Amended Record of Decision SUlmnary of Remedial Alternative Selection Sapp Battery NPL Site OU2 September 20 II

]]J)lE<CILAJRA'fITON lFOIR 'flHJ:lE AMlENDMlEN'f 'f0 'fIHIlE

lRlE <C 01RlIJ) ((])IF DlE<C1l§1l0 N

This Amendment to the Record of Decision (AROD) is for Operable Unit (OU) 2 (groundwater) ofthe Sapp Battery Superfund Site (the "Site") located in Cottondale, Jackson County, Florida. The U.S. Environmental Protection Agency (EPA) Site Identification Number is FLD980602882.

This decision document presents an amendment to the Selected Remedy for the Sapp Battery Superfund Site, OU2 (groundwater), which was chosen in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, as amended by the Superfund Amendment and R_eauthotization Act of 1986 (SARA), and, to the extent practicable, the National Contingency Plan (NCP). This decision is based on the Administrative Record (AR) for the Site. The State ofFlorida has reviewed the reports which are included in the AR for the Site. The support agency, Florida Department of Environmental Protection (FDEP), has provided input in accordance with 40 Code of Federal Regulations (CFR) Section 300.430 and has actively participated in the decision-making process. FDEP concurs with the overall approach of the remedy. This decision represents the final remedy selected for the Site and following completion of this remedial action, the Site may qualify for Site completion. The Site may, at some point in time, also meet criteria that will allow it to be ready for reuse.

The response action selected in this AROD is necessary to protect the public health or welfare or the environment from actual or threatened releases of(1) hazardous substances to the environment and (2) pollutants or contaminants from this Site, which may present an imminent and substantial endangem1ent to public health or welfare.

lIJ)escrnptnmD qJJf Sellededl Remedly

This document selects Monitored Natural Attenuation (MNA) as the amended Selected Remedy. The data at the Site clearly demonstrate that MNA is working and is consistent with EPA's approach for the selection of an MNA alternative (Black & Veatch Special Projects Corp. [Black & Veatch], 2011). The selection of MNA for OU2 (groundwater) is compatible with the remedies for OU I (solidification/stabilization [SIS] of soil and source material) and OU3 (off-site disposal of impacted wetland sediments). The OU2 remedy will be protective of both human and ecological receptors. The amended remedy is compatible with the planned future use of the property.

Amended Record of Decision Sununal)' of Remedial Alternative Selection Sapp BatteI)' NPL Site OU2 September 2011

The major components of the amended OU2 remedy include:

Q Sample select existing wells for natural attenuation parameters and contaminants of concem (COCs).

It Sample select potable wells for COCs. " Submit Data Summary Reports following select sampling events. e Conduct Five-Year Reviews of the remedy to ensure protectiveness of the remedy. () Implement Institutional Controls (lCs) for the Site including, but not limited to, the

following measures: o Restrict property use for industriaVcommercial uses only. o Restrict groundwater use until cleanup levels are met. o Restrict access to the Sapp property with fences and waming signs. o Restrict intrusive activities on the Sapp property without written approval

from the EPA and FDEP.

Statutory Determinations

The Selected Remedy is protective of human health and the environment, complies with fedenil and state requirements that are applicable or relevant and appropriate to the remedial action, and is cost effective. This remedy utilizes pemlanent solutions to groundwater contamination. The statutory preference for treatment to reduce toxicity, mobility, or volume was satisfied by the OU I (soil and source material) remedial action. This Selected Remedy eliminates human and ecological exposure to contaminated groundwater and protects groundwater resources. The materials that may have constituted a principal threat waste were removed from the Site by the OU I remedial action.

Because the remedy for the Site will result in hazardous substances, pollutants, or contaminants remaining on the Site above levels that will allow for unlimited use and unrestricted exposure, a statutory review will be conducted within five years ofconstruction of the remedy to ensure that the Site remedy remains protective of human health and the environment, inclusive of the applicable ICs.

Data Certification Checklist

The following infoffilation is included in The Decision Summary ofthis AROD. Additional infonnation may be found in the AR file for this Site: .

COCs and their respective concentrations (Section 3.2), o Baseline risk represented by the COCs (Section 3.4), Q Site-specific cleanup levels established for the Site's COCs (Table 2), o How source materials constituting principal threats are addressed (Section 5.1), o Current and reasonably anticipated future land use assumptions and current and

potential future beneficial uses ofgroundwater used in the Baseline Risk Assessment (BRA) and AROD (Section 3.4),

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Amended Record of Decision Summary of Remedial Alternative Selection Sapp Battery NPL Site aD2 September 2011

• Potential land and groundwater use that will be available at the Site as a result ofthe Selected Remedy (Section 3.3),

• Estimated capital, and total present worth costs, discount rate, and the number of years over which the remedy cost estimates are projected (Section 4.0), and

• Key factor(s) that led to selecting the remedy (describe how the Selected Remedy provides the best balance of tradeoffs with respect to the balancing and modifying criteria, highlighting criteria key to the decision) (Section 5).

1#1

Amended Record of Decision Summary of Remedial Alternative Selection Sapp Battery NPL Site OU2 September 20 II·

AMENDED RECORD OlF Jl)EC!SllON

T ABLE OF CONTENTS

1.0 Introduction to the Site and Statement of Purpose : 1 1.1 -Site Description 1

1.2 Statement of Purpose 1 1.3 Administrative Record 2

2.0 Site History, Contamination, and Original Selected Remedy· 3 2.1 Site Background 3 2.2 1986 Record of Decision Selected Remedies : 3 2.3 Enforcement Action 4 2.4 Elements of the Remedy Performed to Date .4

3.0 Basis for Amended Record of Decision 6 3.1 Updated Site Information 6

3.2 Updated Nature and Extent of Groundwater Contamination ;.9 3.2.1 Surficial Aquifer : 10

3.2.2 Intermediate System 10

3.2.3 Floridan Aquifer System 11 3.3 Current and Potential Future Land Use 11

3.4 Sunlmary of Site Risks 12 3.4.1 Human Health Risk Assessment.. ; 12 3.4.2 Ecological Risk Assessment 12

3.5 Remedial Action Objectives : 12 3.6 Cleanup levels 13

4.0 Description of Alternatives 14

4.1 Original Selected Groundwater Remedy from 1986 ROD: Alternative 5: Groundwater Pump and Treat with Ex-situ Treatment and Disposal 14

4.2 2011 Proposed Alternative GW1: No Action 14

4.3 2011 Proposed Alternative GW2: In-Situ Treatment with Monitored Natural Attenuation , 15

4.4 2011 Proposed Alternative GW3: MonitoredNatural Attenuation 16 4.5 Common Elements of Alternatives 16 4.6 Explanation of Change to Remedial Action Objectives 17

4.7 Explanation of Changes in Expected Outcomes 17

5.0 Evaluation of Remedial Alternatives.; ; 18

5.1 Principal Threat Wastes 21

5.2 Description of the Selected Remedy - GW3 Monitored Natural Attenuation22

Amended Record of Decision Summary of Remedial Alternative Selection Sapp Battery NPL Site OU2 September 2011

6.0 Support Agency Comments 23

7.0 Statutory Detemlinations 24 7.1 Protection of Human Health and the Environment. 24

7.2 Compliance with ARARs 24

7.3 Cost Effectiveness 25 7.4 Permanent and Alternative Treatment Solutions 25

7.5 Preference for Treatment as a Principal Element.. 26 7.6 Five-Year Review Requirement.. 26 7.7 Documentation of Significant Changes 26

8.0 Public Participation Compliance 27

9.0 References 28

TABLIES

Table 1 Historical Change in Extent of Groundwater Lead Contamination Table 2 ' Site-Specific Cleanup Levels Table 3 Capital, O&M, and Net Present Value for the 1986 and Amended Selected

Remedy Table 4 Chemical-Specific ARARs TableS Action-Specific ARARs Table 6 Location-Speci fic ARARs

JF[CUlRlES

Figure I Site Location Map Figure 2 Lead Groundwater Plume 1985 and Groundwater Analytical Results 2005-20 II

(Surficial Aquifer)

(lntemlediate System, North)

(lntemlediate System, South)

(Floridan Aquifer)

Figure 3 Lead Groundwater Plume 1985 and Groundwater Analytical Results 2005-20 II

Figure 4 Lead Groundwater Plume 1985 and Groundwater Analytical Results 2005-20 II

Figure 5 Lead Groundwater Plume 1985 and Groundwater Analytical Results 2004-2008

AI?JPlEN1I)]lCIES

Appendix A Responsiveness Summary

11


AR ARAR AROD BRA CERCLA

CFR COC CY E&E EPA FDEP FS ft HHRA HQ IC MCL

1lg!L MNA NaOH

. NAP

NCP NPL O&M au pH PRP RA RAO RD RDl RI ROD SARA Site SREA SIS T/M/V

ACRONYMS AND ABBlREVIAlfIONS

Administrative Record applicable or relevant and appropriate requirement Amended Record of Decision Baseline Risk Assessment Comprehensive Environmental Response, Compensation, and Liability Act Code of Federal Regulations contaminant of concern cubic yards Ecology and Environment, Inc. U.S. Environmental Protection Agency Florida Department of Environmental Protection Feasibility Study feet Human Health Risk Assessment hazard quotient institutional control maximum contaminant level micrograms per liter monitored natural attenuation sodium hydroxide natural attenuation parameter National Contingency Plan National Priorities List operation and maintenance Operable Unit hydrogen ion concentration Potentially Responsible Party Remedial Action Remedial Action Objective Remedial Design Remedial Design Investigation Remedial Investigation Record of Decision Superfund Amendments and Reauthorization Act of 1986 Sapp Battery Superfund Site Superfund Recycling Equity Act solidification/stabilization Toxicity/Mobility/Volume

111

Amended Record of Decision Summary of Remedial Alternative Selection Sapp Battery NPL Site OU2 September 201 1

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Amended Record of Decision Sununary of Remedial Alternative Selection Sapp Battery NPL Site OU2 September 20 II

DECKSION SUMMARY

1.0 Introductuon to the Site and Statement of Purpose

1.1 Site Description

The Sapp Battery Superfund Site (the Site) is located in Cottondale, Jackson County, Florida, approximately five miles south ofCottondale and two miles north ofAlford about 1,000 feet west of the intersection of State Route 231 and County Road 280 (Corbin Road). Figure 1 depicts a map showing the location of the Site. The U.S. Environmental Protection Agency (EPA) is the lead agency for this Site and is supported by the Florida Department of Environmental Protection (FDEP). The Site was placed on the National Priorities List (NPL) in 1982 and the EPA Site Identification Number is FLD980602882.

