RECORD OF DECISION (RODS)Record of Decision Page iii Coleman-Evans Wood Preserving Company Operable...

EPA/ROD/R2006040001242 2006

EPA Superfund

Record of Decision:

COLEMAN-EVANS WOOD PRESERVING CO. EPA ID: FLD991279894 OU 02WHITEHOUSE, FL09/28/2006

RECORD OF DECISIONSUMMARY OF REMEDIAL ALTERNATIVE SELECTION

COLEMAN-EVANSWOOD PRESERVING COMPANY

SUPERFUND SITE

OPERABLE UNIT 02(RESIDUAL DIOXIN IN SOIL)

WHITHOUSE, DUVAL COUNTY, FLORIDA

PREPARED BY:

U.S. ENVIRONMENTAL PROTECTION AGENCYREGION 4

ATLANTA, GEORGIA

SEPTEMBER 2006

Record of Decision Page ii Coleman-Evans Wood Preserving Company Operable Unit 02 (Residual Dioxin in Soil) September 2006

TABLE OF CONTENTS

PART 1: THE DECLARATION

1.1 Site Name and Location 1 1.2 Statement of Basis and Purpose 1 1.3 Assessment of Site 1 1.4 Description of Selected Remedy 1 1.5 Statutory Determinations 2 1.6 Data Certification Checklist 2 1.7 Authorizing Signature 2

PART 2: THE DECISION SUMMARY

2.1 Site Name, Location, and Brief Description 3 2.2 Site History and Enforcement Activities 5

2.2.1 Operational History 5 2.2.2 Regulatory and Enforcement History 5 2.2.3 Previous Investigations 7 2.2.4 2005-2006 OU2 Focused Remedial Investigation 10

2.3 Community Participation 11 2.4 Scope and Role of Operable Unit or Response Action 12 2.5 Site Characteristics 12

2.5.1 Conceptual Site Model 12 2.5.2 Site Overview 12 2.5.3 Geology 13 2.5.4 Hydrogeology 16 2.5.5 Ecological Assessment 16 2.5.6 Nature and Extent of Contamination 16

2.5.6.1 Nature and Extent of Residual Dioxin Soil Contamination 17 2.5.6.2 Attribution of Residual Dioxin Soil Contamination 21

2.5.7 Potential Exposure Pathways 22 2.6 Current and Future Land Use 24

2.6.1 Current Land Use 24 2.6.2 Future Land Use 25

2.7 Summary of Site Risks 25 2.7.1 Summary of Human Health Risk Assessment 25

2.7.1.1 Identification of Chemicals of Concern 26 2.7.1.2 Exposure Assessment 27 2.7.1.3 Toxicity Assessment 31 2.7.1.4 Risk Characterization 33 2.7.1.5 Uncertainties 35

2.7.2 Summary of Ecological Risk Assessment 36

Record of Decision Page iii Coleman-Evans Wood Preserving Company Operable Unit 02 (Residual Dioxin in Soil) September 2006

2.8 Remedial Action Objectives 36 2.9 Description of Alternatives 37

2.9.1 Detailed Remedial Alternatives Evaluation 37 2.9.1.1 Alternative 1 - No Action 37 2.9.1.2 Alternative 2 - Excavation with On-site Disposal 38 2.9.1.3 Alternative 3 - Excavation with Off-site Disposal 41

2.9.2 Common Elements and Distinguishing Features of the Alternatives 43 2.10 Comparative Analysis of Alternatives 44

2.10.1 Overall Protection of Human Health and the Environment 46 2.10.2 Compliance with Applicable or Relevant and Appropriate

Requirements 46 2.10.3 Long-Term Effectiveness and Permanence 47 2.10.4 Reduction of Mobility, Toxicity, or Volume through Treatment 47 2.10.5 Short-Term Effectiveness 48 2.10.6 Implementability 48 2.10.7 Cost 49

2.11 Principal Threat Wastes 50 2.12 Selected Remedy 51

2.12.1 Rationale for the Selected Remedy 51 2.12.2 Description of the Selected Remedy - Excavation with On-site

Disposal 51 2.12.2.1 Excavation and Property Restoration 52 2.12.2.2 Site Grading and Cover Installation 52 2.12.2.3 Institutional Controls 54 2.12.2.4 Five-Year Reviews 54

2.12.3 Summary of Estimated Remedy Costs 54 2.12.4 Expected Outcomes of the Selected Remedy 54

2.12.4.1 Available Land Use 55 2.12.4.2 Final Cleanup Goals 56

2.13 Statutory Determinations 56 2.13.1 Protection of Human Health and the Environment 56 2.13.2 Compliance with ARARs 57 2.13.3 Cost Effectiveness 57 2.13.4 Permanent and Alternative Treatment Solutions 61 2.13.5 Preference for Treatment as a Principal Element 61 2.13.6 Five-Year Review Requirement 61

2.14 Documentation of Significant Changes 61 2.15 References 62

PART 3: RESPONSIVENESS SUMMARY

Responsiveness Summary 63

Record of Decision Page iv Coleman-Evans Wood Preserving Company Operable Unit 02 (Residual Dioxin in Soil) September 2006

LIST OF FIGURES

Figure 1. Coleman-Evans Site Location Map 3 Figure 2. Coleman-Evans OU2 Conceptual Site Model 13 Figure 3. Coleman-Evans OU2 Investigative Area 14 Figure 4. Coleman-Evans OU2 Soil Sample Location Map 18 Figure 5. Coleman-Evans OU2 Soil Sample Dioxin TEQ Concentration Ranges 19 Figure 6. Dioxin Congener Groupings as Result of Principle Component Analysis 22 Figure 7. Extent of Attributable Residual Soil Dioxin Contamination 23 Figure 8. Coleman-Evans OU2 Proposed Soil Excavation Areas 53

LIST OF TABLES

Table 1. Summary of Coleman-Evans OU2 Soil Sampling 20 Table 2. Coleman-Evans OU2 Soil Cancer Risk Summary 34 Table 3. Comparable Evaluation of Remedial Alternatives for Coleman-Evans

OU2 45 Table 4. Comparison of Remedial Alternatives Costs for Coleman-Evans OU2 50 Table 5. Estimated Remedy Construction Costs for Coleman-Evans OU2 55 Table 6. Final Soil Remedial Cleanup Goals for Coleman-Evans OU2 56 Table 7. Chemical-Specific ARARs, Criteria, and Guidance for Coleman-Evans

OU2 58 Table 8. Action-Specific ARARs, Criteria, and Guidance for Coleman-Evans OU2 59

LIST OF APPENDICES (On Compact Disc)

Appendix A - Public Meeting Transcript

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LIST OF ACRONYMS and ABBREVIATIONS

ABSGI appropriate gastrointestinal absorption value ARAR applicable or relevant and appropriate requirement AROD Amended Record of Decision AST Aboveground Storage Tank ATSDR Agency of Toxic Substances Disease Registry Black & Veatch Black & Veatch Special Projects Corporation bls below land surface BRA Baseline Risk Assessment CalEPA California Environmental Protection Agency CAMU corrective action management unit CDD chlorinated dibenzo-p-dioxins CDF chlorinated dibenzo-p-furans CDI chronic daily intake CDM Camp, Dresser and McKee, Inc. CERCLA Comprehensive Environmental Response Compensation Liability Act CFR Code of Federal Regulations cm2 square centimeter COC chemical of concern COPC chemical of potential concern CSF cancer slope factor CTE central tendency exposure cy cubic yards EPA U.S. Environmental Protection Agency EPC exposure point concentration ERA Emergency Response Action ESD Explanation of Significant Differences /F degrees Fahrenheit FAC Florida Administrative Code FDEP Florida Department of Environmental Protection FFS Focused Feasibility Study FRI Focused Remedial Investigation FS Feasibility Study ft bls feet below land surface HEAST Health Effects Assessment Summary Tables HHRA Human Health Risk Assessment HI hazard index HQ hazard quotient ILCR incremental lifetime cancer risk IRA Interim Response Action LOAEL lowest observed adverse effect level km kilometer m2 square meter m3 cubic meter m3/kg cubic meter per kilogram MCL maximum contaminant level

Record of Decision Page vi Coleman-Evans Wood Preserving Company Operable Unit 02 (Residual Dioxin in Soil) September 2006

µg microgram µg/kg micrograms per kilogram (parts per billion) µG/L micrograms per liter mg milligram mg/cm2 milligrams per cubic meter mg/kg milligrams per kilogram mg/kg-day milligrams per kilogram per dayMRL minimal risk levelM/T/V mobility/toxicity/volumeNCP National Contingency Plan NOAEL no observed adverse effect level NPDES National Pollutant Discharge Elimination System NPL National Priorities List O&M operation and maintenanceOSHA Occupational Safety and Health AdministrationOU Operable UnitPCA principle component analysis PCP pentachlorophenolPEF particulate emission factorppm part per million PQL Practical Quantitation LimitPRC PRC Environmental Management, Inc. RAO Remedial Action ObjectiveRCRA Resource Conservation and Recovery Act RA Remedial Action RD Remedial Design RfC reference concentration RfD reference doseRGO Remedial Goal Option RME reasonable maximum exposure RI Remedial InvestigationROD Record of DecisionSARA Superfund Amendments and Reauthorization ActSCTLs Soil Cleanup Target Levels"Site" Coleman-Evans Wood Preserving Superfund Site S/S stabilization/solidificationTBC to-be-considered TCLP Toxicity Characteristic Leachate ProcedureTCDD tetrachloro-dibenzo-p-dioxin TEF toxicity equivalent factor TEQ toxicity equivalent quotient TS Treatability Study URF unit risk factor USACE U.S. Army Corps of Engineers WHO World Health Organization

Record of Decision Page 1 Coleman-Evans Wood Preserving Company Operable Unit 02 (Residual Dioxin in Soil) September 2006

PART 1: THE DECLARATION

1.1 Site Name and Location

This Record of Decision (ROD) is for the Coleman-Evans Wood Preserving Company SuperfundSite, Operable Unit (OU) 02 (Residual Dioxin in Soil) that is located at 101 Celery Street in thecommunity of Whitehouse, Duval County, Florida. The U.S. Environmental Protection Agency(EPA) Site Identification Number is FLD0991279894.

1.2 Statement of Basis and Purpose

This decision document presents the Selected Remedy for the Coleman-Evans Wood PreservingCompany Superfund Site (the "Site"), OU2 (Residual Dioxin in Soil) that was chosen in accordancewith the Comprehensive Environmental Response, Compensation, and Liability Act of 1980(CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA),and, to the extent practicable, the National Contingency Plan (NCP). This decision is based on theAdministrative Record for the Site. This decision represents the final remedy selection for the Site,and, following completion of the remedial action the Site will be ready for reuse. The State ofFlorida, as represented by the Florida Department of Environmental Protection (FDEP), has beenthe support agency during the remedial investigation/feasibility study process for the Site. Inaccordance with 40 Code of Federal Regulation (CFR) Sec300.430, as the support agency, FDEPhas provided input during the process.

1.3 Assessment of Site

The response action selected in this ROD is necessary to protect the public health or welfare and theenvironment from actual or threatened releases of hazardous substances to the environment.

1.4 Description of Selected Remedy

The overall cleanup strategy for the OU2 final remedy is to remove remaining soil contaminatedwith low-levels of dioxin attributable to the former facility from nearby properties and dispose ofthe soil on the former facility property. The selected remedy for OU2 is compatible and works inconjunction with the remedy for OU1. Following completion of remedy and construction andestablishment of institutional controls, the remedy will be protective of both human and ecologicalreceptors. The Selected Remedy is compatible with the planned future use of the former facilityproperty, the Coleman-Evans Park at Whitehouse. The maj or components for the Selected Remedyinclude:

• Excavation of soil delineated with attributable dioxin contamination above the selectedcleanup goals noted in Table 6 with restoration of affected properties with clean soil;

• Placement of the soil on the pre-graded former facility property and installation of two-feetof vegetated soil cover;

• Institutional control through a restrictive covenant to limit future land use to compatiblecommercial/recreational purposes; and

• Five-Year Reviews of the remedy to ensure protectiveness is maintained.

Record of Decision Page 2Coleman-Evans Wood Preserving Company Operable Unit 02 (Residual Dioxin in Soil) September 2006

1.5 Statutory Determinations

The Selected Remedy is protective of human health and the environment, complies with Federal andState requirements that are legally applicable or relevant and appropriate to the remedial action(unless justified by a waiver), and is cost effective. This remedy utilizes permanent solutions andalternative treatment technologies to the maximum extent practicable for OU2 but does not satisfythe statutory preference for remedies that employ treatment to reduce toxicity, mobility, or volumeas a principal element. However, in conjunction with the remedy for OU1, the statutory preferencefor treatment has been satisfied for the Site. The remedy eliminates human and ecological exposureto contaminated soil, permanently controls the mobility of the contaminants, and is protective ofground water resources. The contaminated materials being addressed through OU2 are relativelyimmobile and therefore do not constitute principal threat wastes.

Because this remedy will result in hazardous substances, pollutants, or contaminants remainingon-site above levels that allow for unlimited use and unrestricted exposure, a statutory review willbe conducted within five years of construction of the remedy to ensure that the on-site remedyremains protective of human health and the environment.

1.6 Data Certification Checklist

The following information is included in The Decision Summary, Part 2 of this ROD. Additionalinformation can be found in the Administrative Record file for this Site.

• Chemicals of concern (COCs) and their respective concentrations (pages 26-27) • Baseline risk represented by the COCs (pages 25-26) a Cleanup goals established for COCs

and the basis for these levels (pages 36-37) • How source materials constituting principal threats are addressed (page 50) • Current and reasonably anticipated future land use assumptions and current and potential

future beneficial uses of ground water used in the Baseline Risk Assessment (BRA) andROD (page 25)

• Potential land and ground water use that will be available at the Site as a result of theSelected Remedy (pages 25)

• 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(pages 50, 55,61)

• Key factor(s) that led to selecting the remedy (i.e. describe how the Selected Remedyprovides the best balance of tradeoffs with respect to the balancing and modifying criteria,highlighting criteria key to the decision) (page 44)

1.7 Authorizing Signatures


PART 2: THE DECISION SUMMARY

2.1 Site Name, Location, and Brief Description

This ROD is for the Coleman-Evans Wood Preserving Superfund Site, OU2 (Residual Dioxin inSoil), that is located at 101 Celery Street in the community of Whitehouse, Duval County, Florida,approximately eight miles west of downtown Jacksonville, Florida. The site location is shown onFigure 1. The EPA is the lead agency for this Site, and the EPA Site Identification Number isFLD991279894. Site remediation is to be conducted and financed through Superfund, with the Stateof Florida's Department of Environmental Protection administering a State Cost Share often percentof the remedial action costs.

The Site encompasses the 11-acre former facility property and nearby properties that have beenimpacted by releases from the Site. The land use in the vicinity of the Site includes residential andcommercial properties. The Site is bordered on the south and west by a mix of residential andcommercial properties, on the east by woodlands, and on the north by a CSX rail line andcommercial development. This remedial action provides a final remedy that, in conjunction with theremedy for OU1, will permanently address contamination attributable to the Site and is consistentwith the planned future use of those properties.


The Site is a former wood preserving facility that produced treated lumber from 1954 to themid-1980s. Although wood-treating operations ceased in the late 1980s, sawing and kiln drying ofuntreated lumber continued at the site until mid-1994. After that time, all commercial activities atthe site ceased. Due to poor waste management practices, soil and ground water in the vicinity ofthe Site became contaminated with pentachlorophenol (PCP) and dioxin.

The Coleman-Evans Wood Preserving Site was placed on the National Priorities List (NPL) in 1983.Between 1986 and 1994, the EPA conducted several emergency response actions at the site toaddress immediate threats that could impact residents living near the site, and performed a RemedialInvestigation/Feasibility Study (RI/FS) for the site. Following completion of the emergency responseactions and the RI/FS, the EPA selected an Interim Response Action (IRA) for the site in theSeptember 1997 Amended Record of Decision (AROD), which included the excavation of on-siteand off-site contaminated soil and sediment followed by an innovative on-site treatment processcalled thermal desorption. This amended decision followed an earlier ROD (1986) and previousAROD (1990). The IRA also provided for the collection and treatment of contaminated groundwater on-site.

Soil treatment was completed in May 2004 when cleanup goals for soil established in the 1997AROD were achieved (PCP <2 milligrams per kilogram [mg/kg; 2 parts per million] and dioxintoxicity equivalent quotient [TEQ] <1 microgram [µg] per kilogram [µg/kg; parts per billion]) forthe Site. Ground water contamination was reduced to a small exceedance of ground water cleanupgoals established in the 1997 AROD (PCP <1 microgram per liter [µg/L]) in a single well that isbeing monitored for natural attenuation. During the course of this action, over 210,000 net wet tonsof soil were treated and placed on the facility property, and approximately 73,500,000 gallons ofground water and storm water were treated and discharged. The cleanup action for OU1 includedissuance of four Explanation of Significant Differences (ESDs) to address the addition of a pollutioncontrol device to the treatment system, two increases in the estimated volume of soil requiringtreatment, and a change in the technical approach to completion of the ground water remedy.

Following completion of soil treatment during the IRA, EPA and FDEP defined OU2 to addressresidual dioxin contamination of soils outside the areas addressed by the OU1 action. The residualdioxin contamination in soil both on and off the former facility property is generally present at lowconcentrations below EPA's nationally recommended residential cleanup goal of 1.0 µg/kg dioxinTEQ for Superfund site remedial actions (EPA, 1998). OU2 was necessary because the cleanup goalfor dioxin in soil in the OU1 AROD was based on EPA's nationally recommended residentialcleanup goal of 1.0 µg/kg for Superfund site remedial actions, and subsequently the State of Floridaestablished a requirement for cleanup actions to attain an incremental lifetime cancer risk (ILCR)of less than 1 X 10-6 (one in one million) and a hazard index (HI) of less than 1.0. Because thepossibility of a lower dioxin cleanup goal was contemplated at the time the OU1 AROD was signed,the OU1 cleanup was an interim action for dioxin in soil pending further cleanup to meet the lowergoal. Otherwise, the OU1 action constituted the final action for other contaminants in soil and forground water contamination.


2.2 Site History and Enforcement Activities

2.2.1 Operational History

From 1954 to the mid-1980s, the Coleman-Evans facility treated wood products with a mixture ofPCP and fuel oil. The treatment process included steaming, drying, and pressure soaking the woodproducts, all of which were carried out within a single pressurized chamber. During the steamingprocess, wood products were impregnated with PCP and No. 2 fuel oil using 255 degrees Fahrenheit(/F) steam for a period of eight hours. This process drove wood extracts from the lumber whichsettled on the bottom of the chamber with PCP and wastewater from the condensed steam. Due topoor waste management practices, soil and ground water in the vicinity of the Site becamecontaminated with PCP and dioxin. Among other sources of release, the facility operations includedchip incinerators.

Prior to 1970, the effluent wastewater from the treatment process was precipitated with caustic sodaand aluminum sulfate, passed through a sand filter and discharged into a drainage ditch whichchanneled the water south, ultimately making its way to McGirts Creek. The precipitated sludge wasdeposited into two unlined pits, each approximately 100 feet by 50 feet, located along thesoutheastern boundary of the Site. In 1970, use of the sludge disposal pits was discontinued whenthe company began storing its waste sludge in above ground storage tanks (ASTs) located near thesouthwestern edge of the facility property. During this upgrade of its waste management practices,an engineering firm was hired to design and construct a wastewater treatment system for theeffluent. Chlorination and lime precipitation then was incorporated into the treatment system toclarify the wastewater discharge.

Although wood-treating operations ceased in the late 1980s, sawing and kiln drying of untreatedlumber continued at the site until mid-1994.

2.2.2 Regulatory and Enforcement History

In September 1980, ground water contamination was confirmed at the Coleman-Evans WoodPreserving Company by the City of Jacksonville Department of Health, Welfare, and BioEnvironmental Services. As a result, Coleman-Evans incorporated activated charcoal filters into itsexisting wastewater treatment system to improve the removal of organics.

In 1981, a closed-loop steam treatment system was constructed on-site, which resulted in nodischarge of process water. In that same year, Coleman-Evans was found by EPA to be in violationof hazardous waste reporting, planning, and safety requirements enforced under the ResourceConservation Recovery Act (RCRA). In October 1981, the Site was proposed for inclusion on theNPL, based on a hazard ranking score of 59.14. In March 1983, the proposed inclusion of the siteon the NPL became final. In that same year, Coleman-Evans was identified by EPA as a generatorand storer of hazardous waste, in violation of RCRA requirements.


In September 1984, a RI/FS was initiated. The RI was delayed by the refusal of Coleman-Evans toallow access to the Site. As a result, EPA and the Department of Justice filed a motion in FederalCourt to obtain an order granting access to the Site.

In June 1985, EPA and its agents were granted access to the Coleman-Evans property. In that sameyear, EPA issued a Section 106 Removal Order to Coleman-Evans pursuant to the CERCLA.Coleman-Evans did not comply with the Section 106 Removal Order. EPA conducted EmergencyResponse Actions (ERAs) at the Site in 1985 and 1993 to control the major sources of PCPcontamination in the upper surficial aquifer and to protect nearby residents from exposure. TheERAs included:

• Excavating two on-site sludge disposal pits, including 1,000 pounds of PCP, and disposingof the waste off-site,

• Removing contaminated structures on-site, • Installing a temporary fence at the drainage ditch north and south of General Avenue to keep

children from contacting contaminated sediment in the drainage ditch, • Excavating contaminated soil and sediment in the residential area and placing it on-site; and• Installing permanent fencing and warning signs around the site pending remedial action.

