Third Five-Year Review Report for

Reeves Southeastern Galvanizing Corp. EPA ill FLD000824896

Tampa Hillsborough County, Florida

September 2011

Prepared By: Skeo Solutions

921 Second Street SE Charlottesville, Virginia

22902

For: United States Environmental Protection Agency

Region 4 Atlanta, Georgia

Date:

A:~ Franklin E. Hill Director, Superfund Division U.S. EPA, Region 4

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Third Five-Year Review Report for

Reeves Southeastern Galvanizing Corp. 9510 East Broadway #20

Tampa Hill~borough County, Florida

List of Acronyms ~ 5

Executive Summary 7

Five-Year Review Summary Form 12

1.0 Introduction 16

2.0 Site Chronology 17

3.0 Background 19

3.1 PHYSICAL CHARACTERISTICS , 19 3 ') LAND AND RESOURCE USE ; 23 3.3 HISTORY OF CONTArvIlNATION 23 3.4 INITIAL RESPONSE 24 3.5 BASIS FOR TAKING ACTION 25

4.0 Remedial Actions ~ 27

4.1 RErvlEDY SELECTION 27 4.2 REMEDY IMPLErvfENTATION 30 4.3 OPERATION AND MAINTENANCE (O&M) 34

5.0 Progress Since the Last Five-Year Review 36

5.1 COMPLETE IMPLEMENTATION OF PILOT STUDY WORK PLAN : 37 5.2 INSTALL ADDITIONAL MONITORING WELLS 37 5.3 SAMPLE GROUND WATER FOR MERCURy 38 5.4 INVESTIGATE POTENTIAL UNIDENTIFIED SOURCE AREAS FOR GROUND WATER

CONTAtvllNATION 38 5.5 EVALUATE NEED FOR SEDI1\IENT EXCAVATION 39 5.6 EVALUATE SOIL AND GROUND WATER INSTITUTIONAL CONTROLS :.. 39 5.7 DECIDE ON FINAL GROUND WATER REMEDy 39

6.0 Five-Year Review Process 40

6.1 ADMINISTRATIVE COMPONENTS 40 6.2 COMMUNITY INVOLVEMENT 40 6.3 DOCUMENT REVIEW 40 6.4 DATA REVIEW 43 6.5 SITE INSPECTION 68 6.6 INTERViEWS 74

7.0 Technical Assessment ; 75

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7.1 QUESTION A: Is THE REMEDY FUNCTIONING AS INTENDED BY THE DECISION DOCUMENTS? 75

7.2 QUESTION B: ARE THE EXPOSURE ASSUMPTIONS, TOXICITY DATA, CLEANUP LEVELS AND REMEDIAL ACTION OBJECTIVES (RAOS) USED AT THE TIME OF REMEDY SELECTION

STILL V ALID? : 76 7.3 QUESTION C: HAS ANY OTHER INFORMATION COME TO LIGHT THAT COULD CALL INTO

QUESTION THE PROTECTIVENESS OF THE REMEDY? 77 7.4 TECHNICAL ASSESSMENT SUMMARy 77

8.0 Issues 80

9.0 Recommendations and Follow-up Actions 81

10.0 Protectiveness Statements 83

11.0 Next Review 84

Appendix A: List of Documents Reviewed A-I

Appendix B: Press Notice B-1

Appendix C: Interview Forms C-1

Appendix D: Site Inspection Checklist D-1

Appendix E: Photographs from Site Inspection Visit E-l

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Tables Table 1: Chronology of Site Events 17 Table 2: List of Site Property Parcels 19 Table 3: Soil and Sediment cac Cleanup Goals 28 Table 4: Ground Water cac Cleanup Goals 29 Table 5: Annual a&M C.osts 35 Table 6: Prog~ess on Recommendations from the 2006 FYR 36 Table 7: Additional Site Characterization Monitoring Wells 38 Table 8: Previous and Current ARARs for Ground Water cacs 42 Table 9: Previous and Current ARARs for Surface Water cacs 42 Figure 4: Semiannual Ground Water Sampling Results for Cadmium, 2006-2010 47 Figure 5: Semiannual Ground Water Sampling Results for Zinc, 2006-2010 47 Figure 6: Semiannual Ground Water Sampling Results for Nickel, 2006-2010 48 Figure 7: Semiannual Ground Water Sampling Results for Aluminum, 2006-2010 48 Table 10: Routine Performance Monitoring Ground Water Sampling Results, 2006-2010 49 Table 11: Ground Water Sampling Results from Additional Monitoring Wells, 2006-2010 54 Table 12: Measured Water Hardness Values, 2006-2010 57 . Table 13: aU3 Surface Water Sampling Results, 2006-2010 63 Table 14: aU3 Sediment Sampling Results, 2006-2010 66 Table 15: aU3 Biota Sampling Results, 2006-2009 68 Table 16: Deed Documents from Hillsborough County Clerk of the Circuit Court 70 Table 17: Institutional Control (IC) Summary Table 72 Table 18: Current Site Issues 80 Table 19: Recommendations to Address Current Site Issues 81

Figures Figure 1: Site Location Map 21 Figure 2: Detailed Site Map 22 Figure 3: Approximate Extent of Ground Water Contamination to be Addressed Under aU2 46 Figure 4: Semiannual Ground Water Sampling Results for Cadmium, 2006-2010 47 Figure 5: SemimIDual Ground Water Sampling Results for Zinc, 2006-20 I0 47 Figure 6: Semiannual Ground Water Sampling Results for Nickel, 2006-2010 48 Figure 7: Semiannual Ground Water Sampling Results for Aluminum, 2006-2010 48 Figure 8: AnnualSurface Water Sampling Results for Aluminum, 2006-2010 59 Figure 9: Annual Surface Water Sampling Results for Arsenic, 2006-2010 59 Figure 10: Annual Surface Water Sampling Results for Cadmium, 2006-2010 60 Figure 11: Annual Surface Water Sampling Results for Chromium. 2006-2010 60 Figure 12: Annual Surface Water Sampling Results for Lead, 2006-2010 61 Figure 13: Annual Surface Water Sampling Results for Mercury, 2006-2010 61 Figure 14: Annual Surface Water Sampling Results for Nickel, 2006:2010 62 Figure 15: Annual Surface Water Sampling Results for Zinc, 2006-2010 62 Figure 16: Site Parcels and Florida Ground Water Delineated Area 73

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List of Acronyms

AOC ARAR bgs CERCLA CFR CIC COC CS EPA ESD FAC FDEP FDER FFS FS FYR GWET IC IGA IRIS MCL /lg/L mg/kg mg/L MNA MSL MV NCP NOAA NPL O&M au PRP RA RAO RCRA RD RI ROD RPM SARA SEG SEW SQAG

Administrative Order on Consent Applicable or Relevant and Appropriate Requirement below ground surface Comprehensive Environmental Response, Compensation and Liability Act Code of Federal Regulations Community Involvement Coordinator Contaminant of Concern Calcuhlted Standard United States Environmental Protection Agency Explanation of Significant Differences Florida Administrative Code Florida Department of Environmental Protection Florida Department of Environmental Regulation Focused Feasibility Study Feasibility Study Five-Year Review Ground Water Extraction and Treatment Insti tutional Control Industrial Galvanizers of America Integrated Risk Information System Maximum Contaminant Level micrograms per liter milligrams per kilogram milligrams per liter Monitored Natural Attenuation Mean Sea Level Measured Value National Contingency Plan National Oceanographic and Atmospheric Administration National Priorities List Operation and Maintenance Operable Unit Potentially Responsible Party Remedial Action Remedial Action Objective Resource Conservation and Recovery Act Remedial Design Remedial Investigation Record of Decision Remedial Project Manager Superfund Amendments and Reauthorization Act Southeastern Galvanizing Property Southeastern Wire Property Sediment Quality Assessment Guideline

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SQuiRT SR SSV SVOC TBe TEC VOC

Screening Quick Reference Table State Road Sediment Screening Value Semivolatile Organic Compound To-be-considered Threshold Effect Concentration Volatile Organic Compound

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Executive Summary

Introduction

The Reeves Southeastern Galvanizing Corp. site (the Site) in Tampa, Hillsborough County, Florida consists of the 17-acre Southeastern Gal vanizing (SEG) property, the II-acre Southeastern Wire (SEW) property and the 1.75-acre North Wetland. A 10-acre portion of the SEG property is currently leased to Industrial Galvanizers of America (lGA), which has continued hot-dip galvanizing operations at the Site since 1996. The SEW property is located southeast of the SEG property and upgradient in terms of ground water tlow direction. In 2001, the SEW property was purchased by Master-Halco, Inc., which continues to operate a wire fence manufacturing facility on the Site. The North Wetland is located adjacent to the western border of the SEG property in an electrical utility right-of-way. The Peak Oil Co./Bay Drum Co. Superfund site is located south of the SEG property along State Road (SR) 574 and abuts the western edg~ of the SEW property.

The fonner disposal of process waters to percolation/evaporation ponds on both the SEG and SEW properties has resulted in heavy metal contamination of ground water, sediment and soil at the Site. The potentially responsible party (PRP) for the Site, Reeves Southeastern Corporation, sold all its assets in 200 I and fonned the Reeves Trust to implement remedial actions at the Site according to the tenns of a 1995 Consent Decree with the United States Environmental Protection Agency (EPA).

