Five-Year Review Report

Second Five-Year Review Report for

Helena Chemical Company (Tampa Plant) EPA ID FLD053502696

Tampa Hillsborough County, Florida

May 2011

Prepared By: E2 Inc.

921 Second Street SE Charlottesville, Virginia

22902

Prepared For: United States Environmental Protection Agency

Region 4 Atlanta, Georgia

Date:

shIll ~I

11111111111111111111111111111111111111111111111111 10801697

Second Five-Year Review Report for

Helena Chemical Company (Tampa Plant) 2405 North 71 st Street

Tampa Hillsborough County, Florida

List of Acronyms ........................................................................................................................... 3

Executive Summary ...................................................................................................................... 4

Five-Year Review Summary Form ............................................................................................. 7

1.0 Introduction............................................................................................................................. 9

2.0 Site Chronology ..................................................................................................................... 10

3.0 Background ........................................................................................................................... 11

3.1 PHYSICAL CHARACTERISTICS ........................................................................................ 11 3.2 LAND AND RESOURCE USE ............................................................................................ 15 3.3 HISTORY OF CONTAMINATION ....................................................................................... 15 3.4 INITIAL RESPONSE ......................................................................................................... 17 3.5 BASIS FOR TAKING ACTION ........................................................................................... 17

4.0 Remedial Actions .................................................................................................................. 18

4.1 REMEDY SELECTION ...................................................................................................... 18 4.2 REMEDY IMPLEMENTATION ........................................................................................... 20 4.3 OPERATION AND MAINTENANCE (O&M) ....................................................................... 26

5.0 Progress Since the Last Five-Year Review ......................................................................... 27

5.1 GROUND WATER REMEDY DISCUSSIONS ....................................................................... 28 5.2 XYLENE SOURCE AREA DISCUSSIONS ............................................................................ 29 5.3 INSTITUTIONAL CONTROLS EVALUATION ...................................................................... 29

6.0 Five-Year Review Process .................................................................................................... 31

6.1 ADMINISTRATIVE COMPONENTS .................................................................................... 31 6.2 COMMUNITY INVOLVEMENT .......................................................................................... 31 6.3 DOCUl\tIENT REVIEW ...................................................................................................... 31 6.4 DATA REVIEW ............................................................................................................... 33 6.5 SITE INSPECTION ............................................................................................................ 39 6.6 INTERViEWS ................................................................................................................... 43

7.0 Technical Assessment ........................................................................................................... 45

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

DOCUMENTS? ............................................................................................................... 45 7.2 QUESTION B: ARE THE EXPOSURE ASSUMPTIONS, TOXICITY DATA, CLEANUP LEVELS AND

REMEDIAL ACTION OBJECTIVES (RAOs) USED AT THE TIME OF REMEDY SELECTION

STILL VALID? ............................................................................................................... 46

I I 7.3 QUESTION C: HAS ANY OTHER fNFORMATION COME TO LIGHT THAT COULD CALL fNTO

QUESTION THE PROTECTIVENESS OF THE REMEDY? ...................................................... 46 7.4 TECHNICAL ASSESSMENT SUMMAR'{ ............................................................................. 46I

8.0 Issues .............................................................................................................................. 48

I 9.0 Recommendations and Follow-up Actions ......................................................................... 49

10.0 Protectiveness Statenlents .................................................................................................. 50

I 11.0 Next Revie\'V ......................................................................................................................... 51

I Appendix A: List of Docunlents Revie\'Ved ............................................................................. A-I

I Appendix B:- Press Notice ......................................................................................................... B-1

Appendix C: Interview Forms ................................................................................................. C-l

I Appendix D: Site Inspection Checklist ................................................................................... D-l

Appendix E: Photographs from Site Inspection Visit ........................................................... E-l

Tables

I Table I: Chronology of Site Events .............................................................................................. 10 Table 2: COCs and Cleanup Goals ............................................................................................... 19 Table 3

.................................................... 33 : Progress on Recommendations from the 2006 FYR ...................................................... 27

I Table 4: Previous and 2010 ARARs for Ground Water COCs Table 5: Sulfur Area Pilot Test COC Detections in Ground Water to Date ................................. 34 Table 6: Xylene Area Pilot Test COC Detections in Ground Water to Date ............................... 37

I Table 7: Institutional Control (lC) Summary Table ..................................................................... 42

I Table 8: Current Site Issues ................................................................................................... , ...... 48 Table 9: Recommendations to Address Current Site Issues ......................................................... 49

Figures

I Figure 1: Site Location Map ........................................................ _ ................................................. 13 Figure 2: Detailed Site Map .......................................................................................................... 14

I Figure 3: Map of Pilot Study Area ................................................................................................ 25 Figure 4: Site Parcel Map ............................................................................................................. 41

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List of Acronyms I 4,4'-DDT ~lg/L ARAR bgs BHC CERCLA CFR CIC COC DOD DOE DDT EPA ESD FAC FDEP FHRS FYR HQ IC LTTD MCL mg/kg NCP NPL O&M PRP RA RAO RD RIIFS ROD RPM SWFWMD TBC VOC

4,4' -Dichlorodiphenyltrichloroethane Imicrograms per liter Applicable or Relevant and Appropriate Requirement below ground surface IBenzene Hexachloride Comprehensive Environmental Response, Compensation and Liability Act Code of Federal Regulations ICommunity Involvement Coordinator Contaminant of Concern Dichlorodiphenyldichloroethane I Dichlorodiphenyldichloroethylene -Dichlorodiphenyltrichloroethane United States Environmental Protection Agency I Explanation of Significant Differences Florida Administrative Code Florida Department of Environmental Protection I Florida Department of Health and Rehabilitative Services Five-Year Review Hazard Quotient I Institutional Control Low Temperature Thennal Desorption Maximum Contaminant Level I milligrams per kilogram National Contingency Plan National PriOlities List I Operation and Maintenance Potentially Responsible Party remedial action I remedial action objective remedial design remedial investigation and feasibility study I record of decision Remedial'Project Manager Southwest Florida Water Management District I To-Be-Considered Criteria Volatile Organic Compound I

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I I Executive Summary

I Introduction

The Helena Chemical Company (Tampa Plant) Site (the Site) consists of approximately eight

I acres located on four property parcels in Tampa, Hillsborough County, Florida. Since 1929, the

I Site has been used for pesticide and agricultural chemical operations. Helena Chemical Company moved most of the plant's chemical fommlation activities to a facility in Georgia in 1981. Some fOlll1ulation and packaging of insecticidal spray oil and liquid fel1ilizers continues at the facility; however, the Site serves predominantly as a warehouse and distribution center for Helena

I Chemical Company's Florida sales locations. Historical chemical mixing and tOlll1ulation practices resulted in the contamination of soil and ground water with pesticides, xylenes and sulfuric acid.

I The 1996 Record of Decision (ROD) selected a remedy for the Site that consisted of excavation

I and off-site disposal of contaminated soil from source areas, and ground water containment, extraction and treatment. In 2000, approximately 7,700 tons of pesticide-contaminated soil, sediment and debris were excavated from the fonner xylene tank area and from the east drainage

I ditch along the CSX railway line located immediately to the south of the Site. In 2004 and 2005, demolition and removal of concrete from the central courtyard area allowed for excavation of approximately 3,000 tons of contaminated soil from the tonner sulfur pit area.

I The Site is located adjacent to two other Superfund sites: Alaric Area Ground Water Plume

I (Alaric Site) and Stauffer Chemical Co. (Tampa). The ground water pump-and-treat system selected in the 1996 ROD has not been implemented so as not to exacerbate ground water plume migration from the Alaric Site. In August 2009, the potentially responsible party (PRP), Helena Chemical Company, began a pilot-scale bioremediation treatability study at the Site to test the effectiveness of substrate injection in ground water contaminant source areas, in order tor

I biological and physical degradation of the contaminants to occur. The study was scheduled to continue for 12 months, with a contingency period of another 12 months, if necessary.

I The triggering action for this Five-Year Review (FYR) was the signing of the previous FYR report on January 31,2006.

I Remedial Action Objectives

I The United States Environmental Protection Agency (EPA) issued the site-woide ROD on May 7, 1996. Based on the results of the Site's remedial investigation and feasibility study (RIIFS), EPA detennined that remediation of soil, sediment and ground water would be required for the protection of human health and the environment. Remedial action objectives (RAOs) established

I in the ROD tor the Site include:

• Restore the Site to beneficial use;

I • Reduce risk to human health within EPA's acceptable risk range (i.e., total residual cancer risk between 1 x 10-4 to 1 x 10-b

, and maximum individual contaminant hazard quotient of one);

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I I• Reduce ecological risk; and

• Protect ground water from continued degradation by site contaminants.

ITechnical Assessment

The review of documents, applicable or relevant and appropriate requirements (ARARs), lisk Iassumptions and the Site inspection indicate that the Site's soil remedy is functioning as intended by Site decision documents for soil and sediment. Pesticide-contaminated surface soil and sediment at the Site and the adjacent CSX railway line east drainage ditch were excavated and Ishipped off site for biological treatment and disposal. Contaminated soil and residual sulfur were also excavated and shipped off site for disposal. Since there is commingling of the Site's ground water plumes with those of the adjacent Alaric Site, the pump-and-treat ground water remedy Iselected in the 1996 ROD may not cunently be appropriate to-implement at the Site, until the Alaric Site's plumes have been remediated. Helena Chemical Company proposed a pilot-scale treatability study to evaluate the feasibility of biological and physical ground water contaminant Idegradation. The work plan for this treatability study was approved by EPA in August 2009. The study is cunently underway and was scheduled to conclude by the fourth quarter of 20 10, with a contingency period of another 12 months, if necessary. A final report documenting the I efTectiveness of the first full year of the treatability study was not available at the time this FYR report was drafted; therefore, a decision regarding whether to implement the additional 12 month contingency period had also not been made. The final results of the treatability study will be used I to infonn the selection of a revised ground water remedy for the Site. In the event that the treatability study is not successful, EPA may consider additional avenues to approach remediation, including additional excavation. I The ARARs for four of the nine ground water contaminants of concern (COCs), aldrin, alpha­benzene hexachloride (BHC), beta-BHC and dieldrin, have become more stringent since the I signing of the 1996 ROD. During the cunent ground water treatability study, alpha-BHC and beta-BHC have been detected at levels greater than the 1996 cleanup goal. Remedial activities at the Site have allowed the continued industrial use of the property and have reduced ecological I risk at the Site. The selection of a revised ground water remedy is required before achieving the remaining two RAOs: 1) protection of ground water from continued degradation by site contaminants, and 2) reduction of risk to human health within EPA's acceptable risk range. I Residual soil contamination remains present below the water table and the ground water plume continues to exceed cleanup goals. The industrial land use at the Site and in the sunounding area has not changed since the ROD was signed; therefore, the exposure assumptions are still valid. I The 1996 ROD selected the implementation of institutional controls in the fonn of deed restrictions because industrial remedial goals for the soil and sediment were selected, due to the I Site's industrial zoning. In addition, an engineering control in the form of fencing was specifIed.. Land use restrictions have not yet been implemented for the Site; however, some interim institutional controls to protect against exposure to ground water contamination have I been implemented. Cunent and future zoning designations are consistent with the industrial land use criteria used in selection of Site COC cleanup goals. In 2008, EPA entered into a Memorandum of Agreement with the Southwest FlOlida Water Management District I (SWFWMD). The document confIrms SWFWMD's regulatory authority to place restrictions on

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I I well placement and construction. Through shared infonnation between the two agencies,

SWFWMD can make infonned pennitting and enforcement decisions to prevent exposure to

I ground water contamination that could pose a risk to human health. No impacted ground water wells are used for potable water; buildings at the Site and in the surrounding area are connected to municipal water supply lines. At the request of the FDEP, the need for additional institutional

I controls will be evaluated upon selection of a revised ground water remedy for the Site.

The Site is well-maintained and is surrounded by a secured perimeter fence with signs restricting

I access. Access is limited to authorized persons during regular business hours. All site-related wells have been secured or, if no longer operational, have been properly abandoned.

I Conclusion

The Site's remedy cun·ently protects human health and the environment in the short-tern1

I because it is functioning as intended by the Site's decision docllments for soil and sediment. Source materials have been excavated and removed for off-site treatment and disposal. The selected ground water remedy has not yet been implemented due to concerns with promoting

I migration of the ground water plume from the neighboring Alaric Site. A pilot-scale bioremediation treatability study is underway and will hopefully aid in the selection of a revised ground water remedy for the Site. The affected surticial aquifer in the vicinity of the Site is not

I used for potable water supply and area residents and businesses are connected to municipal water

I supply. In order for the remedy to be protective in the long-term, issues concerning implementation of a revised ground water remedy and institutional should be addressed.

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Five-Year Review Summary Form

SITE IDENTIFICATION !

NO Site is in continucd usc by the Helena Chcmical Company.

REVIEW,ST ATUS ,

Lead agency: ['g] EPA o State 0 Tribe 0 Other Federal Agency Author name: Sabrina Foster and Christy Fielden (Reviewed by EPA) Author title: Associate and Project Manager I Author affiliation: E2 Inc.

Review period": 04/15120 I 0 to 01/3112011 Date(s) of site inspection: 07/0812010 Type of review:

['g] Post-SARA o Pre-SARA o NPL-Removal only o Non-NPL Remedial Action Site o NPL StatelTribe-lead o Regional Discretion

Review number: o I (first) ['g] 2 (second) 0 3 (third) 0 Other (specify) Triggering action: o Actual RA Onsite Construction at OU# o Actual RA Start at OU# o Construction Completion ['g] Previous Fivc-\' car Review Report

o Other (spccify)

Triggering action date (/rolll WasteLAN): 01/3112006 Due date (jil'e years after triggerillg actioll date): 01/3112011

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..* [..OU . relers to operable unit.] ** [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN.] I

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Five-Year Review Summary Form continued

Issues: I) A revised ground water remedy for the Site has not been selected or implemented and sampling events continue to detect COC concentrations in ground water that are greater than cleanup goals. 2) Land use restrictions for the Site have not yet been implemented. 3) The ARARs for aldrin, alpha-BHC, beta-BHC and dieldrin have become more stringent since the signing of the

1996 ROD.

Recommendations and Follow-up Actions: I) At the conclusion of the current pilot study, evaluate results and, if appropriate, document the selection of a revised ground water remedy for the Site. 2) During the future modification of the selected ground water remedy, evaluate the need for soil and sediment source control institutional controls and for additional ground water. institutional controls and implement as appropriate.

Protectiveness Statement: The Site's remedy currently protects human health and the environment in the short-ternl because it is functioning as intended by the Site's decision documents for soil and sediment. Source materials have been excavated and removed for off-site treatment and disposal. The selected ground water remedy has not yet been implemented due to concerns with promoting migration of the ground water plume from the neighboring Alaric Site. A pilot-scale bioremediation treatability study is underway and will hopefully aid in the selection of a revised ground water remedy for the Site. The atfected surticial aquifer in the vicinity of the Site is not used for potable water supply and area residents and businesses are cOimected to municipal water supply. In order for the remedy to be protective in the long-term, issues concerning implementation of a revised ground water remedy and institutional controls should be addressed.

Other Comments: Deed records for the Site could not be located through the Hillsborough County Deed Records Oftice or through an EPA property title search. If evaluation of appropriate institutional controls for the Site results in the selection of a restrictive covenant, these deed records will need to be located for the restrictive covenant to be implemented.

Environmental Indicators - Current human exposures at this site are under control. - Current ground water migration is not under control.

Are Necessarv Institutional Controls in Place? D All ~ Some D None A Memorandum of Agreement between EPA and the Southwest Florida Water Management District (SWFWMD) contirms SWFWMD's authority to regulate ground water well use and to impose additional restrictions for the Site and surrounding area. Current and anticipated future land uses and zoning are consistent with the industrial criteria used in selection of Site cleanup goals. At the request of the FDEP, once a revised ground water remedy has been selected, the Site will be further evaluated to detennine whether additional institutional controls are required.

