EPA Superfund Proposed Plan Cabot / Koppers Superfund Site

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U.S. ENVIRONMENTAL PROTECTION AGENCY
SUPERFUND PROPOSED PLAN
CABOT CARBON/KOPPERS SUPERFUND SITE
Gainesville, Alachua County, Florida
July 2010
This document has been prepared to provide the general public with an understanding of the activities that have been occurring at the Cabot
Carbon/Koppers Site. For technical information, please review the documents in the Administrative Record located at the information
repositories.

Introduction
The U.S. Environmental Protection Agency
(EPA) is releasing this Proposed Plan (Plan) for Public Comment Period
the environmental cleanup at the Koppers July 15, 2010 to August 15, 2010
portion of the Cabot Carbon/Koppers Superfund
Site in Gainesville, Alachua County, Florida. Public Meeting
This Proposed Plan identifies the preferred Date: August 5, 2010
alternative for cleaning up the Koppers Site and Time: 6:00-8:00 p.m.
provides rationale for this preference. It includes
summaries of other remedial alternatives Location: Stephen Foster Elementary School
evaluated and the findings in the Remedial 3800 Northwest 6th Street
Investigation (RI), Baseline Risk Assessments, a Gainesville, Florida 32609
new (2010) Feasibility Study (FS), and other
The community is invited to a public meeting
documents included in the Administrative where EPA will present its understanding of Site
Record. EPA is issuing this Plan as part of its conditions, alternatives evaluated in the Feasibility
public participation responsibilities under Study, and provide its rationale for the preferred
Section 300.430(f)(2), of the National Oil and alternative presented in this Plan. In addition, this
Hazardous Substances Pollution Contingency meeting provides the community with an
Plan (NCP). opportunity to ask EPA questions about the
preferred alternative or Site activities and finding.
This document is issued by EPA, the lead agency
The Administrative Record file for the
for Site activities. EPA, with support from the Cabot Carbon/Koppers Site is available at the
Florida Department of Environmental Protection following location:
(FDEP), will select a final remedy for the Site
after reviewing and considering all information Alachua County Library
submitted during the 30-day public comment 401 E. University Ave.
Gainesville, FL 32601
period. (352) 334-3900
www.aclib.us/locations/headquarters
Public participation is an important part of the
Site cleanup decision process. Based on public
comments, EPA, along with FDEP, may modify Therefore, the public is encouraged to review
the preferred alternative or select another and comment on the cleanup alternatives
alternative presented in this Plan. presented in this Plan.

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What is a Proposed Plan? The public comment period for this Plan starts
A Proposed Plan presents EPA’s preferred on July 15, 2010 and ends August 15, 2010.
alternative to address contamination at a Site,
presents other alternatives that were evaluated, During this 30-day period, the public is
and provides the rationale for EPA’s preferred encouraged to review the findings of the RI and
alternative. In addition, the Plan solicits public the details of the alternatives presented in the
involvement and comment on the Site’s remedy final FS. These and other documents are
selection process. Issuance of this Plan is part of available at the information repository listed on
the Superfund process depicted below. page 34 of this document. Citizens are
encouraged to submit written comments to EPA.
What are the next steps in the
Superfund process? Following the public comment period, EPA will
EPA will hold a public meeting on Thursday, carefully consider all public comments before
August 5, 2010, 6:00 p.m. at Stephen Foster selecting the remedy for the Site. All comments
Elementary School. The purpose of the meeting submitted in writing by August 15, 2010, will be
is to present the Proposed Plan for cleaning up the addressed in the Responsiveness Summary, as
Koppers Site. This meeting will provide an will the questions and answers discussed at the
opportunity for citizens to ask questions of EPA public meeting. If you are not on the Site
representatives. Questions and answers will be mailing list and would like to be, please contact
recorded to assist EPA in the final selection of the Ms. LaTonya Spencer at 404-562-8463 or 1-800-
remedy and in preparation of a Record of Decision 435-9234.
(ROD). All comments received during the public
comment period and corresponding responses will A ROD, which summarizes the remedy decision
be documented in the Responsiveness Summary process and announces the remedy will be
of the ROD. prepared and signed by EPA. Once the ROD is

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issued, the design of the remedy will be other areas in Alachua County. The Murphree
scheduled and conducted, followed by the Well Field withdraws water from the Upper
implementation of the remedy. Floridan Aquifer (UFA). Under the Koppers
Site, the UFA is overlain by the Hawthorn Group
Site History (HG) and by the Surficial Aquifer (Figure 3). In
The Cabot Carbon/Koppers Superfund Site documents for this Site, the two water-bearing
encompasses approximately 170 acres, bridging zones in the UFA have been designated the
two properties in a commercial and residential upper and lower transmissive zones of the UFA,
area of the northern part of the Gainesville city and the two zones in the HG with moderate
limits, Alachua County, Florida. This Site was permeability have been designated the Upper
originally two Sites; Cabot Carbon in the Hawthorn and the Lower Hawthorn.
southeast portion of the Site, and Koppers on the
western portion of the Site (Figure 1). Cabot Former wood-treatment facilities are located
Carbon, is currently inactive, is now in use as within the southeastern portion of the Koppers
commercial property. Koppers was an active Site (Figure 2). This includes a recently-active
facility until December 2009. On March 31, process building and adjacent drip tracks where
2010, Beazer East, Inc. purchased the property chromated copper arsenate (CCA) was used to
from Koppers in order to facilitate remediation. preserve wood. The central and northern
portions of the Site were recently used for wood
The Cabot Carbon portion of the Site was storage, staging, and debarking. The Koppers
operated as a pine tar and charcoal generation Site was serviced by railroad sidings that entered
facility from 1911 until 1967. Process at the facility’s northeast corner. These sidings
wastewater containing residual pine tar was connected to a rail spur of the CSX railroad that
discharged to three unlined lagoons as early as still exists along the eastern boundary of the
1937. Koppers Site.

The Koppers Site operated as a wood-treating Wood treating processes at the Koppers Site
facility from 1916 to late 2009 and covers began with a creosote impregnation process in
approximately 86 acres (Figure 1 and Figure 2). 1916. The treatment processes were modified
Portions of the area east of the Koppers Site and over the years to include two additional
north of the former Cabot Carbon property are processes: one using CCA, beginning in the
now commercial properties; other portions 1960s, and another using pentachlorophenol
remain undeveloped. The areas to the west and (penta), beginning in 1969. The use of creosote
north are single-family and multi-family decreased in the 1970s and creosote use was
residences. A Gainesville Public Works facility, completely phased out at the Site by 1992.
small businesses, and a mobile home community Pentachlorophenol use was discontinued by
are located to the north/northwest of the Site. A 1990. Koppers used only CCA to treat wood at
small drainage ditch that currently runs through the Site from 1990 through 2009.
the Koppers Site collects storm water from the
property and directs it north. The drainage exits The Former North Lagoon and Former South
the property at a point along the northern Lagoon (Figure 2) at the Koppers Site were used
boundary and discharges into Hogtown Creek, to manage process wastewater. Based on
which then flows into Springstead Creek. historical aerial photographs, the Former North
Lagoon was active from approximately 1956
The Murphree Well Field is located until the 1970s, and the Former South Lagoon
approximately 2 miles northeast of the Site was active from 1943 or earlier through 1975 or
(Figure 1). This 26 million-gallon-per-day 1976. Both former lagoons have been closed,
(mgd) well field is operated by the Gainesville covered, and graded. The CCA wood-treating
Regional Utilities (GRU) and provides public
water supply for the City of Gainesville and

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process used most recently at the Site did not In March 1991, the EPA issued a Unilateral
generate wastewater. Administrative Order (UAO) to Beazer East
directing development of a remedial design for
The Cabot Carbon/Koppers Site was proposed the Site. However, further investigation
for the National Priorities List (NPL) in revealed Site conditions that were not
September 1983, and listed as final on the NPL contemplated by the ROD or UAO.
in September 1984. Remedial investigations at Specifically, groundwater impacts below the
the Site began in 1983. An initial groundwater water table were greater than expected and the
interceptor trench was installed on the Cabot amount of dense non-aqueous phase liquid
Carbon portion of the Site in 1985, and a (DNAPL) below the water table was greater
permanent subsurface collection system was than expected. These discoveries called into
installed in 1995, with the groundwater question the potential effectiveness and
discharging to the principally-owned treatment practicality of the ROD-specified removal
works (POTW). A POTW is a wastewater actions. A Surficial Aquifer groundwater
treatment facility that is owned by a state or extraction system was designed to prevent off-
municipality. The Cabot portion of the Site has Site migration of contamination in shallow
been redeveloped and currently contains a groundwater, and operation began in 1995. In
commercial shopping mall, a car dealership, and 2009, this Surficial Aquifer groundwater
a series of small stores and businesses. extraction system was upgraded to increase
Therefore, in this Plan, the word “Site” refers to pumping capacity and capture contaminated
the Koppers portion of the Cabot groundwater through placement of recovery
Carbon/Koppers Superfund Site, unless trenches next to the 4 principal source areas.
otherwise specified. Currently, fourteen groundwater extraction
wells operate along the northern and eastern
The remedial investigation (RI) was completed property boundaries, and groundwater recovery
in 1987, and a Supplemental RI was completed drains operate near each of the four principal
in 1989. A Baseline Risk Assessment and FS source areas.
were completed in 1990. A remediation plan
was selected and a ROD for the Cabot Based on post-ROD Site data and concerns
Carbon/Koppers Site was signed in1990. For regarding the technical practicability of the
the Koppers property, the ROD specified (1) selected remedy, the UAO was amended in
excavation of soils in the Former North and April 1994, This amendment required
South Lagoons to a depth of 4 feet, (2) additional Site characterization and
bioremediation of soils in the Former Process development of a Supplemental FS that included
area and Former Drip Track Area by remedial alternatives appropriate for the
recirculating groundwater with nutrient expanded extent of Site impacts. Subsequently,
amendment, (3) installation of a groundwater studies were conducted to identify a revised
extraction system in the Surficial Aquifer, and remediation strategy based on an updated
(4) long-term institutional controls on Site use. understanding of the Site.
At the time the ROD was prepared and signed, it
was concluded that, based upon then-current A Supplemental FS was prepared in 1997 based
information, (a) the HG was a single thick clay on the existing and updated data and an
layer that provided an effective vertical barrier improved understanding of flow and transport
for groundwater flow and transport and (b) the mechanisms at the Site. A Revised
potential source zones were primarily in the Supplemental FS was issued in 1999 to address
shallow unsaturated zone with a small volume comments from both EPA and FDEP. The
of impacted soil below the water table in the Revised Supplemental FS recognized that the
Surficial Aquifer. potential impacts from source areas were deeper
than contemplated by the 1990 ROD; however,

