TRANSCRIPT - PROPOSED PLAN PUBLIC MEETING FOR THE … · 2 I'm L'Tonya Spencer. I'm the Community...

U.S. Environmental Protection Agency Public IVIeeting September 7, 2011

U.S. ENVIRONMENTAL PROTECTION AGENCY

SUPERFUND PROPOSED PLAN

SAPP BATTERY SUPERFUND SITE

OPERABLE UNIT 2 - GROUNDWATER

DATE:

TIME:

PLACE:

REPORTED BY:

/

PUBLIC MEETING

September 1, 2011

6:06 p.m. to 7:06 p.m.

Cottondale Community Center

2666 Front Street

Cottondale, Florida 32431

Stephanie R. Zeitvogel

Court Reporter

Notary Public

State of Florida at large

Pagel

U ORIGINAL

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U.S. Environmental Protection Agency Public Meeting September? , 2011

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PARTICIPANTS; ERIK SPALVTNS Remedial Project Manager [email protected]

-and-LTONYA SPENCER Community Involvement Coordinator spencer. I atonya@epa. gov U.S. EPA. Region 4 Superfund Remedial Branch Superfund Division 61 Forsyth Street, SW Atlanta, Georgia 30303 (800)435-9233 CHRIS PELLEGRINO (FDEP) ROY BAGGETT CHRIS RUTHERFORD LEIGH BROOKS

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1 cleanup. 2 This meeting is to discuss the proposed plan 3 for the site, and it's a proposed plan for the 4 cleanup. So we're at the stage where we are 5 prepared to make a decision about part of the 6 cleanup for the site. 7 We have in attendance here also from the 8 govermnent, from the State govemment, Chris 9 Pellegrino with DEP. He is the State counterpart.

10 On this site it's somewhat complicated site. 11 But the DEP is EPA's partner in paying for part of 12 the cleanup. So I wanted to recognize Chris. 13 Then, I guess, if there's no questions, I will 14 just start with my PowerPoint presentation. All 15 right? Good deal. 16 Basically, what we're going to have here Is a 17 very brief discussion of the history of the site, 18 how we got to where we are today, and the status of 19 the groundwater cleanup and what we're proposing to 20 do with this proposed plan. Then anybody — we've 21 gotten such a small crowd, I'd say, if anybody has 22 a question at any poinl, feel free to let me know 23 and we can have a conversation. When you've got a 2 4 small group like this, it's pretty easy to handle 2 5 it that way.

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1 MS. SPENCER: For those of you who are here, 2 I'm L'Tonya Spencer. I'm the Community Involvement 3 Coordinator for the Sapp Battery site. I'm with 4 the Environmental Protection Agency Region 4 out of 5 Atlanta, Georgia. Erik is the Remedial Project 6 Manager for the site. 7 I'm going to take the time to welcome you to 8 the Sapp Battery proposed planning meeting site. 9 We do have a transcriber here, and we are asking

10 that, at the end of Erik's presentation, ifyou 11 have questions, please introduce yourself first so 12 we can make sure to get your name on the 13 transcription for our records. 14 Did you want to introduce ~ 15 MR. SPALVTNS: Sure, I can do that. Thanks, 16 L'Tonya. 17 Well, my name is Erik, and 1 am the Project 18 Manager for the Superfund site here at Sapp Battery 19 Superfund site. Basically, my responsibilities are 20 to manage the site from investigation to trying to 21 decide what the options are, identifying exactly 2 2 what the problem is, what are the options to fix 23 the problem, and then how do you fi.x the problem. 2 4 Tlien, once we make that decision, then the project 2 5 manager is responsible for carrying out the

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1 So I want to briefly cover the Superfund 2 process, which was discussed a little bit. This 3 site has been around for a while. It became a part 4 ofthe Superfund program back in the eighties. So 5 it's been around for a while, and there have been 6 some cleanup actions already at the site. So the 7 site has already been through this Superflind 8 process in some parts of the site. 9 So we have the — we have a cleanup of the

10 soil, we have a cleanup of the ~ 11 Oh, I'm sorry. 12 MS. BROOKS: You're fine where you are. 13 MR. SPAL\/TNS: Plenty of room to move around 14 on this one. 15 We have the soil cleanup, we have lhe cleanup 16 ofthe svi'amps, and we also have the cleanup ofthe 17 groundwater. So those are the three portions of 18 the site that we've got. 19 So what we have — the soil cleanup has 2 0 already been through this entire process; 21 investigation, which is where we identify exactly 22 what the problem is; feasibility studies, where we 23 lay out the options and we decide, you know, (he 2 4 pros and the cons of each of the options to fix the 25 problem.

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U.S. E n v i r o n m e n t a l Pro tec t ion Agency Publ ic Mee t ing S e p t e m b e r 7, 2011

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1 The proposed plan, which is where we are 2 today, leads into the Record of Decision. Those 3 two ~ that's the remedy selection process. So the 4 cleanup approach that we use, we call that the 5 "remedy." 6 So to select the remedy, the process is we 7 have a proposed plan that we issued to the public, 8 which we mailed out, and then we have a public 9 meeting, which is this meeting today. Then, after

10 we receive 30 days of public comments and comments 11 from the State, then we will issue the final Record 12 of Decision, which is the document the EPA uses to 13 document what we're planning to do to fix the 14 problem and why we're going to choose that. 15 So today we're talking about a proposed plan 16 for part of the cleanup, just the groundwater part. 17 After that we have the remedial design stage 18 where we lay out the details of how we're going to 19 fix the problem. Then remedial action is where we 2 0 carry out the cleanup. 21 Af\er that is over, then you enter the 2 2 operation and maintenance phase, which is something 2 3 that goes on for a long period of time, depending 24 on the remedy. 2 5 So this site, the Sapp Battery site, is about

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1 a 45-acre site. In the early seventies up until 2 1980, there was a battery recycling operation on 3 the site. So what happened was, the companies and 4 individuals would bring batteries to the site and 5 the company that was operating there would open up 6 the batteries, release the — and the sulfuric acid 7 would go into a drainage, into a holding pond, and 8 then they would take the lead from the batteries 9 and send it for recycling.