In April 1986, the RI, which characterized the extent of contamination at the Site, was completed.In that same year, a Public Health Evaluation (Human Health Risk Assessment [HHRA]) identifiedPCP as the primary COC at the Site. PCP was shown to be present in sediment, soil, surface water,and in the upper surficial aquifer. In July 1986, the draft FS was released to the public, and inAugust 1986, a public meeting was held to present the FS alternatives to the community. InSeptember 1986, the ROD was signed. The 1986 ROD called for:

• Excavation and incineration of soil (approximately 9,000 cubic yards [cy]) contaminatedwith PCP at levels >10mg/kg; and

• Recovery of PCP contaminated ground water during excavation and treatment via a granularactivated carbon adsorption unit.

In October 1986, a General Notice Letter was issued to Coleman-Evans regarding implementationof the Remedial Design/Remedial Action (RD/RA). Citing financial inability, Coleman-Evansdeclined to implement the RD/RA.

In December 1987, a Special Notice Letter was issued by EPA, giving Coleman-Evans anopportunity to enter into negotiations with EPA to implement the RD/RA. Citing financial inability,Coleman-Evans again declined to implement the RD/RA.

In April 1988, a CERCLA Section 106 Order was issued to Coleman-Evans to implement theRD/RA. In response, Coleman-Evans requested a settlement conference with EPA. In April and May1988, Demand Letters were issued to Coleman-Evans and Jack Coleman (president) for past costsincurred in the 1985 ERA. In July 1988, the Department of Justice filed a civil action againstColeman-Evans, seeking recovery of those funds and punitive damages for failure to comply withthe Section 106 Order.


Due to refusal to cooperate by Coleman-Evans with the Section 106 Order, EPA decided to usefederal funding to implement the RD. Based on data collected during RD, the volume of PCPcontaminated soil needing treatment was increased to approximately 27,000 cy. Due to the increasedcost associated with treating this additional material, EPA and the FDEP decided to evaluate otheralternatives in a Treatability Study (TS).

The TS was initiated in March 1989. PCP contaminated soil samples were obtained from the Sitein order to investigate the technical effectiveness of other treatment technologies, particularly soilwashing, biotreatment, and solidification/stabilization (S/S). The TS was completed in March 1990.

In April 1990, Coleman-Evans settled with the United States Government for $350,000 and acomplete covenant not to sue. In August 1990, a public meeting was held to present the TSrecommendations and EPA's proposed amended remedy. In September 1990, an AROD was signedcalling for:

• Remediation of soil contaminated with PCP at levels greater than 25 mg/kg via a treatmenttrain consisting of soil washing, biotreatment, and S/S; and

• Recovery of PCP contaminated ground water during excavation and treatment via a granularactivated carbon adsorption unit. This treatment train was considered to be the most effectiveoverall source control method.

An additional soil sampling investigation was conducted in June 1992. This investigation determinedthat dioxin/furans are also contaminants at the Site. As a result of this finding, further sampling wasperformed to determine the extent of the dioxin/furan contamination. Due to the presence of dioxins,the selected technology train was re-evaluated. EPA completed a Focused Feasibility Study (FFS)in April 1995 as part of that re-evaluation.

The RI and subsequent investigation and removal actions at the Coleman-Evans Site were conductedbetween 1986 and 1997. A BRA was completed, and an FFS addressing remedial alternatives wasprepared by 1995. Based on the findings and conclusions of the RI, BRA, and FFS, it wasdetermined by EPA that the remedy selected in the 1990 AROD would not be effective in addressingdioxin contamination in soil. EPA issued a revised Proposed Plan identifying a preferred remedialalternative based on thermal desorption of contaminated soil, and this was circulated for communityinput. The September 1997 AROD, selected the remedy that was performed to address soil andground water contamination. This remedy was an interim action with regard to the selected cleanupgoal for dioxin in soil.

2.2.3 Previous Investigations

1986 Remedial Investigation/Feasibility Study Several site investigations were conducted between1980 and 1983. Studies of the air, soil, ground water and surface water were conducted by thefederal and state agencies and by two consultants to Coleman-Evans. Based on a review of theseinvestigations, additional data was necessary to complete a remedy action plan for the site.


In 1984, the EPA tasked Camp, Dresser and McKee, Inc. (CDM) to conduct a RI to characterize thesite in sufficient detail to support a FS to evaluate and select the cost-effective remedy for the Site.

The specific objectives of the RI were to:

• Determine the areal and vertical extent of soil contamination on the Coleman-Evans Site andin the areas adjacent to the site.

• Determine the extent of contaminant migration via ground water in the water table zone, andto determine if the limestone unit of the surficial aquifer was contaminated.

• Determine whether contaminants from the Site have migrated via surface runoff to McGirtsCreek.

• Determine if air contamination from the Site is present. • Determine the hydraulic characteristics of the water table zone, the limestone unit, and the

confining layers at the Site.

The field investigation was performed from May through October in 1985. The Final RI Report wassubmitted in April 1986. The RI concluded the following:

Soil Contamination • The soil samples collected on the facility property defined the widespread occurrence of

PCP. Contamination off the facility property to the south was identified. The vertical extentof PCP contamination was found to exist at depths ranging from 10 to 35 feet below landsurface (ft bls). Other soil contaminants included; arsenic, selenium, thallium, vanadium,chromium, beryllium, and mercury and trace amounts of cyanide. Many of these may benaturally occurring. Several organic compounds which may have leached from the fuel oilwere also detected in the soil including; naphthalene, alkanes, and xylenes. Presumptiveevidence from the laboratory indicated the presence of 2,3,7,8-tetrachloro-dibenzo-p-dioxin(TCDD) contamination in the soil. The levels could not be quantified.

Ground Water Contamination • PCP contamination of ground water off the facility property was limited to a 200 foot area

south of the property in the water table zone. No elevated metals, PCP, or 2,3,7,8-TCDDwere detected in ground water in either the water table zone outside this area or in thelimestone unit off the facility property that is used for drinking water supply.

Surface Water and Sediment Contamination • Analysis of surface water and sediment samples revealed the presence of PCP in the water

and sediments of the drainage swale leading from the site toward McGirts Creek. Surfacewater concentrations on the facility property exceeded the EPA surface water criteria, butattenuated as it migrated from the Site.

Air Contamination • There was no evidence of air contamination at the Site during the RI field effort based on the

air monitoring performed during the field events.


1985 Emergency Response Action EPA conducted an ERA at the site to control the major source of PCP contamination in the uppersurficial aquifer. Two unlined pits were excavated and the contaminated soil/sludge was shippedoffsite to a hazardous waste management facility in Emelle, Alabama. The pits were backfilled withclean material and an improved site drainage system was installed on-site.

1991-1997 Post ROD Supplemental Dioxin InvestigationsNeither the 1986 ROD nor the 1990 AROD addressed cleanup goals for dioxins or furansattributable to the Site in soil and ground water. Dioxins and furans are known by-products of themanufacture of PCP. Consequently in March 1991, PEER Consultants was contracted by EPA tosample the soils, ground water and various wastes at the Coleman-Evans site for dioxin and furancongener concentrations. Five soil samples, five ground water samples and five waste samples wereanalyzed for ten dioxin and furan congeners. Elevated levels of dioxin were detected in all the soiland waste samples. The ground water sample results were below laboratory detection limits for2,3,7,8-TCDD.

Based on the results of this study, additional soil samples were needed to delineate the soil dioxinconcentrations on and off the facility property. In June 1992, EPA conducted a field samplinginvestigation to collect surface and subsurface soil samples at seventeen locations on the facilityproperty and three locations off the property adjacent to the southwest boundary of the facility fordioxin and furan congener analysis. The results of this study detected dioxin contamination on andoff the facility property that required further delineation.

In August 1995, EPA conducted additional surface soil, subsurface soil and ground water samplingfor dioxin analysis at the residences adjacent to the south side of the facility. Four compositesamples were collected from the backyards and under the houses along General Avenue and threeground water samples were collected from the private drinking water wells from three of theresidences. The soil sample results revealed elevated levels of dioxins and furans. The ground watersamples were at or near the laboratory detection limits.

In 1995, a BRA and FFS were conducted to evaluate the most effective remedies based on thepresence of the dioxin soil contamination.

In 1996, as an attempt to delineate the lateral extent of the dioxin and furan contamination in thesurface soils adjacent to the site, the EPA tasked PRC Environmental Management, Inc. (PRC) toperform additional soil sampling. The FDEP established a soil action level of 0.007 µg/kg for dioxinTEQ in 1996. Therefore, PRC was tasked to delineate the dioxin TEQ in the adjacent soil to 0.007µg/kg. The samples were collected on a 100-foot grid pattern, from the center of the grid at theintersection of General Avenue and Celery Street. A total of 92 samples were collected. The resultsof this study did not completely delineate the lateral or vertical extent of the soil dioxin TEQ, butwas successful in further refining the site characterization.

1997-2004 Interim Response Action In the fall of 1997, the EPA tasked the U.S. Army Corps of Engineers (USACE) to conduct the RDfor the remedy selected in the 1997AROD and contract services to perform the IRA. In the spring


of 1999, the USACE and its contractor mobilized to the site to begin implementation of the IRA.Installation of the temporary thermal desorption unit and associated performance testing werecompleted and the unit began treating contaminated soil at approximately 300 tons per day. Awastewater treatment plant was also installed to treat contaminated ground water and surface waterrunoff.

Soil treatment was completed in May 2004 when cleanup goals for soil established in the 1997AROD were achieved, which were PCP < mg/kg and dioxin TEQ <1 µg/kg. Over 210,000 wet tonsof soils were treated and approximately 73,500,000 gallons of ground water and storm water weretreated and discharged. The results of the IRA are documented in the USACE's Draft InterimResponse Action Report, December 2004.

2.2.4 2005-2006 OU2 Focused Remedial Investigation

In the fall of 2005, the EPA contracted with Black & Veatch Special Projects Corporation (Black& Veatch) to perform a Focused Remedial Investigation (FRI) for OU2. The overall purpose of theFRI was to obtain the data necessary to complete delineation of the nature and extent of site-relateddioxin contamination in surface soil outside of the areas previously remediated (OU1) that pose anILCR above 1.0 X 10-6 or exceed a dioxin TEQ concentration of 0.007 µg/kg. The data gathered wasused to support a final remedy selection, and development of the RD plans and specifications,general provisions, and special requirements for the selected remedy for OU2.

The following is a summary of the FRI objectives that were established for Coleman-Evans OU2:

• Conduct a pathway evaluation for all dioxin contaminant migration and exposure pathwaysbased on review of historical operations and waste management practices;

• Review and evaluate newly acquired data and site historical data based on dioxin TEQvalues, congener composition, and profile analysis. Historical data was evaluated based onthe toxicity equivalent factor (TEF) 89 format and the data collected as part of this FRI wereevaluated using the 1998 World Health Organization (WHO) TEQ Mammalianconcentration benchmarks. The laboratory Practicable Quantitation Limit (PQL) was usedas the surrogate for non-detectable concentrations in the calculation of the dioxin TEQ;

• Compare dioxin congener composition and profiles of all available site data to literaturevalues for congener/profiles of various waste streams, including wood treating processes aswell as other common compositions for other waste practices to support an evaluation ofcontaminant attribution;

• Develop a HHRA to define a range of risk-based Remedial Goal Objectives (RGOs); and,• Development of cleanup alternatives using a presumptive remedy approach.

During the OU2 FRI field investigation, which was performed in December 2005, a total of 38surface soil samples were collected from 19 locations. Samples were collected at two depths (0 to6 inches bls and 6 to 12 inches bls). Combined with prior sampling data, the 2005 FRI data formsthe basis for the investigation findings. The data used in the FRI consists of a total of 120 samplesincluding: 49 samples collected in July 1996, 31 samples collected in December 1996, 2 samplescollected in October 2000, and the 38 samples collected in December 2005.


2.3 Community Participation

The community of Whitehouse, which surrounds the Site, has generally been supportive of thecleanup process for the Coleman-Evans Wood Preserving Superfund Site. Interest in the cleanup hasvaried over the 25-years EPA has been involved at the Site. Since completion of the IRA,community interest has been limited; focused primarily on completion of the cleanup and relatedreal estate concerns. The community has not pursued a Technical Assistance Grant for the Site.Numerous fact sheets have been issued during the cleanup process, as well as number of PublicMeetings and Public Availability sessions that have been held over the course of the cleanup. Sincethe 1997 AROD was completed, the following summarizes some of the community involvementactivities for the Site prior to issuance of the Proposed Plan:

• OU2 Focused Remedial Investigation Fact Sheet issued April 2006 • A Community Day was held on May 22, 2004 to mark completion of soil treatment; • A Public Availability Session was held in March 2004; • A Public Availability Session was held in August 2003; • A Public Meeting was held in June 2002; • A Public Workshop was held on August 15, 2001; • A Public Availability Event was held in December 2000, to discuss suspension of work; • A Public Meeting was held on April 5, 2000; • February 2004 Fact Sheet for ESD No. 3; • August 2003 Fact Sheet for ESD No. 2; • June 2002 Fact Sheet; • June 2001 Fact Sheet for ESD No. 1; • March 2001 Fact Sheet; • November 2000 Fact Sheet; • August 2000 Fact Sheet; • March 2000 Fact Sheet; • December 1999 Fact Sheet; • July 1999 Fact Sheet;

In support of this decision, the OU2 Proposed Plan Fact Sheet was made available to the communityon August 29, 2006. The Administrative Record file is available to the public and is placed in theinformation repository maintained at the EPA Region 4 Superfund Record Center and at theJacksonville West Regional Library at 1425 Chaffee Road South, Jacksonville, Florida. The noticeof the availability of the Administrative Record and an announcement of the Proposed Plan publicmeeting was published in the Jacksonville Times Union newspaper on September 3,2006. A publiccomment period was held from August 29, 2006 to September 27, 2006. The Proposed Plan waspresented to the community during a public meeting on September 14, 2006 at the WhitehouseElementary School. At this meeting, representatives from EPA and FDEP answered questions fromthe community concerning the proposed remedy. EPA's responses to the comments received duringthe public comment period are included in the Responsiveness Summary, located in Part 3 of thisROD. The transcript from the public meeting can be found in the Administrative Record and asAppendix A to this ROD.


2.4 Scope and Role of Operable Unit or Response Action

EPA has chosen to use two OUs for the Coleman-Evans Wood Preserving Superfund Site. OU1addressed contaminated soil and ground water that was present on and adjacent to the former facilityproperty and soil contamination present in areas within the surface water drainage pathway leadingfrom the facility. The cleanup goals established for soil and ground water for OU1 were final withthe exception of the interim standard selected for dioxin in soil. OU2 addresses residual dioxincontamination in soil outside the areas addressed by OU1. The final selected cleanup goal for dioxinin soil that is selected in this ROD and noted in Table 6 is below EPA's nationally recommendedresidential cleanup goal of 1.0 µg/kg for Superfund site remedial actions (EPA, 1998) that was usedfor OU1. This decision document presents the final remedy for the Coleman-Evans Wood PreservingSuperfund Site. This action will reduce or eliminate risks to human and ecological receptors fromcontaminated soil, and provide for completion of remedial action at the Site and future reuse.

2.5 Site Characteristics

2.5.1 Conceptual Site Model

The conceptual site model for OU2 describes the release mechanisms, migration pathways, andpotential exposure mechanisms for human receptors. Waste materials, the most contaminated surfaceand subsurface soil, and ground water contamination have been addressed through OU1.Attributable residual dioxin contamination of soil in areas outside OU1 generally reflect impactsfrom the same release mechanisms as OU1. Due to the lipophilic nature of dioxin and low observedconcentrations of OU2 contamination, leaching to ground water is not a pathway of concern. Asummary of the conceptual model is provided as Figure 2 and is summarized below:

• Releases from spills, former waste pits/piles, burning/incineration of waste materials,airborne dust and process emissions, and contaminated storm water runoff potentiallyimpacting surface soil outside the OU1 remediation area;

• Contaminated surface soils pose a potential incidental ingestion and direct contact risk to siteworkers and nearby residents; and

• Contaminated soil could be potentially be entrained as airborne particulates and pose a riskthrough inhalation.

2.5.2 Site Overview

The Coleman-Evans Wood Preserving Site is an 11-acre former wood preserving facility, locatedin the community of Whitehouse, Duval County, Florida, approximately eight miles west ofdowntown Jacksonville, Florida. Duval County lies within the drainage basin of the St. Johns River,in northeast Florida. The topography is coastal plain; however, rolling hills predominate throughoutthe county. The Coleman-Evans Site is bordered on the north by the CSX Railroad, on the south byresidential homes along General Avenue, on the east by heavy vegetation, and on the west byprimarily commercial properties across Celery Avenue with residences to the southwest.


The climate in Duval County, Florida is generally subtropical, but is typically cooler than the Floridapeninsula to the south. Winters may be marked by cold weather spells, a limited snow or ice eventoccurs once every few years. The hottest month is July, with an average high of 92/F, and anaverage low of 70/F. The coldest month is December, with an average high of 61/F, and an averagelow of 38/F. Normal annual precipitation is 51.3 inches, with the largest monthly totalsaccumulating from July through September 2005. Winds are variable at the Jacksonville, FloridaWSO airport, located approximately 17 miles northeast of the site. However, the annual prevailingwind direction for the airport is west-southwest based on monthly wind statistics from 1930 to 1996.

The Coleman-Evans site has been divided into two OUs. OU1 consists of the Coleman-Evans formerfacility property and the areas directly impacted by the facility operations along the drainage fromthe property to the south. OU2 is the residential/commercial area surrounding the Coleman-Evansproperty, which may contain residual site-related dioxin contamination in surface soil that is abovethe State of Florida risk-based cleanup objective of an incremental lifetime cancer risk (ILCR) below1 X 10-6. Figure 3 shows the general boundaries of OU2 study area as defined by the possiblyaffected parcels, and illustrates the known potential sources of dioxin contamination.

2.5.3 Geology

The lithological structure of the northeastern Florida is sedimentary in origin. Since Miocene times,sedimentary material has been transported to this area from the region of the present Appalachian


Mountains. The Ocala Limestone Formation of Eocene age is the upper unit of the Floridan aquifer.The Ocala is overlain by the Hawthorn Formation of Miocene age, the lower part of which acts asa confining layer for the Floridan. The upper part of the Hawthorn Formation contains lenses ofsand, limestone, and dolomite, and forms the basal part of the surficial aquifer system in DuvalCounty. The formations, which overlie the Hawthorn and comprise the remainder of the surficialaquifer system, are named according to their respective geologic ages. These formations are theUpper Miocene and Pliocene deposits, and the Pleistocene and Holocene deposits.

The Ocala Group is a homogeneous sequence of permeable, hydraulically connected marinelimestone beds. A few dolomite and less soluble limestone beds locally restrict vertical ground watermovement. The Hawthorn Formation consists of mainly dark gray and olive green, sandy to siltyclay, clayey sand, clay and sandy limestone, all of which contain moderate to large amounts of blackphosphate sand. The Upper Miocene or Pliocene deposits were found to consist of sand, shell, sandyclay, and limestone in the study area. The sediments can generally be distinguished from theHawthorn Formation by lack of phosphate and by lighter colors, usually tan, buff, or light gray.Pleistocene and Holocene sediments, which blanket all of Duval County, were deposited during theformation of marine terraces and beach ridges. These sediments overlie the Upper Miocene orPliocene deposits and were deposited on a slightly irregular, undulating surface.

The Pleistocene and Holocene deposits in the study area were found to consist of primarily tan toyellow, medium-to-fine grained, unconsolidated quartz sand. The deposits locally contain thin, gray,sandy-clay beds. Discontinuous layers of brown hardpan, underlie most of the higher areas.

The geologic data obtained during the 1986 RI generally were in accordance with published dataon the region. The top 4 to 6 feet of soil that covers the Coleman-Evans facility area consists of avery poorly cemented fine grained quartz sand. This sand is dark brown to black in color due to theabundance of heavy minerals and naturally occurring organic materials present. Minor amounts ofblack clay and silt are also present.

A hardpan layer is generally present through the site area directly below the surficial unconsolidatedzone. This relatively hard layer consists of dark brown to yellowish brown fine-grained quartz sand.This hardpan zone, which is present to approximately 30 feet bls, is thought to have been producedas a result of cementation of sand grains and soil particles by precipitation of relatively insolubleiron oxide. A grayish green to green clay and sand is present from 30 feet to approximately 100 feetbls. The clay is present in intermittent lenses. The sand portion of this zone consists of a poorlysorted, very fine to coarse grained quartz sand, with medium grains as the predominate sand size.The limestone unit, which occurs as a light gray, sandy to very sandy limestone, is present belowapproximately 100 feet. The base of this unit was not encountered by wells installed during the RI;however, local drillers' logs indicate that this limestone unit is approximately 30 feet thick in thevicinity of the Coleman-Evans Site (CDM, 1986). The upper 30 feet of sand constitutes the watertable aquifer zone. The 60-foot section sand, sandy clay, and clay acts as a confining unit above thelimestone aquifer below.