Has the Site Been Designated as Site-Wide Readv for Anticipated Use? D Yes ~ No

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Second Five-Year Review Report I for

Helena Chemical Company (Tampa Plant) Superfund Site I 1.0 Introduction I The purpose of a Five-Year Review (FYR) is to evaluate the implementation and perfollnance of a remedy in order to detemline if the remedy will continue to be protective of human health and the environment. The methods, findings, and conclusions of FYRs are documented in five-year I review reports. In addition, FYR reports identify issues found during the review, if any, and document recommendations to address them. I The U.S. Environmental Protection Agency (EPA) prepares FYRs pursuant to the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Section I121 and the National Contingency Plan (NCP). CERCLA Section 121 states:

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

IEPA interpreted this requirement further in the NCP; Title 40 of the Code of Federal Regulations (CFR), Section 300.430(f)(4)(ii) states:

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

E2 Inc., an EPA Region 4 contractor, conducted the FYR and prepared this report regarding the I remedy implemented at the Helena Chemical Company (Tampa Plant) Site (the Site) in Tampa, Hillsborough County, Florida. This FYR was conducted from April of2010 to January of201l. EPA is the lead agency for developing and implementing the remedy for the potentially I responsible party (PRP)-financed cleanup at the Site. The Florida Department of Environmental Protection (FDEP), as the support agency representing the State of Florida, has reviewed all supporting documentation and provided input to EPA during the FYR process. I This is the second FYR for the Site. The triggering action for this statutory review is the previous FYR in 2006. The FYR is required due to the fact that hazardous substances, pollutants or I contaminants remain at the Site above levels that allow for unlimited use and unrestricted exposure. I

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I I 2.0 Site Chronology

I The following table lists the dates of important events for the Site.

Table 1: Chronology of Site Events

I Event Date

Initial discovery of contamination AlIgust I, 1980

I Site proposed for the National Priorities List (NPl) Febmary 7, 1992 Administrative Order on Consent between EPA and Helena Chemical

I September 2, 1992

Company; remedial investigation and feasibility study (RIIFS) start date Site listed on the NPL October 14, 1992 RIfFS completed July 20. 1995

-Record of Decision (ROD) signed

I - - ~1ay7,1996

Unilateral Administrative Order and Consent Decree issued by EP A to DeceIl1ber 10, 1996 Helena Chemical Compnny for implementation ofremedinl design (RD) and remedial action (RA) RD start date

I December 26, 1996

Soil RD completion date; and RA start date Febmary 14, 2000 Soil RA completed March 7, 2001 RD for sulfur area started

I Ma rch 18,2003

RD for sulfur area completed May 8, 2003 Explanation of Significant Differences (ESD) for xylene issued January 27,2005 Consent Decree issued by EP A to Helena Chemical Company for cost July 20,2005 recovery

I First FYR signed January 31, 2006 Memorandum of Agreement signed between EPA Region 4 and

I September 1 I, 2008

Southwest Florida Water Management District (SWFWMD) Pilot test for ground water and interim monitoring program start A ugust 2009

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3.0 Background I 3.1 Physical Characteristics I

The Site is located at 2405 North 71 st Street, within the City of Tampa in Hillsborough County, Florida (Figure 1). This active commercial and industrial land use area is known Ias Orient Park or Bunchville. An active CSX railway line runs along the southern border of the Site. The active main operating facility is on a single 6.5-acre parcel (Parcel #A­14-29-19-4CA-000000-00022.0) bounded by Orient Road to the east, East 14th Avenue to Ithe north and North 71 st Street to the west. Three additional parcels (Parcel #A-14-29-19­4CA-000000-00032.0; Parcel #A-14-29-19-4CA-000000-00033.0; and Parcel #A-14-29­19-4CE-000003-00001.0) totaling 1.97 acres located west of North 71 st Street are also I included as part of the Site and are known as the Helena Woods. The Site is situated between two other Superfund sites: 1) the Alaric Area Ground Water Plume Superfund Site (Alaric Site) to the north of the Helena Woods area and to the west of the main I operating facility; and 2) the Stauffer Chemical Company (Tampa) Superfund Site to the southeast of the Site, on the southern side of the CSX railroad tracks.

I The Site is approximately 0.5 miles west of Six Mile Creek and the Tampa Bypass Canal. The Site is subject to flooding during periods of intense and extended rainfall. Surface water at the Site is composed entirely of stonnwater runoff, and the sediment remediation I in the Site's selected remedy addresses sediment deposited by this overland flow. Stonnwater runoff from the central portion of the Site channels into concrete drainage swales and tlows into an on-site retention pond located in the southeastern corner of the I operating facility parcel. The retention pond is designed to hold stonmvater runoff during a 20-year storn1. A spillway at the southeastern corner of the retention pond allows overflow to drain into a drainage ditch parallel to the CSX railroad tracks. The retention I pond is part of the runoff control system at the Site and does not constitute a significant ecological habitat. I On the western and northern boundaries of the operating facility parcel, stonnwater flows to the southwest where it collects in a low-lying section of the Helena Woods area and then flows to the north via a paired ditch/culvert system along the east and west shoulders I of North 71 st Street. On the east boundary, surface water flow continues south along the ditch parallel to Orient Road. Drainage turns eastward through a culvert under Orient Road, then travels east-northeast for approximately 0.5 miles. The drainage pathway I continues through a swale on the north side of the CSX right-of-way.

ISurticial deposits at the Site consist of a thin, three to six inch layer of topsoil and sediment coveling fine- to medium-grained sands. These deposits extend approximately 11 feet below the ground surface (bgs) and are primarily unconsolidated brown, fine­grained sands with traces of organic matter, clay, silt, medium-grained sand and shells. I The surticial deposits fonn a sharp contact with the underlying Intern1ediate Confining Unit, which is a stiff intennediate clay unit between the overlying surficial aquifer and Ithe underlying poorly consolidated limestones that grade into more indurated limestones.

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I I The bottom portions of the surficial unit are saturated year-round; the water table

fluctuates drastically with precipitation, with seasonal high-water tables rising to within

I one foot bgs. The clay of the Intermediate Confining Unit, or intennediate aquifer system, has low hydraulic penneability and fonns the semi-confining unit between the ground water of the surficial aquifer and the Floridan aquifer. The Upper Floridan aquifer

I is encountered at approximately 80 feet bgs. Moderately indurated, clayey, sandy limestone is present in the upper section of the Floridan aquifer.

I Ground water flow at the Site is oriented in a radial pattern to the northeast, east, southeast, south and southwest. Gradients are the highest in the southeastern direction, and lowest toward the northeast and southwest.

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I IFigure 1: Site Location Map

Hele.,a Choemical COfTllany ~ ~ Super1und S

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H@naChemJCal sljp&:sJ;:MII ' Company

