**HRS DOCUMENTATION RECORD COVER SHEET**

**Name of Facility:** Sanford Dry Cleaners

**EPA ID No.** FLD032728032

Contact Persons

U.S. Environmental Protection Agency (EPA), Region 4:

Barbara Alfano, Remedial Project Manager (404) 562-8923 Jennifer Wendel, NPL Coordinator (404) 562-8799

Investigation: Site Inspection 09/2009

Documentation Record: Allyson Warrington, Project Manager Oneida Total Integrated Enterprises, Inc., START (678) 355-5550

Pathways, Components, or Threats Not Scored

Sanford Dry Cleaners is being scored on the ground water migration pathway. The evaluation of the ground water migration pathway yields a score above the NPL listing cutoff value of 28.50. Observed contamination is documented and municipal and community drinking water wells are located within a 4-mile radius. No surface water migration or air migration pathway releases have been documented and these pathway scores do not contribute significantly to the overall HRS score for the Sanford Dry Cleaners site. In addition, no contamination on residential properties has been docu mented, and the soil exposure pathway does not contribute significantly to the site score.1 **HRS DOCUMENTATION RECORD**

Name of Facility: Sanford Dry Cleaners

EPA Region: 4 Date Prepared: March 2010

Street Address of Facility*: 121 South Palmetto Avenue

City, County, State, Zip: Sanford, Seminole County, Florida, 32771

General Location in the State: East-Central

Topographic Map: Sanford, Florida

Latitude: 28 ° 48' 40.38" North Longitude: 81 ° 15' 56.18" West (Ref. 3)

The Global Positioning System (GPS) coordinates were collected from the easternmost building on the 121 S. Palmetto Avenue property, specifically the northwest corner of the building.

*The street address, coordinates, and contaminant locations presented in this Hazard Ranking System (HRS) documentation record identify the general area in which the site is located. They represent one or more locations that the U.S. Environmental Protection Agency (EPA) considers to be part of the site based on the screening information EPA used to evaluate the site for National Priority List (NPL) listing. EPA lists national priorities among the known "releases or
threatened releases" of hazardous substa nces; thus, the focus is on the release, not precisely delineated boundaries. A site is defined as where a hazardous substance has been "deposited, stored, placed, or otherwise come to be located." Generally, HRS scoring and the subseque nt listing of a release merely represent the initial determination that a certain area may need to be addressed under Comprehensive Environmental Response, Compensation, and Recovery Act (CERCLA). Accordingly, EPA contemplates that the preliminary description of facility boundaries at the time of scoring will be refined as more information is developed as to where the contamination has come to be located.

**Scores**

Air Pathway Not Scored Ground water Pathway 100.00 Soil Exposure Pathway Not Scored Surface Water Pathway Not Scored

**HRS SCORE 50.00** 2 **WORKSHEET FOR COMPUTING HRS SCORE**

S S 2

1. Ground water Migration Pathway Score (S gw ) 100 10,000

2a. Surface Water Overland/Flood Migration Component

(from Table 4-1, line 30) NS NS

2b. Ground water to Surface Water Migration Component

(from Table 4-25, line 28) NS NS

2c. Surface Water Migration Pathway Score (S )
sw Enter the larger of lines 2a and 2b as the pathway score. NS NS

3. Soil Exposure Pathway Score (S
s ) (from Table 5-1, line 22) NS NS

4. Air Migration Pathway Score (S
a ) (from Table 6-1, line 12) NS NS

5. Total of S gw 2 + S sw 2 + S s 2 + S a 2 10,000

6. **HRS Score** Divide the value on line 5 by 4 and take the square root 50.00

NS - Not Scored Reference 1, Table 3-13 **GROUND WATER MIGRATION PATHWAY SCORESHEET**

**Factor Categories and Factors Maximum Value**  **Value Assigned**

**Likelihood of Release to an Aquifer:**

1. Observed Release 550 550

2. Potential to Release:

2a. Containment 10

2b. Net Precipitation 10

2c. Depth to Aquifer 5

2d. Travel Time 35

2e. Potential to Release [lines 2a x (2b + 2c + 2d)] 500

3. Likelihood of Release (higher of lines 1 and 2e) 550 550

**Waste Characteristics:**

4. Toxicity/Mobility a 10,000

5. Hazardous Waste Quantity a 10

6. Waste Characteristics 100 18

**Targets** :

7. Nearest Well 50 20

8. Population:

8a. Level I Concentrations b 0

8b. Level II Concentrations b 0

8c. Potential Contamination b 2,688.5

8d. Population (lines 8a + 8b + 8c) b 2,688.5

9. Resources 5 0

10. Wellhead Protection Area 20 5

11. Targets (lines 7 + 8d + 9 + 10) b 2,713.5

**GROUND WATER MIGRATION SCORE FOR AN AQUIFER**

12. Aquifer Score [(lines 3 x 6 x 11)/82,500] c 100 100.00

**GROUND WATER MIGRATION PATHWAY SCORE**

13. Pathway Score (S gw ), (highest value from line 12 for all aquifers evaluated) c 100 100.00

a Maximum value applies to waste characteristics category.

b Maximum value not applicable.

c Do not round to nearest integer.**Source: ArcGIS Online Services Disclaimer: This map is intended for visual orientation use only.** 
**In no way is this map to be used for precise locational use.** 

**Sanford, Seminole County,**  **Florida** 

### 0 **1 2**  **Miles** 

# $ **United States Environmental Protection Agency**

SANFORD DRY CLEANERS SA NFORD, SEMINOLE COUNTY

FLORIDA TDD No. TNA-05-003-0092

FIGURE 1 GE NERAL LOCATION MAP**G:\GIS_Workspace\Sanford Dry Cleaners\mxd\Figure 1 - General Location Map.mxd**



# Legend

**Site Location** 

### Sanford Dry Cleaners

# Legend

113 SOUTH

PALMETTO AVE.



### EAST 2ND STREETS. PALMETTO AVENUES. SANFORD AVENUE

121 SOUTH

PALMETTO AVE. 

### EAST 1ST STREET Parcel

Site Boundary 

# $

0 40

Feet



### Sanf Sem ord, inole Coun ty, Florida

United States Environmental Protection Agency



### SANFORD DRY CLEANERS SANFORD, SEMI FLOR NOLE COUNTY,
IDA TDD No. TNA-05-003-0092



## FIGURE 2 PROPERTY LAYOUT MAPG:\GIS_Workspace\Sanford Dry Cleaners\mxd\Figure 2 - Property Layout Map.mxd

Aerial Source: GlobeXplorer ImageConnect (April 2008) 80

### ! < ! < ! < ! < ! < ! <

! ? ! ? ! ? ! ?

! < ! <

! < ! <

! U

! U ! U

! U ! U

! U ! U ! U ! U

! > ! >

! > ! >

MW-01-GW DEP-05D-GW

DEP-03S-GW DEP-03D-GW

DEP-1D-GW SDC-012D-GW

SDC-003-GW

SDC-002-GW

SDC-001-SF SDC-009-SB

SDC-004-SB

SDC-003-SB

SDC-002-SB

SDC-006-SB SDC-008-SB SDC-005-SF

SDC-004-SF

SDC-002-SF SDC-009-SF

SDC-006-SF SDC-007-SF SDC-0010-SB

SDC-007-SB SDC-0010-SF

SDC-001-SB SDC-003-SF

SDC-008-SF 113 SOUTH

PALMETTO AVE.



### EAST 2ND STREETS. PALMETTO AVENUES. SANFORD AVENUE

121 SOUTH

PALMETTO AVE. SB

SF 

# Legend

! < Surface Soil Sample


### ! Subsurface Soil Sample 

### U

! > Shallow Groundwater Sample



### ! Deep Groundwa er Sample 

### ? t

Parcel

Site Boundary

Subsurface Soil

Surface Soil

GW Ground Water

MW Monitoring Well

SDC Sanford Dry Cleaners

DEP XXX

D Deep 

# $

S Shallow 0 20

Feet



### Sanf Sem ord, inole Coun ty, Florida

United States Environmental Protection Agency



### SANFORD DRY CLEANERS SANFORD, SEMI FLOR NOLE COUNTY,
IDA TDD No. TNA-05-003-0092



## FIGURE 3 SAMPLE LOCATION MAPGIS_WorkspaceG:\\Sanford Dry Cleaners\mxd\Figure 3 - Sample Location Map.mxd

Aerial Source: GlobeXplorer ImageConnect (April 2008) 407 **REFERENCES**

Ref.
No. Description of the Reference

1. U.S. Environmental Pro tection Agency (EPA). Hazard Ranking System, 40 CFR Part 300, Appendix A, 55 FR 51533. December 14, 1990. Excerpt. 34 pages. A complete copy is available in the regional docket.

2. EPA. Superfund Chemical Data Matrix (SCDM). January 2004. Excerpt. 51 pages. A complete copy of SCDM is available at http://epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm

.
3. U.S. Geological Survey (USGS). 7.5 Minute series Topographic Quadrangle Maps of Florida: Osteen, 1980; Sanford, 1988. Scale 1:24,000. 1 map.

4. City of Sanford, Department of Planning & Development Services. Memorandum to Multiple City and County Entities. Subject: Revision of addresses, One Hundred block of Palmetto Avenue, Tax Parcel Number: 25-19- 30-5AG-0301-011A, 25-19-30-5AG-0301-0110. July 26, 2006. 2 pages.

5. Seminole County Property Appraiser. Parcel Se arch 25-19-30-5AG-0301-0110 and 25-19-30-5AG-0301-011A. Accessed online at http://www.scpafl.org/web/re_web.seminole_county_title?PARCEL=2519305AG030 10110&coparcel=1930255AG03010110&cparcel=1930255AG03010110&cdor=&cctr=&cto tal=&cfparcel=2519305AG03010110&cmap=Y&crank=1 and http://www.scpafl.org/web/re_web.seminole_county_title?PARCEL=2519305AG030 1011A&coparcel=1930255AG0301011A&cparcel=1930255AG0301011A&cdor=&cctr=&cto tal=&cfparcel=2519305AG0301011A&cmap=Y&crank=1 . September 8, 2009. 2

pages.

6. Florida Department of Environmental Protection (FDEP). Final Site Inspection Report. Sanford Dry Cleaners. September 2009. 288 pages.

7. Environmental Data Resources, Inc. (EDR). Certified Sanborn® Map Report. Inquiry Number: 2560915.3. August 11, 2009. 3 pages.

8. EDR. The EDR-City Directory Abstract. Inquiry Number: 2560915.6. August 13, 2009. 9 pages.

9. Environmental Solutions and Services, Inc. Contamination Assessment Report of Thrifty Service Station. January 22, 1993. 26 pages.

10. EPA. Drinking Water Contaminants. Accessed online at http://www.epa.gov/safewater/contaminants/index.html . October 2, 2009. 14 pages.

11. ESSI Omega, Inc. Contamination Assessment Rep ort Addendum for the Former Thrifty Service Station. December 20, 1993. 40 pages.

12. FDEP. Letter from Gail Mowry, Waste Cleanup P rogram, to Dan Porter, ENCO International. Subject: Application to Drycleaning Solvent Cleanup Program. September 18, 1997. 8 pages.

13. EPA, Science and Ecosystem Support Division (SESD), Region 4. Environmental Investigations Standard Operating Procedures and Quality Assurance Manual. November 2001. 413 pages.

14. USGS. A Tapestry of Time and Terrain: The Union of Two Maps-Geology and Topography. Accessed online at http://tapestry.usgs.gov/physiogr/physio.html . September 10, 2009. 3

pages.