2.5.4 Hydrogeology

The top 4 to 6 feet of material in the site area consists of poorly cemented, fine-grained, quartz sandwith minor amounts of clay and silt. Below this soil cover is a well cemented, fine-grained, quartzsand unit which extends to 3 5 ft bls. This unit is considered the upper surficial aquifer at the site.A sandy clay unit with intermittent clay lenses and sand layers exists from 35 ft bls to approximately100 ft bls. This 65-foot thick unit appears to act as a confining layer, which separates the uppersurficial aquifer and the deeper limestone aquifer. The limestone unit is present from 100 ft bls toapproximately 130 ft bls. Both the upper surficial aquifer and the deeper limestone aquifer composethe surficial aquifer system.

Ground water flow in the upper surficial aquifer is predominantly from northeast to southwest. Thedepth to water is generally between 2 to 5 ft bls, and the average horizontal hydraulic gradient isapproximately 0.01. The saturated thickness of the upper surficial aquifer is 31 feet, horizontalhydraulic conductivity is 5.4 feet/day, specific yield is estimated to be 0.02, and storativity is 0.003.Recharge to the upper surficial aquifer occurs in the vicinity of the Site, and ground water dischargesto McGirts Creek to the southwest.

Ground water flow in the deeper limestone aquifer is toward the west-southwest under a horizontalhydraulic gradient of 0.04. The saturated thickness of the deeper limestone aquifer is 30 feet,horizontal hydraulic conductivity is 9.7 feet/day, and storativity is 0.0015. Based on water levelmeasurements collected from both units, the upper surficial aquifer and the deeper limestone aquiferare not in hydraulic communication (USACE, 2004).

2.5.5 Ecological Assessment

The Coleman-Evans Wood Preserving Superfund Site is located in a well-established area ofsuburban commercial, agricultural, and residential land use. As such, plant and animal habitats arefragmented and modified by development activities. No threatened or endangered species have beenidentified in the immediate vicinity of the Site, and no critical habitats are present on or adjacent tothe Site. Surface water drainage from the Site leads to McGirts Creek, an important ecologicalresource in the area.

The completed IRA resulted in the re-grading of the 11-acre facility property as well as propertyalong the Site drainage to the south. The areas addressed by OU2 are primarily residential yards,roadway right-of-ways, and similar areas. No ecological resources of concern are present withinthese areas. Potential impacts to McGirts Creek and its tributaries are the primary ecologicalconcerns at the Site.

2.5.6 Nature and Extent of Contamination

This section summarizes the results and presents conclusions derived from the FRI of OU2 (Black& Veatch, 2006a).


2.5.6.1 Nature and Extent of Residual Soil Dioxin Contamination

During the OU2 FRI field investigation, a total of 38 surface soil samples were collected from 19locations and analyzed for dioxin. Combined with prior sampling data, the 2005 FRI data forms thebasis for defining the nature and extent of OU2 dioxin TEQ contamination of soil. The data used inthe FRI consists of a total of 120 samples including: 49 samples collected in July 1996, 31 samplescollected in December 1996, 2 samples collected in October 2000, and the 38 samples collected inDecember 2005.

Since dioxins and furans may have many sources in the environment, distinguishing the individualcongeners is important in evaluating the nature and extent of site-related contamination. Dioxins andfurans refer to 75 chlorinated dibenzo-p-dioxins (CDD) and 135 chlorinated dibenzo-p-furans (CDF)congeners, respectively. These congeners have a triple-ring structure that consists of two benzenerings connected by either one or two oxygens, so referred to as furans and dioxins, respectively.CDD and CDF congeners have 8 ring positions, enumerated as 1 through 4 and 6 through 9, whichcan be occupied by chlorine. Depending on the number of substituted chlorines, CDD and CDFcongeners are distributed among eight classes of mono-through octa-chlorinated isomer groupings.

Of environmental concern are the 17 CDD/CDF congeners with four or more chlorines, whose ringpositions 2, 3, 7, and 8 are occupied by chlorines. The most toxic dioxin is 2,3,7,8-TCDD. Thetoxicity of each of the other congeners is measured relative to the toxicity of the 2,3,7,8-TCDD bya TEF. The product of a congener concentration and its corresponding TEF yields its TEQ.

CDDs/CDFs are strongly lipophilic with very low water solubility and are very stable under mostenvironmental conditions. Once adsorbed to soil, dioxins are highly resistant to leaching orvolatilization. Dioxins are not intentionally produced, with the exception of small quantitiesproduced specifically for research purposes. Instead, dioxins are byproducts of both natural andanthropogenic combustion processes such as forest fires, waste incineration, backyard barrel burns,vehicle exhaust emissions, and the manufacture of chlorinated organic compounds. A number ofdioxin sources are known to be present, or have been present, in the vicinity of the Coleman-Evanssite. Residential burning of household waste may be a component of the dioxin contamination foundin the site area, since burning of waste is documented to have occurred prior to 1968 whenresidential garbage pickup became available in the area (Black & Veatch, 2006).

The analytical results for surface soil from undisturbed/unremediated areas are used to discuss thenature of potential contamination for OU2. Figure 4 shows the soil sample locations outside the areaaddressed by OU1. All dioxin TEQ results were compared to the EPA Region 9 PRG for residentialsoil dioxin TEQ screening value of 0.0039 µg/kg and the FDEP residential Soil Cleanup TargetLevel (SCTL) of 0.007 µg/kg. Figure 5 presents the results in a grid format which includes fourranges of dioxin TEQ concentrations: (1) <0.007 µg/kg; (2) range between 0.007 µg/kg and 0.10µg/kg; (3) range between 0.10 µg/kg and 1.0 µg/kg; and (4) >1.0 µg/kg). The maximum dioxin TEQdetected for all samples within the data set was 1.30 µg/kg in Sample 5330, collected from near thenorthwest corner of the former facility property.

The analytical results for the 120 surface soil samples collected from OU2 indicate that 68 samplescontained dioxin TEQs above 0.007 µg/kg. A few of these samples were located along the outsideboundary of the area sampled. However, the results of the attribution of contamination evaluation


indicate that the extent of site-related dioxin contamination above cleanup levels has been defined.Table 1 summarizes the results of the dioxin sampling used to evaluate OU2 soil.

Table 1. Summary of Coleman-Evans OU2 Soil SamplingDioxins/Furans PRG SCTL MIN*

ng/kgMAX*ng/kg

AVERAGE*ng/kg

1,2,3,4,6,7,8-HEPTACHLORODIBENZOFURAN 2.2 4700 307.7

1,2,3,4,6,7,8-HEPTACHLORODIBENZO-P-DIOXIN 11 37000 1495.2

1,2,3,4,7,8,9-HEPTACHLORODIBENZOFURAN 0.26 250 14.8

1,2,3,4,7,8-HEXACHLORODIBENZOFURAN 0.18 1100 40.9

1,2,3,4,7,8-HEXACHLORODIBENZO-P-DIOXIN 0.29 590 20.9



1,2,3,7,8,9-HEXACHLORODIBENZOFURAN 0.25 9.4 3.9


1,2,3,7,8-PENTACHLORODIBENZOFURAN 0.14 58 4.1

1,2,3,7,8-PENTACHLORODIBENZO-P-DIOXIN 0.23 260 8.8


2,3,4,7,8-PENTACHLORODIBENZOFURAN 0.23 50 4.5

2,3,7,8-TETRACHLORODIBENZODIOXIN 0.14 10 2.9

2,3,7,8-TETRACHLORODIBENZOFURAN 0.16 60 3.9

Heptachlorodibenzodioxin (Total) 22 61000 2691.9

Heptachlorodibenzofuran (Total) 2.2 5000 430.4

Hexachlorodibenzodioxin (Total) 5.2 13000 456.8

Hexachlorodibenzofuran (Total) 0.83 8800 335.7

OCTACHLORODIBENZODIOXIN 70 230000 8926.0

OCTACHLORODIBENZOFURAN 0.77 16000 924.7

Pentachlorodibenzodioxin (Total) 1 1200 49.5

Pentachlorodibenzofuran (Total) 0.7 1900 77.7

TEQ (Avian Toxic. Equiv. Value, From WHO TEQ-98) 1.2 60 10.3

TEQ (Fish Toxic. Equiv. Value, From WHO TEQ-98) 0.88 54 10.1

TEQ (Mammalian Toxic. Equiv. Value, From WHO TEQ-98) 3.9 7 1 72 13.0

TEQ (Toxic. Equiv. Value, From I-Tef/89) 3.9 7 0 1300 57.8*Calculated minimum, maximum and average values include estimated values and non-detected values set to the reporteddetection limit.


2.5.6.2 Attribution of Residual Dioxin Soil Contamination

Due to the numerous potential sources of dioxin at the Site and because the residual dioxin TEQconcentrations in the OU2 soils are low, EPA has utilized a weight-of-evidence approach to identifysite-related dioxin contamination. The principal lines of evidence used for this approach include:review of historical site operations; contaminant pathway evaluation, including review of aerialphotographs for topography and drainage patterns; dioxin "fingerprinting"; and dioxin congenerconcentrations. Dioxin "fingerprinting" is a forensic analysis tool that can be useful in discriminatingdioxin contamination by source. Fingerprinting analysis is performed by statistically evaluating thedistribution of the individual dioxin congeners, specifically the 17 dioxin species which pose risk,to distinguish possible groupings within the data set.

Based on the statistical analyses and multiple comparisons and evaluations of the congener profiles,three groupings of the samples were identified as indicated on Figure 6. Two of these groupingshave been classified as site-related primarily based on the locations of the samples within the areapreviously remediated. The remaining group of samples appear to have a different congener profilebased on the PCA and have lower dioxin TEQ concentrations. A total of four (4) samples wereidentified outside the areas already remediated that are elevated. These elevated samples are locatedat the northwest corner of the former facility property and just off the facility property to thesoutheast and southwest as are shown on Figure 7.

The results of the statistical attribution analysis provide one line of evidence in defining theremaining site-related dioxin that exceeds cleanup goals noted in Table 6. Since the delineation ofcontamination should reflect an evaluation using the best available scientific information, aweight-of-evidence approach has been used to define the extent of contamination. The evaluationof dioxin distribution for OU2 indicates that the primary pathway of concern in transporting dioxinfrom the former facility is storm water flow. The storm water flow pathway was evaluated throughanalysis of the topography on and around the Site, review of historic drainage patterns, andinterviews with long-time residents. This evaluation concluded that properties adjacent to the Siteand along a portion of Celery Street were likely impacted by contaminated storm water flow fromthe facility property. This is substantiated, in part, by the statistical attribution analysis. The weight-of-evidence evaluation clearly indicates that samples located on properties adjacent to the formerfacility and along the identified storm water pathways are site-related.

The results of the pathways evaluation and dioxin "fingerprinting" analysis were further evaluatedin context with the observed distribution of the dioxin congeners to define dioxin contaminationattributable to the Site that exceeds cleanup goals noted in Table 6. This evaluation resulted in thedelineation of cleanup target areas and four potential additional areas, requiring further action. Theremaining ambient dioxin identified during the FRI is not considered to pose an unacceptable riskbased on EPA's nationally recommended residential cleanup goal of 1.0 µg/kg for Superfund siteremedial actions (EPA, 1998) and environmental guidelines for dioxin issued by the U.S. Agencyfor Toxic Substances and Disease Registry and Florida Department of Health. However, some ofthe ambient dioxin concentrations are elevated relative to the FDEP residential SCTL of 0.007µg/kg.


2.5.7 Potential Exposure Pathways

Exposure pathways are determined by evaluating a conceptual site model that incorporatesinformation on the chemical sources, affected media, release mechanisms, transport mechanisms,and known or potential receptors to identify potentially complete exposure pathways. A humanexposure pathway 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; and (3) there is a route of exposure (oral,dermal, or inhalation) through which the chemical may be taken into the body.

For Coleman-Evans OU2, the source of the chemical release is from spills/leaks, storm watertransport, and airborne dust/emissions from the former facility. These sources have been eliminatedthrough the removal and remedial actions already performed at the Site as part of OU1. The residualdioxin in soil that comprises OU2 may act as a secondary source of contamination, but due to thelow concentrations and current land use in this area the exposure risk is small. However, since OU2contaminated soil is present on residential properties and along public roadways, exposure byresidents and workers may occur. These exposures would primarily occur through dermal contact,but dust inhalation and incidental ingestion are possible exposure pathways.


Based on the expected fate and transport of contaminants identified at the Site, and the potential forhuman contact, the following media/receptors were identified:

• Surface Soil - Potential current and future receptors are residents and workers that may beexposed through direct contact with contaminated soil, inhalation of airborne dust, and/orincidental; ingestion.

• Air - Dust released from the contaminated soil may potentially impact current or futureresidents and workers through inhalation.

In terms of potential impacts to human health, the observed dioxin concentrations pose minimal risk.In general, these compounds resist degradation, which explains their presence several years afterfacility operations ended. In addition, they are relatively insoluble in water, and thus they remainin the soil matrix. Once bound to soil particles, they can provide a secondary source ofcontamination for further transport. Human exposure for potential receptors may occur throughdermal contact with contaminated surface soil, ingestion of contaminated surface soil, and/orinhalation of dust derived from contaminated soil. Therefore, potentially complete exposurepathways for contaminated surface soil exist for both current and future human receptors.

2.6 Current and Future Land Use

2.6.1 Current Land Use

The population of Duval County, Florida is estimated at 821,338 for the year 2004 (USCB, 2005).The main industries for employment include retail trade (17.8 percent), educational and health careservices (14.5 percent), finance, insurance, and real estate (12 percent), and manufacturing (9.1percent) (USCB, 2005).

Historically, land use surrounding the Site has included residential, commercial, and recreationalbased on observations noted from aerial photographs of the area taken between 1952 and 2004. Thisland use pattern reflects the current land use. Land use within ½-mile of the Site includes residential,a school, churches, commercial, and light manufacturing. Parcels included within OU2 include aportion of the former facility, residential and commercial land uses.

Residential properties adjacent to and near the former facility property use private water supplywells completed in the upper potion of the limestone aquifer for domestic supply. No site-relatedground water contamination has been detected in this aquifer or in these domestic supply wells.Surface water bodies in the vicinity of the site are primarily wet weather conveyances although thereis some ground water discharge along deeper portions of these ditches from the upper surficialaquifer. Stormwater from the former facility property drains predominantly to the south through aculvert and ditch system, but overland flow to the east and north also occurs. Surface water bodiesin this area are tributaries to McGirts Creek which is a locally significant ecological resource.


2.6.2 Future Land Use

As part of the reuse planning for the former facility property, the EPA has provided a reuse planninggrant to the City of Jacksonville which hired HDR/Landers Atkins Planners to research and developalternatives for future use of the Site property. The Master Plan provides a guideline for thedevelopment of a park on the undeveloped 11 acre parcel. The scope of work for the Master Planincluded three phases. These include: analysis and data gathering, plan alternatives and conceptualdesign, and the generation of the final Master Plan. The goal of the Master Plan was to provide asafe and functional place for the local residents to participate in recreational activities. Four conceptswere considered in the development of the Master Plan. The final Master Plan includes the followingfeatures: auto circulation and parking, provision of domestic water and sewer utility, a communitycenter and gymnasium, sports courts, passive recreation facilities, pedestrian circulation, andsecurity.

The planned future use of the former facility property is considered compatible with the expectedfuture use of the surrounding properties. This reflects continued growth in residential land use inwest Jacksonville along with the supporting commercial development. Since much of the areaaround the former facility is zoned commercial/residential and is in close proximity to Chaffee Roadand Interstate-10, the area impacted by OU2 may experience a changeover from predominantlyresidential to commercial land use in the future. Ground water use for domestic supply is beingsupplanted by municipal water and sewer systems in the community of Whitehouse. It is reasonableto expect that residential and commercial properties along General Avenue will be served by themunicipal water system in the future. No significant changes in the patterns of surface water floware anticipated in the foreseeable future.

2.7 Summary of Site Risks

A HHRA was completed as part of the FRI for OU2 in 2006 (Black & Veatch, 2006a)

2.7.1 Summary of Human Health Risk Assessment

The HHRA evaluates the potential risks to human health and the environment due to dioxincontamination of surface soil at the Coleman-Evans OU2 Site. The main objective of this HHRAis to provide the information necessary to assist in the decision-making process at theColeman-Evans OU2 site. The specific objectives of the HHRA are to:

• Identify and provide analysis of baseline risks (defined as risks that might exist if noremediation or institutional controls were applied at the Site) and help determine what actionis needed;

• Provide a basis for determining the levels of chemicals that could remain on-site and still notadversely impact public health and the environment; and,

• Provide a basis for comparing potential health and environmental impacts of variousremedial alternatives.


The HHRA for OU2 was based on the same 120 samples used during the FRI, and the risk posedby the detected dioxin congeners in these samples was evaluated. The procedures used in theperformance of the risk assessment and its scope are consistent with and based on EPA guidanceprocedures and policies for the performance of risk assessments at hazardous waste sites. Anexposure assessment was conducted to estimate the magnitude of actual (current) and potential(future) human exposures to site media, the frequency and duration of these exposures, and thepathways that result in human exposures. In the exposure assessment, conservative estimates ofexposure were developed for both current and future land-use assumptions. A toxicity assessmentwas performed to determine the types of adverse health effects associated with the chemicalexposure, the relationship between magnitude of exposure and adverse effects, and the relateduncertainties involved. Since the carcinogenic potency of dioxin is the subject of ongoing scientificdebate, a range of valid cancer slope factors were used in the risk assessment to evaluate the rangeof potential risks at the Site. During risk characterization, chemical-specific toxicity information wascompared with the estimated exposure levels to determine whether dioxin at the site poses currentor future risks that are of a magnitude to cause concern.

The results of the HHRA determined that the HI for the adult resident was less than 1, the thresholdof concern, in all areas, with the exception of soil sample locations 5329 and 5330. Both of thesesample locations exceeded the acceptable limit. The results of this HHRA also were evaluated todetermine the ILCR posed by OU2 soils. Since dioxin is a probable human carcinogen, evaluationof ILCR will account for a range of potentially acceptable risks (1 X 10-4 to 1 X 10-6) throughexposure (ingestion, inhalation, and direct contact) under commercial/industrial and residential landuse scenarios. This evaluation indicates that the range of ILCR in sample locations 5329, 5330, andfor the site-wide aggregate exceeded the threshold level of 1 X 10-6 for the commercial/industrialworker. The lower end of the range for ILCR in all areas as well as at sample location 5369 was lessthan 1 X 10-6 for the commercial/industrial worker; however, the upper end of the range exceededthis threshold level. The lower range at sample location 5316 was 1 x 10-6; however, the upper endof the range exceeded this level. The range of ILCR in the west, south, near the former facility, atthe noted elevated sample locations, and for the site-wide aggregate exceeded the threshold levelof 1 X 10-6 for the resident.

Site-specific exposure information was unavailable for Coleman-Evans OU2; therefore, defaultexposure assumptions and professional judgment were used to select exposure units and exposureassumptions for the various receptors evaluated in the HHRA. These exposure assumptions areconservative and are likely to overestimate hazards and risks. In conclusion, the health hazard posedby dioxin, as represented by the HI, in OU2 soils is acceptable, with the exception of noted elevatedsample locations. The ILCR of the aggregate OU2 soils, while within the EPA risk range, exceedsthe FDEP risk threshold of 1 X 10-6. The two noted elevated on-site sample locations, 5329 and5330, also exceeded the EPA risk range threshold of 1 X 10-4.

2.7.1.1 Identification of Chemicals of Concern

The OU2 investigation and HHRA evaluated dioxin in soil as the sole remaining contaminant ofconcern at the Site. Measurable concentrations of dioxin were found in surface soils both on and offthe former facility property. Dioxin TEQ was identified as the COC for OU2 following completion


of the soil-phase cleanup for OU1 that was based on EPA's nationally recommended residentialcleanup goal of 1.0 µg/kg for Superfund site remedial actions (EPA, 1998). Dioxin compounds,whose toxicity is represented as 2,3,7,8-TCDD TEFs, are comprised of over 230 individualcongeners, 17 of which may pose risk to human health. The 17 congeners which pose risk are thebasis for calculation of dioxin TEQ. The toxicity of each of congener is measured relative to thetoxicity of the 2,3,7,8-TCDD by a TEF. The product of a congener concentration and itscorresponding TEF yields its TEQ.

Dioxins are not intentionally manufactured by industry, except for research purposes. They may beformed during chlorine bleaching processes (e.g., at pulp and paper mills), and are also formedduring chlorination of waste and drinking water by treatment plants. Dioxin can occur ascontaminants in the manufacture of certain organic chemicals, such as pentachlorophenol used forwood treating. Additionally, dioxins are released into the air in emissions from municipal solidwaste and industrial incinerators, domestic trash burning, and vehicle exhaust. Finally, dioxin is aproduct of combustion and is associated with forest fires, land clearing and domestic waste burning.

2.7.1.2 Exposure Assessment

Human exposure to dioxin may occur through a number of pathways. Ingestion of foods (primarilymeat, dairy products, and fish) makes up more than 90% of the intake of dioxins for the generalpopulation. Breathing low levels of dioxin in air and drinking low levels in water also contribute toexposure. Skin contact with certain pesticides and herbicides, and living near uncontrolled hazardouswaste sites or incinerators releasing dioxins also may be specific sources of exposure. Occupationalexposure may occur through working in industries involved in producing certain pesticides, workingat paper and pulp mills, or operating incinerators.

