Record of Decision:
CITY INDUSTRIES, INC.EPA ID: FLD055945653OU 01ORLANDO, FL03/29/1990
Record of Decision
Summary of Remedial Alternative Selection
City Industries (City Chemical) Site
Winter Park, Florida
Prepared by: U. S. Environmental Protection Agency
Region IV Atlanta, Georgia
RECORD OF DECISION
SITE NAME AND LOCATION
City Industries (City Chemical) Winter Park, Florida
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the City Industries Site inWinter Park, Florida chosen in accordance with CERCLA, as amended by SARA and, to the extentpracticable, the National Contingency Plan. This decision is based on the administrativerecord file for this site.
The State of Florida concurs on the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not addressed byimplementing the response action selected in this ROD, may present an imminent andsubstantial endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE REMEDY
This remedy is the final action for the site. It addresses the ground-water contamination,which is the principal threat remaining at the site. This is accomplished by pumping andtreating the contaminated ground-water. The treated ground-water will be discharged to apublicly-owned treatment works (POTW).
The major components of the selected remedy include:
Institutional Controls or Other Land Use Restrictions; Ground-water Monitoring of Surficial and Floridan Aquifers; Ground-water Recovery via Wells; Ground-water Treatment by Aeration to Pre-treatment Standards; Discharge of Treated Effluent to the Iron Bridge POTW or other local POTW; Treatability Studies to Ensure Compliance with POTW Pre-treatment Standards Backup Discharge Plan; and Review of Ground Water Use for Surficial Aquifer Every Five Years.
EPA has also selected a contingency alternative, in the event that the POTW does not agree toaccept the discharge.
The major components of the contingency remedy include:
Institutional Controls or Other Land Use Restrictions? Ground water Monitoring of Surficial and Floridan Aquifers; Ground water Recovery via Wells; Ground water Treatment by Aeration, Precipitation, Filtration, and Carbon
Adsorption; and Surface Water Discharge of Treated Effluent. Treatability Studies to Ensure Compliance with Surface Water Discharge Criteria Review of Ground Water Use for Surficial Aquifer Every Five Years.
The selected and contingency remedies are protective of human health and the environment,comply with Federal and State requirements that are legally applicable or relevant andappropriate to the remedial action, and are cost-effective. These remedies utilize permanentsolutions and alternative treatment (or resource recovery) technologies to the maximum extentpracticable and satisfy the statutory preference for remedies that employ treatment thatreduces toxicity, mobility, or volume as a principal element. Because these remedies will notresult in hazardous substances remaining on-site above health-based levels, the five-yearreview will not apply to this action.
TABLE OF CONTENTS
1.0 Site Location and Description 1
2.0 Site History 1
3.0 Community Relations History 4
4.0 Scope and Role of Response Action 6
5.0 Summary of Site Characteristics 6
6.0 Summary of Site Risks 10 6.1 Exposure Assessment Summary 10
6.11 Surficial Soil Contact 11 6.12 Drainage Ditch Exposure 11 6.13 Ground Water Exposure 12
6.2 Toxicity Assessment 13 6.21 Cancer Potency Factors 13 6.22 Reference Doses 13
6.3 Risk Characterization 15 6.31 Cancer Risk 15 6.32 Noncarcinogenic Risk 15
6.4 Environmental Risk 18
7.0 Description of Alternatives 18 7.1 Alternative 1 - No Action 18 7.2 Alternative 2 - Extraction, Aeration, POTW Discharge 21 7.3 Alternative 3 - Extraction, Aeration, Filtration, Precipitation,
Carbon Adsorption, Surface Water Discharge 24 7.4 Alternative 4 - Extraction, Aeration, Biological Oxidation,
Filtration, and Carbon Adsorption, Reinjection 29 7.5 Alternative 5 - Extraction, Aeration, Precipitation, Filtration,
Carbon Adsorption, Reinjection 30
8.0 Summary of Comparative Analysis of Alternatives 31 8.1 Protectiveness of Human Health and the Environment 32 8.2 Compliance with Applicable or Relevant and Appropriate Requirements (ARARS) 32 8.3 Reduction of Toxicity, Mobility, or Volume 32 8.4 Short-term Effectiveness 33 8.5 Long-term Effectiveness 33 8.6 Implementability 33 8.7 Cost 33 8.8 State Acceptance 33 8.9 Community Acceptance 34
9.0 The Selected Remedy 34
10.0 Statutory Determinations 41 10.1 Protection of Human Health and the Environment 41 10.2 Attainment of Applicable or Relevant and Appropriate Requirements 41 10.3 Cost-Effectiveness 41 10.4 Utilization of Permanent Solutions and Alternative Treatment or Resource Recovery Technologies to the Maximum Extent Practicable 41 10.5 Preference for Treatment as a Principal Element 42