15. Florida Geologic Survey (FGS) and Lindquist Database. Lithologic Well Logs (W-346, W-361, W-413, 526, and 594). Accessed online at http://www.dep.state.fl.us/geology/gisdatamaps/litholog.htm . 12 pages.

16. USGS. Ground-Water Resources of Seminole County, Florida. Report of Investigations No. 27. 1962. Excerpt. 41 pages.8 17. FDEP. Sinkholes Database. Accessed online at http://www.dep.state.fl.us/geology/gisdatamaps/sinkhole_database.htm

. October 2, 2009. 1 page.

18. Florida Department of Natural Resources, Bureau of Geology. Sinkhole Type, Development, and Distribution in Florida. Map Series No. 110. 1985. 1 map.

19. Reference Removed.

20. EPA, SESD, Region 4. Operating Procedure: Ground Water Sampling. November 1, 2007. 30 pages.

21. FDEP, Division of Waste Management, Bureau of Waste Clean-Up, Program & Technical Support Sect ion. Pre-CERCLIS Screening Assessment. Sanford Dry Cleaners. December 2, 2008, Revised January 5, 2009. 23 pages.

22. Izzo, Victor J. Dry Cleaners A Major Source Of PCE In Ground Water. March 27, 1992. 15 pages.

23. World Health Organization (WHO). Concise International Chemical Assessment Document 68, Tetrachloroethylene. 2006. 122 pages.

24. EDR. The EDR Radius MapTM Report with GeoCheck®. Inquiry Number: 2560915.2s. August 11, 2009. 195 pages.

25. Oneida Total Integrated Enterprises. Project Note to file. Subject: FDEP GIS/PWS Lookup. November 11, 2009. 10 pages.

26. FDEP. Public Water Systems. Accessed Online at http://www.dep.state.fl.us/swapp/PWSType.asp . October 6, 2009. Wellhead Protection. Accessed online at: www.dep.state.fl.us/Water/groundwater/wellhead.htm October 7, 2009. 4 pages.

27. Reference removed.

28. USGS. Ground Water Atlas of the United States: Alabama, Florida, Georgia, South Carolina. HA 730-G. Accessed online: http://pubs.usgs.gov/ha/ha730/ch_g/G-text2.html . Excerpt. 17 pages.

29. McCarthy, James, PG., FDEP. Documentation Record. Subject: Sanford Drycleaner, Sanford, Florida Karst Aquifer Documentation. November 4, 2009. 2 pages.

30. U.S. Department of Labor, Occupational Safety & Health Administration. Dry Cleaning Hazard Recognition. Accessed online: http://www.osha.gov/SLTC/drycleaning/recogniti on.html . January 22, 2010. 1 page.

31. EPA, SESD. Quality Assurance Project Plan. Sanford Drycleaners. 11

pages.

32. FDEP. Site Inspection Work Plan. Sanford Drycleaners. April 14, 2009. 38 pages.Site Description - General Description and History

9 **General Site Description and History**

The Sanford Dry Cleaners site, for HRS scoring purposes, consists of contaminated soil on the 121 South Palmetto Avenue pa rcel of the Sanford Dry Cleaner property and contaminated ground water associated with releases from the contaminated soil

source.

The entire Sanford Dry Cleaners property is comprised of t wo contiguous parcels located on South Palmetto Avenue, in the historic section of downtown Sanford, Seminole County, Florida (Refs. 3; 4, pp. 1, 2; 5, pp. 1, 2; 6, p. 4). The numeric street addresses of the parcels have changed over time, but are currently addressed 121 and 113 South Palmetto Avenue (Refs. 3; 4, pp. 1, 2; 5, pp. 1, 2; 6, p. 4). The geographic coordinates, collected from the northwest corner of the easternmost building located on the 121 South Palmetto Avenue parcel, are 28°48'40.38" North latit ude, 81°15'56.18" West longitude, Section 25, Township 19 South, Range 30 East (Ref. 3). The Seminole County Parcel numbers are 25-19-30-
5AG-0301-0110 and 25-19-30-5AG-0301-011A for the 121 and 113 South Palmetto properties, respectively (Refs. 3; 4, pp. 1, 2; 5, pp. 1, 2; 6, p. 4).

The 121 South Palmetto A venue property is approximately one acre in size (Ref. 6, p. 5). The building located on the 121 South Palmetto Avenue property is a 2- story building with a single story building that extends from the east of the main building (Ref. 6, p. 5). The 121 South Palmetto Avenue building is the last known location of the Sanford Dry Cleaners operation (Ref. 6, p. 5).

Two single-story buildings with connected facades are located on the 113 South Palmetto Avenue property (Ref. 6, p. 5). The taller building, sometimes referred to as the old E.E. Brady Livery building, is located on the northern portion of the property (Ref. 6, p. 5). The building was built in the late 19th century, and is included on the National Register of Historic Places (Ref. 6, p. 5). It is of brick construction, overlaid with stucco (Ref. 6, p. 5). Directly behind the building is a boiler room of concrete block construction (Ref. 6, p. 5). The shorter building, located on the southern portion of the 113 South Palmetto Avenue property was reportedly built in the 1970s and is also overlaid with stucco (Ref. 6, p. 5). The property is bordered by Investors Realty Network (former Thrifty Service Station) to the south; an alley to the east with a plumbing business (Exact Plumbing) and a home style restaurant across the alley; and South Palmetto Avenue to the west, with a pottery store and Wine Company across the street; and the City of Sanford historic Firehouse is located to the north of the subject pro perty (Ref. 6, p. 5). An art studio and residence occupy the first and second floors, respectively, of the Firehouse (Ref. 6, p. 5).

The property has been owned and operated by numerous individuals and companies over the years; however, it has primarily been operated as a dry cleaning and laundry business (Ref. 6, p. 5). The dry cleaning business was first established on the 121 South Palmetto Avenue property in the 1940s under the name Downtown Drycleaners & Laundry (Ref. 6, p. 5). The 1947 Sanborn Fire Insurance map indicates that the easternmost building of the current 121 South Palmetto Avenue property operated as a “ Drycleaner” (Refs. 6, p. 5; 7, p. 3). In 1964, the owner of the dry cleaning and laundry business purchased the adjoining property, now known as 113 South Palmetto Avenue (Ref. 6, p. 5). In the early 1970s, the 113
and 121 South Palmetto A venue properties were sold together with all dry cleaning equipment (Ref. 6, p. 5). Dry cleaning operations continued under the name Sanford Dry Cleaners (Refs. 6, p. 5; 8, p. 6). In the late 1970s, the property owner arranged to construct the one-story building on the southern half of the
113 South Palmetto Avenue property, which had formerly been a vacant lot (Ref. 6, p. 5). According to the State of Florida Division of Corp orations, Sanford Dry Cleaners incorporated in 1983 and dissolved in 1997 (Ref. 6, p. 5). The property owners reportedly operated the dry cleaner at the location until both parcelsSite Description - General Description and History

10 were sold to EnCon Enterprises Trust (EnCon) in 1996 (Ref. 6, p. 6). Dry cleaning operations continued under EnCon’s ownership (Ref. 6, p. 6). In 2001, Lavie Partnership LLC (Lavie) purchased both parcels as investment real estate (Ref. 6, p. 6). In 2004, Lavie sold the 113 South Palmetto Avenue property to Clark Mears, LLC, and the 121 South Palmetto Avenue property to Palm Property Investments, LLC (Palm) (Ref. 6, p. 6). Subsequently, in 2006, Palm gifted the 121 property to a non-pr ofit entity, The Lighthouse, An Association of Landlords, Inc. (Lighthouse), which shortly thereafter transferred the 121 South Palmetto
Avenue property to a closely affiliated entity, Metro Orlando Affordable Housing, Inc. (MOAH) (Ref. 6, p. 6). In 2008, the City of Sanford foreclosed on the 113 South Palmetto Avenue property owned by Clark Mears, LLC for historic building code violations (Ref. 6, p. 6). The 121 South Palmetto Avenue property is currently owned by MOAH (Ref. 6, p. 6).

Very little information is available regarding the actual day to day operations at Sanford Dry Cleaners (Ref. 6, p. 6). However, it is known that previous property owners/operators used perchloroethylene or tetrachloroethylene (PCE) also referred to as “PERC”, as the cleaning agent, which is consistent with the historic use of dry cleaning solutions in the industry (Ref. 6, p. 6).

In January 1993, a Conta mination Assessment Report (CAR) submitted to the Florida Department of Environmental Protection (FDEP) by Environmental Solutions and Services Incorporated (ESSI), for the fo rmer Thrifty Service Station, documented chlorinated volatile organic compounds ( VOCs) in ground water (Refs. 6, p. 6; 9, pp. 5, 20, 23). Ground water samples were collected for l aboratory analysis in December 1992 (Refs. 6, p. 6; 9, p. 20). The former Thrifty Service Station site, which was located just south of the Sanford Dry Cleaners, was being evaluated as part of the FDEP Petroleum Cleanup Program (Ref. 6, p. 6). Two wells were sampled during the assessment and are both located in proximity to Sanford Dry Cleaners to the north of the service station (Ref. 6, p. 6). PCE (28 micrograms per liter [ug /L]) and trichloroethene (TCE) (19 ug/L) were detected in ground water samples collected from monitoring well MW-2 (Ref. 6, p. 6). PCE (100 ug/L), TCE (43 ug/L), and trans-1,2-dichloroethylene (trans-1,2-DCE) (17 ug/L) were detected in ground water samples collected from monitoring well MW-5 (Ref. 6, p. 6). The PCE and TCE concent rations in both wells exceeded the State and federal Maximum Contaminant Levels (MCLs) (Refs. 6, p. 6; 10, p. 10). FDEP requested additional ground water assessment activities to delineate a petroleum related ground water plume as well as an assessment of the presence of the chlorinated VOCs (Ref. 6, p. 6).

A CAR Addendum, submitted in December 1993, confirmed the presence of chlorinated VOCs in ground water (Refs. 6, p. 6; 11, pp. 2, 3, 7). PCE (28 ug/L), TCE (42 ug/L), and trans-1,2-DCE (10 ug/L) were again detected in ground water samples collected from monitoring well MW-5 (Refs. 6, p. 6; 11, p. 10). The PCE and TCE concentrations exceeded the State Ground Water Cleanup Target Levels (GCTLs) and federal MCLs (Refs. 6, p. 6; 11, p. 10). A deeper surficial aquifer monitoring well (DW-1) was installed near MW-5 at the southeast corner of the former Sanford Dry Cleaners building (Ref. 6, p. 6). However, no chlorinated VOCs were detected in the deep well during the December 1993 sampling event (Ref. 6, p. 6). The chlorinated VOCs were at tributed to a source off the property (Refs. 6, p. 6; 11, p. 7). Since no petroleu m-related constituents were found in ground water or soil samples at levels above FDEP Soil or GCTLs, a No Further Action/Site Rehabilitation Completion Order was issued for the former Thrifty Service Station property (Ref. 6, p. 6).

On September 18, 1997, FDEP sent a letter to the owner of the Sanford Dry Cleaners property (EnCon) (Refs. 6, p. 6; 12, pp. 1-2). T he letter stated that unless an application was filed for the State Dry Cleaning Solvent Cleanup Program (DCSCP) within 60 days, the State would pursue enforcement activities (Refs. 6, pp. 6, 7; 12, p. 1). No application was received, so FDEP forwardedSite Description - General Description and History

11 another letter to the property owner on February 11, 1998, reiterating the information detailed in the previous letter (Ref. 6, p. 7). On February 20, 1998, EnCon forwarded the FDEP letter to its contractor, Florida Environmental Assessments, for review and a price quote to complete the DCSCP Site Screening Report (Ref. 6, p. 7).