The Site occupies an area of approximately 45 acres in a rural part of Jackson County, Florida. From the early 1970s to 1980, the Site was a salvage operation which recovered lead from spent automotive batteries. The Site is currently vacant and the nearest residence borders the Site on the west.

1.2 Statement of Purpose

This Amended Record ofDecision (AROD) modifies the groundwater remedy, replacing the original Pump and Treat remedy with Monitored Natural Attenuation. The data at the Site clearly demonstrate that Natural Attenuation is effectively reducing the contaminant concentrations, and the Site satisfies the EPA's three-tiered approach for the selection of a Monitored Natural Attenuation alternative (Black & Veatch Special Projects Corp. [Black & Veatch], 2011).

The EPA signed the original Record of Decision (ROD) on September 26, 1986, and selected multiple remedies to clean up the entire Site (EPA, 1986). Following a site-wide Remedial Design investigation (RDI) in 1988, the Site was divided into three operable units (OUs): OU 1 is the on-facility soil and pond sediment contami"nation; OU2 is the groundwater contamination; and OU3 is the off-facility wetlands sediment and surface water contamination (EPA, 1989). The original groundwater remedy from the 1986 ROD was extraction with ex-situ treatment (pump and treat) (EPA, 1986). The OU 1 and OU3 remedies have been completed and the OU2 remedial action is all that remains to be completed at the Site. The EPA attempted to implement the 1986 groundwater pump and treat remedy. However, after the first field effort, the EPA detern1ined that the pump and treat approach would not work at the Site because the most contaminated parts of the aquifer consisted of low permeability peat, clays and silts (Lockheed Martin, 2005). As new groundwater data became available, the understanding of Site conditions evolved, and new remedial approaches became feasible. In addition, regulatory cleanup levels changed since 1986, which required are-evaluation of the cleanup levels and development ofsite-specific cleanup levels for OU2 (Black & Veatch, 2011). The re-evaluation of the cleanup levels, the

Amended Record of Decision Sunmlary of Remedial Alternative Selection Sapp Battery NPL Site OU2 September 2011

impracticability ofthe 1986 pump and treat remedy, and the recent groundwater data provide the basis for this AROD. . '

This AROD will become part of the Administrative Record file for this Site, in accordance with National Contingency Plan (NCP) §300.825(a)(2). The Administrative Record is available for review at the Jackson County Public Library during the hours of 10:00 am 6:00 pm Monday through Friday and 9:00 am - 2:00 pm on Saturday. The Jackson County Library is located at 2929 Green Street in Marianna, Jackson County, Florida. This is part of the EPA's requirements under §117 of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and §300.435(c)(2)(ii) of the National Contingency Plan (NCP).

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Amended Record of Decisiori Summary of Remedial Alternative Selection Sapp Battery NPL Site OU2 September 20 II

2.0 Site History, COlIltamimntnorrn, and Origill1laB SellectedllRemedy

2J. Site Background

The Sapp Battery Superfund Site is a fonner battery salvage and recycling facility that operated from the early 1970s unti11980. The recycling operations involved cracking open the lead-acid batteries, removing the lead for recycling, and dumping battery acid and plastic battery casings into an on-site holding pond and the surrounding swamps. The battery acid eventually drained into the West Swamp, then into the East and Southeast Swamps, and ultimately drained into Steele City Bay via a culvert under County Road 280. The lead and battery acid released from the cracked batteries caused significant groundwater contamination at the Site. The battery acid created low pH (acidic) conditions, and the acidic groundwater contributed to the release of naturally occurring metals (aluminum, iron, manganese and vanadium) from the aquifer material. The improper disposal of battery casings and battery acid also resulted in contamination of the facility soil and surrounding swamps (Ecology and Environment, Inc. [E&E], 1986).

The acid discharge from the plant started to kill the cypress trees in Steele City Bay and beyond, and in the spring of 1978, residents complained to the State of Florida. The Sapp Battery Company attempted to solve the ongoing contamination, but was unsuccessful. In 1980, after legal action by the State of Florida, the Sapp Battery Company abruptly closed and abandoned the facility (EPA, 1986).

The EPA conducted an emergency removal action in 1980. In August 1982, the EPA placed the Site on the NPL. The State ofFlorida conducted several more interim response actions in 1984 and 1985. The State of Florida prepared a Remedial Investigation (RI) Report and a Feasibility Study (FS) for the Site in 1985. The State documented gross contamination of groundwater at the Site, as shown by the 1985 sampling results where all 13 Floridan wells exceeded 15 Ilg/L (micrograms per liter) (Florida Department ofEnvironmental Regulation [FDER], 1985). The size ofthe lead plume in the Floridan aquifer was estimated to be about 36 acres (Black & Veatch, 2011). Groundwater modeling conducted at the time of the ROD predicted that by the year 2000, lead contamination above 10 Ilg/L would extend 1,000 feet to the east of the facility, and that eventually lead would increase above 100 ~lg/L 1,000 feet to the east of the facility. The groundwater model also calculated that some nearby residential wells could contain over 50 ~lglL lead by 1995 (EPA, 1986).

2.2 1986 Record of Decision alllld 1986 SeDeded Remedies

The EPA finalized a site-wide ROD in September 1986 which addressed all the contaminated media at the Site: soi Is, sediments, surface water and groundwater (EPA, 1986).

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Amended Record of Decision Summary of Remedial Alternative Selection Sapp Battery NPL Site OU2 September 20 II

The remedy as originally described in the 1986 ROD is presented below:

o Excavation of soils and sediments containing contaminant levels above those set in the Risk Assessment.

o . Fixation of the excavated soils/sediments and on-site disposal ofthe solidified matrix into a cell built to Florida Class I Sanitary Landfill Standards.

o Groundwater extraction and treatment of the underlying aquifers (pump and treat). o Treatment and discharge ofcontaminated surface water from the on-site swamp and

the off-site Steele City Bay area. o Institutional controls to be assessed and implemented during the Remedial Design

and Remedial Action phase of the project. o A monitoring program for potable water wells located within a one-mile radius ofthe

Site. o Operation and Maintenance (O&M) activities including: groundwater monitoring and

maintenance of the on-site disposal cell. o A laboratory study will be performed by EPA's Environmental Response Team to

assess the applicability of the soils washing technology at the Site.

2.3 lErrnforcemelJ1lt ActnolJ1l

During the Site investigation, the EPA found documentation of the companies and individuals that were responsible for the Site contamination and pursued them through enforcement actions. The EPA demonstrated that several Responsible Parties had liability for the Site contamination. In 1992, the EPA signed a Consent Decree with a. group of Potentially Responsible Parties (PRPs) to carry out the OU 1 (soil and source area) design and remedial action (EPA, 2007). The PRPs fomled the Sapp Battery Group to conduct the cleanup.

The passage ofthe Superfund Recycling Equity Act of 1999 (SREA) provided an exemption from liability for the PRPs that made up the Sapp Battery Group. As a result, the Sapp

.Battery Group completed the OU I cleanup and the EPA is implementing the cleanups of OU2 and OU3.

2A lEllemelJ1lt§ of tllne IRemedy Performed to Date

The Remedial Actions at the Site were prioritized, with OU I (soils and source area) conducted first, OU3 (wetlands) second and OU2 (groundwater) last. The Responsible Parties completed the cleanup ofOUI in 2001. The EPA completed the cleanup ofOU3 in 2005. The EPA began a renewed OU2 investigation in 2004 and the EPA will perfoml the OU2 cleanup.

OUI (Soils and Source Area) Remedial Action

From 1992 to 1999, the Sapp Battery Group and the EPA conducted additional investigations and prepared the design for the OU I remedy. The Sapp Battery Group conducted the OU I

4


(soil) Remedial Action from 1999 through 2001. The au 1 soil remedy addressed source material by treatment. Contaminated soils were mixed with water, MAECTlTE@ (a patented chemical treatment process for lead and other heavy metals), and Portland cement. The treated material was tested to confirm the unconfined compressive strength, permeability, and leachability. A total of 93,944 cubic yards of material were excavated, solidified, stabilized and pfaced on-site in a monolith about 13 acres in area (TriAD, 2001). The Sapp Battery Group will continue to monitor the effectiveness ofthe soil remedy and will maintain the on-site disposal area.

au] (Wetlands) Remedial Action

The EPA conducted the aU3 cleanup. The design for aU3 began in July 2003 and was completed in March 2005. The EPA collected surface water and sediment samples to refine the nature and extent of sediment contamination as part of the design. The cleanup for aU3 started in 2007 and was compfeted in September 2008. Approximately 58,347 tons of contaminated soil and sediment from the swamps at the Site were excavated and transported off-site for disposal.

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Amended Record of Decision Sununary of Remedial Alternative Selection Sapp Battery NPL Site OU2 September 2011

3.0

This section summarizes the infonnation that prompted and supports fundamentally changing the remedy selected in the ROD. The EPA has detemlined that the extraction remedy from the 1986 ROD is inappropriate at the Site because the contaminated portions of the aquifer consisted of low pemleability peat, clays and silts that prevent effective extraction and/or injection. Groundwater data since 1986 has documented changing site conditions and a better understanding of the Site has evolved. The current nature and extent of groundwater contamination is vastly different than in 1986. Based on new data and understanding of the groundwater conditions, new remedial approaches have been evaluated and the Site meets, EPA guidance for an MNA remedy. Furthemlore, new regulatory cleanup target levels and action levels have changed since 1986. For these reasons, the EPA is pursuing a fundamental change to the groundwater remedy selected in the 1986 ROD. The Selected Remedy identified in this AROD is necessary to protect human health from actual or threatened releases of hazardous substances into the environment.

3.] Upd!ated! SUe liH1llformatnmll

3.1.1 OllJ2 (Groundwatell") nnvestigation

The investigation and characterization ofgroundwater at the Site has taken place over many years. Impacts to the groundwater probably began in the mid 1970s, when the Sapp Battery Company was dumping battery acid from lead acid batteries into an unlined pond. This dumping stopped in 1980, when the Company abruptly closed and abandoned the facility (EPA,1986).

