RECORD OF DECISION

CASCADE PARK GASIFICATION PLANT AND CASCADE PARK LANDFILL SUPERFUND ALTERNATIVE APPROACH SITES (managed by the U.S. Environmental Protection Agency as one site)

TALLAHASSEE, LEON COUNTY, FLORIDA

PREPARED BY:

U.S. ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA, GEORGIA

February 2019

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Table of Contents

List of Acronyms and Abbreviations ......................................................................................... iii 1.0 DECLARATION ...................................................................................................................... 1

1.1 Site Name and Location .............................................................................................. 1

1.2 Statement of Basis and Purpose .................................................................................. 1

1.3 Description of Selected Remedy ................................................................................. 1

1.4 Statutory Determinations ............................................................................................ 2

1.5 Authorizing Signature ................................................................................................. 2

2.0 DECISION SUMMARY .......................................................................................................... 3

2.1 Site Name, Location and Description ......................................................................... 3

2.1.1 Cascade Landfill CERCLIS ID: FLD984769177 (AOC 1) ........................................ 3

2.1.2 Cascade Park Gasification Plant CERCLIS ID: FLD981931959 (AOCs 2 and 3) .... 3

2.1.3 Site Hydrogeology ...................................................................................................... 8

2.2 Site History and Enforcement Activities .................................................................... 8

2.2.1 Non-Time Critical Removal Action Memorandum .................................................... 9

2.2.2 2006 Removal Action ............................................................................................... 10

2.2.3 Additional Removal Action during Park Construction, 2010-2014 ......................... 11

2.2.4 Groundwater Sampling, 2007-2010 .......................................................................... 14

2.2.5 Groundwater Remedial Investigation, 2011-2014 .................................................... 14

2.2.6 Post Park Construction Groundwater Investigation, 2014-2018 .............................. 15

2.3 Community Participation .......................................................................................... 18

2.4 Scope and Role of Response Action ......................................................................... 19

2.5 Site Characteristics: Revised Conceptual Site Model ............................................... 20

2.6 Current and Potential Future Site and Resource Uses .............................................. 21

2.7 Site Risks .................................................................................................................. 21

2.7.1 Human Health Risk Summary ..................................................................................... 21

2.7.2 Ecological Risk Summary ............................................................................................ 23

2.8 Documentation of Significant Changes .................................................................... 23

3.0 RESPONSIVENESS SUMMARY ......................................................................................... 24

3.1 Availability of Administrative Record ...................................................................... 24

3.2 Response to Specific Comments ............................................................................... 25

Appendix A. Public Comments ................................................................................................ 33

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List of Acronyms and Abbreviations AOC Administrative Order on Consent ARAR Applicable or Relevant and Appropriate Requirement CERCLA Comprehensive Environmental Response, Compensation and Liability Act CERCLIS Comprehensive Environmental Response, Compensation, and Liability

Information System City City of Tallahassee CSM Conceptual Site Model CTL Cleanup Target Level ECMP Environmental Construction Management Plan EE/CA Engineering Evaluation/Cost Analysis EPA United States Environmental Protection Agency FAC Florida Administrative Code FDEP Florida Department of Environmental Protection GCTL Groundwater Cleanup Target Level ISCO In-Situ Chemical Oxidation MGP Manufactured Gas Plant µg/L Micrograms per Liter MNA Monitored Natural Attenuation NCP National Contingency Plan OSWER Office of Solid Waste and Emergency Response RI/FS Remedial Investigation/Feasibility Study SAA Superfund Alternative Approach SCTL Soil Cleanup Target Level State State of Florida

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1.0 DECLARATION 1.1 Site Name and Location The Cascade Park Gasification Plant site and the Cascade Landfill site are located near downtown Tallahassee in Leon County, Florida, immediately south of Bloxham Street and east of South Monroe Street. The latitude and longitude are 30.433584° and -84.278974°. The EPA identification number as recorded in the Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS) is FLD981931959 for the Cascade Park Gasification site and FLD984769177 for the Cascade Landfill site. The EPA manages the Cascade Park Gasification Plant site and the Cascade Landfill site as one site (Site) under the Superfund program. The Site is not listed on the National Priorities List. 1.2 Statement of Basis and Purpose This decision document presents the selection of a no further remedial action decision for groundwater associated with the Cascade Park Gasification Plant and Cascade Landfill Superfund Alternative Site (Site) in Tallahassee, Florida. This decision was chosen in accordance with the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), 42 U.S.C. § 9601 et seq., as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA) and, to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 Code of Federal Regulations (CFR) Part 300, as amended. This decision is based on the Administrative Record, which was developed in accordance with Section 113(k) of CERCLA, 42 U.S.C. § 9613(k). The Administrative Record file is available for review at the LeRoy Collins Leon County Main Public Library in Tallahassee, Florida, at the EPA Region 4 Records Center in Atlanta, Georgia, and on the EPA’s website at https://www.epa.gov/superfund/cascade-park-gasification-plant under the “Site Documents & Data” link. The EPA is the lead agency at the Site and is supported by the Florida Department of Environmental Protection (FDEP). The State of Florida (State), represented by the FDEP, has worked closely with EPA on the evaluation and selection of the Site remedy and State concurrence of the selected no further remedial action decision is anticipated. The FDEP did not provide comments during the public comment period. 1.3 Description of Selected Remedy This no further remedial action decision is limited to groundwater because subsurface soil, surface soil, sediment, and groundwater contamination at the Site were successfully addressed through a non-time critical removal action occurring from 2006 to 2014 in accordance with a 2003 Removal Action Memorandum. In 2011, prior to the full implementation of the non-time critical removal action, the EPA determined that groundwater contamination was increasing and the Site owner, the City of Tallahassee (City), agreed to perform a groundwater Remedial Investigation (RI) and Feasibility Study (FS) with EPA oversight. Upon completion of the non-time critical removal action in 2014, groundwater conditions began to improve at the Site. As of 2017, groundwater poses no known current or potential unacceptable threat to human health or

the environment and the previous response has eliminated the need for further remedial action. The groundwater located outside of the capped areas of the removal action on Site is below Federal and State of Florida health-based drinking water standards.

1.4 Statutory Determinations

The EPA has determined that no further action is necessary for the groundwater to ensure protection of human health and the environment. No remedial action is being selected; therefore, the statutory determinations under CERCLA § 121 regarding remedial actions do not apply.

The non-time critical removal action successfully addressed ecological and human health risks at the Site by excavating contaminated soil, sediment and aquifer material that contributed to groundwater contamination. In areas where excavation was limited by safety concerns, residual contamination was capped. The non-time critical removal action removed approximately 85,000 tons of material in 2006 and removed an additional 12,500 tons from 2010 to 2014. No residual , contamination exists outside the removal action's capped areas. The use of contaminated media (sediment, soil, and groundwater) located beneath capped areas on the Site is restricted by institutional controls in the form ofrestrictive covenants, which were implemented in 2011 pursuant to the Post-Removal Site Control Plan and are overseen by the State of Florida.

The Remedial Investigation, which focused on groundwater, began in 2011. In 2014 and 2015, data indicated significant improvements in the groundwater conditions at the Site. Groundwater data in 2016 indicated that contamination had further decreased. In 2017, groundwater sampling results were below health-based cleanup levels. The EPA expects that the groundwater will continue to remain below health-based cleanup levels in the future . As a result, the EPA has determined that no further action is necessary to protect public health or welfare or the environment. Because the groundwater located outside of the capped areas of the removal action poses no unacceptable risk, the EPA will not conduct five-year reviews.

1.5 Authorizing Signature

This Record of Decision documents the selected no further remedial action at the Site. The Director of the Superfund Division in EPA Region 4 has been delegated the authority to approve and sign this Record of Decision.

, Director Superfund Division U.S. Environmental Protection Agency, Region 4

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2.0 DECISION SUMMARY 2.1 Site Name, Location and Description The Site is located near downtown Tallahassee in Leon County, Florida, immediately south of Bloxham Street and east of South Monroe Street (see Figure 1). The latitude and longitude are 30.433584° and -84.278974°. The EPA identification number as recorded in the Comprehensive Environmental Response, Compensation and Liability Information System (CERCLIS) is FLD981931959 for the Cascade Park Gasification Site and FLD984769177 for the Cascade Landfill Site. The EPA manages the Cascade Park Gasification Plant Site and the Cascade Landfill Site as one site (Site) under the Superfund program utilizing the Superfund Alternative Approach. The current layout of the Site and of groundwater monitoring wells is shown in Figure 2. The Site is now a portion of the 25-acre “Cascades Park”, which was conceived by Florida’s Governor and Cabinet in November 1971 and designated as a historical landmark that should be restored and developed as a park. (This document will refer to the 25-acre park as “Cascades Park” and will refer to the Site name as “Cascade Park Gasification Plant” and “Cascade Landfill”.) Figure 3 shows a 2014 aerial photograph of the completed Cascades Park. Cascades Park consists of several former industrial facilities and residential areas and is divided into six areas of concern (AOCs): AOC 1: Former Cascade Landfill; AOC 2: Cascade Park Gasification Plant; AOC 3: Former Centennial Field; AOC 4: Former City Electric Light Plant; AOC 5: Former City Incinerator; and AOC 6: Former Smoky Hollow Neighborhood. The City of Tallahassee (City) is addressing AOCs 4, 5 and 6 under the State of Florida cleanup program. The City addressed AOCs 1, 2 and 3 through a non-time critical removal action overseen by the EPA. Figure 4 shows the historical Site features and the location of AOCs 1 through 5. 2.1.1 Cascade Landfill CERCLIS ID: FLD984769177 (AOC 1) The City operated the former Cascade Landfill from 1928 to 1936. The landfill received vegetative debris, construction materials, ash from the old City incinerator and filter materials from the gasification plant's purifiers. The 1-to-2-acre landfill is located south of the CSX railroad right-of-way. Waste at the landfill contaminated surface soil, subsurface soil, creek sediments and groundwater. 2.1.2 Cascade Park Gasification Plant CERCLIS ID: FLD981931959 (AOCs 2

and 3) The City operated the former manufactured gas plant (MGP) (AOC 2) between 1890 and the mid-1950s on a 2.5-acre parcel located west of Gadsden Street. The plant manufactured gas using the carbureted water process, which involved the destructive distillation of bituminous coal or coke in the presence of water vapor. The byproducts of the MGP operations included coal tar, light and heavy oils, sludge/ash, and ammonia wastes. Wastes from the MGP processes

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contaminated surface soil, subsurface soil, creek sediments and groundwater with metals and organic chemical contamination.

