Five-Year Review Report

Fifth Five-Year Review Report for

Alpha Chemical Corporation FLD041495441

Kathleen Polk County, Florida

September 2013

United States Environmental Protection Agency Region 4

Atlanta, Georgia

Approvedyby Date:

f/r//:t *^ Franklin E. Hill

Director, Superfund Division

Fifth Five-Year Review Report for

Alpha Chemical Corporation 4620 N. Galloway Rd.

Kathleen, Polk County, Florida

List of Acronyms 3

Executive Summary 5

Five-Year Review Summary Form 7

1.0 Introduction 9

2.0 Site Chronology 11

3.0 Background 12

3.1 PHYSICAL CHARACTERISTICS 12

3.2 LAND AND RESOURCE USE 15

3.3 HISTORY OF CONTAMINATION 15

3.4 INITIAL RESPONSE 16

3.5 BASIS FOR TAKING ACTION 17

4.0 Remedial Actions 18

4.1 REMEDY SELECTION 18

4.2 REMEDY IMPLEMENTATION 19

4.3 OPERATION AND MAINTENANCE 20

5.0 Progress Since the Last Five-Year Review 21

5.1 GROUND-WATER MONITORING 22

5.2 PRIVATE POTABLE WELL SAMPLING 23

5.3 PUBLIC DOCUMENT REPOSITORY 23

6.0 Five-Year Review Process 24

6.1 ADMINISTRATIVE COMPONENTS 24

6.2 CoMMLFNiTY I N V O L V E M E N T 24

6.3 DOCUMENT REVIEW 24

6.4 DATA REVIEW 30

6.5 SITE INSPECTION 32

6.6 INTERVIEWS 34

7.0 Technical Assessment 36

7.1 QUESTION A: Is THE REMEDY FLFNCTIONING AS INTENDED BY THE DECISION

DOCUMENTS? 36

7.2 QUESTION B: ARE THE EXPOSURE ASSUMPTIONS, TOXICITY DATA, CLEANUP LEVELS

AND REMEDIAL ACTION OBJECTIVES USED AT THE TIME OF REMEDY SELECTION

STILL VALID? 3 6

7.3 QUESTION C: HAS ANY OTHER INFORMATION COME TO LIGHT THAT COULD CALL INTO

QUESTION THE PROTECTIVENESS OF THE REMEDY? 38

7.4 TECHNICAL ASSESSMENT SUMMARY 38

8.0 Issues 39 1

9.0 Recommendations and Follow-up Actions 40

10.0 Protectiveness Statement 41

11.0 Next Review 42

Appendix A: List of Documents Reviewed A-1

Appendix B: Press Notice B-1

Appendix C: Interview Forms C-1

Appendix D: Site Inspection Checklist D-1

Appendix E: Photographs from Site Inspection E-1

Appendix F: Toxicity Value Evaluation F-1

Appendix G: Results of 2013 Ground-Water Monitoring Well Sampling G-1

Appendix H: Results of 2013 Potable Well Survey and Sampling H-1

Appendix I: Results of 2013 Soil Sampling I-l

Tables Table 1: Chronology of Site Events 11 Table 2: Summary of Remediation Goals for Ground Water and Surface Water 19 Table 3: Progress on Recommendations from the 2008 FYR 21 Table 4: ARAR Review for Ground-Water COCs 26 Table 5: Deed Documents from Polk County Public Records 27 Table 6: Institutional Control Summary Table 28 Table 7: January 2013 COC Concentrations in Ground Water 30 Table 8: Historical Maximum Detections of Surface Water COCs 31 Table 9: July 2013 Soil Sampling Results 32 Table F-1: Summary of Changes in Toxicity Values for the Alpha Chemical Corporation Superfund Site F-3

Figures Figure 1: Site Location Map 13 Figure 2: Detailed Site Map 14 Figure 3: Institutional Control Base Map 29 Figure 4: 2013 Soil Sampling Locations 32

List of Acronyms

AOC, LLC Alpha/Owens-Coming, LLC ARAR Applicable or Relevant and Appropriate Requirement ARC Alpha Resins Corporation CalEPA California Department of Enviromnental Protection CD Consent Decree CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations CIC Community Involvement Coordinator COC Contaminant of Concern CSF Cancer Slope Factor EA Endangennent Assessment EPA Enviromnental Protection Agency ESD Explanation of Significant Differences FAC Florida Administrative Code FDEP Florida Department of Enviromnental Protection (formerly FDER) FDER Florida Department of Environmental Regulation FDOH Florida Department of Health FYR Five-Year Review GCTL Ground-Water Cleanup Target Level HI Hazard Index IC Institutional Control IRIS Integrated Risk Infonnation System lUR Inhalation Unit Risk Factor MCL Maximum Contaminant Level Hg/L Micrograms per Liter mg/L Milligrams per Liter ND Not Determined NCP National Oil and Hazardous Substances Pollution Contingency Plan NPDWR National Primary Drinking Water Regulation NPL National Priorities List OEHHA Office of Environmental Health Hazard Assessment OSHA Occupational Safety and Health Administration OU Operable Unit O&M Operation and Maintenance PAH Polycyclic Aromatic Hydrocarbon PRP Potentially Responsible Party RAO Remedial Action Objective RCRA Resource Conservation and Recovery Act RfC Reference Concentration RfD Reference Dose RI Remedial Investigation Rl/FS Remedial Investigation/Feasibility Study RMCL Recommended Maximum Contaminant Level ROD Record of Decision RPM Remedial Project Manager RSL Regional Screening Level

SCTL Soil Clean-up Target Levels SDWA Safe Drinking Water Act SMCL Secondary Maximum Contaminant Level UU/UE Unlimited Use/Unrestricted Exposure VOC Volatile Organic Compound

Executive Summary

Introduction The Alpha Chemical Corporation Superfund Site (the Site) is located 3 miles north of Lakeland, Florida, in the town of Kathleen, Polk County. The Site covers approximately 30 acres and contains a resin manufacturing plant, parking areas, storage tanks, a rail spur and undeveloped land. In 1967, Alpha Resins Corporation (ARC), the potentially responsible party (PRP), started producing unsaturated polyester resin at the Site. Wastewater from resin manufacturing was discharged into two of four on-site surface impoundments irom 1967 until 1976. The two ponds receiving wastewater were unlined and permitted by the State to receive the wastewater. One of the ponds was later used to deposit solid waste and then covered with dirt and seeded. In the 1980s, the Florida Department of Environmental Protection (FDEP) and the U.S. Environmental Protection Agency confirmed that ethylbenzene and other volatile organic compounds (VOCs) contaminated ground water, soils and sediment in the area of the two former wastewater ponds and the wetlands. The EPA placed the Site on the National Priorities List (NPL) in 1983.

A Record of Decision (ROD) was issued in 1988 and ARC has been implementing and maintaining the remedy. In 1994, ARC transferred the site property to Alpha/Owens-Coming, LLC (now AOC, LLC). The AOC, LLC facility continues to manufacture unsaturated polyester resin for fiberglass manufacturers, principally for the boat and bathtub industries. The Site consists of one operable unit (OU), which addresses sitewide contamination. The remedy selected in the 1988 ROD included capping the former unlined pond area and long-term monitoring of surficial ground water and on-site surface water. Remedy construction was completed in 1990. The Interim Close Out Report for the Site was signed on September 21, 1989. An Amended Close Out Report followed in 1995, documenting the success of the remedy at achieving the standards described in the ROD. Together these two documents constituted the Final Close Out Report for the Site. The Site was deleted from the NPL on June 28, 1995. The property is in continued industrial use and is anticipated to remain in industrial use for the near future. The triggering action for this statutory Five-Year Review (FYR) is the date of signature for the previous FYR on September 9, 2008. In 2010, an Explanation of Significant Differences (ESD) placed Institutional Controls (ICs) on the Site.

Remedial Action Objectives The remedial action objectives (RAOs) were developed based on information presented in the 1988 ROD and the 2010 ESD. The following RAOs were developed:

• Reduce percolation of atmospheric precipitation into the unlined pond and reduce leachate production into the surficial aquifer fi-om the unlined pond and landfill to levels that meet maximum contaminant levels (MCLs).

• Prohibit use of the Site in a manner that would disturb the integrity of the final cover or the function of any monitoring system.

Technical Assessment The review of decision documents and applicable or relevant and appropriate requirements (ARARs), site inspection, and the results from sampling indicate that the remedy is fiinctioning as intended by the 1988 ROD and 2010 ESD.

The former unlined pond area was emptied, backfilled with clean soil, and capped. The cover is well maintained and the current use of the Site is consistent with the selected remedy and the original exposure assumptions. ICs are in place to prohibit use of the Site in a manner that would disturb the integrity of the final cover or the ftinction of any monitoring system. In addition, the Site is located within a Florida ground-water delineated area, which restricts well placement.

In January 2013, the PRP collected ground-water samples from downgradient monitoring wells. All concentrations were either below the laboratory detection limit or between the laboratory detection limit and the laboratory practical quantitation limit; the concentrations were all well below MCLs.

In late 2012 and early 2013, FDOH sampled 15 private potable wells within 1/4 mile of the Site. All VOC concentrations were below the laboratory detection limits except for one sample, which had a concentration of chloroform slightly above the detection limit but well below the MCL.

