYRAND MARINE TERMINAL • JAXPORT CRUISE TERMINAL November 1,2016 Mr. Robenson Joseph EPA Remedial Project Manager Atlanta Federal Center 61 Forsyth Street S.W. Atlanta, GA 30303 [email protected] Re; Kerr-McGee Chemical Corp. (Kerr-McGee) Jacksonville Superfund Site, Jacksonville, Florida Dear Mr. Joseph, This correspondence is to supplement the Jacksonville Port Authority's (JAXPORT) comments to the Proposed Plan dated October 12, 2016 for the above referenced Superfund site. As you know, JAXPORT requested in its comments to the Proposed Plan that EPA incorporate into its Record of Decision and other decision documents a requirement that funds from the Greenfield Environmental Multistate Trust, LLC (the "Trust") be retained through a reservation or escrow in a sum sufficient to meet Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) media- specific Remedial Action Objectives (RAO) on the JAXPORT Property. The Environmental Response Trust Agreement dated February 14, 2011 (Trust Agreement), to which the United States, the State of Florida and the Trust are parties, provides explicit authority to implement JAXPORT's request. Section 2.1.6 of the Trust Agreement gives the authority to divide the multistate trust account into "such number of trust subaccounts dedicated for specific uses as may be deemed necessary...." EPA's decision to require in the Record of Decision that the Trust retain in a separate escrow or trust subaccount funds necessary to meet CERCLA obligations (and any other future obligations such as maintaining or improving the contamination cap on the JAXPORT Property or additional remediation) is, therefore, permissible under the Trust Agreement. JAXPORT looks forward to EPA's response to JAXPORT's comments. As always we are able to meet with EPA regarding this matter. Very truly yours. David Kaufman Sr. Director, Planning & Commercial Development P.O. Box 3005 • 283 1 TALLEYRAND AVENUE • JACKSONVILLE, FL 32206-0005 Janet Simoneaux JM FAMILY Envhvwnentnl, Henlth nnd Safety Director TNTERPRISESJNC. 201 ]im Moran Blvd. Deerfield Beach, Florida 33442 (954) 420-4731 . Fax (954) 596-7246 October 12, 2016 Ms. Carol Monell Branch Chief Superfund Restoration Branch US EPA Region 4 61 Forsyth Street N.W. Atlanta. GA 30303 Re: EPA ID FLD0390491Z01 Comments to Proposed Cleanup Plan Dated September 12, 2016 for Kerr-McGee Chemical Corporation Superfund Site 1611 Talleyrand Avenue Jacksonville, Florida 32206 Dear Ms. Monell: JM Family Enterprises, Inc. (JMFE) appreciates the opportunity to provide comments on the above-referenced Proposed Cleanup Plan (PCP) for the Kerr-McGee Superfund Site (the Site) in Jacksonville, Florida. As you will recall, JMFE is a diversified automotive company whose subsidiaries include Southeast Toyota Distributors (SET), which is the world's largest independent distributor of Toyota and Scion vehicles. For nearly 50 years, SET has operated a vehicle processing facility (the Facility) on the Jacksonville Port Authority (JaxPort) property located immediately north of the Site (the Leasehold). Here, hundreds of thousands of new vehicles are imported and processed for distribution across the southeast region of the United States. JMFE appreciated the opportunities to meet at the Facility with the United States Environmental Protection Agency, Region IV (EPA), the Florida Department of Environmental Protection (FDEP), and the Trust. JMFE believes that a viable remedy should not only be protective of human health and the environment, it should also address potential impacts to all affected parties. JMFE understands the importance of this project to EPA, FDEP, and the Trust, and we truly look forward to the initiation of cleanup activities at the Site. JMFE, including its team of knowledgeable staff and consultants, stands ready to assist EPA, FDEP, and the Trust, and is ina unique position to do so, given our close proximity to, and in-depth knowledge of, the Site. As an adjacent business owner, affected party, significant job provider, and member of the Jacksonville community, the following comments are submitted in support of your ongoing efforts to identify a viable remedial strategy for the Site. JMFE is pleased to inform EPA that it approves of and supports the PCP as is and urges EPA to finalize it without further modifications, as the PCP is a viable remedy for the Site that considers the interests and concerns of all stakeholders and affected parties. JMFE's concerns identified in its March 14, 2016 comments related to the FS have been addressed by the PCP. For your convenience, a copy of those comments to the FS is attached. Assuming there are no modifications to the PCP as presented, and it is finalized as is, JMFE supports it in its current form. However, should EPA modify the current PCP in a manner which would adversely impact JMFE's operations and associates at the facility, as well as other businesses, by reconsidering proposed remedial activities at the Site found in the FS, JMFE reiterates its objections to any such modifications to the PCP. JMFE would like to express its sincere appreciation to EPA, FDEP, and the Trust for its careful consideration of comments and concerns of all stakeholders and affected parties and for its accessibility throughout the process which resulted in the PCP. JMFE appreciates the opportunity to provide these comments to EPA, FDEP, and the Trust. We look fonward to participating in ongoing discussions to approve and implement the PCP for the Site. Sincerely, /rh Janet Simorfgaux Environmental Health and Safety Director JM FAMILY ENTERPRISES, INC. Hard Copy/Email: Carol Monell Copy via email: Caren J. Snead Williams Ralph A. DeMeo Joseph Robenson Peter Cornais Kelsey Helton Rick Rachal Robert Wojcik Cynthia Brooks Attachments: Comments to Revised Draft Feasibility Study March 14, 2016 M FAMILY ENTERPRISES. INC 100Jim Moicin Boulevard Deerfield Beaciv Florida 33442 (954) 429-2000 March 14, 2016 Ms. Carol Monell Branch Chief Superfund Restoration Branch US EPA Region 4 61 Forsyth Street N.W. Atlanta, GA 30303 Re: EPA ID FLD0390491Z01 Comments to Revised Draft Feasibility Study Prepared by AECOM for Greenfield Environmental and Multistate Trust, LLC, Dated February 2016 Kerr-McGee Chemical Corporation Supetfund Site 1611 Taiieyrand Avenue Jacksonville, Florida 32206 Dear Ms. Monell: JM Family Enterprises, Inc. (JMFE) appreciates the opportunity to provide comments on the above-referenced draft feasibility study (FS) for the Kerr-McGee Superfund Site (the Site) in Jacksonville, Florida. JMFE is a diversified automotive company whose subsidiaries include Southeast Toyota Distributors (SET), which is the world's largest independent distributor of Toyota and Scion vehicles. For nearly 50 years, SET has operated a vehicle processing facility (the Facility) on the Jacksonville Port Authority (JaxPort) property located immediately north of the Site (the Leasehold). Here, hundreds of thousands of new vehicles are imported and processed for distribution across the southeast region of the United States. By way of background, the Facility Is a major employer with substantial economic impact to Jacksonville and the state of Florida. The Facility is composed of 6 buildings with a total 218,000 square feet on 75 acres at JaxPort. SET employs 197 full time associates, as well as the equivalent of 40 full time longshoremen. In addition, there is an average of 83 vessels and 901 rail cars that arrive annually at the Facility. In 2015, the Facility processed 77,128 Toyotas, 60,891 Lexus, and exported 14,035 vehicles. During the same period, auto carriers transported 138,120 vehicles in 15,335 'W'iicw fAi' I I III -I truckloads, 2,200 vehicles were transported in 183 rail cars, and 11,744 vehicles were transported by vessel for export. Any interruption to SET's operations at JaxPort could without question cause a ripple effect of costs for SET and other businesses that serve the Facility or rely upon the vehicles being processed at the Facility for timely delivery and sale. This could mean layoffs for hundreds of SET associates and others. Such damages could far exceed millions of dollars of costs and lost revenue which JMFE would expect to be borne by the Greenfield Environmental Multistate Trust, LLC (the Trust), the current owner of the Site. To JMFE, the Facility is more than just a critical component to the success of our business. Its operations provide thousands of direct and indirect jobs for the citizens of Jacksonville and the surrounding communities. To give some perspective, in 2015 SET processed 492,305 vehicles, approximately 28% of which arrived by ship at the Facility. We bring ail of this to your attention because the draft FS proposes a comprehensive remedial strategy that poses significant short- and long-term risks to JMFE/SET, not only in terms of disruptions to our business, but it also raises very serious concerns related to the health and safety of our associates, and the potential for damage to the Facility. Therefore, even though we are not the land owner, due to the nature of the proposed remedial activities, JMFE and SET are affected parties. JMFE appreciated our recent meeting on March 2, 2016 at the Facility with the United States Environmental Protection Agency, Region IV (EPA), the Florida Department of Environmental Protection (FDEP), and the Trust. JMFE believes that a viable remedy should not only be protective of human health and the environment. It should also address potential impacts to all affected parties. JMFE understands the importance of this project to EPA, FDEP, and the Trust, and we truly look forward to the initiation of cleanup activities at the Site. JMFE, including its team of knowledgeable staff and consultants, stands ready to assist EPA, FDEP, and the Trust, and is in a unique position to do so, given our close proximity to. and knowledge of the Site. As an adjacent business owner, affected party, significant job provider, and member of the Jacksonville community, the following comments are submitted in support of your ongoing efforts to identify a viable remedial strategy for the Site. A photographic log (attached) is presented to show the close proximity of the Leasehold structures to the property line and on site structures and operations conducted at the Leasehold. Comments and Concerns Related to Construction of the Proposed Slurry Wall The draft FS proposes construction of a soil-bentonite slurry wall to a total depth of 50 feet below ground surface (bgs) immediately south of the Leasehold, to be located just a few feet from SET's accessory installation building (the "Box"), cafeteria, and areas where SET fuels and processes all its vehicles, and within close proximity to our associates. The proposed slurry wall, during and after construction, will substantially interfere with our extensive operations, as the northern segment of the slurry wall is within a few feet of the property line where the several of the Facility's buildings are situated. As shown on Figure 1 (attached), the Box, the cafeteria, a sanitary sewer line, and other structures, are located in this area. The remedial strategy as proposed in the FS will result in the following interferences: • The construction of the slurry wall likely will require the removal of the fence between the Site and the Leasehold, which presents serious health, safety, and security risks. • The construction of the slurry wall would affect an underground sanitary sewer conveyance near the Leasehold property boundary that carries all of SET'S wastewater, which could cut off wastewater service, thereby shutting down our operations. • The construction of the slurry wall will impact the health and safety of SET'S associates as a result of activities on the Site close to and likely on the Leasehold, including generating dust, vapors, and other contamination that might cross the property boundary into the breathing zone of those working nearby. In addition, due to the close proximity of Facility's to the proposed work area, there could be significant impacts to the health of our employees regarding noise and vibration associated with the use of heavy equipment. • The placement of the slurry wall anywhere near the Leasehold property boundary could have significant adverse effects on the Box, cafeteria, and buried infrastructure as a result of induced ground movements. These ground movements could cause significant damage to structure foundations as well as building envelopes. This in turn could make the buildings more susceptible to secondary damages such as water infiltration and damaging Insulation materials. A technical memorandum, prepared by Colder Associates, Inc., presenting the results of an assessment of geotechnical issues related to installation of the slurry wail as proposed in the FS, is provided as an attachment to this correspondence. Additionally, if the slurry wall construction requires SET'S south fence to be removed, it would have several impacts on security including the foilowing: • The Southeast Toyota Port Facility Security Plan was made per the regulations in 33 CFR and approved by the United States Coast Guard ("USCG"). Up to 16 cameras would lose power and fiber connectivity. • Prior to fence demolition, the power circuit on the fence would have to be turned off and disconnected, [please note: the power circuit is mounted on the fence itself because the Leasehold has contaminated soil] • The fiber and power runs would have to be disconnected at each camera pole. • Following fence re-installation, new fiber and power runs to each camera would be required. • A breach in the fence line would require notification to the USCG of the impairment, approximate time frame, and a proposed solution. • A security officer would be required to monitor the breach 24 hours a day, 7 days a week at a cost of approximately $2,500 per week. • USCG has the discretion to require additional security measures. Based on all of the above concerns, JMFE requests that EPA, FDEP, and the Trust, continue working to identify a more suitable remedial alternative along the boundary between the Leasehold and the Site that does not pose serious risks to JMFE and addresses our above-stated concerns. JMFE would also request that a detailed health and safety and industrial hygiene risk assessment be conducted of the proposed work that addresses the above noted safety and potential exposure concerns for SET associates. Comments and Concerns Related to Implementation of the Proposed In-Situ Groundwater Treatment Strategy In the Offslte Area The draft FS proposes extensive in-situ groundwater treatment where impacts to groundwater exceed the groundwater cleanup target levels (GOTLs) on the Leasehold near the Box, cafeteria, and in areas where SET fuels and washes all its vehicles. The footprint of the proposed treatment area is shown on Figure 1 (attached). As shown, the footprint of the treatment area encompasses a critical area of our Leasehold. Based on review of information in the FS, the proposed groundwater remedy includes injection of nearly 650,000 pounds of zero vaient iron (ZVI) into the target treatment area, which would require the remedial contractor to work in this critical area for nearly two years, Based on the above, it Is very clear to JMFE that the proposed in-sItu groundwater treatment strategy will substantially interfere with SET's extensive operations, as the proposed Injection operations will be in direct conflict with our daily business activities. This portion of our Leasehold is where 90% of SET's operations occur. Therefore, alternative remedial strategies to address offsite groundwater impacts in this area should be considered. Further, JMFE recommends removing from further consideration any alternative that would require off-site access to the Leasehold for implementation, other than periodic monitoring. It is understood that monitored natural attenuation (MNA) of impacted groundwater in the off-site area is still under consideration, and JMFE/SET would be willing to work with EPA, FDEP, and the Trust to allow periodic Facility access in support of this or an equivalent remedial strategy that does not disrupt SET's operations. Comments and Concerns Related to Implementation of the Proposed Sediment Remediation Strategy The draft FS identifies dredging of sediments and/or construction of a major bulkhead (including sediment encapsulation) along the St. John's River on the east side of the Site immediately adjacent to the area on the Leasehold where ships unload vehicles. The proposed dredging on the St. John's River adjacent to the Facility's dock, where thousands of cars are offloaded per month, would have significant adverse impacts on Facility operations. Under this scenario, dredging impacts to SET's operations should be considered and quantified. One of the identified remedies, bulkhead construction and sediment encapsulation, should be considered and quantified as it may have less impacts on JMFE's long term operations. For the purpose of providing perspective on these concerns, approximately 83 ships per year arrive at the Facility. This amounts to one ship every five days on average that may remain moored at our dock for 24 hours or more during our normal unloading activities. It is anticipated that during sediment remediation activities, the dredging/bulkhead contractor will deploy various types of marine equipment and vessels, including barges, boats, scows, turbidity controls, etc., which will be working in the St. John's River immediately adjacent, to SET's dock. It is our concern that these activities could obstruct or interfere with navigation, docking, and/or subsequent offloading of vehicles at the Facility. To further illustrate this concern, the image below is an aerial overview of SET's dock with a vessel present. As shown on Figure 2 (attached), when present, a typical vessel received at the Facility's dock occupies the entire berth, hence there is no room to accommodate any other vessels or equipment in this area without obstructing navigation and/or potentially delaying receipt of ships, and hence vehicles, at the Facility. Additionally, it is understood that temporary access through the Leasehold may need to be established, which would further disrupt facility operations and security. Based on the above information, JMFE requests that EPA, FDEP, and the Trust, continue working to identify a better remedial alternative to address sediment that does not pose a serious disruption risk to our business and addresses our concerns. Closing As you can see from the above, the Trust's proposed remedial activities at the Site pose a significant threat to JMFE's operations and associates at the Facility, as well as to other businesses. Furthermore, it Is our understanding that the EPA had previously "fast tracked" approval of the FS. However, this is to confirm that at JMFE's request, EPA has agreed to accept comments from JMFE, delay finalization of the FS until it had the opportunity to consider JMFE's comments, and to either meet with or confer by telephone with JMFE prior to deciding what changes should be made to the FS by AECOM for the Trust. JMFE looks forward to this meeting or conference call with EPA in the near future. Please direct all future communication to JMFE's outside environmental counsel Ralph A. DeMeo at Hopping Green & Sams, P.A., PO Box 6626, Tallahassee, Florida 32314. JMFE appreciates the opportunity to provide these comments to EPA, FDEP, and the Trust. We look forward to participating in ongoing discussions to develop a viable remedy for the Site that considers the interests and concerns of all stakeholders and affected parties. Sincerely, /rr> anet Simoneaux Environmental, Health and Safety Director JM FAMILY ENTERPRISES. INC. Hard Copy/Email: Carol Monell Copy Via Email: Caren J. Snead Williams Kevin Beswick Robenson Joseph Peter Cornais Kelsey Helton Rick Rachal Robert Wojcik Ralph A. DeMeo Cynthia Brooks Attachments: Photograph Log Figure 1 - Site Layout Technical Memorandum for Geotechnical Considerations Figure 2 - Vessel Moored at SET's Receiving Dock 0) £ •o c n D) c i2 '5 CD o (A in O u £ §-2 ^ 0) (D "3£ " o in Oo 5 > IN £a E oO) o £ 0. a> u c (0 "S "o to Q) p (0 £ o I- o 4U 2fi (0 m []} o c CO (0 0) u I x>0) >b- 0) o u 0) c "O s TJ C (0 o o T3 (b) (6) C oR c 0) £ » o. £ (0 0) fc- £ o o £ D. (b) (6) a> _c •c <13 a. o a> £ •o c re re B -55 B B re h- O o> 03 •£ £ "O "2s" S t5 c re 0) O m O) > c o n o o G) 5 £ o. (b) (6) S o> o "5 ax: O C w f- >re re Si (b) (6) >•^1 o- £ Q. O) o (0 OJ n D1 c « 5 O o Zo 3•= . ^ c . Q) (D s X3 0) •C "D W i| 2 ^ TO «(/) '1 %_ <"(A D) O c nj 5 a o w O O) (b) (6) — (0 Q. ID "g •i.