On June 3, 1999, Stillwater Technologies (Stillwater) subm itted a Limited Phase II Environmental Site Assessment (ESA) Report for the Sanford Dry Cleaners property on behalf of the property owner (EnCon) (Ref. 6, p. 7). The report documented the previous contamination assessment findings (Ref. 6, p. 7). In addition, Stillwater reported the findings of its Phase II ESA field investigation conducted in April 1999 (Ref. 6, p. 7). Two borings, GP-1 (15 feet deep) and GP-2 (30 feet deep), were advanced at the northeast and southeast corners, respectively, of the Sanford Dry Cleaners building (Ref. 6, p. 7). Soils from the borings were screened with an organic vapor analyzer (OVA) (Ref. 6, p. 7). Ground water and soil samples were collected from the borings for laboratory analyses (Ref. 6, p. 7). Ground water samples were also collected from existing monitoring wells MW-4, MW-5, and DW-1 (also called MW-5D) (Ref. 6, p. 7). OVA readings [1,634 parts per million (ppm) to 3,0 91 ppm) were detected in the soils from the GP-2 boring (Ref. 6, p. 7). The soil screened from GP-2 had a strong odor (Ref. 6, p. 7). However, no specifics were provided in the report as to the type of odor encountered in the boring (Ref. 6, p. 7).

PCE [72,000 micrograms per kilogram (ug/kg)] and TCE (420 ug/kg) were detected in soil sample SS-1 collected from the GP-2 boring (Ref. 6, p. 7). The PCE and TCE concentrations in SS-1 s ignificantly exceeded the State Soil Cleanup Target Level (SCTL) for ground water leachability (30 ug/kg) (Ref. 6, p. 7). The PCE concentration also exceeded the SCTL for direct contact in industrial settings (18,000 ug/kg). PCE (14 ug/L and 4,800 ug/L), TCE (240 ug/L and 540 ug/L), and vinyl chloride (55 ug/L) were detected in the ground water samples collected from GP-1 (Ref. 6, p. 7). PCE (31,000 ug/L) and TCE (8,900 ug/L) were detected in the ground water samples collected from GP-2 (Ref. 6, p. 7). Ground water samples collected from monitoring well MW-5 contained TCE (13I ug/L) and cis-1,2-DCE (170 ug/L) (Ref. 6, p. 7). The levels of PCE, TCE, and cis-1,2-DCE found in ground
water exceeded both State and federal MCLs (Ref. 6, p. 7). Based on the results of the ESA, Stillwater concluded that soil and ground water at the Sanford Dry Cleaners had been impacted by dry cleaning compounds (Ref. 6, p. 7).

On August 30, 1999, the Sanford Dry Cleaners property owner (EnCon) submitted an application to FDEP for enrollment into the DCSCP (Refs. 6, p. 7; 12, pp. 3-8). However, on August 23, 2000, FDEP notified the property owner that the application was received beyond the deadline (December 31, 1998) stipulated in the DCSCP statute (F.S 376.3078) (Ref. 6, p. 7). On September 22, 2000, the property owner submitted a letter as Petition for an Administrative Hearing (Ref. 6, p. 7). On November 17, 2000, FDEP dismissed the petition based on the fact that the application was received after the deadline stipulated in the statute and the petition did not comply with the requirements of the Florida Administrative Code (Ref. 6, p. 7).

On January 13, 2000, EnCon requested a p arking variance from the City of Sanford for the former Sanford Dry Cleaners (Ref. 6, p. 7). This included both the current 113 and 121 South Palmetto Avenue properties (Ref. 6, p. 7). EnCon indicated that it planned to renovate these buildings and develop them for commercial use as food, beverage, and entertainment venues (Ref. 6, p. 7). Between 2000 and 2004, FDEP attempted to coordinate with the various potentially responsible parties (PRPs) and owners to conduct further contamination assessment activities at the property (Ref. 6, p. 7). This was complicated by the limited financial resources of the PRPs as well as the liability p rotection provided to PRPs under Florida Statute 376.3078 (Ref. 6, p. 7). Provi sions in this statute preclude the use of soil or ground water assessment data submitted during theSite Description - General Description and History

12 application process from being used for enforcement purposes (Ref. 6, p. 7).

In February 2005, based on the lack of progress, the FDEP Central District requested technical assi stance from the FDEP Site Investigation Section (SIS) for a contamination assessment of the Sanford Dry Cleaner property (Ref. 6, p. 7). The fieldwork investigation was conducted in several phases beginning in October 2005 and concluding in March 2006 (Ref. 6, pp. 7, 8). Site access was not granted by the owners (Palm Property Investments, LLC) of the property (Ref. 6, p. 8). As a result, ass essment activities were limited to properties adjacent to Sanford Dry Cleaners and the City of Sanford right-of-ways (Ref. 6, p. 8). The field investigation incl uded the installation of monitoring wells, the collection of soil samples, the collection of ground water samples from the newly installed and existing monitoring wells, and the collection of electrical conductivity logs (Ref. 6, p. 8).

On October 12-14, 2005, FDEP SIS installed 10 monitoring wells (Ref. 6, p. 8). In addition, five soil borings (SB1 to SB5) were advanced by hand auger and 10 soil samples were collected for VOC analyses (Ref. 6, p. 8). The soil samples were collected from the 1 to 2 foot and 3 to 4 foot depth intervals (Ref. 6, p. 8). Elevated levels of PCE (11,000 to 49,000 ug/kg), TCE (13,000 and 14,000 ug/kg), cis-1,2-DCE (38I to 1,800 ug/kg) and trans-1,2-DCE (22I and 220 ug/kg) were detected in the soil samples collected from SB2, SB3, and SB4 (Ref. 6, p. 8). These sample locations were situated near the backdoor entrance of the former Sanford Dry Cleaner building (Ref. 6, p. 8). The PCE and TCE levels exceeded both the State residential (8,800/6,400 ug/kg) and industrial (18,000/9,300 ug/kg) direct exposure SCTLs, as well as the ground water leachability SCTLs (both 30 ug/kg). A number of the cis-1,2-DCE detections also exceeded the ground water leachability SCTL (400 ug/kg) (Ref. 6, p. 8).

In all, 16 monitor wells were installed by SIS during the field investigation (Ref. 6, p. 8). This included six shallow surficial aquifer wells (DEP-2S, 3S, 4S, 6S, 8S, and 10S) and 10 deeper surficial aquifer wells (DEP-1D, 2D, 3D, 4DR, 5D, 6D, 7D, 8D, 9D, and 10D) (Ref. 6, p. 8). The shallow wells were installed to a depth of 15 feet while the deeper wells were installed to depths between 35 and 40 feet (Ref. 6, p. 8). PCE (6.2 to 75,000 ug/L), TCE (5.2 to 19,000 ug/L), cis1,2-DCE (190 to 5,900 ug/L), and vinyl chloride (1.5 to 400 ug/L) were detected in the ground water samples collected from monitoring wells DEP-3S, 3D, 4S, 5D, 6D, 10D, and MW-5 (Ref. 6, p. 8). These levels exceeded State GCTLs and/or federal MCLs (Ref. 6, p. 8). The highest levels of total chlorinated VOCs were detected in monitoring w ells DEP-3S and DEP-3D also located near the back door of the Sanford Dry Cleaners building (Ref. 6, p. 8). In its report, dated July 2007, FDEP concluded that Sanford Dry Cl eaners was the source of the chlorinated VOC contamination (Ref. 6, p. 8). FDEP also recommended additional soil and ground water assessment activities to de termine the full horizontal and vertical extent of contamination (Ref. 6, p. 8). This included additional assessment activities closer to and beneath the former Sanford Dry Cl eaners building (Ref. 6, p. 8).

On May 5, 2006, FDEP sent a letter to the former Sanford Dry Cleaners PRPs (Ref. 6, p. 8). The letter requested a meeting and informed the PRPs of the results of the 2005 FDEP investigation and the violations of environmental rules (Ref. 6, p. 8). No response to the letter was noted in the file (Ref. 6, p. 8). On December 11, 2006, FDEP sent a letter to the new owner, Lighthouse (Ref. 6, p. 8). Again, the letter informed the new owners of the results of the 2005 FDEP SIS investigation and violations of environmental rules (Ref. 6, p. 8).

On March 14, 2007, FDEP received a Site Specific Activities (SSA) application for the State Response Site Program, which is funded by an EPA Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) 128(a) Targeted Brownfields Assessment (TBA) grant (Ref. 6, p. 8). The application listed theSite Description - General Description and History

13 former Sanford Dry Cleaners property as the parcel of interest (Ref. 6, p. 8). The applicant was MOAH (Ref. 6, p. 8). The application, w hich was supported by the City of Sanford, proposed renovating the building and completing the historical restoration required by the City of Sanford Historic Preservation Board (Ref. 6, p. 8). MOAH proposed placing affordable housing (three residential units) on the second floor w hile providing retail space on the first
floor for the downtown Sanford arts and crafts community and an art museum (Ref. 6, p. 8). Monies for this effort would be generated through Grants for the Arts, fundraisers, and donations (Ref. 6, p. 8). MOAH proposed using CERCLA 128(a) TBA grant money to have FDEP conduct additional contamination assessment activities related to the former Sanford Dry Cleaners operations (Ref. 6, p. 8).

In February 2008, representatives from the FDEP Central District, FDEP Federal Programs Section (FPS) and a State Contractor (Mactec Engineering and Consulting [Mactec]) for the FPS, traveled to the property to meet with a MOAH representative, and MOAH’s environmental consultant (ACT) (Ref. 6, p. 9). The purpose of the meeting was to discuss the site conditions, required corrective actions, and the status of MOAH’s TBA ap plication (Ref. 6, p. 9). ACT presented FDEP with a brief summary of SIS results, the estimated plume boundary map and proposed soil boring locations to delineate the plume dimensions (Ref. 6, p. 9). The FDEP Central District representatives explained that the results of the SIS investigation confirmed that MOAH’s property was the source of an extensive ground water contamination plume and that MOAH needed to complete the Site Assessment, including a soil gas survey, to determine if there was a soil contaminant source on the property (Ref. 6, p. 9). The FD EP FPS representative explained that the extent of the ground water contamination documented by the SIS was severe, and that the costs to clean up the site would far exceed FDEP’s TBA/Site-Specific Activities (SSA) fundi ng ceiling and available budget (Ref. 6, p. 9). However, FDEP FPS told the MOAH representatives that the Department would consider using TBA/SSA f unding to conduct a limited source removal to assist MOAH if the results of the soil gas survey revealed a “soil con taminant source” that could be addressed under Department’s TBA/SSA program (Ref. 6, p. 9).

The MOAH representative explained that MOAH was planning to hold fundraisers to pay to clean up the site (Ref. 6, p. 9). He also told FDEP that MOAH had raised approximately $65,000 and would use the money to pay for the soil gas survey so FDEP could determine whether it would be feasible to conduct a limited source removal with the FDEP TBA/SSA funding (Ref. 6, p. 9). However, as a result of historical building code violations and costs incurred thr ough ACT’s efforts to secure grant funding from the City of Sanford, most of the funding had been exhausted (Ref. 6, p. 9). As a result, MOAH had limited financial resources to complete the soil gas survey in a timely fashion (Ref. 6, p. 9).