10 They didn't have very good controls over how 11 they were managing the waste, the sulfuric acid. 12 As a result, they had widespread contamination of 13 the soils on the site, with both heavy metals and 14 sulfuric acid. 15 iTie holding pond, at times, overflowed and 16 entered the swamp, and so there were fishkills and 17 there were some ~ where the swamp was killed 18 and ~ excuse me. So the acid impacted the swamp, 19 (he acid impacted the groundwater. 2 0 So the EPA and the State both spent some time 21 and energy out at the site cleaning up parts ofthe 2 2 site, trying to neutralize some ofthe acid that 2 3 had been spilled. 24 During the process of investigating that site, 2 5 they found some paperwork and documentation oflhe

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1 companies that had been in business with the owner 2 ofthe property and the facility. So the EPA 3 pursued enforcement action against those companies 4 and individuals. As a result, we found a group of 5 people that became responsible parties for the 6 site, and they entered into an agreement wilh the 7 EPA to do part of the cleanup. 8 So the EPA managed that, the EPA supervised 9 that wdth the State's input, and they handled the

10 soil cleanup. 11 So I may have jumped ahead a little bit here. 12 I guess I should have said that before the 13 companies became responsible parties, the EPA 14 issued a Record of Decision, which is the ROD that 15 we talked about earlier. That was in 1986. 16 In that Record of Decision, the EPA identified 17 a cleanup remedy for lhe soil, for the sediments, 18 and for the ~ 19 (Door slams shut, interrupting the proceedings.) 2 0 The soil cleanup was to build a monolith 21 on-site ~ well, let me go to the next slide. 22 So the OUl is the soils that was — the remedy 2 3 for the OUl was to excavate the soils that had been 2 4 contaminated with lead and acid and then bring them 2 5 together on top of ~ at the site and build a

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1 monolith, mix it with some compounds that would 2 stabilize the soil and prevent the lead from 3 leaching into the groundwater, and then cover that 4 monolith with soils so that there would not be any 5 direct exposure to people that are woridng on the 6 site. So that was the soil cleanup. That was 7 completed by the ~ we call it — PRP is one terni. 8 That stands for Potentially Responsible Party. 9 The folks that we identified that had

10 contributed to the contamination, they coalesced 11 and formed a group called the Sapp Battery Group 12 that conducted that cleanup. 13 The planning for that took several years, but 14 they carried it out ~ they started it — or, they 15 finished it in September of 2001. 16 Then, in 1999, Congress passed the Superfund 17 Recycling Equities Act, which released certain 18 classes of people and companies from responsibility 19 for Superfund cleanups. The idea behind that was 2 0 that there were a lot of small companies that had 21 been impacted in that industry, the batteries 22 recycling industry. So Congress passed a law 2 3 speciflcally to give them some relief from the 2 4 Superfund liability. So the remainder of the site 2 5 was handled by the federal govermnent, based on

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U.S. Environmental Protection Agency Public iVIeeting September 7, 2011

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that act of Congress. So the next part ofthe site that underwent

construction was OU3, which was sediments. This was handled by the federal govemment with the State's help. The EPA finished the remedial design in 2005 and carried out the ~ and they carried out the cleanup and finished it in September 2008. Then they closed out lhe paperwork for that in 2009. That's why 1 have two different dates here.

But what they did for the swamp, basically, is they excavated the sediments in the swamps that were contaminated by heavy metals and hauled them to the landflll. And then, that restored the swamp.

Then the rest ofthe remediation oflhe swamp was to naturally attenuate it. 1 have some pictures ofthe swamp today, and it really has improved a lot. So where this excavator is in this photo, you can see back behind it the dead swamp as they were excavating it. This is right after the excavation was done and the swamp had filled with water. 1 will show you a picture later that has it restored with lily pads and plants growing in it again.

MS. BROOKS: Wliat-

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MS. SPENCER: Could you state your name? MS. BROOKS: Oh, I'm sorry. Leigh Anna

Brooks, Chattahoochee, Florida. What is the distinction between soils and

sediments? MR. SPALVINS: That's a good question. Basically, it depends ifthey are wet, is

one — the simplest way to talk about it is if the — if it's in part of the body of water, if it's under there, that is considered the sediments. That's the most general description, the way to distinguish between the two.

MS. BROOKS: So what was under water, that was shifted to a landfill, that was hauled off-site?

MR. SPALVINS: Right. MS. BROOKS: The soil that was not under the

water, that was put into the monolith? MR. SPALVTNS: That was put into the monolith,

right. They did get some ofthe sediments, I think.

Or part of that cleanup. In fact, when they dug up the ~ when they did that first big soil remedy, part of fhe objective was to get ridof what might be considered "source material." So that would be stuff that had a lot of acid in it or had a lot of

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lead in it. So they dug pretty deep. They dug into the groundwater table in some

parts, so they did get some saturated soil, which we would consider part — maybe part ofthe aquifer or to be saturated soil. So —

MR. BAGGETT: Well, actually, wc dug down and ; pumped the water out and used it for fixated material. So we went down to where it tested below the target number. So we actually removed the soil that was contaminated and wet. We used the water that was wet into the fixated material, and then the soil was worked into that. It was used in a proprietary material called MAECTITE, which is like a cement.

MS. SPENCER: Could you stale your name for the record?

