UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960 OCT 1 9 2011

Hershel T. Vinyard, Jr. Secretary, Florida Department ofEnvironmental Protection Marjorie StonemanDouglas Building 3900 Commonwealth Boulevard Tallahassee, Florida 32399-3000
Dear Mr. Vinyard:
The purpose ofthis letter is to solicit the support ofthe State ofFloridaonthe listing ofFairfax St. Wood Treaters (the Site), located in Jacksonville, onthe National Priorities List (NPL). The U.S. Environmental Protection Agency has evaluated the Site for releases ofhazardous substances, pollutants orcontaminants under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Based on FloridaDepartment ofEnvironmental Protection (FDEP) and EPA assessments of the Site, both agencies believe the Site poses a significantthreat to public health orthe environment.
The Site is a 12-acreparcel located at2610 Fairfax Street, in a densely populated residential area of Duval County. Itis a former wood treating facility operated by Wood Treaters, LLC, from 1980- 2009. Wood Treaters, LLC used chromated copper arsenate to pressure treat utility poles, marine pilings and other wood products. The Site is adjacentto Susie E. Tolbert Elementary School, R.V. Daniels Elementary School, Pullman Court subdivision, residences along Fairfax Street, and residences along W. 13th Street. Wood Treaters, LLC, was forced into Chapter 7 bankruptcy, and by July 2010 had abandoned the operation. The currentproperty owneris FLM, Inc.
FDEP requested EPA assistance in August 2010 to respond to releases and potential releases of hazardous substances, specifically arsenic, chromium and copper, atthe Site. Releases ofwood treating chemicals have resulted in contamination on the Site and on nearby properties. EPA commenced an emergency response and removal action in August 2010, and expects to complete the removal activities in October 2011. Several sources ofarsenic, chromium and copper contamination have been mitigated viathe on-going EPA emergency response and removal action, including contaminated soil, tanks of woodtreating chemicals, retention ponds and contaminated waste water. In addition, EPA has remediated an area ofarsenic-contaminated soil onthe adjacent elementary school play ground. Additional investigation and remediation ofthe Site and adjacent properties is needed, but is beyond the scope ofthe EPA removal action.
Additional sources ofcontamination still existonthe Site. Further, soil contamination with arsenic, above Florida State Cleanup Target Levels, has been documented on several nearby residential properties. Listing the Site onthe NPL will allow EPAto address additional contamination onthe Site and nearby residential properties, and will allow EPA to investigate, and remediate ifwarranted, local ground water and surface water.
EPA has maintained close communications with the FDEP-NortheastDistrict Office, the Florida Department ofHealth, the Duval County Health Department, Duval Schools, and the City of

Internet Address (URL) • http://www.epa.gov Recycled/Recyclable • Printed wHh Vegelable OH Based Inks on Recycled Paper (Minimum 30% Postconsumer)Jacksonville throughout the assessment and removal process. The participation ofthese agencies has been instrumental in responding to releases at the Site and working with the community.
EPA has completed a draft Hazard Ranking Systempackage for the Site, establishing that the Site qualifies for proposal to the NPL. To further coordinate with the State, we are soliciting the State's written support for EPAto proceed with the NPL listing process for this Site. This letter, therefore, solicits from the Governor ofFlorida, orthe State Environmental Secretary, the State'sposition on proposing the Site to the NPL. Please respond to: Gwendolyn Keyes Fleming Regional Administrator U

.S. Environmental Protection Agency Region4 61 Forsyth Street, SW Atlanta, Georgia 30303-3104
We appreciate a quick response so that EPAmay move forward expeditiously in the listingprocess. In orderto stay on schedule to propose the Site in the nextNPL update (scheduled for March 2012), we mustreceive state concurrenceby December 8, 2011. EPA will continue working closely with FDEP to ensure that ourcommon goal ofprotecting human health andthe environment is fully realized. Should you require any additional information, please do nothesitate to contactme at (404) 562-8599 orhave your staffcontact Cathy Amoroso, Acting Region 4 NPL Coordinator, at (404) 562-8637.

Franklin E

. Hill, Director Superfund Division

cc: Mr. Jorge Caspary, FloridaDEP Ms. FredaYilmaz, Florida DEP Mr. Tony Raia, EPA-OCIR Ms. Terry Jeng, EPA-OSRTI Mr. Robert Myers, EPA-OSTRI