On March 21, 2008, ACT submitted a Source Investigation and Ancillary Task work plan for the Sanford Dry Cleaners site (Ref. 6, p. 9). ACT proposed a soil assessment including OVA soil screening, collecting soil samples for laboratory analysis, and sampling a nearby irrigation well (Ref. 6, p. 9). A soil boring and sampling grid was pr oposed, which included the extreme eastern portion of the building, as well as the area just east of the building (Ref. 6, p. 9). FDEP completed its review of the work plan on October 31, 2008 and concurred with most of the scope of work (Ref. 6, p. 9). However, FDEP recommended relocating more of the soil screening and sampling borings inside the former dry cleaning building (Ref. 6, p. 9). Also, FDEP suggested collecting the first soil screening/sample from the 0 to 6 inch interval rather than the 0 to 2 feet interval (Ref. 6, p. 9). According to FDEP, the scope of work was inadequate for the full and timely delineation of site contamination as well as remediation of the site (Ref. 6, p. 9). However, due to the limited financial resources of MOAH, FDEP allowed an incremental approach to future assessment work at the property (Ref. 6, p. 9). It became apparent that MOAH would have trouble raising enough money to remediate the entire ground water contaminant plume (Ref. 6, p.Site Description - General Description and History

14 9). As a result, FDEP FPS did not provide any TBA/SSA ass istance, and the FDEP Central District referred the site to the Bureau of Waste Cleanup for CERCLA site screening (Ref. 6, p. 9).

On December 5, 2008, the FDEP Program and Technical Support (PTS) Section completed a draft Pre-CERCLIS Screening Assessment (PSA) report of Sanford Dry Cleaners (Ref. 6, p. 9). The report was subsequently forwarded to EPA for review (Ref. 6, p. 9). A revised PSA report, addressing EPA review comments, was completed on January 5, 2009 (Ref. 6, p. 9). Based on levels of chlorinated VOCs in soil and shallow ground water, the presence of karst terrain (and karst aquifer), an eroded or missing confining unit, and the proximity to public drinking water wells serving a large population, the ground water migration pathway was determined to be a major concern (Refs. 6, p. 9; 15, pp. 1-11; 16, pp. 19, 31). FDEP recommended and EPA concurred that the property be placed in the EPA CERCLIS database, EPA’s list of potentially hazardous waste sites, for further CERCLA Superfund action (Ref. 6, pp. 9, 10).

On January 26, 2009, the FDEP PTS Section completed an Abbreviated Preliminary Assessment (APA) report for Sanford Dry Cleaners (Ref. 6, p. 10). The APA report reiterated many of the same findings as the earlier PSA report (Ref. 6, p. 10). Based on the previous and updated information, FDEP recommended a Site Inspection (SI) for Sanford Dry Cleaners (Ref. 6, p. 10).

In March 2009, after a r eview of information supplied to EPA by both MOAH and the City of Sanford, EPA determined that MOAH was the owner of the 121 South Palmetto Avenue property (Ref. 6, p. 10).

On March 26, 2009, representatives from FDEP PTS and the FDEP Central District conducted a site reconna issance of the former Sanford Dry Cleaners property (Ref. 6, p. 14). FDEP met with a representative from MOAH who provided access to the unoccupied building (Ref. 6, p. 14). The eastern building extension was the focus of the investigation (Ref. 6, p. 14). Plywood shutters had been put on the windows to prevent further access to the building by vagrants (Ref. 6, p. 14). Various forms of trash a nd garbage, left by vagrants, littered the interior (Ref. 6, p. 14). An area along the south wall was identified as a possible location of a dry cleaning machine (Ref. 6, p. 14). This area contained a trough with a drain as well as the remains of tie down bolts in the floor (Ref. 6, p. 14). Another drain was noted a short distance away (Ref. 6, p. 14). A small concrete
cutout was observed near the southeast c orner of the building extension near the back door (Ref. 6, p. 14). A walkthrough of the back alley and surrounding property was also conducted (Ref. 6, p. 14). All the previously installed wells were identified and noted (Ref. 6, p. 14).

In June 2009, the FDEP PTS Section conducted a SI jointly with Mactec (Ref. 6, pp. 1-288). The Final SI Report was submitted in September 2009 (Ref. 6). The SI was conducted to gather information to support a site d ecision regarding the need for further Superfund action (Ref. 6, p. 4). The assessment focused on obtaining soil samples ( both inside and outside the former dry cleaning building) for laboratory analyses, installation of monitoring wells (including inside the former dry cleaning building), and the collection of ground water samples for laboratory analyses (Ref. 6, p. 13). Chlorinated VOCs were detected in both soil and ground water samples collected from the property, including underneath the former Sanford Dry Cleaner building (Ref. 6, p. 19). A de tailed description of investigation results are provided in the following sections.Site Description - Characterization and Containment
Source No. 1

15 **2.2 SOURCE CHARACTERIZATION**

Number of the source : 1

Name and description of the source : Contaminated soil

HRS Source Type : Contaminated soil

During the June 2009 field sampling event, soil borings were advanced along the southern, southeastern, eastern, and northeastern edges of the former Sanford Dry Cleaner one-story extension building (Ref. 6, pp. 15, 48). These borings consisted of borings B-1 to B-4 (Ref. 6, pp. 15, 48). At the request of EPA, one additional boring (B-9) was advanced at the Sanford Dry Cleaning “Plant” situated at the current 113 South Palmetto Avenue (formerly 115 and 109 South Palmetto Avenue) location (Ref. 6, pp. 15, 55-56). In addition, four borings (B-5 to B-8) were advanced inside the former dry cleaning one-story building where dry cleaning operations reportedly took place (Ref. 6, pp. 15, 55-56). Two of these borings (B-5 and B-6) were situated near the area of the suspected dry cleaning machine(s) and drains (Ref. 6, pp. 15, 55-56).

The sampling intervals at each location were from 0 to 2 feet and 2 to 4 feet below ground surface (bgs) (Ref. 6, p. 15). It was noted that the planned subsurface soil sample (SDC-005-SB) from the B-8 location could not be collected due to auger refusal (Ref. 6, p. 15).

Surface soil samples collected in and around the Sanford Dry Cleaners property indicated elevated levels of PCE in nine field samples compared to the background sample (Ref. 6, pp. 40-41, 130, 138, 146, 156-163, 170, 178, 186, 194, 202). In addition, at least one breakdown product of PCE (TCE, cis-1,2-DCE, trans-1,2-DCE) was detected at elevated concentration(s) in seven surface soil samples (Ref. 6, pp. 40-41, 128-131, 136-139, 144-147, 156-163, 168-172, 176-179, 184-187, 192- 195, 200-203). Co-located subsurface soil samples contained elevated levels of PCE in eight field samples compared to t he background sample (Ref. 6, pp. 40-41, 126, 134, 142, 150, 166, 174, 182, 190, 198). PCE was also detected at an elevated concentration in the duplicate sample, SDC-004-DUP (Ref. 6, pp. 152- 155). In addition, at least one breakdown product of PCE (TCE, cis-1,2-DCE, trans-1,2-DCE) was detected at elevated concentration(s) in five subsurface soil samples (Ref. 6, pp. 40-41, 126, 134, 142, 166, 182, 198).

Location of the source, with reference to a map of the facility : Contaminated soil is loc ated in the central and eastern portions of the 121 South Palmetto Avenue parcel. Contaminated soil extends to the south of the property boundary. See Figure 3 of this Documentation Record for sample locations.

Containment : Release to ground water: Field sampling notes and soil borings revealed no evidence of a natural or man-made liner being encountered during the subsurface soil sampling activities at the property. In addition, ground water samples collected from monitoring wells located on and around the Sanford Dry Cleaners property have documented PCE, TCE, cis-1,2-DCE, and trans- 1,2-DCE contamination (Refs. 6, pp. 204-268).

Based on Table 3-2 of Reference 1, the contaminated soil yields a containment
value of 10.
**Ground Water Containment Factor Value: 10** Reference: 1, Section 3.1.2.1, Table 3-2Site Description-Hazardous Substances

Source No. 1

16 **2.4 Waste Characteristics**

**2.4.1 Hazardous Substances**

**- 2009 Site Investigation**

The surface and subsurface soil samples listed below were collected during the
June 2009 SI sampling event conducted jointly by the FDEP PTS and Mactec (Ref. 6, pp. 14, 15).

Surface soil samples were collected from 0 to 2 feet bgs according to the EPA Region 4 Science and Ecosystem Support Division (SESD) Environmental Investigations Standard Operating Procedures and Quality Assurance Manual (EISOPQAM) (Refs. 6, pp. 14-15; 13; 31; 32). Subsurface soil samples were collected from 2 to 4 feet bgs according to the EPA SESD EISOPQAM (Refs. 6, pp. 14-15; 13). The background surface and subsurface soil samples (SDC-001-SF/SB) were collected from an area believed to be unimpacted by facility operations ( Ref. 6, pp. 16). See Figure 3 of this Documentation Record for sample locations.

All samples collected during the 2009 SI field sampling event were analyzed by EPA Region 4 SESD Laboratory in Athens, Georgia (Ref. 6, p. 14). Surface and subsurface soil samples were a nalyzed for EPA Target Compound List (TCL) VOCs by EPA Method 8260B (Ref. 6, pp. 15-16, 116). Data validation was performed by EPA SESD according to the EPA Analytical Support Branch’s (ASB) Laboratory Operations and Quality Assurance Manual (LOQAM) (Ref. 6, pp. 116). Analytical data sheets and Quality Assurance/Quality Control (QA/QC) information are presented as Appendix D in Reference 6 of this Documentation Record (Ref. 6, pp. 106-268). Field notes are presented as Appendix E in Reference 6 (Ref. 6, pp. 269-288).

**Table 1. Surface Soil Samples–June 2009**

**Sample ID Hazardous** 
**Substance Hazardous** 
**Substance**
**Concentration (ug/kg)**  **Background**
**Concentration**

**(SDC-001-SF) (ug/kg)**  **MRL (ug/kg)**  **References**

SDC-002-SF PCE 29 0.53U 0.60 6, pp. 35, 40- 41, 107, 109, 112, 118, 119, 130, 138

SDC-002-SF TCE 1.5 0.53U 0.60 6, pp. 35, 40- 41, 107, 109, 112, 118, 119, 130, 138

SDC-003-SF PCE 670 0.53U 43 6, pp. 35, 40- 41, 107, 109, 113, 118, 119, 130, 146

SDC-003-SF Cis-1,2-

DCE 0.74 0.53U 0.61 6, pp. 35, 40- 41, 107, 109, 113, 118, 119, 129, 145Site Description-Hazardous Substances

Source No. 1

17 **Sample ID Hazardous** 
**Substance Hazardous** 
**Substance**
**Concentration (ug/kg)**  **Background**
**Concentration**