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the potential impacts within and below the HG Environmental Investigation Results
were still considered negligible at that time. Numerous remedial and environmental
investigations have been performed at the Site.
More recent investigations (2003, 2004, and These include:
2006) that form the basis for this cleanup plan
have indicated that dense non-aqueous phase • Hydrogeologic investigation;
liquids (DNAPL) from former wood-treating • Initial and supplemental RIs;
substances such as creosote is present in the HG • Site characterization for soil and
and that Site contaminants are present in groundwater remedies;
groundwater in the Upper Floridan Aquifer (See • Field investigations of the HG and UFA;
Figure 3). Ongoing and planned monitoring is • Source delineation study for former source
being used to better characterize potential areas;
impacts in the Surficial Aquifer, HG, and UFA.
• Data summary report for soil and sediment;
and
Since the 1990 ROD, as investigations have
• Surficial Aquifer well redevelopment and
improved the conceptual understanding of the
sampling.
Site, pilot remedial actions and focused studies
have been conducted to assist with the selection
Site soil and groundwater have been sampled to
and evaluation of a final comprehensive
characterize the nature and extent of Site-related
remedial strategy for the Site. These activities
contamination. Over 350 soil borings and 1,000
have included:
soil samples have been collected and analyzed
across the Site since 1984. Groundwater
- Pilot testing active DNAPL recovery in the
monitoring has been routinely performed since
Surficial Aquifer at PW-1 in 1994 and 2004;
1984. Over 150 wells have been installed (and
- Studying vertical groundwater circulation at
sampled) at the Site in the three main
the Former North Lagoon in 1995;
hydrogeologic units (Surficial Aquifer, HG, and
- Recovering DNAPL Manually by periodic
UFA) (See Figure 3). Periodic groundwater
bailing in HG monitor wells since 2004;
monitoring reports are prepared for the EPA.
- Evaluating soil excavation feasibility;
- Evaluating in-situ thermal treatment
Potential impacts to off-Site areas have been
feasibility;
investigated and continue to be investigated
- Evaluating surfactant flushing feasibility;
west of the Site. An additional off-Site soil
- Pilot testing active DNAPL recovery in the
investigation is currently being conducted to
HG beneath the Former North Lagoon; and
completely delineate the extent of impact in
- Bench testing and pilot field testing in-situ
other areas surrounding the Site. Some
biogeochemical stabilization (ISBS) of
information and analytical data has been
DNAPL using modified permanganate
generated from sediment and surface water in
solutions.
Hogtown and Springstead Creeks to evaluate
impacts to aquatic habitats and species.
Two five-year reviews for the Site were
conduced by EPA and finalized in 2001 and
The contaminants of concern (COCs) identified
2006. The 2006 Five-Year Review Report
for soil and groundwater in the 1990 ROD
recommended additional studies to support the
include phenols (such as penta), polycyclic
selection of a new remedial strategy to address
aromatic hydrocarbons (PAH), arsenic, and
the full extent of impacts at the Site. Such
chromium. Creosote, the predominant chemical
studies have been undertaken through the
material historically used for wood treatment at
collaborative FS process to fulfill the specific
the Site, consists mainly of PAHs and includes
recommendations of the Five-Year Review.
both potentially carcinogenic (pcPAH) and non-
carcinogenic (ncPAH) compounds. The EPA
A revised FS was finalized in May 2010.
and FDEP also required sampling and testing
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for polychlorinated dibenzo-p-dioxins and Source areas defined in these figures correspond
polychlorinated dibenzo furans (dioxins/furans) with the areas in the Surficial Aquifer
in soils. Based on the results of this sampling, containing the greatest concentrations of
dioxins/furans have also been identified as contaminants associated with wood-treatment
COCs for Site soil. Relatively low benzene, materials. The wood-treating products that
toluene, ethylbenzene, and xylenes (BTEX) remain in the environment (e.g., creosote
concentrations also have been observed in soils DNAPL, free-product PCP, etc.) are defined as
and groundwater under the four identified the principal threat waste at this Site. Based on
source areas. the physical and chemical properties of DNAPL
and its variable distribution throughout the
Conceptual Site Model various aquifer zones under the Site, it is
A conceptual Site model (CSM) was formulated impracticable to distinguish heavily-
as part of the revised FS using environmental contaminated soil from principal threat waste.
investigation data collected over the past 26 Based on this uncertainty, it is prudent to
years. The CSM describes current Site address the entire soil volume in the four Source
conditions and how Site-related contaminants Areas as principal threat waste. This approach
move in the environment and the potential for will ensure that the vast majority of DNAPL and
contaminants to reach environmental receptors. heavily-contaminated soil can be treated and
Figure 3 is a conceptual block diagram that isolated from the surrounding environment.
depicts migration of contaminants in the
subsurface. Analytical data for source area soil borings
indicate that DNAPL has migrated down into
Groundwater Flow the Lower HG, but the extent to which this has
Hydrogeologic layers beneath the Site are occurred is uncertain and difficult to determine
illustrated on Figure 3. The layers vary in their definitively. Remedial actions proposed as a
ability to transmit groundwater (transmissivity). part of this Plan are intended to address DNAPL
Zones 1, 7, and 9 are the most transmissive. (i.e., principal threat waste) impacts, regardless
Zones 3, 5, 8, and 10 are moderately of its location or source origination on the
transmissive. Zones 2, 4, and 6 have very low Koppers Site.
capacities to transmit water, and limit vertical
flow between transmissive layers. Groundwater Other smaller isolated surface soil areas
flow within the transmissive layers that have throughout the property show high
shown the highest COC concentrations (Zones 1 concentrations of various contaminants that are
and 3) is to the north-northeast. not associated with any particular process area
on the property. These minor locations of
Source Areas elevated contaminant concentrations are not
The origin of contaminants at the Site is linked identified as source areas, but as locations of
directly to facility operations and historical contaminants that either migrated from source
waste management methods. Releases occurred areas (i.e., by surface runoff, soil dust
when wood-treatment chemicals dripped onto deposition, or other surface transport
the soil or were deposited in unlined lagoons. mechanism), or are isolated residuals from
Site investigations have identified four main historic wood treating operations.
contaminant source areas related to former
operations and facilities (the Former Process Soil Contamination
Area, the Former South Lagoon, the Former Soils above the water table contaminated with
North Lagoon, and the Former Drip Track). contaminants of concern (COCs) are a result of
These are labeled [a] through [d] in Figure 3, residual DNAPL in unsaturated pore space or
and are illustrated in Figure 2. contaminants that are adsorbed onto soil
particles. Asenic, pcPAHs (expressed as
benzo(a)pyrene toxic equivalents [BaP-TEQ]),
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and dioxins/furans (expressed as 2,3,7,8- bodies. Since inputs to both Springstead and
tetrachlorodibenzo-p-dioxin toxic equivalents Hogtown Creek are attributable to releases from
[TCDD-TEQ]) are COCs that drive the both the Koppers facility and the Cabot Carbon
evaluation of human-health risk for direct soil facility, cleanup will be performed jointly.
exposure at the Site under current Site use.
Groundwater Contamination
The highest arsenic concentrations were Groundwater impacts have resulted from: (a)
detected in the vicinity of the Former South percolation of contaminants in process water
Lagoon, two sample locations had average down to the water table; (b) dissolution of
surface soil concentrations above 1,000 contaminants from DNAPL in the subsurface;
milligrams per kilogram (mg/kg) for arsenic. and (c) leaching from soils as rainwater
percolates through the unsaturated zone in areas
Elevated PAH concentrations were detected in with high concentrations of COCs.
surface soils at all four DNAPL source areas.
Dioxins/furans were detected over a significant Surficial Aquifer Groundwater
portion of the Site at levels above the Florida The predominant PAH compound detected in
default commercial/industrial soil cleanup target groundwater at the Site is naphthalene.
level (SCTL) (0.03 micrograms per kilogram Naphthalene is used as the primary indicator
[µg/kg]). compound to represent the presence and extent
of COCs in Site groundwater due to its
Concentrations of pentachlorophenol in surface prevalence and very high mobility. As part of
soil were below the Florida default SCTL for the effectiveness monitoring for the existing
commercial/industrial direct exposure (28 groundwater extraction system, groundwater
mg/kg) over most of the Site. There were five quality is measured periodically at extraction
exceptions: three in the Former Process Area, wells and monitor wells. Groundwater samples
one at the Former Drip Track Area, and one at are analyzed for benzene, toluene, ethylbenzene
the Former North Lagoon. and xylenes (BTEX), PAHs, phenols, arsenic,
and chromium. Several of the wells near the
A multi-phase Site-boundary and off-Site soil source areas and near the eastern Site boundary
sampling and analysis program is presently have naphthalene concentrations greater than
being conducted. Initial results from this the Florida default groundwater cleanup target
program show that surface soil immediately level (GCTL) of 14 µg/L. In all locations where
adjacent to the western Site boundary has both a water-table and deeper Surficial Aquifer
elevated concentrations of PAHs, arsenic, well were sampled, the water-table well had a
and/or dioxins/furans above Florida default significantly lower naphthalene concentration.
SCTLs for residential direct exposure. Past Concentrations of some other COCs (PCP,
transport of COCs via dust likely caused the arsenic, benzene, carbazole, dibenzofuran) also
detections of Site COCs in off-Site surface soil exceeded their default GCTLs and/or federal
west of the Site. Further off-Site soil maximum contaminant levels (MCLs) in certain
characterizations are under way to the north, wells.
south, east, and west of the Site and will
continue after remedy selection to facilitate Hawthorn Group Groundwater
expedited cleanup of off-Site residential areas. Naphthalene and other COCs have been
detected at monitor wells near source areas and
Off-Site Creek Contamination near the eastern property boundary at
Investigative work has been done in Hogtown concentrations exceeding default GCTLs.
and Springstead Creeks, north of the Koppers
Site. These studies were done to support Upper Floridan Aquifer Groundwater
evaluation of possible impacts to ecological Water quality in the UFA beneath and
habitats and species in these surface water immediately downgradient (in the direction of
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groundwater flow) of the Site is measured on a Site Risk Assessment
quarterly basis. Risk assessments were conducted to determine
the current and future effects of contaminants on
Monitor wells within the top 30 feet of the UFA. human health and the environment. “What Is
Only one of these wells (a source-area Risk and How Is It Calculated” provides general
monitoring well near the Former North Lagoon)
information on assessing risk. A human-health
currently has organic concentrations above state
risk assessment (HHRA) for on-Site soils and
or federal drinking water standards.
Naphthalene concentrations at this well have sediment was submitted in 2009 and updated in
decreased substantially since July 2004. May 2010 to take into account a change in land
use and to incorporate comments received on
There are 15 multiport, quadruple-cased wells the earlier version. The estimates of potential
quadruple-cased wells completed within the risk presented in the August 2009 HHRA
upper 100 feet of the UFA (the Upper assume that the use of the Site is for wood-
Transmissive Zone). At two of the four source treatment in the foreseeable future because
areas (Former Process Area and Former South wood-treatment operations have ceased, this
Lagoon), inorganic and organic contaminants assumption is no longer valid. The HHRA was
are consistently below state or federal drinking updated to take into account a change in land
water standards in the UFA monitor wells. use not previously contemplated under the 2009
Seven organic contaminants are above state or submittal.
federal drinking water standards in the UFA
north of the Former North Lagoon and Former
The 2009 HHRA includes both a deterministic
Drip Track at a few locations.
(traditional) evaluation of potential risks and a
Organic COCs have never been detected in the more quantitative probabilistic model for
four Lower Transmissive Zone wells at the potential risk evaluation. The assessment shows
northern property boundary. that pcPAHs, arsenic, and dioxins/furans are the
COCs that make the largest contribution to the
In some sampling events, arsenic concentrations overall potential excess lifetime cancer risk
above the Florida default GCTL (10 µg/L) have associated with the Site. Potential exposure to
been identified in groundwater collected from a pentachlorophenol makes a small contribution
few of the UFA monitor wells. These low to the total potential excess lifetime cancer risk.
observed concentrations likely result from
dissolution of naturally occurring minerals in EPA has evaluated the 2009 HHRA and its
the UFA that occurs when oxygenated water is accompanying revisions and has determined that
introduced to the formation during well drilling. the probabilistic risk assessment does not
This is consistent with the absence of inorganic provide an adequate basis to define the required
COCs in overlying aquifers. cleanup goals. Therefore, EPA will base
selection of cleanup goals on a more
Scope and Role of Proposed Remedy conservative cleanup goal derived from
The proposed remedy is intended to be the final deterministic risk calculations.
cleanup for the Cabot Carbon/Koppers Site.
The preferred alternative identified in this Potential ecological risks associated with
Proposed Plan, or one of the other active sediment were also evaluated in 2009. The
measures considered in this plan, will protect Agency has evaluated the 2010 ecological
public health, welfare, and the environment screening level risk assessment and its
from actual or threatened releases of hazardous accompanying revisions and does not believe
substances into the environment. that it provides an adequate basis to select
remedial goals for the Site. This is because this
assessment was based on assumptions used in
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What Is Risk And How Is It Calculated?
A Superfund human health risk assessment estimates the “baseline risk.” This is an estimate of the likelihood of
potential health problems occurring if no cleanup action were taken at a Site. To estimate the baseline risk at a
Superfund Site, EPA undertakes a four-step process:

Step 1: Analyze Contamination.
Step 2: Estimate Exposure.
Sept 3: Assess Potential Health Dangers.
Step 4: Characterize Site Risk.