The removal of source material contributing to groundwater contamination began in 1980 with the EPA emergency removal action. By 1983, a large groundwater monitoring network was in place. Groundwater data from 1983 and 1985 helped fonn the basis for the 1986 ROD. More source material was removed by the State of Florida during other interim response actions in 1984 and 1985. A supplemental groundwater investigation was perfomled in 1988 (EPA, 1989). The focus ofthe site cleanup efforts from 1988 to 2004 was on addressing source material, soil and wetland sediments. The Sapp Battery Group conducted a limited 'monitoring program of four wells around the OUI monolith, which showed improving groundwater conditions after the OU 1 cleanup.

In 2004, the EPA began a series of investigations to address the remaining groundwater contamination. The EPA's initial approach was to implement the pump and treat remedy from the 1986 ROD. After the first field effort, the EPA determined that the pump and treat approach would not work at the Site because the most contaminated parts of the aquifer consisted of low penneability peat, clays and silts (Lockheed Martin, 2005). As new groundwater data became available, the understanding of site conditions evolved, and the EPA began to reconsider its approach and develop and evaluate new remedial approaches.

6


A detailed account of the EPA's investigations since 2004 can be found in the Administrative Record in the Remedial Design Investigation Report from March 2009 and the aU2 Remedial Design Status Summmy Technical Memorandum, dated July 20 II. The current understanding of the Site is summarized in this AROD. The EPA's investigations included groundwater sampling events, treatability studies and field work during the following dates:

December 2004 February 2009 January 2005 September 2009 July 2006 October 2009 August 2006 September 20 I0 April 2008 February 20 II May 2008 April 2011

Analysis of the data accumulated from 2004 to 2009 led EPA to focus on well sampling and redevelopment. The EPA found that turbid samples were causing contaminant levels to appear higher than they actually were. The EPA decided to postpone completion of the design effort in 2009 and collect more groundwater data. Select monitoring wells were sampled in 20 I0 and 20 II using the micro-purge sampling technique in order to reduce sample turbidity and collect more representative groundwater samples.

The improved sampling techniques provided a more clear understanding of groundwater contamination. The July 2011 aU2 Remedial Design Status Summary Technical Memorandum presents a detailed discussion ofthe groundwater data, an updated Conceptual Site Model, and an analysis of Monitored Natural Attenuation (MNA) as a remedial option (Black & Veatch).

3.1.2 OU2 (Groundwater) MNA Evaluation

The EPA has developed guidelines for when MNA can be used as part of a groundwater remedy. The process for selecting MNA is outlined in EPA guidance titled .. Use of Monitored Natural Attenuation at Supelfund, Resource Conservation and RecovelY Act (RCRA) Corrective Action. and Underground Storage Tank Sites," dated April 21 , 1999. The guidance lays out a three-tiered approach to evaluate the potential efficacy of MNA as a remedial alternative. These three tiers ofsite-specific inforn1ation, or "lines ofevidence," are:

( I) Historical data that demonstrate a clear and meaningful trend ofdecreasing contaminant mass and/or concentration over time.

(2) Hydrogeologic and geochemical data to demonstrate indirectly the MNA processes that are aCtive at the Site, and the rate at which such processes will reduce contaminant concentrations to required levels.

(3) Data from field or microcosm studies (conducted in or with actual contaminated site media) which directly demonstrate the occurrence of a particular natural attenuation process at the site and its ability to degrade the contaminants ofconcern (typically used to demonstrate biological degradation processes only).

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Amended Record of Decision Summary of Remedial Alternative Selection Sapp Battery NPL Site OU2 September 20 I I

The guidance also states that MNA will be most appropriate when used in conjunction with or as a follow-up to other remediation measures such as source control or active remediation measures. The guidance further states; "Therefore, sites where the contaminant plumes are no longer increasing in extent, or are shrinking, would be the most appropriate candidates for MNA remedies".

The July 2011 OU2 Remedial Design Status Summary Technical Memorandum contains the detailed evaluation ofMNA as a potential component ofthe groundwater remedy. The Memo concludes that the data satisfies the line of evidence approach and that MNA is a viable remedial alternative for this Site because:

o Historical data shows decreasing trends of contaminants iil the groundwater o Source control actions have been completed for au I and aU3 o The geochemical processes responsible for the attenuation are understood and will

continue

Historical data collected since 1986 clearly show decreasing trends of contaminants in the groundwater. Table 1 summarizes the changes from 1986 to present in the nature and extent ofgroundwater contamination for lead, the most toxic contaminant at the Site. Table 1 shows that the highest lead levels in the 1980s were 3,600 to 6,200 JlglL, with dozens of wells impacted in all three aquifers studied. At present, the highest lead concentration is 18 Jlg/L, with only two Internlediate system wells impacted (EW090 and EW 150). During the initial site investigations, the estimated extent of the 1985 lead plume in the Floridan aquifer covered 36 acres. The groundwater data shows a clear and meaningful trend of decreasing concentrations over time and is of"sufficient quality and duration" to satisfy the first line of evidence to support using MNA.

Source control measures taken from 1980 to 2008 successfully removed and/or treated more than 103,000 CY ofcontaminated soil and debris and treated more than 2,000,000 gallons of contaminated water. As a result, substantial quantities of lead, acid and contaminated media have been removed or treated from the Site that would have been a source of continual contamination of groundwater (Black & Veatch, 2011 ).

Precipitation and complexation reactions are the geochemical processes mostly responsible for the attenuation ofgroundwater contamination. The effectiveness and speed ofattenuation by these mechanisms is dependent on soiVaquifer characteristics and geochemical conditions, especially pH. The source removal actions dramatically enhanced site conditions by eliminating both battery acid and heavy metal contamination. This resulted in significant pH improvements in the soil that are expected to continue over time. In tum, the pH improvements will facilitate the attenuation mechanisms that will reduce the concentrations· of contaminants in the groundwater.

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Amended Record of Decision SUnmlal)' of Remedial Alternative Selection Sapp BatteI)' NPL Site OU2 September 2011

The nature and extent ofgroundwater contamination has changed significantly since the 1986 ROD, due to source control measures taken during the OU 1 and OU3 remedial actions and the process of natural attenuation. The current nature and extent of groundwater contamination makes other remedial alternatives more acceptable than the original pump and treat option.

The nature and extent of groundwater contamination known at the time of the 1986 ROD was based on data collected in 1983 and 1985. The 1986 ROD noted the widespread contamination of the surficial aquifer, with the worst contamination near the former holding pond and the Northwest Landfill. Contamination in the intermediate system and the Floridan aquifer was also highest between the former plant foundation and the West Swamp.. The 1986 ROD noted that lead concentrations in the Floridan aquifer were increasing on the Site. Also, the 1986 ROD noted that five rounds of sampling of nearby residential wells showed increasing lead levels, though no samples exceeded the federal drinking water standard for lead, which was 50 micrograms per liter (~g/L) in 1986 (EPA, 1986).

'fabBe 1: Hustorneal Changes urn !Externt of Groundwater .lead Contamurnation

§mrfncftall Aq[UlftJfer

Max Concentration of Lead

Area of Lead> 15ug/L

1983/1985 6,270 ~g/L at historic well MW9C 18 Acres

20U Below laboratory detection limit oMonitoring Wells oAcres

llnntermedlnate §y§tem



4,300 ~lg/L at historic well MW03B 21 Acres

18 ~g/L at EW09D 17 J,lg/Lat EWI5D 2 Monitoring Wells oAcres

lFllorndlann Aq[Ulnfer



3,680 ~g/L at historic DW2

13 Wells (all Floridan wells) 36 Acres

Below laboratory detection limit oMonitoring Wells oAcres

The 1986 ROD established cleanup levels for six COCs in groundwater; aluminum, arsenic, cadmium, lead, manganese, and nickel (EPA, 1986). The groundwater analytical data collected since 2004 indicate that there are now five COCs in the groundwater; aluminum, iron, lead, manganese, and vanadium (Black & Veatch, 20 II). Figures 2 through 5 show the pre-ROD 1985 lead plume extent so that a comparison can be shown between historical and current site concentrations and extent. The lead plume on these maps, in pink, encompasses

9

----------------------------------------------------,


the concentrations greater than the EPA action level and Florida Primary Drinking Water Standard for lead of 15 Ilg/L.

The EPA considers lead to be the primary remaining site-related contaminant. The current levels of aluminum, iron, manganese, and vanadium are due to the dissolution of naturally occurring elements in the aquifer due to locally persistent low pH (acidic) conditions. The elevated metals concentrations and low pH levels occur in areas with especially low pemleabi1ity, resulting in a slower rate of attenuation than in more pernleable parts of the aquifer.

3.2.1 .Surficial Aquifer

Large parts of the surficial aquifer were excavated during the OU 1 RA. Historic levels of surficial aquifer lead contamination were as high as 5,700 Ilg/L in 1983 at historic well MW 14C, and as high as 6,270 ~lg/L in 1985 at historic well MW9C (Table 1).The estimated surficial lead plume above the action level of 15 Ilg/L encompassed approximately 18 acres in 1985, as shown in Figure 2. As of 20 10, there are no exceedances oflead in the surficial aquifer (Black & Veatch, 2011).

The current nature and extent ofcontamination in the surficial aquifer is summarized below:

o Iron is the only contaminant currently detected above the site-specific cleanup level. o As of 20 10, there are no exceedances of lead in the surficial aquifer. o The historic levels ofCOCs in the surficial aquifer have decreased greatly over time.

3.2.2 Rntermedliate System

Historic well MW03B contained the highest lead concentrations detected in the intermediate system during 1983 and 1985 at 4,300 ~lg/L and 4,280 ~lg/L. respectively (Table 1). The estimated internlediate system lead plume above the action level of 15 ~lg/L encompassed approximately 21 acres in 1985, as shown in pink in Figures 3 and 4. Lead contamination has decreased dramatically over time. As of February 2011, only two wells of the nine lnternlediate system wells sampled exceeded the cleanup level for lead of 15 Ilg/L: EW09D at 18 ~lg/L and EW 150 at 17 ~lg/L. Other contaminant concentrations have also decreased as the pH has moderated to more neutral levels. The relationship between turbidity and contaminant concentrations tends to obscure the long ternl decreasing trend (high turbidity artificially raises the apparent contaminant concentration). Data since 2009 have been collected using a micro-purging sample method, with an extra focus on collecting low turbidity samples (Black & Veatch, 2011).

The current nature and extent of contamination in the intermediate system is summarized below:

o The remaining contamination in the intermediate system is mainly associated with wells located in the fornler West Swamp and screened in low penneability peat, clay and silts, which are much slower to attenuate than other wells screened in sand.