**(SDC-001-SF) (ug/kg)**  **MRL (ug/kg)**  **References**

SDC-003-SF TCE 17 0.53U 0.61 6, pp. 35, 40- 41, 107, 109, 113, 118, 119, 130, 146

SDC-004-SF PCE 31 0.53U 0.56 6, pp. 35, 40- 41, 107, 109, 113, 118, 119, 130, 158

SDC-005-SF PCE 1,500 0.53U 31 6, pp. 35, 40- 41, 107, 109- 110, 113, 118, 119, 130, 162

SDC-005-SF Cis-1,2-

DCE 1.8 0.53U 0.63 6, pp. 35, 40- 41, 107, 109- 110, 113, 118, 119, 129, 161

SDC-005-SF TCE 33 0.53U 0.63 6, pp. 35, 40- 41, 107, 109- 110, 113, 118, 119, 130, 162

SDC-006-SF PCE 730 0.53U 36 6, pp. 35, 40- 41, 108, 110, 113, 118, 119, 130, 170

SDC-006-SF TCE 6.5 0.53U 0.63 6, pp. 35, 40- 41, 108, 110, 113, 118, 119, 130, 170

SDC-007-SF PCE 21 0.53U 0.62 6, pp. 35, 40- 41, 108, 110, 114, 118, 119, 130, 178

SDC-008-SF PCE 8,800J*, C-7 0.53U 120 6, pp. 35, 40- 41, 108, 110, 114, 118, 119, 130, 186

SDC-008-SF TCE 340J*, C-7 0.53U 120 6, pp. 35, 40- 41, 108, 110, 114, 118, 119, 130, 186

SDC-008-SF Trans1,2-DCE 20 0.53U 0.56 6, pp. 35, 40- 41, 108, 110, 114, 118, 119, 130, 186Site Description-Hazardous Substances

Source No. 1

18 **Sample ID Hazardous** 
**Substance Hazardous** 
**Substance**
**Concentration (ug/kg)**  **Background**
**Concentration**

**(SDC-001-SF) (ug/kg)**  **MRL (ug/kg)**  **References**

SDC-009-SF PCE 39 0.53U 0.56 6, pp. 35, 40- 41, 108, 110, 114, 118, 119, 130, 194

SDC-010-SF PCE 70,000J*, C-7 0.53U 820 6, pp. 36, 40- 41, 108, 111, 114-115, 118, 119, 130, 202

SDC-010-SF Cis-1,2-

DCE 19 0.53U 0.52 6, pp. 36, 40- 41, 108, 111, 114-115, 118, 119, 129, 201

SDC-010-SF TCE 1,600J*, C-7 0.53U 820 6, pp. 36, 40- 41, 108, 111, 114-115, 118, 119, 130, 202

SDC-010-SF Trans1,2-DCE 2.9 0.53U 0.52 6, pp. 36, 40- 41, 108, 111, 114-115, 118, 119, 130, 202

Notes: MRL - Minimum Reporting Limit – Analyte concentration that corresponds to the lowest demonstrated level of acceptable quantitation. The MRL is sample-specific and accounts for preparation weights and volumes, dilutions, and moisture content of soils/sediments (Ref. 6, p. 119) ug/kg - Micrograms per kilogram U - Analyte not detected at or above reporting limit J* - The identification of the analyte is acceptable; the reported value is an estimate. Bias unknown. (Ref. 6, p. 119)

SDC - Sanford Dry Cleaners SF - Surface soil sample TCE - Trichloroethene (Trichloroethylene) PCE - Tetrachloroethene (Tetrachloroethylene) DCE - Dichloroethene C-7 - Sample container leaked during transportSite Description-Hazardous Substances

Source No. 1

19 **Table 2. Subsurface Soil Samples–June 2009**

**Sample ID Hazardous** 
**Substance Hazardous** 
**Substance**
**Concentration (ug/kg)**  **Background**
**Concentration**

**(SDC-001-SB) (ug/kg)**  **MRL (ug/kg)**  **References**

SDC-002-SB PCE 48 0.53U 0.57 6, pp. 35, 40- 41, 107, 109, 112, 118, 126,
134

SDC-002-SB TCE 1.1 0.53U 0.57 6, pp. 35, 40- 41, 107, 109, 112, 118, 126,
134

SDC-003-SB PCE 3,800 0.53U 120 6, pp. 35, 40- 41, 107, 109, 112-113, 118, 126, 142

SDC-003-SB Cis-1,2-

DCE 1.5 0.53U 0.58 6, pp. 35, 40- 41, 107, 109, 112-113, 118, 125, 141

SDC-003-SB TCE 21 0.53U 0.58 6, pp. 35, 40- 41, 107, 109, 112-113, 118, 126, 142

SDC-004-SB PCE 42 0.53U 0.55 6, pp. 35, 40- 41, 107, 109, 112-113, 118, 126, 150

SDC-004-

SB-DUP PCE 16 0.53U 0.45 6, pp. 35, 40- 41, 107, 109, 112-113, 118, 126, 154

SDC-006-SB PCE 3,200J 0.53U 53 6, pp. 35, 40- 41, 107-108, 109-110, 112- 113, 118, 126,
166

SDC-006-SB TCE 5.1 0.53U 0.46 6, pp. 35, 40- 41, 107-108, 109-110, 112- 113, 118, 126,
166

SDC-007-SB PCE 1.7 0.53U 0.63 6, pp. 35, 40- 41, 107-108, 109-110, 112, 114, 118, 126,
174Site Description-Hazardous Substances

Source No. 1

20 **Sample ID Hazardous** 
**Substance Hazardous** 
**Substance**
**Concentration (ug/kg)**  **Background**
**Concentration**

**(SDC-001-SB) (ug/kg)**  **MRL (ug/kg)**  **References**

SDC-008-SB PCE 1,100J 0.53U 0.58 6, pp. 35, 40- 41, 107-108, 109-110, 112, 114, 118, 126,
182

SDC-008-SB Cis-1,2-

DCE 14 0.53U 0.58 6, pp. 35, 40- 41, 107-108, 109-110, 112, 114, 118, 125,
181

SDC-008-SB TCE 57 0.53U 0.58 6, pp. 35, 40- 41, 107-108, 109-110, 112, 114, 118, 126,
182

SDC-008-SB Trans1,2-DCE 1.2 0.53U 0.58 6, pp. 35, 40- 41, 107-108, 110, 112, 114, 118, 126, 182

SDC-009-SB PCE 18 0.53U 0.54 6, pp. 35, 40- 41, 107-108, 110, 112, 114, 118, 126, 190

SDC-010-SB PCE 1,900J 0.53U 27 6, pp. 36, 40- 41, 107-108, 110, 112, 114, 118, 126, 198

SDC-010-SB Cis-1,2-

DCE 2.3 0.53U 0.59 6, pp. 36, 40- 41, 107-108, 110, 112, 114, 118, 125, 197

SDC-010-SB TCE 64 0.53U 0.59 6, pp. 36, 40- 41, 107-108, 110, 112, 114, 118, 126, 198

Notes: MRL - Minimum Reporting Limit – Analyte concentration that corresponds to the lowest demonstrated level of acceptable quantitation. The MRL is sample-specific and accounts for preparation weights and volumes, dilutions, and moisture content of soils/sediments (Ref. 6, p. 119) ug/kg - Micrograms per kilogram U - Analyte not detected at or above reporting limit J - The identification of the analyte is acceptable; the reported value is an estimate. Bias unknown (Ref. 6, p. 119) DUP - Duplicate sampleSite Description-Hazardous Substances

Source No. 1

21 SDC - Sanford Dry Cleaners SB - Subsurface soil sample TCE - Trichloroethene (Trichloroethylene) PCE - Tetrachloroethene (Tetrachloroethylene) DCE - Dichloroethene22 Site Description-Hazardous Substances
Source No. 1

**2.4.2 Hazardous Waste Quantity**

**2.4.2.1.1 Hazardous Constituent Quantity**

Insufficient data is available to calculate the hazardous constituent quantity.

Hazardous Constituent Quantity Value (S): Not Scored

**2.4.2.1.2 Hazardous Wastestream Quantity**

Insufficient data is available to calculate the hazardous wastestream quantity.

Hazardous Wastestream Quantity Value (W): Not Scored

**2.4.2.1.3 Volume**

Insufficient data is available to calculate the volume.

Volume Assigned Value (V): 0

**2.4.2.1.4 Area** The area of contamination is a line formed by sampling locations (counterclock wise order) SDC-0 04-SF/SB, SDC-002-SF/SB, SDC-007-SF/SB, SDC-006-SF/SB, SDC-010-SF/SB, and SDC-009-SF/SB collected du ring the 2009 SI (Ref. 6, pp. 1-31). Sampling was limited to a small portion of the property; it is unclear whether the contamination is continuous throughout the source area. The source area is unknown, but was determined to be >0 square feet (ft 2 ) (Ref. 6, pp. 55, 56).

Equation for hazardous waste quantity evaluation for the contaminated soil is A/34,000. Therefore, >0 ft 2 /34,000 = >0

Area Assigned Value: >0 Reference: 1, Table 2-5

**2.4.2.1.5 Source Hazardous Waste Quantity Value**

**Source Hazardous Waste Quantity Value: >0** Reference: 1, Section 2.4.2.2Site Description - Summary of Source Descriptions

**SUMMARY OF SOURCE DESCRIPTIONS**

**Source**

**No. Source Hazardous**  **Waste Quantity**

**Value Containment** 

**Ground Water S**  **urface**

**Water Soil**  **Air**

**Gas Particulate** 

1 >0 10 NS NS NS

SUM >0

Notes: NS- Not Scored

Reference: 1, Section 2.4.2.2, Table 2-6

Description of Other Possible Sources:

No other sources are known to exist at the site.

23Ground Water-Observed Release Surficial/Floridan Aquifer

24 **3.0 GROUND WATER MIGRATION PATHWAY**

**3.0.1 GENERAL CONSIDERATIONS** Ground Water Migration Pathway Description

**Regional Geology/Aquifer Description** : The source is located within the Coastal Plain physiographic province of the state of Florida, and more particularly, in the northern center portion of Seminole County (Refs. 3; 14). The topography of Seminole County can be divided into two types, a flat lowland, characteristic of the area adjacent to Lake Monroe; and hilly uplands, characteristic of the area in the vicinity of Lake Mary (Ref. 16, pp. 14-15). The Sanford property is located adjacent to Lake Monroe in the flat lowland at an elevation of approximately 15 feet above mean sea level (Ref. 3). The land surface altitude in the lowland area ranges from approximately 5 feet above mean sea level near the St. Johns River to approximately 30 feet above mean sea level where the lowland merges into the hilly upland (Refs. 3; 16, p. 15). The source is underlain in descending stratigraphic order by sand of Pleistocene to Recent age, Pliocene and Miocene deposits, the Avon Park Limestone, and the Lake City Limestone (Refs. 15, pp. 1- 11; 16, pp. 9, 19, 31).

The source is directly underlain by Pleistocene and Recent deposits that consist of yellow to white to clear, fine to coarse grained quartz sand with an estimated hydraulic conductivity of approximately 1x10 -2 centimeters per second (cm/s) (Refs. 1, p. 31; 15, pp. 1-11; 16, p. 25). These deposits mantle the entire County and range in thickness from 10 to 80 feet (Refs. 15, pp. 1-11; 16, p. 25). Beneath the level lowlands of Seminole County, thin layers of hardpan have been formed in some locations at a depth of 3 to 5 feet by the cementation of sand by iron oxide (Ref. 16, p. 25).

Pliocene and Miocene deposits consisting of sticky blue clay and shell beds underlie the Pleistocene to Recent deposits (Ref. 16, pp. 19, 24). Based on lithology, the hydraulic conductivity of these sediments is estimated to be approxi mately 1x10 -6 cm/s (Ref. 1, p. 31). The Pliocene to Miocene deposits have been identified in borings in the northern portion of Seminole County and range in thickness from 5 to 30 feet (Ref. 15, pp. 1-11). In Sanford, these deposits unconformably overlie the Avon Park Limestone (Ref. 16, pp. 19, 24, 31).