EPA divided the Site into three operable units (OUs) for remediation: OUI addresses soil and sediment source contamination, OU2 addresses northern surficial ground water and OU3 addresses the North Wetland and Unnamed Creek. Under OU 1, the PRP completed excavation of contaminated soils and sediments for off-site disposal in July 1997. EPA selected monitored natural attenuation (MNA) with a contingency pump-and-treat system as the OU2 remedy. Ground water monitoring has been performed at the Site on a semiannual basis since January 1994. In 2005, EPA determined that MNA would not restore ground water quality within a reasonable timeframe and that an active remedy would be required.

Based on additional site characterization investigations, the bulk of the contaminant mass to be treated in the OU2 ground water was found to be located in a low-permeability Transition Zone between the Sand Zone and Hawthorn Fonnation underlying the Site. The PRP began investigating alternative remedies that would address contamination in the Transition Zone more etlectively and efticientlythan a pump-and-treat system. A draft focused feasibility study (FFS) for an alternative contingent remedy for OU2 was submitted to EPA in March 2010. EPA and Florida Department of Environnlental Protection (FDEP) responded with comments, and a revisedFFS was submitted to EPA in July 20 II. That revision is currently under review.

The stormwater system along State Road 574 discharges into the North Wetland, located adjacent to the SEG property, then exits the North Wetland via Unnamed Creek, which traverses the northwest corner of the SEG property prior to joining up with site drainage swales and discharging to a stormwater conveyance structure north of the SEG property. As a measure to protect OU3 surface water and sediments, a stornlwater conveyance structure was constructed

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just north of the Site in 2004 to prevent OU2 contaminated ground water from discharging to local surface water via a drainage swale and the Unnamed Creek. A remedy of no action with long-term monitoring was selected for OU3. Annual monitoring ofOU3 has been performed by the PRP since 2002.

The triggering action for this Five-Year Review (FYR) was the signing of the previous FYR on September 28, 2006.

Remedial Action Objectives

EPA issued the Record of Decision (ROD) for OUI on October 13,1992. Based on the results of the Site's remedial investigation and feasibility study (RIfFS), EPA determined that remediation of soil and sediment would be required for the protection of human health and the environn1ent. Remedial action objectives (RAOs) established in the ROD for OU 1 include: .

• Reducing cancer risk for industrial workers who continue to work on site to less than 1.0 x 10-4. ~

• Protecting ground water from source contamination causing exceedances of drinking water standards.

EPA issued the ROD for OU2 on September 9,1993. The Site is one of two Superfund sites responsible for area-wide ground water contamination. Remediation of the southern surficial aquifer and the upper Floridan aquifer is being addressed by the relhedies at the adjacent Peak Oil Co./Bay Drum Co. site. Therefore, ground water remediation at the Site addresses ·only the northern surficial aquifer. Based on the results of the Site's RIIFS, EPA determined that remediation of ground water in the northern surficial aquifer would be required for the protection of human health and the environment. RAOs established in the ROD for OU2 include:

• Protecting human health, welfare and the environment. • Ensuring compliance with applicable or relevant and appropriate requirements.

EPA issued the ROD for OU3 on June 28, 1994. The baseline risk assessment determined that, based on assumptions that the remedies for OU 1 and OU2 would eliminate contribution of contamination to surface water, OU3 poses no unacceptable risk to human health and the environment. Therefore, the ROD selected no remedial action and no RAOs were established for OU3.

Technical Assessment

The review of documents, applicable or relevant and appropriate requirements (~RARs), risk assumptions and the site inspection indicate that the Site's remedy has not been completed, but is expected to function as intended by site decision documents upon completion.

Source removal activities under OU 1 were completed in 1997 and require no further action. The SEW property has only been addressed under OU I and no site-related contamination as identified in the 1992 OU 1 ROD remains on the property. Since source contamination was

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disposed of at an off-site facility, the requirement for the implementation of institutional controls to restrict land uses that would have impacted the originally plmmed on-site monolith is no longer necessary.

The ground water remedy selected in the 1993 OU2 ROD was MNA with a contingency pumpand-treat remedy. In 2005, EPA deternlined that MNA was not progressing at a reasonable rate and that an alternate remedy should be investigated. However, additional site characterization revealed that the bulk of the ground water contamination remaining to be remediated is in a lowpermeability layer that would be dit1icult to address with a pump-and-treat system. An FFS investigating the applicability of in situ treatment with chemical injections was originally presented to EPA in 2010, was revised in response to comments from EPA and FDEP, and was recently resubmitted to EPA in July 2011.

The RAOs for OU2 included protecting human health, welfare and the environment and ensuring compliance with ARARs. The remedy for OU2 addresses ground water contamin~tion in the surficial aquifer, which is not currently used as a potable water source. Institutional controls are in place to prevent potential exposure to contaminated ground water. The Site is encompassed within a Florida Ground Water Delineated Area, which restricts ground water use and the installation of wells. In addition, Hillsborough County Ordinance 90-35 mandates that all facilities located within 500 feet of a municipal water supply line must be cOimected to that supply line for potable water.

Ground water cleanup goals for zinc and nickel continue to be exceeded at the Site, and aluminum, while not established as a site contaminant of concern (COC), is present at elevated concentrations. Drinking water standards on which the Remedial Goals are based have changed. The current ground water ARAR for arsenic has become more stringent since 1993 OU2 ROD and the water-hardness dependent surface wate'r ARAR calculations for cadmium, chromium, lead, nickel and zinc have become less stringent than the 1999 FDEP values presently used. A review of ARARs changes indicates that a revised decision document(s) may be necessary. Additionally, aluminum was not selected as a site COC for OU2 or OU3, but given continued exceedances of available regulatory standards for ground water and surface water. Aluminum may be a site COC. Minimum detection levels to enable comparison of the analytical results with the cleanup goal should be consistently used. The modified OU2 remedy will have to address new ARARs and remaining exceedances. Once the modified remedy has been selected, a monitoring plan detailing the monitoring schedule and related remedial activities should be developed for the Site.

The majority of the area of ground water contamination is beneath the SEG property, where IGA currently operates. The facility and neighboring businesses are all connected to municipal water supply. The entire SEG property is surrounded by security fencing and IGA security protocols require all visitors to the Site to register with the main ot1ice at the property entrance before accessing any portion of the Site.

The 1994 OU3 ROD selected no remedial action for the North Wetland and Unnamed Creek because sources of contamination to OU3 were expected to be addressed under the OU 1 and OU2 remedies; contaminant concentrations in OU3 were expected to naturally attenuate without

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those ongoing source contributions. The 1994 OU3 ROD also called for annual monitoring of OU3 to be performed for eight years, or until the OU2 remedy has been completed. Annual OU3 monitoring began in 2002 and, since ground water cleanup goals have not yet been achieved, is ongoing at the Site.

Exceedances of surface water ARARs and sediment cleanup criteria continue to be detected in the North Wetland and Unnamed Creek. In addition, the site PRP has expressed concern that the current tenant, IGA, may be contributing to surface water and potentially ground water contamination through their operations, and FOEP has recently raised this concern as well. The 2006 FYR recommended an evaluation of whether sediment excavation might be appropriate for OU3. Potential sources of containination were also discussed in the 2007 Additional Site Characterization and In Situ Groundwater Treatment Pilot Study Report and the 2007 lGA Zinc Assessment Report, but definitive data has not been collected.

Biota sampling under aU3 has been limited. Stressed or absent biota was noted at sampling locations at the March 2011 site inspection. Surface water data demonstrates that elevated surface water contaminant concentrations entering the North Wetland (NW-Ol) and these concentrations are significantly lower after exiting the North Wetland (NW-02). The fate of these contaminants, whether they are being sequestered or bioaccumulated in the ecosystem, and the impacts on the ecological community, should be evaluated. Institutional controls were not selected as part of the OU3 remedy, and following resolution of ongoing contaminant impacts, are not expected to be necessary.

Conclusion

The remedy at OU 1 is protective ?f human health and the environment in the short term because source contamination identified in the 1992 OU 1 ROD was excavated and disposed of at an authorized off-site facility. Therefore, the originally identified source contamination has been removed from the Site, construction of the OUI remedy was considered complete in 1997 and no further monitoring is required because cleanup goals were attained and no waste remains in place. In order for the remedy to be protective in the long tenn, issues regarding investigation of an ongoing source of contamination and investigation of possible additional source contamination areas should be addressed.

The remedy at aU2 currently protects human health and the environment in the short term because the site is located in a Florida Groundwater delineated zone, and the contaminated surficial aquifer is not utilized as a potable water source. In order for the remedy to be protective in the long term, an active remedy to address groundwater contamination must be selected and implemented. Additionally, institutional controls to prohibit the use of groundwater should be implemented.

A protectiveness detennination of the remedy at OU3 cannot be made at this time until further information is obtained. Further infonnation will be obtained by taking the following actions: 1) completion of a bioaccumulation assessment and ecological h~alth assessment of the North Wetland to detern1ine the fate of COCs entering the wetland; and, 2) completion of investigation into potential on-site and off-site ongoing contamination sources. Based on the results of this

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assessment and study, the remedy decision for aU3 may be modified or revised. It is expected. that these actions will take approximately 18 months to complete, at which time a protectiveness determination will be made. No potential human exposure pathways of concern currently exist at aU3.