In Step 1, EPA looks at the concentrations of contaminants found at a Site as well as past scientific studies on the
effects these contaminants have had on people (or animals, when human studies are unavailable). Comparisons
between Site-specific concentrations and concentrations reported in past studies help EPA to determine which
contaminants are most likely to pose a potential threat to human health.

In Step 2, EPA considers the different ways that people might be exposed to contaminants, and the potential
frequency and duration of the exposure. Using the information, EPA calculates a “reasonable maximum exposure”
(RME) scenario, which portrays the highest level of human exposure that could reasonably be expected to occur.

In Step 3, EPA uses the information from Step 2 combined with information on the toxicity of each chemical to assess
potential health risks. EPA considers two types of risk: cancer risk and non-cancer risk. The likelihood of any kind of
cancer resulting from a Superfund Site is generally expressed as an upper bound of probability; for example a “1 in
10,000 chance”. In other words, the exposed individual would have an excess cancer risk of one in 10,000 due to Site
contaminants. This excess risk would be over and above the existing cancer risk for the individual. For non-cancer
health effects, EPA calculates a “hazard index” (HI). The key concept here is that a “threshold level” (measured
usually as a HI of less than 1) exists below which non-cancer health effects are not expected.

In Step 4, EPA determines whether Site risks are excessive for people at or near the Superfund Site. The results of
the three previous steps are combined, evaluated, and summarized. EPA adds up the potential Risks for each
receptor.

the screening level risk assessment that have not › Groundwater in the Surficial Aquifer,
yet obtained acceptance by EPA and Florida Upper HG, Lower HG, and Upper
DEP. Therefore, the Agency will utilize Floridan Aquifer;
conservative default ecological endpoints in › Subsurface soils;
identification and selection of cleanup goals for › Sediment; and
remedial goal selection. › Surface water.
• Mitigate further migration of impacted
Remedial Action Objectives and
groundwater.
Cleanup Levels • Restore quality of groundwater outside of
Remedial Action Objectives (RAOs) for the Site
source areas to beneficial use having COC
are based on potential migration or exposure
concentrations no greater than Federal
pathways for Site COCs and applicable or
MCLs or Florida GCTLs.
relevant and appropriate requirements (ARARs)
• Reduce the mobility, volume, and toxicity of
identified in the 2010 FS. The RAOs provide
DNAPL to the extent practicable.
media-specific and action-specific requirements
to protect human health and the environment. Cleanup goals for COCs are listed in Table 1.
The RAOs identified for the Site include: The selected cleanup goals are the Florida
commercial/industrial SCTLs for on-Site
• Mitigate risks to potential receptors exposed soils/sediments and either the residential SCTLs
to Site-related contaminants in: or commercial/industrial SCTLs for off-Site
› Surface soils; soils/sediments based on the current land use.
The selected goals for groundwater are the
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Table 1 – Cleanup Goals for COCs Table 1 – Cleanup Goals for COCs (Continued)

Groundwater (µg/L) Off-Site Soil/Sediment (mg/kg)
naphthalene 14 Listed compounds pcPAHs (BaP-TEQ)* 0.1 Florida default
acenaphthalene 210 exceed the federal SCTLs residential
dioxins (TCDD-TEQ) 0.000007
2-methylnaphthalene 28 MCL and/or Florida land-use
Default GCTL
arsenic 2.1
pentachlorophenol 1 (based on values in pentachlorophenol 7.2
arsenic 10 effect on the date pcPAHs (BaP-TEQ)* 0.7 Florida default
carbazole 1.8 that the Proposed dioxins (TCDD-TEQ) 0.000003 SCTLs for
commercial/
dibenzofuran 28 Plan was issued). arsenic 12 industrial land use
1,1 biphenyl 0.5 (depends on
* Primary standard pentachlorophenol 28
phenol 10 specific land-use of
as defined by off-Site location)
2-phenol *
Florida Department
2-methylphenol 35 of Environmental pentachlorophenol 0.03 Florida default
2,4-dimethylphenol 140 Protection in F.A.C. leachability SCTLs
3/4-methylphenol 7 62-777. for CW protection
pentachlorophenol 0.2 Florida default
acenaphthene 210 leachability SCTLs
benzo(a)anthracene 0.05 for protection of
benzo(a)pyrene 0.2 ecological
benzo(b)fluoranthene 0.05 organisms in
surface water
benzo(k)fluoranthene 0.5
chrysene 4.8
bis(2-ethylhexyl) phthalate * federal MCLs or Florida GCTLs, if the latter are
fluoranthene 280 more stringent. In addition, Florida leachability
fluorene 280 criteria for soil are relevant and appropriate for
n-nitrosodiphenylamine 7.1 protection of groundwater.
phenanthrene 210
benzene 1
benzene 5 Federal MCL
Considerable uncertainty surrounds the
derivation of clean-up goals for dioxins and
On-Site Soil (0-2 feet bls)/Sediment (mg/kg) furans, including the development of site-
pcPAHs (BaP-TEQ)* 0.7 Florida default SCTLs for specific risk-based goals, and Florida’s default
dioxins (TCDD-TEQ) 0.00003 commercial/industrial residential SCTL of 0.007 µg/kg. At present
antimony 27 land use and Florida
default leachability there is significant ongoing debate between and
arsenic 2.1 SCTLs unless Site-
chromium (total) 470
among researchers, different regulatory
specific leachability data
copper 89000 are developed during agencies, and the regulated community
lead 1400 remedial design. regarding the toxicity of dioxins/furans and
pentachlorophenol 28 whether meaningful human-health risks are
acenaphthene 2400 * Site concentrations for posed by low concentrations of these
carcinogenic polycyclic
naphthalene 300 contaminants, particularly with respect to
aromatic hydrocarbons
2-methylnaphthalene 2100 (pcPAHs) are converted
concentrations in soils. Evidence of this
fluoranthene 59000 to Benzo(a)pyrene
fluorine 33000 equivalents (BaP-TEQ) ongoing debate can be observed in the
phenanthrene 36000 before comparison with numerous comments submitted to EPA in
1,1 biphenyl 34000 the cooresponding direct response to publication of the agency’s Dioxin
exposure SCTL for
carbazole 240
Benzo(a)pyrene (see the
Science Plan, the proposed interim preliminary
dibenzofuran 6300 February 2005 “Final remediation goals (PRG) for dioxins, and the
benzene 1.2 Technical Report draft response to the National Academy of
2,4,5-trichlorophenol 130,000 Development of Cleanup
18000 Target Levels (CTLs) for
Science’s review of the Dioxin Reassessment.
2,4-dimethylphenol
3/4-methylphenol 31000 Chapter 62-777 F.A.C.” Clean-up goals for dioxins/furans used by
various state regulatory agencies and EPA vary
13

over several orders of magnitude, with Florida’s On-Site Remedies
default SCTL being at the low end of the range. The on-Site remedial alternatives focus
Florida’s SCTLs will be used as the cleanup primarily on addressing impacted groundwater
goal for dioxin-contaminated soil at the Site. and sources of contaminants in the surface soil,
Surficial Aquifer and Upper Hawthorn zones.
Remedial Alternatives Contaminant sources include residual DNAPL
Remedial alternatives were defined and or contaminants adsorbed to soil particles.
evaluated separately for three major
environmental media units of the Site (on-Site Remedy Components Common to
media [excluding UFA groundwater], off-Site Multiple On-Site Alternatives
surface soil, and UFA groundwater). The final Many of the on-Site remedial alternatives
Site remedial alternative will consist of a set of contain remedy components that are common to
three remedies: one for the on-Site media, one multiple alternatives. A description of the
for the UFA, and one for the off-Site surface common components is provided below.
soil unit. • Surface grading and covers - This remedial
component consists of re-grading much of
As part of the remedial design process which the Site and using one or more types of
follows remedy selection, additional surface covers to prevent potential direct
characterization of Site aquifers will be exposure to surface soils. The covers will
conducted to address remaining uncertainties be designed to be impermeable where
related to DNAPL migration and, more leachability and/or infiltration are a concern.
importantly, refine its vertical and horizontal The final surface cover design will be
boundaries for effective remedy consistent with the expected future land use
implementation. Off-Site soil characterization of the property.
continues to the north, south, east, and west of • Storm water rerouting and detention – This
the Site to completely delineate Site-related remedy component will be implemented in
impacts and to expedite cleanup of off-Site concert with the designed surface grading
areas. During the remedial design, an ambient and covers. Storm water controls will
air monitoring network will be installed at the consist of: (a) grading and contouring the
Site. Since the Koppers Facility closure, Beazer Site to direct runoff toward collection
East has begun interim measures to reduce dust points; (b) installation of one or more
including planting of vegetation over former detention/retention ponds; and (c) possible
operation areas. As part of Site building replacement of the existing Site storm water
demolition activities, Beazer East is ditch with another ditch or with an
implementing dust control of continuous water engineered conveyance such as an
application to suppress dust. underground concrete pipe (culvert).
• Soil consolidation area with low-
The following alternatives, developed and permeability cap/cover - This remedy
documented in the 2010 FS, must meet the component consists of placing select soils in
threshold statutory requirements of protection of a designated on-Site consolidation area
human health and the environment to address within the area encircled by a subsurface
chemical-specific, location-specific, and action- barrier wall. The soil placed within the
specific Applicable or Relevant and Appropriate consolidation area includes surface soil that
Requirements (ARARs). is removed during Site grading and soil that
is derived from construction of other remedy
components. A low-permeability cap/cover
will be constructed over the consolidation
14