The Avon Park Limestone occurs throughout the Florida peninsula and consists of layers of light gray to brown, soft to hard, porous to dense, granular to chalky limestone (Ref. 16, p. 21). In the vicinity of the Sanford property, the Avon Park Limestone dir ectly underlies the Pliocene and Miocene deposits (Ref. 16, pp. 19, 31). In the City of Sanford, the elevation of the top of the Avon Park Limestone is 92 feet below mean sea level (Ref. 16, p. 31). The formation has been irregularly dolomitized since deposition; however, the original structures of the rock have generally been preserved (Ref. 16, p. 21). Based on lithology, the Avon Park has an esti mated hydraulic conductivity of 1x10 -2 cm/s (Ref. 1, p. 31). The Avon Park underlies much of the Florida peninsula and is over 500 feet thick in Seminole County (Ref. 16, p. 21). West of the City of Sanford, the Avon Park slopes approx imately 20 feet per mile west toward the Wekiva River (Ref. 16, p. 22).

The Lake City Limestone underlies the Avon Park at an elevation of approximately 600 feet below sea level (Ref. 16, pp. 19-20). The Lake City is comprised of alternating layers of hard, brown, porous crystalline dolomite, and hard cream to tan chalky limestone and dolomitic limestone (Ref. 16, p. 20). Based on the lithology, the hyd raulic conductivity of the Lake City Limestone is approximately
1x10 -2 cm/s (Ref. 1, p. 31). The Lake City is greater than 400 feet thick inGround Water-Observed Release Surficial/Floridan Aquifer

25 southwestern Seminole County (Ref. 16, p. 20). **Site Geology/Aquifer Description** :

A number of borings have been advanced at the property up to a depth of 54 feet below land surface (bls) (Ref. 6, p. 11). Medium to fine-grained sands were
encountered from land surface to 36 feet bls (Ref. 6, p. 11). The sands varied in color from dark to light gray and light brown to tan with shell fragments present from 24 to 36 feet bls (Ref. 6, p. 11). Sandy clay was encountered from 36 to 40 feet bls and greenish-gray clay, with minor shell fragments, was encountered between 40 to 44 feet bls (Ref. 6, p. 11). The top of the Floridan aquifer is approximately 80 to 90 feet bls in downtown Sanford and the water level is approximately 4 to 5 feet bls (Ref. 6, p. 12). FDEP investigations at the site during No vember 2005 and March 2006 indicated that the ground water flow direction varies across the Sanford property (Ref. 6, p. 12). The variation in ground water flow direction may be attributable to the existence of a ground water divide through the property or possibly due to errors induced through lack of control points or ground water modeling oversights (Ref. 6, p. 12).

**- Aquifer/Stratum 1 (uppermost): Surficial Aquifer**

**Description:** The surficial aquifer in Florida includes any otherwise undefined aquifers that are present at the land surface (Ref. 28, p. 1). The sand and shell beds within the Pliocene to Miocene deposits yield small to moderate supplies of water to wells; however, most wells installed at this depth are open to the underlying limestone and draw water from both sources (Refs. 16, p. 25; 28, p. 4). The surficial aquifer in Florida is generally less than 50 feet thick; however, based on the thickness of these deposits and the elevation of the top of the underlying Avon Park Limestone, the aquifer is likely at least 90 feet thick in the City of Sanford (Refs. 16, pp. 25, 31; 28, p. 1). The water t able configuration of the surficial aquifer is generally a subdued reflection of the topography of the area (Ref. 28, p. 2). Ground water flow is under unconfined, or water table conditions in the City of Sanford a nd no confining layers are documented between the surficial aquifer and the underlying Floridan Aquifer System (Refs. 16, pp. 19, 24-25, 31; 28, p. 2). The flow direction is gener ally toward large surface water bodies, and in the City of Sanford, likely toward Lake Monroe (Refs. 3; 28, p. 2). The aquifer is recharged through the infiltration of precipitation (Ref. 28, p. 2). The intermediate aquifer is not present in Seminole County (Ref. 28, p. 5).

**- Aquifer/Stratum 2 (deepest): Floridan Aquifer System**

**Description:** The Floridan Aquifer System underlies the source and is comprised of the Avon Park Limestone and the Lake City Limestone in Seminole County (Refs. 16, p. 28; 28, p. 7). The water-bearing characteristics of the Avon Park and Lake City are due primarily to the wide areal extent, thickness, and high permeability (Ref. 16, p. 22). Most wells completed in the Floridan Aquifer System in Seminole County are screened in the Avon Park formation (Refs. 16, p. 22; 25, pp. 7-9). Municipal wells within the 4-mile Target Distance Limit of the source are screened in the Floridan Aquifer System at depths ranging from 162 to about 700 feet below land surface. The municipal wells are situated at approximately 50 feet above mean sea level; therefore, the wells are co mpleted at depths ranging from 112 to 650 feet below mean sea level in the Avon Park formation of the Floridan aquifer system (Refs. 3; 16, p. 19; 25, pp. 7-9). The general flow of water within the Floridan Aquifer System in Seminole County is toward the northeast (Ref. 16, p. 30).

The Floridan Aquifer System is a carbonate system that is readily dissolved whereGround Water-Observed Release Surficial/Floridan Aquifer

26 it is exposed at the surface or is overlain by only a thin layer of confining material (Refs. 3; 28, p. 10; 29, p. 1). Precipitation absorbs some carbon dioxide from the atmosphere and as precipitation falls much more carbon dioxide is absorbed by organic material, forming a weak carbonic acid (Ref. 28, p. 10). The carbonic acid dissolves the limestone and dolomite of the Floridan Aquifer system, initially by enlarging pre-existing openings such as pores between grains of limestone or fractures (joints) in the rock (Refs. 28, p. 10; 29, p. 1). These small solution openings become larger as more acidic water moves through the aquifer; eventually, the openings may be tens of feet in diameter (Refs. 3; 28, p. 10). The end result of dissolution of carbonate rocks is karst topography/terrain characterized by caves, sinkholes, and other dissolution openings (Refs. 3; 28, p. 10; 29, p. 1). Dissolution of carbonate rocks is greatest where ground water circula tion is most vigorous. Water is able to move through the Floridan Aquifer System in Seminole County because the confining layer is thin, absent, or both (Refs. 16, pp. 19, 31; 28, pp. 10-11; 29, p. 1).

**- Aquifer Interconnections/Distance from Source**

**Description:** No confining layers are present beneath the source that would prevent ground water from entering the Floridan aquifer (Refs. 15, pp. 1-11; 16, pp. 19, 31). Sinkholes are predominant in Seminole County (Refs. 3; 18, p. 1; 29, p. 1). In Seminole County, cover subsidence and cover collapse sinkholes are the most common and according to the Florida Sinkhole Database and FDEP (Refs. 18, p. 1; 29, p. 1). Many of the lakes in Seminole County were likely formed by the collapse of the surface sand and clay into caverns formed by the solution and
removal of the und erlying limestone by circulating ground water (Ref. 16, p. 15). Multiple sinkholes are documented within a 4 mile radius of the Sanford source; although no sinkholes are located within 2-miles of the source (Refs. 3; 18, p. 1; 29, p. 1).

**- Aquifer Discontinuities within Target Distance Limit**

**Description:** Geologic data in Seminole and Volusia Counties suggest the presence of a downthrown fault block along the northern edge of Seminole County and the south edge of Volusia County (Ref. 16, pp. 26, 31). The fault block underlies part of the St. Johns River Valley and most of Lake Monroe (Ref. 16, pp. 26, 31). The surface expression of the fault is shown by the westerly offset of the St. Johns River along the no rthern portion of Seminole County (Ref. 16, p. 26). The source is located on the downward side (north side) of the east west trending fault (Ref. 16, p. 31).Ground Water-Observed Release Surficial/Floridan Aquifer

27 **SUMMARY OF AQUIFER(S) BEING EVALUATED**

**Aquifer**

**No. Aquifer Name**  **Is Aquifer**

**In t**  **erconnected with Upper Aquifer** 
**within 2 miles?**
**(Y/N/NA) Is Aquifer** 
**Continuous**
**within 4-mile**

**TDL? (Y/N) Is Aquifer** 

**Karst?**

**(Y/N)**

1 Surficial NA Y N

2 Floridan Y Y Y

**3.1 LIKELIHOOD OF RELEASE**

**3.1.1 OBSERVED RELEASE**

Aquifer Being Evaluated: Surficial/Floridan Aquifer

**Direct Observation**

An observed release by direct observation has not been documented.Ground Water-Observed Release Surficial/Floridan Aquifer

28 **Chemical Analysis**

**Monitoring Well Samples**

**2009 SI Sampling Investigation**

**-**

**Contaminated Samples**

In June 2009, ground water samples were collected from six newly installed monitoring wells and several existing wells (Ref. 6, p. 17). Monitoring wells MW-1 (shallow) and DEP1D (deep) were used to monitor background ground water conditions (Ref. 6, p. 17). The wells were sampled using low flow/low stress sampling techniques in accordance with FDEP’s Standard Operating Procedures and the EPA Region 4 F ield Branches Quality System and Technical Procedures (Refs. 6, p. 17; 20, pp. 1-30). All ground water samples were a nalyzed for TCL VOCs, EPA Method 8260C (Ref. 6, pp. 17, 211). Analytical results were validated by EPA SESD (Ref. 6, p. 211). The table below details the contaminated shallow and deep wells identified at the Sanford Dry Cleaners property (Ref. 6, pp. 36-37, 46-48, 204-209). Samples with “SDS” as a prefix were collected from the newly installed wells (Ref. 6, p. 20). Samples with “DEP” or “MW” as a prefix were collected from the existing wells installed during the FDEP SIS and Former Thrifty Service Station investigations, respectively (Ref. 6, p. 20). See Figure 3 of this Documentation Record for monitoring well locations.

**Sample ID Total**  **Depth a**  **(feet) Depth to** 
**Water b**  **(feet) Sample Location**  **Date Sampled**  **References**

MW-001-GW (Background) 13 4.91 Existing monitoring
well MW-1 located
south-southwest of former dry cleaning
b uilding 6/2/2009 6, pp. 36, 46- 48, 204, 206, 209, 277

SDC-002-GW 9.25 4.00 Well i nstalled through borehole B-5 inside former dry cleaning building near trough and drain 6/3/2009 6, pp. 36, 46- 48, 204, 206, 209, 281

SDC-003-GW 8.75 4.11 W e ll installed through borehole B-7 inside former dry cleaning building near cutout 6/3/2009 6, pp. 36, 46- 48, 204, 207, 209, 282

DEP-03S-GW 15 4.82 Existing monitoring
well DEP-3S located immediately east of former dry cleaning building 6/2/2009 6, pp. 37, 46- 48, 204, 206, 208, 276

DEP-1D-GW

(Background) 35 4.50 Existing monitoring
well DEP-1D located
south-southwest of former dry cleaning building 6/2/2009 6, pp. 36, 46- 48, 204, 206, 208, 276Ground Water-Observed Release Surficial/Floridan Aquifer

29 **Sample ID Total**  **Depth a**  **(feet) Depth to** 
**Water b**  **(feet) Sample Location**  **Date Sampled**  **References**

DEP-03D-GW 35 4.95 Existing monitoring
well DEP-3D located immediately east of former dry cleaning building 6/2/2009 6, pp. 37, 46- 48, 204, 206, 208, 275

DEP-05D-GW 35 4.55 Existing monitoring
well DEP-5D located

east-northeast of former dry cleaning building 6/2/2009 6, pp. 37, 46- 48, 204, 206, 208, 278

SDC-012D-GW 50 4.05 Deep w ell installed on right-of-way of east

s ide of South Sanford

Avenue near entrance to Post Office 6/3/2009 6, pp. 46-48, 205, 207, 209,
280

Notes:

a Total depth and screened interval measured from ground surface (Ref. 6, pp. 46-47)

b Depth to water measured from below top of casing (Ref. 6, pp. 46-47)

The ground water samples listed below were collected during the 2009 SI field sampling event conducted by jointly by FDEP and Mactec (Ref. 6, p. 14). Monitoring wells MW-1 (MW-01-GW) and DEP1D (DEP-1D-GW) were used to monitor background ground water conditions (Ref. 6, pp. 17, 44-45, 224-226, 242-244). Ground water samples collected during the 2009 SI field sampling event were analyzed for EPA TCL VOCs by EPA Region 4 SESD in Athens, Georgia (Ref. 6, pp. 14, 17, 204-268). Data validation was performed by the EPA SESD (Ref. 6, pp. 211). Analytical data sheets and Quality Assurance/Quality Control (QA/QC) information are presented as Appendix D in reference 6 of this Documentation Record (Ref. 6, pp. 204-268). See Figure 3 of this Documentation Record for sample locations.