MR. BAGGEll: Yes, ma'am. I'm Roy Baggett. I'm a project ~ I'm the PRP project coordinator.

MR. SPALVINS: Does that answer your question? MS. BROOKS: Yes. MR. SPALVINS: The main reason that the

sediments were shipped to the landfill ~ one of the reasons, and there's a lot of different reasons. But from an economic standpoint, it was aflbrdable and it was a safe way to handle that

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material. There was not a lot of acid in that material,

and I believe most of it went to ~ 1 don't recall if it went to a hazardous waste landfill or to a normal landfill, so I probably shouldn't speculate. It's in the record, but I'm afraid I don't remember.

So when the soil cleanup was conducted, they handled a lot more material than was ~ than was involved when they dug out the sediments in the swamps. I think it was almost a hundred thousand cubic yards of material.

So treating it on-site and solidifying it on-site made a lot more sense to do it that way. Because there's a certain amount of infi^astructure that you mobilize to the site when you do on-site treatment, and it didn't make sense to do it for the sediments.

The sediments are a little different because there was a lot of organic matter. So you start trying lo figure out how to pile that into a stable unit on-site and it's a lot harder because the organic material is going lo decompose. So it made more sense to send that to a landfill.

So, like I said, the federal govemment

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U.S. E n v i r o n m e n t a l Protect ion Agency Publ ic Mee t ing S e p t e m b e r 7, 2011

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1 handled the sediment cleanup in the swamps, and the 2 groundwater cleanup is the last component of lhe 3 cleanup for this site. So we have already finished 4 the soil and the sediment. Both of those remedies 5 were carried out ~ both of those remedies were the 6 same remedies thai were in the 1986 ROD. 7 For groundwater, the 1986 ROD called for 8 something called "pump and treat" where you pump 9 out the groundwater, you run it through a treatmeni

10 system, and then you reinject it into the 11 groundwater or you discharge it to surface water. 12 What happened was, in brief— fll go into a 13 little bit more detail than this later — the EPA 14 started working under the design for that remedy in 15 2004. As you see here, we added some more wells in 16 2004 and started to look at, How could we design a 17 pump and treat system to handle the groundwater 18 contamination? 19 As we started to leam more about the 2 0 groundwater contamination, we realized that because 21 ofthe way the aquifer behaved, it would be very 2 2 difficult to pump out the groundwater and treat it 2 3 and get an effective cleanup. 2 4 Plus, we leamed that, over the years, the 2 5 contamination had decreased a lot. It decreased

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1 So what we're looking at ~ and I apologize 2 for the quality ofthe picture. Ifyou want lo 3 come up later and take a look at it on the 4 computer, you can. Or even now, you can. 5 Wliat we have — over here we have the original 6 facility and different buildings that were used in 7 the battery-cracking operation. This is a swamp 8 that existed until the eighties. Tliis is the 9 natural — this is the, what we call, the eastern

10 swamp. This swamp was dug out during the OUl 11 cleanup, the soil cleanup. That swamp was 12 excavated and removed and became part of the 13 monolith. 14 Again, I apologize for the quality of the 15 image we have here. We'll work with what we've 16 got. But this is just to show you what the site 17 looked like originally or during the early stages 18 of the cleanup. 1 9 This is the site, the swamp today. I'm going 20 to flip back here. This part of the swamp right 21 here is what you're looking at in this image here. 2 2 This was about, 1 think, a year ago, maybe. 1 was 2 3 down here and swung by and took a photo. You can 2 4 see lily pads throughout the swamp, big difference 25 compared to the photo with the excavator in it.

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1 tremendously in the aquifer. So we started looking 2 at other options. I'll show you some data in a 3 little bit, the different data from 1986 when pump 4 and treat was the clear choice, to today, where now 5 we think that, based on all the data we have, that 6 we can conclude that contamination will continue to 7 attenuate over time until natural attenuation 8 handles it. 9 The reason that that's possible is because of

10 the source control cleanup that was done by the PRP 11 group wilh the soils, because they dug out so much 12 soil and got so much ofthe material that was 13 contributing to the problem out of the aqui fer. 14 So this is a picture oflhe site. I don't 15 recall exactly when this was taken. This was in 16 the eighties. But I think it ~ I don't recall. 17 Roy, does this ring any bells to you? 18 MR. BAGGETT: Il appears to be familiar. But 19 if it's the one that has the mylar on it, it was 2 0 about in the area of, I would say, 1984 or '85. 21 MR. SPALVINS: Tliat sounds about right. 22 MR. BAGGETT: Because that was before anything 2 3 started being moved or anything started being 2 4 repaired. 25 MR. SPALVTNS: Yeah, that sound about right.

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1 Then — oh, that's a picture ofthe swamp 2 across the street from the south side. That's 3 Steele City Bay, which is this southem swamp area 4 here. 5 So I'm going to make some comparisons of— I 6 talked a lillie bit about how the source control 7 measures had improved the quality ofthe 8 groundwater over time. I tried to figure out how I 9 could talk about that in a way that makes sense,

10 and I hope that this does. 11 What I have here is the acreage of the 12 contamination, ofthe lead contamination in the 13 aquifer. You really can't make out the first 14 column, but this first column is in 1983. This is 15 1983 that the lead plume ~ this is the area of the 16 plume that was above the drinking water standard. 17 This is why there was a lol of concem about this 18 site. 19 In 1983 the surficial aquifer, which is about 2 0 lhe lop 10 or 20 feet in this area, there was about 21 a 20-acre lead plume. The intennediate aquifer, 22 there was about a 14-acre lead plume. The Floridan 2 3 aquifer, which is where most people get their 2 4 drinking water, there was about a 10-acre lead 2 5 plume.