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Amended Record of Decision Sunmlary of Remedial Alternative Selection Sapp Battery NPL Site OU2 September 20 II

'" Five contaminants currently exceed the site-specific cleanup levels: aluminum, iron, lead, manganese and vanadium.

o Low pH groundwater is present in some areas with pH ranging from 3.81 to 5.5, an improvement from the time of the 1986 ROD.

e There is a direct correlation between the. low pH values and high metals concentrations in the intermediate system. The historic levels of COCs in the intemlediate system cited in the 1986 ROD have decreased over time.

o The estimated lead plume above the cleanup level of IS !lglL encompassed approximately 21 acres in 1985, as shown in pink in Figures 3 and 4.

G In 20 II, only two wells exceed the cleanup level for lead of 15 !lg/L: EW090 at 18 !lg/L and EW 150 ~t 17 !lg/L.

3.2.3 Floridan Aquifer System

The highest lead concentration detected in the Floridan aquifer in 1985 was at the historic potable well DW2, with a concentration of3,680 !lg/L (Table 1). Potable well OW2 was a'2inch diameter well that supplied the former Sapp residence on the facility. During the 1985 sampling event, all 13 Floridan wells sampled on-site exceeded the cleanup level of IS !lglL. The estimated size of the Floridan aquifer lead plume in 1985 was 36 acres, as shown in pink in Figure 5. At present, lead contamination in the Floridan aquifer has decreased to below laboratory det.ection limits. Manganese and iron are above site-specific cleanup levels only in EW8L, which is partially screened in the Floridan aquifer and partially screened in the intermediate system (Black & Veatch, 20 II).

The nature and extent ofcontamination in the Floridan aquifer at the Site are summarized as follows: .

o Manganese and iron are above site-specific cleanup levels in one monitoring well. o The pH values in the Floridan aquifer are within a normal range ·of 6.46 to 7.71. o The historic levels of contamination in the Floridan aquifer have dramatically

decreased over time to below cleanup levels in all but one well (EW8L), which is only partially screened in the Floridan aquifer.

o There is no lead contamination above the cleanup level of IS !lg/L in the Floridan aquifer.

3.3 Current and Potential FutUlre Landi Use

The Site is not currently in use. The future land use of the Site is expected to remain nonresidential. The Site is located in a groundwater delineated area, and the State potable water permitting authorities will not allow the potable use of the groundwater. Institutional Controls will be sought to place a restrictive covenant on land and groundwater use.

II


3.41.1 lHIuman lHIeaRth Risk Assessment

A Human Heath Risk Assessment (HHRA) w~s completed in 1987 (E&E, 1987). The HHRA concluded that people could be at risk if they consumed contaminated groundwater from the Site. The HHRA addressed soil and sediment as well, which were addressed by au 1 (soil) and OU3 (sediments) remedial actions. At the time of the 1986 ROD, lead and cadmium in groundwater were detected above the EPA MCLs, which is the maximum level of a contaminant pennitted in drinking water supplied by a public system. Contaminants greater than the MCL are considered potentially hannful to public health, while less than the MCL . are considered protective of public health.

Since contaminants in the surficial, intennediate, and Floridan aquifer systems exceeded their MCLs, the Risk Assessment concluded that potential consumption of the groundwater exceeded the EPA's acceptable risk range for Superfund sites.

3.41.2 lEcological Risk Assessment

The ecological risk assessment detennined that there is the potential for adverse effects to birds, benthic macro invertebrates, and cypress tree regeneration from the surface waterand sediment contamination in OU3. Additional infonnation on ecological risk associated with OU3 can be found in the Ecological Risk Assessment Risk Characterization Memorandum (Arcadis, 2000). The OU3 remedy consisted ofexcavation, solidification/stabilization (SIS) ofcontaminated soil and sediment, and off-site disposal. These efforts etfectively eliminated the ecological risks.

3.5 RemediJiall ActJimu OlbjectJives

The 1986 ROD did not clearly document Remedial Action Objectives (RAOs) for groundwater. This ROD Amendment provides two groundwater RAOs, which address risks associated with groundwater and were used to develop remedial alternatives and cleanup levels. Remedial Action Objectives are the desired outcome of a cleanup action. The following RAOs have been selected in order to protect human health and the environment:

o Prevent human ingestion, dernlal contact and inhalation ofgroundwater contaminated with COCs above health based cleanup levels that are protective of beneficial use (i.e., drinking water use).

o Restore contaminated groundwater to levels that allow beneficial use (i.e., drinking water use).

12


3.6 Cleanup Levels

The cleanup levels in the 1986 ROD do not reflect the current site risks, or RAOs. The EPA is proposing to revise the cleanup levels based on the following factors:

o The lead cleanup level is based on a State chemical-specific ARAR. This is the same level as the EPA action level for lead, which has been reduced to 15 ~lg/L since 1986. The lead cleanup level in the 1986 ROD was 50l!g/L.

o Iron and vanadium are detected at levels that pose an unacceptable risk but they were not included in the 1986 ROD as COCs. Cleanup levels for both have been added.

(II The vanadium cleanup level is based on a State chemical-specific ARAR. o Cleanup levels for aluminum, iron, and manganese are based on risk-based site

specific calculations since there are no federal health-based standards and there are no ARARs for these three compounds.

o Arsenic, cadmium, and nickel have not been detected above MCLs, GCTLs, or 1986 cleanup levels since source removal actions were conducted therefore; they have been eliminated as COCs.

The revised OU2 groundwater site-specific cleanup levels are listed in Table 2.

Table 2: Site-Specific Cleanup Levels

I I.

Contaminant of Concern

Cleanup Level (J12/L

1 )

Source

Aluminum 15,600 Site Specific Risk Number based on Hazard Quotient (HQ) of 1. Child resident exposure assumptions.

Iron 11,000 Site Specific Risk Number based on HQ of 1. Child resident exposure assumptions.

Lead 15 Florida Administrative Code, 62-550.310, Table 1 Primary Drinking Water Standards (also EPA Action.Level)

Manganese ..

400 Site Specific Risk Number based on HQ of I. Child resident exposure assumptions.

Vanadium 49 Florida Administrative Code, 62-777.170, Table 1 Primary Drinking Water Standards

I ~1g!L is micrograms per liter or parts per billion.

13

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The July 2011 aU2 Remedial Design Status Summary Technical Memorandum contains an analysis ofadditional remedial alternatives based on the recent data (Black & Veatch). Those alternatives are described below. The remedy selected for groundwater in the 1986 ROD, is also included for comparison to the alternatives presented in the August 2011 Proposed Plan.

4Lli Original Selected GJrOundwater Remedy from 1986 ROll): Altemative 5: Groundwater Pump and Treat with Ex-situ Treatment and ll)isposal

Estimated Capital Cost: $4,366,600 Estimated O&M Cost: $5,299,600 Estimated Periodic Cost: $0 Estimated Present fVorth Cost: $9,666,200

The 1986 ROD original remedy consisted of extraction and treatment of groundwater and surfac~ water by chemical precipitation on a continuous-flow basis. The inorganic compounds were to be precipitated by the addition of chemicals to the treatment water. Treated water would be either injected into the Floridan aquifer or into an off-site surface water body. Thirty (30) years ofO&M of the water treatment system and the disposal cells were assumed. Private wells within a one-mile radius of the Site would be monitored.

Alternative 5 Remedy Components Activities associated with this remedy included (but were not limited to) the following:

1. Twenty-nine (29) 2-inch diameter wells with depths of 10 to 20 feet (ft) would be used for the surficial aquifer recovery system.

2. Seven (7) exis"ting 4-inch diameter monitoring wells would be used for the Floridan aquifer recovery system and one (I) 250-ft deep well would be installed to recover deep contamination.

3. Extensive pilot studies and bench-scale testing of the effectiveness of chemical fixation would be required prior to implementation to determine the optimum fornmlation which would prevent the contaminants from leaching.

. 4. Long-term perfonnance monitoring.

41.2 20U Proposed AUemative GWI: No Action

Estimated Capital Cost: $32,700 Estimated O&M Cost: $0 Estimated Periodic Cost: $18.900 Estimated Present Worth Cost: $51,600

The No Action alternative does not involve any remedial actions, and the source would remain in its present condition. Under this alternative, no funds are expended for control or

14

Amended Record of Decision SummaI)' of Remedial Alternative Selection Sapp BatteI)' NPL Site OU2 . September 20 II

remediation of contaminated groundwater. Costs associated with the No Action alternative are for abandoning existing monitoring wells.

41.3 2GB Proposed! AJternative GW2: In-Situ Treatment with Monitored Natural Attenuation

Estimated Capital Cost: $449.500 Estimated O&M Cost: $420.600 Estimated Periodic Cost: $18,900 Estimated Present Worth Cost: $889,000

Alternative GW2 consists of injecting a pH buffering reagent, such as sodium hydroxide (NaOH) (or equivalent) to raise the pH while reducing metals concentrations via precipitation. As pH increases, dissolved metals become insoluble and precipitate. In this fonn, they pose no hann to human health or the environment. This alternative consists ofthe installation of injection wells to forn1 a subsurface treatment zone over the lead concentration plume above the cleanup level of 15 Ilg/L. Wells will be installed with screened intervals to target the intennediate aquifer system. Due to the complexity of the lithology in the intermediate system, multiple screened intervals are anticipated within each if the intermediate injection wells

Alternative GW2 includes groundwater sampling for delineation, water level monitoring, and perfonnance-effectiveness monitoring. Scheduled groundwater sampling and perfonnance monitoring of the OU2 remedy, as well as other periodic O&M activities, will be perfoffi1ed as necessary. Five-year reviews would be perfonned until natural attenuation processes reach RAOs.

This alternative would include ICs and Site security measures to limit potential exposure to contaminants.

GW2 Remedy Components Activities associated with this remedy include (but may not be limited to) the following:

1. Installation of a temporary feed system for the pH buffering reagent (i.e., NaOH). 2. Installation of injection wells to treat the intennediate aquifer system (60 ft below

land surface for cost estimating purposes). 3. Injecting reagent 4. Real-time perfoffi1ance monitoring of injection. 5. Long-tenn peifoffimnce monitoring. 6. Reinjection as needed to address "hot-spots". 7. Groundwater sampling for natural attenuation parameters and Site COCs. 8. Restoration of surface features. 9. ICs to limit potential exposure to contaminants. 10. Five-Year Reviews of the remedy to ensure protectiveness of the remedy.

