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 documented, 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 substances; 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 subsequent 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 S2

 

1. Ground water Migration Pathway Score (Sgw) 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 (Ss) 

(from Table 5-1, line 22) 

 NS NS 

4. Air Migration Pathway Score (Sa) 

(from Table 6-1, line 12) 

 NS NS 

5. Total of Sgw2

 + Ssw2 + Ss

2

 + Sa

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 3-1 
3 

 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 (Sgw), (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

012

Miles$

United States Environmental Protection Agency

SANFORD DRY CLEANERS

SANFORD, SEMINOLE COUNTY

FLORIDA

TDD No. TNA-05-003-0092

FIGURE 1

GENERAL 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 STREET 

S. PALMETTO AVENUE

S. SANFORD AVENUE 

121 SOUTH

PALMETTO AVE. 

EAST 1ST STREET 

Parcel 

Site Boundary $

0 40 

Feet 

Sanf

Sem

ord,

inole County, 

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 MAP 

G:\GIS_Workspace\Sanford Dry Cleaners\mxd\Figure 2 - Property Layout Map.mxd 

Aerial Source: GlobeXplorer ImageConnect (April 2008) 

80 
 

 

 

 

 

 

 

 

 

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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 STREET 

S. PALMETTO AVENUE

S. SANFORD AVENUE 

121 SOUTH

PALMETTO AVE. 

SB 

SF 

Legend !< Surface Soil Sample
 !U Subsurface Soil Sample !> 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 County, 

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 MAP 

GIS_Workspace G:\ \Sanford Dry Cleaners\mxd\Figure 3 - Sample Location Map.mxd 

Aerial Source: GlobeXplorer ImageConnect (April 2008) 

40 
7 

REFERENCES 

Ref. 

No. Description of the Reference

1. U.S. Environmental Protection 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 Search 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 Report Addendum for the Former 

Thrifty Service Station. December 20, 1993. 40 pages. 

12. FDEP. Letter from Gail Mowry, Waste Cleanup Program, 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 Section. 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/recognition.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 parcel 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 two 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 latitude, 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 Avenue 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 property (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 Avenue 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 Corporations, 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 parcels 
Site 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-profit 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 Contamination Assessment Report (CAR) submitted to the Florida 

Department of Environmental Protection (FDEP) by Environmental Solutions and 

Services Incorporated (ESSI), for the former 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 laboratory 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 concentrations 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 attributed to a source off the property (Refs. 6, p. 6; 11, 

p. 7). Since no petroleum-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). The 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 forwarded 
Site 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) submitted 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 3,091 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 significantly 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 parking 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 protection provided to 

PRPs under Florida Statute 376.3078 (Ref. 6, p. 7). Provisions in this statute 

preclude the use of soil or ground water assessment data submitted during the 
Site 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 assistance 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, assessment 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 included 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 wells 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 Cleaners was the source of the chlorinated 

VOC contamination (Ref. 6, p. 8). FDEP also recommended additional soil and 

ground water assessment activities to determine 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 Cleaners 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 the 
Site 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, which 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 while 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 application (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 FDEP 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) funding ceiling and available budget (Ref. 6, 

p. 9). However, FDEP FPS told the MOAH representatives that the Department would 

consider using TBA/SSA funding to conduct a limited source removal to assist MOAH 

if the results of the soil gas survey revealed a “soil contaminant 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 through 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 proposed, 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 assistance, 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 review 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 reconnaissance 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 and 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 corner 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 decision 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 detailed 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 the 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 located 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 3-2 
Site 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 analyzed 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, 145 
Site 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, 186 
Site 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 transport 
Site 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, 

174 
Site 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 sample 
Site Description-Hazardous Substances 

Source No. 1 

21 

SDC - Sanford Dry Cleaners 

SB - Subsurface soil sample 

TCE - Trichloroethene (Trichloroethylene) 

PCE - Tetrachloroethene (Tetrachloroethylene) 

DCE - Dichloroethene 
22 

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 (counterclockwise 

order) SDC-004-SF/SB, SDC-002-SF/SB, SDC-007-SF/SB, SDC-006-SF/SB, SDC-010-SF/SB, 

and SDC-009-SF/SB collected during 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 (ft2

) (Ref. 6, pp. 55, 56). 

Equation for hazardous waste quantity evaluation for the contaminated soil is 

A/34,000. Therefore, >0 ft2 /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 2.4.2.2
 

 

Site Description - Summary of Source Descriptions 

SUMMARY OF SOURCE DESCRIPTIONS 

Source 

No. 

Source Hazardous 

Waste Quantity

Value 

Containment 

Ground Water 

Surface 

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. 

23 
Ground 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 

approximately 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 directly 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 estimated 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 approximately 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 hydraulic 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 in 
Ground 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 November 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 table 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 and 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 generally 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 completed 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 where 
Ground 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 circulation 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 underlying 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 northern 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 

Interconnected 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 Field Branches Quality System and Technical Procedures (Refs. 6, 

p. 17; 20, pp. 1-30). All ground water samples were analyzed 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 

Deptha

(feet) 

Depth to 

Waterb

(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 

building

6/2/2009 6, pp. 36, 46-

48, 204, 206, 

209, 277 

SDC-002-GW 9.25 4.00 

Well installed 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 

Well 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, 276 
Ground Water-Observed Release 

Surficial/Floridan Aquifer

29 

Sample ID 

Total 

Deptha

(feet) 

Depth to 

Waterb

(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 well installed on 

right-of-way of east 

side 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) 

Background 

(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, 244 
Ground Water-Observed Release 

Surficial/Floridan Aquifer

30 

Sample ID 

Hazardous 

Substance 

Concentration 

(ug/L) 

Background 

(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/trichloroethylene 
Ground Water-Observed Release 

Surficial/Floridan Aquifer

31 

Deep Wells 

Sample ID 

Hazardous 

Substance 

Concentration 

(ug/L) 

Background 

(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/dichloroethylene 
Ground 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 street 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 Places (Ref. 6, p. 5). This building is sometimes 

referred to as the old E.E. Brady Livery 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 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 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 “Drycleaner” (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 contamination 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 south (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 “orphan 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 dealers, 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 the 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 migration 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 businesses 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 completed 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 situated 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 Auxiliary 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 total 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 irrigation 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 trees 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 

Population 

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-

10 
Ground 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 wells 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 

Population 

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