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U.S. Environmental Protection Agency PubUc Meeting September 7, 2011

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Now, when you're doing estimates like this, it's kind of ballpark, you know. This is a ~ you know, just to give this an idea, in 1985, the surficial aquifer had ~ there was a litfle less, a little smaller, maybe, that's just an — you know. maybe that just isn't a real difference. Maybe it was the same, but we're estimating 18 acres. Intermediate estimated a little bigger.

The big change is to the Floridan aquifer. In 1985, the area that was contaminated grew to about 35 acres. So it went from 10 acres to 35 acres. That's a pretty big increase.

So in 1986, when the original decision was made how to handle this groundwater problem, we were looking at a plume that was starting to grow. We had some modeling that was conducted in the eighties that estimated that the plume could move off-site and in a manner of— a period of years would be impacting some ofthe neiglibors' wells downgradient.

Now, what we know now is thai the models we were using in the 1980s were not very good at predicting lead movement in the aquifer. So it was eariy in that approach.

At any rate, in i 988, the groundwater in the

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surficial aquifer was down to 10 acres of area in '88. So we started to see the plume shrinking.

Tlie intennediate aquifer was about 14 acres, so it's about the same size.

But the contamination ofthe Floridan aquifer is down to 20 acres. So this is where we first started seeing that the Floridan contamination was staning to shrink. This is after some emergency response actions had been taken, but before the source control occurted.

So then the source control was carried out. It was finished in 2001. It was being planned in the nineties, and we are monitoring, as this is happening, the groundwater to make sure it's not getting out of control. They do the source area — the soil and the source area remediation, and then that removed a lot ofthe source oflhe groundwater contamination from the enviromnent.

And by 2005, the ~ there's no plume of ~ lead plume in the surficial aquifer, zero acres. In the Floridan aquifer, same, zero acres. There's just not much left. The intennediate aquifer, we sfill see about an acre of area where there's a small lead plume that remains.

Because what's happening is that the acid was

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removed and the natural attenuafion, the flushing ofthe groundwater, the aquifer maleriai is neutralizing the acid. As a result, the heavy metals contamination is coming to absolution because the heavy metals tend to dissolve more easily where you have acid PH. So as PH levels are going back to nomial, then the lead levels are going back to normal, too.

By 2011, we have continued monitoring and we '• have paid very special attention to the way we are doing the sampling to make sure we are getting good quality samples, and we are down to two points, the end of two wells that are giving us exceedances (sic) for lead, only in the intermediate aquifer.

So this is the way that I think 1 can best describe the magnitude of improvements that we have seen in terms ofthe lead contamination in the groundwaler over the years.

So to take it back to 1986, we have what looked ~ which was, we had a pretty serious problem. The groundwater remedy was we are going to get in here and pump out the water so it can't go very far, we are going lo treat it at the surface, and then we are going to discharge it clean.

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Today the lead problem has largely resolved itself as a result ofthe source control measures that were taken. This is part of the evidence, this is the largest part ofthe evidence that leads us to believe that natural attenuation will be appropriate for the remainder ofthe cleanup. ;

MS. BROOKS: Before you go on - j MR. SPALVTNS: Sure. MS. BROOKS: ~ how many acres are on the site

total? MR. SPALVINS: The site itself is about

45 acres. I have some maps that show the groundwater plumes coming up next.

MS. BROOKS: The plumes - the acreage ofthe plumes that you have on this slide, are those within that ownership or are they — any of them off-site?

MR. SPALVTNS: A little bit of bolh. Some of il was off-site at points.

MS. BROOKS: And then, how did you establish these acreage figures? Through monitoring wells o r~

MR. SPALVTNS; We have monitoring wells. There was a series of monitoring wells that was put in in the eighties. When they did the source



U.S. Environmental Protection Agency Public Meeting September?, 2011

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removal and they excavated large parts ofthe site, they destroyed most of those moniloring wells. So we have gone back in and put in new monitoring wells. So we have a combination of old wells that were used back in the eighties, and we have the new wells thai are built now.

So we have to make a best professional judgment. We have some specific areas where there was an old well that gave us a certain result. That well was destroyed and another well was put in. In some instances we decided we wanted to put another well in next to that well to doublecheck it, and we leamed a lol through that process.

But yeah, we use monitoring wells. A lot of this is computer modeling, and it's basically an eslimale. If one well is very high, then it kind of estimates a large area around it. If there's another well next lo it ihaf s high, then it estimates that it's probably connected.

MS. BROOKS: How many monitored wells are out there?

MR. SPALVINS: Right now, I think we have -MR. PELLEGRINO: Around 60. MR. SPALVINS: ~ about 60. MS. BROOKS: Wow.

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MR. SPALVINS: So this is a figure that shows the - in 1985 ~ well, let me orient everybody.

All right. So this is the facility, the fenced in property boundary right here. Then the original operations were on this parcel here in this area. You may be able to see a little gray oufline here. Tlie gray outline is where the monolith is. So a lot of this monolith, rather than being a pyramid that's tall and huge, most of it is pretty low to the ground, 10 feet, maybe 5 feet in some areas.

It does two things. Wlien you build it that way it's easier to build because you don't have lo build it so high, but it also covers the area and keeps rain from infiltrafing into the groundwater in that area. So waler hits it, it mns off of il and goes into the surface water. So that's why we have a pretty large monolith that covers this area.

Part of this includes the old swamp. This is where a lot of the acid ended up draining to, into this swamp. Then il drained into this swamp, and some of it drained this way into the swamp south of the site. So that's kind of orientation.

Wlien the swamp cleanup was conducted, it involved digging up a lot ofihis area here. So

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this area, largely, was the OUl cleanup, and this was 0U2. Then more further to the south, and 0U2 involved some cleanup up here, too.