area beneath the designed final surface consists of injecting a buffered solution of
cover. sodium permanganate and catalysts into the
• On-Site ex-situ soil treatment - This remedy target zone in order to: (1) chemically
component includes on-Site treatment of oxidize organic COCs; (2) form a
soils from source area excavation and/or geochemical solid through the action of the
resulting from ex-situ solidification/ reagent and the organic COCs; and (3)
stabilization implementation. It is assumed reduce the flux of COCs from residual
that soil will be treated by DNAPL into the aqueous phase by reducing
solidification/stabilization, although other aquifer transmissivity. Inclusion of ISBS as
treatment options (e.g., chemical oxidation, a remedy component includes one or more
thermal treatment, biological treatment) may pilot studies with performance criteria
be evaluated during final design. designed to demonstrate and optimize
• Barrier wall - This remedy component effectiveness as a remedy component. If
consists of installing a cement/bentonite this technology does not meet its designated
slurry wall to encircle all four primary performance criteria, ISS/S would be
source areas. The slurry wall will be implemented instead.
approximately 5,000 feet in length and will • Manual DNAPL recovery - This remedy
extend vertically from land surface to the component involves continuation of the
top of the HG middle clay, approximately 65 current program of bi-weekly DNAPL
feet deep. Other types of vertical barriers bailing from Upper Hawthorn monitor wells
(e.g., sheet pile, in-situ solidified soil HG-11S, HG-15S, HG-12S, HG-10S, and
columns, or injected grout) may be HG-16S. This activity will continue as long
considered during final design based on as DNAPL is recoverable in these wells.
geotechnical testing. • Chemical Oxidation (ChemOx)/ISBS using
• Surficial Aquifer hydraulic containment and existing HG wells - This remedy component
groundwater monitoring - This remedy involves use of existing HG monitor wells
component consists of operating the existing as treatment-injection points for either
hydraulic containment system including the ChemOx or ISBS based on contaminant
perimeter wells and the horizontal concentrations and pilot study results.
groundwater collection drains at the base of • HG groundwater monitoring - This remedy
the Surficial Aquifer near the four source component includes monitoring of Upper
areas. Periodic adjustments to operations Hawthorn and Lower Hawthorn
will be made as necessary to optimize groundwater using existing and new wells.
containment and treatment reliability. The monitoring will be used to demonstrate
• In-situ solidification/stabilization (ISS/S) of remedy performance and provide sentinel
source areas – This remedy component monitoring locations for contingent actions.
consists of applying additives, such as • Contingent actions in the HG - This remedy
cement, lime, fly ash, or polymers, to bind component includes contingent remedial
with the soil particles to reduce the mobility actions for groundwater in the HG if
of the contaminants. S/S agents can be monitoring results indicate that contaminant
applied in-situ with auger drilling/mixing concentrations are either above GCTLs and
equipment. Inclusion of ISS/S as a remedy increasing (at sentinel wells where Site
component includes one or more pilot contaminants have been detected) or begin
studies with performance criteria to provide to be detected above GCTLs at previously
an effective mix design clean sentinel wells. The expected
• In-situ biogeochemical stabilization (ISBS) contingent action for organic contaminants
of source areas – This remedy component is ChemOx using a permanganate solution.
15

ChemOx is used to chemically transform does not meet the threshold criteria necessary
organic COCs into non-toxic or immobile for a viable alternative.
substances.
• Monitored natural attenuation (MNA) - This OnR-2: Continue Current Actions with
remedy component relies on naturally Surface Grading/Covers
occurring geophysical and geochemical Estimated Capital Cost: $6.2M
processes that act on COCs to make them Approximate Annual OM&M: $ 300,000
less toxic/hazardous or less mobile. Total Net Present Value: $ 11.1M
Monitoring results are used to demonstrate Estimated Construction Timeframe: < 1 year
that these processes are occurring in the Estimated Time to Achieve RAOs: many years
subsurface at the Site. Inclusion of MNA as ARARs: action-specific and location-specific
a remedy component requires that additional ARARs are met with this alternative. The
evaluation will be performed to demonstrate remedy may not attain all chemical-specific
active natural attenuation. This evaluation ARARs within a reasonable time.
will be coordinated with any other
groundwater remedy components (e.g., This alternative includes continuing the current
hydraulic containment) to distinguish the interim remedial measures: Surficial Aquifer
effects of MNA from other groundwater groundwater extraction/treatment, groundwater
remedy technologies. monitoring and Manual DNAPL recovery. The
• Institutional controls - This on-Site remedy remedy also includes regrading and covering
component consists of deed restrictions and most of the Site. As a contingency action,
other administrative actions to limit and ChemOx would be injected if necessary to
control potential exposure to media with remediate groundwater impacted principal threat
elevated contaminant concentrations and to materials in the HG. MNA and institutional
ensure the effectiveness of engineering controls are also part of this alternative.
controls.
This alternative includes the following primary
OnR-1: No Action components:
Total Net Present Value: $ minimal • Grading of Site soil and installation of soil
Estimated Construction Timeframe: None covers and storm water controls;
Estimated Time to Achieve RAOs: > 100 years • Continued operation of the Surficial Aquifer
ARARs: Does not attain. extraction and treatment system;
• Expansion of the Surficial Aquifer and HG
Regulations governing the Superfund program monitoring network for: (1) establishment of
require the “No Action” alternative to be monitoring points; (2) demonstration of
considered. The No Action alternative is used active natural attenuation processes; and (3)
as a baseline to compare with other alternatives. establishment of trigger locations for
Under the No Action alternative, all active and contingency measures;
Manual Site activities, including groundwater • Continuation of Manual DNAPL recovery in
extraction, DNAPL collection and groundwater the Upper Hawthorn; and
monitoring, would cease. Furthermore, there • Institutional controls to mitigate risks from
would be no deed restrictions or Site security exposure to Site soil, sediment, surface
controls to prevent use of Site groundwater, water, or groundwater.
limit exposures to Site soil, or restrict certain
kinds of future development. This alternative is
retained as a basis for comparison of risk
reduction using remediation technologies and
16

OnR-3A: Removal – Surficial Aquifer • On-Site treatment of excavated soil
Excavation (solidification/stabilization or alternate
Estimated Capital Cost: $ 64.1M material management options);
Approximate Annual OM&M: $ 165,000 • Return of treated soil to the excavated areas
Total Net Present Value: $ 67.8M with use of excess treated soil as a base
Estimated Construction Timeframe: 2 years layer in cover design;
Estimated Time to Achieve RAOs: several years • Surface grading and covering for most of the
ARARs: Chemical-specific, action-specific and Site with installation of storm water
location-specific ARARs are all met with this controls;
alternative • Continued operation of the Surficial Aquifer
extraction and treatment system to verify
This alternative includes excavating the remedy effectiveness in reducing
Surficial Aquifer material in the four source contaminant flux, then shutdown of this
areas (to approximately 25 feet below surface), system;
treating the excavated soil by ex-situ • Expansion of the Surficial Aquifer and HG
solidification/stabilization, returning most of monitoring network for: (1) establishment of
this material to the excavations, and sentinel locations; (2) demonstration of
incorporating excess solidified material into active natural attenuation processes; and (3)
covers for the excavated areas. Vertical establishment of trigger locations for
retaining/barrier walls will be installed to the contingency measures; and
top of the middle clay unit of the HG to provide • Institutional controls to mitigate risks from
shoring for the excavations and to contain exposure to Site soil, sediment, surface
groundwater impacts in the Upper Hawthorn. water or groundwater.
ChemOx or ISBS (catalyzed sodium
permanganate) treatment will be applied at OnR-3B: Removal – Excavation to Middle
existing Upper and Lower HG wells in source Clay
areas. As a contingency, ChemOx will be Estimated Capital Cost: $ 190M
injected if necessary to remediate potential Approximate Annual OM&M: $ 165,000
groundwater impacts in the HG. The ChemOx Total Net Present Value: $ 193.7M
and ISBS components of this remedy will be Estimated Construction Timeframe: 3.5 years
implemented only if treatability studies Estimated Time to Achieve RAOs: several years
demonstrate successful contaminant treatment ARARs: Chemical-specific, action-specific and
and containment. location-specific ARARs are all met with this
alternative
This alternative includes the following
components: This alternative includes excavating the
• Excavation of source areas to the HG upper Surficial Aquifer material in the four source
clay; areas and in the Upper HG above the middle
• Installation of an encircling vertical clay unit (approximately 65 feet below surface),
retaining/barrier wall around each source treating the excavated soil by ex-situ
area to the HG middle clay; solidification/stabilization, returning most of
• ChemOx or ISBS treatment applied at this material to the excavations, and
existing Upper and Lower Hawthorn wells incorporating excess solidified material into
in source areas (based on acceptable covers for the excavated areas. ChemOx or
performance during pilot tests or treatability ISBS treatment will be applied at existing
studies); Lower HG wells in source areas. As a
contingency, ChemOx will be injected if
17

necessary to remediate groundwater impacts in This alternative includes in-situ solidification/
the HG. stabilization (ISS/S) of impacted soil from the
ground surface to the top of the middle clay unit
This alternative includes the following of the HG (approximately 65 feet below ground
components: surface) in the four source areas. Excess soil
• Excavation of source areas to the HG middle will be treated by ex-situ solidification/
clay with 2:1 side-slopes and vertical stabilization and used as a base layer for surface
shoring where necessary; covers. ChemOx or ISBS treatment will be
• On-Site treatment of excavated soil applied at existing Lower HG wells in source
(solidification/stabilization or alternate areas. As a contingency, ChemOx will be
material management options); injected if necessary to remediate groundwater
• Return of treated soil to the excavated areas impacts in the HG.
with use of excess treated soil as a base
layer in cover design; This alternative includes the following
• Surface grading and covering for most of the components:
Site with installation of storm water • ISS/S to the middle clay unit of the HG in
controls; the four source areas;
• Continued operation of the Surficial Aquifer • ChemOx or ISBS treatment applied at
extraction and treatment system for a period existing Lower HG wells in source areas
of time, then shutdown of this system (based on performance during pilot tests or
(source area horizontal collection drains are treatability studies);
abandoned); • Ex-situ S/S of excess soil for use as a base
• ChemOx or ISBS treatment applied at layer in cover design;
existing Lower HG wells in source areas • Surface grading and covering for most of the
(based on performance during pilot tests or Site with installation of storm water
treatability studies); controls;
• Expansion of the Surficial Aquifer and HG • Continued operation of the Surficial Aquifer
monitoring network for: (1) establishment of extraction and treatment system until such
sentinel locations; (2) demonstration of time as cleanup goals are consistently and
active natural attenuation processes, and; (3) continually met, then shutdown of this
establishment of trigger locations for system;
contingency measures; and • Expansion of the Surficial Aquifer and HG
• Institutional controls to mitigate risks from monitoring network for: (1) establishment of
exposure to Site soil, sediment, surface sentinel locations, (2) demonstration of
water or groundwater. active natural attenuation processes; and (3)
establishment of trigger locations for
OnR-4A: In-Situ Treatment – Solidification/ contingency measures; and
Stabilization to Middle Clay • Institutional controls to mitigate risks from
Estimated Capital Cost: $ 72.5M exposure to Site soil, sediment, surface
Approximate Annual OM&M: $ 165,000 water or groundwater.
Total Net Present Value: $ 78.9M
Estimated Construction Timeframe: 3 years OnR-4B: In-Situ Treatment - Solidification/
Estimated Time to Achieve RAOs: several years Stabilization and Biogeochemical
ARARs: Chemical-specific, action-specific and Stabilization
location-specific ARARs met with this Estimated Capital Cost: $ 38.1M
alternative. Approximate Annual OM&M: $ 165,000
Total Net Present Value: $ 41.8M
18

Estimated Construction Timeframe: 2.5 years establishment of trigger locations for
Estimated Time to Achieve RAOs: several years contingency measures; and
ARARs: chemical-specific, action-specific and • Institutional controls to mitigate risks from
location-specific ARARs met with this exposure to Site soil, sediment, surface
alternative. water or groundwater.