In July 2013, soil samples were taken fi-om below the liner of the capped pond. Contaminant concentrations in these samples were below the Soil Clean-up Target Levels (SCTLs) for leachability to ground water.

The exposure assumptions, cleanup levels and RAOs used at the time of remedy selection are still valid. No other information has come to liglit that could call into question the protectiveness of the remedy.

Conclusion The remedy at the Site is protective of human health and the environment because the remedy has achieved surface water and ground-water cleanup goals, the Site is secure, and institutional controls are in place to prohibit use of the Site in a manner that would disturb the integrity of the final cover.

Five-Year Review Summary Form

SITE IDENTIFICATION

Site Name:

EPA ID:

Region: 4

Alpha Chemical Corporation

FLD041495441

State: PL City/County: Kathleen/Polk County 1

NPL Status: Deleted

Multiple OUs? No

Has the site achieved construction completion?

Yes

Lead agency: Environmental Protection Agency If "Other Federal Agency" selected above, enter Agency name: Click here to enter text.

Author name: Amanda Goyne and Claire Marcussen (Reviewed by EPA)

Author affiliation: Skeo Solutions

Review period: 12/14/2012 - 09/05/2013

Date of site inspection: 01/17/2013

Type of review: Statutory

Review number: 5

Triggering action date: 09/09/2008

Due date (five years after triggering action date): 09/09/2013

Five-Year Review Summary Form (continued)

Issues/Recommendations

pU(s) without Issues/Recommendations Identified in the Five-Year Review:

0U1

Issuesand Recommendations Identified in the Five-Year Revlew:uJ;^t ^-:i-W--:;..aiS's> None 1

Operable Unit: 0U1

Protectiveness Statement

Protectiveness Determination: Protective

Addendum Due Date (if applicable): Click here to enter date.

Protectiveness Statement: The remedy at the Site is protective of human health and the environment because the remedy has achieved surface water and ground-water cleanup goals, the Site is secure, and insfitutional controls are in place to prohibit use of the Site in a manner that would disturb the integrity of the final cover.

Environmental Indicators

Current human exposures at the Site are under control. Contaminated ground-water migration is under control.

Are Necessary Institutional Controls in Place';

All n Some D None

Has EPA Designated the Site as Sitewide Ready for Anticipated Use?

Has the Site Been Put into Reuse?

^ Yes D No The Site is in continued industrial use.

Fifth Five-Year Review Report for

Alpha Chemical Corporatioe Superfund Site

1.0 Introduction

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

The United States Environmental Protection Agency prepares FYRs pursuant to the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Section 121 and the National Oil and Hazardous Substances Pollution Confingency Plan (NCP). CERCLA Secfion 121 states:

If the President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each 5 years after the initiation of such remedial action to assure that human health and the enviromnent are being protected by the remedial action being implemented. In addition, if upon such review it is the judgment of the President that action is appropriate at such site in accordance with secfion [104] or [106], the President shall take or require such action. The President shall report to the Congress a list of facilities for which such review is required, the results of all such reviews, and any actions taken as a result of such reviews.

The EPA interpreted this requirement fiirther in the NCP, 40 Code of Federal Regulations (CFR) Secfion 300.430(t)(4)(ii), which states:

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

Skeo Solutions, an EPA Region 4 contractor, conducted the FYR and prepared this report regarding the remedy implemented at the Alpha Chemical Corporation Site (the Site) in Kathleen, Polk County, Florida. The EPA's contractor conducted this FYR from December 2012 to September 2013. The EPA is the lead agency for developing and implemenfing the remedy for the potentially responsible party (PRP)-financed cleanup at the Site. The Florida Department of Environmental Protection (FDEP), as the support agency represenfing the State of Florida, has reviewed all supporting documentation and provided input to the EPA during the FYR process.

This is the fifth FYR for the Site. The triggering action for this statutory review is the previous FYR. The FYR is required if hazardous substances, pollutants or contaminants remain at the Site

above levels that allow for unlimited use and unrestricted exposure (UU/UE). The Site consists of one operable unit (OU).

2.0 Site Chronology

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

Table 1: Chronology of Site Events

.,:,.-Evenf ' ..}, v^-.qA.;:' -^^mi The EPA discovered the Site The EPA performed a site inspection The EPA proposed the Site for hsting on the National Priorities List (NPL) The EPA finalized the Site on the NPL The EPA performed a preliminary assessment Two Consent Decrees (CDs) were signed to codify agreements between the PRP, Alpha Resins Corporation (ARC) (now Alpha/Owens-Coming, LLC (AOC, LLC)), and the EPA. The EPA started the remedial investigation/feasibility study (RI/FS) The EPA completed the RI/FS and signed the Record of Decision (ROD) The PRP started remedial design The PRP completed remedial design The PRP started remedial action CD signed with requirements regarding sampling, operation and maintenance (O&M), reporting, cost reimbursement, completion of construction activities and institutional controls (ICs) Deed Notice filed as IC for site property The PRP completed remedial action and Interim Close-Out Report The EPA completed the first FYR and surface water monitoring was discontinued ARC transferred the Site property to AOC, LLC and established a

restrictive covenant as an IC The EPA finalized the Close-Out Report The EPA deleted the Site from the NPL The EPA completed the second FYR The EPA completed the third FYR and ground-water monitoring was discontinued O&M Plan was modified to reduce required frequency to monthly inspections of capped unlined pond The EPA completed the fourth FYR The EPA signed the Explanation of Significant Differences (ESD) O&M Plan was modified to reduce required frequency to quarterly inspections of capped unlined pond The PRP completed confirmatory soil sampling from below liner of capped pond

. : . _ • P a t e ^ i i f . - . :.:

3.0 Background

3.1 Physical Characteristics

The Site is located 3 miles north of Lakeland, Florida, in the town of Kathleen. Figure 1 shows the Site's surrounding vicinity. The Site is approximately 30 acres in size. The former Alpha Resins Corporation (ARC) facility has been subdivided into three tax parcels, which were transferred to Alpha/Owens-Coming, LLC (now AOC, LLC) in 1994. The largest parcel is 20.7 acres (Parcel 23-27-28-000000-022010); the other two parcels are 7.1 acres (Parcel 23-27-28-000000-021040) and 1.9 acres (Parcel 23-27-28-000000-022020). Several buildings cover more than 60,000 square feet of the Site, including an office building, the plant facility, garages, storage buildings and utility areas (Figure 2). All three parcels are within the Southwest Florida Water Management District. The Site is in a Florida ground-water delineated area, which restricts well placement (Figure 3).

During ARC's operational history, wastewater containing small amounts of volatile organic compounds (VOCs) was released to two unlined ponds. Pond 2/3 and Pond 4. Contamination was limited to on-site shallow ground water downgradient of the unlined ponds and soils of the unlined ponds. No significant ground-water plume was found during site investigations and ground-water contaminafion was limited to the shallow aquifer. The contaminants of concern (COCs) for this Site are listed in Table 7 of the 1988 Record of Decision (ROD) as xylene, styrene, ethylbenzene, benzoic acid and 1,2-dichloropropane.

The AOC, LLC facility is an active facility that principally manufactures fiberglass resins for the boat and bathtub industries. The Site lies on a ridge in the Hillsborough River drainage basin. Surface water from the Site drains into a swampy, low-lying wetland area at the property's southeastern comer. Water drains from the wetland in an east/northeast direction to a bay east of Galloway Road.

Hydrogeological investigations have identified two aquifer systems in the area, the shallow or surficial aquifer and the deep or Floridan Aquifer. In some places, the surficial aquifer may be divided into a shallow surficial aquifer and a deeper surficial aquifer by layers of clayey sand and sandy clay. These surficial aquifers appear to be interconnected in certain areas on the Site. Ground-water flow in the surficial aquifer is toward the south/southeast and is apparently limited to downgradient and lateral flow with only minor vertical percolation into the sediments below. In the Site area, the surficial aquifer is separated from the deep Floridan Aquifer by a layer of impermeable clay. A network of monitoring wells was installed in 1982 along the northern and southern edges of the wetland, which is located south of the plant and north of Kathleen Road. Other than the wefiands located south of the plant, the land on the Site has been developed or cleared and planted with grass.

Figure 1: Site Location Map

0 0.5 2 ••c==-••••Mnes 1

0 NORTH

Alpha Chemical Corporation Superfund Site Kathleen, Polk County, Florida

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

13

Figure 2: Detailed Site Map

0 Legend c:::l Streets .--Railroad

r:.J Site Boundary l J Pond

~ Wetland '\. Ground Water Flow e Wells

Pond 1- Pond 1 was installed In 1967 to hold noncontact (uncontaminated) cooling water. This pond still exists and serves the same purpose.

Ponds 2 and 3 (origrnally Pond 2/3)- Ponds 2 and 3 were ong1nally constructed as one pond (Pond 213) in 1967 to serve as a percolation pond for the water of reaction produced dunng the manufacture of the polyester res1n After the thermal ox1dtzer was installed 1n 1976. use of this pond was discontinued. and by 1977 the pond was dry. The pond was then divided into two ponds by a dam, With the east side becoming Pond 2 arid the west s1de becoming Pond 3 In 1977. the contents of Pond 2 were pumped to Pond 3 and the use of Pond 3 was d1sconbnued Porld 2 was then lined wtth concrete and used to stOl'eJevaporate caustic ftoor wash. It was determined dunng the remedial investigation that Pond 2 was not regulated under the Resource Conservation arid Recovery Act. A cap was constructed over both ponds in 1989 as part of the Superfund remedy.