® n 6 o o 0. •c 3 O 0) o* c S x: S O) o c 2 o « o "D c 0] 3 JZ o E nm CD0) 9 C Q — ^ I 0) O I = o " 0 (A > E0) 1 E >• • fl5U IT) Q. n so £: CL _ Golder Associates TECHNICAL MEMORANDUM Date: March 11, 2016 Project No.: 16-50367 To: Janet Simoneax Company: JM Family Enterprises, Inc, From: Michael J. Dickey, RE Robert M. Wojcik. PG RE: ASSESSMENT OF GEOTECHNICAL ISSUES RELATED TO INSTALLATION OF A SLURRY WALL ON THE KERR-MCGEE SITE Golder Associates Inc. (Golder) has performed an assessment of certain geotechnlcal Issues and concerns related to installation of a slurry wall on the neighboring Kerr-McGee site, with specific focus on the anticipated impact on Jf\/1FE facilities. The assessment included review of the proposed remedial strategy, review of published information pertaining to ground settlement from installation of soil-bentonlte cut-off walls, and consideration of the potential impact(s) to JMFE facilities from installation of a slurry wall along the north property boundary of the Kerr-McGee site as proposed in a draft Feasibility Study (FS) submitted on February 16, 2016. OVERVIEW In Section 4.4 of the above-referenced draft FS, a comprehensive containment remedy is presented which is described as a "suite of remedial technologies' that when innplemented, would be intended to function in combination to achieve the remedial objectives for the site. The strategy includes a containment component, consisting of a cap and slurry wall that once installed, would encompass the entire site and "effectively contain the upper aquifer within physical flow barriers.' A conceptual layout is presented on Figure 6-2 of the FS, and the conceptual design for the slurry wall is described to consist of a 2-foot thick by 50-foot deep containment barrier constructed using a soil-bentonite mixture. Based on review of the conceptual layout as presented in the FS, the slurry wall would be installed immediately adjacent to critical Jf^FE facilities including the "Box" and the cafeteria. The "Box" is a two-story warehouse used for accessory installation and vehicle processing, and the cafeteria is a two-story commercial structure used for employee meals and breaks. Both are assumed to be founded on shallow foundations, and both structures are situated within a few feet of the proposed slurry wall alignment. SUBSURFACE CONDITIONS (KERR-MCGEE SITE) Based on review of information presented in the draft FS, upper soils at the Kerr-McGee site are described to consist of fine-grained sand with varying amounts of silt and clay, frequently mixed with debris in the near surface. Peat is reported to be present in the shallow subsurface near the western end of the site, and clay lenses less than 4 feet thick are reported to be present intermittently at various locations and depths across the site. At a depth range of approximately 34 to 43 feet, upper soils are underlain by weathered limestone mixed with carbonate clay and hard-greenish gray silt with abundant phosphate nodules (typical of the Hawthorn Group in northeast Florida). GROUND DEFORMATIONS DUE TO SLURRY WALLS Current ground conditions beneath Jft/IFE's facilities can generally be considered to be in a state of equilibrium with regard to how the applied loads at the foundation level are supported by, and distributed within, the underlying soils. Construction activities such as excavation work, trenching, vibratory pile driving, and dewatering activities can induce building settlement(s) by disrupting this existing state of equilibrium, wherein the interaction of applied loads with the newly-created subsurface conditions can result in significant ground deformations until equilibrium has been re-established. Gol<)«r Associates Inc. 942B Baymesdows Road, Suite 400 Jacksonville. FL 32256 USA Tel: (904)363-3430 Fax: (904)363-3445 unvw.goldercom Colder Associates: Operatfons in Africa, Asia, Auslrslasia, Europe, North America and South America Golder. Golder Associates and the GA globe design are trademarks of Golder Associates Corporalion Previous studies of soil-bentonite cutoff walls have indicated that ground deformations can occur during various phases during construction, and can continue long after a slurry wall has been installed. This is summarized below, and illustrated in Figure 1. • Trenching; During trenching activities, it is common lo use a benlonlte-water slurry to keep the trench from collapsing and to minimize stuffing, During this phase, the trench walls may move inward, which induces settlement of the ground surface and could cause damage to adjacent structures. • Backfilling: During backfilling, the bentonite-water slurry is replaced with soil-bentonite, which has a higher unit weight. This could cause the trench walls to move outward and reduce settlement, however, at this point, the building envelope and foundation of an adjacent structure may have already been damaged. • Long-Term Consolidation of Soil-Bentonlte Mixture: Following completion of slurry wall construction activities, the newly-placed soil-bentonite wall begins to undergo long- term consolidation. During this phase, the trench walls may again move inward, resulting in additional settlement of the ground surface causing additional damage to adjacent structures. Building Cutoff Wall I a) Trench excavation under b) Possible rebound during soil- c) Consolidation of the soil-bentonite benlomte-water slurry. bentonite backfill placement. backfill after placement. Figure 1: Ground Deformations Due to Construction of a Sofl-Bentonlte Cutoff Wall (Fllz 1996) PREDICTING GROUND SETTLEMENT FROM SLURRY WALLS While there is some Information in the literature that allows for estimating ground movements that occur during the trenching phase, little information has been published with regard to tracking movement of adjacent ground during the backfilling and consolidation phases. Cowland and Thorley (1985) published data associated with trenching activities completed as part of a major urban infrastructure project in Hong Kong where several buildings founded on shallow foundations over silty sands underwent settlement as a result of the construction activities. It was noted that the data did not include Information for ground movements that may have occurred during subsequent phases. In general, the data from Cowland and Thorley (1985) indicates some general correlations between the magnitude of the observed settlement, trench depth, and distance from the trench. The study also noted a general correlation between the magnitude of the measured settlement and relative position of the settlement reading along the length of the trench. Readings were generally lower near the ends of the trench than near the middle. In the case of a soil-bentonite slurry wall, this is of significance because the trenching is typically done continuously as opposed to a being completed In "panels" (as would be expected Colder lecti memo for geoiechconstderaiiong-l 6ocx Associates for a structural diaphragm wall or soil-cement mix wall), so settlement values would be expected to more closely resemble the higher readings recorded along the centers of the panels. Figure 2 presents the data from the above-referenced study. Figure 2: Building Settlements Due to Slurry Trench Excavation (Cowland and Thoriey 1985) DISCUSSION AND CONCLUSION Using the above correlation, and assuming a trench depth of 50 feet, a building situated within 5 feet of the trench would be predicted to undergo at least 1 inch of settlement as a result of the trenching operations alone, not including additional ground movements that would occur as a result of backfilling and long-term consolidation. Of primary concern is that long-term consolidation would result in significantly more settlement on the order to several more inches, in turn resulting in significant damage to JMFE facilities, as the buildings will have already met or exceeded allowable tolerances for total and differential settlement during trenching operations. Given this information. Colder has serious concerns regarding the feasibility of constructing a slurry wall as shown in the FS, without causing damage to the adjacent buildings, which would ultimately have an adverse effect on JMFE's business. REFERENCES 1. Cowland, J. W. and Thoriey, C. B. B. (1985). "Ground and building settlement associated with adjacent slurry trench excavation." Ground Movements and Structures - Proc.,Third Int. Conf., University of Wales Institute of Science and Technology. J. D. 2. Filz, G. M. (1996). "Consolidation stresses In soii-bentonite backfilled trenches." Proc., 2nd Int. Congress on Environmental Geotechnics, M. Kamon, ed., Balkema, Rotterdam, 497-502. GVROJECTSM6-\16-50367\TECH MEMO FOR GEOTECH CONSlOERA'nONS-1 DOCX ^ Golder lecn memsfor eeoiech considerations.1 docx Associates Hopping Green & Sams Attorneys and Counselors November 14,2016 Robenson Joseph Remedial Project Manager Superfund Restoration Branch US EPA Region 4 61 Forsyth Street N.W. Atlanta, GA 30303 Re: EPA ID FLD0390491Z01 Comments to Proposed Cleanup Plan Dated September 12,2016 for Kerr-McGee Chemical Corporation Superfund Site 1611 Talleyrand Avenue Jacksonville, Florida 32206 Dear Mr. Joseph: On October 12, 2016, the United States Environmental Protection Agency Region 4 (EPA) issued an announcement extending until November 11, 2016, the public comment period on the Proposed Cleanup Plan (PCP) for the Kerr-McGee Superfund Site (the Site) in Jacksonville, Florida. JM Family Enterprises, Inc. (JMFE) appreciates this opportunity to provide additional comments on the PCP. As you will recall, JMFE is a diversified automotive company whose subsidiaries include Southeast Toyota Distributors (SET), which is the world's largest independent distributor of Toyota and Scion vehicles. For nearly 50 years, SET has operated a vehicle processing facility (the Facility) on the Jacksonville Port Authority (JaxPort) property located immediately north of the Site (the Leasehold). Here, hundreds of thousands of new vehicles are imported and processed for distribution across the southeast region of the United States. JMFE appreciated the several opportunities to meet at the Facility with EPA, the Florida Department of Environmental Protection (FDEP), the Greenfield Environmental Multi- State Trust, LLC (Trust), and JaxPort. As stated at these meetings and in subsequent written comments to EPA, JMFE believes that a viable remedy should not only be protective of human health and the environment, it should also address potential impacts to all affected parties. As stated in JMFE's comments provided via letter to EPA on October 12, 2016, JMFE continues to approve of and support the PCP, as the PCP is a viable remedy for the Site that considers the interests and concerns of all stakeholders and affected parties. On October 12, 2016, the Jacksonville Port Authority (JaxPort) provided comments via letter to the EPA for the site. In its letter, JaxPort acknowledges that the property immediately north of the Site, which is contaminated as a result of the activities of the Site, is currently Post Office Box 6526 Tallahassee, Rorida 32314 119 S. fylonroe Street, Suite 300 (32301) 850,222,7500 850,224.8551 fax www.hgslaw.com Robenson Joseph November 14, 2016 Page 2 of 2 leased to JMFE. As JaxPort states in its letter: "JM Family imports and processes new Toyota vehicles and is a well-recognized economic engine in the Jacksonville area that provides numerous job opportunities to area residents." JaxPort further states: "Moreover, JaxPort appreciates that EPA and the Trust do not want to incur the significant business disruption expenses and severe economic duress that would be caused by intrusive soil and groundwater remediation at the JaxPort property and the operations of JM Family." JMFE appreciates JaxPort's above comments, and shares its concerns. JaxPort also states in its October 12, 2016, letter to EPA that it may be necessary for more active remediation to be required based on certain events, including but not limited to: "the decision by JM Family to relocate to another JaxPort location or some other event making the JaxPort property available for more aggressive remediation...." Please note that JMFE has no present plans to relocate to another JaxPort location other than the Leasehold; however, in the event that JMFE decides "to relocate to another JaxPort location," or there occurs "some other event making the JaxPort property available for more aggressive remediation," JMFE would not object to JaxPort's request for more active remediation, provided it does not result in adverse impact to JMFE's operations. JMFE would like to express again its sincere appreciation to EPA, FDEP, and the Trust for its careful consideration of comments and concerns of all stakeholders and affected parties and for its accessibility throughout the process which resulted in the PCP. JMFE appreciates the opportunity to provide these additional comments to EPA, FDEP, and the Trust. JMFE looks forward to participating in ongoing discussions to approve and implement the PCP for the Site. Sincerely, HOmJjD QRfiEN & SAMS Ralph A Deffteo Hard Copy/Email: Robenson Joseph Copy via email: Caren J. Snead Williams Janet Simoneaux Carol Monell Peter Comais Kelsey Helton Rick Rachal Robert Wojcik C3mthia Brooks Hopping Green &Sams Attorneys and Counselors OFFICE OF MAYOR LENNY CURRY ST JAMHS BUILDING PM: (904) 630-1776 117 WEST DUVAL STREET, SUITE 400 FAX; (904) 630-2391 JACKSONVILLE. FLORIDA 32202 wwwcoj ncl October 12, 2016 Robenson Joseph, Remedial Project Manager, U.S. EPA, Region 4 Superfund Division / Restoration and Sustainability Branch 61 Forsyth St., SW, Atlanta, GA 30303 Dear Mr. Joseph: Thank you for your presentation on September 28th at Matthew Gilbert Middle School regarding the EPA's plan to address contamination at the Kerr-McGee superfund site on Talleyrand Avenue. This letter represents the official comments of the City of Jacksonville on the proposed cleanup. As I understand it, your plan (Operable Unit 1) contemplates some removal and offsite disposal of contaminated soil, some accumulation and segregation of contaminated material onsite, solidification in areas where highly contaminated groundwater and/or soil are present as well as the use of pump-and-treat operations until natural attenuation has had its full effect. I also understand that EPA intends to install a low-permeability cap over the contaminated areas to retard the vertical and horizontal migration of contaminants. Although the EPA's plan to clean and stabilize the primary site appears workable, the City of Jacksonville believes the area of contamination may extend beyond the boundaries of the Kerr-McGee property and the areas already tested. My primary concern at this time is the documented landward contamination to the north and south of the property line as well as documented sediment contamination in the river and in Deer Creek. The City of Jacksonville therefore respectfully requests the following: That EPA further delineates the contamination north and south of the official boundaries of the Kerr-McGee site and in the St. Johns River for the purpose of identifying any additional areas where mitigation and remediation efforts would be warranted and where contaminates in the river would need to be impounded and capped. That any seawalls/bulkheads constructed in the St. Johns River by EPA for the purpose of impounding contaminated sediment be able to withstand the effects of a catastrophic windstorm. That EPA develops and publishes a reasonable timeline for completing the Deer Creek clean-up (Operable Unit 2). Because of their proximity to the St. Johns River and certain residential neighborhoods, it's vitally important that the Kerr-McGee site and Deer Creek be remediated in a timely manner that eliminates any threat to public health and to our river. Sincerely, ^ Lenny Curry Mayor City of Jacks ^nville Co: Hon. Lori Beyer, President, Jacksonville City Council Hon. John Crescimbeni, Vice President, Jacksonville City Council Hon. Aaron Bowman, Chairman, Jacksonville Waterways Commission ^JOHN^ RIVERKEEPER^ October 12, 2016 Mr. Robenson Joseph EPA Remedial Project Manager Atlanta Federal Center 61 Forsyth Street SW Atlanta, GA 30303 RE: St. Johns Riverkeeper Comments - Proposed Cleanup Plan - Kerr-McGee Chemical Corporation (Kerr-McGee) Jacksonville Superfund Site, Jacksonville, Florida Dear Mr. Joseph: Thank you for the opportunity to submit comments regarding the U.S. Environmental Protection Agency's (EPA) Proposed Cleanup Plan of the Kerr-McGee site located on the St. Johns River. While we commend EPA, the Multistate Environmental Response Trust (the Multistate Trust) and the Florida Department of Environmental Protection (FDEP) for addressing this contamination, we are concerned that the EPA's preferred remedial alternative does not fully address the numerous chemical threats to the St. Johns River. Introduction The St. Johns Riverkeeper mission is to be an independent voice that defends, advocates, and activates others to protect and restore the St. Johns River. Established in 1999, we are a privately-funded, trusted voice for the St. Johns River and the public to whom it belongs. We have nearly 1400 individual, family, business, and organizational memberships that include several thousand people who use and enjoy the waters of the St. Johns River for boating, fishing, and observing birds and other wildlife throughout the watershed. St. Johns Riverkeeper is a member of the Waterkeeper Alliance, an international environmental organization uniting more than 290 Waterkeeper programs globally. St. Johns Riverkeeper, Inc. • 2800 University Boulevard N. • Jacksonville, FL 32211 • 904.256.7591 Outstanding Concerns On September 28, we attended the Open House hosted by EPA, FDEP, the Multistate Trust and the Eastside Environmental Council. At that meeting, several concerns were raised that remain unanswered including the following. Uncertain Timing of Cleanup Plans for the Entire Site The proposed cleanup plan is only for a portion of the contaminated area. Operable Unit 1(0IJ1). 0U1 plans to address the site-contaminated soil, groundwater, sediment and surface water from the St. Johns. 0U2 will address site-related sediment and surface water contamination in Deer Creek, a tributary of the St. Johns. The National Oil and Hazardous Substances Pollution Contingency Plan (NCP) defines an operable unit (OU) as a "discrete action that is comprises an incremental step toward comprehensively addressing site problems." A timeline was not given for the cleanup of Deer Creek (0U2). This omission undermines the effectiveness of the proposed plan by not addressing all contaminants in a timely fashion. • Please provide a timeline of the anticipated cleanup of 0U2. • Please describe implementation of the 0U1 remediation activities and how they will interface and synchronize with the 0U2 remediation activities. On page 14 of the September 2016 Kerr-McGee Superfund Proposed Plan Fact Sheet (Fact Sheet), it states: "Surface water-specific remedial alternatives were not evaluated in the FS since it was anticipated that the preferred remedy for the Site would consist of a combination of soil-, groundwater-, and sediment specific alternatives, that directly or indirectly address the surface water contamination." However, this does not take into account the ongoing surface water contamination from Deer Creek that is not currently being considered for remediation. Lack of Critical Information It appears that critical information and assessment needed to fully understand the benefits and challenges of the proposed cleanup plan are not currently available for public review or decision making. In the Fact Sheet, EPA commits to "during the design phase of the project, a long-term surface water sampling and monitoring program will be developed to assess surface water quality for DDD, gamma chlordane, aluminum, copper, iron and mercury. The data collected during these sampling events will be used to evaluate achievement of surface water remedial objectives." • Will there be the opportunity for the public to review sampling and monitoring programs before they are finalized? • Will there be an opportunity for stakeholders to submit technical comments? In Figure 7, sediments sample site locations are not located beyond the extent of the identified plume limiting a full understanding of the extent of the contamination in the St. Johns. • Will additional sampling be conducted to better understand the extent of the plume in the river? • Please provide detailed information how the conceptual site model will be refined and updated to fill the apparent data gaps including: • Incomplete assessment of the sediment in the St. Johns River and Deer Creek • Incomplete understanding of contamination issues North and South of site • How will the stormwater/surface water discharges be regulated from the site? • Please address infiltration and preferential flow via annual spaces and subsequent discharge of contaminated groundwater to the St. Johns River via the sewer and utilities between JAXPORT and the Kerr-McGeee site. Inadequate Cleanup of the St. Johns River ERA'S preferred alternative for addressing approximately 2.5 acres of contaminated soil in the St. Johns is inadequate. Capping the contamination behind a bulkhead creates unacceptable risk due to storm events and potential leaching. Design work has not been conducted to determine the effectiveness of the proposed bulkhead/seawall. No information is provided as to how the sediment contamination behind the proposed bulkhead/seawall will be addressed. Figure 8 shows surface water to the west of the bulkhead/seawall while the narrative proposed a "cap" with no detail, only "Capping a 2.5-acres area enclosed by the bulkhead." • At what point will citizens be able to review and comment on details regarding the proposed cap and bulkhead/seawall prior to the finalization of the plan? • Will the bulkhead/seawall and cap be designed to withstand a Category 5 hurricane? • What controls will be in place during the dredging of sediments to the East of the proposed bulkhead/seawall? • What controls will be in place during the installation of the bulkhead/seawall and cap? On page 14 of the Fact Sheet, it states that Five-Year Reviews will be required to verify the effectiveness, but does not discuss remedies available if needed. • At what point will this be shared with stakeholders? Additional Public Engagement Necessary Recognizing that the proposed plan is currently a conceptual site model, we expect many refinements and potentially significant changes to the final cleanup design. • At what point will citizens be able to review and comment on critical data and design prior to the finalization of the plan? As an example, on page 12 of the Fact Sheet, the following comments elevate our concern: "It is EPA's current judgement that the Preferred Alternative identified in this Proposed Plan, crone of the other active measures considered in the Proposed Plan is necessary to protect human health or welfare or the environment..." "Remedial Action Objectives (RAOs) are finalized and documented in the Record of Decision (ROD)." "Based on consideration of factors during the nine criteria analysis and using the PRO (Preliminary Remediation Goals) as a point of departure, the final cleanup levels (to be included in the Record of Decision(ROD)) may reflect a different risk level within the acceptable EPA risk range (1x10-6 to 1x10-4 for carcinogens) than the originally identified PRGs." It is not clear what if any additional public engagement is available. On page 24 of the Fact Sheet, the Community Participation ends with the October 12 Public Comment deadline. • What are the in the community engagement process between now and the publication of the ROD? And the implementation of the remediation plan? • Please provide details for ongoing stakeholder participation during the design and implementation process.. Conclusion Thank you again for the progress made on the Proposed Cleanup Plan for the Kerr McKee site and the St. Johns River. While we are pleased with the forward movement, we recognize the much work is still to be done. We look fonA/ard to meeting with you and discussing the following prior to the finalization of the ROD: • Uncertain Timing of Cleanup Plans for the Entire Site • Lack of Critical Information • Inadequate Cleanup of the St. Johns River • Additional Public Engagement Necessary Thank you for your consideration. For the River, Lisa Rinaman St. Johns Riverkeeper 904-509-3260 [email protected] MILES & STOCKBRIDGEP.C. Amanda Neidert Kesler, Esq. 410-385-3852 [email protected] November 11, 2016 VIA FEDERAL EXPRESS and ELECTRONIC MAIL Robenson Joseph EPA Remedial Project Manager Atlanta Federal Center 61 Forsyth Street SW Atlanta, GA 30303 Re: Comments to EPA's Proposed Plan and Final Feasibility Study for the Kerr McGee Chemical Corporation Superfund Site, Jacksonville, FL Dear Mr. Joseph: Enclosed please find the comments of Emhart Industries, Inc., a now dissolved, Connecticut corporation ("Emhart") on the U.S. Environmental Protection Agency's Proposed Plan (September 2016) and the Final Feasibility Study (August 2016) for the Kerr McGee Chemical Corporation Superfund Site located in Jacksonville, Florida ("Site"). Please be advised that The Black & Decker Corporation, having received a General Notice Letter for the Site, dated June 10, 2013, hereby adopts, as if filed on its own behalf, the comments submitted by Emhart. Should you have any questions or would like to discuss Emhart's comments, please do not hesitate to contact me. Sincere Amanda Neidert Kesler ANK:abg Enclosure cc: Cynthia Brooks (Multistate Trust) Joseph W. Hovermill, Esq. 100 LIGHT STREET I BALTIMORE, MD 21202-1153 I 410.727.6464 I milesstockbndge.com EASTON. MD • FREDERICK, MD • ROCKVILLE.MD • TOWSON. MD • mOMS CORNER. VA • WASHINGTON, D C :*]RP MOVE YOUR ENVIRONMENT FORWARD November 11, 2016 Mr. Robenson Joseph, Remedial Project Manager U.S. EPA, Region 4 Superfund Restoration and Sustainability Branch Superfund Division 61 Forsyth Street SW Atlanta, GA 30303 Emhart Comments Regarding EPA's Proposed Cleanup Plan, dated September 2016 and Final Feasibility Study, dated August 2016 Kerr-McGee Chemical Corporation Superfund Site Jacksonville, Florida EPA ID FLD039049101 For Inclusion in the Administrative Record Dear Mr. Joseph, On behalf of Emhart Industries, Inc., a now dissolved, Connecticut corporation (Emhart), HRP Associates, Inc. (HRP) has prepared the following