The Coleman-Evans OU2 site consists of residential and commercial properties surrounding theColeman-Evans OU1 site. OU2 is limited to the residential and commercial propertied bordered onthe north by U.S. Highway 90, on the south by the right-of-way of Interstate 10, on the west byresidential homes two parcels deep west of Celery Avenue, and on the east by up to 14 parcels.

Current/future residents and commercial/industrial workers living and working at the OU2 site maybe exposed to contaminants in surface soil. Exposure to contaminated ground water is not considereda pathway of concern for OU2 due to the very low leachability of dioxin from soil, the low observedconcentrations of dioxin in OU2 soils, and the absence of dioxin in ground water monitored indomestic supply wells. Contaminated ground water is being addressed through the OU1 action, anddioxin is not a contaminant of concern for that action. Natural attenuation monitoring beingperformed during OU1, which includes dioxin sampling, has not indicated impacts from leachingof dioxin from soil.

This HHRA quantitatively evaluates potential risks from exposure to concentrations of dioxin TEQin surface soil on residential and commercial properties at OU2.

The conceptual site model for OU2 (Figure 2) incorporates information on the potential chemicalsources, affected media, release mechanisms, routes of migration, and known or potential human


receptors. The purpose of the conceptual site model is to provide a framework with which to identifypotential exposure pathways occurring at the Site.

An exposure pathway consists of four elements: (1) a source and mechanism of chemical release;(2) a retention or transport medium (or media in cases involving media transfer of chemicals); (3)a point of potential human contact with the contaminated medium; and (4) an exposure route (e.g.,ingestion) at the contact point. When all of these elements are present, the pathway is consideredcomplete. The assessment of pathways by which human receptors may be exposed to the chemicalsof potential concern (COPC) includes an examination of existing migration pathways (i.e., soil) andexposure routes (i.e., ingestion, dermal absorption), as well as those that may be reasonably expectedin the future.

After the sources of the COPC were identified, the next step in the development of the conceptualmodel was to determine mechanisms of release to environmental media. The primary releasemechanisms include airborne dust, surface water, drainage bank deposition, leaks, spills, and soiltrackout.

Soils at OU2 became contaminated through runoff and trackout of contaminated soil from OU1.Surface soil samples were quantitatively evaluated in the HHRA. Therefore, it was assumed thatcurrent/future residents and commercial and industrial workers may be exposed to surface soil at theOU2 site. The potentially exposed receptors and routes of exposure evaluated in the HHRA include:

• Current/future commercial and industrial worker (outdoor). Workers may be exposed todioxin TEQ in surface soil. Potential routes of exposure for the commercial and industrialworker include incidental ingestion, inhalation, and dermal contact.

• Current/future residents. Residents may be exposed to dioxin TEQ in surface soil. Potentialroutes of exposure for the residents include incidental ingestion, inhalation, and dermalcontact.

The following basic equation was used to calculate human intake of an environmental constituent:

DI = C x HIF

Where:

DI = Daily Intake (mg of chemical per kg of body weight per day). C = Concentration of the chemical in mg/kg or milligrams per Liter (mg/L) or parts per

million (ppm). HIF = Human Intake Factor (kg of medium per kg body weight per day).

Each intake variable in the above equation has a range of values. The intake variable values for agiven pathway were selected so that the combination of intake variables resulted in an estimate ofthe reasonable maximum exposure that can be expected to occur.


In the risk assessment process, potential risk is estimated as a function of exposure with potentialrisk of adverse effects increasing as exposure increases. Information on the levels of exposureexperienced by different members of the population is key to understanding the range of potentialrisks that may occur. In order to describe the range of potential risk, both high and central tendencydescriptors are used to convey the variability in potential risk levels experienced by differentindividuals in the population. For the purposes of this risk assessment, an estimate of the high endrisk descriptor is the reasonable maximum exposure (RME) and the estimate of the central tendencydescriptor is the central tendency exposure (CTE).

The concentration term used in the intake equations is an upper bound estimate of the arithmeticaverage concentration for a chemical of potential concern based on a set of site sampling results.Ideally the exposure point concentration (EPC) should be the true average concentration within anexposure unit.

The EPA has developed exposure algorithms for use in calculating RME chemical intakes throughthe exposure pathways and routes that are relevant for this site. These algorithms combine thechemical EPCs with potential pathways and route-specific parameters to produce RMEs that can beexpected to occur at the Site. Ultimately, these algorithms result in potential daily chemical intakesor doses which are expressed in terms of mg of chemical that could be taken into the body per kgof body weight per day (mg/kg-day).

Chronic daily intakes were calculated for each exposure route applicable to the current/futureresident and commercial and industrial worker. Chronic daily intakes were estimated separately forpotential carcinogenic and non-carcinogenic health effects in accordance with EPA methodology.

The current/future commercial and industrial worker (outdoor) scenario assumed that an individualworks at the site for 25 years. This value represents the 95th percentile for time spent working at onelocation. It was further assumed that the commercial/industrial worker is at work 5 days a week for50 weeks per year (250 days total).

The current/future residential scenario assumed that individuals live in the same residence for 30years. In addition, it was assumed that residents take about two weeks of vacation per year, spending350 days per year at home. Two age groups were evaluated: a child (age 1 to 6) and an adult;consequently, exposure durations of 6 and 24 years, respectively were used. A body weight of 15kg was used for a child while a body weight of 70 kg was used for an adult resident.

• Incidental Ingestion of Surface Soil. Incidental surface soil ingestion can result from placingsoil-covered hands or objects in the mouth. Surface soil ingestion is a potential route ofexposure for the current/future commercial and industrial worker and resident.

Commercial properties occupy a portion of the OU2 area. The commercial and industrialworker was assumed to be exposed to soil when performing outdoor activities. The surfacesoil ingestion rate that was assumed for the current/future commercial and industrial workerswas 100 mg per day, the soil ingestion rate recommended for workers. It was assumed thata current/future


outdoor commercial and industrial worker is exposed to COPCs in surface soil 5 days a weekfor 50 weeks per year (a total of 250 days per year) for 25 years.

Private residences also occupy a portion of the OU2 area. The current/future resident wasassumed to be exposed to surface soil during outdoor activities, such as yard work orrecreational activities. An exposure period of 350 days per year to surface soil was assumed.It has been estimated that children ages 1 to 6 incidentally ingest 200 mg of surface soil ona daily basis and that individuals over the age of 6 ingest 100 mg of surface soil per day.Therefore, residential exposure will be divided into two age groups to reflect these varyingingestion rates.

• Dermal Absorption from Surface Soil. Dermal contact with surface soil could result inabsorption of chemicals through the skin. Dermal absorption of chemicals from surface soilis a potential exposure route for current/future residents and commercial and industrialworkers.

The exposed skin areas that were used to evaluate dermal contact with surface soil areoutlined below:

• Current/Future Commercial and Industrial Worker (Outdoor) was based on the adultmale Utility Worker activity and assumes face, forearms, and hands (3,300 squarecentimeters [cm2]) are exposed. It is expected that all other body areas will becovered while working on the site and that there is minimal contact with soil.

• Current/Future Adult Resident was based on Gardeners/Grounds Keeper activity andassumes face, forearms, hands, and lower legs (5,700 cm2) are exposed.

• Current/Future Child Resident was based on children playing in wet soil and assumesface, forearms, hands, lower legs, and feet (2,800 cm2) are exposed.

In the absence of chemical-specific absorption factors, as recommended in the EPA Region4 Guidance, an absorption factor of 1.0 percent was used for organics. EPA Region 4guidance also recommends a range of 0.2-1.0 milligrams per square centimeter (mg/cm2) forthe soil to skin adherence factor. An adherence factor of 0.2 mg/cm2 was used for theoutdoor worker and 1.0 mg/cm2 was used for the adult and child residents. The value of 1.0mg/cm2 is likely over-conservative based on recent EPA guidance.

• Inhalation of Particulate Emissions from Soil. Inhalation of particulate emissions occurswhen conducting outdoor activities in unpaved areas at the OU2 site. Inhalation ofparticulate emissions from surface soil is a potential exposure route for the current/futurecommercial and industrial workers and residents. It was assumed that an outdoor workerinhales the site-related COPC at a rate of 20 cubic meters (m3) per day, 250 days per year,for a period of 25 years. The adult resident was also assumed to inhale the COPC at a rateof 20 m3 per day, 350 days per year, for a period of 24 years. The child resident was assumedto inhale the COPC at a rate of 20 m3 per day, 350 days per year, for a period of 6 years. Thedefault particulate emissions factor (PEF) of 4.63 X 109 cubic meter per kilogram (m3/kg)was used for the OU2 site. The following equation may be used to calculate a site-specificparticulate emission factor when site-specific information is available:


2.7.1.3 Toxicity Assessment

The purpose of the toxicity assessment is to identify the types of adverse health effects that achemical compound may potentially cause to define the relationship between the dose of thecompound and the likelihood and magnitude of an adverse effect (response). Adverse effects arecharacterized by the EPA as carcinogenic and non-carcinogenic. Dose-response relationships aredefined by the EPA for oral and inhalation exposures. Oral dose-response values were used to deriveappropriate dermal toxicity values.

The dose-response assessment evaluates the available toxicity information and quantitativelydescribes the relationship between the level of exposure (either from animal or humanepidemiological studies) and the occurrence of an adverse health effect. This relationship isdescribed by a cancer slope factor (CSF) or unit risk factor (URF) for carcinogens and an ReferenceDose (RfD) or reference concentration (RfC) for systemic toxicants, collectively called toxicityvalues.

Toxicity values were obtained from the following hierarchy of sources in accordance with the EPAOffice of Superfund Remediation and Technology Innovation:


• Tier 1 - Integrated Risk Information System • Tier 2 - Provisional Peer-Reviewed Toxicity Values • Tier 3 - Other (Peer Reviewed) Values, including: Agency for Toxic Substances Disease

Registry (ATSDR) Minimal Risk Levels (MRLs); California Environmental ProtectionAgency (CalEPA) values; and Health Effects Assessment Summary Tables (HEAST)

In evaluating potential health risks, both carcinogenic and non-carcinogenic health effects must beconsidered. The potential for producing carcinogenic effects is limited to substances that have beenshown to be carcinogenic in animals and/or humans. Excessive exposure to all substances,carcinogens and non-carcinogens, can produce adverse non-carcinogenic effects. Therefore, it isnecessary to identify reference doses for every chemical selected regardless of its classification, andto identify CSFs for those that are classified as carcinogenic.

Toxicity criteria used to evaluate potential non-carcinogenic health effects are termed RfDs. It isassumed in developing RfDs that a threshold dose exists below which there is no potential forhuman toxicity. The term RfD was developed by the EPA to refer to the daily intake of a chemicalto which an individual can be exposed without any expectation of non-carcinogenic effects (e.g.,organ damage, biochemical alterations, birth defects) occurring during a given exposure period. TheRfD is derived from a no-observed-adverse-effect level (NOAEL) or lowest-observed-adverse-effectlevel (LOAEL) obtained from human or animal studies. Non-carcinogenic toxicity values used inthe HHRA were based on the following:

• Oral Reference Doses. A Chronic RfD was available for the COPC at the Coleman-EvansOU2 site. The Tier 3 RfD used for dioxin TEQ was 1x10-9, as presented by the ATSDRMRL for chronic exposure. The MRL is a peer-reviewed value that is intended to serve asa screening tool.

• Inhalation Reference Doses. Inhalation RfDs are used to evaluate the risk from exposure tochemicals through inhalation exposure pathways such as the inhalation of particulateemissions from surface soil. No inhalation reference dose was available for dioxin TEQ.

• Dermal Reference Doses. No RfDs have been developed by EPA for the dermal route.Therefore, the dermal RfD was derived for the COPC in accordance with EPA guidelines.A chronic dermal RfD was derived by multiplying the value used as the chronic oral RfDby an appropriate gastrointestinal absorption value (ABSGI).

Carcinogenic potency was estimated based on the CSF. CSFs are developed by the EPA under theassumption that the risk of cancer from a given chemical is linearly related to dose. EPA maydevelop cancer slope factors from laboratory animals or epidemiological studies in which relativelyhigh doses of the chemical were administered. It is conservatively assumed that these high doses canbe extrapolated downward to extremely small doses, with some incremental risk of cancer alwaysremaining until the dose is zero. As a result, the estimated carcinogenic risk is likely to represent aplausible upper limit to the risk.

The carcinogenic potency of a substance depends on its route of entry into the body (i.e., oral,inhalation, or dermal). Therefore, slope factors are developed and classified according to the


administration route. EPA has not developed dermal slope factors for any carcinogens. The basisfor evaluating carcinogenic toxicity was as follows:

• Oral Slope Factors. Oral slope factors are used to evaluate the risk from exposure to potentialcarcinogens through oral exposure pathways such as, incidental ingestion of soil. Oral slopefactors were available for the carcinogen TEQ. The toxicity values from three Tier 3 sourceswere available and include the cancer slope factor of 1.5 x 105, as presented by the HEAST,2.6 x 104 as presented by the CalEPA, and 1 x 106 as presented in the dioxin reassessmentdraft document submitted by EPA to the National Academy of Sciences. The CalEPA cancerslope factor is the proposed public health goal for dioxin in drinking water.

• Inhalation Slope Factors. Inhalation slope factors are used to evaluate the risk from exposureto potential carcinogens through inhalation exposure pathways such as the inhalation ofparticulate emissions from surface soil. Inhalation toxicity values are given as unit risks forcarcinogens. The conversion to an inhalation slope factor is accomplished as follows: Inhalation SF = Unit Risk (µg/m3)-1 x 70 kg x (20 m3/day)-1 x 1,000 µg/mg (mg/kg-day)-1

• Dermal Slope Factors. As with reference doses, dermal slope factors are not available fromthe EPA, but it was assumed that chemicals which are carcinogenic orally will also producecancer by dermal exposure. In the absence of dermal slope factors, the oral slope factor isdivided by an appropriate ABSGI absorption value.

2,3,7,8-TCDD is known to be one of the most potent compounds in producing the skin disorder,Chloroacne. In addition, symptoms such as aching muscles, loss of appetite, weight loss, digestivedisorders, easy fatigability, insomnia, loss of libido, headache, neuropathy, sleep disturbance,sensory changes, and uncharacteristic bouts of anger have been reported in some case studies ofsmall groups of people exposed to 2,3,7,8-TCDD at high levels in an occupational setting or inindustrial accidents. Evidence that 2,3,7,8-TCDD is a human carcinogen has been difficult to assess,but animal data clearly indicate that it acts as either a complete carcinogen or a carcinogen promoterand has been classified by EPA has a probable human carcinogen.

2.7.1.4 Risk Characterization

The risk characterization is an evaluation of the nature and degree of potential carcinogenic andnon-carcinogenic health risks posed to current and future receptors at the Coleman-Evans OU2 site.Non-carcinogenic and carcinogenic risks were evaluated for each exposure pathway and scenarioby integrating the calculated exposure doses with the toxicity criteria for dioxin.

The risk of adverse non-carcinogenic effects from chemical exposure is expressed in terms of thehazard quotient (HQ). The HQ is the ratio of the daily intake that a human receives to the RfD, theestimated dose below which it is unlikely for even sensitive populations to experience adverse healtheffects. Since dioxin TEQ is the sole contaminant of concern for Coleman-Evans OU2, the HQ andHI, which is the sum of all contaminant HQs, are the same. A HI less than 1 indicates that, basedon the sum of all HQ's from different contaminants and exposure routes, toxic non-carcinogeniceffects from all contaminants are unlikely. A HI greater than 1 indicates that site-related exposuresmay present a risk to human health.


The HI for OU2 was well below the threshold of concern for the commercial and industrial workerin all areas. The HI for the adult resident was below 1 in all areas, with the exception of the samplelocations 5329 and 5330. Both of these locations exceeded the acceptable limit. The HI for the childresident was below 1, the acceptable level of concern in areas off the facility property. However,sample locations 5329 and 5330 exceeded the acceptable limit as did the sitewide aggregate. Table2 summarizes the calculated HI for OU2 soils.

The incremental risk of developing cancer from exposure to a chemical at the site is defined as theadditional probability that an individual exposed will develop cancer during his or her lifetime(assumed to be 70 years). This value is calculated from the average daily intake over a lifetime(chronic daily intake [CDI]) and the CSF for the chemical as follows:

Risk = CDI x CSF

According to EPA policy, the target total individual risk resulting from exposures at a SuperfundSite may range anywhere between 1 X 10-6 and 1 X 10-4. Thus, remedial alternatives should becapable of reducing total potential carcinogenic risks to levels within this range for individualreceptors. For the Coleman-Evans OU2 Site, the risk management decision was made to designatea risk estimate of 1 X 10-6 as unacceptable. Therefore, if the cancer risk exceeded 1 X 10-6, then thelevels of dioxin TEQ were considered unacceptable and remediation may be warranted in that areafor the specified receptor. A summary of the range of carcinogenic risks for each receptor ispresented in Table 2.

Table 2. Coleman-Evans OU2 Soil Cancer Risk Summary

Areas

Receptor

Commercial/Industrial Worker (ILCR range/HI)

Adult Resident (ILCR range/HI)

Child Resident(ILCR range/HI)

Resident * (ILCR range)

Sample Location 5316 Sample Location 5329 Sample Location 5330 Sample Location 5369 Site-wide

1E-06 - 5E-05/0.2 4E-06 - 1E-04/0.4 7E-06 - 3E-04/0.7

8E-07 - 3E-05/0.09 2E-06 - 7E-05/0.2

5E-06 - 2E-04/0.6 1E-05 - 5E-04/2 3E-05 - 1E-03/3

3E-06 - 1E-04/0.3 7E-06 - 3E-04/0.8

9E-06 - 4E-04/4 2E-05 - 9E-04/11 4E-05 - 2E-03/19 5E-06 - 2E-04/2 7E-05 - 4E-04/5

1E-05 - 6E-04 3E-05 - 1E-03 7E-05 - 3E-03 8E-06 - 3E-04 8E-05 - 7E-04

* In accordance with EPA guidance, the cancer risk results for the child and adult were combinedto obtain an excess cancer risk for a resident (30 years) (EPA, 1989).

As indicated above, the range of cancer risks at sample locations 5329, 5330, and Site-wideexceeded the acceptable level of 1 X 10-6 for the commercial and industrial worker. The range ofcancer risks site-wide exceeded the acceptable level of 1 X 10-6 for the resident.

Site-specific exposure information was unavailable for the Coleman-Evans OU2 site; therefore,default exposure assumptions and professional judgment were used to select exposure units andexposure assumptions for the various receptors evaluated in the HHRA. These exposure assumptions


are conservative and are likely to overestimate hazards and risks. Three CSFs were used to calculaterisks associated with dioxin TEQ at the Coleman-Evans OU2 site. All CSFs used are considered Tier3 toxicity values. These values have not been validated and are considered draft, thus introducinguncertainty into the HHRA. The risk calculated for site OU2 may be overestimated orunderestimated.

The HHRA was conducted in a manner in which comparisons could be made between the cancerrisks and hazards for the commercial/industrial worker and the child and adult residents exposed tosite-related and non-site related dioxin concentrations. The results of the analysis indicate that thecancer risks and hazards for the non site related dioxin concentrations are in the range of thesite-related dioxin concentrations at the Coleman-Evans OU2 Site.

2.7.1.5 Uncertainties

There are uncertainties which are inherent in the risk assessment process. The factors which maylead to either an overestimation or an underestimation of the potential adverse human health effectsand associated environmental risks posed by exposures to contaminants from Coleman-Evans OU2include the following:

• Contaminant concentrations in soil for future use were assumed to be the same as currentconcentrations, with no adjustment due to migration or degradation. This may result in anoverestimation of dose;

• The RME concept was used to develop exposure doses in the current/future scenarios andis defined as the "maximum exposure that is reasonably expected to occur at the site".Several variables that were used to determine the exposure dose for the RME are generallybased on upper-bound (typically 90th percentile or greater) estimates. These are:

o Exposure duration (upper-bound value). o Intake/contact rate. o Exposure frequency.

Therefore, the calculated exposure dose for any given chemical, which results from integration ofthese variables, typically represents an upper-bound probable exposure dose estimate. The use ofthese upper bound exposure parameters, coupled with conservative estimates of toxicity, will yieldrisk results that represent an upper-bound estimate of the occurrence of carcinogenic andnon-carcinogenic health effects;

• The toxicological uncertainties primarily relate to the methodology by which carcinogenicand non-carcinogenic criteria (i.e., CSFs and reference doses) are developed. In general, themethodology currently used to develop CSFs and reference doses is very conservative, andlikely results in overestimation of human toxicity;

• The EPA's linear extrapolation approach for CSFs assumes there are increased risk of cancerat all levels of exposure. This uncertainty implies that exposure to even a single moleculeof a chemical may be associated with a finite risk, however small. A significant uncertaintyfor the carcinogens is whether the CSFs accurately reflect the carcinogenic potency of these


chemicals at low exposure concentrations. The calculated slope factor is used to estimate anupper bound lifetime probability of an individual developing cancer as a result of exposureto a particular carcinogen level. Therefore, the CSFs developed by EPA are generallyconservative and represent the upper bound limit of the chemical's carcinogenic potency. Theactual risk posed by each chemical is unknown but is likely to be lower than the calculatedrisk, and may even be as low as zero. The CSFs used for OU2 are considered Tier 3 toxicityvalues; and,

• Three CSFs were used to calculate the risks from exposure to dioxin at the Coleman-EvansOU2 Site. This methodology was implemented due to the limitations of the epidemiologicdata and the necessity to extrapolate the effects across various species as well as humans.The scientific community has not reached consensus on the reliability of using animal datato estimate human hazards and risks when dealing with this class of compounds.