~==~=:::::=~;:::; Supeffund Site

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• I.- -- -' •

~~

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~_______c~ I

~~~~/_.--------~--------~~~ I I

A Figure 1 Helena Chemical Company Superfund Site • '~ile Vicinity Map Tampa. H- sborough County. Florida NORT

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

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I I Figure 2: Detailed Site Map

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I¢I:roIm1:lle B<>~rd"'y or SLtlfiCiaj Aquilt!' GlOU1d I/t.':!J]", PUll'!<!

A<,:!proxrn;:rt.,. BOlIrd;ry or .,.0;, c Aql.ffcr S~'" Gflll.",d 'MIl Plunlt

~ -_ '".! SHe o~n~!'( l:::. Pn....101 ~\II)11i FOUfl(! 0 11'9 SIte 1I18padiorl

o NORTH

Figure 2 SrteMap

Helena Chemical Company Superfund Site Tampa Hillsborough County, Florida

Di claimer: This map and any boundary lines within the map are approximate and ubjectto change. The map is not a survey. The map is for infonnational purposes only regarding EPA's response actions at the Site. and is not intended for any other purpose.

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I I3.2 Land and Resource Use

The Site has been used for the manufacture, storage and distribution of agricultural ,Iproducts since 1929. The original Site owner, Flag Sulfur Company, fommlated a wide variety of insecticides, herbicides and fungicides, including wettable and dusting sulfur, at the Site from 1929 until 1967. Helena Chemical Company acquired the business in I1967 and continued manufacturing operations. In 1981, Helena Chemical Company ,moved the pesticides, herbicides and fungicides fonnulation operations to a facility in Georgia in 1981, and the Tampa facility has continued fommlating and packaging Iinsecticidal spray oil and liquid fertilizers since that time. The Site also serves as Helena Chemical Company's main distribution warehouse for sales locations in the State of Florida. I The Site consists of four land parcels within a secured Site perimeter fence. The largest of these parcels (6.5 acres) contains the active Helena Chemical Company offices, Iwarehouses and distribution centers, as well as associated paved parking areas. This parcel (#A-14-29-l9-4CA-OOOOOO-00022.0) is presently zoned for light industrial land uses. The Planning Commission serving Hillsborough County, the City of Plant City, the ICity of Temple Terrace and the City of Tampa anticipates this parcel's future land use to be heavy industrial. The three smaller parcels fonning the Helena Woods area are covered by low grassy vegetation and oak trees, and also contain several ground water I monitoring wells for the Alaric Site, located immediately to the north. Two of the Helena Woods parcels are listed as being vacant, and the third is zoned for a mobile home park. The Planning Commission anticipates that all three parcels will be zoned for heavy I industrial use in the future. North 71 st Street fomlerly crossed the CSX railroad tracks to the south of the Site, but the road was closed after an accident at the crossing. The street now dead ends at the entrance gate to the truck loading area on the Helena Chemical I Company property, and the closed section of street between the entrance gate and the railroad tracks is included within the Site perimeter fencing. I Surrounding land uses predominantly include various light and heavy industrial uses as well as commercial land uses. Small pockets of single family residences are located several blocks to the north and to the west of the Site. Buildings on the Site and I throughout the area impacted by site-related ground water contamination are connected to municipal water supply lines. None of the ground water wells impacted by contamination from the Site are used for potable water supply. I

3.3 History of Contamination I The facility was built in 1929 as a chemical plant for the production of sulfur and was owned and operated by Flag Sulfur Company. No historical records regarding the specific products fonnulated during Flag Sulfur Company operations are available, but I previous facility managers indicated that the company manufactured wettable and dusting sulfur and fomlulated pesticides, herbicide~, fungicides and fertilizers at the Site. In 1967, Helena Chemical Company purchased the facility from Duval Corporation, the owner of I Flag Sulfur Company. From 1967 to 1981, Helena Chemical Company produced

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I I wettable and dusting sulfur and fom1Ulated pesticides, herbicides, fungicides and

fertilizers at the Site. The company purchased the raw materials from suppliers and added

I solvent, emulsifiers and/or surfactant to give the finished product certain characteristics required for various applications and strengths.

I Historically, most agricultural chemical fonnulation occurred in the East Warehouse building, located in the south central portion of the main operating facility parcel. The fom1Ulation process for liquid products would consist of mixing a technical chemical

I with various solvents, a surfactant and/or emulsifiers in aboveground mixing vessels in the East Warehouse building. Various solvents, including xylene and an intemlediate range petroleum solvent calIed T -500, were used as pesticide carriers or diluents. These

I solvents were stored on site in aboveground storage tanks. A 3,500-gallon capacity aboveground xylene storage tank was historically located in a benned area to the east of the East Warehouse building. This tank was vandalized in 1977 causing a release of

I xylene to the soil and ground water below.

In 1974, Helena Chemical Company began using a three-tank pollution control system to

I handle the wash-down waste generated from pesticide manufacturing. The wash-down waste consisted primarily of pesticides in a xylene carrier. It was diluted with other

I process water and storm water, treated with caustic soda, run through an aeration evaporation treatment system and finally discharged to the on-site stomlwater retention pond. Sludges associated with the treatment system were periodically removed and

I shipped to the Chemical Waste Management Inc. facility in Emelle, Alabama, for appropriate disposal. At an undetennined time between 1984 and 1988, use of the three­tank pollution control system was discontinued.

I According to the 1996 ROD, the on-site stomlwater retention pond may have received

I some overflow waste from the East Warehouse building before the pollution control tanks were installed in 1974. During construction of the retention pond, soil in the southeastern portion of the Site was removed using backhoes and placed in the Helena Woods area. While the Helena Woods area was never used for agricultural chemical

I fonnulation or packaging, contamination in this area is attributed to the dredge materials from the retention pond and to treatment with pesticides and herbicides during routine maintenance activities.

I I Dry products were formulated in the east end of the West Warehouse building, just south

of the loading dock, using a Raymond Mill for grinding and a set of ribbon blenders for mixing. Helena Chemical Company would then package the finished product for resale.

I Both Flag Sulfur Company and Helena Chemical Company manufactured sulfur dust and wettable sulfur on site. Flag Sulfur Company's operations are largely unknown. Helena Chemical Company's sulfur processing operations consisted oftranspol1ing molten sulfur to the Site and unloading the sulfur in the f0n11er sulfur pit area, located south of the current central paved courtyard between the West and East Warehouse buildings. The

I sulfur was contained in berms for a period of approximately 48 hours until it had solidified. Heavy equipment was then used to break the sulfur into pieces for processing through the Raymond Mill.

I I 16

I I

3.4 Initial Response I In 1976, Helena Chemical Company stopped processing sulfur products. The fomler sulfur pit area was excavated and then filled with clean sand. In 1980, the fom1Ulation of Idry fertilizers was also discontinued at the facility. In 1981, Helena Chemical Company moved the pesticide, herbicide and fungicide fonnulation operation to a company facility in Georgia. Since 1981, Helena Chemical Company has forn1Ulated insecticidal Ipetroleum oil (a 70-viscosity paraffin-based oil with an emulsifier additive) and liquid fertilizers at the Site. In addition to products produced at the facility, numerous agricultural products are stored in the warehouse prior to distribution to Helena Chemical I- Company~s Florida sales offices.

In 1984, FDEP inspected the Site and required quarterly monitoring of the surficial Iaquifer. From 1988 to 1990, EPA investigated the Site and found pesticide contamination in the on-site soil, sediment and surficial aquifer. Based on the potential for human exposure via ingestion of contaminated f,'Tound water, EPA proposed the Site for listing Ion the NPL in February 1992 and finalized the listing in October 1992.

The Florida Department of Health and Rehabilitative Services (FHRS, the predecessor of IFDEP), in cooperation with the Agency for Toxic Substances and Disease Registry, prepared a public health assessment for the Site in September 1993. In that report, FHRS expressed concern for on-site worker contact with contaminated soil and exposure to I sediment and ground water. FHRS made several recommendations that additional data should be collected. Under a September 1992 Consent Order with EPA, Helena Chemical Company perfonned a RIfFS at the Site. The primary objectives of the investigation were I to deternline the nature, magnitude and extent of contamination; evaluate potential risks to human health and the environment; and evaluate potential cleanup alternatives. Site operations have remained active throughout site investigations and remedial activities. I

3.5 Basis for Taking Action I The results of the RIIFS documented extensive surface soil and sediment contamination, including pesticides, semivolatile organic compounds and volatile organic compounds (VOCs) related to fonner operations by Helena Chemical Company and its predecessors. I The investigations also documented contamination of ground water in the surficial aquifer and internlediate aquifer systems with chlorinated pesticides, polycyclic aromatic hydrocarbons, phenols and VOCs. A human health risk assessment perfonned by Black I and Veatch in 1994 concluded that risks to current and future site workers, current and future trespassers, and potential future Site residents exceeded acceptable risk and hazard thresholds. I

I I

17

I

I I 4.0 Remedial Actions

I In accordance with CERCLA and the NCP, the ovelTiding goals for any remedial action are

I protection of human health and the environment, and compliance with applicable or relevant and appropriate requirements (ARARs). A number of remedial altematives were considered for the Site; final selection was made based on an evaluation of each altemative against nine evaluation criteria that are specified in Section 300.430(e)(9)(iii) of the NCP. The nine criteria include:

I 1. Overall Protectiveness of Human Health and the Environment 2. Compliance with ARARs

I 3. Long-Tenn EtTectiveness and Pem1anence 4. Reduction of Toxicity, Mobility or Volume of Contaminants through Treatment 5. Short-tem1 EtTectiveness

I 6. Implementability 7. Cost 8. State Acceptance

I 9. Community Acceptance

4.1 Remedy Selection

I I EPA issued the site-wide ROD on May 7,1996. Based on the results of the Site's RIIFS,

EP A detennined that remediation of soil, sediment and ground water would be required for the protection of human health and the environment. Remedial action objectives (RAOs) established in the ROD for the Site include:

I • Restore the Site to benefIcial use. • Reduce risk to human health within EPA's acceptable risk range (i.e., total

residual cancer risk between I x 10-4 to I x 10-6, and maximum individual

I contaminant Hazard Quotient of I).

• Reduce ecological risk. • Protect ground water from continued degradation by Site contaminants.

I The remedy selected in the Site's 1996 ROD consisted of the following remedial components for source control in soil and sediment:

I I

• Implement institutional controls (i.e., fencing (cuITently considered an engineering control) and deed restrictions).

• Demolish tank fam1 pads east of the liquid processing building (East Warehouse) and dispose of the debris off site.

I • Excavate material from the fonner sulfur pit and dispose of excavated materials off site.

• Neutralize soil in place iflocated in areas where sulfur is present but inaccessible.

I • Excavate contaminated surface soil and sediment (zero to two feet) where concentrations exceed soil cleanup goals.

• Biologically treat contaminated surface soil and sediment.

I I 18

I I• Place treated soil back on site.

Major components of the ground water remedy selected in the 1996 ROD include: I • Extract contaminated ground water. • Treat contaminated ground water to meet surface water discharge standards. I• Discharge treated ground water to on-site ponds or to the Tampa Bypass Canal

under a National Pollutant Discharge Elimination System pennit. • Place controls on Site to restrict the use of ground water beneath the Site through I

the filing of deed notices in order to limit exposure to contaminated ground water until cleanup goals are met.

I The 1996 ROD selected cleanup goals for contaminants of concern (COCs)'in both ground water and surface soil (Table 2). As Site data suggested that sediments with pesticide contamination attributable to the Site were primarily present in drainage ditches I that were typically dry, remediation of sediment in Site drainage features was to be managed using the surface soil cleanup goals protective of human health. The 1996 ROD also selected a contingency remedy for Site soil and sediment. If treatability studies I demonstrated that the selected biological treatment remedy could not achieve the performance standards listed in Table 2, low temperature thennal desorption (LTTD) was to be used in lieu of the biological treatment. I Table 2: COCs and Cleanup Goals I

. ,r. ./?lJ/' Contaminant ofConcern

4,4' -dichlorodiphenyltrichloroethane (4,4'-DDT) Aldrin Alpha-benzene hexachloride (Alpha-BHC) Beta-benzene hexachloride (Beta-BHC) Gamma-benzene hexachloride (Gamma-BHC) Chlordane Dichlorodiphenyldichloroethane (DDD) Dichlorodiphenyldichloroethylene (DDE) Dichlorodiphenyltrichloroethane (DDT) Dieldrin Endosulfan I Endosulfan II Heptachlor Heptachlor epoxide Total xylenes Toxaphene NA: not applicable

Ground Water Cleanup Goal

(micrograms per liter, Ilg/L)

0.3

0.05

0.05

0.1

0.2

NA NA NA NA 0.1 2 2

NA NA 20 NA

','>S~rface Soil and Sediment Cleanup Goal

(milligrams per kilogram, Img/ko )

NA

0.18 I 0.47

INA

NA I2.3 12.6 8.9 8.9 I

0.19 NA NA I0.67 0.34 NA 2.76 I

I 19

I

I I In January 2005, EPA issued an Explanation of Significant Differences (ESD) to modify

part of the remedy described in the 1996 ROD. The purpose of the ESD was to modify

I the xylene cleanup goal for ground water from 20 micrograms per liter (Ilg/l) per the Florida secondary maximum contaminant level (MCl) to 10,000 pg/L per the State and federal primary MCL. Secondary MCls are non-mandatory standards under the

I Superfund program and are not enforceable by EPA; however, they are a component of the State of Florida's drinking water statute. State and federal primary MCls are enforceable standards established to protect the public against consumption of drinking

I water that presents a risk to human health. The ESD also called for continued monitoring of the effectiveness of the xylene treatment and for evaluation of further remedial actions should the presence of xylene, a solvent, mobilize residual soil pesticide contaminants

I into ground water.

4.2 Remedy Implementation

I Remedial design and remedial actions for soil, sediment and ground water at the Site are being implemented by the Helena Chemical Company, under a 1996 Unilateral

I Administrative Order. An additional Consent Decree was filed in 2005 for EPA to

I recover past and future costs incurred and to require Helena Chemical Company to pay EP A oversight costs at the Site and at a separate Site in South Carolina also owned by Helena Chemical Company.

I Soil and Sediment Source Control

I In 1999, additional grid-based sampling was conducted in the xylene source area (east of the East Warehouse building) to deternline the boundaries for the soil removal excavation. Bench-scale studies were performed by EPA's Ecosystems Research Division and EPA's Science and Ecosystems Support Division to investigate the

I effectiveness of incorporating zero-valent iron in soil to facilitate abiotic degradation of chlorinated pesticides. These studies were implemented in 1999, but were tenninated

I early due to lack of measurable COC degradation. Helena Chemical Company then explored the option of using the Xenorem bioremediation process, which had been

I successfully implemented on the adjacent Stauffer Chemical Co. (Tampa) Superfund site. The extent of contamination prevented direct application of the Xenorem approach at the Site. Helena Chemical Company learned, however, that an off-site disposal facility, the

I Waste Management Inc. hazardous waste treatment facility in Carlyss, louisiana, (facility number lAD0007772010PI), had been authorized to bioremediate wastes in July 1998 and could potentially accept the excavated Site materials for bioremediation at the off-site facility. EPA approved the change from on-site to off-site treatment and disposal of contaminated soil and sediment in a letter dated February 14, 2000.

I The 1996 ROD had also stipulated lTTD as a contingency soil treatment should biological treatment be ineffective. EPA requested this contingency be explored in 1999.

I Helena Chemical Company retained Focus Environmental Inc. to perfonn the evaluation of the contingency treatment. The evaluation concluded that l TTD was not a practical remedy for the Site primarily due to concerns related to elevated sulfur concentrations in

I I 20

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

I Isoil, which would require air pollution controls to remove acid gas generated by the

treatment, as well as space limitations on the Site, which would not pernlit an efficient layout and operation of the treatment and material handling units. I In 2000, Helena Chemical Company excavated 7,700 tons of pesticide-contaminated soil from the Site, including the xylene source area, and an additional 600 tons of pesticide­contaminated soil and sediment from the drainage ditch area along the CSX railway I. right-of-way just south of the Site. Soil was transported to the Waste Management Inc. facility in Carlyss, Louisiana for bioremediation and· off-site disposal. Surface soils were Iexcavated to a depth of two feet. According to the 1996 ROD, the water table in the area fluctuates between two and four feet bgs. Therefore, the excavation of surface soils to two feet bgs would address soil contamination above the water table, but not Icontamination existing below the water table. The excavation areas were lined with an-­indicator fabric prior to backfilling the areas with clean materials and seeded with grass where appropriate. 1 Delineation activities to deternline the extent of sulfur contamination in the fonner sulfur pit area were perfonned from 2001 through 2003, and remedial work was perfonlled in Itwo separate phases. A metal building covering much of the area where sulfur remedial work was to be performed was dismantled and transported off site for recycling. During phase I remedial work performed in 2004, soil and concrete were excavated from the Ielevated loading dock area and the west side of the tank farnl for off-site treatment and disposal. During phase II remedial work perfonned in 2005, soil and concrete were excavated from the northern tank fann and fonner warehouse boundaries. Approximately 13,000 tons of soil and crystallized (fomlerly molten) sulfur were removed during the 2004 and 2005 removal activities and also shipped to the Waste Management Inc. facility in Carlyss, Louisiana for off-site disposal. I The 2005 ESD changed the xylene ground water cleanup goal from 20 )lg/L to 10,000 )lg/L. Since the presence of xylene in ground water could mobilize residual pesticide I contamination in soil into ground water, the ESD included post-treatment monitoring of the xylene area. This monitoring includes all COCs established in the 1996 ROD and a specitlc assessment of whether the remaining xylene concentrations are sufficiently low 1 to ensure that cosolvency is not facilitating the transport of residual pesticides that might be lingering in the soil. If cosolvency is found to be mobilizing residual pesticide contaminants from soil to ground water, this assessment will be used to detennine I whether further active treatment of xylene to below the federal and state primary standard IS necessary. I Ground Water