15

Amended Record of Decision Sununary of Remedial Alternative Selection Sapp Battery NPL Site OU2 September 2011

4L4! 20U lPll"olPosed Altemative GW3: Monitored Natull"an Attenuation

Estimated Capital Cost: $37,900 Estimated O&M Cost: . $262.800 Estimated Periodic Cost: $18,900 Estimated Present Worth Cost: $319.600

This alternative will utilize natural physical, chemical, and biological processes (i.e., natural attenuation) to restore groundwater to beneficial use. The data at this Site clearly demonstrate that MNA is working. The EPA conducted an MNA evaluation in July 2011 documenting that:

o Historical data shows decreasing trends of contaminants in the groundwater o Source control actions have been completed for OU I and OU3 o The geochemical processes responsible for the attenuation are understood and will

continue

The Site satisfies the EPA's three-tiered approach for the selection of an MNA remedy. IyiNA would achieve remedial objectives in a reasonable time frame compared to other options. .

Alternative GW3 consists of groundwater sampling, water level monitoring, and perfornlance and effectiveness monitoring. The assumptions for cost estimating purposes were annual monitoring for three years, and then every two years for twelve years. The exact MNA sampling plan will be developed by the EPA in consultation with the FDEP during the remedial design process. Five-year reviews would be performed until natural attenuation processes reach RAOs. This alternative would include lCs and Site security measures to limit potential exposure to contaminants.

GW3 Remedy Components Activities associated with this remedy include (but may not be limited to) the following:

1. Groundwater sampling for natural attenuation parameters and COCs. 2. Progress reporting and data analyses. 3. lCs to limit potential exposure to contaminants. 4. Five-Year Reviews of the remedy to ensure protectiveness of the remedy.

41.5· Common lEllement§ of Alltelt"natnves

Both GW2 and GW3 alternatives include Five Year Reviews, an Institutional Control plan, and a restrictive covenant to prohibit drilling drinking water wells on-site and to prohibit residential use of the Site.

16

Amended Record of Decision Summary ofRemedial Alternative Selection Sapp Battery NPL Site OU2 September 20 I I

4.l6 lEXlPllall1latftOII1l of Cll1annge to lRemediftall ActftOHll Olbjedftve§

The 1986 ROD did not clearly document Remedial Action Objectives. This ROD Amendment adds two Remedial Action Objectives, which address site risks and were used to develop the cleanup levels.

4.7 ExpBann.atioull of Changes inn. Expected Oantcomes

The original Groundwater remedy is no longer feasible or implementable based on the low pem1eability conditions at the Site. Recent data indicate that contaminant concentrations are decreasing due to natural processes (e.g., biodegradation, dilution, adsorption, dispersion),

. and the Site satisfies the EPA's three-tiered approach for the selection of an MNA remedy. As a result, the EPA is selecting MNA as the amended Selected Remedy.

The amended remedy will still be protective in the short and long term, will be more costeffective and implementable, and will equally comply with ARARs.

17


5.0 lEvallu.natnmn of lRemedlnall AllterU1l.atnves

The remedial alternatives have been examined with respect to the evaluation requirements in the NCP, CERCLA, and the factors described in Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA (EPA, 1988). For completeness, the original remedy from the 1986 ROD is also included. The nine evaluation criteria are:

Threshold Criteria o Overall protection of human health and the environment; and, o Compliance with ARARs.

Balancing Criteria o Short-tern1 effectiveness; o Long-term effectiveness and permanence; o . Reduction of mobility, toxicity, or volume through treatment; o Implementability; and, o Cost.

Modifying Criteria o State acceptance; and o . Community acceptance.

The comparative analysis compares ano contrasts alternatives with respect to the evaluation criterion. The comparative analysis focuses on the key differences between the alternatives and attempts to highlight critical issues ofconcern. The primary objectives for the preferred remedial action are satisfying the threshold criteria: to protect human health and the environment and to comply with ARARs. For an alternative to be considered for selection, these two threshold criteria must be met. The "No Further Action" Alternative, Proposed Alternative GW I: No Action, is removed from further analysis because it does not meet the two threshold criteria; however, it is included in the summary table for comparison.

I. Overall Protection of Human Health and the Environment

Alternatives GW2 (In-Situ Treatment with MNA) and GW3 (MNA) both are protective of human health and the environment and would meet cleanup levels. Alternatives GW2 and GW3 both rely on Institutional Controls to restrict groundwater use until cleanup levels are

. reached. The 1986 Remedy might also attain cleanup levels, but given the information obtained to date, there is a significant level of uncertainty that this remedy will achieve cleanup levels in a reasonable time frame. In addition, the 1986 does not have any provision for Institutional Controls to restrict groundwater use and prevent current exposure.

2. Compliance with ARARs

This evaluation criterion is used to determine whether an alternative meets federal and state ARARs. This criterion must be satisfied for an alternative to be considered in the selection

18 .


process. Applicable requirements are those cleanup standards, standards ofcontrol, and substantive environmental protection requirements promulgated under federal or state law that specifically address the Site. Relevant and appropriate requirements are those federal and state regulatory requirements that, while not "applicable", address problems or situations sufficiently similar to those encountered at the Site and are appropriate to the circumstances of release or threatened release. Cleanup levels are numerical values that represent chemicalspecifie ARARS. Alternatives GW2 and QW3 both comply with ARARs. The 1986 Remedy would not meet current ARARs.

3. Long-Term Effectiveness and Pemlanence

This criterion addresses the long-term effectiveness and permanence the alternatives afford, along with the degree of certainty that an alternative will prove successful. Factors to be considered include: 1) the effectiveness ofan alternative in terms of residual risk remaining at the Site after response objectives have been completed and 2) the reliability and maintenance of controls that are used to manage the risk posed by treatment residuals and untreated media. The evaluation assesses residual constituents that may remain in the groundwater after the remedial action has been completed.

The 1986 Remedy and Alternatives GW2 and GW3 provide long-term effectiveness. The 1986 Remedy has implementation issues and would not be as effective in the long term.

4. Reduction of Toxicity, Mobility, and Volume through Treatment

This criterion addresses the degree to which alternatives permanently and significantly reduce mobility, toxicity, or volume of COCs in media exceeding clean up goals. This cri terion considers: I) the treatment process used; 2) the amount of impacted media treated; 3) the degree of expected reduction in mobility, toxicity, or volume; 4) the degree to which treatment is pernlanent; and 5) the type and quantity of residuals remaining after treatment, both in the groundwater matrix and from any treatment process.

The source control measures from the OUI soil remedial action provided significant reduction ofT/MIV through treatment. Since that time, natural attenuation processes have contiriued the reduction of T/M/V by several orders of magnitude. Alternatives GW2 and GW3 would continue to reduce mobility through natural attenuation processes. The 1986 Remedy would remove contamination from the aquifer, but because ofthe low permeability, the effectiveness would be limited to areas with high permeability or that are immediately adjacent to the wells.

5. Short-Ternl Effectiveness

This criterion addresses the effects of each alternative during the implementation and construction phases until RAOs are achieved (for example clean-up levels are achieved). Alternatives are evaluated under this criterion based on their effects on human health, welfare, and the environment during initial phases of the remedial project. The evaluation considers I) the protection of the community during remedial actions, 2) the protection of

19

Amended Record of Decision Sunmlary of Remedial Alternative Selection Sapp Battery NPL Site OU2 September 20 II

workers during remedial actions, 3) the environmental impacts ofconstruction and operation, and 4) the time until remedial response objectives are achieved.

Implementation of Alternative GW2 and the 1986 Remedy would require construction and operation of remedial systems. Alternative GW2 would involve the handling of caustic chemicals during injections. For the 1986 Remedy groundwater would be brought to the surface for treatment, providing a potential route of exposure. Both Alternative GW2 and the 1986 Remedy involve the installation ofmany wells, which could lead to typical construction site health and safety hazards. Alternative GW3 has the least potential for impacts during implementation and construction. Monitoring wells are already in place, so there is minimal construction activities associated with this alternative.

The short-term impacts to the community are anticipated to be low for Alternative GW2 and the 1986 Remedy and lower for Alternative GW3. Short-term ihlpacts to workers are expected to be low for Alternative GW3 and higher for Alternative GW2 and the 1986 Remedy due to the potential for contact with contaminated groundwater.

6. Implementability

This criterion addresses whether or not there are technical problems or administrative issues associated with an alternative that would halt or delay the remediation. This includes analyzing the availability of various services and materials required during its implementation. This criterion considers I) the ability to construct and operate the technology; 2) the reliability of the technology; 3) the ease of undertaking future remedial actions; 4) the duration of monitoring required; 5) the coordination with otheragencies; 6) the availability of treatment, storage capacity, and disposal services; and 7) the availability of necessary equipment, specialists, and materials.

The 1986 Remedy is the least implementable alternative due to the low permeability in the aquifer. The low permeability is also the main barrier to the implementability of Alternative GW2. Alternative GW3 is the most implementable alternative. The equipment and services are proven, reliable, and readily available. There are no on-site or off-site impediments for any alternatives. Monitoring activities are currently on-going, therefore it is expected that this element will not prove difficult to implement.

7. Cost

This criterion addresses the cost for each alternative. Costs evaluated include capital, O&M, and present worth. The estimated net present worth of Alternative GW3 is the least of the three alternatives that meet the threshold criteria. Alternative GW2 is more than twice expensive than GW3. The 1986 remedy is about 30 times more expensive than GW3. The capital, O&M, and present worth costs for the alternatives considered are provided in Table 3.

20

Amended Record of Decision Sunm1ary of Remedial Alternative Selection Sapp Battery NPL Site OU2 September 2011

TabRe 3: Capital, O&M, and Net Present Value for the 1986 and Amended Selected !Remedy

Alternative Capital Costs O&M Present

Worth Present Worth

1986 ROD Alternative 5: Groundwater

Pump and Treat $4,366,600 $5,299,600 $9,666,200

GW2: In-Situ Treatment with Monitored Natural

Attenuation $449,500 $420,600 $889,000 .

GW3: Monitored Natural Attenuation

$37,900 $262,800 $319,600

5.1 lPr!ncilPal Threat Wa§h~§ .