2.7.2 Summary of Ecological Risk Assessment

A baseline ecological risk assessment was not performed for Coleman-Evans OU2. Due to theextensive rework of the former facility property during the remedy for OU1, the limited scope ofOU2, and the existing state of development in the area, an ecological risk assessment was notconsidered necessary.

2.8 Remedial Action Objectives

Remedial Action Objectives (RAOs) for the Coleman-Evans Wood Preserving Company SuperfundSite OU2 were developed based on a review of the results of the site sampling data, site-specific riskand fate and transport evaluations, and review of applicable, or relevant and appropriate,requirements (ARARs). The contaminant of concern for OU2 is dioxin TEQ.

Clean-up goals noted in Table 6 were derived from analysis described in more detail in the HHRAand from ARARs and were related to the risks identified at the Site. Contaminated soils on and offthe former facility property exceed the acceptable potential residential and worker cancer riskassociated with direct exposure to soils and exceed the acceptable potential residential non-cancerrisk associated with direct exposure to soils.

Under the NCP, EPA's goal is to reduce the excess cancer risk to the range of 1x10-4 to 1x10-6 forthe expected future land use at the Site. The cleanup goals being selected for OU2 are based on afuture residential land use for the properties surrounding the Site and a commercial land use for theformer facility property. The ARAR-based cleanup goal for dioxin TEQ is based on Florida StatuteSection 376.30701 requiring cleanups to attain an ILCR of <1 X 10-6 and a HI of <1 fornon-carcinogens. This cleanup goal results in a more stringent cleanup goal than EPA's nationallyrecommended residential soil cleanup goal of 1.0 µg/kg for Superfund site remedial actions (EPA,1998). The RAOs developed to address the above issues include the following:

• Prevent incidental ingestion, dust inhalation, or direct contact with surface soil that containconcentrations of dioxin TEQ attributable to the Coleman-Evans Wood PreservingSuperfund Site in excess of the soil cleanup goals noted in Table 6 of this ROD; and,


• Control future releases of contaminants to ensure long-term protection of human health andthe environment.

Based on the human health risk-based criteria and analysis of ARARs, the final cleanup goals forcontaminated soils at the Coleman-Evans Wood Preserving Company Superfund Site OU2 arepresented on Table 6. As noted above, these cleanup goals were prepared from analysis describedin more detail in the HHRA and from ARARs.

2.9 Description of Alternatives

Three remedial alternatives were developed for detailed evaluation to address surface soilcontamination in off-site areas associated with Coleman-Evans OU2. Cleanup alternatives for OU2were based on a presumptive remedy approach. This approach is appropriate due to low contaminantconcentrations levels, limited volume of contaminated soil, the lack of viable treatment alternativesto reach the cleanup goals, and the overall compatibility of this approach with the OU1 remedy. Thepresumptive remedies to address the site-related dioxin contaminated surface soils that pose anunacceptable risk include excavation with on-site disposal, and excavation with off-site disposal.Additional components of the remedy would include modifications to the soil cover (relative to theplanned OU1 cover) and institutional controls. Additionally, a no action alternative was alsoconsidered for a baseline comparison, which is a requirement of the NCP and the Superfundprogram.

2.9.1 Detailed Remedial Alternatives Evaluation

2.9.1.1 Alternative 1 -- No Action

Under this alternative, no action would be taken to remedy the contaminated soil. Five-YearReviews would be performed to evaluate the ongoing protectiveness of the remedy. No additionalfunds would be expended to conduct the reviews, since five-year reviews are already a componentof the OU1 remedy. It is anticipated that each Five-Year Review would consist of a site visit andreport preparation.

Overall Protection of Human Health and the Environment

Because remedial actions would not be initiated as part of this alternative, it would not provide anyincreased protection to human health. If no action is taken, contaminants would remain in place.

Compliance with ARARs

This alternative does not achieve the RAOs or chemical-specific ARARs established for thecontaminated surface soil. Action-specific ARARs do not apply to this alternative since furtherremedial actions will not be conducted.


Long-Term Effectiveness and Permanence

The continued exposure of receptors to surface soil is a potential long-term impact of thisalternative. The cleanup goals noted in Table 6 for protection of human health would not be met.Because contaminated material remains on-site under this alternative, a review/reassessment of theconditions at the site would be performed at 5-year intervals to ensure that the remedy does notbecome a greater risk to human health and the environment.

Reduction of Mobility/Toxicity/Volume (M/T/V) Through Treatment

No reductions in contaminant M/T/V are realized under this alternative.

Short-Term Effectiveness

Since no further remedial actions would be implemented at the site, this alternative poses noshort-term risks to onsite workers. It is assumed that Level D personal protection would be usedwhen conducting site visits for Five-Year Reviews.

Implementability

This alternative could be implemented immediately because monitoring equipment is readilyavailable and procedures are in place.

Cost

There are no capital or annual costs associated with this alternative.

2.9.1.2 Alternative 2 — Excavation with On-Site Disposal

This alternative addresses site-attributable dioxin contamination above the cleanup goals noted inTable 6 identified at sample locations 5316, 5329, 5330, and 5369 and areas adjacent to the site andadjacent to drainage pathways which may have been impacted by contaminated storm water runofffrom the Site. These excavation areas are shown on Figure 7, and will include four "Hot Spot" areasto be defined in consultation with FDEP during remedial design. Pre-excavation vertical delineationsampling will be performed to refine the vertical delineation of the proposed excavation areas, andsample locations 5329 and 5330 (northwest boundary of the facility property) will be addressedthrough the grading plan for the former facility property. It is estimated that approximately one soilsample per 40 linear feet of proposed excavation will be collected at depths of 6 inches to 1 foot blsand will be analyzed for dioxins to complete vertical delineation. The excavated soil will be placedand graded on the facility property to match pre-cover grades for the Site. The excavations withinresidential properties will be backfilled with clean topsoil and re-sodded. The remaining excavationareas will be backfilled with clean fill and re-seeded. The action will take approximately six monthsto complete from pre-excavation sampling to final completion.

The soil cover for the OU1 remedy will be augmented by an additional 1-foot of clean soil, and thefinal grades will be contoured to drain predominately away from the residential tracts along the


southern boundary of the property. The cover will be seeded to stabilize the soil (as alreadyproposed for the OU1 remedy). A restrictive covenant will be established to limit the use of theproperty to commercial/industrial (including use as a park) as an institutional control. Five-YearReviews will be performed to ensure the remedy remains protective and effective.

Leaving waste on-site beneath a cover system that protects people and the environment fromexposure and prevents contaminant migration is not incompatible with a successful redevelopmentof the site. Understanding and accommodating future use in selecting and implementing remediesis an important part of EPA's cleanup responsibility. Modifications to the design can be consideredthat better reflect the future use of the area, as those plans become better defined. For example, thedesign and location of waste containment areas may provide for future utility access in anticipatingfuture use. Because EPA has a responsibility to choose and implement (as far as possible) remediesthat are consistent with anticipated use, this example of accommodating the remedy to anticipatedfuture use can be considered part of the remedial activities because it contributes to the long-termprotectiveness of the remedy. However, EPA is prohibited from funding, or requiring others to fund,activities that are considered "enhancements" to the remedy.

Additional necessary components of this alternative include institutional controls, and periodicinspections and reviews. Restrictive covenants would be placed on the property to restrict the futureuse of the property to those uses compatible with the remedy. State and local agencies would beresponsible for the enforcement of these restrictions. Monitoring would be required to assess theeffectiveness of the remedial action.


Alternative 2 would protect the public and the environment from the risks posed by site-attributablecontaminants in the soil at the site by removing and isolating the site-attributable contaminated soilfrom human receptors.

The estimated time of remediation for Alternative 2 is approximately six months from pre-remedialsampling to completion. Engineering controls, such as fencing and barricading, would beimplemented to reduce the risk of injury while remediation is occurring. Once remediation iscomplete, no long-term residual risks would be expected due to site-attributable soil contaminationfrom the remediated areas. Cross-media impacts are not expected to occur.


This alternative achieves the RAOs and chemical-specific ARARs established for the Site byconsolidating and isolating contaminated surface soil and implementing restrictions on land use. Airquality and emission standards also would have to be met during the implementation of thisalternative.



Excavation and on-site disposal of the contaminated soil would permanently remove the specifiedvolume of contaminated soil from the off-site areas. The construction of a vegetated soil cover andthe implementation of deed restrictions would eliminate the long-term risk associated with thecontaminants.

Reduction of M/T/V Through Treatment

This alternative does not meet the statutory preference for treatment as a principal element. Theuntreated contaminated soil will be transported to the Coleman-Evans site for disposal. Theconstruction of a 2-foot thick vegetated soil cover would reduce the mobility of the contaminants.Removal of the contaminated soil would result in the reduction of contaminant mobility, but nottoxicity or volume at the Site. The excavation areas would be backfilled with clean soil andre-seeded or re-sodded as appropriate.


Community risk associated with Alternative 2 would be low during the soil removal and minimalfor the transportation of the soil. The risk would be greater for workers performing the remedialaction, but would be minimized by compliance with Occupational Safety and Health Administration(OSHA) requirements and guidelines for general construction site activities. Due to the lowconcentrations, soil removal and transportation activities would not require that these workers betrained and certified to perform hazardous waste site activities and transport; and these workerswould not be required to wear Level D personal protective equipment during soil removal andloading/dumping.

Environmental impacts resulting from the soil removal would include noise pollution during theremoval and transport of the soil. During the remedial action, construction controls would beimplemented to minimize contact with contaminated soil. Erosion controls would be required, andsurface water runoff would require management during construction activities. Any wastesgenerated during construction activities would be collected and disposed of properly at appropriatefacilities.

The time required to achieve cleanup goals noted in Table 6 is estimated to be six months from theonset of pre-excavation sampling activities. The soil excavation and restoration is estimated to takeapproximately six weeks.

Implementability

The removal and disposal of contaminated soil is an established remedial alternative. Contractorsthat perform this type of work are readily available and abundant. Additional remediation at the site,if required, could be implemented fairly easily and may include the adjustment of areas ofcontamination removal.


Cost

The capital costs include both direct and indirect capital costs. The direct capital costs include theadditional vertical delineation sampling; soil excavation, testing, transportation and disposal;backfilling with clean fill; associated equipment, materials, and supplies; permits and licenses;engineering design, procurement, and reporting; and construction oversight. With the addition ofindirect costs, the total capital cost is estimated to be $836,785.

O&M activities associated with this alternative include Five-Year Reviews; however, sinceFive-Year Reviews are already included in the remedy for OU1, there would be no additional costsassociated with the Five-Year Reviews for this alternative. The total present worth of Alternative2 is estimated to be $1,307,476, including contractor fees, engineering and administrative costs, andcontingencies.

2.9.1.3 Alternative 3 — Excavation with Off-site Disposal

This alternative addresses the same contaminated soil as Alternative 2, specifically site-attributabledioxin contamination above the cleanup goal noted in Table 6 identified at sample locations 5316,5329, 5330, and 5369 and areas adjacent to the site and adjacent to drainage pathways, which mayhave been impacted by contaminated storm water runoff from the site. These excavation areas areshown on Figure 7 and will include four "Hot Spot" areas to be defined in consultation with FDEPduring remedial design. Pre-excavation vertical delineation sampling will be performed to refine thevertical delineation of the proposed excavation areas, and sample locations 5329 and 5330(northwest boundary of the facility property) will be addressed through the grading plan for theformer facility property. It is estimated that approximately one soil sample per 40 linear feet ofproposed excavation will be collected at depths of 6 inches to 1 foot bls and will be analyzed fordioxins to complete vertical delineation. The excavated soil will be hauled to a permitted off-sitefacility for disposal. This alternative will not require modification of the soil cover or institutionalcontrols proposed for the OU1 remedy. The excavations within residential properties will bebackfilled with clean topsoil and re-sodded. The remaining excavation areas will be backfilled withclean fill and re-seeded. The action will take approximately six months to complete frompre-excavation sampling to final completion. Five-Year Reviews will be performed to ensure theremedy remains protective and effective.


Similar to Alternative 2, Alternative 3 would protect the public and the environment from the risksposed by site-attributable contaminants in the soil at the site by removing and isolating thesite-attributable contaminated soil from humans and environmental receptors.

The estimated time of remediation for Alternative 3 is approximately six months from pre-remedialsampling to completion. Engineering controls such as fencing would be implemented to reduce therisk of injury while remediation is occurring. Once remediation is complete, no long-term residualrisks would be expected due to site-attributable soil contamination from the remediated areas.Cross-media impacts are not expected to occur.



This alternative achieves the RAOs and chemical-specific ARARs established for the contaminatedsurface soil at the site since areas of concern are being excavated and transported off-site fordisposal. Air quality and emission standards also would have to be met during the implementationof this alternative. Transportation of contaminated soil would have to comply with all federal andstate ARARs concerning hazardous and/or non-hazardous material transportation. In addition, thisalternative would require compliance with RCRA removal, transportation, and land disposalregulations.


Excavation and off-site disposal of the contaminated soil would permanently remove the specifiedvolume of site-attributable contaminated soil from the off-site areas. The off-site disposal at anappropriate engineered disposal facility would eliminate the long-term risk associated with thecontaminants.

Reduction of M/T/V Through Treatment

This alternative does not meet the statutory preference for treatment as a principal element. Theuntreated contaminated soil will be transported to an appropriate off-site facility for disposal,resulting in a reduction in mobility of the site contaminants. Toxicity and volume would not bereduced. The excavation areas would be backfilled with clean soil and re-seeded or re-sodded asappropriate.


Community risk associated with Alternative 3 would be low during the soil removal and minimalfor the transportation of the soil, similar to Alternative 2. The risk would be greater for workersperforming the remedial action, but would be minimized by compliance with OSHA requirementsand guidelines for general construction site activities. Due to the low concentrations, soil removaland transportation activities would not require that workers be trained and certified to performhazardous waste site activities and transport, and these workers would not be required to wear LevelD personal protective equipment during soil removal and loading/dumping.

Environmental impacts resulting from the soil removal would include noise pollution during theremoval and transport of the soil. During the remedial action, construction controls would beimplemented to minimize contact with contaminated soil. Erosion controls would be required, andsurface water runoff would require management during construction activities. Transportation of thecontaminated soil to the off-site disposal facility would create short-term risks associated withincreased vehicle traffic. And these risks would be quantitatively evaluated in a transportation planshould this alternative be selected. Any wastes generated during construction activities would becollected and disposed of properly at appropriate facilities.


The time required to achieve cleanup goals noted in Table 6 is estimated to be six months from theonset of pre-excavation sampling activities. The soil excavation and site restoration are estimatedto take approximately six weeks.

Implementability

The removal and disposal of contaminated soil is an established remedial alternative. Contractorsthat perform this type of work are readily available and abundant, and appropriate disposal facilitiescapable of handling the volumes of soil requiring disposal are regionally available. Additionalremediation at the site, if required, could be implemented fairly easily and may include theadjustment of areas of contamination removal.

Cost

The capital costs include both direct and indirect capital costs. The direct capital costs include theadditional vertical delineation sampling; soil excavation, testing, transportation and disposal;backfilling with clean fill; associated equipment, materials, and supplies; permits and licenses;engineering design, procurement, and reporting; and construction oversight. With the addition ofindirect costs, the total capital cost is estimated to be $1,949,540.

O&M activities associated with this alternative include Five-Year Reviews; however, sinceFive-Year Reviews are already included in the remedy for OU1, there would be no additional costsassociated with the Five-Year Reviews for this alternative. The total present worth of Alternative2 is estimated to be $3,046,109, including contractor fees, engineering and administrative costs, andcontingencies.

2.9.2 Common Elements and Distinguishing Features of the Alternatives

With the exception of Alternative 1 - No Action, both alternatives address surface soil contaminatedabove remedial cleanup goals noted in Table 6, and meet the threshold criteria of protection ofhuman health and the environment and attainment of ARARs. Since Alternative 1 - No Action doesnot meet these criteria, it will not be discussed further in this section. The contaminated soil islocated in off-site areas, and all of the alternatives are based on excavating the off-site areas,backfilling the excavated areas with clean fill, and re-seeding or re-sodding. The volume ofcontaminated soil to be addressed is the same for both alternatives and is approximately 3,770 cy.

Both remedial alternatives consider one basic approach to address contaminated soil at theColeman-Evans OU2 Site. Alternatives 2 and 3 reduce or eliminate the mobility of the contaminantsthrough containment. Both of these alternatives involve reasonably well-established technologiesthat can be readily implemented. Neither of the alternatives meets the statutory preference fortreatment to reduce the M/T/V of contamination. The short-term impacts and the duration of theseimpacts of both alternatives are similar.


2.10 Comparative Analysis of Alternatives

The seven remedial alternatives have been examined with respect to the requirements in the NCP(40 CFR Part 300.430[e][9] iii), CERCLA, and factors described in Guidance for ConductingRemedial Investigations and Feasibility Studies Under CERCLA (EPA 1988). The nine evaluationcriteria include the following:

Threshold Criteria

• Overall protection of human health and the environment; and, • Compliance with ARARs.

Balancing Criteria

• Short-term effectiveness; • Long-term effectiveness and permanence; • Reduction of mobility, toxicity, or volume through treatment; • Implementability; and, • Cost.

Modifying Criteria

• State acceptance; and • Community acceptance.

A comparative analysis of the soil alternatives based on the threshold and balancing evaluationcriteria is presented below. The objective of this section is to compare and contrast the alternativesto support selection of the remedy for Coleman-Evans OU2 Site. The alternatives compared include:

• Alternative 1 - No Action; • Alternative 2 - Excavation and On-site Disposal; and • Alternative 3 - Excavation with Off-site Disposal;

Table 3 presents a summary of each remedial alternative along with qualitative ranking scores foreach evaluation criterion. Each alternative's performance against the criteria (except for presentworth) was ranked on a scale of 0 to 5, with 0 indicating that none of the criterion's requirementswere met and 5 indicating all of the requirements were met. The ranking scores combined with thepresent worth costs provide the basis for comparison among alternatives. With the exception ofshort-term effectiveness, Alternatives 2 and 3 are ranked higher than Alternative 1 across all thecriteria. Alternatives 2 and 3 are the same for overall protection, compliance with ARARs, reductionof M/T/V, and implementability. Alternative 3 ranks slightly higher in long-term effectiveness andpermanence.

Record of DecisionColeman-Evans Wood Preserving CompanyOperable Unit 02 (Residual Dioxin in Soil)

Page 45

September 2006

Table 3. Comparative Evaluation of Remedial Alternatives for Coleman-Evans OU2

RemedialAlternative

1 — No Action

Criteria Rating

Overall Compliance Long-TermProtection of with Effectiveness

HumanHealth and

theEnvironment

ARARs andPermanence

Reduction ofM/T/V

ThroughTreatment

Short-TermEffectiveness

Implement-Ability

ApproximatePresent Worth

($)

$0

2 — Excavationw/On-siteDisposal

3 — Excavationw/Off-siteDisposal

$1,307,476

$3,046,109

Rating is based on professional engineering judgment with 0 being the lowest rating and 5 being the highest for each criteria


2.10.1 Overall Protection of Human Health and the Environment

All of the alternatives, except Alternative 1 - No Action, would provide protection of human healthand the environment by eliminating, reducing, or controlling risk through removal, treatment, and/orcontainment with engineering and institutional controls. Since Alternative 1 does not meet thethreshold criteria for the cleanup, it will not be discussed further in this section.

2.10.2 Compliance with Applicable or Relevant and Appropriate Requirements

Section 121(d) of CERCLA and NCP § 300.430(f)(1)(ii)(B) require that remedial actions atSuperfund sites at least attain legally applicable or relevant and appropriate Federal and Staterequirements, standards, criteria, and limitations, which are collectively referred to as "ARARs,"unless such ARARs are waived under CERCLA Section 121(d)(4).

Applicable requirements are those cleanup goals, standards of control, and other substantiverequirements, criteria, or limitations promulgated under Federal or State environmental laws orfacility siting laws that specifically address a hazardous substance, pollutant, contaminant, remedialaction, location, or other circumstance found at a Superfund site. Only those State standards that areidentified by a state in a timely manner and that are more stringent than Federal requirements maybe applicable. Relevant and appropriate requirements are those cleanup goals, standards of control,and other substantive requirements, criteria, or limitations promulgated under Federal or Stateenvironmental laws or facility siting laws that, while not "applicable" to a hazardous substance,pollutant, contaminant, remedial action, location, or other circumstance at a Superfund site, addressproblems or situations sufficiently similar to those encountered at the Superfund site that their useis well-suited to the particular site. Only those State standards that are identified in a timely mannerand are more stringent than Federal requirements may be relevant and appropriate. Compliance withARARs addresses whether a remedy will meet all of the applicable or relevant and appropriaterequirements of other Federal and State environmental statutes or provides a basis for invokingwaiver.

Each remedial alternative is evaluated for its compliance with ARARs as defined in CERCLASection 121(f). The following items must be considered during the evaluation:

• Compliance with contaminant-specific ARARs (i.e., maximum contaminant levels [MCLs]).This consideration includes whether contaminant-specific ARARs can be met and whethera waiver may be appropriate if they cannot be met.