11.0 Documentation of Significant Changes 42
LIST OF FIGURES
Figure 1-1 Site Vicinity Map 2 Figure 1-2 Site Location Map 3 Figure 5-1 Little Econlockhatchee Drainage Basin 7 Figure 5-2 Estimated Plume Boundary 9 Figure 7-1 Conceptual Layout of Sewer System Discharge Alternative 22 Figure 7-2 Process Schematic for POTW Discharge 23 Figure 7-3 Conceptual Layout of Surface Water Discharge Alternative 27
LIST OF TABLES
Table 6-1 Weight of Evidence and Potency Factors for Suspect Carcinogens Reported at the City Chemical Site 14
Table 6-2 Indicator Chemical Reference Doses for Short-Term and Chronic Exposure 16 Table 6-3 Summary of Potential Toxic Responses of Constituents 17 Table 6-4 Cancer Risks and Hazard Indices for Ground Water Exposure at Potable
Well 19 Table 6-5 Cancer Risks and Hazard Indices for Ground Water Exposure at
Non-Potable Well 20 Table 7-1 Ground Water Cleanup Goals for City Chemical Site 25 Table 7-2 Fresh-water Aquatic Life Criteria 28 Table 9-1 Detailed Cost Breakdown for Preferred Alternative 36 Table 9-2 Detailed Cost Breakdown for Contingency Alternative 39
LIST OF APPENDICES
Appendix A - Remedial Investigation Sampling Data and Locations Appendix B - Responsiveness Summary Appendix C - State Concurrence Memorandum
1.0 SITE LOCATION & DESCRIPTION
The City Industries (City Chemical) - Forsyth Road site is located at 3920 Forsyth Road,Winter Park, Florida. It should be noted that while the mailing address for the site isWinter Park, it is actually located in the unincorporated township of Goldenrod. The CityChemical Company operated a waste storage, disposal, and recycling facility at the ForsythRoad site from 1971 until August 1983. The one acre site Is situated in a light industrialarea in the eastern section of Orange County, Florida, approximately 1.2 miles east of WinterPark and 2.2 miles northeast of Orlando. A map showing the site vicinity is provided inFigure 1-1.
The site is bounded by Cato Steel, a metal fabricator, to the north, Topgun Gunite to thewest, Forsyth Road to the east., and a wooded area to the south. A site location map showingthe City Chemical site and adjacent properties is presented in Figure 1-2. Activities at thefacility included the receipt, handling, storage, reclamation, and disposal of various wastechemicals. General classes of wastes handled included chlorinated and nonchlorinated organicsolvents, paint and varnish wastes, acid/ alkaline plating wastes, and waste ink.
2.0 SITE HISTORY
In 1971, City Industries, Inc., purchased the fuel oil business previously owned and operatedby Charles Blackburn. Mr. Blackburn retained ownership of the property at Forsyth Road. In1977, it developed into a recycling and transfer facility for hazardous wastes. Due toinadequate plant practices and intentional dumping, soil and ground water at the site becamecontaminated. From 1981 through 1983, EPA and Orange County found the company to be out ofcompliance with safety and Resource Conservation and Recovery Act (RCRA) requirements, andordered the business to be closed in July, 1983.
In August 1983, the site was abandoned by the owner/operator of City Industries, ArthurGreer, leaving approximately 1,200 drums of hazardous waste and thousands of gallons ofsludge in a number of large holding tanks on the site. A removal of these wastes, funded bythe Florida Department of Environmental Regulation (FDER), was conducted during August andSeptember 1983. In early 1984, EPA issued an Administrative Order under CERCLA requiring CityIndustries to clean sludge from holding tanks, remove contaminated soils, and treatcontaminated ground water. The company did not comply with the EPA order. Beginning inFebruary 1984, the remaining sludge and storage tanks were removed by the EPA. In May 1984,the EPA removed 1,670 tons of contaminated soil, heat treated it, and returned it to thesite. Additionally, 180 cubic yards of highly contaminated soil were removed and transportedto a hazardous waste landfill. The City Chemical site was proposed for the NationalPriorities List (NPL) in August 1984. EPA notified approximately 250 potentially responsibleparties (PRPs), primarily waste generators, of their potential liability for remediation ofthe site and demanded payment for cost incurred during the removal of wastes. A settlementwith approximately 163 PRPs for $520,722 was obtained in July, 1988.
In December 1985, Arthur Greer was indicted on thirty-three counts involving mail fraud andenvi
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