Pond 4- Pond 4 was installed In 1972. The pond was designed to hold additional water of reaction from the plant and was used as a percolation pond unbl tnstallation of the thermal oxidizer 1n 1976, when use of this pond was discontinued. By 1977 the pond was dry, at which point 1t was used for one year as a landfill by the Alpha facility and its employees. At the end of this year, the landfill was covered with 2 feet of native soil and use of the landfill was discontinued.

Pond 2/3 and Pond 4 were the two state-permitted surface water Impoundments that led to contamination of the Alpha Chemical Site.

() NORTH

Alpha Chemical Corporation Superfund Site Kathleen , Polk County, Florida

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

14

3.2 Land and Resource Use

Prior to the plant's construcfion in 1967, the Site and the surrounding area were either undeveloped or used for agricultural purposes. No previous industrial practices are known to have taken place at the Site. Since 1967, the plant has produced unsaturated polyester resins for manufacturers that produce fiberglass boats, shower stalls, and other construction and recreation-related products. In 1994, ARC transferred the Site property to AOC, LLC. The AOC, LLC facility manufactures unsaturated polyester resin for fiberglass manufacturers, principally for the boat and bathtub industries. No changes to the current industrial land use are anticipated at this time. Approximately 650 people live within 1/2 mile of the Site. Over time, residential land use has increased in the area surrounding the Site and this pattern is expected to continue in the fiature.

There are two aquifers at the Site: the surficial aquifer and the deeper, Floridan Aquifer. Ground water in the Floridan Aquifer serves as the area's main drinking water supply. Both private ground-water wells and municipal lines are used to supply drinking water to businesses and residences downgradient of ground-water flow at the Site. Private ground-water wells supply drinking water on North Galloway Road, Old Kathleen Road, Galloway Lane, Falling Leaf Lane, Mt Tabor Road, Coogle Road, Daisy Lane and Strickland Road. Municipal water lines supply drinking water to residences on Daisy Lane and Sleepy Hollow Lane.

The capped former unlined pond area is a grassy graded area marked by warning signs; it is located south of the plant near the rail spur (Figure 2). The surrounding land uses are primarily residential to the west, north and east of the Site, with a mix of residenfial and commercial areas to the south. The town of Kathleen covers about 3 square miles and, according to the 2010 Census, has a population of 6,332. The Census Bureau estimated that as of July 1, 2011, the City of Lakeland has more than 98,000 residents.

3.3 History of Contamination

In 1967, ARC began to manufacture unsaturated polyester resins on the Site. During production a waste stream was generated, known as "water of reaction." This wastewater was composed mainly of water, but also contained small amounts of VOCs. Two ponds were constructed to contain the plant's wastewater; Pond 1 was built to hold the non-contact (uncontaminated) cooling water and continues to be used to contain the plant's cooling water. Another pond built in 1967 was eventually divided to create Ponds 2 and 3, but began as a single unlined percolation pond (Pond 2/3) that was used for evaporation of the plant's water of reaction. Pond 2/3 was 110 feet by 90 feet in size and approximately 4 feet deep. In 1972, another unlined percolafion pond was installed (Pond 4) to hold additional water of reacfion from the plant; Pond 4 was approximately 100 feet by 200 feet and 4 feet deep.

From 1967 until 1976, the plant's wastewater was discharged into these two unlined ponds (Pond 2/3 and Pond 4). In 1976, a thermal oxidizer was installed to treat the water of reaction. Since 1976, all of the plant's water of reaction has been incinerated rather than disposed of in the percolation ponds. This was done in part to reduce the odor

15

associated with the wastewater. By 1977, the two percolation ponds were dry. In 1977, Pond 4 was used for one year as a landfill by the facility and its employees. According to the 1988 ROD, ARC (now AOC, LLC) stated that the following items are indicafive of the types of materials placed in the pond: boxes, pallets, old resin drums, fires, empty bags, grass cuttings, old furniture and shrubbery. The resin drums placed in the pond were either empty or contained discarded resins. The 1988 ROD stated that the resins in these drums are most likely solid because the solidification reaction occurs quickly regardless of whether the appropriate catalyst is added. In addition to the above items, 80,000 pounds of non usable solid phthalic acid was placed in one comer of the Pond 4 landfill. At the end of 1977, two feet of native soil was used to cover the Pond 4 landfill and its use was discontinued.

The 1988 ROD documented that additional remedial acfion at the Pond 4 landfill was not necessary. In 1977, Pond 2/3 was divided with a dam; the east side became Pond 2 and the west side became Pond 3. The contents of Pond 2 were pumped into Pond 3 and use of Pond 3 was discontinued. Pond 2 was then lined with concrete and used to store/evaporate caustic floor wash. It was determined during the 1985 remedial investigation (RI) that Pond 2 was not regulated under the Resource Conservation and Recovery Act (RCRA). Ponds 2/3 and 4 were the two state-permitted surface water impoundments that resulted in contamination at the Site. Additional detail about the ponds, including their history of usage and remediation, is available in Figure 2.

In 1982, ARC (now AOC, LLC) applied to the Florida Department of Environmental Regulation (FDER) to line Pond 3 with concrete so that it could be used to store/evaporate caustic floor wash. As part of the permit application process, FDER required monitoring wells to be installed and ground-water samples to be collected. On-site ground-water contamination was detected during this sampling. The Site was proposed for listing on the National Priorities List (NPL) on December 30, 1982, and was listed on the NPL on September 8, 1983. Between 1982 and 1984, ground-water monitoring allowed FDER and the EPA to identify Pond 3 as a source of on-site ground-water contamination. The contamination from the unlined pond area resulted in detections of ethylbenzene, xylene, naphthalene and benzene in on-site ground water. The 1985 RI identified soil contamination in the area near the previously used unlined ponds. Contaminants identified in soil and ground water were the same VOCs found in the plant's wastewater; ethylbenzene was the most prevalent contaminant. The RI found that the contamination was confined to the surficial aquifer and remained within the boundaries of the property.

3.4 Initial Response

There were no interim or removal actions at the Site prior to implementafion of the remedy selected in the 1988 ROD. Two Consent Decrees (CDs) were signed in March 1985 to codify agreements between the PRP, ARC (now AOC, LLC), and the EPA. One CD dealt with the payment of penalties associated with violation of the permitted ground-water standards. The second CD required ARC (now AOC, LLC) to perform the RI,

16

endangerment assessment (EA), and, if necessary, feasibility study to carry out the remedial action.

3.5 Basis for Taking Action

The placement of wastewater in the Site's unlined percolafion ponds caused the contamination of both soil and ground-water resources. Ethylbenzene was identified as the most prevalent contaminant at the Site, both in terms of concentrations and the number of samples in which it was detected. In addition to ethylbenzene, xylene and styrene also exceeded drinking water standards. Other organic priority pollutants included phthalates, halogenated and non-halogenated VOCs, phenols, and polycyclic aromafic hydrocarbons (PAHs). Contamination was identified in the soils of the closed landfill and the unlined percolafion pond (Pond 3). Contaminafion was also identified in the on-site surficial aquifer and the EPA concluded that the potential existed for off-site migration of contaminants, although the plume was not clearly defined.

In 1986, an EA was carried out in accordance with the EPA's Superfiind Health Assessment Manual. The EA found that the most probable pathway for human exposure was via contaminated ground water from the surficial aquifer. The pathway of greatest concern for human exposure was ingestion of this contaminated surficial ground water, although the primary drinking water source in the area is the Floridan Aquifer. The EA concluded that the plume was not large, off-site exposure was expected to be minimal, exposure assumptions were highly conservative, and there was no expected increase in risk over background as a result of Site contamination.

17

4.0 Remedial Actions

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

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

4.1 Remedy Selection

The EPA signed the ROD on May 18, 1988. It addressed contamination in surficial ground water and soils in the unlined ponds. The remedy selected in the 1988 ROD was designed to achieve the following Remedial Action Objective (RAO):

• Reduce percolation of atmospheric precipitation into the unlined pond and reduce leachate producfion into the surficial aquifer from the unlined pond and landfill to levels that meet maximum contaminant levels (MCLs) in the surficial ground water.

The remedy components included in the 1988 ROD were:

• Placement of a low-penneability cap over the unlined pond area. • Long-tenn monitoring of the surficial aquifer and the on-site surface water.

Although institufional controls (ICs) were placed on the property deed in July 1989 as a requirement of the CD between the EPA and ARC, ICs were not included in the remedy selected in the 1988 ROD. Thus, the Explanation of Significant Differences (ESD) signed by the EPA on September 28, 2010, added the following RAO to the selected remedy:

• Prohibit use of the Site in a manner that would disturb the integrity of the final cover or the fijnction of any monitoring system.

Table 2 summarizes the remediation goals for shallow ground water and surface water as presented in the 1988 ROD.