Figure 1. Site Location Map

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Site Location Map

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Figure 2. Site Map and Groundwater Monitoring Well Locations

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Figure 3. 2014 aerial photograph of the completed “Cascades Park”

SOURCE: INTERIM STA TUS REPORT CONSTRUCTION RELATED SOIL REMOVAL ACTIVI TIES, CASCADES PARK AOC 2 ANO 3, TALLAHASSEE, LEON COUNTY, FLORIDA FEBRUARY 6, 2014

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The former Centennial Field (AOC 3) was located on a 5-acre parcel between the former MGP and South Monroe Street. Centennial Field opened for games played by community teams in 1924. A stone wall was built around the field in 1928. By 1935, the grandstand had been constructed using funds from a federal work project. Lighting was added in 1938, allowing for the first evening baseball games and public events. Centennial Field closed in the early 1970s. The City sold both the former MGP property and Centennial Field to the State of Florida (State) for the development of Cascades Park in 1963. The State began park development activities in the 1970s, when the State rerouted Cascade Creek, stockpiled soil from the MGP, and spread contamination from the MGP into the former Centennial Field. In 2005, the State conveyed legal title of the former MGP property and Centennial Field back to the City for the construction of Cascades Park. 2.1.3 Site Hydrogeology The main feature of the Site hydrogeology is that it is a karst environment featuring a weathered limestone aquifer. The Site is located in a former natural drainage called Cascade Creek. Prior to industrial use, a waterfall existed nearby, and the area became known as “the Cascades”. The aquifer system consists of a surficial aquifer system, intermediate aquifer system and the Floridan Aquifer. The surficial and intermediate aquifers consist of silty-sand and clay layers interbedded with silty-clay lenses. The weathered limestone is typically encountered at depths ranging from 40 to 65 feet below ground surface. The variability of the depth to limestone is typical of karst formations. As the limestone weathers, voids form, collapse, and are filled with the overlying material. Prior to the non-time critical removal action, the surface water was the expression of the surficial and intermediate aquifers. During the removal action, contractors excavated to the top of limestone in the former MGP parcel, removing soil, the surficial aquifer, and the intermediate aquifer material. The excavated area is now a stormwater pond, lined with an impermeable liner. Karst lithology creates complicated groundwater flow dynamics. The primary direction of groundwater is downward in the area around the former natural drainage, which is now under a lined stormwater pond. Groundwater levels of the current monitoring wells suggest groundwater flow would be considered to be in a southeasterly direction. However, a study in 2012 and 2013 showed that injections near the pond did not flow in the southeasterly direction but flowed downward. 2.2 Site History and Enforcement Activities The City, as the current owner and a past owner of the Site, and the State, as a past owner of the Site, are potentially responsible parties. The City and the State jointly conducted investigations at the Site from the mid-1980s until 2002. After that time, the City conducted additional investigations and response actions at the Site with oversight from the EPA in accordance with settlement agreements entered into with the EPA.

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A brief history of the Site prior to the non-time critical removal action is summarized below.

• 1987-1989: the State conducted a preliminary assessment and site inspection. • 1990: a Consent Order was executed by the Florida Department of Environmental

Regulations and issued to the Florida Department of General Services, the Florida Department of Natural Resources and the City to assess contamination at the Site.

• 1993-1994: a phase 1 site assessment was performed by the State. • 1994: a site inspection prioritization was submitted to the EPA. • 1996-1997: an expanded site inspection was performed by the EPA.

2.2.1 Non-Time Critical Removal Action Memorandum In 1997, the EPA selected a removal strategy to address contamination at the Site. In October 1997, the EPA sent notice of potential liability letters to the City, the FDEP and the Florida Department of Management Services (FDMS) offering the parties an opportunity to enter into an administrative settlement for a removal action with the EPA. The City, the FDEP and the FDMS entered into an Administrative Order on Consent for Removal Action with the EPA to perform an engineering evaluation/cost analysis (EE/CA) in November 1998. The EPA conducted community interviews in March 1999 and developed a Community Relations Plan for the Site in May 1999. The EE/CA Report was completed in February 2002. The EPA published a Proposed Plan in March 2002 and sought public comments on the EE/CA Report and the EPA’s recommended removal alternative from March 25, 2002, through May 24, 2002. A public meeting to discuss that Proposed Plan was held in Tallahassee on April 2, 2002. On May 29, 2003, the EPA signed an Action Memorandum selecting a non-time critical removal action. Responses to the comments received during the public comment period were included in the Responsiveness Summary and attached to the Action Memorandum. In 2004, the City agreed to perform the non-time critical removal action, with EPA oversight, by entering into an Administrative Order on Consent with the EPA. The overall approach of the non-time critical removal action was source removal, off-site disposal, capping residual contamination, and monitored natural attenuation (MNA) of groundwater with pump and treat as a contingency. The Action Memorandum selected groundwater “remedial goals” for 29 contaminants of concern, based on federal maximum contaminant levels, or more stringent state primary drinking water standards under Florida Administrative Code (FAC) 62-550 that were identified as relevant and appropriate chemical-specific requirements. Under the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) at 40 CFR 300.415(j), removal actions shall attain applicable or relevant and appropriate requirements (ARARs) to the extent practicable considering the exigencies of the situation. The FDEP promulgated groundwater cleanup target levels (GCTLs) under FAC 62-777, Table 1 that incorporate by reference the Florida primary drinking water standards as well as health-based groundwater cleanup levels. The EPA considers the promulgated health-based GCTLs to be more stringent state chemical-specific ARARs but GCTLs based on organoleptic factors (such as taste, odor or coloration) are not considered ARARs. The 2003 Action Memorandum required the following removal action components for Cascade Landfill (AOC 1):

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• Install 24-inch clay cap and sod. • Require a deed restriction to limit groundwater use, limit well drilling, limit construction,

maintain stormwater features, limit land use, maintain on-site engineering controls and provide access.

• Install geotextile liner over sediment at the landfill. • Sample groundwater. • Remove contaminated creek sediments. • Construct concrete channel for Cascade Creek.

The Action Memorandum required the following removal action components for the Cascade Park Gasification Plant (AOC 2) and Former Centennial Field (AOC 3):

• Excavate the source area and dispose of soil off Site. • Leave the excavation to build a stormwater management feature and install an

impermeable pond liner. • Conduct and complete MNA of groundwater within 20 years, with a pump-and-treat

contingency. • Remove creek sediments. • Dispose of soil and sediment off Site. • Require a deed restriction to prevent groundwater use and restrict land use.

2.2.2 2006 Removal Action The City conducted removal actions between October 2005 and December 2006, resulting in the disposal of approximately 85,000 tons of contaminated soil and sediment. The detailed summary of that removal action is documented in two reports: Removal Action Report for the Former Cascade Landfill Site (AOC 2 & 3) and Removal Action Report for the Former Cascade Landfill Site (AOC 1). The AOC 1 removal action included sediment removal from the creek, capping of the landfill surface, covering the landfill embankment and covering of the creek channel with a box culvert. The AOC 2 and AOC 3 removal action included excavation and off-site disposal of sediment from Cascades Creek; excavation of source material from the MGP; disposal of material at an off-site disposal facility; dewatering, treatment and disposal of contaminated water; and installation of a low-permeability earthen liner within the excavated area. The excavation of AOC 2 and AOC 3 was divided into shallow and deep areas. The shallow excavations removed soil from the soil surface to a depth of approximately 15 feet. The deep excavations extended as deep at 41 feet below ground surface. Where residual contamination was not accessible for excavation, a geotextile liner or clay cap was placed at the maximum extent of the excavation. The excavations were backfilled with clean soil. A temporary clay pond liner was installed in the bottom of the new pond and was the main engineering control to prevent infiltration of surface water laterally into the intermediate and vertically into the Floridan Aquifer. The non-time critical removal action removed the surficial and the intermediate aquifer materials. The EPA