The ground water remedy described in the 1996 ROD has not yet been implemented at I the Site due to discovery of contamination and investigations at the adjacent Alaric Site and concerns that the selected remedy would potentially cause further contamination of the aquifer systems. Alternative ground water treatments are currently being investigated I in the pilot-scale treatability study underway at the Site. Supplemental data collection and

1 21

1

I I ground water plume delineation studies began in 1998. Ground water sampling

perfonned in existing surticial aquifer and internlediate aquifer system monitoring wells

I in February 1998 resulted in the installation of additional surficial aquifer wells south of the Site to further delineate the nature and extent of contamination. The results of this study also deternlined the need for further investigation of ground water contamination in

I the xylene area (location of 1977 release immediately east of the East Warehouse on the Site; Figure 3), in the sulfur area (location of the fonner sulfur pit in central courtyard on the Site; Figure 3), and in the intennediate aquifer system.

I Field activities to address the recommendations of the February 1998 investigation were implemented in April 200 I. Eight additional monitoring wells (MW-24 through MW-31;

I Figure 2) were installed south and east of the Site on City of Tampa rights-of-way to monitor the extent of contamination in the surficial aquifer. Contamination was also identitied in shallow areas of the intennediate aquifer system. Ground water sampling

I and supplemental tield activities were perfonned from October 2002 through January 2003. These activities included intennediate aquifer investigations, xylene source area investigations, downgradient surficial aquifer monitoring well installation, and sulfur area

I investigations. Additional intennediate aquifer system monitOling wells (MW-32 and MW-33; Figure 2) were installed along Olient Road dUling a November 2002 comprehensive ground water sampling event. The new wells were installed to provide

I internlediate monitOling points for xylene, pesticide and herbicide contamination.

I While the 2002 and 2003 tield activities were being perfonned, significant chlorinated solvent contamination from the apjacent Alaric Site was discovered in both the surficial aquifer and intennediate aquifer systems; this contamination was commingling with the

I western portion of the Site's ground water plume. The implementation of the ground water pump-and-treat remedy selected for the Site had the potential to exacerbate

I contaminant plume migration from the Alaric Site. For this reason, EPA detennined that implementation of the pump-and-treat remedy for the Site should be delayed until delineation and remediation of the surticial aquifer at the Alaric Site is completed.

I Additional comprehensive ground water sampling events were perfonned in May 2005 to provide a baseline for water quality following completion of the sulfur area removal actions, and in December 2006 to detennine current conditions across the monitoring

I well network. Selected wells were also sampled in March, August and November 2007

I and January 2008 to gauge the overall effectiveness of the sulfur area removal in addressing source contamination of the surticial aquifer. Given the probability that the selected pump-and-treat remedy for ground water at the Site would be incompatible with

I ground water treatment activities being designed at the adjacent Alaric Site, several alternative management approaches to address bTfound water contamination in the sulfur area and associated plume were explored.

I In June 2009, Helena Chemical Company presented EPA with a Pilot Test and Interim Monitoring Work Plan to address ground water contamination without implementing the pump-and-treat remedy. EPA approved the Work Plan in August 2009, and implementation began in August 2009. The pilot study is expected to last for one year

I I 22

I Iwith an additional one-year contingency period. The work plan addresses four critical

areas of source control and monitoring: the sulfur area, the xylene area, supplemental monitoring efforts and interim ground water monitoring activities while pilot testing is underway. I Sulfur Area Pilot Study I The pilot study objective in the sulfur area is to detennine whether butTering pH and introducing zero-valent iron will allow natural degradation of benzene hexachloride I(BHC) and sulfates in the source area through biological or physical mechanisms. Low pH, elevated sulfate and residual sulfur in the sulfur area are thought to be inhibiting natural biological degradation processes and minimizing the physical attenuation of I- -- contaminants within the aquifer-matrix, which would typically occur through adsorption­and aqueous chemical reactions such as hydrolysis. Given the residual sulfur in the soil, which continues to act as a long-tenn source for sulfuric acid, sulfate control was Irequired in addition to pH controls. Zero-valent iron was selected as the primary pilot study treatment technology for the sulfur area because it has been used effectively to facilitate abiotic degradation of BHCs, is effective at moderating pH and acts as an Ioxygen scavenger, limiting any future oxidation of residual sulfur in the soil. Additional neutralization with lime and/or hydroxides and biological sulfate reduction may also be utilized to control pH levels, if necessary. I Two sulfur study areas, known as the East Plot and the West Plot, have been implemented in the central courtyard of the Site on either side of the fomler sulfur pit Ilocation (Figure 3). Each plot consists of eight injection wells. Chemical injections were administered in the third quarter of 2009 and sampling is being conducted at 60-day intervals for the 360 days following the injections. I Xylene Area Pilot Study

I The xylene pilot test was designed to gauge the effectiveness of anaerobic biodegradation in degrading xylene and residual BHCs. Total xylene concentrations have declined since the 2000 soil removal action in the fonner xylene tank area, but have remained above I cleanup goals. Site conditions such as low pH, lack of nutrients and lack of electron accepting substrates (e.g., nitrate, iron and sulfate) were thought to be limiting xylene and BHC degradation. The pilot test also sought to increase degradation rates without I introducing treatments that would complicate etTorts in the adjacent sulfur pilot study . area. so the xylene treatment was designed in consideration of the existing anaerobic Site conditions. I One xylene pilot study area was implemented in the fonner xylene tank area (Figure 3). The plot includes six injection wells and 12 monitoring wells. The first round of nutrient I and electron acceptor substrate injections was perfonned in the third quarter of 2009 and the second round of injections was perfonned in the fourth quarter of2009. As with the sulfur pilot study area, sampling is being conducted at 60-day intervals for the 360 days I following the first round of injections.

I 23

I

I I

Monitoring Activities

I Supplemental monitoring efforts in the work plan include installation of monitoring wells on the Festive Floats property, located directly south of the Site on the opposite side of

I the CSX railway tracks, and additional investigation to determine the northern extent of low pH and elevated sulfate and BHe concentrations. Until a revised ground water remedy is selected for the Site, interim ground water monitoring activities in both the

I surficial and intermediate aquifer systems will include sampling every nine months to assess seasonal variability in concentrations and monitor for any changes in COC concentrations.

I I I I I I I I I I I I I I 24

-

----

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

Figure 3: Map of Pilot Study Area

swr2:0 ... swr u

s£n srnu SET"O ..../ ...

I SETSD

East Wafl~hou~

.... * ,,-"

11!1(\~s " " _ - - ­st.olage --- " ,,_ .....

~ .... -- .. " .. -

We t Warehou~ ....... .. -.. ­.. --- -",,­

.. --,,- .. -" ~

Legend

.. SurltclM Mu/l'erSolfurArea PlIO! Test well : : : ] Sue Bou1'lCl8f\( rl----L___...JIFe~

Surfic:ia Aquirer Xylene Ar"", Pi"" r"", I c1Jan WI:II o 50 100

Surl"cia Aquirel Xylene Arf:lll "ilol T~I lAbnilonng \/\!ell

n NORTH

Figure 3 Site Map:

Pilot Study Areas

Helena Chemical Company Superfund Site

Tampa, Hillsborough 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 iofonnational purposes only regarding EPA's response actions at the Site, and is not intended for any other purpose.

25

I I 4.3 Operation and Maintenance (O&M)

I The 1996 ROD anticipated that the ground water pump-and-treat system would be operated at the Site for a 30-year period and estimated that O&M of the system would cost $1,289,000 over the course of the 30 years. The ground water remedy selected in the

I 1996 ROD has not yet been implemented due to developments at the adjacent Alaric Site and ongoing pilot testing at the Site. As remedial activities continue \vith pilot testing, there are no O&M activities underway at the Site and the activities to be addressed in a

I site O&M plan will depend on the future revised remedy for ground water for the Site.

I I

°1

I I I I I I I I I I I 26

I I5.0 Progress Since the Last Five-Year Review

The protectiveness statement from the 2006 FYR for the Site stated the following: I "The reme(~v implemented otthe [Helena Chemical Company} Tampa Site currentzv protects human health and the environment because source arca actions implernentedfor Ipesticide-contaminated soil and the sulfur pit source area have been completed dllring this review "period. Additional evaluations (?f low pH conditions ll'ill be pc/formed to assess the needfor sllpplementalnelltralization in conjunction lvitlz future groundwater Iactions. No remedial actions/or grounchvater have been implemented at this time. Site data evaillations and reme«v evaluations 1I,il/ ensure the remeczv will be protective. III the interim, e.\posure pathways that could result in unacceptable risks are incomplete . I

. -Conditions-attize site are not e_\pected to change in the nearfuture; given the area's lalld use (commercial/industrial). However, ill orderfor the reme«v to be protectil'e in the long term, thefollowillg actions need to be taken: afull evaluation (?fthe needfor deed I restrictions and. ({necessm:v, they will be imposed. ..

The 2006 FYR included three issues and recommendations. Table 3 summarizes each I recommendation and its current status.

Table 3: Progress on Recommendations from the 2006 FYR I Section Recommendations

Parties Responsible

Milestone Date

Action Taken and Outcome

Date of Action

5.1

EP A, FDEP and Helena Chemical Company will discuss ground water remedy issues, including the need for further assessment of natural attenuation processes. Dialogue will generate a priority list for evaluation, identify evaluation teclmiques, and establish an evaluation timetable. Ground water remedy discussions will be initiated by the second quarter of 2006.

EPA, FDEP, Helena

Chemical Company

4/3012006

Discussions between EP A, FDEP and Helena Chemical Company have resulted in the development of a pilot testing work plan to explore treatment options for enhancing biological and physical degradation processes. This pilot study was initiated in August 2009.

0813112009

27

I I I I I I I I I I

I I I I I I I I I I I I

SeCtion , :~ecommendations

Parties Responsible

Milestone Date

Action Taken and Outcome;':~ ..

Date of Action

- ­

5.2

EPA, FDEP and Helena Chemical Company will evaluate xylene source area issues. Discussions will include prioritization of any additional RD activities, evaluation of remedial cleanup goals, etc. Xylene remedy discussions will be initiated by the first quarter of 2006.

EPA, FDEP. Helena

Chemical Company

4/3012006

--

Pilot test program discussions between EP A, FDEP and Helena Chemical Company have resulted in the development of a work plan to explore effectiveness of anaerobic degradation of xylene and BHCs. This pilot study was initiated in August 2009.

08/31/2009

5.3

Helena Chemical Company will evaluate the requirements for implementing deed restrictions on the property, and whether any remedy-speci fic requirements must be incorporated into the institutional control. A full evaluation of the

Helena Chemical Company

12/31/2006

EPA and FDEP are is discussions regarding the restrictive covenant for the Site's soil in order to prevent exposure. Land use zoning is consistent with soil cleanup criteria and land use is not anticipated to change in the foreseeable future.

Pending

need for deed restrictions will be made and, if necessary. they will be imposed. This evaluation will be completed by the fourth quarter of 2006.

Ground water institutional controls are enfi.1fced through an EP A Memorandum of Agreement with the Southwest Florida Water Management District.

I 5.1 Ground Water Remedy Discussions

I The ground water pump-and-treat remedy selected in the 1996 ROD has not been

I implemented due to potential complications arising from commingling of the Site's ground water contaminants with those from the adjacent Alaric Site. A Pilot Study and Interim Monitoring Work Plan was approved by EPA and implementation began in August 2009. The Work Plan describes the investigation of chemical injections to enhance and facilitate natural physical and biological degradation rates for contaminants

I in the sulfur area and in the xylene area. The study is designed to assess the following questions:

I • Is degradation occurring under pilot conditions? • Can aquifer geochemistry be adjusted to facilitate remediation?

I • What is the longevity of amendments being injected?

I 28

I I• What zone of discharge is developed following injection, and what is the expected

duration of the zone of discharge?

IThe study was scheduled to continue for 12 months, with a contingency period of another 12 months, if necessary. At the conclusion of the study, these questions will be addressed to detennine next steps in selecting an appropriate ground water remedy for the Site. A Ifinal report documenting the effectiveness of the first full year of the treatability study was not available at the time this FYR report was drafted; therefore, a decision regarding whether to implement the additional 12 month contingency period had also not been Imade.

5.2 Xylene Source Area Discussions I As noted in Section 5. L EPA approved the Pilot Study and Interim Monitoring Work Plan in 2009. Per the Work Plan, two rounds of nutrient and electron acceptor substrate Iwere injected in the xylene area in late 2009. The injections are expected to enhance natural degradation rates of xylene and BHCs; sampling is being conducted every 60 days. The study was scheduled to continue for 12 months, with a contingency period of I another 12 months if necessary. A final report documenting the effectiveness of the first full year of the treatability study was not available at the time this FYR report was drafted; therefore, a decision regarding whether to implement the additional 12 month I contingency period had also not been made.

5.3 Institutional Controls Evaluation I At the request of FDEP, the appropriate land use restrictions for the Site has not been yet been implemented. While the ground water remedy is being assessed, some interim I institutional controls to protect against exposure to ground water contamination have been implemented. The Site is presently surrounded by a secured perimeter fence that only pennits access to the property by authorized persons during regular business hours. I Helena Chemical Company intends to continue Site operations for the foreseeable future and does not intend to sell or lease the property, so there is minimal potential for a party to unknowingly become exposed to Site soil or sediment contamination or to impact the I protectiveness of the remedial actions already in place. The operating facility parcel is zoned light industrial; the three Helena Woods parcels are zoned as either vacant land or as a mobile home park. The local Planning Commission anticipates all four parcels will I be zoned for heavy industrial use in the future, which remains consistent with the industrial criteria used in selection of cleanup goals for the Site. I EP A has also taken steps to limit the potential for exposure to contaminated Site ground water while ground water treatment pilot testing activities are completed. In September 2008, EPA Region 4 and the Southwest Florida Water Management District (SWFWMD) I entered into a Memorandum of Agreement regarding Site ground water. Per the agreement, EPA provides SWFWMD with infonnation regarding the area of ground water impacted, or potentially impacted, by the Site, and SWFWMD acts as the I regulatory authority to implement and enforce ground water use restrictions at and near

I 29 I

I I the Site. The ground water area impacted by the Site is designated as Zone A, marking

the contamination zone, and Zone B, marking a buffer area surrounding Zone A. The

I agreement stipulates that EPA must conduct a well survey of Zones A and B at least once every five years to identify any new wells constructed or operating since the previous survey. EPA remedial project manager (RPM) Galo Jackson conducted the tirst well

I survey concurrently with the FYR Site inspection and identified two wells (Figure 2). One well was located along East 9lh A venue on the EQ Florida property in Zone A. The second well was located along East 7lh Avenue on the R&L Metals property in Zone B.

I SWFWMO was notified of these wells in September 2010. The well in Zone A is currently.pennitted for industrial use by EQ Florida and the well in Zone B has been plugged and abandoned on the R&L Metals property.

I SWFWMO has the authority to impose reasonable conditions necessary to protect the applicable water source and to prevent the spread of ground or surface water

I contamination. For well construction penn its, such conditions include: prohibiting use of the well as a potable water supply, requiring notice to well owners of potential ground water contamination or requiring specific methods of construction. Under Florida

I Administrative Code (FAC) Rule 400-3.505(3), SWFWMO will deny an application for

I a well construction pemlit for activity in Zone A ifuse of the well would increase the potential for hann to public health, safety and welfare,.or if the proposed well would degrade the water quality of the aquifer by causing pollutants to spread.

I I I I I I I I I I 30

I I6.0 Five-Year Review Process