comments regarding the EPA's September 2016 Proposed Cleanup Plan (PCP) and the August 2016 Final Feasibility Study (FS) pertaining to the Kerr-McGee Superfund Site located in Jacksonville, Florida (the Site). The U.S. Environmental Protection Agency (EPA) issued the PCP on September 12, 2016 with a deadline to submit written comments by October 12, 2016, which was subsequently extended to November 11, 2016. Emhart appreciates both the opportunity to meet with EPA and representatives of the Multistate Trust on November 1, 2016 and the opportunity to now provide written comments to EPA on the PCP and FS for the Site. Executive Summary Since 2006, the FS for this Site has been revised at least 6 times and the 2016 PCP is the second time EPA has issued a preferred remedy for the Site. What started as a comprehensive remedy in 2006 with a net present value of $18.6 million dollars has evolved into a preferred remedy totaling approximately $69 million dollars to address three impacted media (i.e., soil, groundwater, and sediment) across the 31-acre Site. EPA selected Alternative SS-2 (removal of principal threat waste and installation of a low permeability cap with institutional controls) to address soil and Alternative SD-5 (bulkhead construction with institutional controls) to address sediment at the Site. For groundwater, EPA selected not one, but two groundwater remedies consisting of Alternative GW-7 (in-situ stabilization of groundwater with monitored natural attenuation/long term monitoring and institutional controls) and Alternative GW-8 (hydraulic containment with pump & treat and institutional controls^ The two groundwater remedial strategies selected by EPA Region 4, as detailed within the PCP, are grossly excessive compared to their overall effectiveness based on site information and the data/conclusions presented within the 2005 Remedial Investigation (RI) and aforementioned FS. This determination is HRP ASSOCIATES, INC. | 197 SCOTT SWAMP ROAD, FARMINGTON, CT 06032 | PHONE (860) 674-9570 | FAX (860) 674-9624 Emhart Comments Regarding EPA's PGP and FS November 11, 2016 Page 2 of 11 based on the fundamental concept of remedial practicability with respect to the expectation of restoring groundwater to drinking water quality. The National Contingency Plan (NCR), which provides the regulatory framework for Superfund, states that groundwater is to be returned to beneficial use wherever practicable and within a reasonable timeframe. [40 CFR 300.430(a)(l)(iii)(F).] The NCR also incorporates an understanding of cleanup limitations, and states that when restoration of groundwater to beneficial use is not practicable, ERA expects to prevent further migration of the plume, prevent exposure to the contaminated groundwater, and evaluate further risk reduction (i.e., Risk-Based Corrective Action). The RI and FS reports do not adequately demonstrate that Site groundwater can be practicably restored to drinking water quality within a reasonable timeframe given the circumstances of the property. Environmental engineering firms have a variety of innovative remedial tools at their disposal pertaining to the mitigation of contamination in 2016 (e.g., in situ injection of biological or chemical amendments, thermal desorption, installation of permeable reaction barriers, etc.). Flowever, despite the emergence of modern technologies, there are sites located across the region and the country where groundwater simply cannot be restored to beneficial use, no matter the magnitude of the investment. The Kerr-McGee Superfund Site is such a property. This is especially true given that the Site sits in an area that has and will continue to be an industrial use area where groundwater will never be used for drinking water. Because the selected groundwater remedies are driven by the existing State classification of groundwater at the Site, reclassification of the groundwater should be sought and/or the remedial action objective (F^O) to restore the groundwater at the Site to potable use should be revised. The FS also does not provide sufficient information to substantiate the effectiveness and need for the selected groundwater remedies. Additional studies are warranted 1) to support the depth of the in-situ stabilization for GW-7, 2) to ensure brackish water will not contaminate the groundwater or foul the pump & treat system under GW-8, 3) to ensure the effectiveness of achieving drinking water standards, some of which are below practical quantification limits, and 4) to confirm the permanence and effectiveness of the pump and treat system of GW-8 next to the St. Johns River. Re-evaluation of the soil and sediment remedial alternatives is also merited to re-adjust the focus on aggressive treatment of soil, rather than groundwater, where returns on improvements groundwater quality are more certain. Finally, important cost components omitted from the FS should be incorporated prior to re- analysis of the alternatives so that the definition and costs of the alternatives are accurate relative to each other for proper comparison and decision-making. According to ERA'S Guidance for Conducting Remediai Investigations and Feasibiiity Studies (October 1988), the accuracy of the $69 million dollar estimate for the selected remedy must be within -30%/+50%, which translates to a range of $48 million dollars to $104 million dollars. Based on HRR's third party review of the budget calculations in the 2016 FS (see Section 2.4 below), the total cost of ERA'S current preferred remedy could exceed $150 million at project completion due to the omission of tasks, underestimation of fees, and vague timeframes for milestone completion. HRP ASSOCIATES, INC ! 1327 MILLER ROAD, SUITE D, GREENVILLE, SC 29607 1 PHONE (864) 289-0311 | FAX (864) 281-9846 Emhart Comments Regarding EPA's PGP and FS November 11, 2016 Page 3 of 11 In summary, the selection of grossly excessive cost remedies (GW-7, GW-8, and SD-5), and their implementation in unison, over other alternatives that are protective of human health and the environment does not reflect a reasoned evaluation of the alternatives and Site circumstances under the primary balancing criteria as required by 40 CFR 300.430(f). Emhart presents the following comments in support of the aforementioned position in response to the ERA'S September 2016 PGR and August 2016 FS. 1.0 RESTORATION OF AQUIFER TO DRINKING WATER QUALITY Although groundwater at the Site is not currently used for potable or non-potable purposes and it is not expected to ever be used for potable purposes, ERA established the restoration of groundwater to drinking water standards as a remedial action objective (RAO) for the Site. This RAO, as phrased, is not appropriate for the Site given the existence of non-contiguous source areas scattered across the property, the age of the releases, the degree of contamination, and the presence of co-contaminants (e.g., metals, pesticides, VOCs, etc.). That is, these issues in aggregate are highly difficult to overcome, if not insurmountable, given the extremely stringent drinking water standard. Specifically for a-BHC, restoration to drinking water standards would be impractical because it would require achieving a standard lower than laboratory practical quantitation limits (RQLs). These cumulative factors warrant a risk-based mitigation approach regarding groundwater impacts. Risk-Based Corrective Action (RBCA) is standard industry practice commonly applied at complex sites, such as the Kerr-McGee Superfund Site, and is promulgated by states within ERA Region 4 in various regulatory frameworks (i.e., state lead, voluntary cleanup projects, Brownfields). In particular, Florida has expanded the use of RBCA under the "Global" RBCA rule (F.A.C. Ch. 62- 780) to apply to all contaminated sites when legal responsibility for site rehabilitation exists, including the statutory directive that citizens be protected "under actual circumstances of exposure." The Kerr McGee Site has been used for industrial purposes since 1893 (123 years), is and has been surrounded by industrial use, and is adjacent to brackish water to the east. All of these factors make potable use of groundwater at the Site relatively impossible. Despite this reality, the State of Florida has classified the groundwater at the Site as G-II, a potential future potable water source to which state drinking water standards apply. Although Florida provides for the use of RBCA, ERA considers the drinking water standards to be ARARs at the Site. These standards and the concomitant RAO to restore groundwater to these standards are not appropriate based on the following site specific characteristics: no on-site or down-gradient potable supply wells, indefinite industrial end use accepted by stakeholders, proposed institutional controls (ICs) which prevent human exposures, available alternative remedies to address groundwater to sediment pathway, and the presence of a brackish shallow aquifer with total dissolved solid (TDS) levels that are inconsistent with a potable water classification. Because of this G-II classification and the incorporation of a drinking water AF^R, the Human Health Risk Assessment was revised in 2016 to, among other things, assess the risk to a hypothetical groundwater user that will never exist and the FS incorporated an unachievable HRP ASSOCIATES, INC ! 1327 MILLER ROAD, SUITE D, GREENVILLE, SC 29607 ! PHONE (864) 289-0311 | FAX (864) 281-9846 Emhart Comments Regarding EPA's PGP and FS November 11, 2016 Page 4 of 11 ARAR and RAO to restore groundwater to drinking water within a reasonable timeframe. To the contrary, the following passages obtained from technically relevant documents suggest the ingestion pathway for human receptors is, and will remain, incomplete, making restoration to ARARs unnecessary: • 2016 FS; page 1-3; "Although residences are located near the Site, there are no plans to modify the Site for a residential land use. Due to the highly industrialized nature of the properties surrounding the Site, it is unlikely that the Site would be used for residential purposes in the future." • 2016 FS; page 2-1; Conflicting statements pertaining to exposure: "actual site conditions...minimize inadvertent human contact" in contrast to "restore contaminated groundwater to... drinking water." on page 2-2. • 2016 FS; page 5-4; Wavering application of regulatory standards: "Groundwater is currently not used for potable or non-potable purposes at the Site, and the future use plans for the property are not expected to include use of on-site groundwater for potable uses. However, by State of Florida law, the site groundwater is considered a potential potable water source. In each alternative, ICs would be implemented to prevent use of groundwater at the Site until F^Os are achieved. Groundwater was not determined to be an exposure pathway for humans in either the HHF^ (Shaw, 2005b) or in the SLEF^ (Shaw, 2005c), but in the 2015 HHF^ Addendum, it was considered a potentially complete exposure pathway for future construction workers and for hypothetical groundwater users. With ICs in place to prevent groundwater use and protect construction workers, the primary exposure pathway via groundwater is the receiving sediment and receiving water of the St. Johns River via groundwater transport and possible discharges through the sediment into the river." • 2016 FS; Throughout the FS, the Industrial PSVs for soil are used; consistency would require that the groundwater standards also be based on industrial use. • 2016 HHRA; page 4-2; "The reasonably anticipated future land use at the Site is expected to remain industrial." "On-site land use is highly unlikely to change from industrial to residential in the future based on the City's Comprehensive Plan (City of Jacksonville, 2013) and the current surrounding land use." • FDEP website^ an updated summary that includes reference to a Feb 2016 EPA meeting, page 2; "While classified as potential drinking water by the State, a well survey over a 2-mile radius of the site indicates that potable use of these aquifers is unlikely." HRP ASSOCIATES, INC 1 1327 MILLER ROAD, SUITE D, GREENVILLE, SC 29607 1 PHONE (864) 289-0311 | FAX (864) 281-9846 Emhart Comments Regarding EPA's PGP and FS November 11, 2016 Page 5 of 11 "Drinking water for the areas is provided by the City of Jacksonville and drawn from the Floridian Aquifer at depths of approximately 500 feet." "A confining unit separates the surficial and Floridian aquifers. Contaminants associated with the site have not been identified in the Floridian aquifer." ^https://www.dep.state.fl.us/waste/quick_topics/publications/wc/sites/summary/174.pdf • JAXPORT comment letter; 2/25/16; JAXPORT property is subject to a Memorandum of Agreement for land use controls "that minimizes the possibility of a completed pathway to contaminated groundwater." • NRRB Memo; July 28, 2016, page 4; "Based on the information provided to the Board, it appears that the State of Florida has identified the groundwater beneath the Site as a drinking water source (Class G- Il/potable use), and therefore believes the aquifer must meet state-equivalent maximum contaminant level (MCLs). Additional information provided to the Board, however, indicated that Site-wide groundwater had total dissolved solids levels ranging from 300 to 4,000 mg/L." The Board implies that IDS levels render the groundwater unsuitable for drinking. As documented, drinking water receptors do not exist at the Site and will not be present in perpetuity. The EPA further acknowledges the lack of potential drinking water receptors by selecting two groundwater remedies that achieve ARARs in 30 to greater than 100 years. Note that the chosen groundwater remedies comprise institutional controls (ICs) and long-term monitoring (LTM) to evaluate natural attenuation for the duration of the post-remedy phase (timeframe to be determined). While a technical impracticability (TI) waiver may not be supportable at this time, it is likely that over time, despite the unnecessary aggressiveness of the selected remedy, contaminant levels will plateau and never reach drinking water standards. Under this scenario, an inordinate amount of money will have been spent for naught. As an alternative to a TI waiver, however, reclassification of the groundwater should be sought. The shallow aquifer beneath the Site has been misclassified based on the site-specific characteristics and information presented above. It is generally accepted that a broad-brush, macro-characterization of aquifers inherently prevents the identification of subset areal zones that, based on zoning, end use, finite geologic conditions, etc., would alternatively be classified differently than the major aquifer system in which the property resides. EPA's own guidance on the role of State groundwater use determinations based on an EPA-endorsed Comprehensive State Ground Water Protection Program (CSGWPP) recognizes that the CSGWPP should have provisions allowing groundwater classifications to be determined at a specific site. [EPA, The Role of CSGWPPs in EPA Remediation Programs, OSWER Directive 9283.1-09, April 4, 1997 (CSGWPP Directive).] The shallow aquifer should be reclassified as G-III per FAC 62-520 based on 1) the levels of total dissolved solids (4,000 mg/L), 2) the fact that the shallow aquifer is not a single source aquifer (the Floridian aquifer is the local source), and 3) the proximity of brackish water (St. HRP ASSOCIATES, INC ! 1327 MILLER ROAD, SUITE D, GREENVILLE, SC 29607 [ PHONE (864) 289-0311 | FAX (864) 281-9846 Emhart Comments Regarding EPA's PGP and FS November 11, 2016 Page 6 of 11 Johns River) that would further render the shallow aquifer non-potable as a result of a pump and treat remedy (i.e., GW-8). A G-III designation would provide the framework for the implementation of a risk-based groundwater remedial alternative that would provide a similar standard of care towards human health and the environment, in a more cost-effective manner consistent with the NCP statutes. According to EPA's CSGWPP Directive, which supersedes the NCP Preamble where the State has an EPA-endorsed CSGWPP, if the shallow aquifer was reclassified as G-III, the State's determination would prevail even if it differed from the use that would have been determined by EPA's classification scheme or was less stringent. The groundwater classification is not itself an ARAR, but leads to the determination of what may be an applicable or relevant and appropriate requirement. Therefore, the requirement that a state standard must not only be promulgated, identified in a timely manner and more stringent than federal requirements, would generally not apply. [5ee40 CFR §300.400(g)(4).] Further, FAG 62-520 recognizes that "social, economic, and environmental costs may, under certain circumstances, outweigh the social, economic, and environmental benefits if the numerical criteria are enforced statewide. It is for that reason that the Commission provided for exemptions from the water quality criteria such as under FAC 62-520.500 (Water Quality Criteria Exemptions for Installations Discharging into Class G-I or G-II Ground Water). Once the groundwater is reclassified for non-potable use, EPA will be relieved of the undue burden of trying to restore groundwater to potable use under circumstances where restoration is impracticable consistent with 40 CFR 300.430(a)(l)(iii)(F) and the NCP Preamble at 55 Fed. Reg. 8665,8734 (Mar. 8, 1990). Further, the RAO for groundwater in the FS and PCP should be modified to more generally prevent human exposure to groundwater. This type of RAO for groundwater is part of several recent RODs at NPL sites in Florida, including: • Naval Air Station Site 43 in Pensacola, where there is a RAO is to "Prevent unacceptable human health risk associated with exposure to groundwater containing lead concentrations greater than the FDEP GCTL and USEPA Action Level." • Cabot Carbon/Koppers Site in Gainesville, where there is a RAO is to "Restore quality of groundwater outside of principal contaminant source areas to beneficial use having COC concentrations no greater than Federal MCLs or Florida." Allowing MCLS to be exceeded at a portion of the site is an appropriate RBCA strategy. • Flomestead Air Force Base Site, where Land Use Controls were added in the Explanation of Significant Differences (ESD) "Because sites OT022/OU-26, OT024/OU-28, OT026/OU29 were not remediated to a level protective of unrestricted use/unlimited exposure, this ESD is intended to address the residual risk." 2.0 SPECIFIC ISSUES AND ALTERNATIVES TO EPA'S SELECTED REMEDIES The specific technologies that have been selected for soil and sediment are not consistent with a thorough and reasoned analysis of the primary balancing criteria under 40 CFR 300.430(f). There is significant potential for cost effectiveness while raising the standard for protection of HRP ASSOCIATES, INC ! 1327 MILLER ROAD, SUITE D, GREENVILLE, SC 29607 ! PHONE (864) 289-0311 | FAX (864) 281-9846 Emhart Comments Regarding EPA's PGP and FS November 11, 2016 Page 7 of 11 human health and the environment by selecting alternative remedies. The alternatives selected for groundwater should be modified to provide a site-wide, holistic approach that works in tandem with the revised soil and sediment remedies. 2.1 SEDIMENT REMEDY Table 5-1 of the 2016 FS provides a summary of various technologies that were carried through to the comparative analyses, including a relative ranking, by media, using a series of symbols from low to high. The selected remedial alternative, SD-5 (environmental bulkhead construction), ranked comparatively lower than SD-4 (sediment capping) in four of the five balancing criteria and was ranked equal to SD-4 in the fifth (long-term effectiveness and permanence). Implementability of the SD-5 bulkhead ranks the lowest of the sediment remedies and will have to overcome unforeseen administrative hurdles with the Army Corp which are not incorporated in the cost estimate. For example, the PGP states that "SD-5 would take the most time to implement" and that "SD-4 ranks highest for implementability" while "administrative requirements could delay or impede installation of the bulkhead (SD-5)". SD-5 ranks highest in cost, while SD-4 ranks lowest. PGP at 20-21. Further, as EPA is already aware, JM Family Toyota is opposed to SD-5 and expressed a preference for SD-4 given that dredging and bulkhead construction could have a significant adverse effect on their operations, whereas SD-4 would have the least impact since it would take the least time to implement. See PGP at 20, FS at 5-4. Therefore, SD-5 should be replaced with SD-4 as the selected sediment remedy in accordance with 40 GFR 300.430(e)(9)(iii). 2.2 SOIL REMEDY Soil remedy SS-2 (removal of PTW; installation of low permeability cap with IGs) should be replaced by SS-7 (removal of PTW; in-situ stabilization of hot spot soils; installation of low permeability cap with IGs), despite the increased investment. Both soil remedies incorporate the removal of principal threat waste (PTW); however, implementing SS-7 would in turn eliminate the need for groundwater remedy GW-7 (removal of PTW; in-situ stabilization of hot spot soils; installation of low permeability cap with IGs) as discussed below. Industry standard practice lends a larger resource allocation on soil hot spot remedies (i.e., source zones) as opposed to groundwater mitigation as a means towards achieving RAOs in a cost-effective manner. 2.3 GROUNDWATER REMEDIES Sufficient data was not presented in the 2005 RI or 2016 FS to support the assumption that groundwater needs to be remediated at depths up to 20 feet in the shallow aquifer and 45 feet in the intermediate aquifer (multiple remedies). The FS does not adequately identify the targeted zones of impacted groundwater in regards to the selected remedy, GW-7 (removal of PTW; in-situ stabilization of hot spot soils; installation of low permeability cap with IGs). The RI did not present cross-sectional plume maps that demonstrate the need to treat at the assumed depths. FS guidance requires the volumes or areas of media to which general response actions might be applied be identified, and this has not been adequately demonstrated for groundwater hot spots in Section 2.5.3 of the FS. In reviewing the comprehensive August 2015 groundwater sampling results, it appears that MW-IOD is the focus of the intermediate aquifer target area HRP ASSOCIATES, INC ! 