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approved the removal action reports on October 26, 2007, and noted that remaining work included groundwater monitoring and establishment of institutional controls. The construction of Cascades Park was expected to begin soon after the excavation was complete. However, due to economic conditions, park construction was delayed until 2010. From 2006 to 2010, the impermeable pond liner built as the main engineering control failed intermittently due to park construction and geotechnical instability. The City was not able to make permanent repairs to the pond liner until the construction of Cascades Park in 2013 and 2014, as described below. Post-Removal Site Controls As part of the non-time critical removal action, the EPA required post-removal site controls, pursuant to Section 300.415(l) of the NCP, to ensure the effectiveness and integrity of the removal action after its completion. The post-removal site controls include maintaining the engineering controls, conducting groundwater monitoring (discussed in Section 2.2.4) and implementing restrictive covenants. The restrictive covenants implemented in accordance with the Post-Removal Site Control Plan include seven restrictions on use, which include: maintain the engineering controls of the removal action and seek EPA approval prior to construction, excavation, drilling or modifying the stormwater infrastructure. The restrictive covenant for AOC 1 was recorded in pages 82-94 of Book 4241 of Public Records of Leon County, Florida, in April 2011. The restrictive covenant for AOCs 2 and 3 were recorded in pages 95-106 of Book 4241 of Public Records of Leon County, Florida, in April 2011. These restrictive covenants are included in the Administrative Record as document identification #11094737 and #11094738. Both restrictive covenants incorporate as an exhibit a Unity of Title recorded in pages 751-754 of Book 4015 in July 2007 in the Public Records of Leon County (see Administrative Record document identification #11094736). The restrictive covenants are overseen by the State. Information on the Site and its restrictive covenants are entered into the FDEP Institutional Control Registry Database. The FDEP conducts audits of the engineering and institutional controls to ensure restrictions remain protective of human health and the environment. 2.2.3 Additional Removal Action during Park Construction, 2010-2014 Planning and design of Cascades Park began in November 2003, led by an intergovernmental (city/county) agency called Blueprint 2000. The EPA recognized the design and planning process with its Excellence in Site Reuse Award in 2008. The design of Cascades Park incorporates stormwater management functions in a public park. The main stormwater pond is called Boca Chuba pond and is built in the excavation left by the removal action. Because the construction of Boca Chuba pond would uncover additional contamination and would partially destroy and expand the 2006 clay liner, Blueprint 2000’s contractor, URS Corporation, prepared an Environmental Construction Management Plan (ECMP) dated September 2009. The ECMP adapted the remediation components to park construction. The EPA considers the work conducted pursuant to the ECMP from 2010 to 2014 to be a continuation of the non-time critical removal action. The ECMP was modified as needed during construction in January 2011, March 2011 and October 2013.

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Park construction changed Site conditions through the removal of additional soil, the installation of the permanent Boca Chuba pond liner and pressure grouting underneath Boca Chuba pond, as discussed below. Additional Soil Removal During park construction, contractors excavated and disposed of approximately 12,500 tons of additional contaminated soil and source material. Together with the approximately 85,000 tons removed in 2005 and 2006, the total amount of contaminated soil and source material removed was approximately 97,500 tons. The excavation of additional contaminated soils was documented in a series of remediation progress reports prepared by URS Corporation. Permanent Pond Liner Installation Contractors installed the 96,000-square-foot Boca Chuba pond liner system from October 2013 to January 2014. The pond liner meets the design and performance standard requirements of the Action Memorandum and attained an average permeability of 1.33 x 10-7 centimeters per second. The 18-inch compacted clay liner achieved a minimum field density of 95 percent by Proctor Test and is covered with a 12-inch sand layer. The basis for design, construction details and quality assurance/quality control for the pond liner is documented in the September 2014 Boca Chuba Pond Liner Installation Report prepared by URS Corporation. Pressure Grouting Blueprint 2000 conducted pressure grouting for geotechnical purposes in the fall of 2013. The City’s contractor, Ardaman and Associates, injected about 500 cubic yards of cement grout into void spaces located under the pond. Figures 5 and 6 show pressure grouting to address geotechnical issues in 2013. The details of the pressure grouting are in the Progress Report Regarding the Supplemental Subsurface Soil and Limestone Exploration and Remediation of Cavities, Soft Soils and Limestone Conditions in Boca Chuba Pond in the Area of Retaining Wall RW-51, and in the Area of the Former Vortex.

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Figure 5. Pressure Grouting in 2013

Figure 6. Pressure Grouting in 2013

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2.2.4 Groundwater Sampling, 2007-2010 Consistent with the 2003 Action Memorandum, groundwater sampling was conducted from 2007 to 2011 to monitor residual groundwater concentrations after the 2006 removal action. The 2007 Post-Removal Site Control Plan Addendum documents the sampling plan. From 2007 to 2011, data showed overall decreasing trends, but there were increasing trends in certain wells at the Cascade Park Gasification Plant (AOC 2). In 2011, the EPA determined that the groundwater remediation goals may not be met in an appropriate timeframe and required the City to initiate a remedial investigation and feasibility study focused on the residual groundwater contamination. 2.2.5 Groundwater Remedial Investigation, 2011-2014 In December 2011, the EPA and the City entered into an Administrative Settlement Agreement and Order on Consent for Remedial Investigation/Feasibility Study to evaluate potential groundwater remedial actions. The Superfund Alternative Approach was used in that agreement. The Superfund Alternative Approach is an alternative to listing a site on the National Priorities List when a site scores high enough to be listed on the National Priorities List. Under the Superfund Alternative Approach, the same processes and standards for investigation, cleanup and community involvement are used as for a site on the National Priorities List. In 2012 (during park construction), the City began the groundwater remedial investigation, installed new wells and conducted sampling. In 2012, 10 wells contained contaminants above GCTLs and there were five contaminants detected above GCTLs and above background: benzene, acenaphthene, naphthalene, 1-methylnaphthalene and 2-methylnaphthalene. In 2013, nine wells were added to the monitoring network and a total of 11 wells showed exceedances of GCTLs. 2013 Treatability Study The City conducted a treatability study in 2012 and 2013 to evaluate in-situ chemical oxidation (ISCO) as a potential remedial approach. The City summarized the results in the September 2013 In-Situ Chemical Oxidation Field-Scale Treatability Study Report. During review of the report, the EPA observed that the baseline samples, collected prior to ISCO injection (on January 15 and 16, 2013), showed improvements to water quality that could not be attributed to the ISCO injections, suggesting that other changes could be occurring in the aquifers. The ISCO monitoring also demonstrated that the downward flow of groundwater is greater than the horizontal flow. 2014 Feasibility Study The City prepared a Feasibility Study Report, submitted in February 2014, that identified six potential remedial alternatives to address the groundwater contamination. The review of the Feasibility Study Report coincided with the completion of the Boca Chuba pond liner, the grand opening of Cascades Park and groundwater sampling in March 2014. The March 2014 groundwater data showed a decrease in contamination levels and indicated that fundamental changes were occurring in the groundwater. The EPA placed the review of the Feasibility Study

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Report on hold until after groundwater conditions stabilized and more data could be collected to prevent the premature selection of a remedial action. 2.2.6 Post Park Construction Groundwater Investigation, 2014-2018 Park construction finished in 2014. Additional groundwater data collected by the City in 2015 further changed the understanding of contamination at the Site. In 2015 and 2016, three and four wells, respectively, had exceedances of GCTLs. The only contaminants detected above GCTLs in 2015 and 2016 were benzene (maximum of 3.5 micrograms per liter (µg/L), compared to the GCTL of 1 µg/L) and acenaphthene (maximum of 55 µg/L, compared to the GCTL of 20 µg/L). The other 11 wells sampled in 2015 and 2016 did not contain detections above any GCTL. On March 18, 2016, the EPA formally notified the City that the Feasibility Study Report would not be reviewed further until additional sampling was conducted. Detailed Evaluation of Benzene Data In 2015 and 2016, there were four wells with exceedances of the health-based GCTL for benzene: IW201, MW102, IW102 and MW056. Wells IW201 and MW102 The highest detections of benzene in 2015 and 2016 were in wells IW201 (2.6 µg/L) and MW102 (3.5 µg/L). The EPA reviewed the installation of the wells and found that these wells were installed in the footprint of the 2006 clay pond liner. Figure 7 shows the extent of the capped area, the well locations and recent groundwater sampling results. The pond liner is an engineered cap placed over residual contamination and constitutes a waste management area. Under EPA Superfund cleanup policy (OSWER Directive 9283.1-33), the EPA does not expect to restore contaminated groundwater located underneath a waste management area with a containment remedy such as the former landfill (AOC 1). Instead, the EPA expects restoration from the boundary of that area and downgradient throughout a plume (if one exists) to ensure that any contamination does not migrate away from the waste management area. Therefore, the EPA does not need additional sampling from wells IW201 and MW102.

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Figure 7. Extent of Capped Area, Well Locations, and Benzene Trends for Wells IW102 and MW056 Wells IW102 and MW056 The benzene levels in well IW102 were non-detect in 2015 and 1.2 µg/L in 2016. The benzene levels in well MW056 were 1.6 µg/L and 1.1 µg/L in 2015 and 2016, respectively. Both wells also showed a strong decreasing trend from 2013 to 2017. The EPA and the FDEP discussed the technical issues related to evaluating the completion of the MNA response selected for groundwater cleanup required by the Action Memorandum. The EPA, after consultation with FDEP, determined that two additional rounds of groundwater monitoring, conducted at least two months apart, would provide enough additional data to evaluate the completion of the MNA groundwater cleanup in wells IW102 and MW056. The EPA sent correspondence to the City on May 19, 2017, explaining the sampling required. In June and July 2017, the City sampled wells IW102 and MW056, and both wells were non-detect for benzene. In September 2017, a second sampling found the same result – both wells were non-detect for benzene. Figure 7 shows the Site, the well locations, the extent of the capped area and the benzene trends for wells IW102 and MW056. Figure 8 shows benzene concentrations over time in well IW102 with notations for the period of park construction. Figure 9 shows benzene trends for MW056.