• Compliance with location-specific ARARs (i.e., protection of historic sites, regulationsregarding activities near wetlands/floodplains). This consideration includes whetherlocation-specific ARARs can be met or waived.

• Compliance with action-specific ARARs (i.e., RCRA treatment technology standards). Thisconsideration includes whether action-specific ARARs can be met or waived.

All of the alternatives, except Alternative 1, No Action, would comply with ARARs by addressingsurface soils contaminated above remedial cleanup goals noted in Table 6.


2.10.3 Long-Term Effectiveness and Permanence

Long-term effectiveness and permanence refers to expected residual risk and the ability of a remedyto maintain reliable protection of human health and the environment over time, once clean-up levelshave been met. This criterion includes the consideration of residual risk that will remain followingremediation and the adequacy and reliability of controls. Each alternative, except the No ActionAlternative 1, provides some degree of long-term protection. Evaluation of the long-termeffectiveness and permanence of a remedial alternative addresses the results of a remedial alternativein terms of the risk remaining at the site after RAOs are achieved. Long-term effectiveness isevaluated based on the following three factors:

• Magnitude of the remaining risk. This consideration addresses the residual risk remainingfrom untreated waste or treatment residuals at the end of the remedial activities;

• Adequacy of controls. This consideration addresses the adequacy and suitability of thecontrols, if necessary, that are used to manage the treatment residuals or untreated wastesthat remain at the site; and

• Reliability of the controls. This consideration addresses the long-term reliability ofmanagement controls, if used, for providing continued protection from the treatmentresiduals or untreated wastes.

Both Alternatives 2 and 3 achieve long-term effectiveness and permanence; however, Alternative3, Excavation with Off-site Disposal is rated slightly higher than Alternative 2, the On-site Disposalalternative since the soil would be permanently disposed at a facility with permanent controls inplace which would reduce or eliminate the potential for contact by the general public with the soilsfrom the Coleman-Evans OU2 Site. Institutional controls will be necessary for all alternatives toensure compatible land use is maintained. Similarly, all of the alternatives would necessitateFive-Year Reviews of remedy protectiveness since unrestricted use/unlimited exposure criteriawould not be met. Adequate and reliable controls can be readily established for all of thealternatives.

2.10.4 Reduction of Mobility, Toxicity, or Volume Through Treatment

Reduction of M/T/V through treatment refers to the anticipated performance of the treatmenttechnologies that may be included as part of a remedy. This criterion addresses the statutorypreference for selecting a remedial action that employs treatment technologies that are able topermanently and significantly reduce the M/T/V of the COCs as their principal element. The abilityof a remedial alternative to reduce the M/T/V of the COCs is evaluated based on the following fivefactors:

• The treatment processes, the remedies employed and the materials they treat; • The amount (mass or volume) of hazardous materials that will be destroyed or treated by the

remedial alternative, including how the principal threat(s) will be addressed; • The degree of expected reduction in M/T/V of COCs, measured as a percentage of reduction

or order of magnitude; • The degree to which the treatment is irreversible; and


• The type and quantity of treatment residuals that would remain following the treatmentactions.

The on-site and off-site disposal alternatives provide a reduction in mobility, but not in the toxicityand volume of contaminated soil. Neither of the alternatives fully meet the statutory preference fortreatment as a principal element of the cleanup, but Alternatives 2 and 3 partially meet this criterionby reducing the mobility of the contaminated soil (permanently reducing mobility throughexcavation and disposal is a principle element of both these alternatives). Since the remedy for OU1included large-scale treatment of soil and ground water, the statutory preference for treatment hasbeen met at the Site.

2.10.5 Short-Term Effectiveness

Short-term effectiveness addresses the period of time needed to implement the remedy and anyadverse impacts that may be posed to workers, the community and the environment during remedialaction until cleanup goals noted in Table 6 are achieved. The short-term effectiveness of a remedialalternative is evaluated with respect to its effect on human health and the environment during itsimplementation. Short-term effectiveness is evaluated based on the following four factors:

• Protection of the community during the remedial action. This consideration addresses anyrisk that results from the implementation of the remedial action (i.e., dust from anexcavation) that may affect human health;

• Protection of workers during the remedial action. This consideration addresses threats thatmay affect workers and the effectiveness and reliability of protective measures that may betaken;

• Environmental impacts. This consideration addresses the potential adverse environmentalimpact that may result from the implementation of the remedial alternative and evaluateshow effective available mitigation measures would be able to prevent or reduce the impact;and

• The amount of time required until the RAOs are achieved. This consideration includes anestimate of the time required to achieve protection for the entire site or for individualelements associated with specific site areas of threats.

Both Alternatives 2 and 3 involve excavation in residential areas, and many of the short-termimpacts are associated with these activities. Both alternatives would have short durations, and wouldhave low impacts for this reason. Alternative 3 would involve additional considerations associatedwith transporting material off-site for disposal. Equipment, materials and techniques designed tocontrol dust and run-off would be required for both alternatives.

2.10.6 Implementability

Implementability addresses the technical and administrative feasibility of a remedy from designthrough construction and operation. Factors such as availability of services and materials,administrative feasibility, and coordination with other governmental entities are also considered.


This criterion addresses the technical and administrative feasibility of implementing a remedialalternative and the availability of various services and/or materials/supplies required during theimplementation. The implementability of a given remedial alternative is evaluated based on thefollowing factors:

Technical Feasibility

• Construction and operation. This consideration relates to the technical difficulties andunknown aspects associated with a given technology;

• Reliability of a technology. This consideration focuses on the ability of a technology tomeet specified process efficiencies and performance goals, including whether technicalproblems may lead to schedule delays;

• Ease of undertaking additional remedial actions. This consideration includes a discussionof what, if any, future remedial actions may need to occur and how difficult it would beto implement them; and

• Monitoring considerations. This consideration addresses the ability to monitor theeffectiveness of the remedial actions and includes an evaluation of the risks of exposureif monitoring is determined to be insufficient to detect a system failure.

Administrative Feasibility

• Both the ability and time required to coordinate with other offices and regulatoryagencies (i.e., obtaining permits for off-site activities or rights-of-way for constructionactivities).

• Availability of services and materials/supplies; • Availability of adequate off-site treatment, storage capacity and disposal services; • Availability of necessary equipment, specialists and provisions to ensure any necessary

additional resources; • Timing of the availability of each technology; and • Availability of services and materials, and the potential for obtaining competitive bids,

especially for innovative technologies.

Both Alternatives 2 and 3 require excavation in residential areas and rank similarly in theimplementability of this portion of the remedy. Both alternatives involve well-establishedconstruction materials and methods, and would be straightforward to implement.

2.10.7 Cost

For each remedial alternative, a minus 30 to plus 50 percent cost estimate has been developed. Costestimates for each remedial alternative are based on conceptual engineering and design and areexpressed in 2006 dollars. The cost estimate for each remedial alternative consists of the followingfour general categories:

Capital Costs. These costs include the expenditures that are required for construction of the remedialalternative (direct costs) and non-construction/overhead costs (indirect costs). Capital costs areexclusive of the costs required to operate and maintain the remedial alternative throughout its use.Direct costs include the labor, equipment and supply costs, including contractor markups for


overhead and profit, associated with activities such as mobilization, monitoring, site work,installation of treatment systems, and disposal costs. Indirect costs include items required to supportthe construction activities, but are not directly associated with a specific item.

Total Construction Costs. These costs include the capital costs with the addition of the contractorfee (at 10% of capital costs), engineering and administrative costs (at 15% of capital costs), and acontingency allowance set at 25% of the capital costs with contractor fees and engineering andadministrative costs.

Present Worth O&M Costs. These costs include the post-construction cost items required to ensureor verify the continued effectiveness of the remedial alternative. O&M costs typically includelong-term power and material costs (i.e., operational cost of a water treatment facility), equipmentreplacement/repair costs, and long-term monitoring costs (i.e., labor and laboratory costs), includingcontractor markups for overhead and profit. Present worth analysis is based on a 7% discount rateover a period of 30 years.

Total Present Worth Costs. This is the sum of the total construction costs and present worth O&Mcosts and forms the basis for comparison of the various remedial alternatives.

Based on the comparative analysis provided in Table 4, Alternative 2 is the least expensive viablealternative since there would be no disposal fees and the transportation fees would be much less totransport the contaminated soil to the Coleman-Evans Site for disposal.

Table 4. Comparison of Remedial Alternative Costs for Coleman-Evans OU2

Alternative Capital CostTotal

ConstructionCost

PresentWorth

O&M Cost

TotalPresent

Worth Cost

1 - No Action $0 $0 $0 $0

2 - Excavation with On-site Disposal $836,785 $1,307,476 $0 $1,307,476

3 - Excavation with Off-site Disposal $1,949,510 $3,046,109 $0 $3,046,109

2.11 Principal Threat Wastes

The NCP establishes an expectation that EPA will address the principal threats posed by a sitethrough treatment wherever practicable (NCP § 300.430(a)(1)(iii)(A)). Identifying principal threatwaste combines concepts of both hazard and risk. In general, principal threat wastes are those sourcematerials considered to be highly toxic or highly mobile, which generally cannot be contained in areliable manner or would present a significant risk to human health or the environment shouldexposure occur. No source materials constituting principal threats will be addressed within the scopeof this action. The prior action for the Site (OU1) addressed all principal threats and met thestatutory preference for treatment.


2.12 Selected Remedy

2.12.1 Rationale for the Selected Remedy

The remedy selected for Coleman-Evans OU2 addresses residual dioxin contamination of soilaround the area remediated during the OU1 remedial action. This action represents the final remedyselected for the Site, and, as such, is compatible with the intended future use of the Site. This actionalso is compatible with and complimentary to the action for OU1.

Alternatives 2 and 3 both use a presumptive remedy approach of excavation and disposal, with theexception of Alternative 1 - No Action. Alternatives 2 and 3 met the threshold criteria of protectionof human health and the environment and compliance with ARAR's. Therefore, the selectedalternative must provide the best balance among the balancing criteria of short-term effectiveness;long-term effectiveness and permanence; reduction in M/T/V through treatment; implementability;and, cost. Alternatives 2 and 3 were similar in short-term effectiveness and long-term effectivenessand permanence, with Alternative 3 producing slightly higher short-term impacts due to additionaltruck traffic associated with waste transportation. Since Alternative 3 also entails a higher cost thanAlternative 2, Alternative 2- Excavation with On-site Disposal, is the Preferred Alternative for theColeman-Evans Wood Preserving Superfund Site OU2.

The modifying criteria of state and community acceptance have been incorporated into the selectedremedy. The State of Florida, FDEP, as represented by the FDEP, has been the support agencyduring the RI/FS process for the Site. In accordance with 40 CFR § 300.430, as the support agency,FDEP has provided input during the process. The community has participated in review of theProposed Plan, and, based on the comments received, supports the preferred alternative.

2.12.2 Description of the Selected Remedy - Excavation with On-site Disposal

Alternative 2, Excavation with On-site Disposal, is selected because it will achieve substantial riskreduction through the removal and isolation of the dioxin contaminated soils for OU2. Incidentalingestion, dust inhalation, or direct contact with surface soil that contain concentrations of dioxinattributable to the Coleman-Evans Wood Preserving Superfund Site in excess of the cleanup goalsnoted in Table 6 will be prevented on the properties surrounding the former facility throughexcavation of the contaminated soil. These same exposure routes will be physically controlled onthe facility property by installation of a 2-foot soil cover and administratively controlled byestablishment of a restrictive covenant for land use. These measures also will control future releasesof contaminants to ensure long-term protection of human health and the environment.

The major components of the selected remedy include:

• Excavation and property restoration; • Site grading and cover installation; • Institutional controls; and • Five-Year Reviews


2.12.2.1 Excavation and Property Restoration

This remedy addresses site-attributable dioxin contamination above the cleanup goal identified atsample locations 5316, 5329, 5330, and 5369, areas adjacent to the Site, areas adjacent to drainagepathways which may have been impacted by contaminated storm water runoff from the Site, andallows for up to four additional "hot spot" excavation areas as shown on Figure 8. Pre-excavationsoil sampling will be performed to refine the vertical delineation of the proposed excavation areas.

Sample locations 5329 and 5330 (northwest boundary of the facility property) will be addressedthrough the grading plan for the former facility property. It is estimated that approximately one soilsample per 40 linear feet of proposed excavation will be collected at depths of 6 inches to 1 foot blsand will be analyzed for dioxin TEQ to complete vertical delineation. For excavation on residentialparcels, work will be coordinated with the homeowners, and no temporary or permanent relocationis anticipated. Areas with mature trees will be excavated in a manner to minimize damage andpreserve the trees while thoroughly removing contaminated soil. The excavated soil will betransported and placed on the former facility property. The excavations within residential propertieswill be backfilled with clean topsoil and re-sodded. The remaining excavation areas will bebackfilled with clean fill and re-seeded. The action will take approximately six months to completefrom pre-excavation sampling to final restoration.

2.12.2.2 Site Grading and Cover Installation

A grading and drainage plan will be developed for the Coleman-Evans Site to accommodateplacement of excavated soil from OU2, ensure positive site drainage, and result in a parcel suitablefor the planned reuse. The grading plan will include degrading along the northwest portion of theformer facility property to address elevated sample locations in that area. Since there is limiteduncertainty regarding the estimated volume of soil requiring disposal, small changes in this volumewill not materially affect the grading plan or future usability of the former facility property. Pre-grades will be established in accordance with the grading plan to allow for even distribution in theplacement of OU2 soil. The grading and drainage plan will ensure that runoff is predominantlydirected through the existing drainage culvert to the south and to the north and east of the property.

Excavated soil from OU2 will be placed directly onto the pre-graded surface of the former facilityproperty and spread evenly to accommodate installation of the soil cover. A 2-ft soil coverconsisting of 18 inches of clean common fill and 6 inches of clean topsoil will be installed followingexcavation and placement of the OU2 soil. The remedy for OU1 included installation of a 1-foot soilcover (not yet constructed), and this remedy augments that cover with an additional foot of cleancommon fill. The clean topsoil will be seeded with grass (selective use of sod may be necessary incertain areas), and irrigated if necessary to establish a durable turf. A storm water management planwill be prepared as part of the RD to manage runoff and siltation during construction throughestablishment of the turf. Periodic monitoring would be required to assess the ongoing effectivenessof the remedial action.


2.12.2.3 Institutional Controls

A restrictive covenant will be established to limit the use of the former facility property tocommercial/industrial (including use as a park) as an institutional control. The restrictive covenantwill ensure that the land use remains non-residential and that appropriate precautions are taken forany potential future intrusive subsurface work activities (e.g., installation of utility lines) in orderto prevent disturbance of subsurface waste soil and ensure short-and long-term effectiveness of theremedy. Institutional controls are a required component of this remedy since contaminated materialwill remain on-site and the remedial cleanup goals noted in Table 6 on the former facility propertyare based on commercial cleanup goals. The restrictive covenant will be completed followingconstruction and prior to transfer of the property. EPA will coordinate establishment of the covenantwith FDEP. The covenant will be drafted in accordance with FDEP's Institutional ControlsProcedures Guidance (November, 2004) using the model Declaration of Restrictive Covenant.Written notification will be made to local utility service providers, one-call services, and localagencies that issue construction permits with the coordinates of the covered area along with therelevant limitations and contact information.

2.12.2.4 Five-Year Reviews

A statutory review of the ongoing protectiveness of the on-site remedy will be performed by EPAno less often than every five years after initiation of the remedial action. This review is a publicprocess, and will be conducted to ensure that the on-site remedy selected for this Site remainsprotective of human health and the environment.

2.12.3 Summary of Estimated Remedy Costs

The estimated present worth (7% discount rate) cost for remedy construction is approximately$1,307,476 and is summarized in Table 5. Additional changes in the cost estimate are likely to occuras new information and data are collected during the engineering design of the remedial alternatives.Maj or changes, if they occur, may be documented in the form of a memorandum in theAdministrative Record file, an ESD, or a ROD Amendment. This is an order of magnitude costestimate that is expected to be within plus 50 percent to minus 30 percent of the actual project costs.

2.12.4 Expected Outcomes of the Selected Remedy

The results from the implementation of the Selected Remedy include the long-term isolation of allcontaminated soil that may pose a risk to human health in a commercial setting through directcontact or dust generation, and conditions that are compatible with the planned reuse of the Site. Theselected remedy is fully compatible with and complimentary to the remedy for OU1. The requiredinstitutional controls would be necessary for the treated soil placed on the facility property duringOU1, which have a similar range of dioxin concentrations as the OU2 soil, and therefore have noimpact on the long-term effectiveness of the remedy and site reuse. The Selected Remedy has thelowest short-term impacts to the community, and is consistent with similar decisions nationally.


During remedy construction, engineering and administrative controls will be used to protect thepublic from environmental exposure or safety hazards associated with the cleanup activities.

Following remedy construction, the planned reuse of the Site includes residential and commercial(Coleman-Evans Park at Whitehouse) uses. The parcels off the former facility property that areaddressed by OU2 will have unrestricted land use. The former facility property will have restricteduse administered through an institutional control (restrictive covenant). The restriction will preventdisturbance of subsurface waste soil and limit use of the property to commercial use, including useas a park.

Table 5. Estimated Remedy Construction Costs for Coleman-Evans OU2


The cleanup goals noted in Table 6 were derived from analysis described in more detail in theHHRA and from ARAR's. Contaminated soils on and off the former facility property exceed theacceptable potential residential and worker cancer risk associated with direct exposure to soils.Under the NCP, EPA's goal is to reduce the excess cancer risk to the range of 1 X 10-4 to 1 X 10-6

for the expected future land use at the Site. The cleanup goals being selected for OU2 are based ona future residential land use for the properties surrounding the former facility property, and acommercial land use for the former facility property. The ARAR-based cleanup goal for dioxin TEQis based on Florida Statute Section 376.30701 requiring cleanups to attain an ILCR of <1 X 10-6 anda HI of <1 for non-carcinogens. This cleanup goal results in a more stringent cleanup goal thanEPA's nationally recommended residential soil cleanup goal for dioxin TEQ of 1.0 µg/kg forSuperfund site remedial actions (EPA, 1998). Final cleanup goals for other attributable sitecontaminants for both soil and ground water were established in the 1997 AROD, and have been orare being addressed through the OU1 action.

The final remedial cleanup levels for attributable soil dioxin TEQ concentrations in soil are includedin Table 6.

Table 6. Final Soil Remedial Cleanup Goals for Coleman-Evans OU2 Contaminant of Concern Cleanup Goal (µg/kg) Source/Basis

Dioxin TEQ (attributable off facility property) 0.007 FAC 62-780*/1X10-6 Residential

Dioxin TEQ (attributable on facility property) 0.030 FAC 62-780*/1X10-6 Residential

* Florida Administrative Code, Chapter 62-780

2.13 Statutory Determinations

Based on information currently available, EPA as the lead agency believes the Preferred Alternativemeets the threshold criteria and provides the best balance of tradeoffs among the other alternativeswith respect to the balancing and modifying criteria. The EPA expects the Preferred Alternative tosatisfy the following statutory requirements of CERCLA 121(b): (1) be protective of human healthand the environment; (2) comply with ARARs (or justify a waiver); (3) be cost-effective; (4) utilizepermanent solutions and alternative treatment technologies or resource recovery technologies, andsatisfy the preference for treatment as a principal element, to the extent practicable.

2.13.1 Protection of Human Health and the Environment

The Selected Remedy for Coleman-Evans OU2 satisfies the statutory requirement for protection ofhuman health and the environment through isolation of contaminated soil from human receptors,institutional controls, and administrative controls. The Selected Remedy does not include treatmentas a major element, because there are no principal threats to be remedied in this operable unit. Theengineering principles and technology for the selected remedy are well established, and are expected


to be reliable over the long-term. Site conditions are conducive to construction of the remedy, andit is compatible with the expected future use of the Site.

2.13.2 Compliance with ARARs

Implementation of the selected remedy will comply with all federal and state chemical-specific,action-specific, and location-specific ARARs.

Chemical-specific requirements include those laws and regulations governing the release ofmaterials possessing certain chemical or physical characteristics, or containing specified chemicalcompounds. Chemical-specific requirements set health or risk based concentration limits or rangesin various environmental media for specific hazardous substances, contaminants, and pollutants.State requirements to attain risk-based cleanup goals for carcinogens of 1 X 10-6 and a hazard indexof 1 or less for non-carcinogens are ARARs. Additionally, federal and state air quality and stormwater contaminant limits address specific contaminants during remedy construction. Table 7presents the chemical-specific ARARs, to-be-considered (TBCs) guidance, and criteria for theSelected Remedy.

Action-specific requirements are technology-based, establishing performance, design, or othersimilar action-specific controls or regulations for the activities related to the management ofhazardous substances or pollutants. Action-specific requirements are triggered by the particularremedial action selected to accomplish the cleanup. Action specific requirements that will becomplied with by the selected remedy primarily include federal and state hazardous wasteregulations and discharge requirements. A summary of the requirements to be met through theimplementation of the selected remedy is provided in Table 8.

Location-specific requirements are design requirements or activity restrictions based on thegeographic or physical position of the site and its surrounding area. Location-specific requirementsset restrictions on the types of remedial activities that can be performed based on site-specificcharacteristics or location. Location-specific requirements for soil at the Coleman-Evans Site wereevaluated and potentially consist of location standards for work in a floodplain, protection ofendangered species, fish and wildlife coordination, archeological and historical preservation,protection of wetlands, and guidelines for dredged or fill material placement. No location-specificrequirements were identified that would address the conditions at the Site or the selected remedy.