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Five-Year Review Summary Form

SITE IDENTIFICATION Site name (from Jf'asteLAN): Reeves Southeastern Galvanizing Co . EPA ID (from WasteLAN): FLD000824896 Region: 04 State: Florida City/County: Tampa/Hillsborough County

Lead a enc : ~ EPA D State D Tribe D Other Federal Aoenc Author name: Sabrina Foster, Kirby Webster and Treat Suomi Reviewed b EPA Author title: Associates and Senior Associate Author affiliation: Skeo Solutions Review eriod**: 12/10/2010 to 09/28/2011 Date(s) of site ins ection: 03/29/20 II Type of review:

~ Post-SARA D Pre-SARA D Non-NPL Remedial Action Site D Regional Discretion '

D NPL-Removal only D NPL State/Tribe-lead

Review number: D I (first) D 2 (second) ~ 3 (third) D Other (secify) Triggering action:

D Actual RA On-site Construction 'at Oll# D Construction CompletionD Other (specify)

D Actual RA Start at OU# ~ Previous Fi ve-Year Review Report

Triggerin action date (from H'asteLAN): 09/28/2006 Due date (jive years after triggerillg actioll date): 09/28/20 I I

* ['"aU" refers to operable unil.] ** [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN.]

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Five-Year Review Summary Form (continued)

Issues: 1) The need to implement an active remedy at OU2 and the inappropriateness of the current pump-and-treat contingency remedy were determined in 2005. An FFS has been submitted but a modified remedy has not yet been selected or implemented.

2) Annual ground water sampling analysis does not consistently use minimum detection levels low enough to enable comparison of the detected concentrations with selected cleanup goals.

3) The 20 II calculations for water hardness-dependent sllrface water ARARs for metals are less stringent than those currently used by the PRP's contractor.

4) Contaminant concentrations in sediment of the Unnamed Creek and drainage swales continue to exceed sediment screening values. An evaluation of whether an excavation of contaminated sediment might be appropriate was recommended in the 2006 FYR but never completed.

5) The 1997 OU I ESD changed the source contamination remedy to off-site disposal. Therefore, institutional controls called for in the 1992 OU I ROD to protect the originally planned on-site monolith are no longer necessary. However, institutional controls remain part of the selected remedy and soil and land use institutional controls might be appropriate to implement at the Site.

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Five-Year Review Summary Form (continued)

Recommendations:

I) Complete the remedy evaluation and selection for aU2 ground water and update site decision documents. as appropriate.

2) Consistently utilize minimum detection levels that enable comparison of detected contaminant concentrations with ground water cleanup goals.

3) Evaluate and update the surface water standard calculation used to derive the cleanup goal for the Site.

4) Evaluate whether the selected aU3 remedy adequately mitigates risks associated with sediment contamination. If appropriate. consider excavation and removal of contaminated sediment.

5) Evaluate whether au 1 institutional controls other than the protection of the originally planned on-site monolith specified in the 1992 au I RaD are needed at the' Site. Implement soil and land use institutional controls. if appropriate.

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Five-Year Review Summary Form (continued)

Protectiveness Statement(s):

The remedy at au I is protective of human health and the environment in the short term because source contamination identified in the 1992 au I RaD was excavated and disposed of at an authorized off-site facility in 1997. Therefore, the originally identi fied source contamination has been removed from the Site, construction of the au 1 remedy was considered complete in 1997 and no further monitoring is required because there are no existing exposure pathways. In order for the remedy to be protective' in the long term, issues regarding investigation of ongoing sources of contamination and investigation of possible additional source(s) of contamination should be addressed. If an ongoing source of contamination is identified, it may be addressed as part of au 1.

The remedy at aU2 currently protects human health and the environment in the short term because the site is located in a Florida Groundwater delineated zone, and the contaminated surficial aquifer is not utilized as a potable water source. In order for the remedy to be protective in the long term, an active remedy to address groundwater contamination must be selected and implemented. Additionally, institutional controls to prohibit the use of

groundwater should be implemented.

A protectiveness determination of the remedy at aU3 cannot be made at this time until further information is obtained. Further information will be obtained by taking the following actions:- 1) completion of a bioaccumulation assessment and ecological health assessment of the North Wetland to determine the fate ofCaCs entering the wetlands; 2) completion of a full investigation into potential on-site and off-site ongoing contamination sources. and, based on the results of this assessment and study, the remedy decision for aU3 may be modified or revised. It is expected that these actions will take approximately 18 months to complete, at which time a protectiveness determination will be made. No potential human exposure pathways ofconcem currently exist at aU3.

Other Comments:

Environmental Indicators - Current human exposures at the Site are under control. - There are insufficient data to determine groundwater migration control status.

Are Necessarv Institutional Controls in Place? ~ All D Some D None Source control institutional controls were selected to protect the originally planned on-site monolith remedy. However, this remedy was later changed to off-site disposal and these institutional controls no longer apply as there is no monolith at the Site. It may be appropriate to remove this institutional control requirement for the remedy. Appropriate and required institutional controls for ground water are currently in place. EPA is evaluating whether updated ground water institutional controls may be appropriate as part ofthe evolution of a revised aU2 remedy.

Has the Site Been Designated as Site-Wide Ready for Anticipated Use? DYes~No This site currently does not meet the criteria for Site-wide Ready for Anticipated Use. However, parts of the Site are in continued use. .

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Third Fuve-Year Review Report for

Reeves Southeastern Galvanizing Corp. Superfund Site

1.0 Introduction

The purpose ofa Five-Year Review (FYR) is to evaluate the implementation and performance of a remedy in order to determine if the remedy will continue to be protective of human health and the enviromnent. The methods, findings and conclusions of FYRs are documented in FYR reports. In addition, FYR reports identify issues found during the review, if any, and document recommendations to address them.

The United States Environmental Protection Agency (EPA) prepares FYRs pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 12 I and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). CERCLA Section 12 I states:

"If the President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each five years after the initiation of such remedial action to assure that human health and the enviromnent are being protected by the remedial action being implemented. In addition, if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section [104] or [106], the President shall take or require such action. The President shall report to the Congress a list of facilities for which such review is required, the results of all such reviews, and any actions taken as a result of such reviews."

EPA interpreted this requirement further in the NCP; 40 Code of Federal Regulations (CFR) Section 300.430(t)(4)(ii), which states:. . ..

"If a remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such actions no less often than every tive years after the initiation of the selected remedial action."

Skeo Solutions, an EPA Region 4 contractor, conducted theFYR and prepared this report regarding the remedy implemented at the Reeves Southeastern Galvanizing Corp. site (the Site) in Tampa, Hillsborough County, Florida. This FYR was conducted from December 2010 to September 20 I I. EPA is the lead agency for developing and overseeing the implementation of the remedy for the potentially responsible party (PRP)-tinanced cleanup at the Site. The Florida Department of Environmental Protection (FDEP), as the support agency representing the State of , Florida, has reviewed all supporting documentation and provided input to EPA during the FYR process.

This is the third FYR for the Site. The triggering action for this policy review is the previous FYR. The Site consists of three operable units (OUs), all of which are addressed in this FYR.

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2.0 Site Chronology

Table 1 lists the dates of important events for the Site.

Table 1: Chronology of Site Events

Event Date Initial discovery of contamination August I, 1980 EPA proposed Site to the National Priorities List (NPL) December 30, 1982 Site listed on NPL September 8, 1983 Preliminary site assessment October I, 1984 Site inspection November I, 1984 PRP-Iead OU3 remedial investigation and feasibility study (RJIFS) start date

February 5, 1988

PRP-Iead OU2 RJ/FS start date March I, 1988 EPA issued joint Administrative Order on Consent (AOC) to Reeves Southeastern Corporation and PRPs for the adjacent Peak Oil Co./Bay Drum Co. Superfund site for an area-wide ground water RJ/FS; EPA issued AOC to Reeves Southeastern Corporation for performance of the OU I source characterization RIIFS; PRP-Iead OU I RJ/FS start date

February 10, 1989

EPA-lead sitewide removal assessment September 30, 1991 First PRP-Iead OU I human health risk assessment January 15, 1992 Second PRP-Iead OU I human health risk assessment April 15, 1992 PRP-Iead OU I RJIFS completion date; OU I Record of Decision (ROD) signature date

October 13, 1992

EPA issued a modification to the 1989 site-specific AOC to include perfom1ance ofOU I remedial design and remedial action (RD/RA)

March 3, 1993

PRP-Iead OU I RD start date March 26, 1993 PRP-Iead OU2 RIIFS completion date; OU2 ROD signature date

September 9, 1993

PRP-Iead OU3 RIIFS completion date; OU3 ROD signature date

June 28, 1994

Reeves Southeastern Corporation signed Consent Decree with EPA addressing past and future remedial costs for the Site

November 2, 1994

PRP-Iead OU3 RD start and completion date; EPA directed the PRP to prepare an RD for the contingency remedy; PRP-Iead first OU2 RD start date

November 30, 1994

Reeves Southeastern Corporation signed Consent Decree with EPA for perforn1ance of sitewide RD/RA

July 17, 1995

PRP-Iead OU I RD completion date; PRP-Iead OU I RA start date

February 27, 1996

Reeves Southeastern Corporation signed lease agreement with Industrial Galvanizers of America, Inc. (IGA) for use of a IO-acre portion of the SEG property; IGA facility operation start date