1327 MILLER ROAD, SUITE D, GREENVILLE, SC 29607 ! PHONE (864) 289-0311 | FAX (864) 281-9846 Emhart Comments Regarding EPA's PGP and FS November 11, 2016 Page 8 of 11 based on a concentration of aBHC of 0.97 ug/L. However, the database that is available as contained in the RI and FS only contains one other sampling event for this well, on November 29, 2000, when the concentration of this compound was estimated with a J qualifier at 0.010 ug/L. A better understanding of the nature of the target area within the intermediate aquifer should be provided. This data gap directly affects effectiveness, implementability, and cost [40 CFR 300.430(e)(9)] and prevents an adequate evaluation and comparison of alternatives. GW-8 (hydraulic containment with pump 8i treat and ICs) incorporates the installation of 15 recovery wells approximately 150 feet from the shoreline of the St. John's River. The FS does not reflect that EPA modeled the GW-8 remedy to ensure that brackish water from the river does not intrude upon the remediation system, and more importantly, the G-II aquifer designated as a future water supply. Salt water intrusion, caused by the pump and treatment (P8iT) system, would be counter-productive to the RAO of restoring groundwater to beneficial use since the remedy itself will diminish groundwater quality. Furthermore, the cost- effectiveness of GW-8 is unclear due to the fact that financial resources would be used to pump and treat an undetermined volume of captured water from the river, and replace damaged equipment at an expedited timeframe due to the presence of brackish water. An evaluation of the primary balancing criteria, principally permanence, implementability, and cost, does not support the GW-8 remedy [40 CFR 300.430(f)]. Pilot aquifer pumping tests in proximity to the river should be performed in conjunction with modeling efforts prior to final selection of GW-8 so that GW-8 can be properly evaluated and compared to the other groundwater alternatives prior to the issuance of the Record of Decision (ROD). In addition to their technical uncertainties, remedies GW-7 and GW-8 in concert are grossly excessive in conjunction with the selected soil and sediment remedies. Targeting groundwater hot spots following 1) the removal of principal threat wastes (PTW) in soils (i.e., source material), 2) capping the site (prevention of infiltration), and 3) eliminating of the exposure pathway to river sediments is inconsistent with the balanced evaluation of effectiveness, implementability, and cost. [40 CFR 300.430(e)(7).] The preference for treatment and the need for treatment to complement MNA is already satisfied by the removal of PTW in the selected SS-2 remedy and implementation of SS-7 instead of SS-2 as described above would provide even more treatment in a more cost-effective manner that GW-7. Moreover, while much is made of the need for the in-situ stabilization (ISS) under GW-7 as "treatment," ISS only reduces mobility, not toxicity or volume, and the contaminants remain onsite, just as they would with a cap or containment remedy. [See FS at 4-44 ("[GW-7] would reduce the mobility of COCs due to stabilization. This alternative would not reduce toxicity of COCs...").] Further, implementation of SD-4 (sediment capping) would eliminate the need for GW-8. [SeeFS at 6-3 ("based on...implementation schedule of the sediment remedy, it may be necessary to pair a treatment remedy with a containment remedy" implying that due to the length of time required to construct the bulkhead, the pump and treat system will be needed as "interim" containment).] Finally, although the June 2016 Technical Memorandum on MNA by AECOM found that "MNA should be considered when source treatment or source control technologies are conducted to significant (sic) reduce the contaminant mass for achieving cleanup goals in a reasonable timeframe," the source treatment components of the soil and sediment remedial alternatives preclude the necessity of GW-8. HRP ASSOCIATES, INC 1 1327 MILLER ROAD, SUITE D, GREENVILLE, SC 29607 1 PHONE (864) 289-0311 | FAX (864) 281-9846 Emhart Comments Regarding EPA's PGP and FS November 11, 2016 Page 9 of 11 2.4 UNDERESTIMATION OF REMEDIAL BUDGETS The cost estimates for EPA's proposed remedial alternatives provided in Appendix E of the 2016 FS do not incorporate all of the components required by the FS guidance. [EPA, A Guide to Developing and Documenting Cost Estimates During the Feasibiiity Study, OSWER Directive 9355.0-75, EPA 540-R-00-002, July 2000 (Cost Guidance).] As a result, the estimated cost to implement the selected remedies is underestimated. FIRP offers the following comments based on a review of the RACER calculations: • Lack of inclusion of cost components specific to contractor administration and contractor site engineering controls or general conditions (e.g., trailers, security, cameras, administrative, meetings, photos, as-builts, submittals, etc.); • What is the contractor mark-up percentage on directs/indirects? No presentation of profit for a contractor; • Cost estimates associated with river construction activities; • Presented unit costs appear to be low across the board and omit items such as mobilization, etc. For example, a crusher rents for approximately $9,000 per week, and consumes approximately 400 gallons of fuel a day. Utilization of this equipment over 12 hours for $2,000 is not reasonable. Similar observations are made for units rates such as excavation, backfill, concrete demolition, etc. (e.g., it is not reasonable to have a 335 dozer on site for 1 hour to clear a field); • Costs associated with site protection and/or rain water collection and treatment are not presented. There will be significant erosion and sedimentation controls required on a project of this magnitude. Consideration of rain water collection and treatment? • Costs associated with truck washes, street cleaning, off-site load out area protection and cleaning, etc. are not presented; • Limitations to working in the river are likely. Frequently, work cannot proceed during fish migration season, etc. This potential aspect should be factored into cost and scheduling (implementability) as it relates to general conditions, etc.; • Costs associated with on-site testing and inspections appears significantly low. The RACER detailed estimate does not reflect the scope required 1) for on-site, third party, oversight and inspections during the performance of environmental remediation, such as costs for sample collection, sample analysis, survey, etc., or 2) for third party structural inspections required for work construction of the water treatment facility, slurry wall or the bulkhead, such as concrete testing, inspection of the formation of subgrade, etc.; • Pump & Treat system maintenance costs do not appear to be accurately reflected. For example, the SF allowance for the Treatment System Building is not sufficient for a complete and operational pump facility. Costs for installation of pumping equipment and storage tanks associated with ground water collection and treatment reflect specific items like installation of a 50 GPM pump, 5,000 gallon tank, etc. but are missing items such as housekeeping pads, electrical service installation, MCC installation, controls installation and integration and piping. Further, 200 LF of pipe, (1) valve, (1) tee, (3) 90 HRP ASSOCIATES, INC ! 1327 MILLER ROAD, SUITE D, GREENVILLE, SC 29607 ! PHONE (864) 289-0311 | FAX (864) 281-9846 Emhart Comments Regarding EPA's PGP and FS November 11, 2016 Page 10 of 11 degree elbows, (1) 45 degree elbow, (2) couplings and (1) 4"x2" reducer is insufficient for a 2,882 SF pumping facility. Such a facility would measure 30' x 30' and with (1) 12,000 LIST and (3) 5,000 AST's, quantities would be expected to at least be quadrupled along with control valves, controls and controls integration, meters, floats, multiple pumps and likely an emergency generator. • There is no allowance for design, which should include a contingency. The RACER detailed estimate does not itemize design costs which will be extensive and can be categorized, at a minimum, as related to site, structural, architectural, marine, electrical, mechanical, plumbing and environmental. Civil engineering including survey will be required to locate and design existing and final grading along with design of systems supporting the pump facility, site erosion and sedimentation, final storm water control, and utilities design. Civil and marine engineering will be required to design the slurry wall and bulkhead. Marine engineering will also require under water survey for the bulkhead design. Structural, civil, architectural, mechanical, electrical and plumbing engineering will be required for the pump house design. Environmental engineering will be required as per the FS guidance to design the site remediation activities and monitoring activities required which need to coordinate the overall site and the other disciplines involved in the context of remediation activities to ensure compliance with EPA requirements. • There is no allowance for permits and permit application development costs. Specifically, the USACE permit requirements for the sediment remedies will be extensive. In addition to clarification and/or incorporation of the above cost estimate components, a sensitivity analysis may be warranted with respect to the cost estimate for GW-7. According to ERA'S Cost Guidance, a sensitivity analysis should be considered for factors with a relatively high degree of uncertainty that with a small change in value could significantly affect the overall cost of the alternative, such as estimated volumes of contaminated media. [Cost Guidance at 5-15 - 5-16.] The cost of in-situ stabilization in saturated soil increases exponentially with depth. In order to fairly compare this alternative relative to the other groundwater alternatives as required by the NCR, this range in potential cost should be understood, especially because the FS does not provide sufficient data to support the approximated depth of 45 feet bgs. [5^^ Cost Guidance at 2-5 - 2-6 (noting the importance of relative accuracy for comparative cost estimates so decisions between alternatives can be appropriately considered).] Based on this potential for increased costs, it becomes imperative that the primary balancing criteria are evaluated equitably to ensure the fair consideration of implementability and cost effectiveness. 3.0 TREATABILITY STUDIES AND END USER CONSIDERATIONS Treatability investigations (i.e., bench scale, pilot scale) to demonstrate the effectiveness of the selected groundwater remedies with respect to 1) achieving drinking water ARARs below laboratory RQLs, and 2) the permanence and cost-effectiveness of a pump and treat remedy 150 feet from the St. John's River must be conducted. The presence of RI data gaps (analytical HRP ASSOCIATES, INC ! 1327 MILLER ROAD, SUITE D, GREENVILLE, SC 29607 ! PHONE (864) 289-0311 | FAX (864) 281-9846 Emhart Comments Regarding EPA's PGP and FS November 11, 2016 Page 11 of 11 data at depth) and concerns regarding the balanced evaluation of remedial alternatives in accordance with 40 CFR 300.430(e)(7) and (9) dictate that such testing be done prior to final remedy selection in the ROD. [EPA, CERCLA/Superfund Orientation Manuai, p. VII-7, EPA/542/R-92/005, October 1992 ("Treatability Studies should be performed as soon as it becomes apparent that the available information is insufficient to support the selection of a potential treatment technology").] Not only are the studies necessary for a meaningful evaluation of alternatives, but it is also consistent with OSWER guidance recommending a phased approach to groundwater responses. [5^^, e.g., EPA Finai Guidance, Presumptive Response Strategy and Ex-Situ Treatment Technoiogies for Contaminated Groundwater at CERCLA Sites at 5-6, OSWER Directive 9283.1-12, EPA 540/R-96/023, October 1996.] Conducting groundwater treatability studies prior to issuance of the ROD is warranted given the projected capital investment in full scale implementation (i.e., ^^$3914 for GW-7 and GW-8). The information obtained from pilot testing will confirm the appropriateness of the selected remedies, demonstrate that non-selected alternatives should be reevaluated, or support a potential technical impracticability (TI) groundwater waiver. Any of these results would be worth the time and cost to conduct the treatability study now to avoid the administrative burden of a future ROD amendment and the unnecessary expenditure of cost. While additional studies to support the groundwater remedy design will also be implemented following the ROD; treatability studies should be conducted prior to ROD issuance to enable a relative comparison of alternatives and to help avoid the administrative burden associated with a ROD amendment should the results lead EPA to change course on the remedy. 4.0 SUMMARY OF RECOMMENDED ALTERNATIVES TO ERA'S PREFERRED REMEDY In summary, and as articulated above, a more reasonable cleanup plan that would, nevertheless, be protective of human health and the environment would be to replace SS-2 with SS-7, thereby rendering GW-7 unnecessary, and replacing SD-5 with SD-4, rendering GW-8 unnecessary, assuming SD-4 was implemented as quickly as anticipated. We have prepared the following summary of the recommended alternative combination for the cleanup plan, which would achieve a better balance of the nine criteria for evaluation than the current combination of preferred alternatives: PROPOSED PLAN ALTERNATIVE PLAN Remedy By Remedy By Total Cost Total Cost Media Media SS-2 $14,319,400 SS-7 $19,923,400 SD-5 $14,899,300 SD-4 $7,534,700 GW-7 $23,058,800 GW-2 $2,175,400 GW-8 $16,416,300 Total Cost $68,693,800 Total Cost $29,633,500 Difference in Total Cost = $39,060,300 HRP ASSOCIATES, INC ! 1327 MILLER ROAD, SUITE D, GREENVILLE, SC 29607 1 PHONE (864) 289-0311 | FAX (864) 281-9846 Emhart Comments Regarding EPA's PGP and FS November 11, 2016 Page 12 of 11 Please do not hesitate to contact HRP at (800) 782-3922 with any questions regarding the above information. Sincerely, HRP ASSOCIATES, INC. Daniel E. McDonnell, PG Project Manager cc: Ms. Cynthia Brooks (Multistate Trust) Ms. Kathryn Hinckley (Emhart); Mr. Joseph W. Hovermill (Miles & Stockbridge); Ms. Amanda Kesler (Miles & Stockbridge); Mr. Dan Titus (HRP Vice President); and Mr. Shaun Malin (HRP Regional Manager) HRP ASSOCIATES, INC j 1327 MILLER ROAD. SUITE D, GREENVILLE, SO 29607 | PHONE (864) 289-0311 | FAX (864) 281-9846 s w MNHENIJL N Robenson Joseph Remedial Project Manager USEPA Region 4 61 Forsyth Street SW Atlanta, GA 30303 Re: Kerr McGee Superfund site Dear Mr. Joseph The Eastslde Environmental Council appreciates the opportunity to comment on the September 28^^ 2016, proposed Kerr McGee site cleanup. Thank you for proposing long overdue Kerr McGee site cleanup plan that will help protect our community from exposure of harmful and toxic pollutants. The Eastslde Environmental Council and community residents have waited nearly two decades to see the Kerr McGee legendary site cleaned-up. We are very pleased that EPA has made this site a priority. We also look forward to reviewing your plans to address contamination in Deer Creek. The Eastslde Environmental Council is interested in a job creation program relating to Kerr-McGee site cleanup. The Eastslde Environmental Council would like to work with EPA, FDEP and the Multistate Trust on setting up a program that can help train and employ local Eastslde residents and college students to work on the cleanup of the Kerr McGee site. Best regards, Wynetta Wright The Eastside Environmental Council - 1637 Walnut Street, Jacksonville, FL 32206 (904) 354-5052 | [email protected] | http://www.theeec.org Appendix B Proposed Plan Public Meeting Transcript IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meeting on 09/28/2016 U.S. ENVIRONMENTAL PROTECTION AGENCY KERR-McGEE CHEMICAL CORPORATION SUPERFUND SITE 3 4 5 PUBLIC MEETING FOR PUBLIC REVIEW AND COMMENT ON PROPOSED CLEANUP PLAN 6 KERR-McGEE CHEMICAL CORPORATION (KERR-McGEE) JACKSONVILLE SUPERFUND SITE, 7 JACKSONVILLE, FLORIDA 9 Held on Wednesday, September 28, 2016, at 6:00 p.m., 10 at the Matthew W. Gilbert Middle School Auditorium, 11 1424 Franklin Street, Jacksonville, Florida, as reported by 12 Janice Lynn Carrico, Florida Professional Reporter and 13 Notary Public in and for the State of Florida at Large. 14 15 _ _ _ 16 17 PRESENT: 18 Robenson Joseph, EPA Remedial Project Manager 19 L'Tonya Spencer, EPA Community Involvement Coordinator 20 Cynthia Brooks, Multistats Trust Managing Principal 21 Tasha Lewis, Multistats Portfolio and Project Manager 22 Ty Griffith, Multistats Trust Site Manager 23 Chris Amrhine, Multistats Trust Director of Communications 24 25 _ _ _ www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 2 1 INDEX 2 3 PAGE NO. 4 INTRODUCTORY REMARKS BY MS. SPENCER...... 3 5 OPENING REMARKS BY MS. BROOKS .... 6 6 PRESENTATION BY MR. JOSEPH ... 9 7 COMMENTS AND QUESTIONS BY PUBLIC ... 49 8 CLOSING REMARKS BY MS. WRIGHT ... 87 9 CLOSING REMARKS BY MS. SPENCER ... 88 10 11 12 13 - - - 14 15 16 17 NO EXHIBITS 18 19 20 21 - - - 22 23 24 25 www huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston -- San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 3 1 September 28, 2016 6:00 p.m. 2 MS. SPENCER: Hello. If everyone could 3 take their seat, please, so we can get started. 4 First I'd like to thank you, everyone, for 5 coming out today to this very, very important 6 meeting. We're here today to talk about the 7 Proposed Plan for the Kerr-McGee Chemical 8 Corporation Superfund Site here in Jacksonville 9 and we're happy to be able to make this 10 presentation to you tonight because it means 11 that we are moving forward, and after many, many 12 years we're happy to be able to let you know 13 what we're proposing to do for the cleanup. 14 For those of you who don't know me my name 15 is L'Tonya Spencer. I'm the Community 16 Involvement Coordinator for the Kerr-McGee site. 17 I've been coming back and forth to Jacksonville 18 for about 15 years, since 2001. And the first 19 thing we're going to do is do some 20 introductions. 21 First I would like to introduce our 22 Technical Assistance Grant Group, the Eastside 23 Environmental Coali- -- Coalition. And, 24 Ms. Wright, if you wanted to introduce -- 25 MS. WRIGHT: Eastside Environmental www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 4 1 Council. 2 MS. SPENCER: -- Eastside Environmental 3 Council. 1 got it wrong. 4 Okay. If you could stand and introduce 5 your board. 6 MS. WRIGHT: Yes, it is. Ms. Bean 7 [phonetic], Ms. Haberry [phonetic]. 8 AUDIENCE MEMBER: They're outside. 9 MS. WRIGHT: Oh, okay. 10 MS. SPENCER: No problem. 11 MS. WRIGHT: Okay. They do what they want 12 to do. Okay. The -- this is the board, yes. 13 MS. SPENCER: Okay. So that's the board. 14 AUDIENCE MEMBER: Yes, it is. 15 MS. SPENCER: And also we have 16 representatives here from the Florida Department 17 of Environmental Protection. 18 [FDEP representatives stand, are acknowledged, 19 and resume seats.] 20 MS. SPENCER: Okay. We also have Virgil 21 Degabney [phonetic] here. 22 Are there any other City of Jacksonville 23 representatives present tonight? Would you 24 please stand. 25 [Audience members stand, are acknowledged, and www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 5 1 resume seats.] 2 MR. LUMB: Robin Lumb, (inaudible). 3 MS. SPENCER: I'm sorry? 4 MR. LUMB: Robin Lumb, Office of the Mayor. 5 MS. SPENCER: Okay. Thank you. 6 MR. RICHARDSON: James Richardson, 7 Environmental Protection Board. 8 MS. SPENCER: Thank you. 9 MR. POSTAL: Maurice Postal, City Planning 10 Department. 11 MS. SPENCER: Okay. We also have the -- 12 the Technical Advisor, Mr. Ken Pennix, is here. 13 And, of course, we have some other 14 Environmental Protection Agency representatives 15 present. Would you, please, stand. 16 Folks from the EPA. 17 [Representatives stand, are acknowledged, and 18 resume seats.] 19 MS. SPENCER: Then we do also have our 20 Multitech- -- Multistate Trust present: Cindy 21 and Tasha. 22 [Ms. Brooks and Ms. Lewis stand, are 23 acknowledged, and resume seats.] 24 MS. SPENCER: So what we're going to do is 25 the -- we're going to have opening remarks by www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meeting on 09/28/2016 Page 6 1 Cindy, who's with the Multistate Trust. She's 2 going to do some introductions as well. 3 And, also, please note, if you can, please 4 hold your questions and your comments till the 5 end of the presentation. We do have a 6 transcriptionist here, who will be taking 7 questions and comments and answers to those 8 which will be a part of the Record of Decision, 9 so we want to try to keep it decent in order for 10 her to make sure she can transcribe it 11 correctly. So if you have a question or you 12 have a statement when we get to the 13 question-and-answer portion, please, state your 14 name first and then your question or your 15 comment. 16 So Cindy is going to op- -- do opening 17 remarks and then we're going to turn it over to 18 Robenson to start the presentation. 19 MS. BROOKS: Thank you, Tonya. 20 Good evening. Thank you all for coming 21 out. We are very, very excited to be at the 22 cusp of moving forward with the cleanup of the 23 Kerr-McGee Site. It's been a long time coming, 24 I know, for all of you. 25 I thought I would just take a couple of www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 7 1 minutes and explain what the Multistate Trust 2 is. We are an Environmental Response Trust and 3 we were established by the U.S. Bankruptcy Court 4 of the United States and in the State of 5 Florida. And -- and, essentially, the company 6 that owned and operated the pesticide plant -- 7 plant here on Talleyrand Road -- and Robenson's 8 going to go through all of those details with 9 you -- but -- but they, essentially, ended up 10 filing for bankruptcy, and coming at the 11 settlement that was approved by the Court, it 12 established the Multistate Trust and several 13 other Environmental Response Trusts. We 14 essentially are -- our responsibilities include 15 owning and managing the site and the -- the 16 cleanup funds that were earmarked for the site, 17 implementing the cleanup. And the cleanup 18 plans, of course, are approved by the EPA. The 19 EPA also approves the budgets of the Trust. And 20 then our final responsibility is to facilitate 21 the -- the safe redevelopment of the property. 22 EPA and the Florida Department of 23 Environmental Protection, FDEP, are the two 24 agencies that we are essentially accountable to 25 and EPA approves all the cleanup plans. EPA and www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 8 1 the State of Florida have approval over any sale 2 of Multistate Trust lands. 3 I guess a couple of other things that are 4 worth noting, the Multistate Trust works very 5 closely with the group of stakeholders and 6 representatives from the community that we are 7 very privileged to have an opportunity to -- to 8 work with, including Ms. --Ms. Wynetta, the 9 Eastside Environmental Council/ oh, obviously, 10 the -- the residents of the Eastside community,* 11 the City of Jacksonville,* the Jacksonville Port 12 Authority; Toyota, JM Family. There's a host of 13 stakeholders that are very important to our work 14 and we're looking forward to working with you on 15 implementing this very important cleanup. 16 And with that, I'm going to turn the 17 meeting over to Robenson Joseph. I will -- and 18 I'll just say that Robenson is -- he's the 19 Remedial Project Manager from U.S. EPA Region 4 20 for the Kerr-McGee Site, and in many ways our 21 fearless leader. And so I will turn it over to 22 Robenson and he's going to present the Proposed 23 Cleanup Plan for the Kerr-McGee Site. 24 [Audience applause.] 25 MR. JOSEPH: Thank you, Cindy, for the www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 9 1 introduction. 2 Good evening to you all. 3 AUDIENCE MEMBERS: Good evening. 4 MR. JOSEPH: How -- before I get into my 5 presentation, let me just take a few seconds 6 with -- to tell you -- to say a very special 7 thank you to you all. We were very excited that 8 you are here, and, you know, I understand that 9 you have all the inquiries, you have a whole lot 10 really going on, but I again want to thank you 11 for taking the time out of your very busy 12 schedules to be here with us this evening. 