6.1 Administrative Components I EPA Region 4 initiated the FYR in May 2010 and scheduled its completion for January 2011. The EPA site review team was led by EPA RPM Galo Jackson and also included IEPA site attorney Kevin Beswick, EPA Community Involvement Coordinator (CIC) L'Tonya Spencer, and contractor support provided to EPA by Christy Fielden and Sabrina Foster ofF Inc. In May 2010, EPA held a scoping call with the review team to Idiscuss the Site and items of interest as they related to the protectiveness of the remedy currently in place. A review schedule was established that consisted of the following activities: I

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

I6.2 Community Involvement

In January 20 II, a public notice was published in the Tampa Tribune announcing the commencement of the FYR process for the Site, providing contact information for RPM I Galo Jackson and CIC L'Tonya Spencer and inviting community participation was published. The press notice is available in Appendix B. The FYR report will be made Iavailable to the public once it has been finalized. Copies of this document will be placed in the designated site repository: University of South Florida Library, located at 4202 East Fowler Avenue, Tampa, Florida 33620. Upon completion of the FYR, a public Inotice will be placed in the Tampa Tribune to announce the availability of the final FYR report in the Site's document repository.

I6.3 Document Review

This FYR included a review of relevant, site-related documents including the ROD, Iremedial action reports and recent monitoring data. A complete list of the documents reviewed can be found in Appendix A.

IARARs Review

Section 121 (d)(2)(A) of CERCLA specifies that Superfund remedial actions must meet Iany federal standards, requirements, criteria or limitations that are detennined to be applicable or relevant and appropriate requirements (ARARs). ARARs are those standards, criteria or limitations promulgated under federal or state law that specifically Iaddress a hazardous substance, pollutant, contaminant, remedial action, location or other circumstance at a CERCLA site. To-Be-Considered criteria (TBCs) are non-promulgated

I 31

I

I I advisories and guidance that are not legally binding, but should be considered in

detennining the necessary level of cleanup for protection of human health or the

I environment. While TBCs do not have the status ofARARs, EPA's approach to deternlining ifan RA is protective of human health and the environment involves consideration ofTBCs along with ARARs.

I Chemical-specific ARARs are specific numerical concentration restrictions on individually listed contaminants in specific media. Examples of chemical-specific

I ARARs include the MCls specified under the Safe Drinking Water Act as well as the ambient water quality criteria enumerated under the Clean Water Act. Because there are usually numerous contaminants of potential concern for any Site, various numerical

I quantity requirements can be ARARs. The final remedy selected for this Site was

I designed to meet or exceed all chemical-specific ARARs and meet location- and action­specific ARARs.

Ground Water

I According to the 1996 ROD, cleanup goals for the nine b'Tound water COCs were selected to ensure that remaining ground water concentrations would not exceed the 1 x 10-6 risk level for carcinogens, a Hazard Quotient (HQ) of 1 for non-carcinogens, under I an industrial land use scenario. The cleanup goals for 4.4 '-DDT, endosulfan ] and

I endosulfan II were selected based on health-based criteria. The site-specific health-based cleanup goal for 4,4'-DDT was less stringent than Florida's ground water guidance, and the ROD notes that the cleanup goal may need to be revisited in the future to obtain FDEP's agreement with deletion of the Site from the NPl upon completion of cleanup

I activities.

I I

Cleanup goals for aldrin, alpha-BHC, beta-BHC and dieldrin were based on the Florida Groundwater Guidance Concentration, which is a TBC for the Site. The cleanup goal for total xylene listed in the 1996 ROD was selected based on the State secondary MCl, but was later modified in the 2005 ESD to be consistent with federal and State primary MCls. The cleanup goal for gamma-BHC was selected based on federal and State MCls.

I The ARARs for aldrin, alpha-BHC, beta-BHC and dieldrin were compared to the current Florida Groundwater and Surface Water Contaminant Cleanup Target levels (62 FAC 777), which is the CUITent State guidance on acceptable ground water contaminant

I concentrations (Table 4). The ARARs for all four of these COCs have become more stringent since the signing of the 1996 ROD. The cleanup goals for gamma-BHC and total xylene were compared with National Primary Drinking Water regulations (40 CFR

I 141-143) and FDEP Drinking Water Standards, Monitoring and Reporting Requirements (62 FAC 550.310). The cleanup goals for gamma-BHC and total xylene remain the same as in the 1996 ROD and 2005 ESD, respectively. This review did not find that the

I assumptions used in calculation of the site-specific health-based cleanup goals for 4,4' ­DDT, endosulfan ] and endosulfan II had changed.

I I 32

Table 4: Previous and 2010 ARARs for Ground Water COCs

. Contaminant of Concern ..".~\~ ~:t>i3

1996 ROD ARAR (JlgfL)

2005 ESD ARAR (llglLF

2010ARAR .~.~ .-...:: (llgIL)

ARA,R Cbange ~',\s;: (0";-0;

4,4'-00T O.Y -­ 0.3 None Aldrin O.OSb -­ 0.002" More Stringent Alpha-SHe 0.05" -­ 0.006" More Stringent Seta-SHC 0.1 b -­ 0.02" More Stringent Ganuna-BHC 0.2e -­ 0.2·g None Dieldrin O.lb -­ 0.002e More Stringent Endosulfan I 2<1 -­ 2 None Endosulfan II 2" -­ 2 None T olal xylenes 20" 10,000 10,000 None a.

b. c. d. e.

f

0"'.

Sitt'-specific health-based standard selected Il1 ensure that remaining ground watt'r concentrations would not t'xct't'd the I .\ 10 <, risk Ien'l lor carc inogt'lls, an HQ of I fix Iloll-carcinogt'ns, or the illstl1l1llt'llt quantitation limit undt'r an industrial land use sct'natio. Cleallup gnal ,t'lectt'd bast'd on Fk)rida Groundwater Guidanct' Concentration, which is a TBC for the Site. Cleanup goal seiectt'd based nn federal and Florida MCl,. Cleanup goal selectt'd based 011 Florida secondal)' MCLs. Florida Groundwater and Surlace Water Cleallup Target levels arc available at: hlt[> :.Iiwww.dc[>. stak.ll.us/wast clq u ick tOQicsiruks/docunh:nts/62-777/TablclGround,,·utcrCTls4-1 7-()5.Qdf (accessed 8112120 I 0). A CClmpatison of Florida' s 1999 allli 2005 Groundwater and Surlilce Water Cleanup Target levels is available at: htt[>:l111'11' II' _de[> .stak.Il.usill'astdq uic k t"pies/Qub I icat ions/we/brown lields/CompT,lb It's/Ground wat t'randS u rlile l'WaterC I<"anu))Target L t'vels·Rdf Cun-ent MCls are based on federal (40 CFR 141-143) and state (62 FAC 550.310) drinking water standards. Federal standards are based on National Primary and Secondaty Drinking Water Maximum Contaminant Levds (!!.!J.r>:i/watel'.l·pa.c(l"/drink/cnntumin,tnISiindcx.c rm#lisl, accessed 8112/20 I (I) and state standards are based on Florida State Drinking Water Synthetic Organic Contaminants and their Standards (!illp:l/www.dL'p.stale.ll.u,;iwatcr i drinkingwatcr.'syn CI)n.hllll. accessed 8112/20 10). Gamma-BHC is listed as lindane in federal and state MCLs.

6.4 Data Review

Confln11atory sampling for the 2000 pesticide area removal action and for the 2004 and :W05 sulfur area removal actions was perfonned immediately tollowing the removals. Surface soil and sediment with COC concentrations above industrial use cleanup goals had been etTectively removed, and no further sampling or O&M activities are required for surface soil and sediment.

Ground water pilot test activities currently underway include baseline sampling and four subsequent sampling events for the sulfur area (Table 5) and the xylene area (Table 6), The treatability study sampling events have been implemented as follows:

• Baseline sampling in August 2009; • 60-Day Event sampling in November 2009; • 120-Day Event sampling in January 20 I 0; • l80-Day Event sampling in March 2010; and • 240-Day Event sampling in May 2010

The pilot test is investigating methods for the biological and physical degradation of Site contaminants. Follow-up sampling analyzes various aqueous geochemical parameters in addition to contaminant concentrations, Per the EPA-approved work plan, routine sampling analyses include four of the nine ground water COCs: alpha-BHC, beta-BHC,

33

I I I I I I I I I I I I I I I I I I I

I I gamma-BHC and total xylenes in addition to various other contaminants and break-down

products.

I In both the sulfur area and the xylene area, ground water concentrations of alpha-BHC, beta-BHC and gamma-BHC have predominantly remained consistent with baseline

I sampling levels and largely remain elevated above cleanup goals for the Site. In the sulfur area, total xylene concentrations in ground water, when detected, are well below the cleanup goal of 10,000 j..lg/L. The xylene release at the Site occurred downgradient

I from the fornler sulfur pit, and these low concentrations of xylene are consistent with expectations for this area. In the xylene area, total xylene concentrations are responding to the treatment, showing declines below the cleanup goal in several wells (e.g., X3U,

I X5U, X9U and XII U), but showing increasing concentrations in other wells (e.g., X6D, X7U and X8D). Only data trom-the tirst nine months of the treatability study were available at the time this FYR report was being drafted; detennination of the

I etTectiveness of these treatments must wait until the study has been completed.

I Of the site-related VOCs present in the ground water plume, only xylene and possibly ethylbenzene are present in the surficial aquifer and poses a potential vapor intrusion concern. Remedial contractor EnSafe, Inc. included an updated total xylene plume map

I as Figure 5-5 in the 2009 Pilot Test and Interim Monitoring Work Plan. This figure shows that concentrations at or above the xylene ground \vater cleanup goal are located

I on the Helena Chemical Company property, along the CSX Railroad right-of-way or under the railroad tracks. The few buildings within this plume area are open-sided warehouse structures on the Helena Chemical Company property and thus a vapor intrusion assessment has not been necessary.

I Table 5: Sulfur Area Pilot Test COC Detections in Ground Water to Date

I I I I I I I I 34

Well Sampled

Sampling Event "'0 i4Y<i4Y> ,

COCs and Detected Concentrations (J.lg/L)

AJpha-BHC . ~ .'. ".

Beta-BHC h~+<~

Gamma-BHC Total Xylenes.

(Cleanup Goal) (0.05 J.lg/L) (0.1 J.lg/L) (0.2 J.lg/L) (IO,OOOJ.1g/L)

East PIOI Wells

SETIU

Baseline Event 2JD 3.3 .I 4.3 J /.9/

60-Day Event 31 3.61 6.8 NA 120-Day Event 17 4 4') 0.46/

180-Day EveJ1l 19 2.5 5.7 NA 240-Day Event 24 2.9 5.2 3. I

SET2D

Baseline Event 4.4 0 1.20 1.10 U

60-Day Event 3.9 0.45 0.66 NA 120-Day Event 2.6 0.56 0.44 n.33/

ISO-Day Event 2.6 0.59 0.47 NA 240-Day Event 3.8 0.86 0.7 0.S2

SET3U Baseline Event 22 3 5.5 5.8

60-Day Event 19 41 3.9 I NA

Well Sampled

~ •• " .:... •• ~. ~ •• y

Sampling Event

Xf,): COCs and Detected Concentrations (Ilg/L) ... .. ()i;'

Alpha-BHC Be·ta~BHC Gamma-BHC Total Xylenes

(Cleanup Goal) (0.05 ~lg/L) (0.1 Ilg/L) (0.21lg/L) (IO,OOOllg/L)

120-Day Event 17 3.3 4.4 8.6

180-Day Event 17 2 I 3.4 I NA 240-Day Event 28 3 5.7 7

SET4D

--

Baseline Event 4.1 D 0.611 0.741 1.71

60-Day Event 6.2 1.5 0.S7 NA

120-Day Event 3.7 0.94 I.2 1.1 1

180-Day Event 3 0.461 0.461 NA

240-Day Event 3.7 - 0.68 - _. 0.52 0.36

SET5U

Baseline Event 21 D 3.6 3.9 6.4

60-Day Event 17 41 3.71 NA

120-Day Event 13 4.7 3.1 3

180-Day Event 26 4 5.1 NA

240-Day Event 34 6.1 4.8 3.9

SET6D

Baseline Event 9.7 D 1.2 1.1 2.5

60-Day Event 4.6 1.2 0.82 I NA

120-Day Event 4.4 0.95 0.5 7.6

180-Day Event 2.8 0.781 0.4 1 NA

240-Day Event 6.3 0.75 0.43 5.6

SET7U

Baseline Event 12 1.3 3.2 ::.1

60-Day Event 14 1.61 2.7 NA

120-Day Event II 1.3 2.8 3.5

180-Day Event II 1.5 2.3 NA

240-Day Event 14 1.5 2.8 1.5

SETSD

Baseline Event 4.7 0.S7 I U

60-Day Event 3.6 0.73 1.4 NA

120-Day Event 3.2 0.64 I.l 3.3

ISO-Day Event 3.9 O.S 1 I I NA

240-Day Event 4.7 0.76 0.95 1.7

H'es! Plot Wells

SWTIU

Baseline Event 1.9 IJ 0.631 U U

60-Day Event 0.99 0.53 0.32 NA

120-Day Event 1.4 0.52 0.38 U

I SO-Day Event 1.3 0.6 0.3 NA

240-Day Event 2.2 0.75 0.59 U

SWT2D

Baseline Event 0.481 0.23 J U 0.441

60-Day Event U U U NA

120-Day Event U U U 0.71

180-Day Event 0.031 0.14 0.00941 NA

35

I I I I I I I I I I I I I I I I I I I

I I I I I I I I I I I I I I I I I I I 36

Well Sampled

0.

, <-"L

Sampling Event COCs and Detected Conc/entrations (J1g/L)

Alpha-BHC Beta-BHC Gamrh~-BHC Total Xyleues

(Cleanup Goal) (0.05 ~lg/L) (0.] ~lg/L) (0.2 J1g/L) (] 0,000 J1g/L)

240-Day Event U U U U

swnu

Baseline Event 0.75 ] 0.21 J U 2

60-Day Event 1.8 0.79 0.29 NA 120-Day Event 1.3 0.35 0.084 U

n~O-Day Event 1.4 0.33 0.19 NA

240-Day Event ") ..,-.­ 0.47 0.22 0.69

SWT4D

Baseline Event 0.73 0.36 U U

60-Day Event 0.18 . -­ - 0.094 0.12 NA

120-Day Event U U 0.11 U

180-Day Event U U 0.12 NA

240-Day Event U U U U

SWT5U

Baseline Event 5.1 2.6 2.4 72

60-Day Event U 2.3 2.4 NA

120-Day Event 1.6 0.93 0.8 73

ISO-Day Event 4.1 0.12 I 0.52 NA

240-Day Event 1.8 0.36 U 60

SWT6D

Baseline Event 0.37 J 0.29 J U 3.6

60-Day Event 0.73 0.33 0.031 I NA 120-Day Event 0.56 0.22 U U

I80-Day Event 0.57 U U NA

240-Day Event 0.61 0.26 U U

SWT7U

Baseline Event 0.39 0.3 U U

60-Day Event 0.29 0.39 U NA

I20-Day Event 0.45 0.47 U U

ISO-Day Event 0.59 0.57 U NA

240-Day Event 0.73 0.51 U U

SWT8D

Baseline Event 0.28 U U 9.2

60-Day Event 0.2 0.13 0.0171 NA

120-Day Event 0.15 0.11 0.021 J U

ISO-Day Event 0.16 U U NA 240-Day Event 0.11 0.056 U U

D: value reponed li·om second dilution. I: estimatcd "alu.:' below reponing limit. J: estimated value. NA: not analyzed. U: undetected. ftalies: COC was detected but concentration was below cleanup goal.

-- -

I ITable 6: Xylene Area Pilot Test COC Detections in Ground Water to Date

<4":\ .. " COCs and Detected Conce~trations (,lg/L) :Y'h:'::.

IQ. Well Sampled

Sampling Event Alpha-BHC Beta-BHC Gamma-BHC Total Xylene

., (Cleanup Goal) (0.05 Ilg/L) (0.1 Ilg/L) (0.2 'lg/L) .<10,000 Ilg/L)

Baseline Event SO 1.90 U 200

60-0ay Event NA NA NA 13

XIU 120-0ay Event NA NA NA 1/

ISO-Day Event 5.6 1.31 U ., , ~.J

240-0ay Event NA NA NA 29

Baseline Event 7.1 1.7 . - 0.71 I ­ 180

60-0ay Event NA NA NA 56

X20 120-0ay Event NA NA NA 54

ISO-Day Event 5.81 1.7 1 1.4 1 150

240-0ay Event NA NA NA 42

Baseline Event 150 31 0.461 23000

60-0ay Event NA NA NA 11000

X3U 120-0ay Event NA NA NA 13000

180-Day Event 15 3.6 ·0.56 1400

240-Day Event NA NA NA 4500

Baseline Event 12 D 1.3 J 4.2 J 19000

60-Day Event NA NA NA 12000

X4D 120-Day Event NA NA NA 19000

180-Day Event 23 1.31 8.2 22000

240-Day Event NA NA NA 15000

Baseline Event 7.S 0 0.93 ID U 18000

60-Day Event NA NA NA 21000

X5U 120-Day Event NA NA NA 20000

180-Day Event 4.4 J 0.8 J 0.1 J 3200

240-Day Event NA NA NA 13000

Baseline Event 5.2 D 0.91 ID 3.8 D 3000

60-Day Event NA NA NA 1100

X6D 120-Day Event NA NA NA 6000

ISO-Day Event 2.S J 0.7 J 2 J 40000

240-Day Event NA NA NA 3000

Baseline Event 6.1 D I.2D U 24000

60-Day Event NA NA NA 31000

X7U 120-Day Event NA NA NA 37000

180-Day Event 4.6 0.S9 U 81000

240-0ay Event NA NA NA 34000

I I I I I I I I I I I I I I I I

37 I

I I I I I I I I I I I I I I

Well Sampled

Sampling Event

COCs and Detected Concentrations (llg/L)

A1pha-BHC Beta-BUC Gamma-BHC Total Xylene

(Cleanup Goal) (0.05Ilg/L) (0.1 Ilg/L) (0.2Ilg/L) (10,000 ,'giL)

X8D

Baseline Event 5.7 1.4 1.2 960

60-Day Event NA NA NA 7100

120-Day Event NA NA NA 27000

180-Day Event 2.1 J 0.18 1J 0.57 IJ 19000

240-Day Event NA NA NA 5700

X9U

Baseline Event 3.9 0.21 I 0.25 I 22000

60-Day Event NA NA NA 14000

120-Day Event NA - NA NA 35000

180-Day Event 5.3 0.26 J 0.17 J 2700

240-Day Event NA NA NA 950

XIOD

Baseline Event 4.3 0.49 4.5 770

60-Day Event NA NA NA 260

120-Day Event NA NA NA 780

180-Day Event 5.9 0.61 I 7 760

240-Day Event NA NA NA 540

XI1U

Baseline Event 8.1 0.97 U 14000

60-Day Event NA NA NA 3800

120-Day Event NA NA NA 1600

180-Day Event 4.9 0.75 I U 600

240-Day Event NA NA NA 11000

XI2D

Baseline Event 3.9 0.641 1.6 4900

60-Day Event NA NA NA 250

120-Day Event NA NA NA 1100

ISO-Day Event 5.6 0.93 ID 3.4 5800

240-Day Event NA NA NA 9300 D: value reponed from second dilution. 1: estimated value below reponing limit. J: estimated value. NA: not analyzcLi. U: m't applicable. Italics: cae was detected but concentration was below cleanup goal.

I I I I I 38

I I6.5 Site Inspection

On July 8, 20 I 0, the site inspection was perfomled by the following participants: Galo IJackson of EPA Region 4, Edward Brister of the Helena Chemical Company, and Christy Fielden and Sabrina Foster of E2 Inc. The completed Site inspection checklist is available in Appendix D. Photographs were taken of site features, including monitoring wells and Iaccess controls (Appendix E).

The Site has been in continuous.operation since 1929 as an agricultural chemical Imanufacturing and distributing facility. The bulk of chemical fonnulation activities have been moved off-site to a ditTerent Helena Chemical Company facility in Georgia; however, some fonnulation and packaging of insecticidal spray oil and liquid fel1ilizers Istill occur at the Site. The Site also serves as Helena Chemical Company's main­distribution warehouse for sales locations in the State of Florida.

IThe Site inspection was led by Mr. Ed Brister, the Engineering, Safety, Health and Environment Director for the Helena Chemical Company, who provided a tour of the full Helena Chemical Company property indicating where remedial actions had been Iimplemented and explaining the locations and associated activities of current pilot testing for the ground water treatability study. Several monitoring and injection wells were located during the Site inspection; all active site wells were properly secured or had been I appropriately abandoned. Injection and monitoring wells for the adjacent Alaric Site were noted on the Helena Woods area of the Site, but were not inspected since they are related to a different site. The Site is well maintained and has a secure perimeter fence and clear I signage in place. Unauthorized persons are restricted from accessing the property outside of regular business hours.

I Evaluation and implementation of institutional controls were discussed during the Site inspection. Several interim institutional controls have been implemented for the Site and final institutional controls, including land use restrictions, will be evaluated and I implemented, if necessary, once the current pilot-scale ground water remedy treatability study has concluded and a revised ground water remedy has been selected. Zoning designations and the Helena Chemical Company's intention to continue operations at the I Site for the foreseeable future limit the potential for inappropriate land uses or on-site operations incompatible with remedy components in place. EPA has also implemented ground water institutional controls through a Memorandum of Agreement with I SWFWMD.

On July 7, 2010, E2 Inc. staff conducted research regarding Site deed infonnation at the I Hillsborough County Deed Records Office. The approximately eight-acre Site is situated on four parcels ofland: 1) 6.S-acre Parcel #A-14-29-19-4CA-000000-00022.0; 2) 0.88­acre Parcel #A-14-29-19-4CA-000000-00032.0; 3) O.92-acre Parcel #A-14-29-19-4CA- I 000000-00033.0; and 4) 0.17-acre Parcel #A-14-29-19-4CE-000003-0000 1.0 (Figure 4).

Deed records for the four parcels could not be located in the online database or microfilm collection at the deeds office. Galo Jackson, EPA RPM for the Site, was infonned that the I deeds could not be located and conducted a title search for the property through EPA

I 39

I

I I databases, but was also unable to locate deed records. According to the Hillsborough