March I, 1996

OU 1 explanation of signiticant differences (ESD) signature date April 15, 1997 PRP-Iead OU I RA completion date October 2, 1997 PRP-Iead first OU2 RD completion date; PRP-Iead OU2 RA start date

September 15, 1998

EPA issued AOC to IGA for compliance with terms of 1995 Consent Decree

December 6, 1999

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Event Date EPA signed prospective purchaser agreement and covenant not to sue with Master-Halco, Inc.; EPA determined au I required no further action

January 19,200 I

Reeves Southeastern Trust established April 2001 First FYR signed September 25, 200 I PRP-Iead aU2 RA completion date; PRP-Iead aU2 operations and maintenance (a&M) start date; EPA determined that monitored natural attenuation (MNA) would not achieve aU2 cleanup goals within a reasonable timeframe and that implementation of a contingency remedy was needed; EPA and PRP concurred that the pump-and-treat contingency remedy would not effectively address contamination and that ·alternative remedies should be evaluated

April 19, 2005

PRP-Iead second aU2 RD start date June 10, 2005 Second FYR signed September 28, 2006 Dilution of quench solution for IGA operations resulted in an overflow and discharge of 15,168 gallons of chromium-containing water at the Site

November 29, 2007

Additional Characterization and In Situ Ground Water Treatment Pilot Study Report submitted to EPA

December 6, 2007

FDEP released IGA from further obligations in response to the quench solution discharge based on the Interim Source Removal Report

June 15,2009

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3.0 Background

3.1 Physical Characteristics

The Site is located in an industrial area of Tampa, Hillsborough County, Florida and is made up of three properties (Figure 1). The Reeves Southeastern Galvanizing (SEG) facility consists of 17 acres and is located on the north side of State Road (SR) 574. Industrial Galvanizers of America, Inc. (IGA) leased an approximately 1O-acre portion of the SEG property in March 1996 and has operated a hot-dip galvanizing facility on the Site since that time. The Reeves Southeastern Wire (SEW) facility consists of 11 acres and is located on the south side of SR 574, immediately east of the Peak Oil Co.lBay Drum Co. Superfund site. Master-Halco, Inc. purchased the assets of the Reeves Southeastern Corporation's wire division, including the SEW property, in 2001 and has manufactured chain-link and other fence systems on the Site since that time. The third property is the 1.75-acre North Wetland, which is located immediately west of the SEG

.property in an electrical transmission line right-of-way. The Unnamed Creek flows from the North Wetland, along the western border of the SEG property and traverses the northwest corner of the property flowing in a north-northeasterly direction.

The Site is located on five property parcels owned by five separate legal entities (Table 2). The parcel of the SEG property currently being leased by IGA has a deed recorded in the name of Reeves Southeastern Realty, Inc. and the second parcel forming the SEG property remains in the name of Reeves Southeastern Corporation. The North Wetland is located on portions of two privately owned parcels and access agreements with the owners are in place to allow for continued OU3 activities. The SEW property occupies the majority of the parcel owned by Master-Halco, Inc.

Table 2: List of Site Property Parcels

Owner Location Folio # Parcel Acreage Reeves Southeastem Realty Inc. SEG Property 0654590000 10.09 Reeves Southeastem Corporation SEG Property 0654590100 6.35 KRM Development Corporation North Wetland 0655072622 3.68* STS Buildings Associates LP North Wetland 0655072625 I ..,~*._.J Master-Halco, Inc. SEW Property 0654870000 15.84* *Onlya portion of the total parcel acreage is included in the Site.

Topographically, the area where the Site is located is relatively flat. Surface elevatioT!s at the SEG property range from 36 feet above mean sea level (MSL) at the southern boundary to 26 feet above MSL at the northern boundary. The topographic contour of the SEW facility slopes to the south, sending surface water runoff away from the facility. Of area wetlands, the North Wetland was the only one found to have both a surface water inlet and outflow. After rain events, surface water intlow originates in a ditch paralleling SR 574 and runs west between the Peak Oil Co.lBay Drum Co. Superfund site and the south side of SR 574. A series of culverts direct runoff from the Peak Oil Co.lBay Drum Co. Superfund site under the CSX railroad track that also runs parallel to SR 574 and then into the drainage ditch. The surface water then runs through a culvert under SR 574

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at the electrical transmission lines and then enters the North Wetland. Surface water exits the North Wetland via the Unnamed Creek and crosses the northwest corner of the SEG property before joining a drainage ditch carrying runofI from the SEG facility. The Unnamed Creek continues north into a stormwater conveyance structure (see section 4.2) that carries water under Queen Palm Drive to the storn1water drainage system at Sabal Industrial Park. Stormwater eventually t10ws into the Tampa Bypass Canal.

The ground water system beneath the Site consists of two major water-bearing units: a surficial aquifer and the Floridan aquifer system. The surficial aquifer is defined as a Class lIB aquifer, which means it is considered a potential drinking water source. However, to EPA's knowledge, this aquifer is not presently used for any purpose. The Hawthorn formation, a clayey, low-permeability layer, separates the surficial aquifer from the underlying Floridan aquifer. The surficial aquifer is hydraulically connected to the wetlands near the Site and ground water flow direction varies seasonally. Water levels also fluctuate seasonally and change rapidly in response to rainfall and other natural influences. Ground water historically might have discharged seasonally to the Unnamed Creek, but construction of a storn1water conveyance structure in 2004 (see section 4.2) has largely mitigated this potential pathway in the area north of monitoring well S-2 (Figure 2). The potential discharge of contaminated ground water to surface water in the. North Wetland would have to occur laterally because the North Wetland is located geographically upgradient of site ground water contamination.

Although the Floridan aquifer tlows to the west-southwest at a regional scale, the tlow shifts toward the northwest in the vicinity of the Site. This is thought to be due to the proximity of the Site to the Tampa Bypass Canal, whichreportedly cuts into the lowpermeability Hawthorn fonnation and reaches the upper Floridan aquifer in several places. The Floridan aquifer is the primary source of drinking water and water for industrial use in Hillsborough County. However, there are no permitted wells that are used for drinking water in the vicinity of the Site and the area has been designated as a Florida Ground Water Delineated Area. In addition, potable water supply for this area of Florida comes from the Florida aquifer and site-related ground water remediation only addresses ·contamination in the surficial aquifer, which is not utilized as a drinking water source in any area.

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Figure 1: Site Location Map

Tam~,FL

Q~••nP,:t1M

Peak Oil/Bay 0 Cgmplny SuperfUl'ld S

Galvanizing Corp.

NORTH

o 405 81

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding EPA's response actions at the Site, and is not intended for any other purpose.

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SEW flropert>,

ves Southesstem Galvanizing p.

u d

Figure 2: Detailed Site Map

---- --'----------_....:._---~_.....

O__250I::::::=l5OO::iiI 1.~

Leg nd: EJWtIIWs [::J Rceown sew p• 0U3 M~"""h~ !..I:aUan r-

--Ibl~ W . ~C;O/IY'~ Of 1\JQl1l" !. _ oJ Pwk Of co 18@y Drum co R_ S£Q Pfttp.1tt' •

Reeves Southeaslem Galvaniling Superfu d Site

NORTH Tampa, Hillsborough Counl)'. Flotida

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding EPA's response actions at the Site, and is not intended for any other purpose.

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3.2 Land and Resource Use

The majority of the Site has remained in continued commercial/industrial use throughout remedial activities. In March 1996, IGA purchased the Reeves Southeastern Corporation's galvanizing assets and signed a 20-year lease with 20 five-year renewal options for use ofa 10.09-acre portion of the property formerly utilized by the Southeastern Galvanizing Division. Since that time, IGA has continued to operate a hotdip galvanizing facility on the Site. In January 2001, EPA finalized a prospective purchaser agreement and covenant not to sue with Master-Ha1co, Inc. for acquisition of the SEW property. In April 2001, Master-Halco, Inc. acquired the Reeves Southeastern Corporation's Southeastern Wire Division, including the SEW property. Master-Ha1co, Inc. has continued to operate a wire-fencing manufacturing facility on the SEW property.

The second parcel of the SEG property, which still has a deed recorded in the name of Reeves Southeastern Corporation, is the location of the former evaporation/percolation ponds used by the SEG facility. This land is currently vacant and has been fenced to prevent access. The North Wetland is located in an electrical transmission right-of-way on land that is owned by two separate entities. This is an open wetland habitat area located approximately 10 yards from SR 574.

Land use in the area is predominantly industrial and commercial. The area north of the Site includes vacant land for lease and the Saballndustrial Park, which is a development containing light industry and office buildings. Immediately south of the SEG facility and west of the SEW facility is the Peak Oil Co.lBay Drum Co. Superfund site. There is no residential development in the immediate vicinity bfthe Site. The nearest residence is located more than a quarter-mile southeast of the Site.

3.3 History of Contamination

SEG Facility

The SEG facility was originally built and operated as Acme Plating and Galvanizing in the mid-1960s. In 1970, the facility was acquired by Metal Coatings, Inc., which merged into the Southeastern Galvanizing Corporation in 1971. Through internal reorganizations, Southeastern Galvanizing Corporation became the Southeastern Galvanizing Division of Reeves Southeastern Corporation. Reeves Southeastern Corporation operated at the Site until March 1996, when IGA purchased the Company's galvanizing assets and continued operations on the Site under a lease from Reeves Southeastern Corporation.