13 Approximately two weeks ago the EPA issued 14 a Proposed Plan for this site, and tonight we're 15 here to discuss our Proposed Plan. And what I 16 would try to do -- and I will probably say most 17 importantly in addition to really discussing the 18 Proposed Plan which is what we plan to do so 19 that we can address the contamination that was 20 found on this site, the most important for -- is 21 going to be for us to hear from you. We want to 22 know what you think. We want to know if there 23 are any questions or any comments or any 24 concerns about the strategy that we have 25 available to address the contamination that was www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 10 1 found on this site. And, again, your opinion 2 will be extremely valuable to us, and we need 3 your participation. 4 Here is the agenda that 1 will try to cover 5 during my presentation. 6 [PowerPoint presentation being shown on screen.] 7 MR. JOSEPH: I will touch on some very 8 basic background information about the Site. 9 Secondly, 1 will discuss the Remedial 10 Investigation that was performed on the Site as 11 well. Next 1 will discuss the Feasibility 12 Study, which is, basically, the process where we 13 try to identify our goals and objectives and 14 certainly evaluating different options that we 15 believe can, quote, effectively and aggressively 16 address in the Site. 17 And, more importantly, again, we will spend 18 a little bit of time discussing the proposed 19 remedy, which is the plan that was included in 20 our document that we issued about two weeks ago 21 outlining all the steps that we're planning to 22 take so that we can address the contamination of 23 the Site. Lastly, 1 will touch on some very -- 24 on some highlights of the Public Comment Period. 25 Well, we know that old saying, A picture is www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetinson 09/28/2016 Page 11 1 worth a thousand words. What I intend to do 2 with this picture here (indicating) is, using 3 very few words, to walk you all through the 4 approximate location of the Site, the Site 5 district, and its description, and, certainly, 6 the conditions the Site is actually in today and 7 what we plan to do in the future. 8 The figure that we have on the lower left 9 corner of the Site is an aeri- -- aerial 10 photograph. As we all can see the property is 11 located directly adjacent to the St. Johns 12 River, right in here. The property to the north 13 is owned by JAXPORT, however, it is currently 14 leased to JM Family Enterprises where it is 15 currently used for staging, processing, and 16 distribution of cars. 17 Down south is an eight-acre parcel that is 18 wholly woo- -- wooded and it is currently owned 19 by CSX. Further south is Deer Creek, Jones 20 Chemical, and Crowley Interna- -- Crowley Marine 21 is located right here. To the west of the 22 property we have Talleyrand and a lot of 23 additional commercial and industrial facilities. 24 But what I -- what I also wanted to emphasize on 25 that figure is the fact that although the area www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 12 1 near the Site is primarily used for commercial 2 and industrial purposes we also have some 3 residential properties that are located 4 roughly -- I'll probably say less than a quarter 5 of a mile from the Site. So, yes, the area is 6 primarily used for commercial and industrial 7 purposes, but there are also some people living 8 nearby. 9 The next thing that I want to do -- still 10 focus- -- focusing on that figure right here -- 11 is to walk you through a little bit about the -- 12 you know, I've just covered the description,* now 13 I want to talk a bit about the history and 14 operations on this Site. 15 Oh, let's go back up to the Site -- the 16 Site Plan and diagram, please. 17 Well, as you can see right in here the -- 18 all of those features that are all in white, 19 they are the former features that were on the 20 property when the facility was in operation back 21 in 1893. Well, right in this area here, which 22 is, basically, the northwest central portion of 23 the Site, that's where pesticides manufacturing 24 operations were conducted. And what I -- the 25 reason I bring that up is because it's going to www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 13 1 be of real importance or real interest when I 2 talk to you a bit about what we will do to 3 address the contamination. This area here where 4 the former FASCO and Herbicide buildings are 5 located at, that's where the pesticides 6 operations were primarily conducted starting in 7 the 1893. Wastewater from the pesticide 8 manufacturing processes were discharged right in 9 here in that som- -- former Surface Impoundment. 10 And, again, I bring that up because we believe 11 based on all the investigation that we have 12 conducted, this area is one of what we call 13 "source areas." These are the areas where based 14 on results of our investigations we have found 15 the highest concentration of contaminants in 16 soil and in groundwater. It is an area of 17 special interest. 18 In addition to this area here where the 19 pesticide manufacturing operations were 20 conducted, right down here in the southeast 21 corner of the property that's where the 22 fertilizer manufacturing operations were 23 conducted. And right up here in the northeast 24 corner of the property sulfuric acid used to be 25 produced right in that area. The figure on the www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 14 1 upper right corner, all I wanted to show here is 2 the existing conditions of the Site. 3 Like I said, operations were -- operations 4 started back in 1893, however, by 1978 all 5 manufacturing op- -- operations were stopped and 6 all the buildings that were on the property, 7 they were all demolished. And as of today all 8 we have left is just these two foundations. 9 That's where the former FASCO building was 10 located at and the Herbicide building. 11 And, again, I will keep empha- -- 12 emphasizing on those two buildings because based 13 on the re- -- on results of our investigations 14 that's where we -- we have -- we have found most 15 of the contamination. But that doesn't mean 16 that the rest of the -- of the property is -- is 17 clean, by no means. That's not what we're 18 trying to convey here. But based on what we 19 know this area here is where the highest 20 concentrations in soil and groundwater were 21 mainly observed. 22 And, la- -- lastly, that figure on the 23 lower right-hand corner, I'm not going to spend 24 too much time on that right now because further 25 down it will come up, and all I will say is www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 15 1 that's where we're looking at -- that's where 2 we're looking to land. We've talked about the 3 former operations of the building or of the 4 property. We talk about the existing 5 conditions. Then, obviously, if we're proposing 6 to do something then we -- you know, things 7 would change and how we will change them. 8 What I want to point your attention to here 9 is when I talk about the operations and -- of 10 the manufacturing operations that were conducted 11 at the facility I kept on referencing to this 12 area right here, the former FASCO and Herbicide 13 buildings. As you can see right in here these 14 are the areas where we're planning on 15 aggressively really addressing the 16 contamination, again, because that's where we 17 believe the source of the contamination is 18 found. 19 Let's move to the next slide. 20 The next slide is something else, but like 21 I said at the very beginning, I wanted to touch 22 on some very basic background information on the 23 Site. Most of this -- what is saw on that slide 24 I -- we have touched somewhat on those, but some 25 of them are worth repeating. The Site is www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meeting on 09/28/2016 Page 16 1 located at 1611 Talleyrand Avenue in an area 2 that is heavily used for industrial and 3 commercial purposes/ however, yes, there are 4 also residences west of Westcott Street, 5 approximately a quarter of a mile from the 6 property. 7 The 30- -- the 31-acre property was 8 utilized as a pesticides and manufacturing 9 facility from 1893 to 1978. All the buildings 10 that were on the facility or on the Site are all 11 demolished except for the foundations of two 12 former buildings. The property is vacant. It 13 is unoccupied, however, it is fenced in in order 14 to prevent unauthorized entry. 15 Operations and disposal practices did 16 result in the contamination of pretty much all 17 media of the property: Soil, groundwater, 18 surface water, and sediment at the St. Johns 19 River, and we also believe that operations 20 outside did contribute to the contamination in 21 Deer Creek. 22 And then they have, what are we looking at 23 and how do we plan to move forward? And what I 24 want to emphasize now is the fact that because 25 of the uncertainties associated with the -- the www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 17 1 delineation of the contamination in Deer Creek 2 we have decided to divide the Site Remediation 3 into two Operable Units or two Phases. The 4 first Phase, that's where we will focus mainly 5 on soil, the groundwater, the sediment, and 6 surface water in the St. Johns River. And then 7 cleanup and remediation of Deer Creek will be 8 Phase 2 or Operable Unit 2, which should be 9 coming up in the very near future. 10 Well, just as anything else in life -- and 11 I think that's probably true on a daily basis, 12 when we're faced with a problem, with a 13 challenging situation, what do we do? We all go 14 back and say. Well, what are the sources of that 15 problem? What is the mag- -- what is the 16 magnitude of that problem and how do I address 17 it? It's more or less the same thing for the 18 Superfund member process. We knew starting back 19 in 1893, the property was utilized as a 20 pesticides and fertilizer manufacturing 21 facility, and we must know that housing pra- -- 22 practices, disposal practices, and everything 23 else did contribute to contamination of the 24 property. So we know we have a problem. 25 So now what do we do? The first step that www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 18 1 we -- we took was to perform the Remedial 2 Investigation. The objectives of that Remedial 3 Investigation were twofold/ one, to define the 4 nature and extent of the contamination, and, 5 two, to assess the potential risks from exposure 6 to that contamination. 7 Remedial Investigation starting back in the 8 1984 all the way to 2008, the responsible party, 9 Kerr-McGee, subsequently Tronox, which is the 10 successor of Kerr-McGee, performed several 11 environmental investigations at the Site. Those 12 investigations were performed under the 13 oversight of the FDEP and EPA. And the primary 14 activities that were conducted during the 15 Reme- -- Remedial Investigation consisted of, 16 one, sampling and analysis. Sampling and -- 17 during the sampling and analysis phase, I -- I'm 18 quoting that -- what we did then is we went out 19 and collect soil samples from all media. I 20 mean, we collect the samples from all media,* 21 from soil, groundwater, pore water, and surface 22 water samples were collected. Those samples 23 were sent to a -- the laboratory for analysis, 24 and based on the results from the laboratory it 25 did turn out that all media were impacted or www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 19 1 contaminated primarily by the pesticides and the 2 metals/ however, we had some VOCs, SVOCs, and 3 some radioactive materials that were also found 4 on the Site. 5 In addition to the sampling and analysis 6 step that was taken during the Remedial 7 Investigation, we also conducted some 8 Hydrogeological Investigation, and the primary 9 objective of that was so that we may have a much 10 better handle or much better understanding of 11 transport and the kind of -- to see -- so that 12 we can know how far and how that contamination 13 or the contaminants will travel from soil to the 14 groundwater and once reaching the groundwater 15 where does it go? We had to find that out, and 16 that is exactly what we did when conducting the 17 Hydrogeological Investigation. 18 We drilled some holes and tried to 19 represent exactly what kind of sediment is on 20 the property. We did find some sand, some silt, 21 and also some clay was in the sediment. 22 Next, how do we understand how far does 23 that contaminant -- does -- that those 24 contaminants would have traveled and where is 25 the -- the groundwater level and what direction www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 20 1 does it flow and how fast does -- does it flow? 2 All of these were part of the Hydrogeological 3 Investigation that was conducted, and based on 4 what we know we have found that groundwater at 5 the Site is generally found at a depth ranging 6 from two to ten feet below land surface. And we 7 also know that the groundwater at the Site is 8 primarily flowing towards the river/ however, 9 there is a component of that flow that goes also 10 towards Deer Creek. 11 Lastly, like I said earlier, the Remedial 12 Investigation process or the objectives of the 13 Remedial Investigation were of twofold: To 14 define the nature and extent of the 15 contamination, and, next, to assess the 16 potential risk to exposure to that 17 contamination. That's what we did there under 18 the Risk Assessments. 19 What we did was perform both Human Health 20 and Ecological Risk Assessments so that we can 21 then figure out whether or not exposure to that 22 contaminant, if that will result in any 23 unacceptable risk to health. 24 Next slide please. 25 The next couple slides I'm going to show www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 21 1 you I'm probably not going to be spending too 2 much time on them for as they are just figures 3 showing the extent of the contamination, how far 4 does it go, and that was, basically, just based 5 on all the samples that have been collected. 6 This figure here, it shows the extent of 7 the contam- -- of -- of the contamination in 8 soil, and we use two different criteria to 9 define the extent of the contamination in the 10 soil for this particular Site. Because of what 11 we know in terms of potential future use of the 12 Site we found that we de- -- determined that -- 13 that it made sense for you to compare the data 14 that we collected with the soil cleanup 15 standards from FDEP based on commercial and 16 industrial future use. And that's exactly what 17 that figure shows. As you can see, I would 18 probably say about 60 to 70 percent of the 19 property is impacted. 20 Next. 21 Now, comparing the data with another set of 22 criteria based on leachability of the 23 groundwater, basically, the overall concept here 24 is, well, we know we have contaminants on the 25 site and also there is that possibility that by www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 22 1 doing nothing then when it rains the rainwater 2 would have a tendency really to go -- obviously, 3 reach the ground and then the contamination or 4 the contaminants that are in the soil will have 5 the tendency really to be dragged down into the 6 groundwater, so FDEP has a whole different set 7 of standards that says that, well, the 8 concentration of your contaminants in your soil, 9 they have to reach a certain level that would be 10 acceptable, this way we will know for a fact 11 that the contaminants will not be leaching into 12 the groundwater and resulting in contamination 13 of the groundwater. 14 What did we find? We found that pretty 15 much the entire property is, quote-unquote, 16 contaminated based on that leachability 17 standard. 18 Next slide. 19 This slide here is just sort of a slide 20 showing the extent of the contamination, the 21 extent of the sediment contamination in the 22 St. Johns River. It's just that shaded area 23 here. Again, that is based on samples that were 24 collected/ sediment, pore water, and surface 25 water samples, then we determined that, yes. www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 23 1 that is the extent of contamination in the 2 river. 3 (Indicating. ) 4 This slide here, all it shows is the extent 5 of the contamination of the groundwater. We 6 have two different iso-contour lines. I call 7 them "iso-contour lines." Basically, it's just 8 lines and then we're showing, well, how do we 9 get there? Then just Re- -- we sit back and go 10 quickly, during the Remedial Investigation we've 11 also installed a number wells on the property. 12 I believe we have somewhere around 60 to 65 13 wells at the property, and from those wells we 14 collected groundwater samples. Those samples 15 were analyzed and we got the results. And based 16 on the results of those groundwater samples we 17 found out that, basically, as you can see, 18 grou- -- groundwater at the entire Site is 19 contaminated. And I have those two iso-contour, 20 the lines, here,* what I'm trying to show is when 21 we did the -- when we performed the 22 Hydrogeologic In- -- Investigation it did turn 23 out that on -- for this Site, like I said 24 earlier, groundwater is generally found at a 25 depth ranging from two to ten feet. However, www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 24 1 those wells that we have installed -- installed 2 on the Site they will screen at different 3 depths. We have some wells that screen in the 4 shallow zone, which we estimate to be anywhere 5 between two up to about thirty or 6 twenty-five feet below land surface. And we 7 have found also what we called the "intermediate 8 zone" which is right below the shallow zone, and 9 the depth of that ranges from twenty-five, 10 thirty all the way down to about forty-five 11 feet. 12 And then also we did further characterize 13 that groundwater by collecting additional 14 groundwater samples that will be deeper to find 15 out where we were at, if the contamination had, 16 you know, went any deeper than that. And based 17 on all the samples that were collected the 18 contamination was primarily contained in the 19 shallow and the intermediate zone, meaning that 20 from about two all the way down roughly to about 21 forty-five feet below land surface. 22 And those two iso-contour lines that I'm 23 showing here, the purple one is kind of the 24 overall extent of contamination in the shallow 25 zone, and then the orange line shows the extent www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 25 1 of contamination in the intermediate zone. 2 Well, I think I spent quite a bit of time 3 on the Remedial Investigation. And we get that 4 nailed down pretty much at that point. We have 5 all the data that we need. We have a lot of 6 information. We know the Site is contaminated. 7 We know the extent of the contamination. We 8 also performed the Risk in -- Ecological Risk 9 Assessment. We also know that these people or 10 e- -- ec- -- ecological receptors would come 11 into contact with contaminating media. There 12 was our potential risk. 13 So now knowing that information, what do we 14 do next? Well, I spoke -- the Superfund 15 process, the very next step is to perform what 16 we call a "Feasibility Study." The primary 17 objectives of that Feasibility Study is, again, 18 two -- twofold: One, we develop what we call 19 "Remedial Action Objectives." Basically all 20 that means is knowing all that we know, knowing 21 all the potential re- -- for -- for ecological 22 receptors to come into contact with contaminants 23 we said. Well, let's try to describe and find 24 out how we put a system in place so that we -- 25 will -- we can really accomplish or reach the www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meeting on 09/28/2016 Page 26 1 point that -- where we can minimize or even 2 eliminate all of those risks that were 3 identified during the Remedial Investigation 4 process. 5 Next. 6 Let's go back. Go back up. Go back up. 7 Okay. And once -- after -- then what we 8 can do with the Remedial Action Objectives, the 9 second part of Feasibility Study process is also 10 to identify and compare Remedial Options that 11 are capable of achieving those Remedial Action 12 Objectives. 13 We -- well, what we did, we spent quite a 14 bit of time looking at the information that we 15 have, looking at the data and knowing that there 16 were some risks associated with exposure to the 17 property or to the contaminants, and we said, 18 What are we doing to do? How do we -- how do we 19 deal -- how do we deal with this? How do we get 20 to this at the foundation? And I will tell you, 21 it was a challenge because based on what you 22 have heard so far and knowing that you-all, the 23 community, you know this is not a simple Site, 24 you know this is not a Site where we can just 25 get up one morning and walk out there and the www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 27 1 next morning it's all done and it's all -- it's 2 all -- you know, it's all disappeared. Now, it 3 is complex. And, obviously, complex problems 4 they do require complex solutions. 5 We spent a little time trying to figuring 6 out exactly what do we do, and based on that we 7 developed a number of Remedial Options. 8 Basically, those are. Okay, how do we deal 9 with it? How do we combine these? How -- 10 et cetera, et cetera. So during that 11 Feasibility Study what we did, again, we 12 developed Proposed Remedial Actions so that we 13 can address the contamination in all the media: 14 Soil, groundwater, and sediment. Those Remedial 15 Actions were grouped into four main categories, 16 including removal. Well, I think that word 17 speaks for itself. Removal means coming out -- 18 in the case of soil, for instance, dig it up and 19 dispose of it off-site. Containment or 20 isolation. Containment or i- -- isolation, 21 basically, what we figured then we will do at 22 that point is either physically or somehow by 23 putting in a covenant system or installing 24 some -- and putting some, you know, physical 25 features so that we can pre- -- prevent contact www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 28 1 with that contaminated media, whether it's soil, 2 the groundwater, or the sediment. 3 Ex-situ treatment. Ex-situ treatment is, 4 basically, the first way -- again, I'm going to 5 use soil as an example. If you know that you 6 have soil that is contaminated and you say that 7 you want to treat it utilizing some ex-situ 8 treatment technology, what that means that is 9 you'll go in and mostly likely excavate that 10 soil that is contaminated and then treat it. 11 After the treatment you can either use it as 12 backfill material or you dispose of it off-site. 13 Lastly, in-situ treatment, again, that word 14 speaks for itself. At that point what we do 15 knowing where the contamination is located at, 16 we don't go in and excavate it or anything,* we 17 treat it right where it is in place. 18 Well, it is required -- it is one of the 19 requirements of the Superfund law once you have 20 developed all of those Remedial Options you 21 can't just sit back and look at those options 22 and say. Oh, yeah, that one looks pretty good, 23 why don't we just move forward and just 24 implement that. 25 No. It's -- that's not the way it works. www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 29 1 We are obligated to really spend some additional 2 time and compare those options side by side, and 3 that comparison is based on a very prescribed 4 set of criteria that we usually call the "Nine 5 Criteria." The first one is overall protection 6 of human health and the environment. Well, 7 that's what we do. That's our mission. As the 8 EPA, our job, our responsibility is doing just 9 that: Protecting human health and the 10 environment. We will -- never will consider a 11 re- -- a cleanup strategy if we don't feel 12 confident that we will achieve that objective, 13 which is, again, protecting human he- -- health 14 and the environment. 