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17

Figure 8. Well IW102 Benzene Concentrations Over Time

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18

Clarification of Cleanup Standards In 2016, the EPA evaluated the cleanup standards used by the City in the remedial investigation and feasibility study. The EPA found that the City correctly used the benzene GCTL of 1 µg/L, which is a promulgated health-based number (Florida Primary Drinking Water Standard) that the EPA considers as a chemical-specific ARAR. The EPA also found that the acenaphthene GCTL of 20 µg/L is an organoleptic-based (odor minimizing) value as opposed to a health-based level for consumptives uses of groundwater. As a result, the GCTL for acenaphthene was determined by the EPA to be ‘relevant’ but not an ‘appropriate’ requirement and thus would not be the basis for the groundwater cleanup level for that contaminant. Instead, the EPA calculated a health-based value of 530 µg/L for acenaphthene, which is based on a hazard index of 1. The maximum detection of acenaphthene was 55 µg/L. For reference, the State of Florida calculated a health-based value of 420 µg/L for acenaphthene (see Table 7 of Technical Report: Development of Cleanup Target Levels (CTLs), FAC Chapter 62-777). 2.3 Community Participation The EPA has been actively engaged in seeking community input at the Site since the 1990s. Community involvement activities commenced prior to a non-time critical removal action being selected. The EPA conducted community interviews in March 1999 and developed a Community Relations Plan for the Site in May 1999. The EE/CA Report was completed in February 2002. The EPA published a Proposed Plan in March 2002 and on March 22, 2002, published notice of a public meeting and comment period on the proposed removal action in the Tallahassee Democrat. The EPA sought public comments on the EE/CA Report and the EPA’s recommended removal alternative from March 25, 2002, through May 24, 2002. A public meeting to discuss that Proposed Plan was held in Tallahassee on April 2, 2002, and a transcript of the public meeting was prepared. The EPA issued fact sheets about the Site and sent them to community members in 2002, 2005, 2012, 2017 and 2018. Prior to issuance of a Proposed Plan recommending no further remedial action at the Site, the EPA updated the Community Involvement Plan and finalized it on June 20, 2018. The EPA hosted a public availability session with approximately 15 people in attendance on June 21, 2018, at the Tallahassee Community College Plaza Conference and Events Room to discuss the Site’s history and inform the public that a Proposed Plan would be issued in the near future recommending no further remedial action. On July 9, 2018, the EPA issued a Technical Memorandum that presented the technical recommendation to end the Remedial Investigation. The memo includes a table of groundwater analytical results for the twenty wells in the monitoring program from 2008 and 2018. The July 9, 2018 Technical Memorandum was distributed to all attendees of the June 20, 2018 community meeting. On July 26, 2018, the EPA issued a Proposed Plan recommending no further remedial action. The Proposed Plan public comment period started on July 26, 2018, with an initial end date of August 27, 2018. The Administrative Record was made available via compact discs and placed in the Information Repository located at the LeRoy Collins Leon County Main Library and in the

19

EPA’s Region 4 Office. The EPA distributed the Proposed Plan by email on July 24, 2018, to the attendees of the public availability session. Notice of the issuance of the Proposed Plan, the public comment period and the availability of the Administrative Record was published in the Tallahassee Democrat newspaper on July 28, 2018. An extension of the Proposed Plan public comment period was requested. As a result, the public comment period was extended to September 26, 2018, and notice of the comment period extension was published in the Tallahassee Democrat on August 31, 2018. During the public comment period, a commenter notified the EPA that compact discs containing the Administrative Record could not be viewed in the LeRoy Collins Leon County Main Library. In response, on September 28, 2018 the EPA placed all of the documents contained in the Administrative Record on its website at: https://cumulis.epa.gov/supercpad/SiteProfiles/index.cfm?fuseaction=second.docdata&id=0404729#AR to be publicly viewed online and in the Information Repository. Additionally, the EPA extended the public comment period until November 17, 2018, and notified the public of the extension in the Tallahassee Democrat on October 17, 2018, and that the Administrative Record could be viewed on EPA’s website, electronically at the Information Repository, or in EPA’s Region 4 Office. The AR can also be located by selecting the “Site Documents & Data” link on the site profile page at https://www.epa.gov/superfund/cascade-park-gasification-plant. 2.4 Scope and Role of Response Action The scope of this Record of Decision is limited to groundwater, for which there are no current unacceptable Site risks. The original cleanup strategy for the Site was:

• Removal of contaminated soil and sediment. • Removal of material acting as a source of groundwater contamination. • Residual soil contamination above leachability criteria was capped in place with a clay

liner. • Groundwater attenuation within 20 years, with pump and treat as a contingency. • Institutional controls and maintenance of the engineering controls to maintain

protectiveness. • Implementation of post-removal site controls to sustain the integrity of the removal

action. The cleanup strategy was revised in 2011 because the groundwater contamination was not attenuating as expected. The EPA required a groundwater remedial investigation with the expectation that a remedial action would be needed to address groundwater contamination. From 2011 to 2014, the removal action continued during park construction:

• Removal of additional source material. • Replacement of damaged liners. • Installation of new liners and caps. • Continued groundwater sampling as part of the groundwater investigation.

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When park construction was complete and all the components of the removal action were permanently in place, the groundwater contamination rapidly attenuated. The EPA now understands that damage to the liner was a significant factor in the failure of the initial groundwater strategy. The original removal cleanup strategy is now functioning as intended. No further remedial action is necessary to ensure protection of human health and the environment. No residual contamination exists outside the removal action’s capped area. The groundwater outside of the capped area poses no known risk to human health or the environment and does not constitute waste left in place, therefore, the EPA will not conduct five-year reviews. 2.5 Site Characteristics: Revised Conceptual Site Model The Site’s Conceptual Site Model (CSM) that was most recently presented in the 2014 Feasibility Study Report is now outdated due to the changed conditions at the Site and 2016 and 2017 groundwater sampling data. An updated CSM is summarized below and describes the changes in nature and extent of contamination over time and in response to past cleanup actions. The CSM is based on current and future land use of the Site remaining recreational. Prior to 2006, large amounts of source material were present in the soils and had moved into the intermediate aquifer and the top of the Floridan Aquifer. This source material was in contact with infiltrated rainwater, surface water and groundwater, and contaminants leached into the groundwater, causing significant groundwater exceedances. The 2006 removal action removed large amounts of source material from site soils and the aquifer, which eliminated the leaching of contaminants. Because there were physical limitations to the extent of excavations along the CSX railroad and along Gadsden Street, impermeable clay or plastic liners were placed where residual contamination was left in place. Also, the City built a stormwater pond inside the pit left by the excavation. The City placed a clay liner in the bottom of the pond. The increase in groundwater contamination in some wells from 2006 to 2011 is now understood as most likely being the result of the destruction of the pond liner and/or the result of water infiltrating through residual subsurface contamination. Prior to park construction and implementation of the ECMP, contaminants continued to leach into groundwater. The mechanisms of the improvements to water quality are likely a combination of source removal and reduced infiltration of surface and groundwater into residual contamination. It is possible that the pressure grouting positively changed conditions. Overall, the ECMP and park construction reduced the contaminant concentrations in groundwater. As of 2017, the non-time critical removal action has removed or capped virtually all of the source materials contributing to groundwater contamination. There is no expectation that the total dissolved mass of contaminants will increase. The EPA expects that the groundwater will continue to remain below health-based cleanup levels in future. Residual capped contamination

21

and clay liners are engineering controls of the removal action. Capped areas are subject to implemented restrictive covenants and overseen by the State. 2.6 Current and Potential Future Site and Resource Uses The Site’s current and future land use is recreational. The Site has been fully redeveloped as part of Cascades Park. The 2003 Action Memorandum assumed this future land use and required restrictive covenants to limit the future land use accordingly. The restrictive covenant for AOC 1 was recorded in pages 82-94 of Book 4241 of Public Records of Leon County, Florida, in April 2011. The restrictive covenant for AOCs 2 and 3 were recorded in pages 95-106 of Book 4241 of Public Records of Leon County, Florida, in April 2011. These restrictive covenants are included in the Administrative Record as document identification #11094737 and #11094738. Both restrictive covenants incorporate as an exhibit a Unity of Title recorded in pages 751-754 of Book 4015 in July 2007 in the Public Records of Leon County (see Administrative Record document identification #11094736). The covenants state: “There shall be no agricultural use of the land including forestry, fishing and mining; no hotels or lodging; no amusement parks, camps, or zoos; no residential uses; and no elementary and secondary schools, or day care services.” Information on the Site and its restrictive covenants are entered into the FDEP Institutional Control Registry Database. The FDEP conducts audits of the engineering and institutional controls to ensure restrictions remain protective of human health and the environment. Groundwater is classified as a potential drinking water source, but groundwater is not currently in use. 2.7 Site Risks The scope of this Record of Decision is limited to groundwater, for which there are no known current or potential Site risks. This summary of Site risks includes historical risk information collected prior to 2002. The detailed summary of the non-time critical removal action is documented in the removal action reports – the Removal Action Report for the Former Cascade Landfill Site (AOCs 2 & 3) and the Removal Action Report for the Former Cascade Landfill Site (AOC 1). 2.7.1 Human Health Risk Summary Human health risks were successfully addressed by the non-time critical removal action. The key findings of the streamlined human health risk evaluation were included in the 2002 EE/CA. In 2002, the human health risk evaluation indicated the following media exceeded the screening levels:

• Surface and subsurface soils at AOC 1 (Former Cascade Landfill). • Surface and subsurface soil, and groundwater at AOC 2 (Cascade Park Gasification

Plant). • Groundwater at AOC 3 (Former Centennial Field).