18

Table 2: Summary of Remediation Goals for Ground Water and Surface Water

COC .(pi-:

Ethylbenzene

Styrene

Xylene

1,2-Dichloropropane

Benzoic acid

Grirfuind Water"

0.680

0.140

0.440

0,006

NA

. : . . • : • • > .

•^ '̂iSurface Water" "•:̂

1.4

0.9

6.0

1.4

23

a. Recommended maximum contaminant levels (RMCLs) as listed in Table 7 of the 1988 ROD.

b. Ambient Water Quality Criteria for the Protection of Fresh Water Life as listed in Table 7 of the 1988 ROD.

NA = RMCL criteria not available in 1988 ROD.

4.2 Remedy Implementation

The PRP started the remedial design on November 30, 1988, and completed it on January 6, 1989. The PRP started the remedial action on March 15, 1989, which included two components: 1) Construction of a cap over the unlined pond area (Pond 3), and 2) Long-term monitoring of surface water and ground water.

Prior to cap installation, the PRP pumped water from the unlined pond area, removed vegetation and backfilled the pond area with clean clay soil. The PRP installed a synthetic low-permeability liner over the compacted fill material and placed layers of drainage material, filter fabric and topsoil over the synthetic liner. The PRP then installed drainage swales around the cap; these swales led to two drainage ditches on the south side of the pond that channel runoff from the capped area into the wetland south of the fonner pond. The final step included placing seed and sod on the capped surface to prevent erosion. The EPA signed the Interim Close-Out Report for the Site on September 21, 1990. An Amended Close-Out Report followed in 1995 documenfing the success of the remedy at achieving the RMCLs for the COCs described in the ROD. Together these two documents constitute the Final Close-Out Report for the Site.

The remedial design contained an outline for the quarterly surface water and ground-water sampling, which began immediately after the capping acfion was complete. The PRP installed eight surficial aquifer wells and one deep Floridan Aquifer well downgradient of the unlined pond area and monitored the wells to assess ground-water quality. The PRP identified the culvert leading to the wefiand and the wetland itself as the two areas that would be sampled to monitor surface water quality. The PRP conducted surface water monitoring to evaluate whether concentrations of the five COCs met surface water ARARs. The ROD presented values for the EPA's Ambient Water Quality Criteria for Protection of Fresh Water Life for each COC. The 1994 FYR found that maximum in-stream COC concentrations in surface water at the Site were significantly

19

below both the RMCLs and the Ambient Water Quality Criteria for Protection of Fresh Water Life. After 1994, surface water monitoring was discontinued. Because all ground-water results had been below cleanup levels for the five years preceding the 2003 FYR, ground-water monitoring was discontinued after the 2003 FYR. Therefore, no ground water or surface water samples were analyzed for the 2008 FYR. The PRP sampled three monitoring wells in January 2013 to provide data in support of the current FYR.

On May 17, 1989, the PRP signed a CD with the EPA. This CD contained requirements regarding sampling, operation and maintenance (O&M), reporting, cost reimbursement, completion of construction activities, and ICs. In July 1989, to comply with the IC requirements of the CD, ARC (now AOC, LLC) attached a Deed Notice to the Site property that contained use restrictions due to the presence of hazardous substances. The use restrictions prohibit any actions that would damage the integrity of the cover or monitoring system. In 1994, ARC transferred the Site property to AOC, LLC and recorded a Special Warranty Deed that established a covenant that runs with the land, prohibits any activities that would disturb the remedy, grants the EPA access to the Site, and promises to infonn any fiiture Site tenants or Site owners about the CD and their obligation to uphold its terms. The results of the surface and ground-water monitoring and the implementation of ICs for the Site supported the Amended Close-Out Report for the Site, which was signed on March 28, 1995.

4.3 Operation and Maintenance (0«&M)

O&M activities were detailed in the July 1989 O&M Plan and in the revised Project Operations Plan, which was finalized on August 22, 1989. O&M acfivities include routine inspections of the monitoring wells and the cap. The Site remedy was declared operational and fiinctional in October 1989. AOC, LLC is responsible for designing, conducting and fianding O&M activities. The ROD stated that O&M costs for the enfire 30-year maintenance and monitoring period for ground water would total $186,207 in 1988 dollars. The monitoring period for ground water ended after 13 years rather than 30 years, resulting in lower-than-anticipated O&M costs.

Currently, the only O&M costs at the Site are for the time spent by AOC, LLC staff conducting and documenting the ongoing cap inspections. The 1989 O&M Plan required inspections every two weeks to ensure the cap's integrity and drainage construction, and to check for evidence of erosion. In December 2007, following the site inspecfion for the 2008 FYR, the Remedial Project Manager (RPM) revised the O&M Plan to require monthly rather than biweekly inspections of the capped area. A January 24, 2013 revision of the O&M Plan fiirther reduced inspecfion frequency, requiring quarterly inspecfions of the capped area. Checklists submitted to the EPA describe the condifion of the cap and actions taken to address any problems; the checklists indicate that the cap is performing as designed. Semi-annual reports on the inspection results are submitted to both FDEP and the EPA. Annual O&M costs for the past five years have not been tracked because the acfivities have only included inspections and reporting by facility personnel.

20

5,0 Progress Since the Last Five-Year Review

The protectiveness statements from the 2008 FYR for the Site stated the following:

"The remedy at the Site is protective of human health and the environment and exposure pathways that could result in unacceptable risks are under control. Ground-water monitoring at the Site is complete because sampling results from the J 0 years prior to the 2003 FYR indicated that contaminant concentrations were consistently below the cleanup levels established in the ROD. Based on the site inspection, access controls are well maintained and public access to the Site is restricted. The Site is in industrial reuse and the Site's owner intends for this use to continue in the long term. Clean fill was placed over the contaminated soils and the cover has been maintained. Institutional controls have been implemented to ensure the long-term protectiveness of the soil remedy. "

The 2008 FYR included three issues and recommendations. Table 3 below summarizes each recommendation and its current status.

Table 3: Progress on Recommendations from the 2008 FYR

Section

5.1

f # Recommendation ; ̂

To suppoil protectiveness detenninations and demonstrate that the cap remains eftective, ground -water monitoring data should be collected from limited monitoring wells at least once every five years prior to each subsequent FYR.

Party Riesponsible*

AOC, LLC

MilcfsWne

09/01/2013

Action Taken a n d t f „ ••,\'*'sr;-

In January 2013, the PRP collected ground-water samples from downgradient monitoring wells AC-102,AC-106and AC-107. These wells were sampled because they contained contaminants during the June 1987 sampling event. Samples were analyzed for ethylbenzene, styrene and .Kylene and were all well below MCLs.

Date oifii4ction

01/04/2013

Sectibn;:;;

5.2

5.3

Recommendation

EPA should consult with the Florida Department of Health (FDOH) to determine whether or not private wells should be sampled.

EPA should ensure that copies of recent Site documents are provided to the Lakeland Public Library.

Party Responsible

EPA, FDOH

EPA

Milestone Date

09/30/2009

09/30/2009

Action Taken and Outcome

FDOH sampled one private well in December 2012 and 14 private wells in February 2013. All concentrations were below the laboratory detection limits for VOCs e.xcept for one sample, which had a chloroform concentration slightly above the detection limit but well below MCL.

On November 8, 2010, the EPA mailed electronic copies of the ESD Administrative Record and the Deletion Docket to the Lakeland Public Library.

: ' ^ ^ • ' • • ' '

Dafetof Action:

02/2013

11/08/2010

5.1 Ground-Water Monitoring

In January 2013, the PRP collected ground-water samples from downgradient monitoring wells AC-102, AC-106 and AC-107. These wells were sampled because they are located downgradient of the cap and they contained contaminants during the June 1987 sampling event; the other six monitoring wells did not contain detectable contaminant concentrafions during the June 1987 sampling. January 2013 samples from these three wells were analyzed for ethylbenzene, styrene and xylene. The other two COCs were not included in the analysis because 1,2-dichloropropane was not detected in any of the initial sampling and benzoic acid does not have an MCL. Further, the endangerment assessment indicated that the highest detected concentration of benzoic acid in ground water was 17,000 ng/L; this value is three fimes lower than EPA's May 2013 residential tap water Regional Screening Level (RSL) of 58,000 |ag/L. Ethylbenzene, styrene and xylene were either below the laboratory detection limit (

5.2 Private Potable Well Sampling

The FDEP consulted with the FDOH and determined that private potable wells in the Site's vicinity should be sampled to help evaluate whether the Site is suitable for UU/UE. The FDOH standard procedures for conducfing a potable well survey are to locate and sample up to 10 wells within 1/4 mile of a site. The Polk County Health Department idenfifled 15 wells within 1/4 mile of the Site. One well was sampled in December 2012 and 14 wells were sampled in February 2013. All samples were analyzed for VOCs using EPA method 524.2. All concentrations were below the laboratory detection limits for VOCs except for one sample, which had a concentration slightly above the detection limit for chloroform in well AA08549. The chloroform concentration of 0.2 |ag/L in this well is significanfiy below the MCL of 80 |ig/L. See Appendix H for a map of well locafions and sample results.