The NCP establishes an expectation that EPA will address the principal threats posed by a site through treatment wherever practicable (NCP §300.430(a)(I)(iii)(A)). Identifying principal threat waste combines concepts ofboth hazard and risk. In general, principal threat wastes are those source materials considered to be highly toxic or highly mobile, which generally c3:nnot be contained in a reliable manner or would present a significant risk to human health or the environment should exposure occur. The materials that may have constituted a principal threat waste were removed from the Site by the OU 1 remedial action. Contaminated groundwater generally is not considered to be a source material and there is no current evidence ofNon-Aqueous Phase Liquids (NAPLs). Therefore, principal threat waste is not present in OU 2.

21

Amended Record of Decision SummaI)' of Remedial Alternative Selection Sapp BatteI)' NPL Site OU2 September 20 II

5.2 ])e§~IrfiptfiOlJll of tlllle SeHectedi Remedy - GW3 MOIJ1lfitoIredi N ahuan A UenJIu.natfionJI

The amended Selected Remedy is Alternative GW3, Monitored Natural Attenuation. Alternative GW3 meets the threshold criteria and provides the best balance oftradeoffs with respect to the balancing and modifying criteria. The data at this Site clearly demonstrate that MNA is working, and satisfies EPA's approach for the selection of an MNA remedy. Aggressive'treatment is not feasible due to the hydrology at the Site and would result in marginal improvement in the timeframe at a significant additional cost.

Activities associated with the Selected Remedy will include monitoring progress ofMNA on a regular basis unti I cleanup levels are met. The exact MNA sampling plan will be developed by the EPA in consultation with the FDEP during the remedial design process. Potable wells within a one-mile radius of the Site will be monitored at a minimum ofonce prior to the first five-year review; additional sampling of the potable wells will be evaluated as part of the first five-year review. The major components for the amended remedy include:

o Sample select existing wells for natural attenuation parameters and contaminants of concern (COCs).

o Sample select potable wells for COCs. o Submit Data Summary Reports following select sampling events. o Conduct Five-Year Reviews of the remedy to ensure protectiveness of the remedy. o Implement Institutional Controls (lCs) for the Site including, but not limited to, the

following measures: o Restrict property use for industrial/commercial uses only. o Restrict groundwater use until cleanup levels are met. o Restrict access to the Sapp property with fences and warning signs. o Restrict intrusive activities on the Sapp property without written approval

from the EPA and FDEP.

Alternative GW3, MNA, will be protective of human health and environment, will comply with federal and state requirements that are applicable or relevant and appropriate, and is the most cost effective, technically feasible and implementable solution to reduce the human health risk at this Site.

Amended Record of Decision Sunmlary of Remedial Alternative Selection Sapp Battery NFL Site OU2 September 2011

§lIllPlPOIrt AgerrntCy Commerrnts

The FDEP is the support agency for the State of Florida, has been involved in the process and supports the new Selected Remedy. State support of Alternative GW3 is anticipated.

23

Amended Record of Decision Sunmlary of Remedial Alternative Selection Sapp Battery NPL Site OU2 September 2011

7.G

Pursuant to Section 121 of CERCLA and the NCP, the lead Agency must select remedies that are protective of human health and the environment, comply with ARARs, are cost effective, and that utilize permanent solutions and alternative treatment technologies to the maximum extent practicable. In addition, CERCLA includes a preference for remedies that employ treatment that permanently and significantly reduces the volume, toxicity, or mobility of hazardous wastes as a principal element and a bias against off-site disposal of untreated wastes. Pursuant to 40 CFR Section 300.430(f)(5)(ii), the following sections discuss how the amended remedy selected in this AROD meets these statutory requirements.

7.n Protednmn of lHIUllmall1l lHIealltlln alJ1ldl time lErrnvnroll1lmell1lt

The amended Selected Remedy will be protective of human health and environment. Contaminants will be converted to less soluble fomls, reducing bioavailability (toxicity) and mobility. Long-term monitoring will-ensure that the risks to human and ecological receptors continue to diminish.

Remedial actions for cleanup of hazardous substances must comply with requirements and standards under federal or more stringent state environmental laws and regulations that are applicable or relevant and appropriate (i.e., ARARs) to the hazardous substances or particular circumstances at a site or obtain a waiver, per Section 121(d) of CERCLA. See also 40 C.F.R: § 300.430(f)( 1)(ii)(B). ARARs include only federal and state environmental orfacility siting laws/regulations and do not include occupational safety or worker protection requirements. Compliance with OSHA standards is required by 40 C.F.R. § 300.150 and therefore the CERCLA requirement for compliance with or wavier ofARARs does not apply to OSHA standards.

The amended Selected Remedy will comply with all ARARs. ARARs are divided into three categories for ease of identification: chemical-specific, action-specific, and location-specific.

"Applicable" requirements are those cleanup standards, controls, and other substantive environmental protection requirements, criteria, or limitations promulgated under federal or state law that specifically address a hazardous substance, pollutant, or contaminant, RA, location, or other circumstance found at a CERCLA site. Only those state requirements that are identified by a state in a timely manner and that are more stringent than federal requirements may be applicable per 40 Code of Federal Regulations (CFR) 300.5.

"Relevant and appropriate requirements" are those cleanup standards, standards ofcontrol, or other substantive environmental requirements, criteria or limitations promulgated under federal environmental or state environmental or facility citing laws that, while not "applicable" to a hazardous substance, pollutant, contaminant, RA, location, or other

24


circumstance found at a CERCLA site, address problems or situations sufficiently similar to those encountered at the CERCLA site that their use is well suited to the particular site.

C.hemical-specific ARARs are usually health- or risk-based restrictions on the amount or concentration of a chemical that may be found in or discharged to the environment. Chemical-specific ARARs set levels that are considered protective ofhuman health and the environment because they place restrictions on the concentration of the chemicals of interest in the designated media. Chemical-specific ARARs also may indicate acceptable levels for discharge if discharge occurs as part of a RA. If a chemical has more than one such requirement that is an ARAR, compliance should generally be to the more stringent level. Table 4 lists potential chemical-specific ARARs for the Site. The EPA has identified MARs for lead and vanadium in groundwater based on Florida Administrative Code, 62-550.10, Table I and 62-777.170, Table 1, respectively. In the absence of an MCl or other ChemicalSpecificARARs, site-specific risk-based remedial goalswere developed for aluminum, iron and magnesi urn, groundwater COCs. S::\s>Tabl e 2.

Action-specific ARARs establish controls or restrictions on the activities which are part of the remedy. They are triggered by the specific activity rather than a specific contaminant. Action-specific ARARs may establish perfoffi1ance levels, actions, or technologies, as well as specific levels for discharged or residual contaminants. Table 5 presents the actionspecific ARARs for the Sapp Site.

Location-specific ARARs prevent damage to unique or sensitive areas, such as floodplains, historic places, wetlands, and fragile ecosystems, and restrict other activities that are potentially harn1ful because of where they take place. Location-specific ARARs establish restrictions on concentrations ofconstituents or on conducting activities solely because they are in any ofthos~ unique or sensitive areas. Table 6 presents the location-specific ARARs for the Sapp Site.

The amended Selected Remedy in this AROO is the most cost-effective alternative considered. The amended Selected Remedy provides the best overall protection in proportion to cost, and meets all other requirements of CERCLA. Section 300.430(t)( I )(ii)(D) of the NCP requires the EPA to evaluate the cost-effectiveness by comparing all of the alternatives which meet the threshold criteria, overall protection of human health and the environment, and compliance with ARARs, against three additional balancing criteria: long-term effectiveness and permanence; reduction of toxicity, mobility, or volume through treatment; and short-term effectiveness. Based on this evaluation, the amended Selected Remedy is the most cost-effective alternative. The estimated present worth cost for the amended Selected Remedy is $319,600.

Of the alternatives that are protective ofhuman health and the environment and that comply with ARARs, the EPA has determined that the amended Selected Remedy is the most

25

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efficient and effective alternative when evaluated using the five balancing criteria while also considering 1) the statutory preference for treatment as a principal element, 2) the bias against off-site treatment and disposal, and 3) state and community acceptance. The amended Selected Remedy offers good long-tern1 effectiveness and an acceptable reduction in volume and mobility through natural attenuation processes per existing long-tern1 data trends. Longterm monitoring will ensure that RAOs are met.

7.5 JPrdereIl1lce ifm' 'IreatmeIl1lt a§ a JPrllIl1lcDlPaB ERemeIl1l.t

MNA is not a treatment technology and does not meet the statutory preference for remedies that employ treatment as a principal element. There are no principal threat wastes present in OU2. However, in conjunction with the remedy for OU 1 and OU3, the statutory preference for treatment is satisfied for the Site.

7.6 lFllve-Year Revllew Req]UJlllremeIl1lt

CERCLA Section 121 and 40 CFR Part 300 require a review ofRAs at least every five years if the RA results in hazardous substances, pollutants, or contaminants remaining in place above levels that allow for unlimited use and unrestricted exposure. Because this remedy will result in hazardous substances, pollutants or contaminants remaining on-site above levels that allow for unlimited use and unrestricted exposure, a statutory review will be conducted within five (5) years after initiation of the RA to ensure that the remedy is, or will be, protective of human health and the environment.

Pursuant to CERCLA 117(b) and NCP 300.430(f)(3)(ii), the AROO must document any . .

significant changes made to the Preferred Alternative discussed in the Proposed Plan. There are no significant changes between Preferred Alternative discussed in the Proposed Plan and the Selected Remedy in this AROO.

26

Amended Record of Decision Sunmlary of Remedial Alternative Selection Sapp Battery NPL Site OU2 September 20 I 1

The EPA identified and proposed the preferred remedial alternative in the Proposed Plan. The preferred remedial alternative did not differ from the amended Selected Remedy in this AROO. In accordance with 42 U.S.c. §117 (a) and 40 C.F.R. §300.45 (c)(2)(ii)(O), the opportunity for a public meeting was provided during the public comment period. The public meeting was advertised in the Proposed Plan fact sheets sent to individuals and other interested parties. The start of the public comment period was advertised in the Jackson County Floridan after the fact sheet was released. The EPA's responses to the comments received during the public comment period are included in the Responsiveness Summary, Appendix A of this AROO. The AR and Information Repository are available tothe public at the EPA Region 4 Superfund Record Center and the Jackson County Public Library, 2929 Green Street, Marianna, Florida 32446.

27

Amended Record of Decision Sunmlary of Remedial Alternative Selection Sapp Battery NPl Site OU2 September 20 II

ARCADIS, 2000. ARCADlS Geraghty & Miller, Inc. Operable Unit 3 Ecological Risk Assessment Risk Characterization Tehcnial Memorandum. March 2000.