22

Key Findings of the 2011 Remedial Investigation Human Health Risk Assessment The groundwater remedial investigation that started in 2011 included a streamlined human health risk assessment, using groundwater data from 2006 to 2012. The 2012 Remedial Investigation Report used a preliminary risk evaluation approach, which used a simplified risk assessment approach comparing groundwater concentrations to default GCTLs. The 2012 results indicated a lifetime excess cancer risk of 4.80 x 10-5 due to benzene and a non-cancer risk of 73.71 due to non-carcinogenic polyaromatic hydrocarbons. This level of risk exceeds the risk range the EPA considers acceptable under CERCLA and the EPA would require an action at CERCLA sites where this level of risk is present. However, Site conditions and groundwater data changed dramatically between 2012 and 2017 and the EPA considers the risk analysis from the 2012 Remedial Investigation Report to no longer represent current conditions and to be out of date. 2018 Summary of Human Health Site Risks As of 2017, groundwater contaminants of concern are below health-based cleanup levels that are either based on chemical-specific ARARs (namely federal maximum contaminant levels or more stringent FDEP GCTLs) or, in the case of acenaphthene, must be calculated. The EPA did not complete an update to the 2012 streamlined human health risk assessment because there are no groundwater constituents above drinking water or health-based standards. The health-based levels used for comparison were the FDEP GCTL of 1 µg/L for benzene, the EPA calculated health-based value of 530 µg/L for acenaphthene (based on a hazard index of 1), and the FDEP GCTLs for other polyaromatic hydrocarbons. The potential risk to future residents from exposure to groundwater is less than a hazard index of 1 and less than one in a million for cancer risk. Table 1 summarizes the improvements in groundwater quality. The data from the last two wells with exceedances is summarized in Figures 8 and 9. The pond liner is an engineered cap and constitutes a waste management area and the EPA does not expect to restore groundwater located underneath engineered cap areas in accordance with the NCP and EPA policy (OSWER Directive 9283.1-33).

23

Table 1. Number of Wells with Health-Based Exceedances Outside of Capped Area

Year Number of Wells with Health-Based Exceedances Outside of Capped Area

Wells with Health-Based Exceedances Outside of Capped Area

2010 4 MW036, MW049, MW055, MW056

2011 4 MW036, MW049, MW055, MW056

2012 7 (9 wells added) MW049, MW055, MW056, MW103, MW104, MW105, IW102,

2013 8 MW036, MW049, MW055, MW056, MW103, MW104, MW105, IW102,

2014 3 MW036, MW056, IW102

2015 1 MW056

2016 1 MW056

2017 0 none

2.7.2 Ecological Risk Summary Ecological risks were successfully addressed by the non-time critical removal action by excavating and/or capping contaminated sediments. A streamlined screening-level ecological risk assessment conducted for the 2002 EE/CA found organic and inorganic constituents posed unacceptable ecological risks to fish, benthic macro invertebrates, soil invertebrates, insectivorous mammals, and omnivorous birds. To streamline the analysis, EPA Region IV ecological risk-based screening levels were used. The non-time critical removal addressed ecological risks from PAHs and petroleum related constituents. The detailed summary of the removal action is documented in the removal action reports – the Removal Action Report for the Former Cascade Landfill Site (AOCs 2 & 3) and the Removal Action Report for the Former Cascade Landfill Site (AOC 1). 2.8 Documentation of Significant Changes There were no changes between the Proposed Plan and the Record of Decision.

3.0 RESPONSIVENESS SUMMARY The EPA proposed a no further action remedial decision in the Proposed Plan. The EPA presented a Site update at a public availability session with approximately 15 people in attendance on June 21, 2018, at the Tallahassee Community College Plaza Conference and Events Room to discuss the Site’s history and to inform the public that a Proposed Plan would be issued in the near future recommending no further remedial action. In accordance with CERCLA Section 117(a), 42 U.S.C. §9617(a) and 40 C.F.R. §300.430(f)(3)(D), the EPA provided an opportunity for a public meeting during the public comment period. The EPA issued the Proposed Plan recommending no further remedial action on July 26, 2018. During the public comment period, the EPA received comments from one commenter who is a nearby resident of the Site representing himself and the Myers Park Neighborhood Association. The comments EPA received during the public comment period are summarized below and included as Appendix A of this ROD. Public involvement is a central component of the EPA’s work at Superfund and Superfund Alternative Sites. This section documents public comments on the Proposed Plan and the EPA’s responses to those comments. 3.1 Availability of Administrative Record On July 26, 2018, the EPA issued a Proposed Plan recommending no further remedial action. The Proposed Plan public comment period started on July 26, 2018, with an initial end date of August 27, 2018. The Administrative Record was made available via compact discs and placed in the Information Repository located at the LeRoy Collins Leon County Main Library and in the EPA’s Region 4 Office. Notice of the issuance of the Proposed Plan, the public comment period and the availability of the Administrative Record was published in the Tallahassee Democrat newspaper on July 28, 2018. An extension of the Proposed Plan public comment period was requested. As a result, the public comment period was extended to September 26, 2018, and notice of the comment period extension was published in the Tallahassee Democrat on August 31, 2018. During the public comment period, a commenter notified the EPA that compact discs containing the Administrative Record could not be viewed in the LeRoy Collins Leon County Main Library. In response, on September 28, 2018, the EPA placed all of the documents contained in the Administrative Record on its website at: https://cumulis.epa.gov/supercpad/SiteProfiles/index.cfm?fuseaction=second.docdata&id=0404729#AR to be publicly viewed online and in the Information Repository. Additionally, the EPA extended the public comment period until November 17, 2018, and notified the public of the extension in the Tallahassee Democrat on October 17, 2018, and that the Administrative Record could be viewed on EPA’s website, electronically at the Information Repository, or in EPA’s Region 4 Office.

3.2 Response to Specific Comments Letter dated August 13, 2018, from Resident, representing self and Myers Park Neighborhood Association.

Comment 1:

• The timing of the Alternate Superfund Proposed Action is rather fast considering the long period the site has undergone study, soil removal and site construction of the park. This is especially true with regards to citizen involvement and knowledge of the true environmental condition of the site. The site repository has not yet been stocked with all material required for informed decisions. The only document I found was the Original Administrative Record, 1999-2004. I believe you stated that this has now been amended, but have no concrete evidence of this.

EPA’s Response:

• This no further action decision is the result of years of studies and cleanup work at the Site. When the EPA addresses all risks at a Superfund Site, a no further action decision is warranted. Based on the commenter’s requests, the Proposed Plan public comment period was extended twice from August 27 to November 17, 2018, to provide the public additional opportunities to view the Administrative Record and provide comments. Please see Section 3.1 above for information on the availability of the administrative record at the Information Repository located at the LeRoy Collins Leon County Main Public Library.

Comment 2:

• The lack of area wide environmental data adjacent to the site and which may have an effect on at least, ground water flow at the site. There are several environmental cleanup sites in the South Monroe corridor (Buddy’s Marine, Concord cleaners, Exxon/Sunoco gas station, etc) which have documented contamination (BTEX,’perc’ for example). You reference the BTEX coming from probably an offsite source, but do not sufficiently explain that reasoning. There are also adjacent City of Tallahassee potable water supply wells (CW01,CW03:with GAC filtration systems ), as well as State office and Florida State University air conditioning supply wells. These wells have the potential to affect the groundwater flow beneath the site. I have not seen historic nor recent Potentiometric maps of the Upper Floridan Aquifer for this site. In view of the fact that there is probably perched water at the site(personal communication, Mr. George Wigand, LFR), mitigating groundwater contamination based on just 2 sample events may be premature.

EPA’s Response:

• Areas of perched water at the Site were largely removed during the non-time critical removal action.

• It is not accurate to characterize EPA’s decision as solely based on two sampling results. Groundwater sampling included about 22 monitoring wells around the MGP. After the removal action was complete, only two of 22 wells exceeded the GCTL for benzene. The EPA requested additional sampling prior to any decision making. The EPA delayed the cleanup decision to allow groundwater conditions to stabilize after the park construction. The EPA developed a testable hypothesis that the removal action had addressed contamination. To test this hypothesis,

EPA required two sampling events, consistent with the concept of using the most recent groundwater data for remedial decision making. If those two sampling events indicated contamination above the benzene GCTL, the EPA would have concluded that additional sampling or remedial action would have been warranted.

• The scope of EPA’s no further remedial action decision is limited to the Site.

• Contamination at the nearby sites mentioned by the commenter is addressed by State cleanup authority. This ROD does not limit the State’s ability to address contamination at those sites.