Now, the box here is the 45 acres. The pink oufline is based on the wells in 1985. Wliat it showed, what it is describing here is the estimate of how big the plume in the Floridan aquifer was. about — I guess this was the one that was about 35 acres. So you can see that we have some wells thai are ~ some estimates that are coming 1 off-site. Now, there's a railroad track over here. 1 Obviously, we didn't have ~ I don't believe we had any wells over on the other side oflhe railroad track. This is an esflmale. This is where it's kind ofa professional judgment.

Now, what I have on the next slide shows an overlay of the new data. I'm going to apologize for the pictures here. The proposed plan that we \ mailed out has more detailed images.

Do you have it? MR. PELLEGRINO: Yeah. MR. SPALVINS: Thank you. Did you get one? MS. SPENCER: No. ' MR. SPALVINS: It's got a DEP stamp on it. So

this is what we're talking about right here. This l

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is the same image here. j So these are the new wells. So what we have \

done is, we have the sampling history on these 1 wells. So this is '04, '05, '08, '05, '08, '04, '05,'06,'08. Someof these are newer wells that | we installed recently. i

These are the test results for different 1 parameters; aluminum, iron, lead, manganese. vanadium, pH and turbidity.

Turbidity is important at this site because some of the stuff that we are trying to clean up for, it is elevated when there's a lot of— ; turbidity is a measure of the clarity.

You know what ~ MS. BROOKS: Uh-huh. MR. SPALVTNS: It's a measure of the clarity

ofthe water sample. So when turbidity is elevated ~ sometimes you get elevated numbers for certain results.

Like this turbidity is 35. This is EW2D in 2005, and the lead number was 310 micrograms per liter, which is pretty high. That's the cleanup -the groundwater, I'm sorry ~ the drinking water standard for lead is 15. So that's pretty high.

Now, when you see that you think, well, then, j




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1 that's a real problem. But then you have to ~ you 2 know, we started paying more attention to the 3 turbidity, and we realized that maybe il was an 4 issue wilh the quality of the sample. So we 5 sampled again in 2008 and we got a more clear 6 sample. When we analyzed for lead, it was 7 below detecfion level. That's what the U stands 8 for. It means undetected. The 4 that's there is 9 the detecfion level.

10 So what we — there's a lot of data on this 11 site, but what we tried to do is present the data 12 we had in '86 we based that infonnation on, and 13 then the new data is what we are basing our current 14 information on. So this 8L is one that we'll talk 15 about a litfle bit later. You can have this copy 16 of this. 17 MS. BROOKS: Okay, thank you. 18 MR. SPALVTNS: And there's, 1 believe - we 19 have more groundwater data ~ 2 0 MS. SPENCER: Okay. 21 MR. SPALVTNS; ~ for the other figure. So at 22 least you can see what is on my projector. We're 2 3 going to have to buy a screen, I guess. 2 4 All right. So I mentioned 8L to you. The 2 5 thing about this site, the main characteristic of

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1 this site is that there are sinkholes at the site. 2 The swamps are where the sinkholes have filled in 3 over the eons with sand and clay and peat and 4 plants and big alligators and all kinds of stuff. 5 So what we have at some ofthe wells like that 6 8L, continues to have high iron numbers. One of 7 the reasons is because ~ and you can't see it on 8 the projector maybe, but you can see it in the 9 proposed plan. 8L is this well here. 8L is a

10 screen in a zone of the aquifer that is comprised 11 of silts, clays, sands, but you have a lot of silts 12 and clays that are mixed in there with some organic 13 matter. As a result, the permeability of that 14 aquifer material is lower, so the water is going to 15 move slower through it. 16 Basically, whafs happening is, there is some 17 low PH groundwater in pockets in these low 18 permeabihty zones. It's there. We couldn't pump 19 it out because the permeability is so low that it 2 0 comes out as a slow trickle. We could try to 21 inject, but we wouldn't be very successful, again, 2 2 because we wouldn't be able to push much water into 2 3 it because there's low pemieability. 2 4 The good news is that, because it's a low 2 5 penneability, it's very ~ the water that's in

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1 there is only going to release into the rest of the 2 aquifer very, very slowly. So it's not going to 3 impact the rest of the aquifer in temis of creafing 4 an ongoing groundwater problem. 5 But it's bad that the permeability is low on 6 one hand because if it was higher it already would 7 have attenuated, the water would have flushed 8 through and the PH would have gone to neutral and 9 the metals would have decreased. But it hasn't

10 because it's low pemieability. So it's kind of a 11 good thing from the standpoint of not impacting the 12 groundwater but a bad thing because there continues 13 to be contaminafion there. 14 The good news for us is, at this site, it's 15 not enougji that it's going to make the plume get 16 bigger. If it was a different type of contaminate, 17 we might have to take acfion to go in and get it. 18 But at this site, we're going to let natural ~ 1 9 what ~ we would like to let natural attenuation 2 0 take its course. 21 So this is another slide that just shows 2 2 another cross-section of the aquifer. So you have 23 the ground surface here and then different layers 24 of geological material. Undemeath all of it is 2 5 lhe limestone. But in some places you have

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1 sinkholes that have fomied, I don't know how many 2 thousands of years ago, where the limestone was ate 3 away and then everything collapsed into it and then 4 it just filled up over the years. 5 This slide is the intermediate aquifer. Same 6 basic concept that we talked about before. This is 7 the north half of it because it's a litfle larger, 8 a lot more wells so it's hard to talk about. The 9 pink, again, is the lead plume, and then all this

10 data is here. 11 Again, it's in the proposed plan ifyou would 12 like to look al it more closely. I'll sum it up by 13 saying that as we worked on the site since 2004, we 14 leamed that we have to be sure that we get low 15 turbidity samples so that we are getting quality 16 samples. 17 We also identified some areas that we thought 18 were source areas where we thought we had a lot of 19 lead contaminafion. Butthe wells that were there 2 0 were not really producing the right quality data, 21 so we went in next to those wells and we put in new 2 2 wells and we sampled the new wells and we didn't 2 3 find the lead contaminafion. 2 4 So the bottom line was, we had other wells 2 5 that were screened and the material had low

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penneability. Some of it was actually peat that was down in the bottom ofthe sinkhole. Peats, clays, sills, things that do two things really well; ihey hold on lo lead well, and ihey also get in the water well and they don't let water through. So when you're pumping out waler, you gel turbid a sample that has a lot of particulates in il that hold on lo lead really well.