This alternative includes ISS/S of impacted soil OnR-5A: Containment/Treatment – Barrier
from ground surface to the top of the upper clay Wall
unit of the HG (approximately 25 feet below Estimated Capital Cost: $ 12.8M
ground surface) in the four source areas. Excess Approximate Annual OM&M: $ 181,000
soil will be treated by ex-situ solidification/ Total Net Present Value: $ 16.0M
stabilization and used as a base layer for surface Estimated Construction Timeframe: 1 year
covers. ISBS will be injected in Upper HG in Estimated Time to Achieve RAOs: several years
source areas. ChemOx or ISBS treatment will ARARs: chemical-specific, action-specific and
be applied at existing Lower HG wells in source location-specific ARARs met with this
areas. As a contingency, ChemOx will be alternative.
injected if necessary to remediate groundwater
impacts in the HG. This remedy is similar to This alternative is a combination of containment
remedy OnR-4A except that ISBS replaces and treatment remedies and includes installing a
ISS/S in the Upper Hawthorn. barrier wall around the DNAPL source areas to
the top of the middle clay unit of the HG. Soil
This alternative includes the following removed during the slurry wall installation will
components: be used as fill in the soil consolidation area.
• ISS/S to the upper clay unit of the HG in the ChemOx or ISBS treatment will be applied at
four source areas; existing Lower Hawthorn wells in source areas.
• ISBS in the Upper HG below the ISS/S
treatment zones (subject to acceptable The barrier wall will limit groundwater inflow
performance during pilot tests or treatability to, and outflow from, DNAPL-impacted areas.
studies); A capped soil-consolidation area will be
• ChemOx or ISBS treatment applied at established inside the barrier-wall for soil
existing Lower HG wells in source areas excavated during on- or off-Site remedy
(based on performance during pilot tests or construction and/or regrading. Outside the
treatability studies); barrier wall, surface regrading and covers will
• Ex-situ S/S of excess soil for use as a base eliminate potential exposure to soil with
layer in cover design; contaminant concentrations exceeding cleanup
• Surface grading and covering for most of the goals. Manual DNAPL recovery will continue
Site with installation of storm water at five source area wells in the Upper Hawthorn
controls; and operation of a modified version of the
• Continued operation of the Surficial Aquifer Surficial Aquifer groundwater extraction system
extraction and treatment system until such will continue until it is no longer needed.
time as cleanup goals are consistently and
continually met, then shutdown of this This alternative includes the following
system; components:
• Expansion of the Surficial Aquifer and HG • A single encircling vertical barrier wall
monitoring network for: (1) establishment of around all four source areas to the HG
sentinel locations, (2) demonstration of middle clay;
active natural attenuation processes; and (3)
19

• ChemOx or ISBS treatment applied at ISBS treatment at the base of the Upper HG.
existing Lower HG wells in source areas Excess soil will be used as fill in the soil
(based on performance during pilot tests or consolidation area. ChemOx or ISBS treatment
treatability studies); will be applied at existing Lower HG wells in
• Establishment of a capped soil-consolidation source areas. As a contingency, ChemOx will
area; be injected if necessary to remediate
• Surface grading and covering for most of the groundwater impacts in the HG. .
Site with installation of storm water
controls; The barrier wall will limit groundwater inflow
• Continued operation of the northern to (and outflow from) DNAPL-impacted areas.
perimeter wells of the Surficial Aquifer A capped soil-consolidation area will be
extraction and treatment system until such established inside the barrier-wall for excavated
time as cleanup goals are consistently and soil. Outside the barrier wall, surface regrading
continually met, then shutdown of these and covers will eliminate potential exposure to
wells; soil above cleanup goals. ISBS injections will
• Continued operation of the horizontal be placed into the Upper HG (subject to
collection drains of the Surficial Aquifer acceptable performance during pilot tests or
extraction and treatment system as needed treatability studies) to treat DNAPL and reduce
for hydraulic control; COC mobility. Operation of a modified version
• Expansion of the Surficial Aquifer and HG of the Surficial Aquifer groundwater extraction
monitoring network to: (1) establish sentinel system will continue until it is no longer needed.
locations; (2) demonstrate active natural
attenuation, and (3) establish trigger This alternative includes the following
locations for contingency measures; components:
• Continued Manual DNAPL recovery at • A single encircling vertical barrier wall
wells HG-16S, HG-10S, HG-12S, HG-15S, around all four source areas to the HG
and HG-11S; and middle clay;
• Institutional controls to mitigate risks from • Establishment of a capped soil-consolidation
exposure to Site soil, sediment, surface area;
water or groundwater. • ISBS in the Upper HG at each source area
(subject to acceptable performance during
OnR-5B: Containment/Treatment –Barrier pilot tests or treatability studies);
Wall plus In Situ Biogeochemical • ChemOx or ISBS treatment applied at
Stabilization in the Upper Hawthorn existing Lower HG wells in source areas
Estimated Capital Cost: $ 18.0M (based on acceptable performance during
Approximate Annual OM&M: $ 165,000 pilot tests or treatability studies);
Total Net Present Value: $ 20.9M • Surface grading and covering for most of the
Estimated Construction Timeframe: 16 months Site with installation of storm water
Estimated Time to Achieve RAOs: several years controls;
ARAR: chemical-specific, action-specific and • Continued operation of the northern
location-specific ARARs met with this perimeter wells of the Surficial Aquifer
alternative. extraction and treatment system until such
time as cleanup goals are consistently and
This alternative is a combination of containment continually met, then shutdown of these
and treatment remedies and includes installing a wells;
barrier wall around the DNAPL source areas to • Continued operation of the horizontal
the top of the middle clay unit of the HG and collection drains of the Surficial Aquifer
20

extraction and treatment system as needed DNAPL and reduce COC mobility. Operation
for hydraulic control; of a modified version of the Surficial Aquifer
• Expansion of the Surficial Aquifer and HG groundwater extraction system will continue
monitoring network for (1) establishment of until it is no longer needed. Note that the only
sentinel locations, (2) demonstration of difference between Alternatives OnR-5B and
active natural attenuation, and (3) OnR-5C is the depth of the ISBS treatment.
establishment of trigger locations for This alternative includes the following
contingency measures; components:
• Institutional controls to mitigate risks from • A single encircling vertical barrier wall
exposure to Site soil, sediment, surface around all four source areas to the HG
water or groundwater. middle clay;
• Establishment of a capped soil-consolidation
OnR-5C: Containment/Treatment – Barrier area;
Wall plus In Situ Biogeochemical • ISBS in the Surficial Aquifer at each source
Stabilization in the Surficial Aquifer area (subject to acceptable performance
Capital Cost and Contingency: $ 18.1M during pilot tests or treatability studies);
Annual O&M: $ 181,000 • ChemOx or ISBS treatment applied at
Total Present Worth: $ 21.3M existing Lower HG wells in source areas
Estimated Construction Timeframe: 16 months (based on acceptable performance during
Estimated Time to Achieve RAOs: several years pilot tests or treatability studies);
ARARs: chemical-specific, action-specific and • Surface grading and covering for most of the
location-specific ARARs met with this Site with installation of storm water
alternative. controls;
• Continued operation of the northern
This alternative is a combination of containment perimeter wells of the Surficial Aquifer
and treatment remedies and includes installing a extraction and treatment system until such
barrier wall around the DNAPL source areas to time as cleanup goals are consistently and
the top of the middle clay unit of the HG and continually met, then shutdown of these
ISBS treatment of the Surficial Aquifer in wells;
source areas. The excess soil will be used as fill • Continued operation of the horizontal
in the soil consolidation area. ChemOx or ISBS collection drains of the Surficial Aquifer
treatment will be applied at existing Lower HG extraction and treatment system as needed
wells in source areas. As a contingency, for hydraulic control;
ChemOx will be injected if necessary to • Expansion of the Surficial Aquifer and HG
remediate groundwater impacts in the HG. monitoring network for: (1) establishment of
sentinel locations; (2) demonstration of
The barrier wall will limit groundwater inflow active natural attenuation processes; and (3)
to, and outflow from, DNAPL-impacted areas. establishment of trigger locations for
A capped soil-consolidation area will be contingency measures;
established inside the barrier-wall extents for • Continued Manual DNAPL recovery at
excavated soil. Outside the barrier wall, surface wells HG-16S, HG-10S, HG-12S, HG-15S,
regrading and covers will eliminate potential and HG-11S; and
exposure to soil with contaminant • Institutional controls to mitigate risks from
concentrations above cleanup goals. ISBS exposure to Site soil, sediment, surface
injections will be placed into the Surficial water or groundwater.
Aquifer (based on acceptable performance
during pilot tests or treatability studies) to treat
21

OnR-5D: Containment/Treatment – Barrier • ISS/S to the upper clay unit of the HG in the
Wall plus In Situ Solidification/ Stabilization four source areas;
in the Surficial Aquifer • ChemOx or ISBS treatment applied at
Capital Cost and Contingency: $ 35.7M existing Upper and Lower HG wells in
Annual O&M: $ 165,000 source areas;
Total Present Worth: $ 38.7M • Establishment of a capped soil-consolidation
Estimated Construction Timeframe: 2.5 years area;
Estimated Time to Achieve RAOs: several years • Surface grading and covering for most of the
ARARs: chemical-specific, action-specific and Site with installation of storm water
location-specific ARARs met with this controls;
alternative. • Continued operation of the northern
perimeter wells of the Surficial Aquifer
This alternative is a combination of containment extraction and treatment system until such
and treatment technologies and includes time as cleanup goals are consistently and
installing a barrier wall around the DNAPL continually met, then shutdown of these
source areas to the top of the middle clay unit of wells;
the HG and ISS/S treatment of the Surficial • Continued operation of the horizontal
Aquifer. Excess soil will be used as fill in the collection drains of the Surficial Aquifer
soil consolidation area. ChemOx or ISBS extraction and treatment system as needed
treatment will be applied at existing Upper and for hydraulic control;
Lower HG wells in source areas. As a • Expansion of the Surficial Aquifer and HG
contingency, ChemOx will be injected if monitoring network for: (1) establishment of
necessary to remediate groundwater impacts in sentinel locations,;(2) demonstration of
the HG. active natural attenuation processes; and (3)
The barrier wall will limit groundwater inflow contingency measures; and
to, and outflow from, DNAPL-impacted areas. • Institutional controls to mitigate risks from
A capped soil-consolidation area will be exposure to Site soil, sediment, surface
established inside the barrier-wall extents for water or groundwater.
excavated soil and excess soil from ISS/S
implementation. Outside the barrier wall, OnR-5E: Containment/Treatment – Barrier
surface regrading and covers will eliminate Wall plus In Situ Biogeochemical
potential exposure to soil with contaminant Stabilization in the Surficial Aquifer and
concentrations that result in estimated potential Upper Hawthorn
risks that exceed applicable risk limits. ISS/S Capital Cost and Contingency: $ 26.1M
mixing will take place in the Surficial Aquifer to Annual O&M: $ 165,000
treat DNAPL and reduce COC mobility. Total Present Worth: $ 29.1M
Operation of a modified version of the Surficial Estimated Construction Timeframe: 2 years
Aquifer groundwater extraction system will Estimated Time to Achieve RAOs: several years
continue until it is no longer needed. ARARs: chemical-specific, action-specific and
location-specific ARARs met with this
This alternative includes the following alternative.
components:
• A single encircling vertical barrier wall This alternative is a combination of containment
around all four source areas to the HG and treatment technologies and includes
middle clay; installing a barrier wall around the DNAPL
source areas to the top of the middle clay unit of
22