County Property Appraiser's Office, all four parcels are presently owned by Helena

I Chemical Company. The active chemical distribution warehouse is located on Parcel #A­14-29-19-4CA-000000-00022.0.

I On July 8,2010, E2 Inc. statTvisited the designated local Site repository at the University of South Florida Library, located at 4202 East Fowler Avenue, Tampa, Florida 33620, as part of the site inspection. The site repository contained fourteen volumes of

I administrative documents and other infonnation pertaining to the Site. This infomlation included documentation of the initial remedial investigation and feasibility study, as well as a copy of the 1996 ROD. The 2005 ESD and 2006 FYR could not be located at the

I time of the Site inspection, but were provided to the library by RPM Galo Jackson on January 21,2011

I The 1996 ROD called for institutional controls to be put in place as part of both the soil and sediment remedy and the ground water remedy (Table 7). According to the ROD, soil and sediment institutional controls were to include deed restrictions. Fencing was to

I provide an engineering control. The Site is presently surrounded by a secured perimeter

I fence and access gates are locked outside of nonnal business hours. The operating facility parcel is currently zoned as light industrial and the Helena Woods parcels are zoned as vacant land and a mobile home park. The local Planning Commission anticipates

I rezoning all four parcels for heavy industrial use. The future anticipated land use is consistent with the industrial exposure criteria used in the selection of Site cleanup goals. The ROD also called for deed restrictions to restrict the use of site-impacted ground

I water on and otT the Site in order to limit exposure to contaminated ground water until cleanup goals are achieved. EPA and FDEP are in discussions regarding the restrictive covenant, in order to prevent future exposure to Site soil. A 2008 Memorandum of Agreement between EPA Region 4 and SWFWMD addresses the need to restrict the use

I of site-related ground water. The agreement establishes regular communication between the two agencies and affinns SWFWMD's regulatory authority to implement and enforce ground water use restrictions at the Site. This authority addresses well construction

I pemlits, restrictions on use of wells for potable water supply, and requirements that well

I owners be notified of ground water contamination that may impact their wells. At the request of the FDEP, once the treatability study is completed and a revised ground water remedy for the Site has been selected, the need for additional ground water institutional controls will be reevaluated and the existing institutional controls will be modified or new institutional controls will be implemented, as appropriate.

I I I I I 40

I IFigure 4: Site Parcel Map

r

I.bot V r~f' 10

" I r G

.. N

Legend

D Site Parcels ApplO1OO111le 80 ndar)' of Su rfiICilJl Aqy]fer Ground Wltsr me

/4rl.~JU1 ~t"'~'ff:t

A t~ 1911l ~o.<XlOOOO 0001 ()

• t. Z$19 'CA¢CInlO DOOno

'" 1"29 1' ;:t<a)'JJ7 tKI:IO l l ~,~ U.fl~l ,IQJ,' 1):01, " f4,.l.-}{f, 1o.a<:J ,0€J:Ucr>WCu.i.1 ~ 1< 22<11 AU. _ ooo:u 0

• l' 2' l ' 6(;1·OOOOOHIOOO:.O "1"'~19-"(~·o::rnc. n

I to,UUDISO

.... 1.29 111.((:[ <lCOO!6 000Xl1

A :_ 2~ I' m OOIIOOS 1861D.0

{4...1" ..""

• 1 '·l!'-I'''C''-<lCOC»)·OOOI~ Q

J\'iIIlql~l OR: HlCJ'XJl n

10.1 Pn"l tO Il "'"IA ·)9..IQ.... 1 OIl­r' a

"14 &19 CE'_;<:OO~ 10 H ""'~·11 .·ucrOO· 0<

" 1',;19. ~""c.o_'.CJOO~ a u 10 U 2t 19 «9 000001 07.0

" U'~I"4C8 ooooo:HlOIlOU W "1'·191"OCf,·~2GI

X ..... 1 ~·1.. ,~.A l.KDn )lIn, Al' 2t IJI ...C£ OOOOO:-OOOou A 14 2!l19 4CI 00000: OOOOlG

.... " l' 2:!-1! Ie>: _7__~C oW A1-4~''' ·''\l I~''·.(IlfI10

.u: A 1 21 1HCA ooooOlHlOO13.3 os A U'~~'19'-CCA-~-00022 AI ... .... 14 I~- q-'l(""tr;f"m ., U Q

....,.·H l r.-m-_la;OO.~ AI .. ,

:.'" 19 2 AU. ~ OOOUl.O la'2!' J4 iCA-OCQOOO-00l20 C:

I\IC Ir l~ 191~ .CE«QOO'1~:J

AI .....' .. 1'1 .. ·.1 t lJIJUf; IOH.'tWl 1

OM • 1. 29-1t-K.J. ~:Q.1 . tl .. 1~ 2!l 19 C[ 0C'000'l 0000 1 1

ACJ

•• A-Id 19· '·4«( -IY.OOOJ·OOOO20 ,. .....1O 'q....t(A-(~ 120

1.111>0< "lI'n' ID IoQ A 14.j't. l (A.u;c.r.u'-PlltI.ll 1

No. .....J~ l' IKJ ~~.O

AS ~ I' 2!l1' lOIlOOII2 ::coal.l AT "'1"1~1~[~H'CKI(I7 CJ HJ " l-4-J" 'l~1

.." "'II I;;< 61& ;e. l"CC~ 000Il3.o

". If 1~ 29- D-trA-OOOOOO·f)0J2l1 0

IoJ _ 1.. ·l9-1....'MI.QU.'1.I·&.'IU1

..... ' tL~ U. tl.'O'XO OOOls.o !!II • 1< 22< 19.U. OOOOC<) ooot. I

rn Parcels

:: : ~ Site Boundlr}' AWIOXlm81e BoundSI)' oflnterm te qu" r Syslern Gro.lnd water Plume

r/ I () I Fig re 4 Helena Chemical Company Superfund Site ~ Parcels Map Tampa, Hillsborough County, Florida

I I I I I I I I I I I I I I I

Di claimer: 1111S map and any boundary lines within the map are approximate and subject to change. The map i not a urvey. The map is for infonnational purposes only regarding EPA's response actions at the Site, and is not intended for any other purpose.

I 41 I

I I Table 7: Institutional Control (lC) Summary Table

I I I I I I I I I I I I I I I

Media ICs Needed .. ; .... : -:

.,:,-.

ICs Called for in the Decision Documents

IC Objective

Instrument in Place ,/ ".

Ground Water Yes

_.­ --

Yes

--

Restrict use of contaminated ground water to limit exposure until cleanup goals are achieved.

The 1996 ROD called for deed notices as the institutional control instrument. These have not been implemented. However, a 2008 Memorandum of Agreement between EPA and SWFWMD contim1s SWFWMO's regulatory authority to restrict well construction, restrict well use as a potable water source and requiring that well owners be.notified of ground water contamination that may impact their wells. This authority applies to on-site parcels as well as off-site parcels, covering the entire area affected by site-related ground water contamination.

Soil and Sediment

Yes Yes Restrict land uses to industrial or similar.

The land use restrictions called for in the 1996 ROD have not been implemented; however, Helena Chemical Company has maintained operations at the Site throughout remedial activities and intends to continue Site operations for the foreseeable future. A restrictive covenant will be placed on the Site to ensure the Site is only used for industrial purposes. The operating facility parcel is presently zoned for light industrial use and all four parcels will soon be rezoned for heavy industrial use, which is consistent with the industrial exposure criteria used in selecting cleanup goals for the Site. ; A secure perimeter fence* restricts access to the Site, limiting the potential for inadvertent soil exposure.

*The 1996 ROD also listed fencing as an institutional control for soil and sediment source control; however, this has not been included above because it is considered an engineering control.

I I 42

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I I6.6 Interviews

During the FYR process, interviews were conducted with parties impacted by the Site, Iincluding the current landowners, and regulatory agencies involved in Site activities or aware of the Site. The purpose of the interviews was to document the perceived status of the Site and any perceived problems or successes with the phases of the remedy that have Ibeen implemented to date. Interviews with Mr. Jackson and Mr. Brister were conducted during the site inspection on July 8, 2010. Interviews with Ms. Milicic and Ms. Yeargan were conducted via e-mail on August 23,2010 and September 27,2010, respectively. ISeveral nearby businesses were also contacted, but declined or did not have interest in being interviewed about the Site. Interviews are summarized below and complete interviews are included in Appendix C. I Galo Jackson: Mr. Jackson is the EPA RPM for the Site. Mr. Jackson indicates that a pilot-scale treatability study for site ground water is presently underway. Results are Ibeing routinely shared with EPA and FDEP, while there have been many challenges and it is still too early to detemline whether the treatments being explored can effectively address ground water contamination, he is hopeful that the treatments will be successful. IHe has not received any complaints or inquiries from the community in the past five years and is not aware of any etTects the Site may have had on the surrounding community. He is pleased with the regular updates and infonnation he receives from the I remedial contractor, EnSafe Inc.

Edward Brister: Mr. Brister is the Engineering, Safety, Health and Environment Director I for the Helena Chemical Company. Mr. Brister indicates that he is pleased with progress at the Site and believes that the remedial activities taken to date are perfomling successfully. He feels well infonned about activities and progress at the Site. He does not I know of any etTects that the Site has had on the surrounding community beyond the potential for Superfund stigma, which is common at many similar sites. Mr. Brister indicates that there is one residence in the area of the Site and that the owners, a couple, I had expressed concems to him in the past. He notes that the couple was temporarily relocated during removal activities in 2000 and again during sulfur area removal actions in 2004 and 2005. Other than his discussions with the couple who were temporarily I relocated, he has not heard any complaints or concems from the community regarding the Site. I Karen Milicic: Ms. Milicic is the FDEP project manager for the Site. Ms. Milicic thinks that activities at the Site are making progress in addressing site COCs. She is aware of the treatability study work that is presently underway and feels very well infonned regarding I progress at the Site. She believes that it is still too early to comment on the etTectiveness of the current treatments being explored for ground water at the Site as the treatability study has not yet concluded. She is not aware of any complaints or inquiries regarding the I Site over the last five years.

IMary Yeargan: Ms. Yeargan is the Environmental Protection Commission of Hillsborough County project manager for the Site. Ms. Yeargan has been involved at the

I 43

I

I I Site for many years and participated in the previous 2006 FYR site inspection. She

indicates that the Site is situated in an area that is impacted by multiple Superfund sites as

I well as other facilities that contribute to blight in the area. She acknowledges that the Site may contribute to some more general community concerns about the presence of Superfund sites in the area, but she does not think that the Site specifically has been the

I source of concern within the larger area. Since the 2006 FYR, Ms. Yeargan has received one complaint about potential ground water contamination that a community member thought may have resulted from one of the area Superfund sites. The well was tested by

I the Department of Public Health; contamination was not detected in the sampling and the well was found to be safe for continued use. She is not aware of any changes in laws or land use in the area that would impact the Site. Given the shortage of lands available for

I heavy industrial uses, she thinks it would be unlikely for the zoning of the parcels that compose the Site-to be changed to anything other than heavy industriaL-She feels welL infomled about site activities and remains in regular communication, as needed, with

I EPA RPM Galo Jackson.

I I I I I I I I I I I I 44

I I7.0 Technical Assessment

7.1 Question A: Is the remedy functioning as intended by the decision documents? I The review of documents, ARARs, risk assumptions and the Site inspection indicate that the Site's soil remedy is functioning as intended by Site decision do~uments for soil and Isediment. Pesticide-contaminated surface soil and sediment at the Site and the adjacent CSX railway line east drainage ditch were excavated and shipped off site for biological treatment and disposal. Contaminated soil and residual sulfur were also excavated and Ishipped off site for disposal. Since there is commingling of the Site's ground water plumes with those of the adjacent Alaric Site, the pump-and-treat ground water remedy selected in the 1996 ROD may not cunently be appropriate to implement at the Site, until I

- -the Alaric Site's plumes have been remediated. Helena-Chemical Company proposed a pilot-scale treatability study to evaluate the feasibility of biological and physical ground water contaminant degradation. The Work Plan for this treatability study was approved I by EPA in August 2009. The study is cunently underway and was scheduled to conclude by the fourth quarter of 20 I 0, with a contingency period of another 12 months, if necessary. A final report documenting the effectiveness of the first full year of the I treatability study was not available at the time this FYR report was drafted; therefore, a decision regarding whether to implement the additional 12 month contingency period had also not been made. The final results of the treatability study will be used to infonn the I selection of a revised ground water remedy for the Site. In the event that the treatability study is not successful, EPA may consider additional avenues to approach remediation, including additional excavation. I The 1996 ROD selected the implementation of institutional controls in the form of deed restrictions for soil, sediment and ground water to limit exposure to site-related I contamination. Fencing was also required by the 1996 ROD. Land use restrictions have not been implemented for the Site; however, some interim institutional controls to protect against exposure to ground water contamination have been implemented. Helena I Chemical Company intends to continue Site operations for the foreseeable future and has no intention to sell, lease or transfer any portion of the Site. Cunent and future zoning designations are consistent with the industrial land use criteria used in selection of Site I COC cleanup goals. In 2008, EPA entered into a Memorandum of Agreement with the SWFWMD. The document confirms SWFWMD's regulatory authority to place restrictions on well placement and construction. Through shared intom1ation between the I two agencies, SWFWMD can make infom1ed pennitting and enforcement decisions to prevent exposure to ground water contamination that could pose a risk to human health. No impacted ground water wells are used for potable water; buildings at the Site and in I the sunounding area are connected to municipal water supply lines. The need for additional institutional controls will be evaluated upon selection of a revised ground water remedy tor the Site.· I The Site is well-maintained and is sunounded by a secured perimeter fence with signs restricting access. Access is liniited to authorized persons during regular business hours. I

I 45

I

I I All site-related wells are secured or, if no longer operational, have been properly

abandoned.

I 7.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid?

I The ARARs for four of the nine ground water COCs, aldrin, alpha-SHC, beta-BHC and dieldrin, have become more stringent since the signing of the 1996 ROD. During the

I current ground water treatability study, both alpha-SHC and beta-SHC have been detected at levels greater than the ROD's less stringent cleanup goals for these COCs. Remedial activities at the Site have allowed the continued industrial use of the property

I and have reduced ecological risk at the Site. The selection of a revised ground water remedy is required before achieving the remaining two RAOs: 1) protection of ground water from continued degradation by Site contaminants and 2) reduction of risk to human

I health within EPA's acceptable risk range. Residual soil contamination remains present below the water table and the ground water plume continues to exceed cleanup goals. The industrial land use at the Site and in the surrounding area is unchanged since the ROD

I was signed; therefore, the exposure assumptions are still valid. Benzene and ethylbenzene are being detected in the groundwater at concentrations above the primary drinking-water standards.

I I

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

I No other infom1ation has come to light that could call into question the protectiveness of the remedy.

7.4 Technical Assessment Summary

I The review of documents, ARARs, risk assumptions and the Site inspection indicate that

I the Site's soil remedy is functioning as intended by Site decision documents for soil and sediment. Pesticide-contaminated surface soil and sediment at the Site and the adjacent CSX railway line east drainage ditch were excavated and shipped off site for biological treatment and disposal. Contaminated soil and residual sulfur were also excavated and

I shipped off-site for disposal. Since there is commingling of the Site's ground water

I plumes with those of the adjacent Alaric Site, the pump-and-treat ground water remedy selected in the 1996 ROD may not currently be appropriate to implement at the Site, until the Alaric Site's plumes have been remediated. Helena Chemical Company proposed a

I pilot-scale treatability study to evaluate the feasibility of biological and physical ground water contaminant degradation. The work plan for this treatability study was approved by EPA in August 1009. The study is currently underway and was scheduled to conclude by

I the fourth quarter of201 0, with a contingency period of another 12 months, if necessary. A tinal report documenting the effectiveness of the first full year of the treatability study was not available at the time this FYR report was drafted; therefore, a decision regarding whether to implement the additional 11 month contingency period had also not been made. The tinal results of the treatability study will be used to infonn the selection of a

I I 46

I Irevised ground water remedy for the Site. In the event that the treatability study is not

successful, EPA may consider additional avenues to approach remediation, including additional excavation. I The ARARs for four of the nine ground water COCs, aldrin, alpha-BHC, beta-BHC and dieldrin, have become more stringent since the signing of the 1996 ROD. During the current ground water treatability study, both alpha-BHC and beta-BHC have been I detected at levels greater than the cUlTent, less-stringent cleanup goal for these COCs. Remedial activities at the Site have allowed the continued industrial use of the property Iand have reduced ecological risk at the Site. The selection of a revised ground water remedy is required before achieving the remaining two RAOs: 1) protection of ground water from continued degradation by Site contaminants, and 2) reduction of risk to I-human health within EPA's acceptable risk range. Residual soil contamination remains present below the water table and the ground water plume continues to exceed cleanup goals. The industrial land use at the Site and in the surrounding area has not changed Isince the ROD was signed; therefore, the exposure assumptions are still valid.

The 1996 ROD selected the implementation of institutional controls in the foml of deed Irestrictions for soil, sediment and ground water to liinit exposure to site-related contamination. Fencing was also required by the 1996 ROD. Land use restrictions have not been implemented for the Site; however, some interim institutional controls to protect Iagainst exposure to ground water contamination have been implemented. Helena Chemical Company intends to continue Site operations for the foreseeable future and has no intention to sell, lease or transfer any portion of the Site. Current and future zoning Idesignations are consistent with the industrial land use criteria used in selection of site COC cleanup goals. In 2008, EPA entered into a Memorandum of Agreement with the SWFWMD. The document confinns SWFWMD's regulatory authority to place Irestrictions on well placement and construction. Through shared infonnation between the two agencies, SWFWMD can make infonned pemlitting and enforcement decisions to prevent exposure to ground water contamination that could pose a risk to human health. I No impacted ground water wells are used for potable water; buildings at the Site and in the surrounding area are connected to municipal water supply lines. The need for additional institutional controls will be evaluated upon selection of a revised ground I water remedy for the Site.