So basically we're getfing the wrong picture about the aquifer. It looked like we had an aquifer where you had mobile lead moving. But in reality, we didn't have that. So we verified that with new wells, and we are a lot more comfortable with attenuation now.

This is the bottom half of the intermediate aquifer. 1 told you eariier we had two points in the intemiediate aquifer where we had lead contaminafion above the cleanup number, which is the drinking water standard for lead. It's these two points here; they are both part of that sinkhole phenomenon. One of them, I believe, the lead contamination is 18. The olher one, the lead level is 17. This compares to the drinking water standard, which is 15.

The numbers are decreasing over fime. The

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1 they get a pennit in such a radius. 2 MR. SPALVTNS; It's a zone that is restricted 3 in terms of water use. So if somebody pulls a 4 pennit to put in a well, the Water Managemenl 5 District is going to tell them. No, you can't build 6 a well there because you can't drink that water. 7 On top of that control, we plan on ~ we will 8 have a restrictive covenant if we can negotiate 9 with the landowner. So we'll have a legal

10 agreement with the landowner that ihey won't let 11 anybody pul a well in it. 12 Then, the other thing that's — one ofthe 13 most effective controls, though, is that there's a 14 monolith over most of this. So a typical well 15 driller would hit that monolith and ihey would be 15 spinning their ~ their bit would be ~ it would be 17 like trying to go through a sidewalk. So that's 18 the main ~ one of the other controls to prevent 1 9 people from drinking this water thaf s contaminated 20 until it cleans up. 21 MS. BROOKS: The restricted area, how far does 2 2 that go out? 2 3 MR. SPALVINS: It's several hundred feet away 2 4 from the property. I have a diagram of it, but I 2 5 don't have it wilh me. But it is on the website on

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1 turbidities are better so we are very comfortable 2 we have good data now, and we are almost at the 3 cleanup number for lead. So we are pretty 4 comfortable that we are going to achieve that over 5 lime. It may take some time. 6 But we also have cleanup numbers for iron, 7 manganese and vanadium. The trend is the same for 8 those metals, that if s decreasing over time. In 9 some places it's slower than others to decrease

10 because ofthe effect ofthe pH, bul the trend is 11 that it will decrease overtime. So we will 12 eventually achieve those cleanup numbers. 13 In the meantime, unfil that time, we have ~ 14 this area is in a groundwater restricted ~ 15 Whafs it called, Chris? 16 MR. PELLEGRINO: Oh, um ~ 17 MR. SPALVINS: Delineated area? 18 MR. PELLEGRINO: Well, yeah, it's definitely 19 delineated. But it's ~ whafs the term? The 2 0 Water Management District uses that tenn within our 21 memorandum of agreenient wilh them or — 22 MR. BAGGETT: It's a covenant? Like a 2 3 covenant? 24 MR. PELLEGRINO: It's similar. It comes 2 5 with — the Water Management District flags it when

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1 one of DEP's databases called Map Direct, I think 2 is what it's called, and it's there. 3 It's several hundred feet off of the property, 4 and we don't have any groundwater contamination 5 outside of that zone. 6 So this is the surficial aquifer, it's the 7 last one I'll show you. I'm just going to pop up 8 the boxes here. 9 One ofthe features ofthe soil cleanup was

10 that most ofthe surficial aquifer was actually 11 excavated and solidified and then put right back in 12 place, but no water is going into it. So 13 basically, when rain hits it, it mns off the top. 14 So most of the surficial aquifer is gone. 15 Then we have our monitoring wells around the 16 monolith thai show that the water in the surficial 17 aquifer has attenuated very nicely. 18 So the risk at the site at this point is that 19 there's a potential risk if people use the 2 0 groundwaler in the future. There's no current 21 exposure, no current health risk because nobody is 22 using the groundwater. But EPA has the Superfund, 23 and the law sets the standard of protection, which 2 4 is that in the future people might use ihis and we 2 5 are going to protect against that potential future

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use. The direct exposure to the contaminated soils

and the control oflhe source ofthe groundwater contamination was addressed during the OUl soil cleanup, and the ecological risk was handled in the sediment cleanup when ihey cleaned up the wetlands. So the only remaining risk is potential future exposure to groundwater contamination.

So what — after we identify what the risk is, we set the remedial acfion objective, which is, basically, What we do we want to accomplish with this cleanup?

The first one for this site is to prevent exposure to contaminated groundwater above acceptable risk levels, which are your drinking water standards. So this would be the level of chemicals that would be allowed lo be in a city water system.

Then, the second remedial action objective is to remm groundwater to the beneficial reuse wherever we can. So that's the general principle of aquifer restoration, which basically is the same as the first one with a different employment.

So then, based on the remedial acfion objectives, is the cleanup goals for the

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1 standard, but not a primary drinking water 2 standard. 3 So the secondary drinking water standards are 4 established based on taste or esthetics or 5 discolorafion. Like iron, iron will lum a sink 6 brovm over fime if there's alot of iron in the 7 water. So we calculated numbers for those. 8 For vanadium, we used a State regulation or a 9 State mie ~ I guess it's a regulafion.