Black & Veatch,2009a. Black & Veatch Special Projects Corp., Remedial Design Investigation Report Operable Unit 2 for the Sapp Batte,)) Site. Jackson County. Flohda. Revision 1. March 2009.

Black & Veatch, 2011. Black & Veatch Special Projects Corporation. Technical Memorandum, Remedial Design Status Summary - Operable Unit 2, Revision 1. July 20 11.

CMC, Inc., 2009. Clay Com1an Excavating, Inc. Sapp Battery Superfund Site, Operable Unit 3 Remedial Action,Report, Cottondale, Jackson County, Florida. June 2009.

E&E, 1986. Ecology and Environment, Inc. Summmy Report on the Field Investigation of the Sapp Battery Site. Jackson County. Florida. Volume 1. November 1986.

EPA, 1986. U.S. Environmental Protection Agency Region 4. Record ofDecision for the Sapp Battery Site. Jackson County, Florida. September 1986.

EPA, 1989. U.S. Environmental Protection Agency Region 4. Remedial Design Field Investigation Reportfor the Sapp Batte,)) Site. Jackson County. Florida. March 1989.

EPA, 1999. U.S. Environmental Protection Agency. Use ofMonitored Natural Attenuation at Superfund. RCRA Corrective Action. and Underground Storage Tank Sites. OSWER 9200A-17P. April 1999.

EPA,2007. U.S. Environmental Protection Agency Region 4. Explanation ofSign(ficant D(fferencesfor theSapp Batte,y Site. Operable Unit 3. Jackson County. Florida. September 2007.·

FDEP, 1985. Florida Department of Environmental Protection. Site-wide Remedial Investigtion / Feasibility Study for Sapp Batte,)) NPL Site. 1985.

Lockheed Martin, 2005. Lockheed Martin Technology Services. Trip Report Sapp Battery Site, Monitor Well Installation and Groundwater Sampling Event. Work Assignment #0-058, Volumes I and 11. October 2005.

TriAD, 2001. TriAD Environmental Consultants, Inc. Final Construction and Source Control Remedial Action Report, Volume Ifor the Sapp Battery NPL Site. Jackson County. Florida. July 2001.

28

TABLES

Table 4 - Chemical-Specific ARARs, Sapp Battery Superfund Site, Cottondale, Florida

Action/Media Requirements

All ground water of the state is classified according to the

Prerequisite Citation(s)

Classification of ground Groundwater within the state of FAC.62-520.410

water designated uses and includes the following:

Class G-I - Potable water use, ground water in single source

aquifers which has total dissolved solids content of less than

3,000 mg/!.

Class G-II - Potable water use, ground water in single

source aquifers which has total dissolved solids content of

less than 10,000 mg/I, unless otherwise classified by the

Florida Environmental Regulation Commission.

All ground water (except for Class G-IV) shall meet the

Florida - Applicable Classification of

Groundwater, Usage,

Reclassification

Restoration of ground Ground water within the state of FAC. 62-520.400

water as a potential minimum criteria for ground water specified in FAC. 62- Florida with designated beneficial Minimum Criteria for

drinking water source 520.400(1 )(a)-(f).

Class I and Class II ground water shall meet the primary

drinking water standards listed in FAC 62-550.310 for public

water systems, except as otherwise specified.

Shall not exceed the maximum contaminant level (MCl)

use(s) of Class G-I or Class G-II -

Relevant and Appropriate

Ground Water

FAC. 62-520.420(1)

Standards for Class - I and

Class " Ground Water

Restoration of ground Supply of water to public water FAC.62-550.310

water as a potential listed in Table 1 INORGANICS. system, as defined in FAC. 62-Primary Drinking Water

drinking water source (These standards may also apply as ground water quality

standards as referenced in Chapter 62-520, FAC.)

• lead - 0.015 mg/l (milligrams/liter)

Specifies Groundwater Cleanup target levels (CTls) for site

550.200 (17) - Relevant and

Appropriate Standards

Rehabilitation (i.e., remediation) of FAC. 62-780.150(5)

rehabilitation. FAC 62-777.170 Table I lists the default site contaminated groundwater -Contaminated Site

Groundwater Criteria.

• vanadium - 49 ~g/l (micrograms/liter) .

Relevant and Appropriate Cleanup Criteria

FAC.62-777.170(1)(a)

Table 4 - Chemical-Specific ARARs~ Sapp Battery Superfund Site, Cottondale, Florida

Action/Media Requirements Prerequisite Citation(s)

Restoration of

groundwater as a

potential drinking water

source

Requires that a lifetime excess cancer risk level of 1.0E-6

and a hazard index of 1 or less shall be used in establishing

alternative contaminant cleanup target levels (CTLs) for

groundwater or soil.

Establishment of alternative·

cleanup target levels (CTLs) for

contaminants of concern at the Site

- Relevant and Appropriate

FAC.62-780.650(1)(d)

Contaminated Site

Cleanup Criteria

ARAR = applicable or relevant a.nd appropriate requirement CTls = cleanup target levels (as specified in Chapter 62-777, F.A.C.) F.A.C. = Florida Administrative Code, Chapters as specified F.S. = Florida Statutes MCl = maximum contaminant level TBC = To Be Considered

Table 5 - Action-Specific ARARs/TBC, Sapp Battery Superfund Site, Cottondale, Florida

Action Requirements - Prerequisite Citation(s)

Groundwater Monitoring Before construction of new ground water Installation. of groundwater monitoring FAC. 62-520.600(6)(g)

Well Installation monitoring wells, a soil boring shall be made

at each new monitoring well location to

properly determine monitoring well

specifications such as well depth, screen

interval, screen slot, and filter pack.

well to detect migration of contaminants

- Applicable

Groundwater Monitoring

Requirements and

Exemptions

In the construction, repair, or abandonment of a

water well, caution shall be taken to maintain

the work site so as to minimize the potential

entrance of contaminants into the bore hole and

the ground water resour~e.

Installation of water well as defined in

FAC. 62-532.200 (26) - Relevant and

Appropriate

FAC. 62-532.500(3)(f)

Water Well Construction

Standards

Only water from a potable water source shall be

used in the construction, repair or abandonment

of a water well, including water for cleaning of

well materials, drilling equipment, and water

used to mix drilling fluids.

FAC. 62-532.500(3)(g)


Standards

Provides detailed guidance to assist in Installation of groundwater monitoring FDEP, Monitoring Well

monitoring well design and material well to detect migration of contaminants Design and Construction

specifications for construction of - To Be Considered Guidance Manual groundwater monitoring well. (2008)

Abandonment of


Well

All abandoned wells shall be plugged by filling

them from bottom to top with neat cement grout

or bentonite and capped with a minimum of one

foot of neat cement grout. An alternate method

providing equivalent protection shall be

approved by the Department and EPA.

Plugging and abandonment of

groundwate(monitoring wells,

piezometers - Relevant and

Appropriate

FAC. 62-532.500(5)


Standards

FAC. 62-520.600(6)(k)


Action Requirements

A minimum of two monitoring wells is required':

• At least one well shall be located at the downgradient edge of the plume; and

• At least one well shall be located in the area(s) of highest groundwater contamination or directly adjacent to it if the area of highest groundwater contamination is inaccessible (for example, under a structure).

The designated monitoring wells shall be

sampled for analyses of applicable

contaminants no more frequent than

quarterly.'

Prerequisite Citation(s)


for MNA remedy

Groundwater monitoring as part of the

remedy relying on natural attenuation -

Relevant and Appropriate

FAC. 62-780.690(8)(a)

Natural Attenuation with

Monitoring

FAC. 62-780.690(8)(b)

Water-level measurements in all designated

wells and piezometers shall be made within

24 hours of initiating each sampling event. '

FAC. 62-780.690(8)(c)

Control of storm water Must comply with the substantive provisions in Stormwater discharges from large and FAC. 62-621.300(4)(a)

runoff from soil the "Generic Permit for Stormwater Discharge small construction activities to surface Generic Permit for

disturbing activities from Large and Small Construction Activities,"

document number 62-621.300(4)(a), issued by

the FDEP and effective February 17, 2009.

Requires development storm water pollution

prevention plan and implementation of best

management practices and erosion and

sedimentation controls for stormwater ruoff to

ensure protection of the surface waters of the

state.

waters of the State as defined in

Section 403.031, F.S. - Applicable Stormwater Discharge

from Large and Small

Construction Activities

'.


Action Requirements Prerequisite Citation(s)

Control of Fugitive Dust No person shall cause, let, permit, suffer or allow the emissions of unconfined particulate matter from any activity, including vehicular movement; transportation of materials; construction, alteration, demolition or wrecking; or industrially related activities such as loading, unloading, storing or handling; without taking reasonable precautions to prevent such emissions.

Land disturbing activity that has

potential for unconfined emissions of

particulate matter - Applicable

FAC.62-296.320(4)(c)

General Pollutant

Emission Limiting

Standards

I The designated number ofwells, sampling time frames/frequency, and specific parameters for analyses will be provided in a Monitoring Plan that is included in a CERCLA post-ROD document prepared as part of the Remedial Design or Remedial Action which will be approved by the EPA and FDEP.

ARAR = applicable or relevant and appropriate requirement F.A.C. = Florida Administrative Code, Chapters as specified F.S. = Florida Statutes MNA = monitored natural attenuation TBe = To Be Considered

Table 6 - Location-Specific ARARs/TBC, Sapp Battery Superfund Site, Cottondale, Florida

Location Requirements Prerequisite Citation(s)

Presence of Wetlands Shall take action to minimize the destruction, loss or

degradation of wetlands and to preserve and

enhance beneficial values of wetlands.

Federal actions that involve potential

impacts to, or take place within, wetlands -

To Be Considered

Executive Order 11990

Section 1.(a) Protection of

Wetlands

Shall avoid undertaking construction located in wetlands unless: (1) there is no practicable alternative to such construction, and (2) that the proposed action includes all practicable measures to minimize harm to wetlands which may result from such use.

Executive Order 11990,

Section 2.(a) Protection of Wetlands

Presence of Floodplains

designated as such on a

map

Shall take action to reduce the risk of flood loss, to

minimize the impact of floods on human safety,

health and welfare, and to restore and preserve the

natural and beneficial values served by floodplains.