the HG and ISBS treatment of the Surficial extraction and treatment system until such
Aquifer and Upper Hawthorn in source areas. time as cleanup goals are consistently and
Excess soil will be used as fill in the soil continually met, then shutdown of these
consolidation area. ChemOx or ISBS treatment wells;
will be applied at existing Lower Hawthorn • Continued operation of the horizontal
wells in source areas. As a contingency, collection drains of the Surficial Aquifer
ChemOx will be injected if necessary to extraction and treatment system as needed
remediate groundwater impacts in the HG. for hydraulic control;
• Expansion of the Surficial Aquifer and HG
The barrier wall will limit groundwater inflow monitoring network for: (1) establishment of
to, and outflow from, DNAPL-impacted areas. sentinel locations; (2) demonstration of
A capped soil-consolidation area will be active natural attenuation processes; and (3)
established inside the barrier-wall for excavated establishment of trigger locations for
soil. Outside the barrier wall, surface regrading contingency measures;
and covers will eliminate potential exposure to • Institutional controls to mitigate risks from
soil with contaminant concentrations above exposure to Site soil, sediment, surface
cleanup goals. ISBS injections will be placed water or groundwater.
into the Surficial Aquifer and Upper HG
(subject to acceptable performance during pilot OnR-5F: Containment/Treatment – Barrier
tests or treatability studies) to treat DNAPL and Wall plus In Situ Solidification/Stabilization
reduce COC mobility. Operation of a modified in the Surficial Aquifer and Upper Hawthorn
version of the Surficial Aquifer groundwater Capital Cost and Contingency: $ 71.8M
extraction system will continue until it is no Annual O&M: $ 165,000
longer needed. Note that the only difference Total Present Worth: $ 74.8M
between OnR-5E and remedies OnR-5B and Estimated Construction Timeframe: 3 years
OnR-5C is the depth of the ISBS treatment. Estimated Time to Achieve RAOs: several years
ARARs: chemical-specific, action-specific and
This alternative includes the following location-specific ARARs met with this
components: alternative.
• A single encircling vertical barrier wall
around all four source areas to the HG This alternative is a combination of containment
middle clay; and treatment technologies and includes
• Establishment of a capped soil-consolidation installing a barrier wall around the DNAPL
area; source areas to the top of the middle clay unit of
• ISBS in the Surficial Aquifer and Upper the HG and ISS/S treatment of the Surficial
Hawthorn at each source area (based on Aquifer and Upper Hawthorn. Excess soil will
performance during pilot tests or treatability be used as fill in the soil consolidation area.
studies); ChemOx or ISBS treatment will be applied at
• ChemOx or ISBS treatment applied at existing Lower Hawthorn wells in source areas.
existing Lower Hawthorn wells in source As a contingency, ChemOx will be injected if
areas (based on acceptable performance necessary to remediate groundwater impacts in
during pilot tests or treatability studies); the HG.
• Surface grading and covering for most of the
Site with installation of storm water The barrier wall will limit groundwater inflow
controls; to, and outflow from, DNAPL-impacted areas.
• Continued operation of the northern A capped soil-consolidation area will be
perimeter wells of the Surficial Aquifer established inside the barrier-wall for excavated
23

soil and excess soil from ISS/S implementation. OnR-5G: Containment/Treatment – Barrier
Outside the barrier wall, surface regrading and Wall plus In Situ Solidification/Stabilization
covers will eliminate potential exposure to soil in the Surficial Aquifer and In Situ
with contaminant concentrations above cleanup Biogeochemical Stabilization in the Upper
goals. ISS/S mixing will take place in the Hawthorn
Surficial Aquifer and Upper HG to treat Capital Cost and Contingency: $ 40.7M
DNAPL and reduce COC mobility. Operation Annual O&M: $ 165,000
of a modified version of the Surficial Aquifer Total Present Worth: $ 43.6M
groundwater extraction system will continue Estimated Construction Timeframe: 3 years
until it is no longer needed. Estimated Time to Achieve RAOs: several years
ARARs: chemical-specific, action-specific and
This alternative includes the following location-specific ARARs met with this
components: alternative.
• A single encircling vertical barrier wall
around all four source areas to the HG This alternative is a combination of containment
middle clay; and treatment technologies and includes
• ISS/S to the middle clay unit of the HG in installing a barrier wall around the DNAPL
the four source areas; source areas to the top of the middle clay unit of
• ChemOx or ISBS treatment applied at the HG, ISS/S treatment of the Surficial
existing Lower Hawthorn wells in source Aquifer, and ISBS treatment of the Upper
areas (based on performance during pilot Hawthorn. Excess soil will be used as fill in the
tests or treatability studies); soil consolidation area. ChemOx or ISBS
• Establishment of a capped soil-consolidation treatment will be applied at existing Lower
area; Hawthorn wells in source areas. As a
• Surface grading and covering for most of the contingency, ChemOx will be injected if
Site with installation of storm water necessary to remediate groundwater impacts in
controls; the HG.
perimeter wells of the Surficial Aquifer The barrier wall will limit groundwater inflow
extraction and treatment system until such to, and outflow from, DNAPL-impacted areas.
time as cleanup goals are consistently and A capped soil-consolidation area will be
continually met, then shutdown of these established inside the barrier-wall extents for
wells; excavated soil and excess soil from ISS/S
• Continued operation of the horizontal implementation. Outside the barrier wall,
collection drains of the Surficial Aquifer surface regrading and covers will eliminate
extraction and treatment system as needed potential exposure to soil with contaminant
for hydraulic control; concentrations that result in estimated potential
• Expansion of the Surficial Aquifer and HG risks that exceed applicable risk limits. ISS/S
monitoring network for: (1) establishment of mixing will take place in the Surficial Aquifer to
sentinel locations; (2) demonstration of treat DNAPL and reduce COC mobility. ISBS
active natural attenuation processes; and (3) injections will be placed into the Upper HG
establishment of trigger locations for (subject to acceptable performance during pilot
contingency measures; and tests or treatability studies) in source areas to
• Institutional controls to mitigate risks from treat mass in that unit and create a barrier to
exposure to Site soil, sediment, surface vertical flow. The combination of ISS/S and
water or groundwater. ISBS is similar to alternative OnR-4B.

24

Operation of a modified version of the Surficial the three elements eliminates the potential
Aquifer groundwater extraction system will exposure pathway and achieves the goal of
continue until it is no longer needed. mitigating the environmental hazard. The other
goal required by CERCLA is restoration of the
This alternative includes the following resource to the maximum extent practicable
components: within a reasonable timeframe. Two viable
• A single encircling vertical barrier wall approaches meet these goals:
around all four source areas to the HG
middle clay; • Treating UFA groundwater in-situ or ex-
• ISS/S to the upper clay unit of the HG in the situ.
four source areas; • Removing the groundwater migration
• ISBS in the Upper HG in the four source pathway. Currently, the potential migration
areas (below the treated ISS/S soil) (subject pathways from the Surficial Aquifer to the
to acceptable performance during pilot tests UFA are not known definitively.
or treatability studies);
• ChemOx or ISBS treatment applied at The most viable strategy for addressing the
existing Lower HG wells in source areas UFA groundwater impacts is in-situ treatment
(subject to acceptable performance during (including natural attenuation processes) or ex-
pilot tests or treatability studies); situ treatment of groundwater with elevated
• Establishment of a capped soil-consolidation levels of contaminants.
area;
• Surface grading and covering for most of the Sentinel wells will be established in the UFA to
Site with installation of storm water ensure that groundwater concentrations do not
controls; exceed Federal drinking-water standards at
• Continued operation of the northern points outside of areas where waste is managed
perimeter wells of the Surficial Aquifer in place (e.g. outside the vertical barrier
extraction and treatment system for a period containment zone).
of time, then shutdown of these wells;
• Continued operation of the horizontal UFA-1: No Action
collection drains of the Surficial Aquifer Total Net Present Value: $ minimal
extraction and treatment system as needed Estimated Construction Timeframe: None
for hydraulic control; Estimated Time to Achieve RAOs: > 100 years
• Expansion of the Surficial Aquifer and HG ARARs: None.
monitoring network for (1) establishment of
sentinel locations, (2) demonstration of Regulations governing the Superfund program
active natural attenuation processes, and (3) generally require the “No Action” alternative be
establishment of trigger locations for considered. The No Action alternative is used
contingency measures; and as a baseline to compare other alternatives.
• Institutional controls to mitigate risks from Under the No Action alternative, the existing
exposure to Site soil, sediment, surface groundwater monitoring in the UFA would
water or groundwater. cease. There would be no restrictions on
groundwater use, and no monitoring would be
Upper Floridan Aquifer Remedies performed to evaluate whether contaminant
The potential risk associated with impacted concentrations above the cleanup goals were
UFA groundwater is addressed by disrupting the migrating beyond the containment area. This
linkage between contaminant, transport alternative is retained as a basis for comparison
pathway, and receptor. Removing any one of
25

of risk reduction using remediation • Evaluation and demonstration of natural
technologies. attenuation processes occurring in the UF
aquifer, in support of active remedial action.
UFA-2: Hydraulic Containment • Additional in situ remedial actions if the
supplemented by Institutional Controls and primary remedy components (i.e., hydraulic
Monitored Natural Attenuation containment, institutional controls, and
Annual O&M: $ 100,000 supplemental MNA) do not adequately
Total Present Worth: $ 1.5M address contamination in the UF aquifer.
Estimated Construction Timeframe: < 1 year
Estimated Time to Achieve RAOs: many years Off-Site Remedies
ARARs: chemical-specific, action-specific and Off-Site Soils posing an unacceptable risk will
location-specific ARARs met with this be addressed by removing potentially complete
alternative. exposure pathways. Removing one of the links
in the exposure pathway chain mitigates the
This remedy consists of a combination of two environmental hazard. To achieve the remedial
technologies: (1) targeted groundwater action objectives, any of the following could be
extraction for groundwater containing higher done to disrupt the potential exposure pathway:
and more persistent contaminant concentrations;
and (2) institutional controls and natural 1. Treating contaminants in surface soil in-situ
attenuation (for relatively low and isolated or ex-situ.
concentrations exceeding GCTLs or the MCL 2. Covering impacted soil in place with an
[benzene only]). Furthermore, if contaminant engineered cover or preventing activities
concentrations in UFA groundwater reach that may result in exposure through an
pertinent action levels, additional in situ remedy engineered control, such as a fence.
actions will be initiated. 3. Change land use to prevent contact with
impacted soil.
This alternative includes the following
components: All of these possible strategies are potentially
• Continuation of quarterly collection of practical approaches for certain off-Site areas,
groundwater samples from monitor wells, depending on land use, property-owner
and analysis of samples for Site-related preferences, and estimated potential risks. Land
organic contaminants; use surrounding the Site consists of both
• Continuation/expansion of the UFA residential and commercial properties. Florida
groundwater extraction/ex-situ treatment risk-based corrective action (RBCA) standards
system, initially using existing wells FW-6 allow for a combination of approaches for
and FW-21B, along with the recently- eliminating potential exposures to contaminants
installed extraction well FW-31BE (near in off-Site soils.
FW-22B);
• As needed, installation of additional high The total area and volume of off-Site surface
capacity groundwater extraction wells for soil requiring remediation is still being
inclusion in the UFA groundwater determined through ongoing sampling.
extraction/ex-situ treatment system to Therefore, the descriptions of off-Site remedies
establish/maintain containment; and are conceptual in nature, allowing flexibility in
• Institutional controls to prevent UFA the actual extent of properties to be remediated.
groundwater extraction for potable use at the
Site or anywhere where cleanup goals for For areas identified requiring remediation, each
Site-related contaminants are exceeded. affected private property owner will be
26