15 Second, compliance with ARARs. It is a 16 mouthful. Basically, all it means is any 17 technology or any cleanup remedy that we decide 18 to select we have to make sure that it is in 19 compliance with all of our federal, state, and 20 local regulations. 21 Long-term effectiveness and permanence. 22 For selecting a remedy, that -- our mission, 23 basically, all we do here is we look at all of 24 these different options,* you ask yourself when 25 it's all said and done will there be some www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetinson 09/28/2016 Page30 1 residual contamination that will be remaining at 2 the Site? And is that remedy that you're 3 implementing, is it a permanent or a temporary 4 patch that you're putting in? Again, that is 5 one of -- of the criteria that we use to 6 evaluate and to compare all of the options that 7 were identified during the Feasibility Study. 8 Reduction of mobility toxicity by -- 9 through -- through treatment. That's another 10 requirement where we compare all the options and 11 see how much material that we can really treat. 12 And -- and, again, it's really somewhat 13 self-explanatory here, that whatever remedy that 14 we end up implementing we have to ensure that it 15 prevents where the contamination go -- keep on 16 moving, yeah, and keep on spreading. 17 And the next requirement is short-term 18 effectiveness. There what we're looking for 19 here is to ensure that we evaluate the potential 20 negative impacts that any remedy that we 21 implement will have either on the community and 22 the people who will be working at the Site, and 23 that is mainly during the construction of that 24 alternative. 25 Implementability, what we look at in www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetinson 09/28/2016 Page31 1 that -- at that point is if we were to select 2 the specific technology how complex is it? Are 3 the equipment readily available? Will it take a 4 super long time to get where -- what we need 5 from a vendor, et cetera, et cetera? So mainly, 6 like it says here, it is an evaluation of our 7 ability to con- -- construct and to operate the 8 remedy that we choose to implement. 9 Cost. We all know that cost is always a 10 factor in anything that we do. At home we would 11 say that's -- that's co- -- that cost is one of 12 the criteria that we use to evaluate and to 13 compare our Remedial Options. 14 Lastly, State and the community acceptance. 15 I know I do not live in Jacksonville. I live in 16 Atlanta. I am not really just going to come 17 from Atlanta and say. That's what we need to do 18 and that's how we're going to do it. No. Your 19 input is extremely valuable to us, and, 20 obviously, that's why we're here. So prior to 21 really selecting a remedy your input, we think 22 that that helps and we want you to participate 23 and to work with us on that. If you don't tell 24 us what you want we won't know it, and probably 25 by then it will probably be too late because it www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetinson 09/28/2016 Page32 1 will be done. So, please, work with us. 2 Provide us with your input. We want to know 3 what you think about the strategy that we are 4 proposing. Your participation, again, is 5 extremely important to us. 6 Well, we spent quite a bit of time talking 7 about Remedial Investigation. We talked about 8 Feasibility Study. 9 Here is the real deal. What are we going 10 to do? I wish we -- like I said at the very 11 beginning, about two weeks ago the Agency issued 12 a Proposed Plan and in that Proposed Plan there 13 was a section that went into great detail, 14 talked a whole lot about the overall strategy of 15 what we're going to do or how we're going to do 16 it, et cetera, et cetera. That's what we're 17 going to do tonight again. I will go over all 18 the primary components of the strategy that we 19 are considering implementing at the Site. 20 And, again, one thing that I want to say 21 is, yes, that's our position to you. We need 22 your feedback. We need your input. 23 So, what's the first component? What we're 24 proposing to do is first -- you know what, I'm 25 going to get down because it's kind of important www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetinson 09/28/2016 Page33 1 that you can see the screen from up -- up here. 2 The first component of that remedy is -- 3 well, let me say one -- one more thing, though. 4 We're going to go through the text right there, 5 but at some point we also have a figure that 6 will somewhat summarize all of the components of 7 the remedy that we're proposing to implement at 8 the Site. 9 First, we are looking at excavating and 10 then dispose off-site of what we call the 11 "Principal Threat Waste." I'm not going to get 12 into too many de- -- details, because there's 13 all -- tons of technical terms associated with 14 that word or with those three words. Principal 15 Threat Waste. In, you know, everyday terms I 16 would say those are nothing else but the areas 17 or part of soil that are heavily contaminated. 18 And, again, based on what I said earlier at the 19 beginning, we have some specific areas 20 particularly right next to the FASCO building 21 where we know that the pesticides and herbicides 22 manufacturing operations were conducted, this is 23 one of the areas where we know we have highly 24 contaminated material, and it is exactly from 25 the surface -- the former Surface Impoundment www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetinson 09/28/2016 Page34 1 area/ and also there is another area on the 2 southeast corner of the property, that's where 3 some of the radioactive materials were found. 4 We also propose excavating those two areas and 5 dispose of that off-site. 6 What else do we say we are going to do? 7 Based on the result of a -- of the investigation 8 we know there is some contamination on the CSX 9 property. What we propose to do is to exca- -- 10 excavate the contaminated soil from the CSX 11 property and bring that material on the Tronox 12 property because we already know that there were 13 some areas that were already impacted and we 14 will take that soil from CSX property and put it 15 on the Tronox property. 16 Next we will install what we call a "Low 17 Permeability Cap." The goal here is, like I 18 said earlier, during the Remedial Investigation 19 we needed to know how the contaminants would 20 travel from the soil into the groundwater, and 21 we have seen that happening,* obviously, that's 22 why the groundwater at the Site is contaminated. 23 What we said we will do to minimize or even to 24 eliminate that from keep happening, we will 25 install a cap over the entire property. This www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetinson 09/28/2016 Page35 1 way when it rains the rainwater is not going to 2 keep on percolating into the soil and washing 3 down the contaminants from the soil to go into 4 the groundwater. 5 Here we have the next thing we will do, we 6 will implement the technology called "in-situ 7 stabilization and solidification." It is a 8 mouthful. ISS. What does that entail? In a 9 very brief -- brief term, what that actually 10 entails is the soil that is in the saturated 11 zone from the point where the groundwater is at 12 that's mainly where the contaminants really are 13 le- -- really are leaching from the soil into 14 the groundwater. The source area, the areas 15 next to the FASCO building, the area next to the 16 Herbicide building, the area where we have the 17 former Surface -- Surface Impoundment where 18 wastewater from manufacturing operations used to 19 be discharged, those are the areas where, again, 20 we know that are the source of the groundwater 21 contamination. What we said we want to do, we 22 want to mix that soil with some sort of 23 material, primarily something like cement, so 24 that we can make it just -- you know, it 25 would -- a piece of rock, and then at that point www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meeting on 09/28/2016 Page 36 1 the contaminants that were initially in that 2 soil will stop leaching into the groundwater. 3 Next, we also know, like I said at the 4 beginning, the contaminated groundwater as 5 is now is flowing towards the river, yes. 6 Ground -- contaminated groundwater is currently 7 discharging into the river. What -- as part of 8 our Remedial Action Objectives we said we need 9 to prevent that from happening. That's why we 10 are implementing or installing the 11 pump-and-treat system. And what I did with my 12 figure I will show you more or less where I 13 believe that system will be -- will be placed. 14 But the goal there is to really at the -- 15 install a series of wells and the contaminated 16 groundwater will then be extracted, treated, and 17 disposed of to prevent really that contaminated 18 groundwater to -- from discharging into the 19 river. 20 Next we say -- again, let's go back to 21 concept. We've seen the figure where we know 22 and we have identified what we're calling 23 "source areas." Those are the areas that we 24 believe we need to deal with them in a very 25 aggressive manner. That's why we are www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetinson 09/28/2016 Page37 1 implementing that ISS. However, there are some 2 other areas where we know we have contamination, 3 however, the concentrations of that 4 contamination is somewhat moderate or at a very 5 low level/ because of that what we said we will 6 do - - and also based on data that we have,* we 7 have been collecting samples -- groundwater 8 samples at the Site for a number of years. We 9 have been analyzing the data. We have been 10 looking at it. And based on what we have seen 11 we have a little bit of a trend where we have 12 been observing that concen- -- concentrations of 13 contaminants in the groundwater outside of the 14 source area is really working in our favor. 15 They are going down. That's a process -- that's 16 a good thing. And because of that observation 17 we are turning that by implementing a less 18 aggressive technology called "na-" -- "monitored 19 natural -- natural attenuation" that should 20 really help us to clean up the residual 21 contamination found on the JAXPORT and CSX 22 property as far as the groundwater is concerned. 23 We are not talking about the soil here,* strictly 24 the groundwater. 25 Next, the sediment, we know there is some www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetinson 09/28/2016 Page38 1 contaminated sediment in the river directly 2 adjacent to the property. What we are proposing 3 to do is to install what we call a "bulkhead" or 4 "seawall." Basically, it's just to build a 5 structure where we will be able to contain that 6 contamination -- that contaminated sediment to 7 prevent in- -- contact with contamination. 8 Well, if you implement -- if you do all of 9 those things, if you implement all of your 10 remedies, well, there's got to be some 11 reconnaissance really to check on what you've 12 done and find out what was -- well, how good 13 would it be if you were just to go away and do 14 all the things and -- and then say. Oh, all 15 right, that's it, we're done, good-bye? No. 16 There's got to be a way to check that remedy 17 that has been implemented to find out whether or 18 not it's operated or if it's achieving your 19 goal. That's why we're proposing to implement 20 what we call a "long-term groundwater sampling 21 and monitoring." Over a long period of time we 22 will keep on collecting groundwater samples just 23 to see how the groundwater is behaving, how 24 the -- our implementation is behaving, if our 25 expectations are being met. www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetinson 09/28/2016 Page39 1 And, lastly, this is more somewhat of an 2 administrative part of things, and what we said 3 we will do also is we know after all of what we 4 have said we're going to do, well, the Site is 5 not going to be -- be cleaned up overnight or 6 the next day for that matter. So after we have 7 implemented all of those reme- -- all -- all of 8 that remedy that we propose to implement there 9 will still be some contamination of the Site, so 10 because of that we will implement what we call 11 "institutional controls." Those are nothing 12 else but the -- the kind of things that we want 13 to put in place to prevent people being -- to 14 come in contact with any residual contamination 15 that is left at the Site after the construction 16 of the remedy. 17 Lastly, we know that there is some surface 18 water contamination at the Site. After doing 19 all those things that we want to do for -- to 20 address the soil, groundwater, and the sediment, 21 we also want to monitor the surface water to 22 make sure that implementation of all of those 23 technologies and of our overall remedy is also 24 effective in addressing the surface water 25 contamination. www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 40 1 And that's what I was talking about earlier 2 when I said that I would have a very nice figure 3 again summarizing all the components of what we 4 call the "Preferred Remedy" or the remedy that 5 we're proposing to implement at the Site. 6 All right. Let me take a deep breath here 7 and see if I can walk you through this one. 8 Well, it's nothing else -- it's a si- -- the 9 over- -- overview of the Site that I touched on 10 just a little while ago. Let me go in order 11 there. 12 First, we said we will excavate the 13 prins- -- in -- dispose off-site the Principal 14 Threat Waste Materials. These two areas here, 15 right here is where -- is where the former 16 Surface Impoundment was located at. We know 17 based on our investigation that this area is 18 heavily contaminated. And down here also based 19 on our investigation we know that there is some 20 radioactive contamination or some radioactive 21 materials right here on the southeast corner of 22 the water. We call these "Principal Threat Risk 23 Materials" and these materials will be excavated 24 and disposed off-site. 25 Now, let's talk about the soil www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 41 1 contamination that was found on both the JAXPORT 2 and the CSX property. For the contamination 3 that was found on the CSX property, as I said in 4 the previous slides, what we're proposing to do 5 is to excavate the contaminated soil and bring 6 it on-site in an area where we know we already 7 have contamination. Next we also will cover -- 8 I mean, obviously, there will be some grading 9 done on bringing things really to level, 10 et cetera, et cetera. And then after that as 11 far as the soil is concerned, we did all of 12 that -- well, if we're -- we were not to do 13 anything in terms of -- and just leaving things 14 just the way they are, when it rains the 15 rainwater will just keep on really just, you 16 know, driving the contaminants from the soil 17 into the groundwater. We want to prevent that. 18 We want to eliminate that. What we're proposing 19 to do in order to achieve that is to install 20 that Low Permeability Cap over the entire 21 property. And that is that green line that 22 you're seeing here. That's what we're trying to 23 show right here, covering the entire property. 24 And let me just touch brief- -- briefly, 25 what we mean by, you know, "Low Permeability www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 42 1 Cap." There are so many different ways we 2 could look at that or certain ways to interpret 3 it, but during our Feasibility Study process, 4 well, we had to come up with some cost estimate. 5 Then at that point we said. Well, what if we 6 were to install some liner -- plastic liner at 7 some level and then backfill it with some -- you 8 know, some soil, primarily a soil material that 9 has very low permeability, and, certainly, some 10 topsoil and some grass to cover, that's what we 11 use -- that's the approach we use for cost 12 estimating purposes. However, when we get to 13 the Remedial Design and the Remedial -- the 14 Remedial Action, so we intend to work very 15 closely with whoever is interested in acquiring 16 the property. 17 Well, any takers? 18 Okay. Anyway, so, yes, we plan to work 19 very closely with anybody who's interested in 20 acquiring the property to really design and come 21 up with a--a--a--a system or a cap system 22 that will achieve all of our objectives: Number 23 one, certainly preventing, you know, evaporation 24 of con- -- of contaminants of the soil and the 25 groundwater, and also achieving the needs and www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 43 1 objectives of whoever is acquiring and wants to 2 redevelop the property. So we will work with 3 the -- the future owner of the property on that 4 front. Now, that was the soil remedy. 5 What are we proposing to do for the 6 sediment? We know there's contamination of the 7 sediment right in here. Like I said earlier, 8 we're going to install a bulkhead to contain the 9 contaminated sediment. And there are a few 10 things that I want to touch on very quickly 11 related to that. As you can see we're proposing 12 to install that bulkhead somewhere in that area 13 right here. And there are several reasons for 14 that. Number one, we will be required to by, 15 you know, probably the St. Johns River or even 16 the Army Corps to -- to stay a ways from 17 where -- from the navigation channel. We don't 18 know exactly what we're going to -- what the 19 percent of it it would be or how far we would 20 need to be, and if we estimate that we probably 21 need to be somewhere in that area. 22 So now if that bulkhead were to be 23 installed where we think it's going to be 24 installed there will be some, you know, a small 25 section where contaminated sediment will still www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 44 1 be in the river, so what we propose to do is to 2 dredge that still -- that area of contamination, 3 well, right in here east of the bulkhead and 4 bring that contaminated material over on the 5 other side so that it will all be -- be 6 contained. 7 Now, groundwater, what we propose to do for 8 the groundwater is -- and, again, implementing 9 that ISS right here in these areas which we call 10 the "source areas" where we know where we have 11 found the highest concentrations of our 12 contaminants in the ground and the soil and the 13 groundwater, these are the areas where ISS will 14 be implemented. As you can see it's mainly 15 nearby the former FASCO building, right by the 16 former Surface Impoundment, near the former 17 Fertilizer building. In addition to these 18 areas, there is also that area all the way down 19 here to the east of the property and that's 20 where the former Sulfuric Acid Plant was located 21 at. Based on our investigation we have found 22 that we have a fairly high level of arsenic 23 contamination in this area. That's why we were 24 also proposing to implement that ISS so that we 25 can address that contamination. And, like I www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 45 1 said earlier, we do know that the groundwater 2 flows from Talleyrand Avenue towards the river. 3 If we were to do everything as I -- like we said 4 we were going to do and said -- you know, as -- 5 and, as I said, well, there will still be that 6 possibility that -- that residual groundwater 7 contamination then will keep on flowing towards 8 the river and destroying that. We do not want 9 that to keep on happening. 10 What do we propose to do? That's where the 11 pump-and-treat system comes into play. We 12 propose to install a number of wells at some 13 distance from the river and the objective there 14 is to keep on pumping the contaminated 15 groundwater, preventing it from -- to discharge 16 into the river. Once we pump the contaminated 17 groundwater we will treat it and dispose of it 18 through a se- -- through the sewer system. 19 Don't get me wrong here, because JEA has some 20 very strict requirements that we need to meet/ 21 we cannot just take it and discharge it into the 22 sewer. We will be required by JEA to treat that 23 groundwater -- contaminated groundwater that we 24 extract from the subsurface. 25 And, finally, I don't know if there's www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meeting on 09/28/2016 Page 46 1 anybody here from JAXPORT. I don't think I see 2 anybody. Yes, there is some contamination of 3 the soil in the JAXPORT property. But the good 4 news is, as of now, nobody really comes in 5 contact with that contaminated soil. And we 6 don't want to be too intrusive. We don't want 7 to cause too much maybe -- what's the word I'm 8 looking for here -- we -- we know JM Family and 9 Toyota, they are right next-door. They have a 10 very extensive operation going there. We don't 11 want to be overly disruptive. What we're 12 proposing at least now to do -- and I'm hoping 13 and believe and I ac- -- I'm -- I actually pray 14 that JAXPORT will be okay with us just to move 15 on and not be excavating that soil because we're 16 trying not to be too -- cause too much of a 17 burden for Toyota. What we're proposing to do 18 is just keeping that cap and make sure that it 19 is maintained, no cracks in it, no damages, 20 because if it were to be damaged, if it were to 21 be cracked, again, when it rains the water -- 22 the rainwater would have a tendency to go 23 through those cracks and potentially keep on 24 driving any contaminants that could have been in 25 that soil into the groundwater. We don't want www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 47 1 to see that happen and that's why we were 2 proposing as part of the remedy, yes, there is 3 no direct contact with that soil as we speak and 4 we want to keep it just the way it is. 5 Well, how did I do? I think pretty okay, 6 right? 7 [Audience applause.] 8 MR. JOSEPH: Ah, now, but I'm not done yet. 9 I saved the last -- the best for last on this. 10 Well, this is -- well, just, again, as I said at 11 the very beginning, just some very quick 12 highlights on the Public Comment Period/ as you 13 all know I said at the very beginning, we issued 14 the Proposed Plan for the Site about two weeks 15 ago and we have what we call a "30-Day Public 16 Comment Period" that will run from September 17 the 12th to October the 12th. And what we are, 18 please, asking for you all is to take a little 19 bit of time to look at that -- that Proposed 20 Plan and at that point if you have any 21 questions, any comments, any concerns -- if you 22 don't say anything now do not say anything 23 forever. 24 I am kidding. 25 No. You will still have the opportunity to www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 48 1 submit your written comments to me by -- either 2 by mail or by e-mail, any way you want to. 3 There will be -- it will be welcome. But the 4 only thing is, please, submit that -- those 5 comments to us no later than October the 12th 6 of -- I mean October the 12th, this year. And 7 our plan is to address all the comments that we 8 receive from you all in what we call the 9 "Responsiveness Summary," which will be included 10 in our Record of Decision. And that Record of 11 Decision is the actual legal document that -- 12 that will document what we will be -- we will 13 do, how we will address the Site contamination. 