• Other releases are addressed by the appropriate State cleanup programs.

o The State of Florida provides online tools to track and identify sites such as: http://geodata.dep.state.fl.us/

o The FDEP Contamination Locator Map is available at http://prodenv.dep.state.fl.us/DepClnup/welcome.do . The output for the area around the Site is show below.

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MCKENZIE TANK LINES (TAUY} 2778 WEST THARP STREET TALlAHASSEE, Fl 32302 facility Id: COM_68413 ACTIVE Other Cleanup Watch This Slte Documents

TEAM TOYOTA INC 2800 W TENNESSEE ST TALlAHASSEE, FL 32304 facllityld: 8510437 ACTIVE Petroleum aeanup Watch This Site Documents

TEAM TOYOTA 2800 WEST TENNESSEE STREET TALlAHASSEE, FL 32304 Facility Id: COM_70163 ACTIVE Other Cleanup Watch This Site Documents

KINGS STATION 2702 W TENNESSEE ST TALLAHASSEE, FL 32304 Facility Id: 8735846 ACTIVE Petroleum aeanup Watch This Site Documents

COLLEGE CORNER 2675 W TENNESSEE ST TALlAHASSEE, FL 32304 Facility Id: 8839696 ACTIVE Petroleum aeanup Watch This Site Documents

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Comment 3:

• Actual groundwater flow may be difficult to discern, but should be attempted.

EPA’s Response:

• The lithology at the Site is complicated by karstic geology and historic sinkholes. The EPA and City have made extensive efforts to understand the groundwater flow. Indirect methods such as using groundwater elevations are complicated by lithology punctuated by karst features and by aquifer units that are not horizontally connected across the Site. The most direct measure of groundwater flow was conducted during the ISCO injection test, where the downward gradient was orders of magnitude larger than the horizontal gradient. As a result, the EPA does not view the groundwater flow direction from elevation maps alone to be definitive. Because the deeper wells are screened in the Floridan aquifer, the EPA is comfortable that the wells are located downgradient of the shallower source area. At this time, the EPA does not see the need for additional study of the groundwater. Groundwater contamination has dropped more than 4 orders of magnitude at this Site since 2002 and does not pose an unacceptable risk. Groundwater contamination was successfully addressed by the removal action and the continuation of the removal action during park construction.

Comment 4:

• Geotechnical Concerns. The site has had a sinkhole form during the Boca Chuba pond (AOC2) construction, and engineering controls were instituted to maintain site integrity. The installation of a synthetic liner beneath the pond with compaction grouting was fairly well documented, whereas the installation of clay liners here, and above the Old City landfill (AOC1) were not well documented in the 2018 EPA documents referenced above. Liner leakage was believed to be a reason for elevated samples before the park opened.

EPA’s Response:

• The commenter can find the Removal Action Report for Area of Concern 1 in the Remedial AR. The Removal Action Report contains the documentation of the cleanup of the landfill and Cascades Creek. The landfill is capped with impermeable liners and the creek was excavated and lined with a concrete box culvert.

• The EPA would address catastrophic physical failure of any component of the removal action under EPA’s removal authority. This includes the formation of a sinkhole under either the landfill or under the Boca Chuba pond clay liner. The City, with State oversight, is responsible for maintaining the engineering controls of the removal action in perpetuity. The City’s compliance with post removal site controls is enforceable by EPA under an Administrative Order on Consent and the EPA’s authorities provided by CERCLA.

Comment 5:

• Based on the Remedial Investigation and Feasibility Study conducted by the City (COT), a resampling was affected in 2017 producing below detection s (BDL) in the target wells with exceedances. Only 2 BDL events were reported and I believe this is insufficient in view of well data presented in Table 1 indicating wells with a 2 event BDL returning to exceedance

detections. Due to the apparently complex hydrogeology, more sustained sampling is needed to account for apparent sample variation. Neither of these COT studies were available to citizens. This is especially true if the main source of contaminants are the contaminated soils where leachability (liner leakage as well) may account for sample variation.

EPA’s Response:

• Please see the response to comment 3 above.

• The City’s sampling results are included in the Administrative Record.

Comment 6:

• The Areas of Concern (AOC’s) are depicted in Figure 2 and agree with the SIS2004 study, except the AOC1/South Gadsden Corridor. Again soil borings, Section 6.8.1 in the SIS2004 study indicate areas that were not tested due to inaccessibility (i.e. CSX railroad easement, paved surfaces), or depth. Because we do not know the true extent of the City Landfill, and what relationship is has with the adjacent sites on South Monroe, additional wells should be installed on the property line with Buddy’s Marine to ascertain the extent of offsite contaminant contribution to this AOC. Furthermore, as far as this commenter is concerned, no borings were taken along the CSX right of way between South Gadsden St and Myers Park Drive to the east (and site of the City public water supply wells. The COT 2007 Removal Action reports supposedly documenting remediation of the Old City Landfill were not available to this commenter at this time, and were not in the Repository!

EPA’s Response:

• The Removal Action Reports for Areas of Concern 1, 2, and 3 are in the Remedial Administrative Record. Please see section 3.1 above for discussion about the availability of the Administrative Record.

• The State is addressing contamination at Buddy’s Marine under the State program.

• The State is responsible for the wells south of the Landfill. Based on sampling results from the removal, no additional action is necessary at the Landfill.

• Myers Park Drive is not part of this Site.

• The City, with State oversight, is responsible for maintaining the engineering controls at the Cascades Landfill in perpetuity. The City’s compliance with post removal site controls is enforceable by EPA under an Administrative Order on Consent and the EPA’s authorities provided by CERCLA.

Comment 7:

• Figure 4 depicts the location of the groundwater wells used in the COT 2007-2011, and 2012 to 2016, 2017, 2018 samples (Table 1). Exceedances of acenapthene (GCTL=530ppb) and benzene (GCTL=1ppb), the two major contaminants, are noted and explained. However, it is noted that the benzene may come from offsite sources (BTEX noted above), another reason to place wells at the south boundary of AOC1. The acenapthelene may be due solely to on-site leaching of

soils, and as such, a good indicator of the success of engineering controls enumerated in this Memorandum. It is noted that two wells probably penetrated the clay liner footprint of Boca Chuba pond and may have shown exceedances of these two contaminants as a result. This may also be a source for Benzene exceedances in MW 56. It is further noted in this section that the increases in contaminants in 2016 led to the continued resampling of the wells along S. Gadsden St corridor and that finally, MW 56 demonstrated 2 consecutive samples of below detection limits (BDL). However it should be noted that at least 2 wells in Table 1 showed BDL results for two sample events before returning to detectable/exceedance results. Therefore, the EPA reasoning that no further action is required because of 2 BDL sample events should be ignored until more samples, on a seasonally regular basis are collected and analyzed. That is to say, the sampling event timetable in Table 1 is somewhat erratic.

EPA’s Response:

• The groundwater at the Landfill (AOC 1) was successfully addressed under the removal action. The cleanup included excavation, capping of residual contamination and groundwater sampling at wells around the landfill. The City completed the groundwater cleanup under the landfill prior to the beginning of the RI/FS for groundwater.

• The reduction in groundwater contamination at the MGP is the result of large scale removal or capping of contaminated material. The trend of decreasing contamination in consideration with the attainment of health-based drinking water standards are the basis for EPA’s expectation that the groundwater will continue to remain below health-based cleanup levels in future.

• Please refer to comments 1, 2 and 3 for additional information.

Comment 8:

• It is stated that the CSM of the site is based on current AND FUTURE land use of the parcel (And presumably AOC1) be retained as RECREATIONAL. This is agreement with the Myers Park Neighborhood and the many users of the site.

EPA’s Response:

• Comment noted.

Comment 9:

• It is further stated “Because there were physical limitations to the extent of excavations along the CSX right of way and South Gadsden Street, impermeable clay or plastic liners were placed where residential contamination was left in place.”And, because it further states: “The increase in groundwater contamination … due to destruction of the (Boca Chuba) pond liner and/or the result of water infiltrating through residential subsurface contamination.” Copies of the Institutional controls(IC) for this area are reported to be at the Clerk’s Office, but I have not been able to visit the office as of this time. Can a copy be placed in the Public Library as Well?

EPA’s Response:

• Additional detail about the extent of excavations are available in the Removal Action Report.

• The Administrative Record contains the Restrictive Covenants, which are also available at: https://cvweb.clerk.leon.fl.us/public/clerk_services/official_records/download_document.asp?type=OR&book=4241&page=00082&subnet=&jwuser=

and at: https://cvweb.clerk.leon.fl.us/public/clerk_services/official_records/download_document.asp?type=OR&book=4241&page=00095&subnet=&jwuser=

Comment 10:

• It is also mentioned in the Fate and Transport section the a copy of the Institutional Controls are entered into the FDEP Institutional Controls Registry Database. Is this information on the FDEP website? If so, can you supply a contact to inform us how and when the audits are performed?

EPA’s Response:

• The FDEP is responsible for managing the Institutional Controls Registry. The City, with State oversight, is responsible for maintaining the engineering controls at the Cascades Landfill in perpetuity. The City’s compliance with post removal site controls is enforceable by EPA under an Administrative Order on Consent and the EPA’s authorities provided by CERCLA.