contacted by the PRP to discuss the best OfR-3: Institutional and Engineering
approaches to address the soil impacts on their Controls
private property. Cost and Timeframe: Since soil volume and the
OfR-1: No Action specific approach chosen by property owners
Total Net Present Value: $ minimal are unknown at this time, cost and remediation
Estimated Construction Timeframe: None timeframe for this alternative are unknown. This
Estimated Time to Achieve RAOs: > 100 years portion of the overall Site remedy is being
ARAR: None. expedited.
ARARs: chemical-specific, action-specific, and
Regulations governing the Superfund program location-specific ARARs are met with this
generally require the “No Action” alternative be alternative.
considered. The No Action alternative is used
as a baseline to compare other alternatives. This remedy includes administrative and/or
Under the No Action alternative, there would be engineering actions intended to prevent
no restrictions on land-use in the residential area exposure to impacted soil. Both institutional
west of the facility, and no actions would be and engineering controls would be applied in a
implemented to mitigate contaminant way that reduces or eliminates exposure to
concentrations in the soil. This alternative is surface soil in the affected area.
included as a baseline to evaluate other
alternatives. Since the alternative does not The components of this remedy are (1)
address the risks posed by the soil, it is not a institutional controls designed to prevent people
viable option. from using or disturbing soil posing potentially
unacceptable risk and (2) engineering controls
OfR-2: Remove Impacted Soil to prevent receptors from potentially contacting
Cost and Timeframe: Since soil volume and the impacted soil.
specific approach chosen by property owners
are unknown at this time, cost and remediation OfR-4: Removal, Institutional Controls,
timeframe for this alternative are unknown. and/or Engineering Controls (Hybrid)
This portion of the overall Site remedy is being Cost and Timeframe: Since soil volume and the
expedited. specific approach chosen by property owners
ARARs: chemical-specific and location-specific are unknown at this time, cost and remediation
ARARs are met with this alternative. timeframe for this alternative are unknown. This
portion of the overall Site remedy is being
This remedy consists of excavating the surface expedited.
soil in areas surrounding the Site determined to ARARs: chemical-specific, action-specific, and
exceed Florida’s allowable risk limit or the location-specific ARARs are met with this
default SCTLs and replacement with clean fill; alternative.
and revegetation.
This remedy consists of a combination of
Excavated soil may be addressed in one of three targeted soil excavation and application of
ways: (1) excavated soil may be transported off- engineering and administrative controls. The
Site to a permitted disposal facility; (2) distinction between soil to be excavated and soil
excavated soil may be consolidated with on-Site to be addressed by institutional and engineering
soil and covered under the engineered cover controls will be based on contaminant
within the facility property; and (3) excavated concentration(s), and parcel land use (present
soil may be used as raw material for and future). This strategy allows maximum
constructing the on-Site engineered surface cap. flexibility in applying excavation or controls to
27

soils that do not meet Florida’s allowable risk mobility, or volume; and (4) short-term
(1X10-6) or default SCTLs. effectiveness. The fifth primary balancing
criterion, cost, is evaluated based on cost
The components of this remedy include (1) estimates
excavation of surface soil, (2) institutional
controls on properties and areas not excavated, 3. Long-Term Effectiveness
and/or (3) engineering controls that act as A remedial action will be effective in the long
physical barriers to contacting impacted soil. term if it results in permanent reductions of
potential risk to acceptable levels. Potential risk
Alternative Evaluation reduction may occur by eliminating potential
Superfund’s nine criteria are used to evaluate exposure to impacted media, preventing
different remediation alternatives individually potential migration of COCs in groundwater,
and against one another in order to select a and eliminating principle threat sources (e.g.
remedy. This section of the Plan profiles the DNAPL) downward movement.
relative performance of each alternative against
the nine criteria, noting how it compares to In comparing on-Site remedies for effectiveness
other options under consideration. The nine in the long-term, the most protective alternatives
evaluation criteria are discussed below. To be combine containment and treatment
retained as a viable alternative, the two components: OnR-5B, OnR-5C, OnR-5D, OnR-
threshold criteria must be met. Alternatives 5E, OnR-5F, and OnR-5G. Alternatives with
were evaluated by the degree and certainty to single remedy components such as removal,
which the criteria are met through assessment of treatment, or containment are rated as less
specific objectives for each of the first four protective in the long-term: OnR-3A, OnR-3B,
balancing criteria. Finally, the two modifying OnR-4A, OnR-4B, and OnR-5A. Alternative
criteria of State and community acceptance are OnR-2 is protective with limitations, and the No
being evaluated through the public involvement Action alternative is not effective.
of this Proposed Plan. A detailed analysis of
alternatives, as well as information about the 4. Implementability
evaluation process can be found in the FS. Implementing remedial alternatives involves
design, planning, construction or installation,
On-Site Alternative Evaluation and operation of the various components of
1 and 2. Protection of Human Health and the remedial actions. The efficiency with which an
Environment and Compliance with Statutory alternative can be installed and operated affects
Requirements how well an alternative achieves its level of
The two threshold CERCLA criteria are: protection (the first threshold criterion) and
Protection of Human Health and the attains ARARs (the second threshold criterion).
Environment and Compliance with ARARs. In some cases, implementation of the alternative
could be technically difficult or impossible
Nine of the ten on-Site alternatives are expected given Site-specific limitations.
to meet the two threshold CERCLA criteria.
Only the No-Action Alternative (Alternative A remedial alternative is judged to be
SWA-1) would fail to meet these mandatory implementable if it ranks highly for the
criteria. The other nine alternatives (Alternative following seven objectives:
SWA-2 through Alternative SWA-5D) are • Constructability;
compared using four of the five primary • Ease of operation and maintenance;
balancing criteria: (1) long-term effectiveness; • Reliability of technologies;
(2) implementability; (3) reduction of toxicity,
28

• Ease of undertaking additional remedial
actions if necessary; Alternatives that result in removal of the largest
• Ability to monitor remediation mass of contaminated media achieve the
effectiveness; greatest reduction in TMV. Alternative OnR-
• Ability to obtain technology-implementation 3B would result in nearly all on-Site
approvals (e.g., confirmation that contaminant mass being treated. A great
substantive permit requirements have been majority of contaminated mass would be treated
met) from regulatory agencies as necessary; with alternatives OnR-4A, OnR-4B, OnR-5E,
and OnR-5F, and OnR-5G. A lesser volume of
• Availability of services and materials. contaminated mass would be treated with
alternatives OnR-3A, OnR-5C, and OnR-5D.
The most implementable alternatives are OnR-2, Only some of the contaminant mass would be
OnR-5A, OnR-5B, OnR-5C, and OnR-5E. treated with OnR-5B, and minor amounts would
These are primarily the most easily be reduced through natural processes with OnR-
implemented alternatives because they are in- 2 and OnR-5A.
situ technologies and because ISBS is more
easily implemented than ISS/S. The following 6. Short-Term Effectiveness
in-situ alternatives are rated the next most Short-term effectiveness of remedial alternatives
implementable: OnR-4A, OnR-4B, OnR-5D, relates to how well an alternative achieves a
OnR-5F, and OnR-5G. Alternatives requiring level of protection of human health and the
soil removal are more challenging: OnR-3A and environment (the first threshold criterion) and
OnR-3B. attains ARARs (the second threshold criterion)
during implementation or installation of the
5. Reduce Toxicity, Mobility, or Volume remedial alternative.
Alternatives that reduce mobility, toxicity, and
volume (TMV) in some way must (a) slow the Short-term effectiveness is evaluated by
migration of contaminants by lowering considering the following four objectives:
concentration gradients within the media, or • Protection of the community during
increase the strength of attachment to some remediation;
solid substrate; (b) chemically alter the toxicity • Protection of remediation workers during
characteristics of the original contaminant or remediation;
prevent receptors from being exposed to toxic • Protection against short-term environmental
doses of the contaminant; and (c) reduce the impacts; and
mass of contaminant(s) or the volume of • Minimization of time to complete remedy
environmental media associated with the construction.
contaminant(s).
Continuing current actions (OnR-2) with soil
Three objectives are used to evaluate each regarding/cover would be implemented the most
alternative with respect to reduction of TMV quickly. Alternative OnR-5A would be
through treatment: effective the next most quickly and alternatives
• Volume of potential source material treated onR-5B and OnR-5C would be effective within
or destroyed (and degree of TMV months. Alternatives OnR-3A, OnR-4B, OnR-
reduction); 5D, and OnR-5G would require a lengthy
• Irreversibility of treatment; and implementation time before being effective.
• Minimization of treatment residuals posing Alternatives OnR-3B, OnR-4A, OnR-5E, and
potential risks. OnR-5F require the longest implementation
times before they are effective.
29

7. Cost supplemented by institutional controls and
Cost is an important factor; the added benefits MNA, meets the two threshold CERCLA
of alternatives with higher costs should be criteria. It is assumed that Alternative UFA-2 is
weighed carefully to determine whether the selected as the remedial alternative for the UFA.
benefits are worth the cost.
3. Long-Term Effectiveness
The No Action alternative is not included in this The more effective of the two UF alternatives
analysis because, although it represents the (in the long-term) is UFA-2. It consists of
lowest cost alternative, it provides no protection hydraulic containment (to prevent expansion of
to receptors and achieves no RAOs. The lowest the plume of dissolved contaminants) and
cost alternative is OnR-2 (continue with current treatment (of recovered groundwater to meet
actions with soil regrading/cover). Although disposal requirements). Hydraulic containment
this alternative cost is the lowest, it is not as and treatment will be evaluated for effectiveness
protective and does not treat as much and long-term institutional controls, MNA and
contaminant mass as other alternatives. other in situ remedial actions will be
Alternately, the highest cost alternative (OnR- implemented to the extent necessary to meet the
3B, removal to middle clay) treats nearly all of RAO. The No Action alternative (UFA-1) is less
the on-Site contaminant volume and is protective in the long-term.
protective, but is likely cost prohibitive. The
remaining alternatives differ in cost, but costs 4. Implementability
vary more narrowly based on the number of UFA-1 is easiest to implement because there is
technologies implemented, the degree of no remedial action involved. UFA-2 can be
difficulty in implementation, and time to meet implemented at this site; groundwater extraction
RAOs. and ex situ treatment are a proven technologies.
Access to the UF aquifer is restricted only by
8. State/Support Agency Acceptance the concern of creating new migration pathways
The State of Florida has been closely involved between it and contaminated aquifers above it.
in the development and evaluation of these Institutional controls and MNA are well-
alternatives and supports the preferred established remedy components.
alternative.
5. Reduce Mobility, Toxicity or Volume
9. Community Acceptance Alternatives that result in removal of the largest
Community acceptance of the preferred mass of contaminated media achieve the
alternative will be evaluated after the public greatest reduction in T/M/V. Alternative UFA-
comment period and will be part of the 2 achieves some mass removal from the UF
Responsive Summary in the ROD Amendment aquifer through a combination of extraction and
for the Site. ex situ treatment.

UFA Alternative Evaluation 6. Short-Term Effectiveness
1 and 2. Protection of Human Health and the Short-term effectiveness of remedial alternatives
Environment and Compliance with Statutory relates to how well an alternative achieves a
Requirements level of protection of human health and the
UFA-1 (the No-Action Alternative) would fail environment (the first threshold criterion) and
to meet these mandatory criteria; therefore it can attains ARARs (the second threshold criterion)
not be selected as a preferred remedy. Of the during implementation or installation of the
two UFA alternatives considered in the FS, only remedial alternative.
Alternative UFA-2, Hydraulic Containment
30

UFA-1 (No Action) is effective by default potentially unacceptable risks due to direct
because no remedial construction activity contact with contaminated soil. Alternative
occurs. Remedy components of UFA-2 OfR-4 allows for a flexible approach that may
primarily are in situ (except for ex situ include institutional and/or engineering controls
groundwater treatment); and would be on properties which are suitable for such
protective of human health and the environment controls, and have owners that are amenable to
in the short term. such controls.