14 And, lastly, if while you're reviewing the 15 Proposed Plan if you feel that there is anything 16 that you need in terms of additional inf- -- 17 information about the Site the -- there are 18 several ways you can go by to get that 19 additional information. First, we try to put 20 all documents that we use to formulate our 21 strategy at the Public Library located at 1390 22 Harrison Street. If you go there and you don't 23 find what we need -- what you need, feel free 24 by -- you know, at any time to reach out either 25 to myself or L'Tonya and we'll be sure that you www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 49 1 have any information that you need about the 2 Site. 3 That's it. And thank you. 4 [Audience applause.] 5 MR. JOSEPH: Well, now it's going to be 6 your turn to get the mic. 7 L'Tonya, giving it to you. 8 MS. SPENCER: Okay. We're at the 9 question-and-answer part. And, again, I, 10 please, ask since we have a transcriptionist, 11 please, state your name. And if it's a 12 difficult name, please, spell it so that she can 13 have it on file. 14 And, please, note as a part of Robenson's 15 presentation these comments and questions will 16 go into the Responsiveness Summary as well. But 17 if you have something else that you want to add 18 in after the fact, please, e-mail it on to him. 19 So who has the first question? 20 Oh, I was about to say, I know you -- you 21 have to -- excuse me. 22 MS. DAVIS-BRYANT: Good evening. My name 23 is Shanell Davis-Bryant. That's S-h-a-n-e-1-1, 24 Davis, D-a-v-i-s, dash, Bryant, B-r-y-a-n-t. 25 I'm with HabiJax. And I just have a point www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 50 1 of clarification. You were talking about the 2 Low Permeability Cap and you said you'd work 3 with the owners/ so are you saying that this -- 4 the remediation isn't going to start until 5 someone buys the property and that's when you 6 decide on the cap, or are you working with 7 Multistate to decide on the cap? 8 MR. JOSEPH: No. The plan is really to 9 keep moving forward. 10 MS. DAVIS-BRYANT: Okay. 11 MR. JOSEPH: The plan is to keep moving 12 forward. But, obviously, the last thing that we 13 want to do if somebody in the very near future 14 while we process or are developing our plan and 15 so on and so forth, they have acquired the 16 property and they have some specific things that 17 they want to do and what we were looking at 18 doing initially would not really meet their 19 goals and objectives that's when we shall -- we 20 work with them. We're not going to stay idle 21 and waiting for somebody to come in before we go 22 ahead. The train is moving. 23 MS. DAVIS-BRYANT: Okay. Good. 24 MS. SPENCER: Next question. 25 MS. RINAMAN: Good evening. My name's Lisa www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 51 1 Rinaman, St. Johns Riverkeeper. Rinaman is 2 R-i-n-a-m-a-n. 3 And it was unclear in the presentation what 4 happens to the contam- -- the contaminated soil 5 that's going to be in between the bulkhead and 6 the -- the boundary or the cap. And we -- we 7 have concerns about that not being dredged out 8 of the river. 9 MR. JOSEPH: Thank you for -- for your 10 question. Well, we understand your concern, 11 first. That's the first thing that I have to 12 say. And for the contaminated -- for the 13 contaminated sediment that we -- that is 14 between, you know, the soil or the shoreline and 15 into the river, again, I would say what we're 16 going to do is installing that bulkhead, but in 17 addition to the bulkhead we're also planning to 18 cap the contaminated sediment as well so there 19 will be a bulkhead and a cap over the 20 contaminated sediment. 21 So, now, I think you also asked -- did you 22 ask about why is it being dredged or why is it 23 being contained? Well, like I said, during the 24 Feasibility Study we looked at, you know, a 25 number of options. Certainly, dredging is also www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 52 1 one of the options that we evaluated in the 2 Feasibility Study, but like I say, during the 3 Feasibility Study what we also did was to 4 compare all of the options that we looked at 5 based on the Nine Criteria, so after all of 6 these evaluations we found that installation of 7 the bulkhead seems to be the most effective and 8 efficient way to address the contamination in 9 the St. Johns River. 10 So, obviously, you know, if you want to 11 further discuss that, you know, you're more than 12 welcome to, you know, see us and we can sit down 13 and dive a bit deeper into the details with you. 14 MS. RINAMAN: Thank you. 15 MR. JOSEPH: You're welcome. 16 MS. SPENCER: Any other questions? 17 MR. WRIGHT: Rickey Wright. I'm just 18 wondering who have EPA awarded to clean up the 19 Site, what company or companies? 20 MR. JOSEPH: Thank you for your question. 21 We are not at that point yet. As of now, I 22 mean, obviously, we're looking in -- I mean, 23 that's actually essential to what we would like 24 to do/ that's why we're here, to let you know 25 what we're thinking about, but we do not know www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 53 1 for sure as of yet what it will be. So we 2 wouldn't go out there and tell somebody, I'm 3 hiring you for something that we don't know what 4 it's going to be as of yet. So we are not at 5 that point yet. 6 So the first step is to issue that Record 7 of Decision. That's our plan. Our plan is to 8 make sure that anybody in the community, in the 9 State, and anybody else supports us with what 10 we're proposing to do. So once we get that 11 support then we will issue what we call "Record 12 of Decision." Once that's done -- and our goal 13 is to issue that by the end of the year. So 14 once that -- that's done, EPA, FDEP, the Trust 15 will work together really to identify some, you 16 know, highly qualified firms to help us with the 17 design and the implementation of the remedy. 18 So no decision has been done yet. 19 MR. WRIGHT: Okay. Thank you. 20 MR. JOSEPH: You're welcome. 21 MR. BROWN: Good evening. I'm Adrian 22 Brown, A-d-r-i-a-n, and last name the color 23 brown, B-r-o-w-n. 24 I have a question with regard to the 25 Proposed Plan on Page 10. It was indicated that www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 54 1 there's a plan to collect fish tissue samples in 2 order to evaluate for the human health risk. 3 There is no timeline for that. I would like to 4 find out when will the fish tissue samples be 5 collected and evaluated? 6 I have four other questions. You want me 7 to to outline all of them or -- or does he want 8 to respond? 9 MS. SPENCER: Do you want -- 10 MR. JOSEPH: Okay. All right. 11 MS. SPENCER: -- go ahead and answer the 12 fish tissue on the -- on -- timeline. 13 MS. LEWIS: Hello. My name is Tasha Lewis. 14 I'm with the Multistate Trust. To respond 15 specifically to your question, we have worked 16 with both FDEP and the EPA to develop a work 17 plan for moving forward with performing the fish 18 tissue sampling and we are in the process right 19 now of moving forward to implement that fish 20 tissue sampling. I do not have a specific date 21 in terms as to when we will be out in the field 22 doing that, however, it is in the very near 23 term. 24 MS. MAYER: Hello. My name is Tammy Mayer, 25 M-a-y-e-r. I heard there was a slight mention www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 55 1 about contamination for Deer Creek -- in Deer 2 Creek, but I didn't see anything included in 3 this plan, and I was curious if it's been 4 determined where that contamination is at the 5 creek and what was going to be proposed for the 6 cleanup. 7 MR. JOSEPH: Well, one of the things I 8 believe I did mention fairly early on during the 9 presentation was the fact that we decided, yes, 10 there is contamination in the creek, however, 11 there are still some uncertainties about the 12 whole -- what extent of it and who contributed 13 to what, et cetera, et cetera, so because of 14 those uncertainties we have decided to divide 15 the Site in two Operable Units or two Phases. 16 Right now we are focusing on everything 17 else but the creek and very soon the creek 18 will be the very next step that we're going to 19 take -- 20 MS. MAYER: Okay. 21 MR. JOSEPH: -- so it's coming. 22 MS. CONGDON: I'm not good at this. I'm 23 Betty Congdon, C-o-n-g-d-o-n. 24 I do want to thank EPA for coming to 25 Jacksonville and trying to make a difference. www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meeting on 09/28/2016 Page 56 1 number one. But what -- and what I do want to 2 ask is when you're talking about the water and 3 you said something about like a sewer plant or 4 something, is that going to be over there off 5 11th in the same area of this problem? Okay. 6 Which is the poor section, and we see a lot of 7 that, you know, in history and in all this, and 8 that -- you know, I worry about the water that's 9 come -- you know, you can't say it's going all 10 the way out to the water. We're talking about 11 children. Has anybody gone around -- like that 12 true story of people that had the chemicals that 13 other people died of, has anybody even done that 14 and walked to see if anybody has been a victim 15 or is there a trail of the cancer where there's 16 been exposure? Have we done anything of that? 17 Are we going to? And, again, is that water, the 18 reprocessing or whatever's going to go in the 19 bulkman [phonetic], I think it's called, if you 20 can ask if -- let us know where your plans are 21 of dumping this stuff, I'd appreciate it. 22 MR. JOSEPH: All right. Let me try 23 first -- and I was having a bit of a difficult 24 time -- 25 MS. CONGDON: Okay. www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 57 1 MR. JOSEPH: -- hearing your questions, so 2 if I miss anything or if I don't answer your 3 question correctly, please, by all means you can 4 just, you know, reengage and ask me again and I 5 will try my very best. 6 I think or I believe I heard you were 7 talking about, number one, the groundwater 8 that's going to be discharged into the sewer,* is 9 that right? Did you mention -- 10 MS. CONGDON: Yeah. You said in like a -- 11 AUDIENCE MEMBER: Treatment. 12 MS. CONGDON: -- reprocessing, yeah. 13 MR. JOSEPH: Right. Okay. So, yes, it is 14 part of our overall plan so that we can prevent 15 the contaminated groundwater -- now to keep from 16 discharging into the river we're proposing to 17 install a series of wells somewhat adjacent to 18 the river so that we can extract that 19 contaminated groundwater and prevent any from 20 discharging into the river. So when we extract 21 it from the subsurface we have to do something 22 with it/ we cannot just take it and discharge it 23 in the sewer system. So that's why we said 24 we'll need to treat it first, because -- and JEA 25 will have some specific requirements. They will www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 58 1 tell us, Your groundwater cannot exceed this 2 value, this numbers, this numbers, and this 3 numbers. And that's what we will do. We will 4 treat it first to meet their requirements and 5 after meeting their requirements then we can 6 discharge it into the sewer. Then -- and, 7 obviously, when it's discharged into the sewer 8 that doesn't mean that's the end of the 9 treatment process,* there will be some additional 10 treatment that JEA will then be conducting prior 11 to discharging it. I don't know exactly where 12 they will be, I mean, yes, there will be a -- 13 you know, a series of steps to -- when it comes 14 to treatment of that contaminated groundwater 15 before it's being disposed of. I think that's 16 part one. 17 The other part of the question I didn't get 18 that as well/ was it whether or not there was 19 some surveys that were -- that was done on -- as 20 far as actual cancer cau- -- causing, so on and 21 sort forth? 22 MS. CONGDON: That's right. 23 MR. JOSEPH: One of the things -- as a 24 matter of fact, I think as recently as 2014, if 25 I'm not mistaken, we also partner with ATSDR, so www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 59 1 that one is a department, the center for -- 2 please help me. 3 MS. SPENCER: The Agency for Toxic 4 Substances and Disease Registry. 5 MR. JOSEPH: There you go. Thank God you 6 are here, Tonya. 7 Yes. We work with the ATSDR and they will 8 work through -- you know, through the Department 9 of Health, and what they do is they perform what 10 we call a "Public Health Assessment." And I do 11 have a copy of that Public Health Assessment 12 that was performed I believe in -- there was one 13 done early on, if I'm not mistaken around 14 2003/2004 time frame. But every so often they 15 will update and revise and revisit the 16 information that they -- you know, that they 17 have, both based on additional sampling, and, 18 you know, what -- and -- and whatnot. And, like 19 I said, as recently as 2014, they looked at the 20 information, they look at the data and -- and, 21 yes, they acknowledge the fact that the 22 contamination is there and they did not see or 23 they have not, I believe, come -- they could 24 reach any -- you know, no definite conclusions 25 to say that if there were to be any type of www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meeting on 09/28/2016 Page 60 1 cancer cluster or if there would be anything 2 that would be strictly linked to the 3 contamination of the former -- of this property. 4 So, again, we tried to keep this somewhat 5 independent and that's why we partner with the 6 Department of Health so they can do their own 7 thing independently, and, you know, share that 8 information with the community. If you need a 9 copy of that Public Health Assessment you can 10 provide us your contact information and we'll be 11 sure that you get a copy of that. 12 MR. GRIFFITH: Robenson. Robenson, I -- I 13 ju- -- I just might add that I -- I think 14 also -- my name is Ty Griffith. I'm with the 15 Multistate Trust also. I think I heard a 16 question, and maybe some concern, about the 17 treatment plant that we're planning to 18 construct. And it's going to be a relatively 19 small unit. It's not -- it's not going to be 20 a -- you know, a -- a very large plant. It 21 might be on the order of a 15- -- a building 22 15-by-15, maybe 20-by-20-foot. Currently 23 it's -- it's identified as being at this 24 location away from the street, but we don't know 25 exactly where it's going to be. But the plan www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meeting on 09/28/2016 Page 61 1 would -- and we don't know the technology that 2 we're going to use yet. That will be put 3 together during the design phase, but if -- if 4 there are any needs for air discharges if they 5 were -- let's say they're stripping chemicals 6 out and then they would be processing those, 7 there would be air treatment for that. They 8 would have to be permitted and those would be 9 monitored to make sure that there's no -- 10 there's no discharges of anything into the 11 community. 12 MS. CONGDON: Thank you. 13 MS. SPENCER: And that was Ty. 14 MR. BROWN: Adrian Brown again. Has the 15 Site been evaluated for liquefaction potential? 16 And to kind of explain liquefaction -- I don't 17 know if the EPA -- I didn't see anything about 18 that, but it's like when the soil behaves like a 19 liquid. I don't know -- I was looking through 20 the report and I didn't see anything with regard 21 to liquefaction potential, because, you know, 22 you put the Permeability Cap,* we are assuming 23 that everything is going to stay in place, but 24 if there's liquefaction potential then you have 25 potential that -- you know, if something happens www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meeting on 09/28/2016 Page 62 1 and that's was why -- my -- the questions I had 2 in regard to -- to liquefaction potential. 3 The next one has to do with sinkholes. 4 We've had some sinkhole occurrences in Duval 5 County, and has that been evaluated with regard 6 to this Site? 7 And the third question has to do with the 8 stormwater detention basin/ will there be a 9 stormwater discharge permit as we see with that, 10 basically, meaning testing for discharge? 11 And then the fourth question has to do with 12 climate change impacts and rising surface water 13 levels/ what will that impact be, the 14 pump-and-treat system? Because if we have 15 rising surface water levels then that could 16 potentially impact the placement of your 17 pump-and-treat system. 18 So those are just some questions. By the 19 way, I'm going to e-mail all of these questions 20 to you. Thanks. 21 MS. SPENCER: The first question. 22 MR. JOSEPH: These are all excellent 23 questions. I think I need to -- do you have a 24 company? I think I should work for you. 25 MR. BROWN: By the way, I'm a professional www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meeting on 09/28/2016 Page 63 1 environmental engineer. 2 MR. JOSEPH: Oh, wow, that says it all. 3 All right. Let's see, where do we start? 4 Thank you for -- soil -- okay. The 5 liquefaction. I don't believe that was really 6 evaluated during the Remedial Investigation 7 Phase of the pro- -- of the project, but 8 certainly during the design this is something 9 that will, you know, certainly be taken in- -- 10 into consideration and -- and e- -- and 11 evaluated. So as you know, you know. Remedial 12 Investigation Phase is somewhat, obviously, 13 preliminary,* all we need to know is having 14 enough information that, you know, we can base 15 on selecting the remedy. When it comes to the 16 actual design and overall operation and how -- 17 you know, how all the pieces of the puzzles will 18 come into place all of these things will be done 19 primarily during the design -- during the design 20 phase. But, certainly, yes, that -- you know, 21 that -- we'll be looking into that. 22 And the other thing was -- 23 MS. SPENCER: Sinkholes. 24 MR. JOSEPH: -- sinkholes. Well, yes, we 25 did as part of our Hydroge- -- -geological www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meeting on 09/28/2016 Page 64 1 Investigation, yes, the normal wells and what 2 those -- where these go throughout on -- on the 3 property, and none was observed. And the good 4 news is because the contamination did not really 5 go, you know, super deep, up to about 45 feet 6 below land surface, it -- I mean, yes, I'm not 7 an expert in ge- -- hydrogeology. I'm not, you 8 know, super familiar with Jacksonville 9 hydrogeology, but usually I think sinkholes have 10 a tendency to be a bit deeper in the flow in an 11 aquifer or in -- you know, ultimately, not 12 really the -- you know, surficial aquifer, so 13 that was a no si- -- no sinkholes were observed 14 during the Remedial Investigation. 15 MR. BROWN: Climate -- can you speak to 16 climate change? 17 MS. SPENCER: The third question climate 18 change impacts. 19 MR. BROWN: Surface water temperature. 20 MS. SPENCER: Surface water temperatures. 21 MR. JOSEPH: We are the EPA. Climate 22 change is what we do every day. 23 No. I'm just kidding. 24 Well, yes, it is one of the requirements 25 that we ought to do these days,* when we select www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meeting on 09/28/2016 Page 65 1 any -- any remedy it's part of the process. We 2 have to take climate -- climate change into 3 consideration and then look at, you know, what 4 are the potential impacts that the climate 5 change would have on the -- on the remedy. So 6 if anything were to be identified, then, 7 obviously, measures would be then put in place 8 so that we can -- you know, can address those 9 potential issues. And that -- further details 10 about that or further evaluation and analysis, 11 again, will be conducted during the Remedial 12 Design. 13 MS. SPENCER: And the last question was 14 about a stormwater discharge permit. 15 MR. JOSEPH: Stormwater discharge permit, I 16 think Tasha touched on that just a little while 17 ago. Yes, we will have to, you know, again, 18 work with JEA and find out exactly what their 19 requirements are. And but, no, we can't just 20 extract it and treat it as we please and just 21 discharge it in the soil. We will have to work 22 closely with JEA to know exactly what their 23 requirements are. I -- as sort of my -- I -- I 24 spoke earlier today with one of the executives 25 from JEA, and, obviously, I have their contact www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meeting on 09/28/2016 Page 66 1 information/ we will be working very closely 2 with them and I believe that will be important. 3 MR. SMITH: Clayton Smith, S-m-i-t-h. 4 I'd like to say that I think Robenson has 5 done an outstanding job as usual. 6 MR. JOSEPH: Thank you. 7 MR. SMITH: I don't have any other 8 statement to make other than that is that I 9 submitted some paperwork. I just want to go on 10 record that I have submitted that to the -- 11 Mr. Robenson's office. And that's all. 12 MS. SPENCER: Any other questions? 13 MS. DAVIS-BRYANT: Hi. This is Shanell 14 Davis-Bryant with HabiJax again. I just wanted 15 to understand the -- the bulkhead or the 16 seawall/ is that something -- I'm thinking of a 17 seawall so it's the barrier but there's water on 18 one side and water on the other, or is it 19 something that like caps it completely? Just 20 some clarification on that. 21 MS. BROOKS: I'm Cindy Brooks from the 22 Multistate Trust. This is a -- the 23 environmental -- the bulkhead is what would be 24 used to contain the contaminated sediments, 25 so -- and that would essentially rise to a level www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meeting on 09/28/2016 Page 67 1 above the -- the -- the St. Johns River water 2 levels, so in terms of -- and your question was 3 is there water on both sides? 4 MS. DAVIS-BRYANT: Yes. 5 MS. BROOKS: So that -- that would -- 6 there's -- the sediments are contained, okay, 7 and they're capped, and that's essentially, you 8 know, how -- how we -- the -- the Proposed Plan 9 proposes to address those. There will be some 10 sediments on the east side of the seawall that 11 will have to be dredged, a minor amount, and 12 those, of course, will be placed along the side 13 or behind the seawall. That's essential the 14 plan. 15 Do you -- it's -- do you want to add 16 anything? 17 MS. LEWIS: (Shakes head.) 18 MS. BROOKS: Okay. 19 MS. DAVIS-BRYANT: All right. Thank you. 20 MS. BROOKS: You're welcome. 21 MS. SPENCER: Any other questions? 22 MS. HARRIS: Darcel Harris. I guess I just 23 want to get clarification. You said there were 24 going to be implementation of institutional 25 controls, and I just want to verify what you www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meeting on 09/28/2016 Page 68 1 mean by "restrictive covenants." Do you mean 2 that -- that no one will ever be able to live 3 there or it couldn't be used for development for 4 housing or -- is that what you mean on that? 5 MR. JOSEPH: I think the short answer to 6 that is probably yes. As we know right now the 7 area is zoned for commercial and industrial 8 usage and we -- we don't believe there will be 9 any, you know, housing development on that 10 property. And we also know that -- and as I 11 said, you know, that was -- you know, on those 12 slides of figures showing you the extent of the 13 contamination, and I -- you know, I was saying 14 that, okay, based on whichever criteria that we 15 use, and one of the criteria was based on 16 cleanup levels based on commercial and 17 industrial use,* that's what we use as our 18 assumption when it comes to addressing the 19 contamination. That said, it is very likely 20 that, you know, that property will continue to 21 be used for commercial and industrial uses only. 22 MS. BRUNSON: Good evening. My name is 23 Niki Brunson, legacy Eastside resident. My 24 question is about the work itself, which I know 25 is anywhere from two to five years down the www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meeting on 09/28/2016 Page 69 1 line. Our community has been designated as a 2 Tier 1 community, which means that we have 3 25 percent of our able-bodied work force is 4 currently out of work. Several years ago many 5 of those people attended environmental 6 certification classes, but those jobs hasn't 7 physically materialized in our community. So my 8 question is: Of this 69 million dollars, will 9 opportunities be presented where we can now use 10 those certificates in the community to help, I 11 guess, in -- with this -- with no better way of 12 saying it, for them to be physically attached to 13 this specific cleanup so that it not only 14 represents a cleanup in our community but it 15 also represents, for lack of a better term, a 16 come-up economically. 