10 MR. PELLEGRINO: Regulation. 11 MR. SPALVINS: Regulafion. Then, we based the 12 vanadium cleanup on Florida Administrative Code 13 62-777.170. Table I in that contains the State 14 regulations that EPA has detennined are applicable 15 lo the ~ to this ~ what is it ~ applicable or 16 relevant in appropriate standards. 17 It's a legal term, basically. Tt means that 18 we are going to defer to the State in 19 certain-situations. WTien they have a cleanup 2 0 number and maybe the EPA or the federal govemment 21 doesn't have a standard, we can defer to those 22 standards. So on vanadium, thafs what we are 23 doing. 24 So then we have developed remedial 25 altematives, which are the cleanup options we have

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1 contamination — pardon me, I'm sorry. Just a 2 second. Sorry, I have been a little under the 3 weather. 4 We set cleanup goals based on remedial action 5 objecfives. For this site, the remaining 6 groundwaler constituents that are of concem are 7 aluminum, iron, lead, manganese and vanadium. Tlie 8 cleanup goals, we get those cleanup goals from 9 different places depending on the chemical and the

10 law and State regulafions and different sources of 11 cleanup goals so that it's protected. 12 One ofthe main ones we use is the 13 groundwater ~ I'm sorry ~ is the drinking water 14 standard. For lead, we have ~ if s called an EPA 15 action level for lead. That is set at 16 15 micrograms per liter. So that's oneof our 17 cleanup goals. 18 We have three chemicals where the EPA 19 calculated a site-specific number based on our risk 2 0 assessment, guidance. Basically, we calculate how 21 much chemical would be in waler over a certain 2 2 period of exposure without causing a health impact. 2 3 We did that for aluminum, iron and nianganese. 2 4 These are chemicals that don't have drinking water 2 5 standards. They have a secondary drinking water

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1 for achieving those cleanup goals. 2 The original groundwater remedy here ~ I will 3 just review ~ was pump-and-treat; pump it out of 4 the ground and treat it out ofthe ground and use 5 chemical precipitation, and reinject the treated 6 water into the groundwater or discharging it into 7 the surface water. 8 Tlie original remedy did not mention the 9 nahiral attenuafion, it did not menfion

10 institutional controls. We are adding 11 institutional controls to this, because it didn't 12 mention these things and we can no longer - we 13 have evidence that shows we don't need to do 14 pump-and-treat to achieve the goals and the 15 pump-and-treat is not pracfical based on the 16 aquifer characteristics. 17 This proposed plan is proposbig a new remedy 18 that is documented in a ROD amendment. So we don't 19 issue a new ROD. We issue a ROD amendment, which 20 just changes part of the original remedy. 21 Tlie three opfions that we evaluated in detail 22 in the proposed plan are the no-action ROD, which 2 3 is something that we have to ~ that is mandated by 2 4 law. You know, if you're going to - if s the 2 5 baseline, Wliat would happen if you didn't do

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1 anything? 2 Tf we didn't do anything, if we just walked 3 away from the site, there is potential that there 4 would continue lo be a risk for future users ofthe 5 groundwater, we wouldn't know, we wouldn't do 6 anything. That's not something we are going to do 7 seriously, but it's baseline. 8 Tn situ treatment would monitor natural 9 attenuation, and it's something that we evaluated.

10 ll was developed ~ an option developed since 2004, 11 injecfing chemicals into the aquifer to adjust the 12 pH and precipitate out the chemicals in-situ. 13 There are some implementability problems with that 14 because of the low permeability nature of the 15 aquifer. It makes it very difficult to inject 16 stuffin there at all. 17 Monitor natural attenuafion is the third 18 remedy that we evaluated, which is, you develop a 19 moniloring plan to look at — to make sure you're 20 monitoring the groundwater. You have to 21 demonstrate that you know whafs happening or you 2 2 know what attenuafion processes are occurring in 2 3 the aquifer, and you can measure them and track how 2 4 the cleanup is proceeding using monitoring natural 25 attenuation. You have a monitoring plan and you

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1 carry it out. So that was the third option we 2 looked at. 3 One of the componenis we look at when we 4 compare remedies is the lotal cost, and so we have 5 some cost numbers here. I can tell you that the 6 moniloring natural attenuation costs won't cost as 7 much. Under the current budget environment, we are 8 looking for ways to do this at a lower cost than 9 this. We have EPA personnel that we hope we can

10 bring the cost dovra. This is the cost, it's 11 $319,000 is the cost, the present cost, is the cost 12 to continue moniloring natural attenuation for ten 13 or 15 years, in terms of dollars today. 14 Tlie in-situ treatment followed by natural 15 attenuation is about $890,000. So monitoring 16 natural attenuation is a clear winner on cosls. 17 But what this table doesn't capture is that, 18 because ofthe implementability issues with 19 injecfing into this aquifer, that opfion would be a 2 0 waste of money. It would not be effecfive much 21 more quickly than monitoring natural attenuafion 22 would be, because in such an aquifer, you can build 23 a well and you can inject it but if s only going to 24 go a certain distance from the well because the 25 well — the aquifer is so tight and so low

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1 pemieability. 2 So this proposed plan lays out in more detail 3 the comparison oflhe altematives, but the 4 preferred remedy that we are proposing is 5 monitoring natural attenuation wilh institutional 6 controls. 7 We have evidence that our off-site wells have 8 already reached our cleanup goals. The cleanup 9 goals for lead are reached on-site with the

10 exception of two wells that are problematic because 11 ofthe turbidity issues and the complications of 12 the way they were built and the material they were 13 screened in. 14 The transfer of iron, manganese and vanadium 15 are improving as the pH is remming to a more 16 neutral level. Some of these wells, it may take 17 ten years more, it may lake 20 years, it may take 18 30 years for the levels to reach where they need to 19 be. 2 0 But the set of tradeoffs, over all, the EPA is 21 making the recommendation that natural attenuation 22 is the way lo go. 23 So with that, I will open the floor to open 2 4 discussion or questions. The details are all in 2 5 the proposed plan, and we are accepting comments

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unfil, I think, the 25lh of September. MS. BROOKS: At the time of, I guess, in the

eighties, when this pian was being worked on, the initial, you know, trying to develop the remedies, were there discharges to surface water and how far did the contaminafion go?