The Site is well-maintained and is surrounded by a secured pelimeter fence with signs I restricting access. Access is limited to authorized persons during regular business hours. All site-related wells have been secured or, if no longer operational, have been properly abandoned. I

I I I

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I I 8.0 Issues

I Table 8 summarizes the current site issues.

Table 8: Current Site Issues

I Affects Current

I Affects Future

Issue Protectiveness Protectiveness (Yes or No) (Yes or No)

A revised ground water remedy for the Site has not been selected or implemented and sampling events

I No Yescontinue to detect cae concentrations in ground water that are greater than cleanup goals.

. ­La-nd use restrictions for the Site have not yet been

No Yes

I implemented.

I I I I I I I I I I ,

I I 48

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I I9.0 Recommendations and Follow-up Actions

Table 9 provides recommendations to address the current site issues. I Table 9: Recommendations to Address Current Site Issues

Issue

, ....

·Recommendations/ Follow-Up Actions

Party Responsible

Oversight Agency

Milestone Date

;Affects Protectiveness?

(Yes or No) Current Future

A revised ground­water remedy for the Site has not been selected or ­implemented and sampling events continue to detect COC concentrations in ground water that are greater than cleanup goals.

- At the conclusion of the current pilot study, evaluate results and, if appropriate, document the selection of a revised ground water remedy for the Site.

PRP EPA

-.- -­

0113112012 No Yes

Land use restrictions for the Site have not yet been implemented.

A restrictive covenant will be concluded, designed to ensure the Site remains industrial.

PRP EPA 01131/2012 No Yes

I I I I I I I I I I I I I I I

49 I

I I 10.0 Protectiveness Statements

I The Site's remedy currently protects human health and the environment in the short-tenn because it is functioning as intended by the Site's decision documents for soil and sediment. Source materials have been excavated and removed for off-site treatment and disposal. The

I selected ground water remedy has not yet been implemented due to concems with promoting migration of the ground water plume from the neighboring Alaric Site. A pilot-scale bioremediation treatability study is underway and will hopefully aid in the selection of a revised

I ground water remedy for the Site. The affected surficial aquifer in the vicinity of the Site is not used for potable water supply and area residents and businesses are connected to municipal water supply. In order for the remedy to be protective in the long-teIl11, issues conceming

I implementation of a revised ground water remedy and institutional controls should be addressed.

I I I I I I I I I I I I I 50

I I11.0 Next Review

This Site is a statutory Site that requires ongoing FYRs as long as waste is left on site that does Inot allow for unrestricted use and unlimited exposure. The next FYR will be due within five years of the signature/approval date of this FYR.

I I I I I I I I I I I I I I I

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I

I I Appendix A: List of Documents Reviewed

I CERCLA Infonnation System Site Infoll11ation accessed from website http://cfpub.epa.gov/supercpad/cursites/csitinfo.cfm?id=0400674. Accessed May 12, 2010.

I EPA Record of Decision: Helena Chemical Co. (Tampa Plant) EPA 10: FLD053502696. Prepared by u.S. EPA Region 4. May 7, 1996.

I Explanation of Significant Differences. Helena Chemical Superfund Site, Tampa, Hillsborough County, FL. Prepared by u.S. EPA Region 4. January 27,2005.

I First Five-Year Review Report for Helena Chemical Company, Tampa, Hillsborough County, Florida. Prepared by EnSafe Inc. for u.S. EPA Region 4. January 31,2006.

I First Quarter 2010 Pilot Test Implementation Report, Helena Chemical Company, Tampa, Florida. Prepared by EnSafe Inc. for Helena Chemical Company. July 7, 2010.

I Fourth Quarter 2009 Pilot Test Implementation Report, Helena Chemical Company, Tampa, Florida. Prepared by EnSafe Inc. for Helena Chemical Company. March 12,2010.

I Memorandum of Agreement between the U.S. Environmental Protection Agency, Region 4, Superfund Division and the Southwest Florida Water Management District. September 11,2008.

I Pilot Test and Interim Monitoring Work Plan for the Helena Chemical Company Superfund Site, Tampa, Florida. Prepared by EnSafe Inc. for Helena Chemical Company. June 30, 2009.

I Pilot Test Implementation Report, Helena Chemical Company, Tampa, Florida. Prepared by EnSafe Inc. for Helena Chemical Company. December 22,2009.

I Second Quarter 2010 Pilot Test Implementation RepOli, Helena Chemical Company, Tampa, Florida. Prepared by EnSafe Inc. for Helena Chemical Company. September 23, 20 IO.

I Third Quarter 2009 Pilot Test Implementation Report, Helena Chemical Company, Tampa, Florida. Prepared by EnSafe Inc. for Helena Chemical Company. December 22,2009.

I I I I I I A-I

Appendix B: Press Notice I I I

U. S. Environmental Protection Agency, Region 4 Announces a Five-Year Review for I

the Helena Chemical Company Superfund Site, Tampa, Hillsborough County, Florida I

Purpose/Objective: The U.S. Environmental Protection Agency (EPA) is conducting a Five-Year Review of the remedy for the Helena Chemical Company Superfuild site (Site) in Tampa, Florida. The purpose of the Five-Year Review is to ensure thnt the selected cleanup actions effectively protect human health and the environment. I Site-Background: The Site covers approximately eight acres and is located in the Orient Park industrial area in Tampa, Florida. The facility was built in 1929 as a chemical plant for the production of sulfur. The initial owners manufactured wettable and dusting sulfur and fommlated pesticides, herbicides, fungicides and fertilizers at the facility. Helena Chemical Company purchased the property in 1967 and Icontinued these manufacturing operations until 1981. The company moved its pesticide, herbicide and fungicide formulation operations to Georgia in 1981, but has continued to fonnulate insecticidal petroleum oil and liquid fertilizers at the facility. Former manufacturing operations by Helena Chemical Company and its predecessors resulted in soil and ground water contamination. EPA placed the Site on the National Priorities List (NPL) in October 1992. I Cleanup Actions: In 1996, EPA signed the Record of Decision (ROD) for the Site, which selected a remedy to clean up contaminants by excnvating nnd treating contaminnted soils, disposing of sulfur-contaminated soils off site, neutmlizing soil pH and containing ground water contamination to prevent off-site migration. Between 2000 and 2005, more than 10,000 tons of contaminated soils were excavated I for treatment and soils with sulfur contamination were disposed of off site. After the soil removals, lime was incorporated into remaining on-site soils to neutralize the sulfuric acid present four feet below the land surface. However, the addition of lime appears to have had minimal effect on areas with low pH. Design of the ground water treatment system was delayed due to the need to distinguish between Isource contnmination at the Site and source contamination emanating from another Superfund site, the Alaric Area Ground Water Plume site, which is located adjacent to the Site. Ground water sampling conducted in 2007 concluded that pesticide concentrations at the Site continue to exceed cleanup goals established in the ROD and require remedial action. Several pilot-scale treatability studies commenced in 2009 and are presently underway. I Five-Year Review Schedule: The Natioml Contingency Plan requires that remedinl actions thm result in any hazardous substances, pollutants or contaminants remaining nt the Superfund Sites nbove levels that allow for unlimited use and unrestricted exposure be Ireviewed every five years to ensure the protection of human health and the environment. The second of the Five-Year Reviews for this Site will be completed in January 20 II.

EPA invites community participation in the Five-Year Review process: EPA is conducting this Five-1T ear Review to evaluate the Ieffectiveness of the Site's remedy and to ensure that the remedy remains protective of human health and the environment. As part of the Five- \{ ear Review process, EPA staff are available to answer any questions about the Site. Community members who have questions about the Site or the Five-Year Review process, or who would like to participate in a community interview, are asked to contact: I Galo Jackson, Remedial Project Manager L'Tonya Spencer, Community Involvement Coordinator Phone: 404-562-8937 Phone: 404-562-8463 / 1-800-435-9234 (toll free) E-mail: jackson.galo((i.epa.gov E-mail: spencer.latonva(a)epn.gov I Mailing Address: EPA Region 4 Sam Nunn Atlanta Federal Center I (i I Forsyth St. SW Mail Code: 9T25 Atlanta, GA 30303-8960 I Site information is also available at the Site's local document repository, at University of South Florida Libmry, 4202 East Fowler Avenue, Tampa, Florida 33620, and online at: /rflp:IIH'WlV.epa.goviregioIl4111'{lstelllpilllp(flsl/reiell((fl./rIIll.

I B-1

I

I I Appendix C: Interview Forms

I Interview Form 2011 Five-Year Review - Helena Chemical Co. (Tampa Plant) Site, Tampa, FL

I Site Name: Helena Chemical Co. (Tampa Plant) EPA ID No.: FLD053502696 Interviewer Name: Sabrina Foster AffLIiation: £2 Inc. Subject's Name: Galo Jackson AffLIiation: EPA Region 4

I Subject's Contact Information: jackson.galo@epa.gov Time: 9:15 a.m. Date: July 8, 2010 Type of Interview (Circle one): In Person Phone Mail Other_____

I Location of Interview: Helena Chemical Co. (Tampa Plant) site

I I. W7wt is YOllr overall impression (?fthe pr(~ject?

In tenns of the pilot-scale treatability study for water, the project is on schedule. We are

I getting results back, having them reviewed, but it is still too early to tell what the final result will be. The treatability study has been challenging but I am hopeful that it will work.

I 2. 1Yhat effect has this site had on the surrounding community. ~fany:

None that J am aware of

I 3. How lve/l do you believe the remeczv currentzv in place is performing: Do you believe the monitoring data ShOll' the remedy's etrectiveness?

I As I said before, we are still working on the treatability study so it is really too early to tell. The study is still in early stages.

I 4. Are you aH'are C?fan,v complaints or inquiries regarding environmental issues or the

remedial action/i'om residents since implementatioll (?fthe cleanup? I have not received any in the last five years.

I 5. Are you invore C?fany changes in pf'{?jected land lise at or near the site: No, as far as I know it is all still zoned for heavy industrial use.

I 6. Do youfeel well if?!ol'med ahout the site's activities and progress? Yes. EnSafe are the remedial contractors and they do a good job keeping me well­infonned.

I 7. Do you have any comments, suggestions or recolJlmendations regarding the site's management or operation?

I Not really. The treatability study is underway and I am hopeful that it will work.

I I I C-l

I ISite Name: Helena Chemical Co. (Tampa Plant) EPA ID No.: FLD053502696

Interviewer Name: Sabrina Foster Affiliation: E2 Inc. SUbject's Name: Ed Brister Affiliation: Helena Chemical Company ISubject's Contact Information: bristere@helenachemical.com Time: 9:00 a.m. Date: July 8, 2010 Type of Interview (Circle one): In Person Phone Mail Other_____ ILocation of Interview: Helena Chemical Co. (Tampa Plant) site

1. 1f"hat is .vour overall impression ofthe project? IMy impression is that it is good and has been a successful project.

2. What e./Ject has this site had on the surrollnding community, ~(([ny? I.--We don't know of any effect on the surrounding community. Certainly, there hasn't been an effect on human health. At any site like this you are going to have stigma issues but we don't hear any concerns out of the community about it. I

3. Hmv well do you believe the remcc(y cllrrent(v in place is pelforming? I think it is doing well. I

4. An! YOli aware (~(an:v complaints or inquiries regarding environmental issues or the remedial actionfrom residellls since implementation l?(the cleanup? IYes. During the implementation of the cleanup, the soil excavations, we did hear of concerns from a neighbor, [Resident I]. We addressed her concerns by temporarily moving her and her husband from their home for a couple of months to a location south I of here. We temporarily moved the [residents] twice: once during the big removal in 2000 and again during the excavation and removal of the sulfur area in 2004-2005.

I 5. A re you mvare l?(uny changes in projected land lise at or near the site?

No, not for here or for the surrounding areas.

I 6. Do you.leelll'ell il?(ormed about the site's activities and progress?

Yes. I 7. Do YOll have any comments. suggestions or recommendations regarding the site 's

management or opera/ion? No. I

I I I I

C-2

I

I I

Site Name: Helena Chemical Co. (Tampa Plant) EPA ID No.: FLD053502696

I Subject's Name: Karen Milicic Affiliation: FDEP Subject's Contact Information: 850-245-8931 Time: 9:13 a.m. Date: August 23,2010

I Type of Interview (Circle one): In Person Phone Mail Other: E-mail Location of Interview: Tallahassee, FL

I i. What is YOllr overall impression o/the project? Good, appear to be making progress on addressing the contaminants of concern.

I 2. HOII' ~vell do you believe the remedy currenr~v in place is pel/arming? Still too early to tell based-on recent lab data.

I 3. Are you cOI1!fortable with the institlltional controls required/or the Site and their cllrrent status o/implementation? Yes at this time.

I I

4. Are you (nrare a/any complaints or inquiries regarding environmental issues or the remedial actionj/"om residents in the lastfive years? No, not aware of any complaints and/or inquiries regarding the Site.

I 5. Has your office conducted any Site-related activities or communications in the last.fi"e

years? ffso. piease give purpose and results o.fthese activities. Yes, to attend a site visit with EPA RPM Galo Jackson.

I 6. Are you aware (~fany changes to state Imvs that might ({[fect the protectiveness a/the rernedy? /Ire you aware a/any changes ill projected land use at the Site?

I Not at this time.

7. Do you feel ~vell if!/Cmned about the Site's activities and progress?

I Feel very well inforn1ed regarding the progress of the Site.

I 8. Do YOll have any comments. suggestions or recol11mendations ,.egarding the Site's

management or operation? None at this time.

I I I I I C-3

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I ISite Name: Helena Chemical Co. (Tampa Plant) EPA ID No.: FLD053502696

Interviewer Name: Sabrina Foster Affiliation: E2 Inc. SUbject's Name: Mary Yeargan Affiliation: Environmental Protection ICommission of Hillsborough Countv Subject's Contact Information: yearganm@epchc.org Time: 3:30 p.m. Date: September 27, 2010 IType of Interview (Circle one): In Person Phone Mail Other

1. What is .'r'ow· overall impression o.(tlze pro.iect? IMy overall impression is that it is continuing along as it has been.

2. What are your )'iell's about cllrrent site condition, problems. or related concerns? I---- I was on.the site visit for the last FYR, so I am familiar with the-Site and the Five-Year Review process. I think that things are continuing to move forward at the Site with the treatments underway I

3. What eflect has this site Iwd on the surrounding commllnity? This is a blighted community, and certainly the presence of a Superfund site contributes Ito the perception of blight. But Helena is not the only Superfund site in the area, there is also Stauffer Chemical, Florida Steel, Alaric, as well as the jail and all the bail bonds places. So there is blight in the community but it is not a direct result of Helena. I

4. Has the local government received any citizen complaints or inquiries regarding en1'ironmentlll isslles or activities at this site? II haven't received any specitic complaints, nothing about Helena in particular. The calls I get largely concern other specific Superfund sites in the area or just the presence of Superfund sites in general. I did receive a call in 2008 from a resident who was I concemed about well water and whether the presence of Superfund sites in the area meant that the water was contaminated. Again, they didn't specifically mention Helena, just Superfund sites in general. We called the Department of Public Health to come out I and sampled the well and there was no contamination present.

5. Have there been routine communications or activities (site visits, inspections, reporting I activities. etc.) conducted by your o.[fice regarding the site? {(yes, please give pwpose and results. No. I

6. Are .1;011 atvare o.fany changes to local laws that might qfrect the protectiveness o.(the reme(zv? Arc you mvare o/any changes in projected lalld lise at the Site? I No, I'm not aware of any changes to local laws that would impact the Site. Helena continues to operate so that land use hasn't changed and I don't imagine that the land use zoning would be changed to anything other than heavy industrial. There is a limited I amount of space available for heavy industrial so they are going to keep any land already zoned for that purpose. I

I C-4

I

I I 7. Do youfeel ~vefl if!{ormed about the Site's activities and progress? {{not. lvhatmethods

would you recommend EPA use to disseminate more il?j(mnation '!

I Sure.

8. Do yO/l have allY comments, suggestions. or recommendations regarding the project?

I None. I have worked with Galo for some time and let him know right away if there are any complaints.

I I I I I I I I I I I I I I I C-5

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I IAppendix D: Site Inspection Checklist

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST I I. SITE INFORMATION I

Date of inspection: July 8, 2010 Site name: Helena Chemical Co. (Tampa Plant)

Location and Region: Tampa, FL; Region 4 EPA 10: FLD053502696 I Agency, office, or company leading the five-year

\Veather/temperature: Clear skies, sunny, 85°Freview: EPA Region 4

Remedy Includes: (Check all that apply) I --- .o Landfill cover/containment - o Monitored natural attenuation

[8] Access controls [8] Groundwater containment [8] Institutional controls o Vertical ban-ier walls I[8] Groundwater pump and treatment o Surface water collection and treatment [8] Other Soil excavation and off-site disl20sal I

Attachments: o Inspection team roster attached o Site map attached

II. INTERVIEWS (Check all that apply)

1. 0&1\1 site manager mm/dd/yyvv I Name Title Date

Interviewed 0 at site 0 at office 0 by phone Phone no. --

Problems, suggestions; 0 Report attached __ I 2. 0&1\1 staff -- mm/dd/yyyy

Name Title Date

Interviewed 0 at site 0 at office 0 by phone Phone no. IProblems, suggestions; 0 Report attached

I I I I I I I

0-1 I

I I I I I I I I I I I I I I I I I

3. Local regulatory authorities and response agencies (i.e., State and Tribal offices, emergency response office, police department, office of public health or environmental health, zoning oftice, recorder of deeds, or other city and county oftlces, etc.). Fill in all that apply.

Agency FDEP Contact Karen Milicic

Name Project Manager Title

Problems; suggestions; D Report attached see Appendix C

8/2312010 Date