5.3 Public Document Repository

On January 16, 2013, Skeo Solufions staff visited the Lakeland Public Library, the designated repository for the Site's documents, to verify that information about the Site was publicly available. A hard copy of the 2008 FYR was available at the library as well as electronic media dated September 2008 containing deletion documents and previous FYRs. Other documents available included a hard copy of the 1998 FYR, the NPL Deletion Docket composed of seven volumes dated May 23, 1996, and the NPL Administrafive Record microfilm index dated May 24, 1995.

23

6.0 Five-Year Review Process

6.1 Administrative Components

EPA Region 4 initiated the FYR in December 2012 and scheduled its completion for August 2013. EPA RPM Deb Cox led the EPA site review team, which also included EPA Community Involvement Coordinator (CIC) L'Tonya Spencer and contractor support provided to the EPA by Skeo Solutions. In December 2012, the EPA held a scoping call with the review team to discuss the Site and items of interest as they related to the protectiveness of the remedy. The review schedule established consisted of the following activities:

Community notification Document review Data collecfion and review Site inspection Local interviews FYR report development and review

6.2 Community Involvement

On January 11, 2013, a public nofice was published in the legal classified secfion of Lakeland's The Ledger newspaper, announcing the FYR for the Alpha Chemical Site, providing Ms. Cox's contact information, and inviting the community's questions, comments and concerns. No comments were received from any parties. A copy of the notice is provided in Appendix B. Notification of the PRPs was carried out in the form of a telephone call between Ms. Cox and Ms. Sprigg (Environmental, Health & Safety Coordinator for AOC, LLC), advising Ms. Sprigg of the date of the site inspection and the commencement of FYR activifies.

6.3 Document Review

This FYR included a review of relevant Site-related documents, including the ROD, remedial action reports and recent monitoring data. Appendix A provides a complete list of the documents reviewed.

ARARs Review

CERCLA Section 121(d)(1) requires that Superfund remedial actions attain "a degree of cleanup of hazardous substances, pollutants, and contaminants released into the environment and of control of fiirther release at a minimum which assures protection of human health and the environment." The remedial acfion must achieve a level of cleanup that at least attains those requirements that are legally applicable or relevant and appropriate.

24

• Applicable requirements are those cleanup standards, standards of control and other substantive requirements, criteria or limitafions promulgated under federal environmental or state environmental or facility siting laws that specifically address a hazardous substance, remedial action, location or other circumstance found at a CERCLA site.

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

• To-Be-Considered criteria are non-promulgated advisories and guidance that are not legally binding, but should be considered in determining the necessary remedial action. For example, To-Be-Considered criteria may be particularly usefial in determining health-based levels where no ARARs exist or in developing the appropriate method for conducting a remedial action.

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

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

Location-specific ARARs are restrictions on hazardous substances or the conduct of the response activities solely based on their location in a special geographic area. Examples include restricfions on acfivifies in wetlands, sensitive habitats and historic places.

Remedial actions are required to comply with the chemical-specific ARARs identified in the ROD. In performing the FYR for compliance with ARARs, only those ARARs that address the protectiveness of the remedy are reviewed.

Ground-Water ARARs

The 1988 ROD established chemical-specific ARARs for four COCs in ground water, based on recommended federal drinking water MCLs (RMCLs) (40 CFR 141-143). This review confirmed that the MCLs for ethylbenzene, styrene, xylene and 1,2-dichloropropane have changed since the selection of the remedy. Changes are presented in more detail in Table 4. Current ARARs are based on current federal MCLs (40 CFR 141-143). Standards for ethylbenzene and xylene have become less stringent, while

25

standards for styrene and 1,2-dichloropropane have become more stringent since the signing of the ROD in 1988. It should be noted that EPA Region 4 no longer considers the xylene promulgated MCL of 10,000 |ag/L health protective based no more current noncancer toxicity values. Based on the current toxicity assessment and standard drinking water exposure assumptions, EPA Region 4 recommends a concentration of 3,500 |ig/L as a health protective remedial level for total xylenes in ground water. Although the Region 4 recommended value of 3,500 |ig/L is more stringent than the current federal MCL, the remedy remains protective because the ground-water data are well below this more stringent value. An MCL has not been established for benzoic acid. However, the historical maximum benzoic acid detection in ground water of 17,000 |ag/L is well below EPA's May 2013 residential tap water RSL of 58,000 î g/L; addifional discussion on the health risks associated with benzoic acid is presented in Section 7.2 of this FYR.

Table 4: ARAR Review for Ground-Water COCs

COC"

Ethylbenzene

Styrene

Xylene

1,2-Dichloropropane

Benzoic acid

1988 ROD ARARs (mg/L)"

0.680

0.140

0.440

0.006

NR

Current Federal ARARs (nig/L)^

0.700

0.100

10"

0.005

NR

AR.\RsChange

Less stringent

More stringent

Less stringent

More stringent

No change

Notes: a. COCs from 1988 ROD b. Federal Register, 1985, "Proposal Rulemaking for National Primary Drinking Water

Regulation" as cited in Table 7 of the 1988 ROD c. Federal primary MCLs are available at

http://water,epa,t;ov/drink,'conlaininants/index,clm (last accessed 11/28/2012) d. EPA Region 4 does not consider the MCL for xylene protective and has developed a

health protective level of 3,500 |.ig/L (3.5 mg/L) for assessing protectiveness. NR = None reported (i.e., none of the federal standards contained ARARs for the contaminant); however, EPA has established a Regional Screening Level for tap water of 58 mg/L that is protective for unrestricted use of ground water.

Surface Water ARARs

The 1988 ROD required surface water monitoring, but surface water monitoring was discontinued after the 1994 FYR due to multiple years of monitoring data that did not exceed federal standards. Current federal Ambient Water Quality Criteria have not been established for the protecfion of aquatic life for the Site COCs. However, since the 2008 FYR a surface water cleanup target level of 9 mg/L for benzoic acid was established under FAC 62-77 and finalized April 17, 2005. The predicted maximum concentration in surface water of 0.02 mg/L as presented in Table 7 of the 1988 ROD is well below the surface water cleanup target level.

26

http://water,epa,t;ov/drink,'conlaininants/index,clm

Soil ARARs

Because a cap was selected for the former percolation pond remedy rather than soil removal, the ROD did not present ARARs or cleanup levels for soil contamination. Therefore, a review of the protectiveness of ARARs for the remediation of soil contamination is not required as part of this FYR.

Institutional Controls Review

Contractor staff conducted online research of Polk County public records and found the deed infonnation pertaining to the Site listed in Table 5.

Table 5: Deed Documents from Polk County Public Records

Datefen •

1946

November 29, 1978

April 17, 1984 June 30, 1989

October 3, 1994

July 19,2004

*• ' t Type ofsM: Docunieiiit

Deed

Warranty Deed

Warranty Deed Notice

Special Warranty Deed

Notice

Description ...'.,'•

Trustees of the Internal Improvement Fund of the State of Florida sell a parcel (later described as Tract 11 of the AOC, LLC property) to the Guilfords. The Robinsons sell a parcel (later described as Tract III of the AOC, LLC property) to the Alpha Chemical Corporation. Alpha Chemical Corporation transfers three tracts of land to ARC. This Notice identifies the CD between the EPA and ARC. This document contains use restrictions due to the presence of hazardous substances and prohibits any actions that would damage the integrity of the cover or monitoring system. ARC transfers the property to Alpha/Owens-Coming, LLC. This deed references the CD, establishes a covenant to run with the land guaranteeing the EPA access to the Site, prohibits disturbing the remedy, and promises to inform any fiiture owners or tenants about the terms of the CD and their responsibility to uphold its terms. Alpha/Owens-Coming, LLC becomes AOC, LLC.

Book#

791

1845

2231

2755

3445

5856

i Page #'. s - : ' . •• ;•:•'

394

1682

559

2020

1659

62

Table 6 lists the ICs associated with areas of interest at the Site. Figure 3 shows the ICs that apply to land use at the Site and the Florida ground-water delineated area within which the Site is located. The Florida ground-water delineated area designation restricts well installations.

Table 6: Institutional Control (IC) Summary Table

(Parcels 23-27-28-000000-022

Medium

- . • - j i . : . . , • . , - • .

Ground Water

Soil

ICs Needed?

• H " .

No

Yes

ICs Called for in the Decision

Documents?

No

Yes

1, Florida's ground-water delineation infonnation

• Areas of Interest ••./rV- . .̂ -̂f-V-ft- •••• > • -31C),;; 23-27-28-000000-021040; and 23-27-28-000000-022020)

'-\ ' ; Impacted

Parcel(s)

23-27-28-000000-022010 23-27-28-000000-022020, 23-27-28-000000-021040 and surrounding parcels (see Figure 3)

23-27-28-000000-022010, 23-27-28-000000-022020, 23-27-28-000000-021040

is available online a

O b j e c t i i ^ ^

No IC is necessary because the remedy has achieved ground-water cleanup goals

Prohibit use of the Site in a manner that would dismrb the integrity of the final cover or the fiinction of any monitoring system

Instrument 6; in Place

. ^D."j'

The Site lies within a Florida ground-water delineated area, which restricts well placement.'

Notice and Special

Warranty Deed

: hllp:;7www.dep.stale,ll.us'waler.'iifoun

.•,.^r." ' "

.n>;'-''^"-Notes ' /

• . • " • ' ; / ' • ; ,

Both private ground-water wells and municipal lines are used to supply drinking water to businesses and residences downgradient of ground-water flow at the Site.