2.13.3 Cost Effectiveness

EPA has determined that the Selected Remedy is cost-effective and that the overall protectivenessof the remedy is proportional to the overall cost of the remedy. The cost-effectiveness of the remedywas assessed by comparing the overall effectiveness of the remedy (i.e., long-term effectiveness andpermanence; reduction in M/T/V; short-term effectiveness) with the other alternatives considered.More than one remedial alternative may be considered cost-effective, but CERCLA does notmandate that the most cost-effective or least expensive remedy be selected.

Record of DecisionColeman-Evans Wood Preserving Company Superfund Site

Operable Unit 02 (Residual Dioxin in Soil)

Page 58

September 2006

Table 7. Chemical-Specific ARARs, Criteria, and Guidances for Coleman-Evans OU2

Applicable and Relevant Provisions ofthe following Standards, Requirements,

Criteria, or Limitations

Federal

Clean Air Act

National Primary and Secondary AmbientAir Quality Standards

National Emissions Standards forHazardous Air Pollutants (NESHAPs)

Approach for Addressing Dioxin in Soil atCERCLA and RCRA Sites

State

"Global" Risk-based Corrective Action

Surface Water Standards and MinimumDischarge Criteria

Citation

Certain provisions of:

40 CFR Part 50

40 CFR Part 61

OSWER Directive9200.4-26(4/13/98)

Florida Statute Section376. 30701/F.A.C 62-780

FAC Chapter 62-302

Description and Comment

Establishes primary (health-based) and secondary (welfare-based) air quality standards for contaminantsemitted from a major source of air emissions. These requirements address the excavation, handling, andtreatment (thermal destruction or biodegradation) of contaminated soil at the site.

Provides emissions standards for hazardous air pollutants for which no ambient air quality standards exist.These requirements address the excavation, handling, and treatment (thermal destruction orbiodegradation) of contaminated soil at the site.

Provides EPA's nationally recommended residential cleanup goal of 1.0 μg/kg for dioxin in soils forSuperfund site remedial actions.

Establishes risk-based cleanup levels (i.e., attainment of an incremental lifetime cancer risk of 1 X 10-6 and ahazard index of 1 for non-carcinogens).

Establishes standards and criteria for protection of state surface water bodies during remedial action of thesite soils or ground water if treated water is discharged from the site.



Page 59

September 2006

Table 8. Action-Specific ARARs, Criteria, and Guidances for Coleman-Evans OU2



Federal

Solid Waste Disposal Act

Criteria for Classification of Solid WasteDisposal Facilities and Practices

RCRA, as amended

Identification and Listing of HazardousWaste

Standards for Owners and Operators ofHazardous Waste Treatment, Storage,and Disposal Facilities

Land Disposal Regulations

Clean Water Act

EPA Administered Permit Programs: TheNational Pollutant Discharge EliminationSystem (NPDES)

Citation

Certain provisions of:

40 CFR Part 257

40 CFR Part 261

40 CFR Part 264

40 CFR 264.552(4)

40 CFR Part 268

40 CFR Part 122


Establishes criteria for use in determining which solid waste disposal facilities and practices pose areasonable probability of adverse effects on public health or the environment. If a remedial alternativeinvolves onsite disposal, certain limitations in this regulation must be met.

Defines those solid wastes that are subject to regulations as hazardous wastes under 40 CFR Parts 262through 265, 268, 270 through 271, and 124 and which are subject to the notification requirements ofSection 3010 of RCRA. Of specific importance are Subparts B (criteria for identifying the characteristics ofhazardous waste and for listing hazardous waste) and C (characteristics of hazardous waste). In addition,Part 261.24 under Subpart C sets forth the maximum concentration of contaminants for the ToxicityCharacteristic Leaching Procedure (TCLP).

Establishes minimum national standards defining the acceptable management of hazardous wastes forowners and operators of facilities that treat, store, or dispose of hazardous wastes. In particular, Subpart N(Landfills) applies to owners and operators of facilities that dispose of hazardous waste in landfills andspecifies the requirements for landfill cover design and maintenance. Subpart O (Incinerators) specifiesperformance standards, operating requirements, monitoring guidelines, inspection guidelines, and closureguidelines for any incinerator burning hazardous wastes. These requirements address the construction of acap or treatment facility at the site.

Provides treatment standards for soil to be placed in corrective action management units (CAMUs) as wellas provisions for adjusted standards accounting fortechnical impractibility, views of the affected community,and engineering design of the CAMU.

Establishes restrictions on land disposal of untreated hazardous waste and provides treatment standards forhazardous waste. These requirements address untreated and/or treated material thatis placed back onsite (i.e., capping or treated material placement). They do not apply to placement ofCAMU-eligible-waste into a CAMU based on the category of waste present.

These requirements address storm water from landfills, construction sites, and industrial activities thatmust be monitored and controlled. This is required of all industrial waste and construction sites ofgreater than five acres that discharge storm water. The Coleman-Evans site is 11 acres in size.



Page 60

September 2006



Criteria and Standards for the NPDES

National Primary and Secondary AmbientAir Quality Standards

Department of Transportation Rules forTransportation of Hazardous Materials

Occupational Safety and HealthAdministration

State

Regulations of Storm water Discharge

Hazardous Waste

Environmental Control - Prohibition ofhazardous waste landfills

Citation

40 CFR Part 125

40 CFR Part 50

49 CFR Parts 107, 171,173, 178, and 179

29 CFR 1910 Part 120

FAC Chapter 62-25

FAC Chapter 62-730

Florida Statute 403.7222


Requires development and implementation of a Best Management Practices program to prevent therelease of toxic constituents to surface water. Establishes specific procedures for the control of toxicand hazardous pollutant spills and runoff. The substantive permit requirements address the preventionof releases from spills or runoff during the implementation of remedial actions.

Establishes primary and secondary air quality standards for compounds emitted from a major source ofair emissions. The principal application of these standards is during remedial activities resulting inexposure through dust and vapors. These requirements apply since contaminated soil will be excavatedand handled on-site.

These regulations establish the procedures for packaging, labeling, and transporting hazardousmaterials. These requirements will address the transportation of contaminated soil from the off-siteresidential areas to the site and any laboratory analysis, treatment, and/or disposal of material at thesite.

This rule provides safety requirements for site workers during soil remedial activities conducted at thesite.

The discharge of untreated storm water may reasonably be expected to be a source of pollution ofwaters of the state and is subject to state regulation. The substantive requirements of this regulationaddress any on-site remedial actions where storm water requires management.

Adopts by reference certain Federal regulations and establishes additional minor requirementsconcerning the generation, excavation, handling, storage, treatment, transportation, and disposal ofhazardous waste in contaminated soil at the site.

Prohibits permitting of landfills for untreated hazardous waste.


2.13.4 Permanent and Alternative Treatment solutions

The selected remedy uses permanent solutions and alternative treatment solutions to the maximumextent practicable. The selected remedy will provide an acceptable degree of long-term effectivenessand permanence. The remedy will require institutional and administrative controls over thelong-term to remain effective, but these remedy components are neither unusual nor exceptional indegree or cost. The remedy can be reliably considered permanent.

2.13.5 Preference for Treatment as a Principal Element

In addition to the four statutory mandates previously discussed, the NCP includes a preference fortreatment for the selected remedies in addressing the principal threat at the Site. The selected remedydoes not include treatment as a major element, because the nature and concentration of thecontaminant addressed by OU2 is not amenable to treatment. The remedy for OU1 was based on thebest available treatment technology, and, while very effective in treating PCP contamination,resulted in residual dioxin concentrations similar to those identified in OU2.

2.13.6 Five-Year Review Requirement

CERCLA Section 121 and 40 CFR Part 300 require a review of remedial actions at least every fiveyears if the remedial action results in hazardous substances, pollutants, or contaminants remainingin place above levels that allow for unlimited use and unrestricted exposure. Since the selectedremedy is based on on-site disposal of contaminated soils, a statutory review of the remedial actionis required within five years of the beginning of remedial construction.

2.14 Documentation of Significant Changes

Pursuant to CERCLA 117(b) and NCP 300.430(f)(3)(ii), the ROD must document any significantchanges made to the Preferred Alternative discussed in the Proposed Plan. There have been nosignificant changes to the Preferred Alternative discussed in the Proposed Plan. However, threeminor changes have occurred as described below:

• Refinement of the cost estimate for the Preferred Alternative/Selected Remedy. This costchange was an approximately 30% increase in cost to account for engineering oversight,contractor fee, and a contingency amount.

• An additional "Hot Spot" for soil cleanup may be defined in conjunction with FDEP duringremedial design.

• The selected remedy will provide for O&M of the soil cover to consist of periodic mowingof the vegetative cover (up to four times during the growing season), re-seeding of the grasson an as needed basis, and an annual inspection of the cover with a letter report. The O&Mwill continue at least through the establishment of a compatible reuse for the former facilityproperty, and the necessity of continued O&M will be evaluated during the Five-YearReviews. The estimated cost for O&M over a standard 30-year period with a 7% discountrate is $79,691.


2.15 References

Black & Veatch, 2006. Black & Veatch Special Projects Corp. Final Remedial Investigation Report for Coleman-Evans Wood Preserving Superfund Site OU2. August 2006.

CDM, 1986. Camp Dresser & McKee. Coleman-Evans Wood Preserving Site Remedial Investigation Final Report (OU#1). April 18, 1986.

EPA, 1988. U.S. Environmental Protection Agency. Guidance for Conducting RemedialInvestigations and Feasibility Studies Under CERCLA, Interim Final. EPA/540/G-89/004.October, 1988.

EPA, 1989. U.S. Environmental Protection Agency. Determining Soil Response Action Levels Based on Potential Contaminant Migration to Groundwater: A Compendium of Examples.

Office of Emergency and Remedial Response. EPA/540/2-89/057, 1989.

EPA, 1998. U.S. Environmental Protection Agency. Approach for Addressing Dioxin in Soil at CERCLA and RCRA Sites. OSWER Directive 9200.4-26, April 13, 1998.

EPA, 2002. U.S. Environmental Protection Agency. Reusing Superfund Sites: Commercial Use Where Waste is Left on Site. EPA-540-K-01-008, 2002.

EPA, 2004. U.S. Environmental Protection Agency. Region 9 Preliminary Remediation Goals (PRGs), Annual Update, San Francisco, California. October 2004.

FDEP, 2005a. Florida Department of Environmental Protection, Florida Administrative Code Chapter 62-777, Contaminant Cleanup Target Levels, Amended April 17, 2005.

FDEP, 2005b. Florida Department of Environmental Protection, Florida Administrative Code Chapter 62-780, Contaminated Site Cleanup Criteria, Amended April 17, 2005.

PRC, 1997. PRC Environmental Management, Inc., Letter Report, Coleman-Evans Wood Preserving Site, Whitehouse, Duval County, Florida, TDD No. 04-9605-0045, April 25,

1997.

USACE, 2004. U.S. Army Corps of Engineers District Jacksonville, Draft Phase (Soil) Interim Remedial Action Report Coleman-Evans Wood Preserving Superfund Site, Whitehouse,

Florida, December 2004.

USCB, 2005. U.S. Census Bureau, Duval County, Florida, web address www. census. gov, 2005.


PART 3: RESPONSIVENESS SUMMARY

3.1 Overview and Summary

This Responsiveness Summary documents public comments and EPA responses to comments onthe Proposed Plan for remediation of OU 2 (Residual Dioxin in Soil) at the Coleman-EvansWood Preserving Company Site in the community of Whitehouse, Duval County, Florida.

3.2 Written Public Comments

EPA received no written public comments either through post or electronic mail.

3.3 Public Meeting Comments

EPA received the following public comment from the community at the public meeting held onSeptember 14, 2006 at the Whitehouse Elementary School:

Stormwater runoff from the former facility property comes down Celery Street into theresidential yards on the south side of General Avenue. Will the remedy address this problem?

EPA's response to this comment is:

The remedy will address stormwater flow from the former facility property. The majority of theoverland flow will be directed to the culvert on the former facility property and drain to thesouth through the existing drainage ditch. The remainder will flow onto adjacent propertiesconsistent with a natural distribution of stormwater. These changes should improve stormwatermanagement in the area.

As part of the remedy, EPA will be performing detailed land surveying to support development ofthe stormwater management plan. Based on this, discussions with the City of Jacksonville maytake place regarding stormwater flow from adjacent properties. EPA cannot undertakeimprovements to these other areas as part of the Superfund remedy; this is considered anenhancement that is not a necessary part of the remedy. EPA will keep the community informedthroughout the remedial design process of the determinations regarding stormwatermanagement.

3.4 Other Public Comment

EPA received no additional comments from the community during the public comment period.


APPENDIX A

Public Meeting Transcript (on CD)

COLEMAN-EVANS WOOD PRESERVING COMPANY

SUPERFUND SITE

OPERABLE UNIT 2

PUBLIC MEETING

DATE: September 14, 2006

TIME: 6:00 to 8:00 p.m.

PLACE: Whitehouse Elementary School -Cafeteria

Whitehouse, Florida

CERTIFIED COURT REPORTERS, INC. (904) 356-4467

2

1 MR. KEEFER: Okay. Good evening everybody,

2 Ms. Hale, and the crowd of regulators, and people

3 that work with the regulators.

4 MS. HALE: I'm stomping with the big folks

5 tonight.

6 MR. KEEFER: We're going to go ahead and get

7 started and if someone comes in late, then we'll

8 go back over whatever parts we need to for their

9 benefit. What we're here tonight to discuss is

10 the Coleman-Evans Wood Preserving Company,

11 Superfund site, Operable Unit 2 which is the last

12 part of the cleanup of the Coleman-Evans site.

13 And we've come up with a proposed cleanup plan

14 and tonight we're going to present it to the

15 community and see what everybody thinks about it

16 and if necessary, we'll modify it.

17 And hopefully in a few weeks, we'll sign the

18 Record of Decision. The next fiscal year for us

19 start in October. We'll move forward with the

20 design — Ms. Fontaine will take care of that —

21 get the cleanup done in the spring and the summer

22 and be done with this finally.

23 MS. HALE: Next year?

24 MR. KEEFER: Yes, ma'am. I'm David Keefer.

25 I'm the project manager for EPA. Here tonight


3

1 among our dignitaries Mr. John Sykes, the project

2 manager for the Florida Department of

3 Environmental Protection; L'Tonya Spencer,

4 community involvement coordinator for EPA; Ms.

5 Judie Kean, she's the supervisor for the Florida

6 Department of Environmental Protection. We have

7 a couple gentlemen you might have seen before,

8 Clark Langston and Mike Schultz from the Army

9 Corps of engineers here in Jacksonville; and

10 Darlene Fontaine, she's the engineer. Most of

11 the work you're about to see are really her work,

12 I just get to take credit for it. We have a

13 court reporter with us tonight so I'd ask that if

14 anybody has a comment to make, they would state

15 their name and their affiliation so the court

16 reporter can know who it is for the record.

17 Let's get started.

18 This is our agenda tonight. We just went

19 through the introduction and opening remarks and

20 the next part of the meeting we'll have a

21 presentation of about 25 to 30 slides and I'll

22 talk about what we're doing, then we'll go

23 through a question and answer period. And if

24 anyone has remarks they want to read into the

25 record, the court reporter is here to take care


4

1 of that. And then we'll have discussions with

2 the media if they show up and call it a night.

3 Coleman-Evans Wood Preserving, Operable Unit

4 2, everyone's familiar with Coleman-Evans, it's a

5 former wood preserver. They used

6 pentachlorophenol and fuel oil as their wood

7 preservative. EPA and Florida DEP performed a

8 large scale cleanup action there that resulted

9 in, among other things, the treatment of about

10 210,000 net tons of contaminated soil, a little

11 over 70 million gallons of ground water and

12 surface water, and we met all the soil cleanup

13 goals; however, the dioxin cleanup standard for

14 that action was set at EPA's interim standard.

15 And at the time we wrote the Record of Decision,

16 different standards were being contemplated by

17 the Florida DEP. And since that time, Florida

18 has enacted their standard so we're here to

19 finish up and take care of the remaining dioxin.

20 There are unexcavated areas of surface soil

21 that do have residual dioxin contamination

22 attributable to past site operations. This

23 proposed remedy will result in the final cleanup

24 action for the site and will be compatible with

25 the planned future use of the property.


5

1 And everybody knows where we are. The

2 Coleman-Evans site is a very interesting part of

3 Jacksonville. It's a mixed commercial and

4 residential land use area. Ms. Hale has been

5 here for a number of years and it's gone from

6 kind of a quiet, almost rural community to a very

7 busy suburban area, new neighborhoods going in

8 all the time. And I think it's reasonable to say

9 that the land use in this area will continue to

10 evolve and the density of land use will increase

11 with time. The property includes — or the site

12 includes the 11-acre former facility property as

13 well as the impacted surrounding properties.

14 A little bit of operational history, the

15 Coleman-Evans facility manufactured treated wood

16 products for about 35 years. The

17 pentachlorophenol or PCP was dissolved in the No.

18 2 diesel fuel, and the wood was preserved using a

19 single pressurized chamber. Releases from

20 wastewater ponds and impoundments on the site are

21 the primary sources of environmental

22 contamination. Surface water and storm water did

23 transport contaminants off the property, and the

24 primary transport was also addressed as part of

25 the components.


6

1 The Coleman-Evans site was recognized as an

2 environmental problem by the City of Jacksonville

3 in 1980. In 1981, EPA and Florida DEP became

4 involved with the site. I believe we were DER at

5 that time. And between 1981 and 198 8, EPA

6 received a number of enforcement actions against

7 the Coleman-Evans Company for violation of the

8 various environmental laws. In 1983, the site

9 was placed on superfund National Priority List.

10 And in April of 1990, a final settlement was

11 reached between the United States and

12 Coleman-Evans.

13 Early in the cleanup process of the site,

14 EPA performed a couple of emergency removal

15 actions. The first one was to excavate some

16 sludge disposal pits and disposed of about a

17 thousand pounds of pentachlorophenol that were

18 present on the site. EPA also set up a temporary

19 fencing to try to limit access to contaminated

20 ditches around the site to protect the residence.

21 In 1993, another emergency removal action was

22 performed to demolish the use of contaminated

23 structures on the property and to excavate the

24 contaminated soil or sediment in the residential

25 area back on site. Permanent fencing was


7

1 installed around the site at that time — we may

2 have another residence so I will stop.

3 (Brief interruption.)

4 MR. KEEFER: Okay. So we were at the point

5 of the removal process for the Coleman-Evans

6 site. I am kind of skipping over a number of

7 years of studies and false starts at this point.

8 I recognize that but we need to get to where we

9 are today. In 1997, there was an amended Record

10 of Decision that the EPA put forth --

11 (Brief interruption.)

12 MR. KEEFER: All right. Back to the show.

13 In the 1997 amended Record of Decision, EPA

14 selected a technology known as thermal desorption

15 to treat the contaminated soil at the

16 Coleman-Evans site. The cleanup standards, like

17 in that Record or Decision, were all soil with

18 pentachlorophenol above two milligrams per

19 kilogram and all dioxin in the soil — dioxin

20 TEQ — I'll explain that a little bit more

21 later — and above one microgram per kilogram.

22 We were thinking of placing treated soil on the

23 facility property with a 1-foot soil cover and

24 all the ground water treated by filtration and

25 carbon polishing to achieve a standard for all


8

1 the ground water contaminated with

2 pentachlorophenol greater than one microgram per

3 liter.

4 The status of that cleanup action, the soil

5 treatment has been completed. Approximately ten

6 hundred thousand net tons of soil were treated.

7 Soil cover has not been installed, pending the

8 remedy selection that we're talking about

9 tonight. The ground water treatment was

10 completed. And the monitored natural attenuation

11 of one well with low concentration of

12 pentachlorophenol is ongoing. The remaining

13 activities to complete the Operable Unit 1

14 action, a removal of the debris piled on the

15 site, the installation of the soil cover, and the

16 continued ground water monitoring.

17 Now, the residual dioxin issue, as we

18 previously stated, the 1997 Record of Decision

19 selected a dioxin cleanup level of one microgram

20 per kilogram, that is and was EPA standard —

21 interim standard for dioxin. At that time,

22 Florida Department of Environmental Protection

23 was contemplating a lower cleanup standard and

24 for that reason, the cleanup standard for dioxin

25 was interim on that property.


9

1 In consultation with the FDEP, the EPA

2 established Operable Unit 2 to address the

3 residual dioxin in the soil. As part of that, we

4 performed a public remedial investigation to

5 assess the residual dioxin in the soil. EPA and

6 the Florida Department of Environmental

7 Protection jointly developed a remedial

8 investigation work plan which called for

9 additional soil sampling.

10 Now, that's the point where you may have met

11 Darlene or some of her folks collecting soil

12 samples here and we combined that information.

13 And about 82 historical samples we collected over

14 the years in order to best use our resources and

15 also 12 samples from the site itself to

16 characterize the attributes of the site-related

17 dioxin. Based on that study, the study results

18 were the extent of site-related dioxin in soil

19 were defined. And we also prepared a baseline

20 human health risk assessment.