17 MR. JOSEPH: Thanks for your que- -- for 18 your question. On day one -- and I think I 19 alluded to that also just a little while ago by 20 saying that, yes, I know I don't live in 21 Jacksonville, I'm from Atlanta, but we take that 22 to heart. We do know and that is really a part 23 of planning. It's been an -- an ongoing 24 conversation. And it's part of our strategy. 25 It's part of our plan. Whatever we do -- and I www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 70 1 will -- well, now, Cindy will have the 2 opportunity to elaborate with you on that, but 3 ourselves, the EPA, as one of the key 4 beneficiary of the Trust, we had and we will 5 continue to make it a requirement that to the 6 maximum extent possible that all the work that 7 is being conducted at this Site -- and -- again, 8 and I'm trying to be very careful here,* I'm not 9 saying all, but to the maximum e- -- extent 10 possible to make sure that the work i- -- stays 11 local. 12 MS. BRUNSON: Thank you. 13 MR. JOSEPH: So it's our goal. It's our 14 objective and we are going to ask that to the 15 Trust. 16 Cindy, do you want to add? 17 MS. BROOKS: As the Multistate Trustee for 18 other sites within this part of -- of the United 19 States we typically put in place a program that 20 allows us to identify people that are interested 21 from the community that either are -- have or 22 would be interested in receiving training to 23 perform activities on the -- this waste site and 24 will help put them through the training, and 25 then, obviously, there's some cleanup that's www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 71 1 going to be implemented, and so we would attempt 2 to place them, get them involved and get -- get 3 employment opportunities from those cleanup 4 activities. Obviously, when the Site is fully 5 cleaned up then those jobs will disappear, but 6 the way we have pursued this in other 7 communities is we help -- essentially, we give 8 these people experience and it's -- and it's one 9 of the reasons we care very deeply about and 10 work very closely with the community 11 stakeholders here in the Eastside, because we 12 hope that -- that you will be willing to work 13 with us to identify those individuals from your 14 community that are -- are looking for new 15 opportunities. 16 And, obviously, it will take some time 17 because we're going to be doing design and some 18 investigations, but as we ramp up for the 19 construction phase of the work we would very 20 much like to partner with you to make sure that 21 we create the maximum number of jobs for the 22 community that has been so impacted by this 23 Site. 24 MS. Brunson: Thank you. 25 MS. SPENCER: And just to add just so you www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 72 1 guys know what Niki was talking about, years ago 2 and in working with the Jacksonville Ash 3 Brownfield Site, we did have a Superfund Jobs 4 Training Program -- 5 MS. Brunson: Yeah. 6 MS. SPENCER: -- during the construction of 7 that and we had a graduation of people who went 8 through environmental classes, but there was 9 also a Brownfields Training Program where they 10 went through the same type of classes, and so 11 there are several people that took those classes 12 through the Brownfields Program that did not get 13 an opportunity to be employed. So those are two 14 programs that we had, but that was several years 15 ago, but Cindy and I are talking, and, like she 16 mentioned, we have done it at other sites and 17 the Trust is willing to do it here as well. 18 MR. PINNIX: Hi. Good evening. Ken 19 Pinnix, Technical Advisor to the Eastside 20 Environmental Council with their Technical 21 Assistance Grant, the TA Grant. Just to 22 elaborate a little bit more on what Tonya was 23 just saying, Florida State College at 24 Jacksonville a few years ago received an EPA 25 Workforce Development Training Grant www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 73 1 specifically for brownfields and environmental 2 issues. There are graduates from that program 3 who are ready and able to work on a project of 4 this type, so it would be my hope that as the 5 contractors are selected one of the criteria in 6 selecting those contractors is a commitment from 7 them to hire from this particular program, 8 because many of those students in the program 9 are from the Eastside area as well as other 10 und- -- as well as other environmentally 11 impacted communities throughout Jacksonville, so 12 there is a source of work that's -- that's 13 there. 14 The second thing is for the la- -- the 15 young lady -- the resident who was speaking 16 about the Public Health Assessment, all of the 17 documents that Robenson was speaking of, all of 18 the Remediation Action Plans, all of the work 19 that's been previously done, the documents are 20 at the Eastside Library. There is a copy of 21 that Public Health Assessment there as well. 22 And what I do as the Technical Advisor is I go 23 and review those documents, make sure that the 24 latest documents from the EPA related to this 25 Site is there and available for -- for anyone to www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 74 1 come in and take a look at. They're open most 2 days. You can go in and review those documents. 3 Some of them are very technical, but many of 4 them have summaries that can give you an idea or 5 a flavor of what the -- what the information is 6 and how that information was obtained and what 7 they feel is in the best interest of the 8 community to know. 9 Thank you. 10 MS. SPENCER: I see a question up here. Is 11 there somebody else? 12 I'll come to you next. 13 MS. McDADE: My name is Ms. Veronica V. 14 McDade. That M-c-D-a-d-e. I want to just say 15 this about Talleyrand, JAXPORT, now, you talking 16 about cleaning up,* when are y'all going to get 17 to the cleaning up? 18 Come on, brother, answer me. Okay. I've 19 live on the Eastside and all 59 years. Y'all do 20 all of that talking but not doing no work. I 21 want to see some work done now. 22 Okay. Talleyrand with Mr. John Superna 23 [phonetic] did that. He got a lot of men 24 working there. And it's a -- you know, it's a 25 shame. If you people were in a Site like that www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 75 1 dirty and nasty and filthy, you don't want to 2 work there. You don't want your son to work 3 there. How about we go to work and work and get 4 those boys off the street and back to work. 5 They got that -- that Talleyrand with all that 6 germ and garbage coming into our community. You 7 got old people living around there in 8 Talleyrand. 9 We need something done. Because all that 10 talking is talking and talking and talking. Put 11 it into action. That would be not in 12 Jacksonville. Because I am tired of coming to 13 those meetings and looking at that board, then 14 you can look at the next mon- -- month, two 15 month, and you look at the next year you got the 16 same thing because you ain't doing nothing. 17 I'll be honest with you, sir, we need to 18 get together because I shake the Eastside. I'm 19 a member or the Environment. We doing something 20 out there. 21 Am I right, Ms. Wright? 22 MS. WRIGHT: Yes, ma'am. 23 MS. McDADE: I'm the secretary -- 24 AUDIENCE MEMBER: Here, here. 25 MS. McDADE: -- and I want something done www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meeting on 09/28/2016 Page 76 1 with those men need jobs -- 2 AUDIENCE MEMBER: Yeah. 3 MS. McDADE: --on Third and Franklin. 4 They got Talleyrand. They got some disease out 5 there with their dirty -- (unintelligible). 6 Talleyrand. We need to get together. We -- 7 these men is going to Shand with the breathing 8 problem. 9 AUDIENCE MEMBER: Uh-huh. 10 AUDIENCE MEMBER: Yeah. 11 MS. McDADE: If some of y'all -- I mean, 12 you have to say something now. Don't stay up 13 there looking like you retarded. 14 AUDIENCE MEMBERS: Yeah. 15 MS. McDADE: We need to get that thing 16 together. 17 AUDIENCE MEMBERS: Yeah. 18 MS. McDADE: I'm here to get it together. 19 I'm not here to waste no time. I'm 72 years 20 old. I'm glad of my age, but 1 want a clean 21 Jacksonville. 22 You want a clean Atlanta. Am 1 right? 23 AUDIENCE MEMBER: That's right. 24 MS. McDADE: 1 want a clean Duval County. 25 Come on. Get -- get to work now. It's time to www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 77 1 work. And it's not a sit down and look/ it's 2 time to do work because we got a lot of sick 3 mens out there in Shands. They coming right 4 there on Talleyrand. Older women that ha- -- 5 has as- -- we got one in our group, she's a old 6 lady, 90-year-old, Aunt Bean [phonetic], she's 7 to -- asthma right on the Eastside. I don't 8 want no asthma. I want good health. I want you 9 to get with your men. I want to see you worked. 10 There ain't no time to play. It's time to 11 worked. I want to see something did. I want to 12 see them males say, Ooh, that EPA done worked 13 it. I want to see -- Ms. Wright, am I working? 14 MS. WRIGHT: Yes, ma'am. 15 MS. McDADE: I mean, I worked. 16 MS. WRIGHT: Yes. Yes. 17 MS. McDADE: You don't see all 18 (unintelligible) there. We ain't got no men do 19 anything. Women doing all the work. Men 20 sitting down and relaxing. 21 Come on now. I'm 72. My momma say, you 22 are married to that God [phonetic] or are you 23 married to me? 24 I'm going to tell it like it is now. 25 MR. JOSEPH: Wow. www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 78 1 MS. McDADE: I want to see some work, sir. 2 I don't want these men to get sick. They got 3 family they have to take care of. 4 Can you answer me that, sir, will you get 5 started that ? 6 MR. JOSEPH: Promise. 7 MS. McDADE: Okay. Not no promise and 8 misstate your promise. I'm not looking for a 9 promise. Take you at your word. 10 MR. JOSEPH: When I make a promise -- 11 MS. McDADE: Okay. Do it. 12 MR. JOSEPH: -- I keep it. 13 AUDIENCE MEMBER: All right. 14 MS. McDADE: All right. I'll check that 15 out. 16 MR. JOSEPH: And just be -- 17 MS. McDADE: I live right there on Franklin 18 Street. I'll be glad to walk down to Talleyrand 19 and see you. 20 MR. JOSEPH: -- take it to the bank. 21 MS. McDADE: Okay. I'm going to take it to 22 the bank/ I want 23 MR. JOSEPH: Wow. 24 MS. McDADE: -- I want it to be cash. 25 MR. JOSEPH: Now, what you take to the bank www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 79 1 is what I 'm going to say right now -- 2 MS. McDADE: Uh-huh. 3 MR. JOSEPH: -- and that is as far as the 4 current site is concerned, like I said just a 5 little while ago 6 MS. McDADE: All right. 7 MR. JOSEPH: -- the train has left the 8 station - - 9 MS. McDADE: Okay. 10 MR. JOSEPH: -- and it's moving forward. 11 MS. McDADE: Okay. 12 MR. JOSEPH: So that's what I will say. 13 MS. McDADE: Okay. 14 MR. JOSEPH: It's moving. 15 MS. McDADE: All right. Thank you. 16 [Audience applause.] 17 MS. MAYER: Hello. Tammy Mayer again. I 18 just want to mention that there's a Florida 19 Brownfields Association Conference that's going 20 to be happening in October. It's the 2nd 21 Southeast Brownfields Conference. It's going to 22 be at the Omni in mid October/ I believe it's 23 the 16th through the 19th, so it's on the 24 internet if you want to look that up. So that 25 might be a good way for these people that are www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 80 1 certified to enjoy the conference and talk to 2 the different businesses that -- that deal with 3 that type of work. 4 I also wanted to ask as far as the 5 excavation of the soil, it's going to be 6 transported off-site, which is probably going to 7 go to a landfill in another state so it's going 8 to be transported a long distance,* was there any 9 consideration of trying to do a local or 10 close-by type of landfill, even maybe in the CSX 11 property, create a landfill and then maybe do 12 some type of property trade with CSX, so then 13 it's not carted through public areas? 14 Thank you. 15 MR. JOSEPH: Thank you for your question, 16 but, frankly, no, we have not looked into that 17 in terms of -- of property swapping or anything 18 like that with CSX. We did not do that and I 19 don't -- I don't know if -- I don't believe we 20 will -- will go down that path/ however, when it 21 comes to the actual disposal of the material 22 that will be excavated, we -- we don't know yet 23 exactly where it's going to be disposed at. 24 During the Remedial Design the designers or the 25 engineers will, you know, certainly do some -- www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 81 1 some research and find out whether or not if 2 there are also, you know, local facilities 3 around here where it could be disposed of and 4 the material will meet their requirements, yes, 5 it could be disposed of, quote-unquote, locally. 6 But, otherwise, it probably will -- you know, 7 will be shipped out across state or sometimes 8 even across country. That happens. I've seen 9 that happen. 10 MS. SPENCER: Okay. We're going to take 11 one last question so we can allow some time for 12 one-on-one. 13 MR. ROBERTS: My name is Shurod Roberts, 14 S-h-u-r-o-d. My concern is I know you're going 15 to cap it off for resale,* I know -- I know all 16 that's going to take place. But my main concern 17 is this has been going on for over a hundred 18 years and we've got that contamination in our 19 water line and we're all drinking it, we're all 20 farming in gardens. These sportsmen -- 21 MS. McDADE: Amen. 22 MR. ROBERTS: -- out here are trying to 23 be -- be healthy, but you can't be healthy 24 because we don't even have the substance to put 25 in the water to neutralize the chemical. So www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 82 1 when are -- are we going to be on top of this? 2 It's already been over a hundred years. So 3 we've got a serious problem here and this 4 ain't -- ain't getting it, so I want to know are 5 we going to have a monitoring station set up so 6 that these people can, like we're doing right 7 now, we're communicating a little better than we 8 have been. That's a plus. 9 But we've got a serious problem with 10 people's health, like the young lady said over 11 here, and it's not being addressed, because like 12 this young lady said it's because we are in a 13 poor area and that's where all -- 14 AUDIENCE MEMBER: Right. 15 MR. ROBERTS: -- the chemicals go. So we 16 know we're not going to drag this over there in 17 Mandarin or out there in -- what's the other 18 one -- Fleming Island, areas like that, we know 19 that, because they're a better taxpayer bracket. 20 Okay. So we need to really get serious and do 21 something with this because this water, we drink 22 it. We go out there and we farm on it. 23 Y'all -- you're not from here. Obviously, 24 it's not your concern, but it is ours and -- 25 MR. JOSEPH: Oh, I'm sorry. Let me -- 1 -- www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 83 1 I'm sorry, I have to interrupt. 2 MR. ROBERTS: -- I want you to. 3 MR. JOSEPH: And, yes, it is my concern. 4 MR. ROBERTS: Thank you. 5 MR. JOSEPH: It is my concern. 6 MR. ROBERTS: You're the first one I've 7 met. 8 MR. JOSEPH: And that's why we're here. 9 MR. ROBERTS: Okay. Then I -- 10 MR. JOSEPH: If we were not concerned we 11 mostly likely wouldn't be here. 12 MR. ROBERTS: -- I -- I got to push you. 13 brother, because I'm a pusher myself. 14 MR. JOSEPH: Please, yes, you can push me 15 to the limit and I guarantee you I will stand. 16 MR. ROBERTS: We can pull each other. 17 MR. JOSEPH: Yes. Yes. We do care. 18 MR. ROBERTS: All right. 19 MR. JOSEPH: All right? And that's why 20 we're here. And, now, as far as the 21 contamination in the groundwater is concerned 22 there are a few things that I wanted to point 23 out very quickly. The first one is, like I said 24 during my presentation, we installed a number of 25 wells at the Site and we screened those wells at www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 84 1 different depths. We've collected samples. 2 We've analyzed those samples. Based on the 3 results of those samples what we found is the 4 contamination is mainly in the shallow zone to a 5 depth of -- up to a depth of approximately 6 45 feet below land surface. Now, the other good 7 thing is drinking water in this area is provided 8 by the public utilities -- 9 AUDIENCE MEMBER: No, it's not. 10 MR. JOSEPH: -- and you've got wat- -- 11 water that is distributed into a -- that is 12 extracted way deeper than that 45 feet that 13 we're talking about. We're talking about at 14 least some 1500 feet below land surface so 15 that's how deep the water that is coming to your 16 land is extracted and collected from. 17 So based on all that we know we have no 18 indications that the contamination at the Site, 19 number one, has been going that deep, and, 20 number two, we really do feel like, yes, it 21 doesn't go there and there are no wells near by 22 that Site, so I believe the closest extraction 23 wells from the si- -- near the Site is roughly 24 about two miles from the Site. That's ba- -- 25 and -- and -- and then that -- that is based on www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 85 1 door-to-door surveys that we conducted during 2 Remedial Investigation. We had people going all 3 around the neighborhood houses by hou- -- after 4 houses, and, you know, trying to identify all 5 the wells that were in the area, so unless -- I 6 mean, you know, I -- I don't -- I don't want to 7 say that if somebody has a clandestine well 8 somewhere there and they are obstructed it 9 from -- from the -- or -- or -- or something 10 like that, that I don't know. That I don't -- 11 we don't have any control of that. And we -- I 12 mean, yes, based on all that we know we have no 13 indication that the contamination at the Site 14 has been going any deeper than roughly that 15 45 feet below land surface, and drinking -- the 16 water is provided by the public utilities and 17 that they extract their water at a depth of 18 about 1500 feet below land surface. 19 MR. ROBERTS: Okay. My next question -- 20 and I understand that, but you put a packet of 21 Kool-Aid in water, like chemicals, and what's it 22 does? It -- it dobs [phonetic] in the water and 23 it travels all through the water bed. Okay. So 24 it's out there somewhere. But are we going 25 further out than just a quarter of a mile from www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meeting on 09/28/2016 Page 86 1 where the contamination is identified or are we 2 going to do some tapping around the area, or are 3 we just going to go to ha- -- half a quarter of 4 a mile back and be done? That's my question. 5 MR. JOSEPH: Well, my response to both of 6 your -- is twofold/ number one, based on what we 7 know and based on the investigation that we 8 conducted also, we know the problem water is 9 flowing in a specific direction and that is 10 primarily from Talleyrand Avenue towards the 11 river. That's the direction it's flowing. And, 12 yes, after we implement the remedy as part of 13 our overall strategy there will -- that's why -- 14 how come I mentioned that we will implement a 15 long-term groundwater monitoring program where 16 wells will be strategically located at specific 17 locations so that we can continue to monitor the 18 progress of the remedy that is implemented, 19 making sure that in any way, shape, or form the 20 contamination does not really go where it's not 21 supposed to go. 22 MS. SPENCER: Okay. We're going to close 23 this out. I'm going to give Ms. Wynetta the mic 24 and after she's finished we will conclude this 25 meeting. www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 87 1 I want to thank everybody for coming 2 tonight. If you did not get a chance to sign in 3 on the sign-in sheet when you first walked in, 4 please, sign in,* we use that to go against our 5 current mailing list in order to ensure that 6 people continue to get information. 7 So I'm going to turn it over to 8 Ms. Wynetta. 9 MS. WRIGHT: Thank you, L'Tonya. And 1 10 would just like to say to the audience is that 11 the Eastside Environmental Council have been 12 working on this Site. We have a tag [phonetic] 13 and we have been working to help to address this 14 issue. We were almost there one time and we've 15 been working on the preliminary -- 16 MS. McDADE: Yes. 17 MS. WRIGHT: -- Record of Decision, so now 18 we have -- 16 years, yeah -- and so we're 19 working now on a Record of Decision, a -- not 20 a--a--a proposed one, so we are excited that 21 this is -- and -- and, believe me, it has been a 22 long, long -- 23 MS. McDADE: Road -- 24 MS. WRIGHT: -- road. 25 MS. McDADE: -- yes. www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 88 1 MS. WRIGHT: And I just would -- I'd just 2 like to make this one comment: We -- EPA, and 3 I've been working with them over 20 years, and 4 they have worked with the community. They have 5 worked with me. And the thing of it is is that 6 the government is being -- the funds are being 7 cut. The workers are being -- we have less 8 workers/ you know, you get on the phone, you 9 call the government or whatever, you're there 10 forever. So I'm just going to say this, is that 11 I've -- I've been in it for the long haul and I 12 know these people here for many years and they 13 are truly, truly dedicated to de- -- getting 14 this Site cleaned up. 15 MR. ROBERTS: That's a blessing. Thank 16 you. 17 [Audience applause.] 18 MS. SPENCER: Thank you, everybody, for 19 coming. And if have you any individual 20 questions, I was trying to end in enough so that 21 if people wanted to talk to Robenson or Cindy or 22 Tasha or anyone, we would have some time left, 23 so we've got about maybe five or ten minutes. 24 About -- that is one of -- but I hope everybody 25 got the information that you came for tonight www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SITERFUND SITE Public Meetins on 09/28/2016 Page 89 1 and we look forward to seeing you when we come 2 back again, because we will be back again. 3 Thank you. 4 [The Public Meeting is concluded at 8:00 p.m.] 5 _ _ _ 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco IN RE: KERR-MCGEE CHEMICAL CORPORATION SUPERFUND SITE Public Meeting on 09/28/2016 Page 90 1 CERTIFICATE 2 3 STATE OF FLORIDA: 4 COUNTY OF DUVAL : 5 6 I, Janice Lynn Carrico, FPR, certify that I was 7 authorized to and did stenographically report the foregoing 8 proceedings of the Public Meeting and that the transcript 9 is a true and complete record of my stenographic and 10 audiotaped notes. 11 Dated this 17th day of October, 2016. 12 13 14 15 16 17 /s/ Janice Lynn Carrico, FPR 18 Janice Lynn Carrico, FPR 19 20 21 22 23 24 25 www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte ~ Atlanta ~ Washington, DC ~ New York ~ Houston ~ San Francisco