**Shallow Wells**

**Sample ID Hazardous**  **Substance Concentration**  **(ug/L) B**  **ackground (MW-01-GW**  **) (ug/L)**  **MRL (ug/L)**  **References**

DEP-03S-GW Cis-1,2-DCE 3,500 0.50U 100 6, pp. 204, 214, 231, 243

DEP-03S-GW PCE 8,300 0.50U 100 6, pp. 204, 214, 232, 244

DEP-03S-GW Trans-1,2-

DCE 750 0.50U 100 6, pp. 204, 214, 232, 244

DEP-03S-GW TCE 5,000 0.50U 100 6, pp. 204, 214, 232, 244Ground Water-Observed Release Surficial/Floridan Aquifer

30 **Sample ID Hazardous**  **Substance Concentration**  **(ug/L) B**  **ackground (MW-01-GW**  **) (ug/L)**  **MRL (ug/L)**  **References**

DEP-03S-GWDUP Cis-1,2-DCE 3,400 0.50U 100 6, pp. 204, 214, 234, 243

DEP-03S-GWDUP PCE 8,900 0.50U 100 6, pp. 204, 214, 235, 244

DEP-03S-GWDUP Trans-1,2-

DCE 760 0.50U 100 6, pp. 204, 214, 235, 244

DEP-03S-GWDUP TCE 5,100 0.50U 100 6, pp. 204, 214, 235, 244

SDC-002-GW Cis-1,2-DCE 8.4 0.50U 0.50 6, pp. 204, 214, 243, 252

SDC-002-GW PCE 32 0.50U 0.50 6, pp. 204, 214, 244, 253

SDC-002-GW TCE 3.8 0.50U 0.50 6, pp. 204, 214, 244, 253

SDC-003-GW Cis-1,2-DCE 15 0.50U 10 6, pp. 204, 214, 243, 255

SDC-003-GW PCE 870 0.50U 5.0 6, pp. 204, 214, 244, 256

SDC-003-GW TCE 140 0.50U 5.0 6, pp. 204, 214, 244, 256

Notes: ug/L - Micrograms per liter MRL - Minimum Reporting Limit – Analyte concentration that corresponds to the lowest demonstrated level of acceptable quantitation. The MRL is sample-specific and accounts for preparation weights and volumes, dilutions (Ref. 6, p. 119)

SDC - Sanford Dry Cleaners DUP - Duplicate
GW - Ground water MW - Monitor well
S - Shallow U - Analyte not detected at or above reporting limit PCE - Tetrachloroethene/tetrachloroethylene DCE - Dichloroethene/dichloroethylene TCE - Trichloroethene/trichloroethyleneGround Water-Observed Release Surficial/Floridan Aquifer

31 **Deep Wells**

**Sample ID Hazardous**  **Substance Concentration**  **(ug/L) B**  **ackground (DEP-1D-GW)**  **(ug/L) MRL**  **(ug/L) References** 

DEP-03D-GW PCE 36,000 0.50U 500 6, pp. 204, 226,
229

DEP-03D-GW TCE 2,000 0.50U 200 6, pp. 204, 226,
229

DEP-05D-GW Cis-1,2-DCE 480 0.50U 100 6, pp. 204, 225,
237

DEP-05D-GW PCE 17,000 0.50U 100 6, pp. 204, 226,
238

DEP-05D-GW TCE 5,300 0.50U 100 6, pp. 204, 226,
238

SDC-012D-GW Cis-1,2-DCE 98 0.50U 2.0 6, pp. 205, 225,
264

SDC-012D-GW Trans-1,2-

DCE 6.0 0.50U 0.50 6, pp. 205, 226,
265

SDC-012D-GW TCE 40 0.50U 0.50 6, pp. 205, 226,
265

Notes: ug/L - Micrograms per liter MRL - Minimum Reporting Limit – Analyte concentration that corresponds to the lowest demonstrated level of acceptable quantitation. The MRL is sample-specific and accounts for preparation weights and volumes, dilutions (Ref. 6, p. 119) SDC - Sanford Dry Cleaners
GW - Ground water MW - Monitor well U - Analyte not detected at or above reporting limit PCE - Tetrachloroethene/tetrachloroethylene TCE - Trichloroethene/trichloroethylene DCE - Dichloroethene/dichloroethyleneGround Water-Observed Release Surficial/Floridan Aquifer

32 **Attribution:**

The Sanford Dry Cleaners property is comprised of two contiguous parcels located on South Palmetto Avenue, in the historic section of downtown Sanford, Seminole County, Florida (Refs. 3; 4, p. 1; 5, pp. 1, 2; 6, p. 4). The numeric s treet addresses of the site parcels have changed over time, but are currently addressed 121 and 113 South Palmetto Avenue (Refs. 3; 4, p. 1; 5, pp. 1, 2; 6, p. 4). The property is approximately one acre in size (Ref. 6, p. 5). The 121 South Palmetto Avenue building consists of two floors (5,365 square feet) with a single story building extending to the east of the main building (Ref. 6, p. 5). The 121 South Palmetto Avenue building is the last known location of the dry cleaners (Ref. 6, p. 5). The 113 South Palmetto Avenue property contains two single-story buildings with connected facades (Ref. 6, p. 5). The building on the northern portion of the property is slightly taller, was built in the late 19th Century, and is included on the National Register of Historic Pl aces (Ref. 6, p. 5). This building is sometimes referred to as the old E.E. Brady Li very and is of brick construction, overlaid with stucco (Ref. 6, p. 5). Directly behind the building is a boiler room of concrete block construction (Ref. 6, p. 5). The slightly shorter building, located on the southern portion of the 113 South Palmetto Avenue property, was reportedly built in the 1970s and is also overlaid with stucco (Ref. 6, p. 5). The property is bordered by Investors Realty Network (former Thrifty Servi ce Station) to the south; an alley to the east with a plumbing business (Exact Plumbing) and a home style restaurant across the alley; and South Palmetto Avenue to the west, with a pottery store and Wine Company across the street; and the City of Sanford historic firehouse to the north of the Site (Ref. 6, p. 5). An art studio and residence occupy the first and second floor, respectively, of the firehouse (Ref. 6, p. 5).

The property has been owned and operated by a number of different people and entities over the years; however, it has been primarily operated as a dry cleaning and laundry business (Ref. 6, p. 5). The dry cleaning business was first established on the 121 South Palmetto Avenue property in the 1940s (Ref. 6, p. 5). The 1947 Sanborn Fire Insurance map indicates that the easternmost building of the current 121 South Palmetto Avenue property operated as a “Drycle aner” (Refs. 6, p. 5; 7, p. 3). In 1964, the adjoining property, now known as 113 South Palmetto Avenue was purchased and operated as a dry cleaning and laundry business (Ref. 6, p. 5). According to the State of Florida Division of Corporations, Sanford Dry Cleaners incorporated in 1983 and dissolved in 1997 (Ref. 6, p. 5).

Very little is known regarding the actual day to day operations at Sanford Dry Cleaners (Ref. 6, p. 6). However, during the 1960s and early 1970s, the owners/operators of Sanford Dry Cleaners reportedly used Stoddard solvents, a petroleum-based cleaning agent (Ref. 21, p. 3). However, beginning in the early 1970s, the facility used PCE as a cleaning agent, which is consistent with the historic use of dry cleaning solutions in the industry (Refs. 6, p. 6; 21, p. 3). Prior to the promulgation of environmental regulations in 1980, and for some time afterward, waste disposal by dry cleaners was unregulated (Ref. 21, p. 3).

PCE was first formulated in 1821 (Ref. 22, p. 3). PCE contamina tion of land, air, surface water, and ground water are primarily a result of industrial spillage or improper disposal during manufacture or use (Ref. 23, p. 14). By the 1960s and early 1970s, it had become a widely used solvent in dry cleaning, metal degreasing, and other industries (Ref. 22, p. 3). In the late 1970s, most industries moved away from the use of PCE (Ref. 22, p. 3). The exception was the dry cleaning industry (Ref. 22, p. 3). By the early 1980s, dry cleaners used the majority of the PCE in the nation (Ref. 22, p. 3). In the late 1980s, dry cleaners used 56% of the PCE in the United States (Ref. 22, p. 3). Industrial disposal is the likely source of PCE contamination in drinking water (Ref. 23, p. 22). PCE volatilizes readily from soils and is resistant to abiotic and aerobic degradation in water; however, it is biodegraded under anaerobic conditions to yield TCE, DCE, vinyl chloride, ethane,Ground Water-Observed Release Surficial/Floridan Aquifer

33 and ethene (Ref. 23, p. 9). PCE is mobile in ground water in the absence of any removal process and leaches rapidly through sandy soil (Ref. 23, p. 15).

Surface and subsurface soil containing PCE (and/or daughter products) is documented to exist at the Sanford Dry Cleaner source (Refs. 6, pp. 1-288; 21). Although the sampling investigation was limited to a specific area, the observed contamination exists on the central and eastern portions of the current 121 South Palmetto Avenue parcel, and continues off the property to the sou th (Ref. 6, pp. 1-288). This area is reportedly where the dry cleaning machine and drains existed (Ref. 6, p. 15). PCE and its daughter products have been detected in monitoring wells on the property at elevated concentrations (Ref. 6, pp. 44-45, 227-238, 251-256, 263-265).

A radial search for businesses within 2 miles of the Sanford Dry Cleaners property was conducted by Environmental Data Resources, Inc. (EDR) (Ref. 24, pp. 1-195). The EDR radial report searched multiple databases including, but not limited to, federal, state, tribal, local land records, emergency release reports, and EDR proprietary records (Ref. 24, pp. 4-5). According to the EDR radial report, there is one dry cleaning facility (Sunshine Laundry and Cleaners) that is part of the State Priority Cleaners sites located at 418 Sanford Avenue, approximately 0.5 miles south-southeast of Sanford Dry Cleaners (Ref. 24, pp. 9, 12-13, 54). Additionally, a CERCLA Exempt Small Quantity Generator (CESQG), Fantastic Cleaners, is located within 0.125 to 0.25 mile west-southwest of Sanford Dry Cleaners (Ref. 24, pp. 6, 10, 12-13, 44-47). CESQG are facilities listed as generating less than 100 kilograms (kg) of hazardous waste, or less than 1 kg of acutely hazardous waste per month (Ref. 24, pp. 6, 14). According to the U.S. Occupational Safety & Health Administration (OSHA), PCE, TCE, and other solvents are common dry cleaning operations (Ref. 30). According to EDR, additional sites could not be mapped due to poor or inadequate address information and are referred to as “o rphan sites” (Ref. 24, p. 11). Their exact location and distance from Sanford Dry Cleaners is unknown; however, they do not appear to be properties of concern (Ref. 24, p. 11). These “orphan sites” include supermarkets, tire shops, auto auction de alers, trash sites and dumps, car rental businesses, and fire stations (Ref. 24, p. 11). Several additional businesses are located within a 2 mile radius of Sanford Dry Cleaners; however, based on their listing, are not considered to be potential contributors to the Sanford Dry Cleaners contamination (Ref. 24, pp. 1-195). The general flow of water within the Floridan aquifer in Seminole County is toward t he northeast (Ref. 16, p. 30).