1989 Notice contains use restrictions and prohibits any actions that would damage the integrity of the cover or monitonng system.

1994 Special Warranty Deed guarantees the EPA access to the Site, prohibits disturbing the remedy, and requires owners to inform any future owners or tenants about the terms of the CD and their responsibility to uphold its terms.

July 2013 Soil Sampling below the cap documents contaminant concentrations below MCLs.

i watcr/delincalu.hlni.

28

http://www.dep.stale,ll.us'waler.'iifoun

Figure 3: Institutional Control Base Map

0 1000 ••c::=•••• Feet 250 500 ··-·······--Site

Legend

c::::l Streets -++++- Railroad

0 Parcel Boundaries '\. Ground Water Flow

c::J Parcels with Land Use Institutional Controls J Ground Water Delineated Area for Benzene

0 Pond

~ NORTH

Alpha Chemical Corporation Superfund Site Kathleen, Polk County, Florida

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

29

6.4 Data Review

Ground-Water Monitoring

In January 2013, the PRP collected ground-'water samples from downgradient monitoring wells AC-102, AC-106 and AC-107. These wells were sampled because they contained contaminants during the June 1987 sampling event; the other six monitoring wells did not contain detectable contaminant concentrations during the June 1987 sampling. January 2013 samples from these three wells were analyzed for ethylbenzene, stjTcne and xylene. The other two COCs were not included in the analysis because 1,2-dichloropropane was not detected in any of the initial sampling and benzoic acid does not have a MCL. In the absence of a MCL for benzoic acid, however, the historical maximum detection in ground water of 17,000 )ag/L is well below EPA's May 2013 residential tap water RSL of 58,000 |Jg/L; additional discussion on the health risks associated with benzoic acid is presented in Section 7.2 of this FYR. All concentrations of ethylbenzene, styrene and xylene from the January 2013 samples were either below the laboratory detection limit (

sample, which had an estimated concentration slightly above the method detection limit for chloroform in well AA08549. The chloroform concentration of 0.2 |ag/L in this well is significantly below the MCL of 80 |ag/L and was flagged by the laboratory with an "I," which indicates that the concentration is an estimated concentration because it was reported between the laboratory method detection limit and the practical quantitation limit. This indicates that the concentration is between the lowest achievable level under ideal laboratory conditions and the lowest achievable level under practical and routine laboratory conditions. See Appendix H for a map of well locations and sample results.

Surface Water

No surface water samples were collected during this review period because long-term monitoring of the surface water was completed in 1993. During 1987, 1989, 1990 and 1993, surface water samples were collected from the swamp and culvert and analyzed for ethylbenzene, styrene and xylene. COC concentrations were below the detection limits in all surface water samples. To ensure that the historical data are also below the current criteria, the maximum concentrations of COCs detected in surface water from 1984 to 1993 were compared to the lowest of the most current state and federal promulgated standards or recommended water quality criteria. According to the 1989 O&M Plan, only three of the five COCs required monitoring in surface water, including styrene, xylene and ethylbenzene. Therefore, for 1,2-dichloropropane and benzoic acid, the maximum predicted concentrations in surface water as listed in the 1988 ROD were used for comparison purposes. As shown in Table 8, the historical maximum concentrations remain well below the current surface water promulgated standards.

Table 8: Historical Maximum Detections of Surface Water COCs

- i c o c ' ' •"""'" • . . I t^^^ . . : : - . :

Ethylbenzene Styrene Xylene

1,2-Dichloropropane

Benzoic acid

Maximum Detection'(ing/L)

Figure 4: 2013 Soil Sampling Locations

1111111111111111111111 11 I 111 11111111 111 1111 11111 11111 11 11

A

B

M MR

Superfund Site Capped Area

------- - -- - -------------·- ·---"' 110FT

t ., ..

Table 9: July 2013 Soil Sampling Results

1 2-Dicbloropropane Etbylbenzene Styrene Sample SCTL Leachabillty 111&1'kEJ•

0.03 0.6 3.6

A-4R 0.0026U 0.0030U 0.0026U

B-4R 0.0024U 0.0027U 0.0024U

Trip Blank 0.50U 0.50U 0.50U

Notes:

Xylene

0.2

0.0054U

0.0049U

0.50U

a= Florida Chapter 62-777 Soil Clean-up Target Levels for leachability to ground-water U = Compound not detected at detection limit

6.5 Site Inspection

A site inspection was conducted on January 17, 2013. The purpose of the site inspection was to observe site conditions and interview, where appropriate, PRPs, state government

32

personnel, and other people associated with the Site. Parties in attendance at the site inspection included: Bill Denman (former EPA RPM for the Site), Deb Cox (current EPA RPM for the Site), L'Tonya Spencer (EPA CIC), Walsta Jean-Baptiste (FDEP), Catherine Sprigg (Environmental, Health & Safety Coordinator, AOC, LLC), Johnny Zimmerman-Ward (Skeo Solufions) and Claire Marcussen (Skeo Solutions). For a full list of site inspection activities, see the Site Inspection Checklist in Appendix D. For photographs of the Site, see Appendix E.

Ms. Sprigg met the site inspection participants at the AOC, LLC facility's main office. The site inspection began with a meeting inside the main office, which was also attended by Martin McLeod (AOC, LLC), Frank Sizemore (AOC, LLC) and Michael Diehl (AOC, LLC). The meeting began with a discussion of the Site background and activities since the previous FYR, including a summary of the most recent ground-water data. Mr. Denman discussed the EPA's interest in confirming whether or not the Site meets UU/UE status which would permit discontinuing future FYRs at the Site; Ms. Baptiste (FDEP) concurred. The EPA and FDEP discussed with AOC, LLC that the FYR process could be discontinued if data were available to demonstrate that residual contamination has achieved levels to support UU/UE. Ms. Sprigg indicated that the on-site ground-water data support UU/UE and proposed conducting additional soil sampling if historical information is not sufficient to support UU/UE.

Ms. Sprigg led a tour of the Site including Pond 1, which is used for noncontact cooling water, and a series of former percolation ponds (Pond 2, Pond 3 and Pond 4) located immediately west of Pond 1. All three former ponds are now covered by a thick carpet of grass, which is routinely mowed and maintained.

Site inspection participants toured the rnonitoring wells, including those located south of the pond area and south of the wetlands. All of the monitoring wells were secured with locks and in good condition. The Pond 3 cap was in good condition with no signs of erosion. However, Ms. Sprigg pointed out a small sinkhole that had opened up on the northern edge of Pond 4 and had been repaired. The fences appeared to be well maintained and no breaches were observed. The drainage ditches between the ponds appeared clear and the drainage pipe features discharging to the wetland area to the south appeared well maintained. The pond covers and the condition of the wells, fences and drainage features were being inspected on a monthly basis, and semi-annual reports summarizing these inspections have been submitted to the EPA and FDEP in February and August each year.

At the conclusion of the site inspecfion, the participants met at the AOC, LLC main office for ftirther discussions. Recommendations included reducing the O&M monthly monitoring of Site condifions to quarterly monitoring. In addition, Mr. Denman stated that, once it has been demonstrated that the Site meets UU/UE, all monitoring wells will need to be properly abandoned. Further, Ms. Baptiste indicated that FDEP has asked FDOH to sample a subset of off-Site private potable wells before March 2013 to help demonstrate that the ground water meets UU/UE (see Sections 5.2 and 6.4 of this FYR for sample results).

33

6.6 Interviews

The FYR process included interviews with parties affected by the Site, including the curtent landowners and regulatory agencies involved in Site acfivities or aware of the Site. The purpose was to document the perceived status of the Site and any perceived problems or successes with the remedy. Most of the interviews took place during the site inspection on January 17, 2013. One resident interview was conducted over the phone on January 22, 2013. The interviews are summarized below. Appendix C provides the complete interviews.

Resident 1: Resident 1 has lived in Lakeland since 1985 and is aware of the enviroru-nental issues at the Site and that AOC, LLC has taken care of it. He expressed concerns about the safety practices of the crew working on the remediation project, particularly after an incident involving a freight train backing into a trailer. The resident believes that there is a correlation between the Site and the well water supply, which dried up during the 2002-2004 period. He suggested the EPA tighten up on Occupational Safety and Health Administration (OSHA) standards for remediation construction zones.

Resident 2: Resident 2 is aware of the environmental issues at the Site. Resident 2 noted that occasionally he can smell the plant. He expressed concern about effects on the local community, particularly public health. Resident 2 has cancer and lost his wife to cancer. In addition, he noted that the trains' noise is disruptive. Though a municipal water line is available, he uses a deep well on his property "for everything." Though Resident 2 is aware of the environmental issues, he stated that neighbors are not kept informed of Site activities. He suggested information should be shared with neighboring residents through the mail.

Resident 3: Resident 3 is not aware of the environmental issues or cleanup activifies at the Site. He expressed preference for receiving informafion and updates by mail. Resident 3 currently uses a private well rather than the municipal water supply.

Resident 4: Resident 4 is not aware of the environmental issues or cleanup acfivities at the Site. He expressed preference for receiving information and updates by mail. Resident 4 currenfiy uses the municipal water supply.