21 This is the investigation conceptual site

22 model that we used. The contaminated soil at the

23 Coleman-Evans site could spread off the facility

24 property — airborne dust, surface water during

25 storm events, or through trackout and leaks and


10

1 spills. All these mechanism are released with

2 the impact of surface soil in surrounding

3 properties. And surface soil in the neighborhood

4 could expose both commercial workers, people who

5 install the utility lines or cut the grass, as

6 well as residence, adults, and children. We had

7 a concern in our conceptual model that people

8 might be exposed to contamination, so that was

9 the reason that we did the investigation and are

10 here tonight to take this action.

11 And I know that no one can read this

12 slide — and I pulled the projector all the way

13 back — but basically, this slide illustrate the

14 amount of information we collected around the

15 Coleman-Evans site, which is the yellow line

16 area, the order of the prior cleanup, and all

17 those little dots are soil samples that we

18 collected to assess the distribution of dioxin

19 around the site.

20 This map tries to illustrate the

21 distribution of the concentration of dioxin

22 around the site using different colors. The

23 green color that you see around the outside, that

24 means the dioxin concentration are not of concern

25 under the most stringent cleanup standards. Then


11

1 you have yellow, which is seven parts per

2 trillion which is micrograms per kilogram which

3 is 100 parts per trillion. And the next color is

4 blue, that's 100 to 1,000. And then red is

5 greater than a thousand. The only place where we

6 had any red, and I know it's kind of hard to see,

7 is up on the northwest corner of the

8 Coleman-Evans property. And we'll get more into

9 those samples. It's kind of near the railroad

10 tracks.

11 MS. HALE: Would that be across the street?

12 MR. KEEFER: If you're going up Celery, just

13 before you get to the tracks, if you look to the

14 right to the side of the fence, kind of where

15 those high weeds are, there's a couple of spots

16 in there.

17 MS. HALE: I understood you to say

18 northwest, that would be east.

19 MR. KEEFER: Yes, ma'am, east.

20 MS. HALE: Okay. East.

21 MR. KEEFER: It's the northwest part of the

22 facility property but it's east itself.

23 The next thing we need to talk about —

24 dioxin contamination is a problem for the

25 environmental regulators because there are other


12

1 sources of dioxin in the environment. So the

2 first question I wanted to ask is why is it

3 necessary to do this assessment, to attribute

4 contamination to a source? And the reason is

5 that the superfund, who I work for, can only

6 address contaminations related to the superfund

7 site. The money that congress makes available to

8 the EPA are restricted in that way. And as I

9 said, there are numerous sources of dioxin in the

10 environment. One of those big source is wood

11 treating with pentachlorophenol. That's why we

12 had dioxin at and around the Coleman-Evans site.

13 Other sources that are of concern are domestic

14 trash burning, diesel vehicle emissions, forest

15 fire, land clearing, medical and municipal

16 incinerator, and certain industries or

17 manufacturers such as pulp and paper mills, all

18 of these are sources of dioxin in the

19 environment.

20 So how does EPA determine or distinguish

21 between the different sources of dioxin? Well,

22 we use an approach that include interviews and

23 looking at historical records to try to figure

24 out if there are other sources of dioxin in the

25 area. We can also perform statistical


13

1 evaluations, and one of the tools that we use is

2 a Congener Profile Analysis or fingerprinting.

3 It's a new tool and the method is still in

4 development.

5 Finally, we looked at pathways. What are

6 the mechanisms which dioxin contamination can be

7 distributed from the site. And we looked at the

8 distribution of dioxin around the site. Based on

9 all of those things, the weight of evidence

10 approach delineate the site-related dioxin around

11 the Coleman-Evans site. That's based on —

12 history, statistics, and fingerprinting indicates

13 there was little remaining site-related

14 contamination; however, the analysis of pathways

15 and contaminant distribution indicates that there

16 appear to be a wider contaminant impact. So EPA

17 in consultation with the Florida DEP has selected

18 a conservative cleanup boundary for the site to

19 make sure we address everything associated with

20 it. And that's what the little green patch areas

21 are.

22 If you look — basically, we're concerned

23 that some of the dioxin we found in the backyard

24 close to the — across the street from you, on

25 the other side of General, you know, maybe during


14

1 storm events, water might have washed off the

2 site and possibly settled in the yards. The two

3 samples Darlene and I were having our sidebar

4 about, compared the area next to the tracks

5 wasn't part of the cleanup during the big soil

6 treatment project, and so there is some dioxin

7 there that we need to take care of. Along Celery

8 Avenue, the same mechanisms concerns us, that

9 during storm events, water might have washed out

10 and carried contamination. Down around the

11 intersection on the corner by Mrs. Ash's

12 property, all those areas, you know, we need to

13 go dig them out, just to make sure we're taking

14 care of everything associated with the site.

15 And also a couple of spots — if you look

16 down the old ditch, there's two spots down there

17 that we think are also potentially impacted by

18 the site. In addition to that, just to keep me

19 honest, we've defined four top spots that as we

20 move forward in the cleanup and the design and

21 actually doing the work, Mr. Sykes and myself

22 will go around and look at the areas, low areas,

23 low line spots, places that might have been

24 impacted, look at daily collected, lay of the

25 land, and use our best judgment to make sure


15

1 we've got everything distributed on the site.

2 So when we get that done, what's going to

3 happen? Well, right now the City of Jacksonville

4 has a master plan to convert the property into

5 use as a park and community center. I know

6 several years ago we had our community day, one

7 of the councilman was there and he's still

8 committed to building this. Obviously, we have

9 to finish our work first, so we're going to

10 perform our work in a manner that allows the City

11 to do this type of use. I can't speak for the

12 City. I don't know what they're going to do or

13 when they might do something. The other land

14 uses in the area, the residence, the school we're

15 standing in now, businesses that are here or

16 moving into the area, all that, you know, will be

17 able to continue without restriction.

18 The human health risk assessment, risk

19 assessment consist of really two parts, one is a

20 hazard analysis — and the hazards in chemicals,

21 we use that term to refer to the noncarcinogenic

22 or noncancer causing impacts of the chemicals —

23 the other is referred to the incremental lifetime

24 cancer risk. Dioxin which is the contaminant

25 that we're looking at here is considered a


16

1 probable human carcinogen. So as you would

2 expect, most of the risk that we've defined for

3 dioxin in the site is associated with the

4 incremental lifetime cancer risk and we evaluate

5 both.

6 Looking at the hazard index for dioxin, all

7 the areas around the Coleman-Evans site, with the

8 exception of those two samples that were in red

9 up there that we just talked about, near the

10 railroad tracks, were below the index value of

11 one. And basically, one — anything below one is

12 good, above one means EPA should consider taking

13 an action. On the incremental lifetime cancer

14 risk, we found a bit more risk. The State of

15 Florida has passed a statute that require all

16 cleanups in the State, including superfund

17 cleanups, to attain a risk when the cleanup is

18 completed of less than one in a million, okay.

19 So exposure to the formerly contaminated site

20 will create a risk of less than one in a million

21 chance that you will have an incremental lifetime

22 cancer risk.

23 And one in a million is one times ten to the

24 minus six, and you'll see that a lot. EPA has —

25 we use a risk range. We set the bottom of the


17

1 risk range at one in a million and the top at one

2 in 10,000, okay, which is one times ten to the

3 minus four. The one times ten to the minus six

4 or one in a million chance of cancer risk was

5 exceeded by the soil around the site, okay. The

6 one in ten thousand was only exceeded in the two

7 areas by the railroad tracks, those two sample

8 locations. We're going to address the risk, the

9 one times ten to the minus six because that's for

10 the department in Florida. It's also good to

11 know that the exceedance of the one times ten to

12 the minus four triggers action for EPA so these

13 findings are very conducive to do the cleanup.

14 So what are our objectives for the cleanup?

15 Well, the number one objective is to prevent the

16 accidental ingestion, inhaling the dust, or

17 direct contact should these surface soils that

18 contain concentration of dioxin that are

19 attributable to the Coleman-Evans site that are

20 in excess of our remedial goals. The other goal

21 or the other objective of the cleanup will be to

22 control any future releases of these contaminants

23 to ensure long-term protection of cleanup in the

24 environment and so forth, so these are our

25 cleanup goals.


18

1 The residential properties, which all of the

2 properties off the former Coleman-Evans site

3 itself are considered residential, to be cleaned

4 up to a standard of seven parts per trillion,

5 0.007 micrograms per kilogram. The Coleman-Evans

6 cleanup goal would be 30 parts per trillion

7 because that is the appropriate working cleanup

8 standard. So how do we go about cleaning it up?

9 We had to evaluate some remedial alternatives.

10 For this site, we used what we refer to as a

11 presumptive remedy approach. The reason for that

12 is that there are a limited number of options for

13 treating low levels of dioxin in the soil. In

14 fact, the only technology that reliably works is

15 incineration.

16 So for that reason alone, excavation and

17 disposal of the soil becomes presumptive remedy.

18 But in addition to dioxin concentration that are

19 in the soil surrounding the site they are similar

20 to the treating soil concentration in Operable

21 Unit 1. And that treatment system we operated

22 there did a great job. It treated the

23 pentachlorophenol, all that fuel, and it also

24 destroyed dioxin. But thermal desorption will

25 not destroy dioxin molecules down to these


19

1 cleanup standards that were selected, so the

2 treated soil does have residual dioxin in it,

3 very similar to the concentration in surrounding

4 properties.

5 And finally, the OU1 remedy which calls for

6 soil cover, that hasn't been installed yet

7 because we contemplated at the time that we may

8 bring some additional soil back on to the

9 property. So for that reason, the remedy we're

10 proposing is going to be compatible with the

11 remedy for Operable Unit 1 which is responsible

12 use of our resources. So the two alternatives we

13 evaluated in addition to the no action

14 alternative were excavation of on-site disposal

15 and excavation of off-site disposal.

16 And this is how EPA evaluates the cleanup

17 alternatives: We have three broad criteria,

18 threshold criteria and balancing criteria and

19 modifying criteria. The threshold criteria are

20 those criteria in which a remedy must be obtained

21 in order for EPA to select it. And for that

22 reason, the no action alternative falls out at

23 this point, okay, because no action does not

24 provide for the overall protection of human

25 health in the environment and does not comply


20

1 with ARARs. ARARs is a — stands for Applicable

2 or Relevant and Appropriate Requirements. What

3 that means is that other laws that are applicable

4 or relevant and appropriate, EPA must comply with

5 those as well as standards for cleanup. The no

6 action alternative does not meet either of the

7 threshold criteria, so it falls out at this

8 point. The two excavation approaches both meet

9 the threshold criteria because they've removed

10 the contaminated soil from the property, a

11 permanent removal.

12 Now, the balancing criteria, how do we pick

13 among our competing approaches? Long-term

14 effectiveness, short-term effectiveness, a

15 reduction of the toxicity, mobility, volume

16 through treatment, the implementability, and the

17 cost. There is five criteria or subcriteria that

18 we reviewed to pick amongst the alternatives.

19 Finally, the modifying criteria, any remedy

20 that EPA select for superfund site must be

21 acceptable to the State and the community, okay,

22 so we may modify a remedy in order to attain a

23 degree of State acceptance or/and community

24 acceptance, if the EPA finds necessary. I should

25 point out that EPA is the agency and we have our


21

1 obligations to the federal government, so we're

2 obligated to do the cleanup and we have to take

3 an action.

4 So here's our evaluation. We've created an

5 arbitrary scoring system for how the different

6 alternatives do relative to those balancing

7 criteria, five is the best, zero is the worst.

8 As you can see, the no action alternative doesn't

9 score. And then the excavation with on-site

10 disposal versus excavation with off-site

11 disposal, they're very similar. The off-site

12 disposal has a slightly higher score for the

13 long-term effectiveness and permanence because

14 that particular soil would be removed, you know,

15 from Jacksonville and taken to some place else as

16 opposed to on the facility property. But it has

17 a lower implementability because digging up that

18 soil and hauling it to wherever it would have to

19 go, you know, creates hazards and traffic and

20 that sort of thing, so the total score of those

21 two alternatives are very similar. And so we

22 would be directed and select based on the cost.

23 As you can see, the on-site disposal option is

24 significantly more cost effective than off-site

25 disposal.


22

1 So EPAs preferred remedy is alternative to

2 excavation with on-site disposal. There's four

3 major components of this remedy: The first of

4 those is excavation and property restoration.

5 EPA removed the contaminated soil from all the

6 areas around the site, the green shaded areas .

7 For the residential properties, we'll replace

8 that soil with topsoil and sod, okay. We hope it

9 will be quick and clean and efficient. The

10 nonresidential properties will be replaced with

11 fill and seed. We'll also take active measures

12 any place where we have trees, particularly along

13 Celery Road, how nice and mature our trees are,

14 we're going to use a method that have a minimal

15 impact on the trees. We're not going to cut down

16 the trees.

17 Then after the soil is removed and

18 everybody's property is restored and the soil be

19 brought on to the Coleman-Evans facility

20 property, the site will be pre-graded so that

21 when the soil is placed and the soil cover is

22 placed, the drainage from the property will not

23 adversely impact the neighborhoods. And that's

24 part of the engineering design that Ms. Fontaine

25 is going to be working on.


23

1 MS. HALE: It comes right down in my yard,

2 the water —

3 MR. KEEFER: Well, we're going to drain it

4 so that it's close to the — that natural grade

5 as we can.

6 And the soil cover for the Operable Unit 1

7 remedy included provision for 1 foot of soil

8 cover. We're going to increase that to 2 feet as

9 a protective measure. The site will also be

10 graded to be compatible if reused as a park.

11 Because of the soil on the site that exceeds the

12 cleanup standards, the institutional controls for

13 the former facility property will be implemented.

14 Those institutional controls will be something

15 called a restrictive cover, which means that

16 forever more, users of that property will be

17 restricted for commercial purposes so people

18 won't build homes and plant gardens there. And

19 also restriction for any self-service work, like

20 install utility line, so that people understand

21 that their soil does have dioxin in it.

22 EPA will then perform five-year reviews.

23 Any remedy they selected that results in some

24 contaminants remaining that are above

25 unrestricted use criteria, require five-year


24

1 review as a matter of law. This site will meet

2 that. So we will do this five-year review which

3 means every five years, EPA will come down and

4 check the condition of the site — or more often.

5 And it's a public process, okay. The five-year

6 review is an opportunity for the community to

7 weigh in on the remedy. If there's a problem

8 with the way it's working, if something is not

9 working right, the EPA will fix that. That's our

10 commitment to the future.

11 So we have here a slide that talks about our

12 rationale for selecting Alternative 2. I believe

13 I've gone over most of this but just to

14 reiterate, Operable Unit 2 does meet our

15 threshold criteria for protection of human health

16 and the environment and will comply with the

17 Applicable or Relevant Appropriate Requirements.

18 It will be effective in minimizing the impact

19 during construction, although, of course, very

20 similar to Alternative 3, will provide for

21 long-term protectiveness and permanence

22 consistent with the planned future use.

23 It will address the mobility and exposure to

24 contaminated soil but it does not involve

25 treatment. And as we talked about, treatment


25

1 alternatives for low levels of dioxin in the soil

2 are really minimal. And it's highly

3 implemenatable using a proven approach, which

4 proven approach is if there is contaminated

5 material, dig it up, and get rid of it. And it

6 is provided at the lowest cost.

7 We believe that EPA will support the remedy

8 and we're here tonight to see if the community

9 supports the remedy as well. It meets our

10 remedial action objectives and we'll represent

11 the final remedy for the Coleman-Evans Wood

12 Preserving, Superfund Site, which, Ms. Hale, I

13 know you've been waiting for it for some 25-odd

14 years. And —

15 MS. HALE: Say that again.

16 MR. KEEFER: This will be the final remedy

17 for this site so hopefully a year from now, EPA

18 and FDEP, while still protecting you in other

19 areas, will be done here. And that's it.

20 Do you have any questions or comments — or

21 anyone else?

22 MS. HALE: It's mind-boggling, isn't it?

23 MR. KEEFER: It's been a large remedy. The

24 Coleman-Evans site is one of the few, what we

25 refer to as megasites. We've learned a lot and I


26

1 think we've done a lot of good here. And if

2 nothing else, we introduced Clark Langston to the

3 community which will have an ongoing impact.

4 MS. HALE: Well, that's a big plus.

5 MR. KEEFER: If you would like to make any

6 comments for us to consider in this cleanup —

7 MS. HALE: A while ago when I said the water

8 comes from the site right down the street, right

9 in my yard —

10 MR. KEEFER: Down Celery?

11 MS. HALE: Yes. And I live directly across

12 from it and every time it rains — I mean, you

13 know, it rains very little but there would be

14 water and it's a very gradual decline.

15 MR. KEEFER: Well, one of the first things

16 during remedial design is, Darlene's company will

17 do a detailed survey of the land, not just on the

18 property but around that. And the grading plan

19 as we referred to it, the biggest goal will be to

20 control and improve the drainage in the area.

21 And I think you know we have a box that channels

22 the water out through the ditch, down towards —

23 MS. HALE: I don't think water goes in there

24 at all.

25 MR. KEEFER: We'll check on that.


27

1 MS. HALE: The City owns that --

2 (inaudible) — but we used to get a lot of rain

3 and there would be so much water.

4 MR. KEEFER: We'll have a much better

5 understanding of the drainage. There will be on

6 the private property, aside from the remedy, EPA

7 will not be able to put in a new ditch system.

8 That's beyond what we're allowed to do with the

9 superfund money. But based on the survey, you

10 know, we'll control the water on the site and

11 work to manage that but there are other problems

12 with the drainage in the area and we'll help make

13 that information known to the City of

14 Jacksonville.

15 And, you know, that's — we can help out and

16 do what we can. We'll do as much as we can to

17 move the water off your property. And I know the

18 little ditch swales in front of your property are

19 very shallow and that's where we're going to be

20 excavating and maybe you will see improvement

21 there and try to help you out with that. We're

22 walking on a thin line there but we'll do the

23 best we can on the drainage. If there's still a

24 problem, we'll talk to the City about it.

25 MS. HALE: I talked to Mr. Keene who works


28

1 for the City. He came and he built a gray ditch

2 on the side and it didn't do a thing for me,

3 water just kept coming right through.

4 MR. KEEFER: We're not going to have nearly

5 as much water maybe now as what's coming off the

6 site on to Celery, so I think that may improve

7 the situation somewhat and most of the water will

8 be going into that system, the ditch along the

9 tracks. You may not be familiar with that

10 system.

11 MS. HALE: What is it?

12 MR. KEEFER: You know where the shed is on

13 the property —

14 MR. SYKES: It's just to the east of the

15 property. It goes from the railroad tracks, down

16 to General Avenue.

17 MR. KEEFER: The ditch — big ditch going

18 down toward the Interstate, that's where most of

19 the water is going to go.

20 We'll be back to talk about the design, so

21 when Darlene gets a chance and time and some

22 money from EPA to work on that design, we'll come

23 down and talk about how we're going to make that

24 water — yes, ma'am.

25 MS. KEAN: David, will EPA be able to


29

1 contact the City and recommend any of this —

2 MR. KEEFER: Yes. We can certainly do that.

3 While the remedy is still being worked on, the

4 local governments normally don't perform some of

5 those functions like building ditches because the

6 property has been turned over to them. And

7 hopefully a year from now we'll be in here. We

8 won't call it community day but we will be done

9 with the site and we'll work with the Florida DEP

10 under the law and complete the superfund site.

11 And if everyone is satisfied that the work is

12 completed, then we'll turn over the property to

13 the State and the State often time will turn it

14 over to the local community.

15 Did you have any other questions today or

16 comments you would like to make?

17 MS. HALE: I don't know enough to talk.

18 MS. KEAN: You know a lot.

19 MS. HALE: Well, I don't know --

20 (inaudible).

21 COURT REPORTER: I can't hear her.

22 MR. KEEFER: I know it's a concern and it's

23 a concern in many of the communities that I work

24 in and I sympathize. The uncertainty and the not

25 knowing is hard on people, you know, as anything


30

1 else. Dioxin is a problematic chemical and no

2 one really knows for sure how potent it is on the

3 human carcinogen.

4 MS. HALE: (Inaudible) — and that steam

5 when they let that out, it fills the air and it

6 was a long time building it up and I suppose it

7 will be a long time caring for it.

8 MR. KEEFER: You know, not so long ago, you

9 know, my first job was working at a gas station,

10 helped out the mechanics, you know. All I needed

11 was a great job to get the grease off. We've

12 learned a lot and I think we're doing good.

13 MS. HALE: I appreciate it, I really do.

14 MR. KEEFER: Well, I appreciate you coming,

15 Ms. Hale.

16 MS. HALE: Well, I really wasn't able but I

17 did come. I had a very busy week and I still

18 tried to be here. I did want to come and I

19 appreciate everybody. Thank you for your

20 interest and your help.

21 (The meeting concluded at 7:05 p.m.)

22 - - -

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1 CERTIFICATE

2

3 STATE OF FLORIDA

4 COUNTY OF DUVAL

5

6 I, Florence Powell, Court Reporter, certify

7 that I was authorized to and did stenographically

8 report the foregoing proceedings and that the

9 transcript is a true and complete record of my

10 stenographic notes.

11

12 Dated this 18th day of September, 2006.

13 _______________________

14 FLORENCE POWELL Court Reporter

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RECORD OF DECISION (RODS)Record of Decision Page iii Coleman-Evans Wood Preserving Company Operable...

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