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 Stoneman Douglas Building 


3900 Commonwealth Boulevard 


Tallahassee, Florida 32399-3000 


Dear Mr. Vinyard: 


The purpose of this letter is to solicit the support ofthe State ofFlorida on the listing ofFairfax St. 


Wood Treaters (the Site), located in Jacksonville, on the National Priorities List (NPL). The U.S. 


Environmental Protection Agency has evaluated the Site for releases ofhazardous substances, pollutants 


or contaminants under the Comprehensive Environmental Response, Compensation, and Liability Act 


(CERCLA). Based on Florida Department ofEnvironmental Protection (FDEP) and EPA assessments of 


the Site, both agencies believe the Site poses a significant threat to public health or the environment. 


The Site is a 12-acre parcel located at 2610 Fairfax Street, in a densely populated residential area of 


Duval County. It is 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 adjacent to 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 current property owner is FLM, Inc. 


FDEP requested EPA assistance in August 2010 to respond to releases and potential releases of 


hazardous substances, specifically arsenic, chromium and copper, at the Site. Releases of wood 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 of arsenic, chromium and copper contamination have been mitigated 


via the on-going EPA emergency response and removal action, including contaminated soil, tanks of 


wood treating chemicals, retention ponds and contaminated waste water. In addition, EPA has 


remediated an area of arsenic-contaminated soil on the 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 of contamination still exist on the Site. Further, soil contamination with arsenic, 


above Florida State Cleanup Target Levels, has been documented on several nearby residential 


properties. Listing the Site on the NPL will allow EPA to address additional contamination on the Site 


and nearby residential properties, and will allow EPA to investigate, and remediate if warranted, local 


ground water and surface water. 


EPA has maintained close communications with the FDEP-Northeast District Office, the Florida 


Department of Health, 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 System package 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 EPA to proceed with the NPL listing process for this Site. This letter, therefore, 

solicits from the Governor of Florida, or the State Environmental Secretary, the State's position 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 EPA may move forward expeditiously in the listing process. In 

order to stay on schedule to propose the Site in the next NPL update (scheduled for March 2012), we 

must receive state concurrence by December 8, 2011. EPA will continue working closely with FDEP to 

ensure that our common goal of protecting human health and the environment is fully realized. Should 

you require any additional information, please do not hesitate to contact me at (404) 562-8599 or have 

your staff contact Cathy Amoroso, Acting Region 4 NPL Coordinator, at (404) 562-8637. 

Franklin E. Hill, Director 

Superfund Division 

cc: 	Mr. Jorge Caspary, Florida DEP 

Ms. Freda Yilmaz, Florida DEP 

Mr. Tony Raia, EPA-OCIR 

Ms. Terry Jeng, EPA-OSRTI 

Mr. Robert Myers, EPA-OSTRI