• FDEP’s Institutional Controls Registry (ICR) is described here: https://floridadep.gov/waste/waste/content/institutional-controls-registry

• The ICR Mapping tool is available at: http://ca.dep.state.fl.us/mapdirect/?focus=icr The following figure shows the output of the ICR mapping tool:

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Comment 11:

• Also, in your “For More information” section of the Proposed Fact Sheet, it does not mention the FDEP data base referenced in the Technical Memorandum. My current understanding is that at some point, the state paid the city for removal from the PRP action with a cash payment. Well, does this mean that both FDEP and City of Tallhassee documents will be supplied? If you could supply us with a chronological list of each, it would certainly help

EPA’s Response:

• The City and State entered into an agreement in April 2004. The EPA is not a party to that agreement.

• The commenter’s request for a copy of that agreement should be directed to the City and State.

• Administrative Orders on Consent for the EE/CA, Removal Action, and the RI/FS entered into by the EPA, State and/or City are included in the Administrative Record. Please see Section 2.2 of the ROD for the chronological history of EPA enforcement activities at the site.

Comment 12:

• Because we agree that the current land use of recreation is of benefit to the entire community, I/we DO NOT RECOMMEND that the site be subject to a NO FURTHER ACTION at this time. Simply because I feel we do not have all the pertinent facts(as partially enumerated above).

EPA’s Response:

• The scope of this Record of Decision is limited to groundwater, for which there are no known unacceptable Site risks. The City, with State oversight, is responsible for maintaining the engineering controls at the Site in perpetuity. The City’s compliance with post removal site controls is enforceable by EPA under an Administrative Order on Consent and the EPA’s authorities provided by CERCLA.

Comment 13:

• I am therefore requesting a delay of 60 days, until all the documents are placed in the Repository, for a determination of No Further Action. The fact that you stated over the phone that they would be supplied on a CDrom is cause for concern, because the Reference Section on the Library does not have a dedicated computer with the software necessary to quickly read the documents to be furnished(as far as my inquiry was concerned).

EPA’s Response:

• Pursuant to the commenter’s requests, two extensions of the public comment period occurred extending the comment period from August 27 to November 17, 2018. Please see the discussion in Section 3.1 above concerning the availability of the Administrative Record.

Comment 14:

• We need more data, especially along the entire 9acre tract of Myers Park, from South Gadsden Street to Myers Park Drive, where the Park offices and City of Tallahassee Public Water Supply wells are located. We would ask at this time the 9ac tract be similarly controlled (as the old Landfill site (AOC 1) via Deed Restriction for recreational Purposes only. Additional soil borings may clear up any uncertainty as to any contamination along the CSX right of way and adjacent city property. Groundwater contamination is likely to continue here, albeit sporadically.

EPA’s Response:

• The scope of EPA’s investigation is limited to releases associated with the Site. The extent of the Site was defined by the Removal and Remedial Investigations and does not include Myers Park.

• The commenter should direct the request to limit development of Myers Park to the City, who owns the property.

• Other contaminated sites mentioned by the commenter are addressed by the appropriate State cleanup programs. The State of Florida provides online tools to track and identify sites. The FDEP Contamination Locator Map is available at: http://prodenv.dep.state.fl.us/DepClnup/welcome.do. The output for the area around the Site is shown above.

• Another source of information about State programs is: http://geodata.dep.state.fl.us/

Email dated September 25, 2018, from Resident, representing self and Myers Park Neighborhood Association. Comment 15:

• As of Monday, September 24, the 2 CD-roms sent by EPA were located wedged in between two older binders for the site. On questioning the Reference Librarian, i learned that: 1) the Leon County Library does not have(nor will it) a computer capable of reading a CD-rom; and, 2) the CD-roms there could not be checked out. This is an unfortunate quandary, to say the least. For this reason, I ask that the following comment be added to the previous set of full comments based on the two works previously mentioned:

"As of 9/25/18, the official Repository for the Cascades Park Alternate Superfund Site is incomplete. The two CD-roms on the shelf are not able to be read and studied. This unfortunate circumstance leaves concerned residents with no up to-date knowledge of the true extent of contamination both at the site an offsite."

EPA’s Response:

• The EPA appreciates the commenter’s notification of issues viewing the Administrative Record. Please see the discussion in Section 3.1 above concerning the availability of the Administrative Record.

A-33

Appendix A. Public Comments

August 13, 2018 To: Mr.Eric Spalvins, US EPA,Region IV 61 Forsythe Street Atlanta, GA 30303-8960 Dear Mr. Spalvins: I am responding to the Environmental Protection Agency’s solicitation of citizen comments regarding the Cascades Park Alternate Superfund Site in Tallahassee, Florida. As a resident of the adjacent Myers Park Neighborhood, we are concerned with the safe use of public land in and adjacent to the site. I attended your Public Meeting on June 21, 2018 after receiving a notice in the mail the previous week. That was quick. I met you at that meeting and you presented data not previously known to the residents. This was a cause for concern, and was the fact that it was designated an Alternate Superfund Site. I am commenting partly because I think this project has evolved too quickly and that we do not have all the facts to make an informed decision. Let me explain in two sections. First, I will give a General overall concern for the site, based on my knowledge of the neighborhood and previous experience with the environmental history of the area. Second, I will base technical comments on the Florida Department of Environmental Site Investigation Section report, performed by Levine Fricke in 2004(SIS 2004) , as well as the EPA Technical Memorandum dated July 9,2018 and sent to me via email. The Proposed Plan Fact sheet will also be referenced as well. I must emphasize that I do not have all the facts, as referenced in these publications because the Public Repository at the Leon County Library has only the 1999-2003 Administrative Record of Decision and nothing else. I believe you stated over the phone that there are approximately 160 documents to be placed in the Public Archive. General Comments: My interest in Myers Park Historic area, geologically and environmentally, began in 2003 when I purchased my house here and became associated with the Myers Park Neighborhood Association(MPNA), to which I now belong and am a board member of. I also represent the association in the Council of Neighborhood Associations(CONA), active in various city issues which may influence our quality of life. We have had an active history of involvement with the Cascades site. As a resident and retired environmental scientist, my/our general concerns touch on the following:

1. The timing of the Alternate Superfund Proposed Action is rather fast considering the long period the site has undergone study, soil removal and site construction of the park. This is especially true with regards to citizen involvement and knowledge of the true environmental condition of the site. The site repository has not yet been stocked with all material required for informed decisions. The only document I found was the Original Administrative Record, 1999-2004. I believe you stated that this has now been amended, but have no concrete evidence of this.

2. The lack of area wide environmental data adjacent to the site and which may have an effect on at least, ground water flow at the the site. There are several environmental cleanup sites in the South Monroe corridor (Buddy’s Marine, Concord cleaners, Exxon/Sunoco gas station, etc) which have documented contamination (BTEX,’perc’ for example). You reference the BTEX coming from probably an offsite source, but do not sufficiently explain that reasoning. There are also adjacent City of Tallahassee potable water supply wells (CW01,CW03:with GAC filtration

systems ), as well as State office and Florida State University air conditioning supply wells. These wells have the potential to affect the groundwater flow beneath the site. I have not seen historic nor recent Potentiometric maps of the Upper Floridan Aquifer for this site. In view of the fact that there is probably perched water at the site(personal communication, Mr. George Wigand, LFR), mitigating groundwater contamination based on just 2 sample events may be premature. Actual groundwater flow may be difficult to discern, but should be attempted.

3. Geotechnical Concerns. The site has had a sinkhole form during the Boca Chuba pond (AOC2) construction, and engineering controls were instituted to maintain site integrity. The installation of a synthetic liner beneath the pond with compaction grouting was fairly well documented, whereas the installation of clay liners here, and above the Old City landfill (AOC1) were not well documented in the 2018 EPA documents referenced above. Liner leakage was believed to be a reason for elevated samples before the park opened.

Specific Comments: These comments are based primarily on the USEPA Technical Memorandum/No Further Action of July 09, 2018. SUMMARY. Based on the Remedial Investigation and Feasibility Study conducted by the City (COT), a resampling was affected in 2017 producing below detection s (BDL) in the target wells with exceedances. Only 2 BDL events were reported and I believe this is insufficient in view of well data presented in Table 1 indicating wells with a 2 event BDL returning to exceedance detections. Due to the apparently complex hydrogeology, more sustained sampling is needed to account for apparent sample variation. Neither of these COT studies were available to citizens. This is especially true if the main source of contaminants are the contaminated soils where leachability (liner leakage as well) may account for sample variation. SITE BACKGROUND. The Areas of Concern (AOC’s) are depicted in Figure 2 and agree with the SIS2004 study, except the AOC1/South Gadsden Corridor. Again soil borings, Section 6.8.1 in the SIS2004 study indicate areas that were not tested due to inaccessibility (i.e. CSX railroad easement, paved surfaces), or depth. Because we do not know the true extent of the City Landfill, and what relationship is has with the adjacent sites on South Monroe, additional wells should be installed on the property line with Buddy’s Marine to ascertain the extent of offsite contaminant contribution to this AOC. Furthermore, as far as this commenter is concerned, no borings were taken along the CSX right of way between South Gadsden St and Myers Park Drive to the east (and site of the City public water supply wells. The COT 2007 Removal Action reports supposedly documenting remediation of the Old City Landfill were not available to this commenter at this time, and were not in the Repository! GROUNDWATER INVESTIGATION. Figure 4 depicts the location of the groundwater wells used in the COT 2007-2011, and 2012 to 2016, 2017, 2018 samples (Table 1). Exceedances of acenapthene (GCTL=530ppb) and benzene (GCTL=1ppb), the two major contaminants, are noted and explained. However, it is noted that the benzene may come from offsite sources (BTEX noted above), another reason to place wells at the south boundary of AOC1. The acenapthelene may be due solely to on-site leaching of soils, and as such, a good indicator of the success of engineering controls enumerated in this Memorandum. It is noted that two wells probably