The metal-galvanizing and plating operations performed by Reeves Southeastern Galvanizing generated process wastewater that was discharged to two on-site evaporation/percolation ponds until a wastewater pretreatment system was installed at the Site in 1982. It is estimated that approximately 26 million gallons of spent acid-pickling bath were discharged to the ponds during their use. In 1982, the facility began treating its wastewater in a lined pond constructed to the east of the two evaporation/percolation ponds. Following treatment, wastewater was discharged to the local publicly owned

treatment works at a connection located in the southeast corner of the facility near monitoring well S-5 (Figure 2). With the introduction of new manufacturing processes and wastewater treatment technologies, the discharge to the publicly owned treatment works was reduced over time until it was completely eliminated in November 1994.

The North Wetland and Unnamed Creek are located adjacent to the SEG facility and predate galvanizing operations at the Site. They form part of the stormwater management system for the Sabal Industrial Park, which was developed to the north (downgradient) of the SEG property in the early 1970s. Discharge of contaminated ground water to surface water and overland flow to this stormwater management area are thought to be the sources of contamination for the North Wetland and Unnamed Creek.

SEW Facility

The SEW facility was originally built in 1955 and operated by Florida Wholesale Fence, Inc., a subsidiary of Reeves Fences, Inc. Through two mergers, Florida Wholesale Fence became the Southeastern Wire Division of Reeves Southeastern Corporation. The first percolation/evaporation pond for disposal of SEW's wastewater was built in 1955 and was used until it was backfilled in the late 1960s. A second pond was constructed prior to 1969, subdivided into two ponds in 1975 and used until 1980, when SEW began an onsite wastewater pretreatment program. Following treatment, wastewater was discharged to the local publicly owned treatment works from 1980 until 1990.

3.4 Initial Response

In 1981 , EPA conducted a site investigation that identified elevated concentrations of heavy metals in the surface water and ground water at the SEG facility. In August 1982, the Florida Department of Environmental Regulation (FDER, now FDEP) conducted a survey of the chemical contaminants and extent of their contamination at the SEG facility. The results of this survey resulted in the placement of the Site on EPA's NPL on December 30, 1982. '

In 1985, contractor CH2M Hill performed a terrain-conductivity survey at the Site using electromagnetic induction technology. The results of the survey indicated the potential for high concentrations of metal constituents in the surficial aquifer underneath both the SEG and SEW facilities.

In 1988, Reeves Southeastern Corporation and a group of PRPs for the adjacent Peak Oil Co./Bay Drum Co. Superfund site signed individual Administrative Orders on Consent (AOCs) to perfonn source characterization RI/FSs at their respective sites, and a joint AOC for an area-wide ground water RI/FS.

The source characterization RI/FS was performed from 1989 to 1992 and included the collection and analysis of soil, sediment, surface water and air samples at both the SEG and SEW facilities. Metal constituents were detected at elevated concentrations in soil, sediment and surface water at both facilities. Contamination was found to be limited in

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areal extent and detected concentrations could be addressed using conventional remedial technologies. During the RI, organic contamination was found along the western boundary of the SEW property. This contamination was attributed to the adjacent Peak Oil Co. property and includedin the scope of the Peak Oil Co. FS because SEW had not used petrochemicals in operations and the oily material was similar to source contamination found in other parts of the Peak Oil Co. property.

The PRP participated in an area-wide ground water investigation from 1988 to 1993. The area investigated included the SEG and SEW facilities, the Bay Drum Co. site, the Peak Oil Co. site (the Bay Drum Co. and Peak Oil Co. sites were later merged into a single site) and adjacent properties covering a total area of approximately 95 acres. Existing wells and additional monitoring wells installed for the investigation were used to sample the surficial and Floridan aquifers. The analytical parameters investigated inCluded· volatile organic compounds (VOCs), semivolatile organic compounds (SVOCs), polychlorinated biphenyls, organochlorine pesticides, total petroleum hydrocarbons, total suspended solids, total dissolved solids, metals and cyanide. A total of 51 surficial aquifer wells and 14 Floridan aquifer wells were sampled.

Ground water sampling in the sudicial aquifer detected 25 VOCs, 29 SVOCs, six pesticides and 23 inorganic constituents. Most of the VOCs and SVOCs were detected in areas Close to the Bay Drum Co. and Peak Oil Co. sites. Ground water sampling results for the Floridan aquifer detected VOCs and metals concentrated around the Peak Oil Co. site production well and the Bay Drum Co. site production well. The VOCs and SVOCs were found only in the Floridan aquifer and in relation to the Bay Drum Co. and Peak Oil Co. sites. The study determined that metals contamination in the surficial aquifer in the northern portion of the area-wide study was attributable to the Site; therefore, no vapor intrusion studies have been necessary at the Site. During the implementation of the areawide ground water RI/FS, EPA also conducted a wetlands impact study of the North Wetland and the Unnamed Creek.

In February 1993, Reeves Southeastern Corporation signed a modification to the 1988 site-specific source characterization AOC under which the company agreed to perforn1 the remedial design for the OUI remedy. Reeves Southeastern Corporation and EPA also signed two Consent Decrees: 1) a 1994 Consent Decree addressed past and future costs associated with remedial activities; and 2) a 1995 Consent Decree addressed the perfonnance of sitewide (all OUs) remedial design and remedial action.

3.5 .Basis for Taking Action

Two baseline risk assessments were perfonned for the Site. The first baseline risk assessment addressed OU 1 source materials and found that human health risks associated with exposure to contaminated soil and sediment fell well within EPA's acceptable risk range for Superfund sites (10-6 to 10.4). EPA also perforn1ed an area-wide wetland impact study which investigated environmental toxicity for five area wetlands. The study found site-related compounds at concentrations above background levels in sediment and surface water in the North Wetland and Unnamed Creek.

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The second baseline risk assessment was performed as part of the area-wide ground water RI/FS. This second assessment did not address current exposure since on-site ground water was not being used and area businesses and residences are all serviced by the Tampa Water Department. However, the risks associated with possible future exposure for workers or residents exceeded the risk range for both the surficial aquif~r and the Floridan aquifer, which is the source of municipal water supplies in the area. For this reason, actual or threatened releases of hazardous substances from the site soil and sediment into the ground water were determined to present an imminent and substantial endangerment to public health, welfare and the environment, if not addressed by remedial action. The endangerment was defined as the potential for further degradation of the area- . wide ground water via leaching of contaminants from the contaminated site soil.

In addition, all site-related contaminants were detected in the northern surficial aquifer at concentrations exceeding either maximum contaminant levels (MCLs) or acceptable health-based numbers. The northern surficial aquifer has been classified as a Class lIB, or potential drinking water source, aquifer and a goal of EPA's Superfund program is to return usable and potentially usable ground waters to their beneficial uses within a reasonable timeframe. MCLs and health-based numbers are considered appropriate cleanup goals for Class I and II aquifers. Therefore, any exceedances of these preliminary cleanup goals were considered as appropriate justification to take action to return the ground water to its beneficial use.

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4.0 Remedial Actions

In accordance with CERCLA and the NCP, the overriding goals for any remedial action are protection of human health and the environment and compliance with applicable or relevant and appropriate requirements (ARARs). A number of remedial alternatives were considered for the Site, and tinal selection was made based on an evaluation of each alternative against nine evaluation criteria that are specified in Section 300.430(e)(9)(iii) of the NCP. The nine criteria include:

1. Overall Protectiveness of Human Health and the Enviromnent. 2. Compliance with ARARs. 3. Long-Tern1 Effectiveness and Permanence. 4. Reduction of Toxicity, Mobility or Volume of Contaminants through Treatment. 5. Short-term Etfectiveness. 6. Implementability. 7. Cost. 8. State Acceptance. 9. Community Acceptance.

4.1 Remedy Selection

Remedial actions for the Site have been partitioned into three OUs: OU 1 addresses soil and sediment source contamination; OU2 addresses ground water contamination in the northern surticial aquifer; and OU3addresses the North Wetland.

EPA issued the Record of Decision (ROD) for OUI on October 13,1992. Based on the results of the Site's RIlFS. EPA determined that remediation of soil and sediment would be required for the protection of human health and the environment. Remedial action objectives (RAOs) established in the ROD for OUI include:

• Reducing cancer risk for industrial workers who continue to work on site to less than 1.0 x 10.4 .

• Protecting ground water from source contamination cat.!sing exceedances of drinking water standards.

The selected remedy forOU 1 consisted of the following remedial components:

• Excavating approximately 6,000 cubic yards of soil and sediment containing metal constituents above cleanup standards.

• Backfilling the excavated areas with clean till. • Performing ex-situ solidification and stabilization of contaminated soil and

sediment. • Disposing of solidified and stabilized material on site above the water table. • Covering the solidified material with an impermeable cap.

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• Implementing deed and/or land use restrictions to prevent any activity with the potential to damage the on-site monolith of solidified and stabilized material.

The 1992 OU 1 ROD selected cleanup goals for three soil and sediment contaminants of concern (COCs) that were designed to prevent leaching of contaminants to ground water above drinking water standards (Table 3).