~~~~'~1:", ITOIl, ID,,, Problems; suggestions; D Report attached __

Agency __

Contact 1__ /-­ 1 N me Title Date

Problems; suggestions; D Report attached see Appendix C

Agency __

Contact 1 1 1 Name TIlle ~

Problems; suggestions; D Report attached see Appendix C

Agency __

Contact 1 1 1 Name TIlle Date

Problems; suggestions; 0 Report attached see ·Appendix C

850-245-8931 Phone No.

1 Phone No.

1 Phone No.

1 Phone No.

1 Ph ne No.

4. Other interviews (optional) D Report attached

EPA Region 4: Galo Jackson, Remedial Project Manager, 7/8/2010,404-562-8937

Helena Chemical Company (PRP): Ed Brister, Director of Engineering, Safety, Health and Environment, 7/812010,901-537-8600

III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)

I. O&M Documents

D O&M manual

D As-built drawings

D Maintenance logs

Remarks:

D Readily available

D Readily available

D Readily available

D Up to date

D Up to date

D Up to date

~N/A

~N/A

~N/A

2. Site-Specific Health and Safety Plan D Readily available

D Contingency plan/emergency response plan D Readily available

Remarks:

~ Up to date

~ Up to date

DN/A

DN/A

3. O&M and OSHA Training Records D Readily available

Remarks: __

D Up to date ~N/A

I I 0-2

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4. Permits and Service Agreements

D Air discharge pennit D Readily available D Up to date fZl N/A

D Eftluent discharge D Readily available D Up to date fZl N/A

D Waste disposal, POTW D Readily available D Up to date fZl N/A

D Other pennits __ D Readily available D Up to date fZl N/A

Remarks: - ­

5. Gas Generation Records D Readily available D Up to date fZl N/A

Remarks:

6. Settlement Monument Records D Readily available D Up to date fZl N/A

Remarks:

7. Groundwater Monitoring Records D Readily available D Up to date fZl N/A

Remarks: Ground water monitoring records are available for the feasibility study currently underway, and intermittent monitoring records from samQling to confiml the effectiveness of soil remedial actions are also available. Since a revised ground water remedy for the Site has not yet been selected or imQlemented, long-tenn monitoring of ground water remedy effectiveness has not yet begun,

8. Leachate Extraction Records D Readily available D Up to date fZl N/A

Remarks: - ­

9. Discharge Compliance Records

DAir D Readily available D Up to date fZl N/A

D Water (eftluent) D Readily available D Up to date fZl N/A

Remarks: - ­

10. Daily Access/Security Logs D Readily available D Up to date fZl N/A

Remarks: --

IV. O&M COSTS

1. O&M Organization

D State in-house D Contractor for State

D PRP in-house D Contractor for PRP

D Federal Facility in-house D Contractor for Federal Facility

D_

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I I I I I I I I I I I I I I I I I I I

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2. O&M Cost Records

I o Readily available o Up to date

o Funding mechanism/agreement in place o Unavailable

Original O&M cost estimate __ 0 Breakdown attached

I Total annual cost by year for review period if available

From nmlidd/yyyy To mm/dd/yyyy o Breakdown attached

I Date Date Total cost

I From ll1m/dd/yyyy To mm/dd/\:yyy o Breakdown attached

Date ate Total cost

I From mm/dd/.yyyy To mmJdd/yyyy ·0 Breakdown attached

Date Date Total cost

From mm/dd/yyyy To lllmJdd/yyyv o Breakdown attached

Date Date Total cost

I From mmJdd/yyyy To mmJdd/yyyy o Breakdown attached

Date Date Total cost

I 3. Unanticipated or Unusually High O&M Costs During Review Period

Describe costs and reasons:

I V. ACCESS AND INSTITUTIONAL CONTROLS ~ Applicable DN/A

A. Fencing

I 1. Fencing damaged o Location shown on site map [8J Gates secured DN/A

Remarks: Fencing surrounds entire I2rOl2ertv; gates are secured outside of ol2eration hours.

I B. Other Access Restrictions

1. Signs and other security measures o Location shown on site map DN/A

Remarks: Access signs are l20sted near entry gates.

I C. Institutional Controls (ICs)

I I I I I I 0-4

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1. Implementation and enforcement

Site conditions imply ICs not properly implemented DYes [gJ No 0 N/A

Site conditions imply ICs not being fully enforced DYes [gJ No D N/A

Type of monitoring (e.g., self-reporting, drive by) __

Frequency __

Responsible party/agency:

Contact mmJddlyyyy

Name Title Date Phone no.

Reporting is up-to-date DYes DNo DN/A

Reports are verified by the lead agency DYes DNo DN/A

Specific requirements in deed or decision documents have been met DYes DNo DN-/A

Violations have been reported DYes DNo DN/A

Other problems or suggestions: o Report attached

2. Adequacy [gJ ICs are adequate D ICs are inadequate DN/A

Remarks: The 1996 ROD calls for institutional controls in the fom1 of site deed restrictions to limit ex Rasure to ground water contam'ination until cleanuR goals are achieved. The ROD also calls for fencing to limit access and eXRosure to site soil contamination. At the reguest of the FDEP, land use restrictions for the Site have not yet been imQlemented; however, some interim institutional controls to Rrotect against eXRosure to ground water contamination have been imRlemented. EPA signed a Memorandum of Agreement with the SWFWMD, affinning SWFWMD's regulatory authority to restrict well construction and well use for Rotable water at and in the area of the Site. Secure Rerimeter fencing Rrovides an engineering control to restrict access to the Site. The risk for eXRosure is minimal because surface soil has been remediated, the Helena Chemical ComRany has continued site oI2erations and Qlans to continue industrial activities at the Site into the foreseeable future, and current and future land use zoning is consistent with the industrial cleanuI2 criteria used in the selection of site cleanuR goals.

I I I I I I I I I I I I

A treatability study is currently underway to helQ detennine the revised remedy for ground water. Once this remedy has been selected and decision documents have been aI2I2roQriately uQdated, Helena Chemical ComQany, EPA, the state and Hillsborough County will evaluate changes to existing institutional controls and addition of new institutional controls for the Site as well as imQacted ground water area, as aI2I2roI2riate.

D. General

1. Vandalism/trespassing D Location shown on site map [gJ No vandalism evident

Remarks:

2. Land use changes on site [gJ N/A

Remarks:

3. Land use changes off site [gJ N/A

Remarks:

VI. GENERAL SITE CONDITIONS

A. Roads [gJ Applicable DN/A

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I I I I I I I

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I. Roads damaged o Location shown on site map ~ Roads adequate ON/A

Remarks: Paved aSQhalt roads are used for access to warehouses and the office building on site.

B. Other Site Conditions

I Remarks:

VII. LANDFILL COVERS o Applicable ~N/A

A. Landfill Surface

I I. Settlement (Low spots) o Location shown on site map o Settlement not evident

Arial extent Depth __

I Remarks:

2. Cracks -- 0 Location shown on site map o Cracking not eviderll·

I Lengths __ Widths Depths __

Remarks:

I 3. Erosion o Location shown on site map o Erosion not evident

Arial extent Depth __

I Remarks:

4. Holes o Location shown on sit map o Holes not evident

Arial extent Depth __

I Remarks:

5. Vegetative Cover o Grass o Cover properly established

I o No signs of stress o Trees/Shrubs (indicate size and locations on a diagram)

Remarks:

I 6. Alternative Cover (amlOred rock, concrete, etc.) ON/A

Remarks:

I 7. Bulges o Location shown on site map o Bulges not evident

Arial extent Height __

Remarks:

o Location shown on site map Arial extent

o Location shown on site map Aria! extent

o Location shown on site map Aria! extent

o Location shown on site map Arial extent --

I I I

I 8. 'Vet Ateasl\Vater Damage

o Wet areas

I o Ponding

o Seeps

I o Soft subgrade

Remarks:

o Wet areas/water damage not evident

0-6

9. Slope Instability D Slides D Location shown on site map

o No evidence of slope instability

Arial extent --

Remarks: --

B. Benches D Applicable ~N/A

(Horizontally constructed mounds of earth placed across a steep landtill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined chalmel.)

I. Flows Bypass Bench D Location shown on site map D N/A or okay

Remarks: -­") Bench Breached D Location sl!.own. on site nlClP_ D N/A or okay----

Remarks: -­

3. Bench Overtopped D Location shown on site map D N/A or okay

Remarks: --

C. Letdown Channels o Applicable ~N/A

(Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side slope of the cover and will allow the runoff water collected by the benches to move off of the landfill cover without creating erosion gullies.)

I. Settlement (Low spots) D Location shown on site map D No evidence of settlement

Arial extent -- Depth __

Remarks: -­') Material Degradation o Location shown on site map o No evidence of degradation

Material type ___ Arial extent --

Remarks: -­

3. Erosion D Location shown on site map D No evidence of erosion

Arial extent -- Depth __

Remarks: -­

4. Undercutting o Location shown on site map o No evidence of undercutting

Arial extent -- Depth __

Remarks: --

S. Obstructions Type __ D No obstructions

o Location shown on site map Arial extent --

Size --

Remarks: - ­

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I I I I I I I I I I I I I I I I I

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I I I I I I I I I I I I I I I I I I I D-8

6. Excessive Vegetative Growth Type __

D No evidence of excessive growth

D Vegetation in channels does not obstruct tlow

D Location shown on site map Arial extent --

Remarks: --D. Coyer Penetrations D Applicable !Z;] N/ A

1. Gas Vents D Active D Passive

D Properly secured/locked o Functioning o Routinely sampled o Good condition

o Evidence of leakage at penetration o Needs Maintenance DN/A

Remarks: -­ - ­-­

-­

2. Gas Monitoring Probes

D Properly secured/locked o Functioning D Routinely sampled D Good condition

o Evidence of leakage at penetration o Needs Maintenance DN/A

Remarks: -­3. Monitoring Wells (within surface area of landfill)

o Properly secured/locked o Functioning o Routinely sampled o Good condition

o Evidence of leakage at penetration o Needs Maintenance DN/A

Remarks: -­

4. Extraction Wells Leachate

o Properly secured/locked o Functioning o Routinely sampled o Good condition

o Evidence of leakage at penetration o Needs Maintenance DN/A

Remarks: -­

5. Settlement Monuments o Located D Routinely surveyed DN/A

Remarks: --

E. Gas Collection and Treatment D Applicable !Z;] N/A

1. Gas Treatment Facilities

o Flaring o Themlal destruction D Collection for reuse

o Good condition o Needs Maintenance

Remarks: -­') Gas Collection Wells, Manifolds and Piping "-.

o Good condition o Needs Maintenance

Remarks: -­

3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)

o Good condition o Needs Maintenance DN/A

Remarks: -­

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F. Cover Drainage Layer o Applicable ~N/A

1. Outlet Pipes Inspected o Functioning ON/A

Remarks: -­

2. Outlet Rock Inspected o Functioning ON/A

Remarks: --

G. Detention/Sedimentation Ponds o Applicable ~N/A

1. Siltation Area extent -- Depth __ ON/A

o Siltation not evident

Remarks: -­") -

Erosion Area extent Depth _-_-_­ --L. -­

o Erosion not evident

Remarks: -­

3. Outlet Works o Functioning ON/A

Remarks: -­

4. Dam o Functioning ON/A

Remarks: --

H. Retaining Walls o Applicable ~N/A

I. Deformations o Location shown on site map o Deformation not evident

Horizontal displacement __ Vertical displacement __

Rotational displacement __

Remarks: -­

2. Degradation o Location shown on site map o Degradation not evident

Remarks: --

I. Perimeter Ditches/Off-Site Discharge o Applicable ~N/A

I. Siltation o Location shown on site map o Siltation not evident

Area extent -- Depth __

Remarks: -­

2. Vegetative Growth o Location shown on site map ON/A

o Vegetation does not impede flow

Area extent -- Type __

Remarks:

3. Erosion o Location shown on site map o Erosion not evident

Area extent -- Depth __

Remarks: --

I I I I I I I I I I I I I I I I I I

D-9 I

I I I I I I I I I I I I I I I I I I I D-IO

4. Discharge Structure D Functioning DN/A

Remarks: --

VIII. VERTICAL BARRIER WALLS D Applicable ~N/A

1. Settlement D Location shown on site map D Settlement not evident

Area extent -- Depth __

Remarks: -­

2. Performance Monitoring Type of monitoring __

D Perfom13nce not monitored

Frequency __ D Evidence of breaching

Head differential . -­--

Remarks: --IX. GROUNDWATER/SURFACE WATER REMEDIES ~ Applicable D N/A

A. Groundwater Extraction Wells, Pumps, and Pipelines D Applicable ~N/A

1. Pumps, Wellhead Plumbing, and Electrical

D Good condition o All required wells properly operating D Needs Maintenance DN/A

Remarks: -­') Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances

o Good condition D Needs Maintenance

Remarks: -­

3. Spare Parts and Equipment

D Readily available D Good condition D Requires upgrade D Needs to be provided

Remarks: --

B. Surface Water Collection Structures, Pumps, and Pipelines D Applicable ~N/A

1. Collection Structures, Pumps, and Electrical

D Good condition D Needs Maintenance

Remarks: -­2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances

D Good condition D Needs Maintenance

Remarks: -­

3. Spare Parts and Equipment

D Readily available D Good condition D Requires upgrade D Needs to be pr vided

Remarks: --

C. Treatment System o Applicable ~N/A

I. Treatment Train (Check components that apply)

o Metals removal o Oil/water separation o Bi remediation

o Air stripping o Carbon adsorbers

o Filters __

o Additive (e.g., chelation agent, tlocculent) __

o Others __

o Good condition 0 Needs Maintenance

o Sampling ports properly marked and functional

o Sampling/maintenance log displayed and up to date

o Equipment properly identified

o Quantity of groundwater treated annually __

o Quantity of surface water treated aIUlually __

Remarks: __

2. Electrical Enclosures and Panels (properly rated and functional)

o N/A 0 Good condition 0 Needs Maintenance

Remarks:

3. Tanks, Vaults, Storage Vessels

o NIA 0 Good condition o Proper secondary containment

Remarks: __

o Needs Maintenance

4. Discharge Structure and Appurtenances

o N/A 0 Good condition

Remarks: __

o Needs Maintenance

5. Treatment Building(s)

o N/A 0 Good condition (esp. roof and doorways)

o Chemicals and equipment properly stored

Remarks:

o Needs repair

6. Monitoring Wells (pump and treatment remedy)

o Properly secured/locked 0 Functioning 0 Routinely sampled

o All required wells located 0 Needs Maintenance

Remarks:

o Good condition

DN/A

D. Monitoring Data

I. Monitoring Data

[g] Is routinely submitted on time [g] Is of acceptable quality

2. Monitoring data suggests:

o Groundwater plume is effectively contained o Contaminant concentrations are declining

I I I I I I I I I I I I I I I I I I

0-11 I

I I E. Monitored Natural Attenuation

I. Monitoring Wells (natural attenuation remedy)

I D Properly secured/locked D Functioning D Routinely sampled D Good condition

D All required wells located D Needs Maintenance [8] N/A

I Remarks: --

I X. OTHER REMEDIES

If there are remedies applied at the site and not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.

I In Segtember 2009, Helena Chemical Comgany began a gilot-scale bioremediation treatabilitv study at the Site to test the effectiveness of sulfate reduction and anaerobic xylene degradation to treat residual ground water contamination in the surficial aguifer and the intennediate aguifer sYstem. The gilot study also investigates reductive dechlorination of BHC isomers through addition of facultative anaerobic cultures;

I enhancement of nitrate-, iron- and sulfate-reducers; and addition of a reduction agent, such as zero-yalent iron, with a gH adjustment. The study was scheduled to conclude by the fourth guarter of 20 10, and a contingency time of an additional 12 months has been allotted in the treatability study schedule. if necessary.

XI. OVERALL OBSERVAnONS

I A. Implementation of the Remedy

The gesticide source contamination in soil was excavated in 2000 and shirmed off site to an aggroved

I disgosal facility in Louisiana. Further soil excayation activities were gerformed in 2004 and 2005 in order to address sulfur contamination source areas. A gilot study to assess treatability of ground water contamination originating from the fonner sulfur git area and the former xylene tank area is gresently underway. Results of the study will inform the selection of the remedy for ground water at the Site.

I B. Adequacy of O&M

A treatability study is gresently underway tor ground water treatment at the Site. O&M activities have yet to commence.

C. Early Indicators of Potential Remedy Problems

I None.

I D. Opportunities for Optimization None.

I I

Site Inspection Team: Galo Jackson, EPA Region 4

I Ed Brister, Helena Chemical Company Christy Fielden, E~ Inc. Sabrina Foster, E~ Inc.

I I I I 0-12

I I Appendix E: Photographs from Site Inspection Visit

I I I I I I I I I I I I I I I I I

Helena Chemical Company office building at the Site.

Signs at delivery gate which is secured outside of facility operating hours.

E-l

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Chemical storage warehouse on site.

Fonner sulfur pit area with new chemical warehouse facilities.

E-2

I I I I I I I I I I I I I I I I I I I

Monitoring well in the fonner sulfur pit area.

Pilot study monitoring wells in the former xylene tank area.

E-3