Federal actions that involve potential

impacts to, or take place within, floodplains

- To Be Considered


Section 1. Floodplain

Management

Shall consider alternatives to avoid, to the extent

possible, adverse effects and incompatible

development in the floodplain. Design or modify its

action in order to minimize potential harm to or within

the floodplain


Section 2.(a)(2) Floodplail)

Management

ARAR = applicable or relevant and appropriate requirement TBC = To Be Considered

FIGURES

3m

Site Location Map Sapp Battery OU2 RD

Cottondale, Jackson County, Florida

276

2.5 Miles I

1.25 I

GCS NAD 83

o I

N

A

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lead Groundwater PkJme 1985 and Groundwater Analytical Resulls 2005 • 2011 (Surficial Aquifer) Sapp BaIlery 002 RD

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117_

NS NS

4JlU NS NS

---

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4..9

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Lead Groundwater Plume 1985 and GroundwaterAnalytical Results 2005 - 2011 (Intermediate System, North) Sapp B:attery 002 RD


- 7I2D11 3,500 3,400

<1.0U e

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~._.._"CUI SaI,,-.~..2IIIIl

="-"¥-,

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Lead GRlundwaler Plume 1985 and Grotntwaler Analytical Resulls 2005 - 2011 (inlermeciale System, South) Sapp 8atlery 002 RD

Collondale, Jadlson County, FJorida

~-

100

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5.DU

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5.OU

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Lead Groundwater Plume 1985 and GroundwaterAnalytic:al ResuIIs 2004 - 2008 (Floridan Aquifer) Sapp BaIIery 002 RD


....., Lead Concentration in Groundwater above 15 ugll as cletected in 1985

7

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5.DU 0.41 J

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APPENDRX A ]RESPONSXVNlESS SUMMARY

Amended Record of Decision Appendix A: Responsiveness Summary Sapp Battery NPL Site OU2 September 2011

Appendix A: !Responsiveness Summary

A.l Overvnew and Summary

This Responsiveness Summary documents public comments and the EPA's responses to comments on the Proposed Plan for OU2, groundwater at the Sapp Battery NPL Site located in Cottondale, Jackson County, Florida. The EPA presented the Proposed Plan to the coinmunity at the Cottondale Community Center on September 7, 20 II, and held a public comment period from August 25 through September 25, 20 II. The EPA published the Public Notice for the Proposed Plan and Public Meeting in the Jackson County Floridan newspaper after the fact sheet was released. The EPA mailed a Proposed Plan fact sheet to individuals and groups on the Site mailing list at this same time.

A.2 Comments from Organizations and Interested Parti.es

The EPA received no commentsfrom organizations or interested parties..

A.3 Comments from the Flodda· Department of .IEnvinmmental Protection

The FDEP provided comments on the Proposed Plan in a memorandum dated September 7,2011 from Zoe Kulakowski, Professional Geologist, Program and Technical Support Section, to Chris Pellegrino, Environmental Specialist ll, Hazardous Waste Cleanup Section (attached). Specific comments made in this memorandum are addressed below.

A.3.n Concurrence with Proposed Remedy

In the memorandum cited above, FDEP's Ms. Kulakowski stated that she concurred with the preferred remedy, GW-3, Monitored Natural Attenuation:

EPA Response:

The EPA appreciates the State's participation in the remedy selection process and its concurrence with the selected remedy.

A.3.2 Proposed C]eanup Goals for Alumim.nm, Iron, and Manganese

In the memorandum cited above, FDEP's Ms. Kulakowski disagreed with the proposed Cleanup Goals for aluminum, iron and manganese. Ms. Kulakowski maintained that the state's health-based values should be used instead of the risk-based remedial goals calculated by the EPA.


EPA Response:

The EPA identified relevant and appropriate chemical-specific requirements for lead and vanadium in groundwater based on the maximum contaminant level (MCL) for lead found in Florida's Primary Drinking Water Standards at F.A.C. 62-550.10, Table 1 and the groundwater cleanup target level (GCTL) for vanadium identified in F.A.C. 62777.170, Table I. The concentrations for these two chemicals are health-based and are considered protective of human health in the event of consumptive use of the groundwater. The EPA did not identify a state MCL or default GCTL for aluminum, iron and manganese as a chemical-specific requirement because these are identified as secondary drinking water standards. Unlike primary water quality standards, these secondary standards are not health-based but instead address aesthetic characteristics of potable water. Concentrations of contaminants above secondary standards may cause the water to appear cloudy or colored, or to taste or smell bad.

Notwithstanding, the EPA acknowledges that the state has concerns about exposure to aluminum, iron and manganese and accordingly developed site-specific risk-based remedial goals for these constituents that are protective of human health and the environment, considering the remedy's goal for restoration of the groundwater to its beneficial uses. Risk-based cleanup goals for these three constituents were calculated in accordance with EPA Region 4's Risk Assessment Guidance for Superfund (RAGS), using a hazard quotient of 1. The EPA finds this approach consistent with the state's method of establishing alternative cleanup target levels for contaminants of concern (COCs) and narrative standard set out in F.A.C. 62-780.650(l)(d), which is identified as a relevant and appropriate requirement in the ARARs Table. F.A.C. 72-780.650(1)(d) requires that a lifetime excess cancer risk level of 1.0E-6 and a hazard index of 1 or less shall be used in establishing alternative contaminant cleanup target levels (CTLs) for groundwater or soil.

For an overview of RAGS, see EPA, 2000. U.S. Environmental Protection Agency, Supplemental to RAGS: Region 4 Bulletins Human Health Risk Assessment Bulletins. EPA Region 4, originally published November 1995, Website version last updated May 2000 (currently under revision): http://www.epa.gov/region4/waste/sf/programs/riskassess/healtbul.html#hhrisk

A.3.3 Proposal to Eliminate Arsenic, Cadmium, and Nickel as Chemicals of Concern

In the memorandum cited above, FDEP's Ms. Kulakowski requested that either the historical results or new data showing detection limits at or below the current GCTLs be provided to support dropping arsenic, cadmium, and nickel as COCs.

2

http://www.epa.gOv/region4/waste/sf7programs/riskassess/healtbul.html%23lilirisk

Amended Record of Decision Appendix A: Responsiveness Summary Sapp Battery NPL Site OU2 September 20 I I

EPA Response:

The EPA has been proposing to remove arsenic, cadmium and nickel as COCs since 2009 because they have not been detected above MCLs since source removal actions were conducted. The sampling results for arsenic, cadmium and nickel are discussed in detail in the March 2009 Remedial Design investigation (RDI) Report, Revision 1. Arsenic and cadmium were routinely analyzed as part of the OUI effectiveness monitoring, with results summarized in the August 2009 Semi-Annual Groundwater Effectiveness Monitoring Report. The RDI sampling in 2006 and 2008 did not analyze for arsenic or cadmium due to the non-detect levels reported in the OU I monitoring reports. Also reported in the RDI report, nickel was last detected at well EW03S in "2005 at a concentration of 8.4 flg/L, which is significantly below the ROD cleanup level and the FDEP GCTL of 100 flg/L. Due to the low concentrations of nickel, it was not analyzed as part of the OU I effectiveness monitoring and was not included in the 2006. or 2008 RDI sampling.

The EPA believes that the data in the Administrative Record file supports the decision to no longer include arsenic, cadmium, and nickel as COCs.

A.3.4 Proposal to Add Sulfate as Chemical of Concern

in the memorandum cited above, FDEP's Ms. Kulakowski requested that sulfate be added as a COC.

EPA Response:

The EPA has evaluated the site data and the Administrative Record file and determined that the proposed cleanup levels are protective of human health. The EPA has detem1ined that sulfate in groundwater does not contribute significantly to an unacceptable risk and therefore does not need to be added as a COC for this response action.

The Feasibility Study Report for the Sapp Battery Salvage Site, prepared by the Florida Department of Environmental Regulation (FDER), included the screening of COCs. The FDER did not include sulfate as a COC for any media.

The EPA has determined that there are no relevant and appropriate state or federal chemical-specific requirements for sulfate. The default groundwater criteria for sulfate contained in Table I of FAC 62-777.170 does not contain a primary standard or maximum contaminant level for sulfate. instead, it cites the secondary standard of250 mg/L which is not a health-based level. With respect to sulfate, the secondary standard is based on imparting a salty taste to water.

3

Amended Record of Decision Appendix A: Responsiveness Summary Sapp Battery NPL Site OU2 September 20 I I

A.3.5 CUatioHl of Part of the Remedy in the 1986 Record of Decision

In the memorandum cited above, FDEP's Ms. Kulakowski cited the 1986 ROD requirement of a laboratory study to evaluate soil washing. She noted that if it was conducted, the tense in the citation should be changed or there should be a statement to the effect that it was later determined to not be needed.

IEPA Response:

The laboratory study in question was performed and the results documented in the Work Plan for the Remedial Design/Remedial Action at the Sapp Battery Site, Jackson County, Florida dated July IS, 1988:

SECTION 3.1 SOILS WASHING A laboratory study on the feasibility of soils washing was performed by EPA's Environmental Response Team. The study was designed to give an indication of whether or not the clean up goals for the Sapp Battery RA could be met using soil washing. The study showed that soils washing (using an EDTA chelation process) reduced lead contamination. Residual lead levels were from 150 to 400 ppm were common for coarse fraction soils and 3,000 to 4,000 ppm for the fines fraction soils. The residual levels for the fines fraction were far above acceptable levels. (Based both on site-specific cleanup levels and experience at other sites.)

.Approximately half of the contaminated soils/sediment at the Sapp Battery site would fall within the "fine soil" category. These soils would require an alternate method of treatment. EPA has a pilot scale soils washing system that has been used at at least two Superfund sites. The two sites are Leeds, Alabama and Lees Farm, Wisconsin. The conclusions from both those sites was,' although this technology was promising, materials handling problems were very serious. The conclusion was that the soil washing technology was several years away from full scale implementability. For the preceding two reasons, EPA has decided not to pursue the soils washing technology for the Sapp Battery site.

A.3.6 Monitoring WeUl Network

In the memorandum cited above, FDEP's Ms. Kulakowski stated that the proposed MNA monitoring well network is inadequate.

, IEPA Response:

The monitoring well network put forth in the Proposed Plan was for cost estimating purposes only. In the selected remedy section of the AROD, the text now reads: "The exact MNA sampling plan will be developed by the EPA in consultation with the FDEP

4


during the remedial design process." As a result, the well network may be amended, as needed.

5

SAPP BATTERY SUPERFUND SITE OPERABLE UNIT 2

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