Resident 5: Resident 5 is aware of the environmental issues and activities associated with the Site. Resident 5 expressed concern about the cleanup because the contaminafion was covered up rather than removed. He had difficulty installing a ground-water well in the past because of restrictions in place, and currenfiy uses a relafive's well because of the cost of connecfing to city water lines. Resident 5 noted that butterflies and birds have returned since air filtration began. He would like to receive updates and information through mail or email.

Catherine Sprigg: Catherine Sprigg is the Environmental, Health & Safety Coordinator

34

for AOC, LLC. She stated that remedial actions have been effective, and ground-water monitoring shows no COCs. Ms. Sprigg stated that the contamination is contained and there are no off-site impacts. Attendees at a recent community meeting inquired about the zone of delineation around the Site. Ms. Sprigg noted that subsequent research indicated this delineation was for benzene, which is not one of the Site's COCs, and that this information was shared with meeting attendees. She expressed that AOC, LLC would like to reduce monitoring requirements, frequency of inspections and ICs. She stated that AOC, LLC will continue working with the EPA to end the requirement for FYRs.

Walsta Jean-Baptiste: Walsta Jean-Baptiste (FDEP) is content with the remediation activities and AOC, LLC's role in the process. She noted that data from ground-water monitoring wells indicate that the remedy is protecfive. She is comfortable with the ICs because AOC, LLC implements them consistently. Though she is not aware of any complaints directly related to remedial activities, she mentioned a resident concerned about the zone of delineafion. She stated that FDEP has not conducted any Site communications activities in the past five years. Currently AOC, LLC submits semi-annual reports summarizing their monthly Site inspections to the EPA and FDEP in February and August each year. She stated that AOC, LLC has proposed a sampling plan that will possibly eliminate the need for tuture FYRs.

Martin McLeod: Martin McLeod is an O&M contractor for AOC, LLC. Overall, Mr. McLeod is content with remediation activities and the results from monitoring data. He stated that O&M responsibilities include Site inspections, lawn cover care, and cleaning the draining area. The only change Mr. McLeod noted is the switch from biweekly to iTionthly inspections. Though Mr. McLeod stated the O&M costs are relatively low, he suggested reduced monitoring from monthly to quarterly.

35

7.0 Technical Assessment

7.1 Question A: Is the remedy functioning as intended by the decision documents?

The review of decision documents and ARARs, site inspection, and the results from sampling indicate that the remedy is functioning as intended by the 1988 ROD and 2010 ESD. The fonner unlined pond area was emptied, backfilled with clean soil, and covered. The cover is well maintained and the current use of the Site is consistent with the selected remedy and the original exposure assumptions. ICs are in place to prohibit use of the Site in a manner that would disturb the integrity of the final cover or the funcfion of any monitoring system. In addition, the Site is located within a Florida ground-water delineated area, which restricts well placement.

In January 2013, the PRP collected ground water samples from downgradient monitoring wells AC-102, AC-106 and AC-107. All concentrations from the January 2013 samples were either below the laboratory detection limit (

|ag/L is no longer considered health protective. Based on the current toxicity assessment and standard drinking water exposure assumptions, EPA Region 4 recommends a concentration of 3,500 |ng/L as a health protective remedial level for total xylenes in ground water. Although the Region 4 recommended value of 3,500 )ag/L is more stringent than the current federal MCL, the remedy remains protective because the ground-water data are well below this more stringent value. In addition, in the absence of an MCL for benzoic acid, EPA established a tap water Regional Screening Level in May of 2013 for benzoic acid of 58,000 |ig/L; the highest historic detection was 17,000 |ig/L is well below the RSL which supports that benzoic acid does not pose health concerns in ground water assuming the ground water were used for potable purposes.

It should be noted that as of June 2003, pursuant to Florida Stafiate 376.30701, FDEP promulgated a 10'̂ cumulafive risk management level for carcinogenic chemicals and a cumulative noncancer hazard index (HI) of 1.0. These risk management levels were subsequenfiy incorporated in 2005 into FDEP's contaminated sites rule, Chapter 62-780, with default SCTLs, ground-water cleanup target levels (GCTLs) and surface water cleanup target levels as criteria specified in Chapter 62-777. Although the FDEP identifies the Florida Secondary MCL standards (SMCLs) as enforceable values and the SMCL is the GCTL for two of the COCs at this site, ethylbenzene (0.03 mg/L) and xylene (0.02 mg/L), these values are not health-based. Therefore, the EPA considers the SMCLs to be non-enforceable under Superfrind. FDEP has acknowledged this interpretation with the understanding that these criteria may still be enforced under state law. The implementafion of FDEP's Chapter 62-780 does not impact the cleanup goals, since the GCTLs for all COCs, with the excepfion of the SMCLs for ethylbenzene and xylene, are equivalent to the federal MCLs. As noted, the SMCLs are not health-based; therefore, the current cleanup goals for ground water remain valid.

During 1987, 1989, 1990 and 1993, surface water samples were collected from the swamp and culvert. COC concentrations were below the detection limits in all surface water samples. As a result, surface water monitoring was discontinued. Long-term monitoring at the Site was completed ahead of schedule.

Toxicity factors for some of the COCs have changed since the EA was conducted in 1986. A summary of the toxicity factors available from the EPA in 1986 compared with current toxicity values is presented in Appendix F. Based on an evaluation of the changes in the toxicity values, the cleanup levels remain valid; the infonnation to support this conclusion is presented in Appendix F.

FDEP consulted with FDOH to sample private wells near the Site; in late 2012 and early 2013, 15 wells were sampled within 1/4 mile of the Site. All VOC concentrations were below the laboratory detection limits except for one sample, which had a concentration of chloroform slighfiy above the detection limit but significantly below the MCL.

Since the Site is outdoors with no buildings, a vapor intrusion assessment has not been performed.

37

7.3 Question C: Has any other information come to light that could call into question the protectiveness of the remedy?

No other information has come to light that could call into question the protectiveness of the remedy.

7.4 Technical Assessment Summary

The review of decision documents and ARARs, site inspection, and the results from sampling indicate that the remedy is funcfioning as intended by the 1988 ROD and 2010 ESD.

The fonner unlined pond area was emptied, backfilled with clean soil, and capped. The cover is well maintained and the current use of the Site is consistent with the selected remedy and the original exposure assumptions. ICs are in place to prohibit use of the Site in a manner that would disturb the integrity of the final cover or the fiincfion of any monitoring system. In addition, the Site is located within a Florida ground-water delineated area, which restricts well placement.

In January 2013, the PRP collected ground-water samples from downgradient monitoring wells. All concentrafions were either below the laboratory detection limit or between the laboratory detection limit and the laboratory practical quantitation limit; the concentrations were all well below MCLs.

In late 2012 and early 2013, FDOH sampled 15 private potable wells within 1/4 mile of the Site. All VOC concentrations were below the laboratory detection limits except for one sample, which had a concentration of chloroform slightly above the detection limit but well below the MCL.

In July 2013, soil samples were taken from below the liner of the capped pond. Contaminant concentrafions in these samples were below the SCTLs for leachability to ground water.

The exposure assumptions, cleanup levels and RAOs used at the time of remedy selection are still valid. No other information has come to light that could call into question the protectiveness of the remedy.

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8.0 Issues

In the course of this FYR, the EPA did not identify any issues that currently prevent the remedy at the Site from being protective, nor did the EPA identify any issues that may do so in the future.

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9.0 Recommendations and Follow-up Actions

Because the EPA did not identify any issues at the Site, no recommendafions or follow-up actions are required under CERCLA.

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10.0 Protectiveness Statement

The remedy at the Site is protective of human health and the environment because the remedy has achieved surface water and ground-water cleanup goals, the Site is secure, and institutional controls are in place to prohibit use of the Site in a manner that would disturb the integrity of the final cover.

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11.0 Next Review

The next FYR will be due within five years of the signature/approval date of this FYR.

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Appendix A: List of Documents Reviewed

Atlanta Enviromnental Management Inc. Operations and Maintenance Plan for Capping of Unlined Pond. Revised August 21,1989.

Bogatin Law Firm. Special Warranty Deed. Book 3445 and Page 1659 of the Polk County Public Records. September 30, 1994.

Declaration for the Record of Decision for the Alpha Resins Corp. Site, Lakeland, Florida. Prepared by EPA Region 4. May 18, 1988.

EPA Record of Decision: Alpha Chemical Corp. EPA/ROD/R04-88/033. Prepared by EPA Region 4 on May 18, 1988.

EPA Consent Decree between Alpha Resins Corporation and EPA. Prepared by EPA Region 4. May 17, 1989.

EPA Superfund Third Five-Year Review Report: Alpha Chemical Corporation Superfund Site, ICathleen, Florida. Prepared by EPA. May 2003.

EPA Superfund Fourth Five-Year Review Report: Alpha Chemical Corporation Superfijnd Site, Kathleen, Florida. Prepared by E'' Inc. September 2008.

EPA Revisions to O&M Plan. Prepared by Bill Denman, EPA Region 4. December 21, 2007.

EPA Explanation of Significant Differences for the Alpha Chemcial Corporation Superfund Site. Prepared by EPA Region 4. September 28, 2010.