**Hazardous Substances Released:**

Cis-1,2-Dichloroethene (cis-1,2-DCE) Trans-1,2-Dichloroethene (trans-1,2-DCE) Tetrachloroethene/tetrachloroethylene (PCE) Trichloroethene/trichloroethylene (TCE)

**Ground Water Observed Release Factor Value: 550**Ground Water-Toxicity/Mobility

34 **3.2 WASTE CHARACTERISTICS**

**3.2.1 TOXICITY/MOBILITY**

**Hazardous**
**Substance Source** 

**No. Toxicity** 

**Factor**
**Value Mobility** 

**Factor**
**Value Toxicity/**  **Mobility Does Hazardous** 
**Substance Meet**
**Observed Release by chemical**  **analysis? (Y/N) References** 

PCE 1 100 1 100 Y 1, Table 3-9; 2, p.
10

TCE 1 10,000 1 10,000 Y 1, Table 3-9; 2, p. 51
Cis-1,2- DCE 1 100 1 100 Y 1, Table 3-9; 2, p. 5

Trans1,2-DCE 1 100 1 100 Y 1, Table 3-9; 2, p. 5

**Toxicity/Mobility Factor Value: 10,000** (Ref. 1, Table 3-9)35 Ground Water-Hazardous Waste Quantity

**3.2.2 HAZARDOUS WASTE QUANTITY**

**Source No. Source Type**  **Source Hazardous Waste Quantity**

1 Contaminated Soil 10

**SUM = 10**

Sum of Values: 10*

*The hazardous constituent quantity is not adequately established for the source. The value of 10 is assigned because the hazardous constituent quantity is not adequately determined for the source, there are no Level I or Level II targets for the ground water mig ration pathway, and there has been no removal action that would impact the hazardous waste quantity evaluation (Ref. 1, Section 2.4.2.2 and Table 2-6).

Hazardous Waste Quantity Factor Value: 10 (Ref. 1, Section 2.4.2.2 and Table 2-6)

**3.2.3 WASTE CHARACTERISTICS FACTOR CATEGORY VALUE**

Toxicity/Mobility Factor Value: 10,000 Hazardous Waste Quantity Factor Value: 10

Toxicity/Mobility Factor Value (10,000) X Hazardous Waste Quantity Factor Value (10) = 100,000

**Waste Characteristics Factor Category Value: 18** (Ref. 1, Table 2-7)Ground Water-Targets

36 **3.3 TARGETS**

The majority of residents within a 4-mile radius of the Sanford Dry Cleaners source obtain drinking water from municipal and community wells completed in the Floridan aquifer (Ref. 25, pp. 1-10). The majority of residents and busi nesses in the area are provided potable water by the City of Sanford water well system (Ref. 25, pp. 7- 9). The system currently serves 62,052 people in the Sanford area (Ref. 25, p. 8). This system consists of 19 wells co mpleted in the Floridan aquifer (Ref. 25, pp. 2, 5; 6, p. 12). One of those wells is currently (as of November 6, 2009) out of service due to a failed pump; however, the well will be placed back online after sample results are received (Refs. 25, pp. 2; 6, 12). Fifteen of the 19 City of Sanford wells are situated within the 3 to 4 mile radius of the property (Refs. 3; 25, pp. 5, 7-9). The majority of the wells are s ituated to the south and southwest of the property (Refs. 3; 25, pp. 7-9). The wells range in depth from 300 to 700 feet below land surface (Refs. 6, p. 12; 25, pp. 3, 7-9). No one well supplies more than 40 percent (%) of the system (Ref. 25, p. 2). The wells are contained into two water treatment plants (WTP), the Main WTP and the Auxiliary WTP (Ref. 6, p. 12). Both plants operate on a full-time basis; however, the Main WTP has a slightly higher pumpage capacity than the Auxiliary WTP which pumps 4 million gallons per day (mgd) (Ref. 25, p. 2). Water from both the Main WTP and Auxilia ry WTP are blended together prior to distribution to the public (Ref. 25, p. 2).

Four community well systems exist within 4 radial miles of the Sanford Dry Cleaners source: Philips Section (Utilities, Inc.), Crystal Lake, Ravenna Park, and Florida United Methodist (Refs. 3; 6, p. 12; 25, pp. 2-3, 5-9). Community wells are defined by the State of Florida as wells that serve a population of at least 25 year-round residents (Ref. 26, p. 1). Based on the well depths, these wells are completed in the Floridan aquifer system (Refs. 6, p. 12; 25, p. 9). The Phillips Section maintains one well located within the 3 to 4 mile radius from the source (Refs. 3; 25, pp. 2, 7-9). Phillips Section serves a total population of 270 persons (Ref. 25, p. 8). The system is connected to the City of Lake Mary so that in the instance of an emergency (severe drought, hurricanes, pump problems, etc.), Lake Mary can supply the water to the community (Ref. 25, pp. 2, 3). Crystal Lake maintains one well located within the 3 to 4 mile radius from the source (Refs. 3; 25, pp. 3, 7- 9). Crystal Lake serves a total population of 609 persons (Ref. 25, p. 8). The Crystal Lake system is connected to the City of Sanford so that in an emergency (severe drought, hurricanes, pump problems, etc.), the City of Sanford can distribute water to the community (Ref. 25, p. 3). Ravenna Park maintains two wells within the 2 to 3 mile radius from the source (Refs. 3; 25, pp. 3, 7-9). Water from the wells is not mixed with any other source and the two wells are alternated for use, both supplying approximately 50% of the total supply (Ref. 25, p. 3). One well operates at 200 gallons per minute (GPM) capacity while the other is 240 GPM (Ref. 25, p. 3). Ravenna Park serves a to tal population of 1,187 persons (Ref. 25, p. 8). Florida United Methodist serves two wells within the 3 to 4 mile radius from the property, serving a total population of 200 persons (Refs. 3; 25, pp. 2, 7-9). The water is mixed prior to distribution (Ref. 25, p. 2). The wells are hooked to an alternator relay, in order to cycle one well at a time (Ref. 25, p. 2). As a result, each well provides 50% of the supply (Ref. 25, p. 2).

Private wells are likely to exist in remote areas of Sanford and northern Seminole County (Refs. 6, p. 12). One irriga tion well, reportedly 200 feet deep, was located during the 2009 SI, approximately 200 feet east-southeast of the site (Refs. 6, p. 12; 25). This well is used solely for watering t rees and shrubs; therefore, it was not considered as a resource for the ground water pathway (Ref. 6, p. 12).Ground Water-Targets

37 **3.3.1 NEAREST WELL**

Well ID: 25719 Level of Contamination: Potential

The nearest well is located on Temple Avenue, within a 2 to 3-mile radius of the Sanford Dry Cleaner source. The value of 20 is based on a target well within 4 miles of the source drawing water from a karst aquifer that underlies at least a portion of Source 1 (Refs. 3; 25, pp. 5, 7-9; 28, p. 10; 29, p. 1).

**Nearest Well Factor Value: 20** (Ref. 1, Section 3.3.1)

**3.3.2 POPULATION**

**3.3.2.1 Level of Contamination**

**3.3.2.2 Level I Concentrations**

No Level I concentrations have been documented.

**3.3.2.3 Level II Concentrations**

No Level II concentrations have been documented.

**3.3.2.4 Potential Contamination**

The municipal and community wells within a 4 mile radius of the source are distributed as follows: 0- to 0.25-mile, 0 wells; >0.25- to 0.5-mile, 0 wells; >0.5- to 1-mile, 0 wells; >1- to 2-miles, 0 wells; >2- to 3-miles, 2 community wells (Ravenna Park); >3-4 miles, 15 municipal wells and four community wells (Phillips Section, Crystal Lake, and Florida United Methodist) (Refs. 3; 25, pp. 1-10).

The population served by municipal and community wells in the vicinity of the source is distributed as follows: 0- to 0.25-mile, 0 persons; >0.25- to 0.5-mile, 0 persons; >0.5- to 1-mile, 0 persons; >1- to 2-miles, 0 persons; >2- to 3-miles, 1,187 persons; >3- to 4-miles, 50,067.35 persons (4 community wells = 1,079; 15 municipal wells = 48,988.35) (Refs. 3; 25, pp. 1-9; 26).

**Distance/**

**Radial**

**Ring Municipal/**  **Community**
**Wellfields No. of** 
**Active**

**Wells P**  **opulation**

**per Wellfield**  **Total Population**  **References**

0

− 0.25

Mile 0 0 0 0

>0.25-0.5 Mile 0 0 0 0

>0.5-1

Mile 0 0 0 0

>1–2 Miles 0 0 0 0

>2–3 Miles Ravenna Park 2 1,187 1,187

>3–4 Miles City of Sanford Phillips Section Crystal Lake FL United Methodist 15
1
1
2 48,988.35
270
609
200 50,067.35 1, Table
3-12; 3; 25, pp. 1-
10Ground Water-Targets

38 Four community wells lie within the 3 to 4 mile radius of the source serving a population of 1,079 (270 Phillips Section + 609 Crystal Lake + 200 Florida United Methodist) (Refs. 3; 25, pp. 1-9). In addition, 15 municipal we lls lie within the >3 to 4 mile radius of the source (Refs. 3; 25, pp. 1-9). The total population served by the system is 62,052 (Ref. 25, p. 8). Since 15 of the 19 wells (population of 3,265.89 per well) lie within >3 to 4 miles from the source, the total population served by municipal wells in the distance ring is 48,988.35 (Refs. 3; 25, pp. 7-9). The total population served within the >3 to 4 mile radius is 50,067.35 (Refs. 3; 25, pp. 1-9).

**Municipal and Community Drinking Water Wells within 4 Miles of the Sanford Dry Cleaners Property** 

**Distance**
**Category**

**(miles) Number of**  **Municipal**

**Wells Number of**  **Community**

**Wells Population per**  **Distance Ring Distance**  **Weighted**

**P opulation** 

**Value**

**(Karst Values)**  **References**

0 - 0.25 0 0 0 0

>0.25 -
0.5 0 0 0 0

>0.5 - 1 0 0 0 0

>1 - 2 0 0 0 0

>2 - 3 0 2 1,187 817

>3 - 4 15 6 50,067.35 26,068 1, Table 3- 12; 3; 25, pp. 1-10

Sum of Distance-Weighted Population Values: 0 + 0 + 0 + 0 + 817 + 26,068 = 26,885

(as applied to Reference 1 Section 3.3.2.4) = 2,688.5

**Potential Contamination Factor Value: 2,688.5**

**3.3.3 RESOURCES**

Ground water resources have not been identified within a 4-mile radius of the Sanford Dry Cleaners source; therefore, a value of 0 was assigned.

**Resources Factor Value: 0**

**3.3.4 WELLHEAD PROTECTION AREA**

Municipal and community wells are located within a 4-mile radius of the source and all municipal and community wells in Florida are located within Wellhead Protection Areas according to Section 1428 of the Safe Drinking Water Act, as amended (Ref. 26, pp. 2-4).

**Wellhead Protection Area Factor Value: 5**