MR. SPALVINS: There had been discharges to surface waler and a large part of the swamp to the south oflhe east/west road, that Steele City Bay, a large part of that had been impacted. Steele City Bay drains to a creek south of Steele City Bay, and there were reports in the late seventies that there were fishkills and that there were animals that were drinking lhe water that died from drinking the water. So there had been discharge to surface water in the seventies.

Now, there were invesfigations of those discharges, and I'm trying to recall exactly when those reports were completed. Tt was in the eighfies. What ~ T do recall that there were studies looking at lead, the lead contaminafion in the sediments and down in the creeks that are downstream ofihis area. The conclusion was that the lead contamination didn't go very far. So 1 believe Dry Creek is dov^aigradient.

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1 There were a lot of studies of Dry Creek, not 2 just because ofihis site, but because of— I 3 think there was another battery-cracker site that 4 drained into the watershed. So the studies that 5 were conducted of Dry Creek were for both of those, 6 and for other upgradient, upstream industries. 7 But I ~ my best recollection is that there 3 was not a lot of downgradient impact of lead for 9 very far. But it was looked at, and it was ~ all

10 that was documented in the eighties. 11 We have a lol of those documents in Aflanta. 12 They were part of the administrative record for the 13 0U3 cleanup, which was the sediment cleanup. We 14 have some of those. I don't think ~ I don't know 15 ifwe have any of those online. But if you're 16 really interested in ihem, I can certainly forward 17 them to you. 18 MS. BROOKS: I'm interested in Dry Creek and 19 learning more about the story, the impacts to Dry 2 0 Creek. 1 guess tha f s -21 MR. PELLEGRINO: The State has a database that 22 you - an OCULUS database. It has some - 1 don't 23 think all - o f t h e old Sapp stuff, but it does 2 4 have a lot of the old Cohee-Bams smff. 25 MS. BROOKS: Cohee-Bams?

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

know, was in that drainage until I saw the EPA nofice. I looked it up on the map to see where it was. I thought. Oh, I wonder if that affected Dry Creek? I've got to leam more.

MR. SPALVTNS: Yeah, ihey did look at that. Tliey did look at it, and it did impact dovm the river or downstream a little ways. I don't know exactly hovi' far.

But what happens, there was — at a site like this, you have the nomial kind of trickle of contaminafion that leads to the site.

But then, maybe there's a storm or maybe there's an accident al the site and there's a large release all at once, and that's the kind of thing that has the maximum — the maximum reach downstream.

It's a very limited ~ at this site, at any rate, il was the limited-type events that were high-volume releases into the creek. I think that is where you saw the most extent of impacts. The chronic release or the longlenn releases that were occurring, I think, were more limited.

I don't think that there will be any lasting impact at Dry Creek as a result of this site. Nothing ~ I don't know of anything that you would

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1 MR. PELLEGRINO: Cohee-Bams is another 2 battery cracker that's under the State-funded 3 cleanup program. I believe thafs lhe one that 4 was ~ you referred to ~ 5 MR. SPALVINS: May have been. 6 MS. BROOKS: Is that a public website, OCULUS? 7 MR. PELLEGRINO: Yes, ma'am. Ifyou go onto 8 our DEP website you can access OCULUS through that 9 and it's a public log-in.

10 MS. BROOKS: Okay. 11 MR. SPALVTNS: Ifyou leave your e-mail on the 12 contact list, I can e-mail you something. 13 MS. BROOKS: Okay, yeah. Actually, if s on 14 there. 15 MR. SPALVTNS: Yeah, 1 read through a lot of 16 those documents. I had someone call me with some 17 questions about Dry Creek about six months ago and 18 I looked into someof those documents. So we 19 definitely have some of those. Someof those were 2 0 not studies the EPA conducted. They were studies 21 that were conducted by other govemment agencies. 2 2 1 don't recall exacfiy who. 2 3 MS. BROOKS: My interest is, as a paddler, I 2 4 like to kayak and canoe on Dry Creek and Spring 2 5 Lake. I didn't even realize this plant had ~ you

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be able to see today. Any questions? All right. Well, I think we

will call it ~ this is end ofthe public meefing. MS. SPENCER: Thank you, everybody, for

coming. MR. SPALVINS: Thank you-all.

(Off the record.)

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U.S. Environmental Protection Agency Public Meeting September? , 2011

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REPORTER'S CERTIFICATE

STATE OF FLORIDA COUNTY OF BAY

I, Stephanie R. Zeitvogel, do hereby cenify that I was authorized to and did report the foregoing proceedings, and that the transcript, pages 1 through 46, is a tme and correct record ofthe proceedings lo the best of my ability.

Done and dated this i 9th day of September, 2011, at Bay County, Florida.

STEPHANIE R. ZEITVOGEL



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U.S. Environmental Protection Agency Public Meeting September 7,2011

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TRANSCRIPT - PROPOSED PLAN PUBLIC MEETING FOR THE … · 2 I'm L'Tonya Spencer. I'm the Community...

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Transcript of TRANSCRIPT - PROPOSED PLAN PUBLIC MEETING FOR THE … · 2 I'm L'Tonya Spencer. I'm the Community...