penetrated the clay liner footprint of Boca Chuba pond and may have shown exceedances of these two contaminants as a result. This may also be a source for Benzene exceedances in MW 56. It is further noted in this section that the increases in contaminants in 2016 led to the continued resampling of the wells along S. Gadsden St corridor and that finally, MW 56 demonstrated 2 consecutive samples of below detection limits (BDL). However it should be noted that at least 2 wells in Table 1 showed BDL results for two sample events before returning to detectable/exceedance results. Therefore, the EPA reasoning that no further action is required because of 2 BDL sample events should be ignored until more samples, on a seasonally regular basis are collected and analyzed. That is to say, the sampling event timetable in Table 1 is somewhat erratic. UPDATED CONCEPTUAL SITE MODEL(CSM) It is stated that the CSM of the site is based on current AND FUTURE land use of the parcel (And presumably AOC1) be retained as RECREATIONAL. This is agreement with the Myers Park Neighborhood and the many users of the site. It is further stated “Because there were physical limitations to the extent of excavations along the CSX right of way and South Gadsden Street, impermeable clay or plastic liners were placed where residential contamination was left in place.” And, because it further states: “The increase in groundwater contamination … due to destruction of the (Boca Chuba) pond liner and/or the result of water infiltrating through residential subsurface contamination.” Copies of the Institutional controls(IC) for this area are reported to be at the Clerk’s Office, but I have not been able to visit the office as of this time. Can a copy be placed in the Public Library as Well? It is also mentioned in the Fate and Transport section the a copy of the Institutional Controls are entered into the FDEP Institutional Controls Registry Database. Is this information on the FDEP website? If so, can you supply a contact to inform us how and when the audits are performed? Also, in your “For More information” section of the Proposed Fact Sheet, it does not mention the FDEP data base referenced in the Technical Memorandum. My current understanding is that at some point, the state paid the city for removal from the PRP action with a cash payment. Well, does this mean that both FDEP and City of Tallhassee documents will be supplied? If you could supply us with a chronological list of each, it would certainly help. CONCLUSION: Because we agree that the current land use of recreation is of benefit to the entire community, I/we DO NOT RECOMMEND that the site be subject to a NO FURTHER ACTION at this time. Simply because I feel we do not have all the pertinent facts(as partially enumerated above). I am therefore requesting a delay of 60 days, until all the documents are placed in the Repository, for a determination of No Further Action. The fact that you stated over the phone that they would be supplied on a CDrom is cause for concern, because the Reference Section on the Library does not have a dedicated computer with the software necessary to quickly read the documents to be furnished(as far as my inquiry was concerned). We need more data, especially along the entire 9acre tract of Myers Park, from South Gadsden Street to Myers Park Drive, where the Park offices and City of Tallahassee Public Water Supply wells are located. We would ask at this time the 9ac tract be similarly controlled (as the old Landfill site (AOC 1) via Deed Restriction for recreational Purposes only. Additional soil borings may clear up any uncertainty as to any contamination along the CSX right of way and adjacent city property. Groundwater contamination is likely to continue here, albeit sporadically.

From:To: Spalvins, ErikSubject: RE: Cascades Park Gasification Plant and Landfill Alternate Superfund site, public commentsDate: Tuesday, September 25, 2018 9:28:07 AMAttachments: image001.png

Good Morning, Eric:

I am writing as a result of our telephone conversation of 9/21/18 and my two visits to theLeon County Public Library("the Repository"). As of this writing, I have not head from theothers in the group.

As of Monday, September 24, the 2 CD-roms sent by EPA were located wedged inbetween two older binders for the site. On questioning the Reference Librarian, i learnedthat: 1) the Leon County Library does not have(nor will it) a computer capable of reading aCD-rom; and, 2) the CD-roms there could not be checked out. This is an unfortunatequandary, to say the least. For this reason, I ask that the following comment be added tothe previous set of full comments based on the two works previously mentioned:

"As of 9/25/18, the official Repository for the Cascades Park Alternate Superfund Site isincomplete. The two CD-roms on the shelf are not able to be read and studied. Thisunfortunate circumstance leaves concerned residents with no up to-date knowledge of thetrue extent of contamination both at the site an offsite."

Very Truly Yours,

, Tallahassee, Florida

On September 17, 2018 at 3:29 PM "Spalvins, Erik" <Spalvins.Erik@epa.gov> wrote:

Mr. ,

The EPA extended the public comment period to September 26th. The notice is copiedbelow. There are two copies of the Administrative Record in the Library in the secondfloor reference section. If you would like a copy, I can have one mailed to you.

Thanks

Erik

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Tallahassee DemocratAug. 31, 2018Miscellaneous Notices

The United States Environmental Protection Agency Announces an Extension ofthe Public Comment Period on a Proposed Plan and the Availability of theAdministrative Record for the Cascade Park Gasification Plant and Landfill Sitelocated in Tallahassee, Leon County, Florida. The United States EnvironmentalProtection Agency (EPA) has issued a Proposed Plan recommending no furtherremedial action for the Cascade Park Gasification and Landfill Superfund Site(the Site), located in Tallahassee, Leon County, Florida. EPA will extend thepublic comment period until September 26, 2018, to seek public input on theProposed Plan. The Proposed Plan presents a summary of groundwaterinvestigations, monitoring data and park construction information. Thesedocuments and other Site documents which provide support for the proposed nofurther remedial action remedy are available in the Administrative Record locatedin the Information Repository on the 2nd Floor Reference Section of LeRoyCollins Leon County Main Public Library, 200 West Park Avenue, Tallahassee,Florida, and at the EPA Region 4 Records Center located at 61 Forsyth Street,S.W., Atlanta, Georgia. During the comment period, the public is encouraged toreview and offer comments on all Site-related documents in the InformationRepository. If requested, EPA shall conduct a public meeting during the publiccomment period at or near the Site. EPA, in consultation with the FloridaDepartment of Environmental Protection, is proposing a No Further RemedialRecord of Decision because the cleanups conducted in 2006 and during theconstruction of Cascades Park from 2010 to 2014 have eliminated the existingand potential unacceptable risks to human health and the environment. TheProposed Plan is available online at: https://www.epa.gov/superfund/cascade-park-gasification-plant or at https://semspub.epa.gov/work/04/11094739.pdfWritten comments on the Proposed Plan should be postmarked/submitted no laterthan September 26, 2018, to Erik Spalvins, EPA Remedial Project Manager, US-EPA Region 4, Superfund Division, 61 Forsyth Street, SW, Atlanta, Georgia30303, or via email to Spalvins.Erik@epa.gov For further information, pleasecontact Ron Tolliver, EPA Community Involvement Coordinator at (404) 562-9591 or via email at Tolliver.Ronald@epa.gov PUBLICATION: 8/31/2018

From: Sent: Wednesday, August 15, 2018 6:02 PMTo: Spalvins, Erik <Spalvins.Erik@epa.gov>

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Subject: RE: Cascades Park Gasification Plant and Landfill Alternate Superfund site,public comments

We can wait. Internet up here in vermont mountain s is sporadic. Have a good week.

On August 15, 2018 at 5:25 PM "Spalvins, Erik"<Spalvins.Erik@epa.gov> wrote:

Apologies for getting the address wrong. I can resend this week or waituntil you return from vacation. Your choice.

Thanks

Erik

Erik SpalvinsRemedial Project ManagerSuperfund Division, U.S. Environmental Protection Agency, Region 461 Forsyth Street SW, Atlanta, Georgia 30303(404) 562-8938

From: Sent: Wednesday, August 15, 2018 8:49 AMTo: Spalvins, Erik <Spalvins.Erik@epa.gov>Subject: RE: Cascades Park Gasification Plant and Landfill AlternateSuperfund site, public comments

Hi Eric. The address is wrong,it is

Tallahassee,32301. I am out of town on vacation untillabor day. Regards

On August 13, 2018 at 3:16 PM "Spalvins, Erik"

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<Spalvins.Erik@epa.gov> wrote:

Thanks for the comments. I will be able to take a look at themlater this week. I’m sorry you did not receive the CD. Pleasetake a look at the address below and provide the correctaddress. I can get another copy to you this week.

Thanks

Erik

Erik SpalvinsRemedial Project ManagerSuperfund Division, U.S. Environmental Protection Agency, Region 461 Forsyth Street SW, Atlanta, Georgia 30303(404) 562-8938

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From: Sent: Monday, August 13, 2018 1:15 PMTo: Spalvins, Erik <Spalvins.Erik@epa.gov>Subject: Cascades Park Gasification Plant and LandfillAlternate Superfund site, public comments

Good afternoon Eric,

Please find attached a copy of my comments for theabove site, per the Proposed Plan Fact SheetInsructions. It is in a Word format. I have sent copies tothe board members available at Myers ParkNeighborhood Association, but not Woodlands Drivefriends.

As of this email, i have not recieved a CD rom on thesite publications. The Site Repository has fewdocuments, as I explained previously.

It has been a pleasure talking to you, and i hope we cancontinue the dialogue.

Regards,

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