7. Cost 3. Long-Term Effectiveness
The No Action alternative is not included in this OfR-1 (No Action) is not effective at addressing
analysis because, although it represents the contaminated soil. The other off-Site remedies
lowest cost alternative, it provides no protection are effective under different scenarios. The
to receptors and achieves no RAOs. Accurate removal component of OfR-2 is effective in the
cost estimation of UFA-2 depends on factors long-term because contamination no longer
such as total volume of groundwater extracted remains. The effectiveness of institutional and
over the entire remedy lifetime; extent of engineering controls through OfR-3 depends on
treatment needed for extracted groundwater; the voluntary compliance. In the long-term, this
need for additional extraction wells; the pump remedy is less dependable than the removal
rate required to maintain hydraulic containment; component of OfR-2. Remedy OfR-4 benefits
and whether additional remedial action is from the strengths of both OfR-2 and OfR-3.
triggered based on performance of the primary
remedial components. These factors, among 4. Implementability
others, represent significant unknowns in the All four off-Site remedies are implementable.
estimation of remedial costs of UFA-2. Soil excavation, institutional controls and
engineering controls are well developed
8. State/Support Agency Acceptance remedial techniques. The limitation to
The State of Florida has been closely involved implementing any off-Site option will be
in the development and evaluation of these property owner concurrence and cooperation.
alternatives and supports the preferred
alternative. 5. Reduce Toxicity, Mobility or Volume
Remedies that remove the most contaminant
9. Community Acceptance mass achieve the greatest reduction in T/M/V.
Community acceptance of the preferred UFA Although technically not a treatment, removal
alternative will be evaluated after the public remedy OfR-2 and the removal component of
comment period. The results of that evaluation OfR-4 eliminates contaminant mass from off-
will be part of the Responsive Summary in the Site surface soil. OfR-1 and OfR-3 do not
ROD amendment for the Site. achieve any T/M/V reduction.

Off-Site Alternative Evaluation 6. Short-Term Effectiveness
1 and 2. Protection of Human Health and the Short-term effectiveness of remedial alternatives
Environment and Compliance with Statutory relates to how well an alternative achieves a
Requirements level of protection of human health and the
Remedy OfR-1, no action, does not meet the environment (the first threshold criterion) and
threshold criteria of protection of human health attains ARARs (the second threshold criterion)
and the environment and attainment of ARARs. during implementation or installation of the
Alternatives OfR-2, OfR-3, and OfR-4 are all remedial alternative.
protective and would effectively eliminate any
31

OfR-1 (No Action) is effective in the short term Preferred Alternative
by default because no remedial activity occurs. The alternative preferred by EPA includes the
Remedy OfR-3 is effective in the short term following:
because little to no disturbance occurs during
implementation. In contrast, the removal On-Site Media: OnR-5C with elements of
components of OfR-2 and OfR-4 involve OnR-5F
substantial soil excavation and potential • A single, continuous vertical barrier wall
increases in exposure to contaminated soil. (~4,800 linear ft) encircling all four source
areas from land-surface to the HG middle
7. Cost clay (~ 65 ft bls)
Cost is an important factor; the added benefits • ISS/S in the Upper HG zone at all four
of alternatives with higher costs should be source areas (below the Surficial Aquifer
weighed carefully to determine whether the and Upper Hawthorn Clay)
benefits are worth the cost. • ISBS in the vadose-zone and Surficial
Aquifer at all four source areas (subject to
OfR-1 is not included in the cost criterion acceptable performance during pilot tests or
evaluation because, although it represents the treatability studies). In the event that ISBS
lowest cost alternative, it provides no protection does not meet its performance criteria, ISS/S
to receptors and achieves no RAOs. Accurate will be implemented as a substitute remedy
cost estimation of the removal component of for this contaminant zone.
OfR-2 and OfR-4 depends on factors such as • ChemOx or ISBS treatment in the Lower
total volume of surface soil excavated from off- HG at all four source areas (applied through
Site contaminated areas and the level of existing wells), and along the eastern
property owner participation. These factors, property boundary (applied through new
among others, represent significant unknowns in wells) (based on performance during pilot
the cost estimation of soil removal in OfR-2 and tests or treatability studies).
OfR-4, but are already the highest cost • Excavation of areas of contaminated soil in
components of the respective alternatives. The non-source areas on-site; consolidation of
institutional and engineering control excavated soil to source areas to be capped
components of OfR-3 and OfR-4 are more • Establishment of a low-permeability
easily estimated, but they contribute a small cap/cover over all four source areas,
portion of the likely total remedial cost for those including the consolidated soil excavated
remedies. from non-source areas (on-site or off-site)
• Surface grading and cap covers on
8. State/Support Agency Acceptance approximately 83 of 86 acres on the Site
The State of Florida has been closely involved property.
in the development and evaluation of these • Installation of storm water controls and
alternatives and supports the preferred improvements (e.g., retention/ detention
alternative. pond)
9. Community Acceptance perimeter wells of the Surficial Aquifer
Community acceptance of the preferred off-Site extraction and treatment system (outside of
remedy will be evaluated after the public the vertical barrier zone); decommission
comment period. The results of that evaluation extraction/treatment system after cleanup
will be part of the Responsive Summary in the goals are attained
ROD Amendment for the Site. • Continued operation of the horizontal
collection drains of the Surficial Aquifer
32

extraction and treatment system as needed effects concentration (transport and
for hydraulic control. consolidate on-site)
• Expansion of the Surficial Aquifer and HG – Monitored natural recovery of remaining
monitoring network for: (1) establishment of impacted sediment until concentrations
sentinel locations; (2) demonstration of reach threshold effects concentration or
active natural attenuation processes; and (3) background levels
contingency measures. Upper Floridan Groundwater: UFA-2
• Institutional controls to mitigate risks from • Hydraulic containment by groundwater
exposure to Site soil, sediment, surface extraction and treatment in areas where
water or groundwater. COCs exceed cleanup goals.
• Construction of additional extraction wells
Alternative OnR-5C was not selected as for the network, as necessary.
presented in the FS because a more aggressive • MNA in areas where concentrations of
option was desired for the Upper HG COCs do not exceed cleanup goals (subject
contamination. For this reason, the ISS/S to demonstration of active natural
component from OnR-5F was included in the attenuation processes).
preferred alternative.
Community Participation
EPA provides information to the community
For the on-Site portion of the remedy the regarding Site cleanup through fact sheets,
estimated costs are as follows: public meetings, local Site information
Capital Cost and Contingency: $ 40.8M repository, and the Administrative Record file.
Annual O&M: $ 165,000
Total Present Worth: $ 43.7M EPA and FDEP encourage the public to learn
more about the Cabot Carbon/Koppers Site and
Off-Site Media: OfR-4 Superfund activities that have been conducted at
• Range of options for off-Site soil for use on the Site by visiting the Site information
individual subparcels with consent of private repositories listed on the front page of this
property owners: Proposed Plan.
– Excavation and removal of impacted soil
that exceeds cleanup goals based on
present land use (transported and
consolidated within capped areas on-
Site).
– Engineering controls that prevent contact
with impacted soil that exceeds cleanup
goals based on present land use.
– Institutional controls to manage access
and use of land/properties.
• Surface water and sediment in Hogtown and
Springstead Creeks:
– On-site detention basin to mitigate on-
going impacts
– Excavation and removal of impacted
sediment in excess of the probable

33

Public Meeting Mailing List
The public meeting for the Cabot Carbon/ Anyone wishing to be placed on the mailing list
Koppers Superfund Site will be held on August for this Site should send his/her request to Ms.
5, 2010 at Stephen Foster Elementary School, LaTonya Spencer, EPA Community
3800 Northwest 6th Street, Gainesville, Florida Involvement Coordinator, at the above address.
32609 You may also call Ms. Spencer with your
request at 1-800-435-9234 or 404-562-8463

Written Comments Information Repositories
Written comments on this Proposed Plan will be Information concerning the Cabot Carbon/
accepted until August 15, 2010, and should be Koppers Superfund Site may be found at the
mailed to: following location:

Mr. Scott Miller Alachua County Library
Remedial Project Manager 401 E. University Ave.
Superfund Division Gainesville, FL 32601
Superfund Remedial Branch (352) 334-3860
Section C www.aclib.us/locations/headquarters
U.S. EPA Region 4
61 Forsyth Street, SW
Atlanta, GA 30303

34

GLOSSARY
Administrative Record: Material documenting EPA's National Oil and Hazardous Substance Pollution
selection of cleanup remedies at Superfund Sites, usually Contingency Plan (NCP): The Federal Regulation that
placed in the information repository near the Site. guides the Superfund program. The NCP was revised in
February 1990.
Applicable or Relevant and Appropriate Requirements
(ARARs): Refers to Federal and State requirements a Operation and Maintenance (O&M): Activities conducted
selected remedy must attain which vary from Site to Site. at Sites after cleanup remedies have been constructed to
ensure that they are properly functioning.
Chemicals of Concern (COCs): Contaminants associated
with a Site which have been released into the environment. Proposed Plan: Superfund public participation fact sheet
which summarizes the preferred cleanup strategy and the
Comprehensive Environmental Response, Compensation rationale and a summary of the RI/FS.
and Liability Act (CERCLA): Also known as Superfund,
is a federal law passed in 1980 and modified in 1986 by the Record of Decision (ROD): A public document describing
Superfund Amendment and Reauthorization Act (SARA); EPA's rationale for selection of a Superfund cleanup
the act created a trust fund, to investigate and cleanup alternative.
abandoned or uncontrolled hazardous waste Sites. The law
authorizes the federal government to respond directly to Remedial Investigation (RI): Part one of a two part
releases of hazardous substances that may endanger public investigation conducted to fully assess the nature and extent
health or the environment. EPA is responsible for managing of the release, or threat of release, of hazardous substances,
the Superfund. pollutants, or contaminants, and to identify alternatives for
clean up. The Remedial Investigation gathers the necessary
Feasibility Study: Study conducted after the Remedial data to support the corresponding Feasibility Study.
Investigation to determine what alternatives or technologies
could be applicable to the Site specific COCs. Responsiveness Summary: A summary of oral and written
comments received by EPA during a comment period on key
Groundwater: The supply of fresh water found beneath the EPA documents, and EPA’s responses to those comments.
Earth’s surface (usually aquifers) which is often used for The responsiveness summary is a key part of the ROD,
supplying wells and springs. highlighting community concerns for EPA decision-makers.

Human Health or Ecological Baseline Risk Assessment: Superfund: The common name used for the Comprehensive
A qualitative and quantitative evaluation performed in an Environmental Response, Compensation and Liability Act of
effort to define the risk posed to human health and the 1980 (CERCLA), the federal law that mandates cleanup of
environment by the presence or potential presence and use of abandoned hazardous waste Sites.
specific pollutants.
TEQ: Toxicity Equivalent Quotient for 2, 3, 7, 8-
Information Repository: A library or other location where Tetrachlorodibenzo-p-dioxin (TCDD). Since there are
documents and data related to a Superfund project is placed multiple dioxins and furans with different toxic effects, so
to allow public access to the material. concentrations of the different dioxins and furans detected
are weighted according to toxicity and collectively added to
Institutional Controls: Restriction that prevents the owner determine the TEQ.
inappropriately developing the property. The restriction
could be implemented as a “deed Restriction” and is
designed to prevent harm to workers or potential residential
development.

35

CABOT CARBON/KOPPERS SUPERFUND SITE
PUBLIC COMMENT SHEET

Your input on the Proposed Plan for the Cabot Carbon/Koppers Superfund Site is important in helping EPA
select a remedy for the Site. You may use the space below to write your comments, then fold and mail. A
response to your comment will be included in the Responsiveness Summary.

------------------------------------------------------------------------------------------------------

Place
Stamp
Name Here
Address
City State Zip

Scott Miller, Remedial Project Manager
Superfund Division, Superfund Remedial Branch
Section C
U.S. EPA Region 4
61 Forsyth Street, SW
Atlanta, GA 30303

EPA Superfund Proposed Plan Cabot / Koppers Superfund Site

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