Table 3: Soil and Sediment cac Cleanup Goals

Soil and Sediment COC

1992 OUI ROD Cleanup Goal in milligrams per kilogram

(mg/kg) Chromium 69

Lead 280 Zinc 10,860

In April 1997, EPA issued an Explanation of Significant Differences (ESD) for the 1992 OU 1 ROD. Despite numerous treatability studies performed on contaminated soil, a reagent mix that would ensure the solidified and stabilized material achieved the performance standards in the ROD could not be identified. The ESD modifIed the remedy to include off-site disposal of excavated materials at an approved landfill. The objectives of the modification were to ensure that cleanup goals were achieved and to reduce the amount of time required to achieve them. The change from on-site to off-site disposal of excavated materials eliminated the need for institutional controls to prevent damage to the originally planned monolith of solidified and stabilized material.

EPA issued the ROD for OU2 on September 9, 1993. The Site is one of two Superfund sites responsible for area-wide ground water contamination. Remediation of the southern surficial aquifer and the upper Floridan aquifer is being addressed by the remedies at the adjacent Peak Oil Co./Bay Drum Co. site. Therefore, ground water remediation at the Site addresses only the northern surfIcial aquifer. Based on the results of the Site's RIIFS, EPA deternlined that remediation of ground water in the northern surficial aquifer would be required for the protection of human health and the environment. RAOs established in the ROD for OU2 include:

• Protecting human health, welfare and the environment. • Ensuring compliance with applicable or relevant and appropriate requirements.

The selected remedy for OU2 'consisted of the following remedial components:

• Implementing remedial actions for OU 1 as selected in the 1992 OU 1 ROD. • Applying monitored natural attenuation (MNA) as the treatment technology for

the northern surficial aquifer. • Installing additional monitoring wells in the northern surficial aquifer.

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• Preventing discharge of ground water from the northern surficial aquifer into the surface water in Unnamed Creek.

• Installing a monitoring well in the upper Floridan aquifer .in the general vicinity of the fornler production wells in the SEG facility.

• Monitoring ground water to follow progress of natural attenuation. • Implementing a well survey within a one-mile radius of the Site. • Implementing institutional controls to restrict ground water use. • Completing the r~medial design for the contingency remedy.

The 1993 OU2 ROD stated that a contingency remedy would be implemented if satisfactory progress was not made by the natural attenuation process. The criterion for implementation of the contingency remedy was a failure to reduce ground water COC concentrations to either below cleanup goals or by at least 50 percent of "time-zero" levels (initial sampling during remedial design) within 2.6 years of the completion of the OU 1 remedial action. The major components of the contingency remedy included:

• Extracting contaminated ground water from the northern surficial aquifer. • Treating extracted ground water by chemical precipitation to remove metals. • Discharging treated ground water into the local publicly owned treatment works.

The 1993 OU2 ROD selected cleanup goals for six ground water COCs in the northern surficial aquifer (Table 4).

Table 4: Ground Water CDC Cleanup Goals

Ground Water COC 1993 OU2 ROD Cleanup Goal in micrograms per liter (llg/L)

. Arsenic 50 Cadmium 5 Chromium 100

Lead 15 Nickel 100 Zinc 10,000

OU3

EPA issued the ROD for OU3 on June 28, 1994. The baseline risk assessment determined that OU3 poses no unacceptable risk to human health and the environment. Therefore, the ROD selected no remedial action and no RAOs were established for OU3. However, COCs were detected at concentrations above background levels in wetland sediment and surface water during the wetland impact study. For this reason, a monitoring-only remedy was selected to monitor the ecological condition of the North Wetland and Unnamed Creek during the implementation of the OUI and OU2 remedies. The selected remedy for aU3 consisted of the following remedial components:

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• No remedial action. • Monitoring and perfom1ing ecological assessments of the North Wetlands and

Unnamed Creek for a period of at least eight years (the estimated time for OU2 cleanup goals to be achieved by MNA). Each assessment shall include:

o Performing general vegetation surveys to assess the composition and health of plant communities.

o Collecting samples to assess relative abundance and diversity of aquatic vertebrates and invertebrates.

o Sampling and analysis of wetland surface water, sediment and biota, to include assays for COCs and a minimum once-annual toxicity and bioaccumulation analysis.

o Performing field measurements of hardness, pH, temperature, dissolved oxygen and conductivity at each sampling station.

• Installing surficial aquifer monitoring wells immediately upgradient of Unnamed Creek, contingent upon final engineering measures selected for OU2.

The 1994 OU3 ROD identified seven surface water COCs: arsenic, cadmium, chromium, lead, mercury, nickel and zinc. Chemical-specific cleanup goals for these seven COCs were not established in the ROD. However, the Florida Surface Water Quality Standards for Class III surface water bodies were selected as an ARAR for surface water at the Site. Aluminum, which is a contaminant currently found in OU3 sediments and surface water, was not identified as a COC at the time the 1994 OU3 ROD was signed.

4.2 Remedy Implementation

OUI

The remedial design (RD) for the OU 1 remedy began in March 1993 and was completed in February 1996. Approximately 6,000 cubic yards of contaminated soil and sediments were excavated from the SEW and 'SEG properties from April to July 1997. Per the 1997 OU 1 ESD, all excavated materials were transported off site for disposal at an approved facility. Excavated areas were backfilled to grade with clean till. Because contaminated soil and sediment were disposed ofoff site, the deed and land use restrictions selected in the 1992 OU 1 ROD to protect the originally planned on-site monolith are no longer required. EPA approved'the OU 1 remedial action report and determined that remedy construction for OU 1 was complete on October 2, 1997. In January 2001, EPA signed a prospective purchaser agreement and covenant not to sue with Master-Halco, Inc. for the SEW property. In the agreement, EPA indicated that no further action was expected for the SEW property. '

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Time-zero COC concentrations used in the determination of whether the contingency remedy needed to be implemented were established at the January 19, 1994 sampling of the OU2 compliance monitoring wells. In November 1994, EPA directed Reeves Southeastern Corporation to prepare an RD report for OU2 outlining the technical requirements for the contingency ground water extraction system.

The PRP performed the RD for the contingency remedy from 1994 to 1998 and EPA approved the report in September 1998. During the drafting of the RD, new monitoring wells were installed in 1997. Per the 1993 OU2 ROD, this installation included a monitoring well screened in the upper Floridan aquifer in the vicinity of the former production wells on the SEG facility. The 1993 OU2 ROD also selected the implementation of well survey within a one-mile radius of the Site as part of the remedy. In accordance with the 1998 final RD for OU2, the radius of the applicable well survey area was shortened to 800 feet northwest of the Site. This well survey was completed in 1998 and no private water supply wells were identified within 800 feet of the northwestern corner of the Site. The PRP group for the Peak Oil Co./Bay Drum Co. site also completed a well survey in January 2004. This survey report confirmed that there were no potable water supply wells in the area immediately hydraulically downgradient (west-northwest) of the Site. The closest hydraulically downgradient non-potable supply wells identified were located more than 2,500 feet north and northwest of the Site's northern property line.

In September 1999, IGA began excavating on-site soil and discharging water from the excavation of the ditch along SR 574 in preparation for the installation of a new kettle for its galvanizing operations. FDEP directed IGA to discontinue discharging water from the Site to the ditch and notified EPA. Due to concerns about the potential impact of activities on the area-wide ground water remedial activities, EPA directed IGA to . suspend excavation and dewatering activities and to submit a plan detailing their activities. EPA conditionally approved the Surficial Aquifer Assessment Plan prepared and revised by IGA's contractors in November 1999. This approval allowed IGA to proceed with installation of sheet piling but prohibited dewatering activities until such time as EPA and IGA entered into a written agreement setting forth IGA's obligations and responsibilities concerning dewatering, sampling, treating and properly disposing of the water from the excavation. This written agreement between EPA and IGA was fonnalized in an AOC in December 1999.

In 2000, the 1998 RD report was modified to account for migration of the ground water plume·beyond the limits anticipated by the ROD and original RD. As part of the modified RD, the PRP submitted the design of a culvert to act as an engineering barrier to prevent ground water contamination from discharging to local surface water via a drainage swale north of the SEG property. This culvert design was approved by EPA in July 2000, but construction of the culvert was delayed due to site access issues. Construction was completed in January 2004 and approved by EPA in July 2004.

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EPA approved the contingency RD in a letter dated July 12, 2000. The 1993 OU2 ROD required that COC levels decline to 50 percent of time-zero levels, or below cleanup goals, within 2.6 years of the source control remedy completion. The OU 1 source control remedy was completed in October 1997 and an assessment of whether MNA was effectively addressing contamination within the prescribed timeframe was perforn1ed in 2000. EPA and FDEP determined that the available ground water data was inadequate to make a determination on the effectiveness of MNA.

Since the ROD anticipated that ground water contamination would attenuate to acceptable levels within 7.6 years of completion of the source control remedy, the PRP continued to gather additional ground water data until that the 7.6-year mark and presented the comprehensive ground water compliance monitoring results in 2004. The OU2 CD provided that EPA would consider the information presented in this report in making its decision concerning the effectiveness of the OU2 remedy and the need to implement the contingency remedy. In 2005, EPA concluded that zinc and nickel perforn1ance standards at the center of the plume were not being met and, therefore, the natural attenuation was not proceeding at a reasonable rate. Although the contingency pump-and-treat remedy had been specitied in the ROD and an RD for implementation of that remedy had been prepared and approved, EPA and the PRP concurred that the contingent remedy may not be the most appropriate technology. EPA authorized the PRP to investigate whether in situ chemical injections would be a viable alternative to the pump-and-treat technology for the Site.