Focused Feasibility Study Report for Alpha Resins Corporation, Lakeland, Florida. Prepared by Camp Dresser & McKee, Inc. for the Florida Department of Environmental Regulation. January 6, 1988.

Law Offices of Holland and Knight. Deed Notice. Book 2755 and Page 2020 of the Polk County Public Records. July 12, 1989.

Monthly Inspection Logs from September 2008 through February 2009 for Alpha Chemical Corp. Prepared by AOC Resins for EPA Region 4. February 23, 2009.

Monthly Inspection Logs from March 2009 through August 2009 for Alpha Chemical Corp. Prepared by AOC Resins for EPA Region 4. August 26, 2009.

Monthly Inspection Logs from September 2009 through February 2010 for Alpha Chemical Corp. Prepared by AOC Resins for EPA Region 4. February 25, 2010.

Monthly Inspection Logs from March 2010 through August 2010 for Alpha Chemical Corp. Prepared by AOC Resins for EPA Region 4. August 24, 2010.

A-1

Monthly Inspection Logs from September 2010 through February 2011 for Alpha Chemical Corp. Prepared by AOC Resins for EPA Region 4. February 23, 2011.

Monthly Inspecfion Logs from March 2011 through August 2011 for Alpha Chemical Corp. Prepared by AOC Resins for EPA Region 4. August 24, 2011.

Monthly Inspection Logs from September 2011 through February 2012 for Alpha Chemical Corp. Prepared by AOC Resins for EPA Region 4. February 22, 2012.

Monthly Inspecfion Logs from March 2012 through August 2012 for Alpha Chemical Corp. Prepared by AOC Resins for EPA Region 4. August 23, 2012.

Polk County Property Appraiser accessed from website http:/'\vww.polkpa.org/CamaDisplay.aspx. Accessed December 10, 2012.

Potable Well Survey Results for Polk County Health Department. Prepared by Florida Department of Health. January 4, 2013.

Potable Well Survey Results for Polk County Health Department. Prepared by Florida Department of Health. February 22, 2013.

Potable Well Survey Results for Polk County Health Department. Prepared by Florida Department of Health. February 24, 2013.

Remedial Investigation Report. Prepared by Stottler, Stagg & Associates for the Florida Department of Environmental Regulation. August 29, 1986.

Revised 2007 Operafions and Maintenance Plan for Capping of Unlined Pond. Prepared by EPA Region 4. January 24, 2013.

State of Florida. State of Florida Drinking Water Standards, Monitoring and Reporting (Chapter 62-550). January 7, 2005.

State of Florida. Groundwater and Surface Water Cleanup Target Levels Comparison (Chapter 62-777). April 17, 2005.

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http://polkpa.org/CamaDisplay.aspx

Appendix B: Press Notice

U. S. Environmental Protection Agency^ Re^on4

Announces a Five-Year Review for ttie Alpha Chemical Corporation

S»e Kathleen, Poik County, Rorida

The U.S. Environmental Protection Agen-cy (EPA) is conducting a Five-Year He-view of the remedy for soil, ground water, and surface water contamination associ-ated with the Alpha Chemical Corporation site (the Site) In Kathleen. Poilc County. Floilda. The Site, which covers 32 acres. lies three miles north of the town of Lake-land at 4620 N. Galloway Road. The pur-pose of the Five-Year Review is to ensure that ttie selected cleanup actions continue to protect human health and the envlron-mera.

Since 1967, the Alpha Resins Corporation (ARC) has produced unsaturated polyes-ter rasJn at the Site. Between 1967 and 1976. ARC discharged wastewater into two unlined ponds on site. Solid waste was later deposited In one of the ponds, which was covered and reseeded. Volatile organic compounds (VOCs) were de-tected in the surfidai ground water, and the Site was rinallzed on EPA's National PrioritieB List (NPL) in 1981. The remedy selected in the 1988 Record of Decision included a low-pemneabHity cap to reduce percolation of atmospheric precipitation in the unlined ponds, vertical migration of water through remaining pond sediments, and leachate production in the surficial ground water. The remedy also included a long-temi grourxj-water and surface water monitoring program. ARC complated cor>-stoiction of the 20-foot thick clay cap for the unlined ponds in late 1989 and moni-tored the ground water until 1994. Ground-water and surface water monitor-ing confirmed that the contaminants had decreased to protective levels and that the remedy was effective, in 1995, EPA de-leted the Site from the NPL

The National Contingency Plan requires that remedial actions which result in any hazardous substances, pollutants, or con-taminants remaining at the Site atx>ve le-vels that allow for unluntted use and unre-stricted exposure be reviewed every five years to ensure protectlcHi of human health and the environment. Five-Year Reviews conducted for the Alpha Chemi-cal Corporation site in 1994. 1998, 2003. and 2008 detennined that the remedy re-mained protective of human health and the environment arxj continued to meet

state and federal standards. The fifth Rve-Year Review for this site is scheduled to be completed by August 2013.

EPA invites community partidpatJon in the Five-Year Review process.

The EPA is conducting a Five-Year Re-view to evaluate the effectiveness of the rernedy and ensure that the remedy re-mains protective of human health and the environment As part of the Rve-Year Re-view process, EPA will be available to an-swer any questions about the Site. Com-munity members who have questions about the Site, the Rve-Year Review process, or wtio would like to partidpate in a community interview, are asked to con-tact the Remedial Project Manager, Deb-orah Cox at the foltowing address:

U.S. EPA, Region 4 61 Forsyth St. (11* Floor) Atlanta. GA 30303-8936 Phone: 800-435-9234

Cox.DeborahOepe.gov

EPA plans to complete tfie Five-Year Re-view process in about nine months: com-ments are welcome during this time. More information ai)out ttie Site may t>e found at the Lakeland Public Library at 100 Lake Morton Dr. Lakeland, FL 33801 or online at: http-y/cfpub.epa.gov/supercpad/cur5ites/c$ itinfo.dm?id=0400623

L80191-11; 2013

http://Cox.DeborahOepe.gov

Appendix C: Interview Forms

Alpha Chemical Corporation Superfund Site Five-Year Review Interview Form Site Name: Alpha Chemical Corporation EPA ID No.: FLD041495441 Interviewer Name: Johnny Zimmerman- Affiliation: Skeo Solutions

Ward Subject Name: Resident 1 Affiliation: Nearby Resident Time: 4:15 p.m. Date: 1/22/2013 Interview Location: Phone

Interview Format (circle one): In Person Phone Mail Other:

Interview Category: Residents

1. Are you aware of the environmental issues at the Site and what cleanup activities have occurred?

Some of them, I've lived at that address since 1985. Aware of problems. They have taken care of it.

2. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as appropriate)?

Not good. I'm not aware of what the safety practices are on Site, but I am aware of some of the accidents that have happened. There was one incident not too long ago where a train backing into the facility hit a trailer. 1 don't know if there was a spill, but my job is a safety job, that seems like a lax safety situation, possibly an oversight and could be other oversights we're not aware of What other things may be happening that are not safe?

3. What effect has this Site had on the surrounding community, if any?

I think property values in area have gone down, not sure if it's Site-related.

4. Have there been any problems with unusual or unexpected activities at the Site, such as emergency response, vandalism or trespassing?

No, there have been incidences with fire department, spills and stuff like that. Don't know of any recent incident other than freight train running into trailer.

5. Has the EPA kept involved parties and surrounding neighbors informed of activities at the Site? How can the EPA best provide Site-related information in the future?

Yes and no. I received a letter six months ago for a town meeting about something going on there. I was unable to go. Letters are fine to let us know what's going on at Site.

C-1

Do you own a private well in addition to accessing city/municipal water supplies? If so, for what purpose(s) is your private well used?

On city water, only one on that street on city water (besides the church). I believe that in -2002-2004, my well went dry and I was pumping sand. I called out Swittmud, who contacted State and the State made the City of Lakeland give me water. Others have followed suit. There was a direct correlation to the well going dry and Alpha Chemical; found part of my property (soil and ground water) and other property nearby contaminated.

Do you have any comments, suggestions or recommendations regarding any aspects of the project?

Tighten up on the safety. I know the EPA is not OSHA, but they work closely with them. Get OSHA involved and try to make them toe the line and follow the policy to the letter.

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Alpha Chemical Corporation Superfund Five-Year Review Interview Form Site Site Name: Alpha Chemical Corporation EPA ID No.: FLD041495441 Interviewer Name: Deb Cox Affiliation: EPA Subject Name: Resident 2 Affiliation: Nearby Resident Time: 11:00 a.m. Date: 1/17/2013 Interview Location: Residence

Interview Format (circle one): In Person Phone Mail Other:

Interview Category: Residents

1. Are you aware of the environmental issues at the Site and what cleanup activities have occurred?

Yes

2. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as appropriate)?

About the same, I can still smell the plant; sometimes not.

3. What effect has this Site had on the surrounding community, if any?

Quite a bit; some folks have cancer in the area, including me and my wife (deceased). The railroad is aggravating as it comes three to four times a week and honks their horn to be let in. Should be able to schedule their arrival and not make so much noise.

4. Have there been any problems with unusual or unexpected activities at the Site, such as emergency response, vandalism or trespassing?

No, they control the place pretty well.

5. Has the EPA kept involved parties and surrounding neighbors informed of activities at the Site? How can the EPA best provide Site-related information in th