A work plan for additional characterization and evaluation of an alternative remedy was approved in 2005 and, from May 2006 to May 2007, the PRP implemented the Additional Characterization and In Situ Ground Water Treatment Pilot Study Work Plan at the Site. The purpose of the work plan was to validate and retine the conceptual site ground water model, collect sufficient data to evaluate the effectiveness of injecting a reagent to treat metals in shallow ground water and to support the design of a full-scale application of this technology. The final report for implementation of the work plan was submitted to EPA and FDEP on' December 6, 2007.

The Additional Characterization and In Situ Ground Water Treatment Pilot Study Report concluded that the contingency pump-and-treat ground water remedy selected in the 1993 OU2 ROD would not adequately address ground water contamination for two reasons. First, the additional characterization determined that the lateral extent of contaminated ground water was greater than was anticipated by the ROD and contained a greater number of COCs exceeding performance standards than had been indicated by perforn1ance monitoring up until the time of the study. Second, approximately two-thirds of the COC mass to be remediated was located within a tine-grained Transition Zone between the Sand Zone and the underlying Hawthorn Forn1ation. The report concluded that timely ground water remediation by either MNA or the contingent pump-and-treat ground water remedy would not be feasible due to slower ground water flow and thus, slower metal transport, in this Transition Zone.

The report went on to investigate the possibility of in situ treatment of metals using chemical injections. A bench-scale study determined that calcium polysulfide was the test reagent with the greatest metal removal efficiency and did not result in solubilization o~ trace metals from soil into ground water. A pilot study was conducted to further evaluate in situ treatment of dissolved metals in ground water in the Sand Zone and Transition Zone using the calcium polysulfide reagent.

During the pilot study, the potential for leaching of arsenic and chromium from soil into ground water during in situ injections as well as the need to detem1ine a method for sustained neutralization of pH prior to injection of the reagent were identified as concerns. An arsenic treatability study report was submitted to EPA in 2009. The report investigated whether arsenic in ground water which had been mobilized from soil as a result of high sulfide concentrations and elevated pH in the calcium polysulfide reagent injections would naturally attenuate after reagent mixing with ground water and soil. The report concluded that natural geochemical processes would effectively attenuate soluble arsenic potentially mobilized by the in situ treatment.

The PRP also investigated the effectiveness of adding pneumatic fracturing to the in situ calcium polysulfide injections. Pneumatic fracturing is a technology used to enhance in situ chemical treatments in low-permeability soil by using high-pressure gas to create a fracture network in the substrate. This network then enhances the hydraulic conductivity of the geologic fom1ation being treated, allowing for increased transport of the reagent to areas of contamination.

Based on results of the pilot studies and bench-scale studies performed at the Site, the PRP prepared a focused feasibility study (FFS) in 2010. The report identified, reviewed and compared potential remedial technologies that would be more effective at addressing ground water contamination in the low-pem1eability Transition Zone than the contingent pump-and-treat remedy. This report was revised after EPA and FDEP provided review and comment. The updated FFS was submitted to EPA in July 201 L and is currently being reviewed.

Reeves Southeastern Corporation drafted and submitted an OU3 wetlands monitoring plan to EPA in August 1995. Based on EPA comments, Reeves Southeastern Corporation revised the plan and resubmitted it to EPA in December 2001. EPA approved the plan in 2002 and monitoring events have been performed annually since 2002. The period of OU3 monitoring was anticipated to last a minimum of eight years, which was the estimated time for OU2 cleanup goals to be achieved by natural attenuation. If the ground water remedy takes longer than eight years to complete, which is the case at the Site, monitoring of the North Wetland and Unnamed Creek will be extended to the monitoring period for the OU2 remedy.

The 1994 OU3 ROD stated that installation of surficial aquifer monitoring wells immediately upgradient of Unnamed Creek may be required depending on the

33

engineering measures selected under OU2 to prevent infiltration of the surficial aquifer to Unnamed Creek. As noted above, a culvert was installed in 2004 to act as an engineering barrier to prevent ground water contamination from entering surface water. Surficial· aquifer monitoring wells have therefore not been installed upgradient of Unnamed Creek.

A surface release attributable to lOA activities on the Site occurred during the current FYR period and required an interim removal action. On November 29,2007, an overflow occurred while diluting a chromate quench solution and 260 gallons of solution were released into the environment containing an estimated 0.169 pound of chromium. lOA excavated 38.53 tons of sediments from the detention pond in the operations area as well as the drainage area leading to the outfall to Unnamed Creek. Excavated sediments were disposed of at an off-site approved facility. Cleanup was performed to meet FDEP's residential direct exposure soil cleanup target level for chromium, but did not consider the ecological sediment screening criteria being utilized for OU3 monitoring. The cleanup did not investigate the presence or concentrations of other potential inorganic compounds, such as aluminum, cadmium, lead, nickel and zinc. FOEP released lOA from further obligation regarding the surface release in a letter dated June 15,2009.

4.3 Operation and Maintenance (O&M)

The OU 1 remedy has been completed and no further action is required to address source contamination. The SEWproperty, now owned by Master-Haleo, Inc., was addressed through OU 1 remedial actions and no site-related ground water contamination is present. The 1992 OUI ROD estimated O&M costs of $7,000 for ground water monitoring related to the originally planned on-site monolith. However, the 1997 OU 1 ESD changed the remedy to off-site disposal and ground water monitoring is no longer necessary. Therefore. there are no O&M activities required for this portion of the Site.

The MNA remedy for OU2 remains underway while an appropriate active remedy is identified, and sleceted, to improve the rate of ground water cleanup. The 1993 OU2 ROD selected semiannual ground water monitoring for the tirst three years and annual monitoring for the subsequent six years. However, the PRP implemented semiannual ground water monitoring events from January 1994 to August 2009, then began annual

. sampling in 2010. Additional monitoring wells have been installed as part of further site characterization studies, but these are not routinely sampled along with the perfonnance monitoring wells. The 1993 OU2 ROD estimated that the MNA remedy would cost $136,000/year and that implementation of the contingency remedy would cost· $2,504,000.

The 1994 OU3 ROD required monitoring of surface water, sediment and biota in the North Wetland and Unnamed Creek for a period of at least eight years, or until the OU2 ground water cleanup goals are achieved. The OU2 remedy has not been completed'and a modification to optimize the remedy is currently being evaluated. OU3 sampling of sediment, surface water and biota has been performed on an annual basis since 2002. However, biota sampling has not been completed at three of the four sampling locations during the current FYR review period or during the 2010 sampling event due to dry

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conditions and the absence of biota. The 1994 OU3 ROD estimated that implementation of the monitoring program would cost approximately $40,000/year.

O&M activities for the current FYR period include the semiannual sampling of ground water performance monitoring wells, annual monitoring of the North Wetland and Unnamed Creek and also additional site characterization studies, pilot testing and benchscale studies related to development of a more appropriate remedy for OU2. LFR Inc., the contractor for the Reeves Trust, was acquired by ARCADIS in 2009. ARDADIS continues to perform O&M activities at the Site for the Reeves Trust. Costs for O&M activities have been greater than those anticipated by the 1993 OU2 ROD and the 1994 aU3 ROD. ARCADIS is paid in annual lump sum payments and a larger sum was allocated in 2010 as a contingency for additional work that might develop during the course of the year.

Table 5: Annual O&M Costs

Date Range Total Cost (rounded to the nearest $),000)

01/0112006 to 12/31/2006 $149,000 01/01/2007 to 12/3 1/2007 $131,000 01/01/2008 to 12/31/2008 $149,000 01/0 1/2009 to 12/3 1/2009 $140,000 01/01/20 I0 to 12/3 1120 I0 $329,000

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5.0 Progress Since the Last Five-Year Review

The protectiveness statement from the 2006 FYR for the Site stated the following:

"For OU} (Soil/Sedirnent Removal) The remedy at OU} is protective ofhuman health and the environment.

For OU2 (Northern SUlj/cial Aquifer Monitoring) . The selected remedy at OU2 is considered protective ofhuman health in the short tenl/ as there are no apparent complete path-ways o/exposure to grozmdHmter. However, in order for the remedy to be protective in the long term, an active remedy should be implemented.

For OU3 (Monitoring ofNorth Wetland and Unnamed Creek) The selected remedy for the North Wetland in OU3 is considered protective ofhillnan health and the environment. A protectiveness determination o.lthe selected remedy for the Unnamed Creek portion o.lOU3 cannot be made untilflirther in/ormation is obtained as part o.f0 U2. However, achieving the long-term protectiveness ofOU2 should be protective ofOU3."

The 2006 FYR included three issues and seven recommendations. Each reconm1endation and its current status are discussed below.

Table 6: Progress on Recommendations from the 2006 FYR

Section Recom mendations Party

Responsible Milestone

Date Action Taken and

Outcome Date of Action

5.1

Complete the implementation of the Additional Characterization and In Situ Groundwater Treatment Pilot Study Work Plan.

Reeves Trust February

2007

A final report summarizing additional site characterization, the bench-scale treatability study and pilot study data collected in accordance with the work plan was submitted to EPA and FDEP.

12/06/2007

5.2 Develop plan for installation of additional monitoring wells.

/

Reeves Trust March 2007

Seven multi-level monitoring well clusters and five additional monitoring wells were installed as part of the Additional Characterization and In Situ Groundwater Treatment Pilot Study Work Plan.

12/06/2007

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Section Recom mendations Party

Responsible Milestone

Date Action Taken and

Outcome Date of Action

5.3 Sample mercury during the next groundwater sanipling event.

Reeves Trust January

2007

Ground water sampling for mercury has been performed at Sand and Transition Zone monitoring wells S-2 and G-5 since 2006 and 2007, respectively.

08/1012006

The pilot study report found that an

5.4

Investigate potential unidentified sources of groundwater contamination outside the former ponds.

Reeves Trust June 2007

additional source of chromium contamination may have been located to the south of the former ponds in the area of the former processing building.

12106/2007

5.5

Evaluate the need for sediment excavation in the Unnamed Creek and drainage swale.

Reeves Trust June 2007

Evaluation of the need to perfornl sediment excavation in Unnamed Creek and drainage swale has not been performed.

Incomplete

5.6 Evaluate institutional controls for both soil and groundwater.

EPA December

2007

The 2010 FFS included a consistent component of ground water institutional controls for each remedial alternative considered.

0310312010

Five remedial

5.7 Make decisiori regarding groundwater remedy.

EPA Based on Decision

alternatives were evaluated in the 20 I0

03103120 I0

FFS.

5.1 Complete Implementation of Pilot Study Work Plan

From May 2006 to May 2007, the PRP implemented the Additional Characterization and In Situ Ground Water Treatment Pilot Study Work Plan at the Site. The purpose of the work plan was to validate and refine the conceptual site ground water model, collect sufficient data to evaluate the effectiveness of injecting a reagent to treat metals in shallow ground water and to support the design of a full-scale application of this technology. The final report for implementation of the work plan was submitted to EPA and FDEP on December 6, 2007.

5.2 Install Additional Monitoring Wells

Additional monitoring wells were installed at the Site as part of additional site characterization activities completed under the Additional Characterization and In: Situ Groundwater Treatment Pilot Study Work Plan. These installations were documented in

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the 2007 Additional Characterization and In Situ Groundwater Treatment Pilot Study Report.

Seven multi-level monitoring well clusters and six individual monitoring wells were installed at the Site as part of the additional site characterization activities (Table 7). Each well cluster consists of two wells: I) the shallower well penetrates to approximately eight feet below the ground water table; and 2) the deeper well is constructed to monitor the Transition Zone between the Sand Zone and Hawthorn Group. Two overlapping microwells (MW008 and MW009) were installed in the Sand and Transition Zone and an additional Floridan aquifer monitoring well (MWOl 0) was also constructed at 90 feet below the ground surface.

Table 7: Additional Site Characterization Monitoring Wells

Multilevel Monitoring Individual Well Clusters Monitoring Wells

MWOOIIMWOOID MWOO6 MWOO21MWOO2D MWOO7 MWOO3/MWOO3D MWOO8 MWOO4/MWOO4D MWOO9 MWOOSIMWOOSD MWOIO

MWOIIIlID MWOl2 MW013/13D -

5.3 Sample Ground Water for Mercury

During the previous FYR period, mercury concentrations were detected in surface water. sediment and sediment pore water. the locations of the detections were at NW-02, where the North Wetland drains to Unnamed Creek, and UNC-02 at the northern outlet of the stornlwater conveyance structure. Ground water monitoring for mercury began at monitoring well S-2, located at the northern extent of the SEG property and east of the inlet to the stornlwater conveyance structure, in August "2006 and has continued annually since that time: Annual monitoring for mercury at monitoring well G-5, located along Unnamed Creek in the northwestern comer of the SEG property, began with an initial sample in January 2007 and has been performed annually since that time. Mercury concentrations have been detected at both wells. Mercury has not been identified as a site cac nor has a ground water cleanup goal for mercury been selected. However, a regulatory value (a federal MCL) is currently available and none of the detection concentrations exceed this value.

5.4 Investigate Potential Unidentified Source Areas for Ground Water Contamination

The 2007 Additional Site Characterization and In Situ Groundwater Treatment Pilot Study Report found that chromium contamination came from the area of the tornler processing ponds and that an additional source may have been located to the south of these ponds, near the location of the former SEG processing building.

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The report also indicated that there is ongoing point source discharge occurring at Outfall 001, which drains the stormwater detention pond in the on-site operations area to the North Wetland, Unnamed Creek and downstream drainage swales, as well as non-point source discharges throughout the large storage area of galvanized inventory. The 2007 Zinc Assessment Report prepared by IGA suggests that stormwater is contributing zinc source material to surface water and potentially to ground water as well. Follow up actions to address the potential additional chromium ground water source area and the zinc source material originating from the current tenant's operations have not been completed.

5.5 . Evaluate Need for Sediment Excavation

Evaluation of the need for sediment excavation as part of the OU3 remedy has not been perfornled.

5.6 Evaluate Soil and Ground Water Institutional Controls

The 2010 FFS evaluated feasible alternatives for addressing ground water contamination at the Site. Institutional controls were listed as a component of each alternative assessed. Current institutiof!al controls in place include a Florida Ground Water Delineated Area, which restricts the use of ground water and inStallation of wells, and also a Hillsborough County ordinance requiring connection to the municipal water supply. No additional ground water institutional controls were identified during the course of the 2010 FFS. However, institutional controls were retained as part of the remedy to eliminate any potential human health exposure pathways that might arise during active and passive remediation and the need for additional ground water institutional controls will be considered in selection of a moditied contingency remedy for OU2. The OU 1 relnedy included institutional controls to protect the originally planned on-site monolith. However, the 1997 OU 1 ESD changed the remedy to otT-site disposal and there is no onsite monolith to protect. For this reason, soil institutional controls were not evaluated. EPA can deternline whether the soil cleanup performed achieves unlimited use/unrestricted exposure standards and, if appropriate, remove OU 1 institutional controls via a site decision document.

5.7 Decide on Final Ground Water Remedy

The FFS examining remedial alternatives for ground water at the Site was presented to EPA and FDEP in March 2010 and is currently undergoing revisions based on Agency comments. The recommended alternatives include in situ treatment of ground water with calcium polysultide injections and institutional controls, as well as possibly lining or capping of the drainage swale area.

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6.0 Five-Year Review Process

6.1 Administrative Components

EPA Region 4 initiated the FYR in November 2010 and scheduled its completion for September 2011. The EPA site review team was led by EPA Remedial Project Manager (RPM) Scott Martin and also included EPA Community Involvement Coordinator (CIC) L'Tonya Spencer, contractor support provided to the Reeves Trust by Scott Starr, Don Bradshaw, Patrick Shirley and Scott Potter of ARCADIS, and contractor support provided to EPA by Treat Suomi and Sabrina Foster ofSkeo Solutions. A review schedule was established that consisted of the following activities:

• Community notitication. • Document review. • Data collection and review. • Site inspection. • Local interviews. • FYR Report development and review.

6.2 Community Involvement

In May 2011, a public notice was published in the Tampa Tribune newspaper announcing the commencement of the FYR process for the Site, providing contact information for Scott Martin, and inviting community participation. The press notice is available in Appendix B. No one contacted EPA as a result of this advertisement.

The FYR Report will be made available to the public once it has been finalized. Copies of this document will be placed in the designated site repository: Brandon Regional Library, 619 Vonderburg Drive, Brandon, FL 33511.

6.3 Document Review

This FYR included a review of relevant, site-related documents including the RODs, ESD, additional characterization and pilot study reports, and recent monitoring data. A complete list of the documents reviewed can be found in Appendix A.

ARARs Review

CERCLA Section 121 (d)(l) requires that Superfund remedial actions attain "a degree of cleanup of hazardous substance, pollutants and contaminants released into the environment and of control of further release at a minimum which assures protection of human health and the environn1ent." The remedial action must achieve a level of cleanup that at least attains those requirements that are legally applicable or relevant and appropriate. Applicable requirements are those cleanup standards, standards of control, and other substantive requirements, criteria or limitations promulgated under federal environn1ental or state enviromnental or facility siting laws that specifically address a

40

hazardous substance, remedial action, location or other circumstance found at a CERCLA . site. Relevant and appropriate requirements are those standards that, while not "applicable," address problems or situations sufficiently similar to those encountered at the CERCLA site that their use is well suited to the particular site. Only those state standards that are more stringent than federal requirements may be applicable or relevant and appropriate.

Chemical-specific ARARs are health- or risk-based numerical values or methodologies which, when applied to site-specific conditions, result in the establishment of numerical values. These values establish an acceptable amount or concentration of a chemical that may remain in, or be discharged to, the ambient environment. Examples of chemicalspecific ARARs include MCLs under the federal Safe Drinking Water Act and ambient water quality criteria enumerated under the federal Clean Water Act.

Action-specific ARARs are technology- or activity-based requirements or limits on actions taken with respect to a particular hazardous substance. These requirements are triggered by a particular remedial activity, such as discharge of contaminated groundwater or in-situ remediation.

Location-specific ARARs are restrictions on hazardous substances or the