HAZARD RANKING SYSTEM (HRS) DOCU MENTATION RECORD COVER SHEET

Name of Site : Fairfax St. Wood Treaters

EPA ID No. : FLD000623041

Contact Persons

Documentation Record : Cathy Amoroso, National Priorities List Coordinator U.S. Environmental Protection Agency, Region 4 61 Forsyth Street, S.W., 11 th Floor Atlanta, Georgia 30303 (404) 562-8637

Quinn Kelley, Site Manager Tetra Tech EM, Inc. 1955 Evergreen Boulevard, Ste. 300 Duluth, Georgia 30096 (678) 775-3101

Pathways, Components, or Threats Not Scored

The ground water migration, surface water migration, a nd air migration pathways were not scored in this Hazard Ranking System (HRS) documentation record because the soil exposure pathway is sufficient to qualify the site for the National Priorities List (N PL). These pathways are of concern to the U.S. Environmental Protection Agency (EPA) and may be considered during a future evaluation.HAZARD RANKING SYSTEM (HRS) DOCUMENTATION RECORD

Name of Site: Fairfax St. Wood Treaters

EPA Region: 4

Date Prepared: March 2012

Street Address of Site*: 2610 Fairfax Street

City, County, State, Zip: Jacksonv ille, Duval County, Florida 32209

General Location in the State: Northeastern portion of state

Topographic Maps: Jacksonville, Florida, 1983

Latitude: 30° 21' 14.73" North

Longitude: 81° 41' 11.02" West

The coordinates above for Fairfax St. Wood Treaters were measured from the entrance to the property within the area of observed contamination (Ref. 4).

* The street address, coordinates, and contaminant locations presented in this HRS documentation record identify the general area where the site is located. They represent one or more locations EPA considers part of the site based on the screening information EPA used to evaluate the site for NPL listing. EPA lists national priorities among the known “releases or threatened releases” of hazardous substances; thus, the focus is on the release, and not on precisely de lineated boundaries. A site is defined 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 re present the initial determination that a certain area may need to be addressed under the Comprehensiv e Environmental Response, Compensation, and Liability Act (CERCLA). Accordingly, EPA contempl ates 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.

Pathway Pathway Score
Ground Water Migration Not Scored
Surface Water Migration Not Scored
Soil Exposure 100.00
Air Migration Not Scored

HRS SITE SCORE 50.00

1WORKSHEET FOR COMPUTING HRS SITE SCORE

S Pathway S 2 Pathway

Ground Water Migration Pathway Score (S gw ) NS NS

Surface Water Migration Pathway Score (S

sw ) NS NS

Soil Exposure Pathway Score (S

s ) 100 10,000

Air Migration Pathway Score (S

a ) NS NS

S 2

gw + S 2

sw + S 2

s + S 2

a 10,000

(S 2

gw + S 2

sw + S 2

s + S 2

a ) / 4 2,500 √

(S 2

gw + S 2

sw + S 2

s + S 2

a ) / 4 50.00

Note:

NS = Not scored

23 T ABLE 5-1 --S OIL E XPOSURE P ATHWAY S CORESHEET Factor categories and factors Maximum Value Value Assigned
Resident Population Threat
Likelihood of Exposure:
1. Likelihood of Exposure 550 550

Waste Characteristics:
2. Toxicity (a) 10000
3. Hazardous Waste Quantity (a) 10

4. Waste Characteristics 100 18
Targets:

5. Resident Individual 50 50
6. Resident Population:

6a. Level I Concentrations (b) 830

6b. Level II Concentrations (b) 374
6c. Population (lines 6a + 6b) (b) 1204

7. Workers 15 5

8. Resources 5 0

9. Terrestrial Sensitive Environments (c) 0
10. Targets (lines 5 + 6c + 7 + 8 + 9) (b) 1259
Resident Population Threat Score
11. Resident Population Threat Sc ore (lines 1 x 4 x 10) (b) 12464100
Nearby Population Threat
Likelihood of Exposure:
12. Attractiveness/Accessibility 100 NS

13. Area of Contamination 100 NS
14. Likelihood of Exposure 500 NS NS

Waste Characteristics:
15. Toxicity (a) NS
16. Hazardous Waste Quantity (a) NS

17. Waste Characteristics 100 NS
Targets:
18. Nearby Individual 1 NS
19. Population Within 1 Mile (b) NS
20. Targets (lines 18 + 19) (b) NS
Nearby Population Threat Score
21. Nearby Population Threat (lines 14 x 17 x 20) (b) NS
Soil Exposure Pathway Score:
22. Pathway Score c (S s ), [lines (11+21)/82,500, subj ect to max of 100] 100 100.00

Notes:

a Maximum value applies to waste characteristics category

b Maximum value not applicable

c Do not round to nearest integer

NS Not scored!.Brown's Dump!.5th and Cleveland(Jacksonville Ash)United StatesEnvironmental Protection AgencyFAIRFAX ST. WOOD TREATERSJACKSONVILLE,DUVAL COUNTY,FLORIDATDD No.TTEMI-05-003-0103FIGURE 1PROPERTY LOCATIONSources:Property Boundary - Ducal CountyProperty Appraiser's OfficeTopographic Quadrangle - USGS,Jacksonville, FL 1983,References6, p. 333, pp. 1, 4./0 1,000 2,000FeetLegendFairfax St. WoodTreaters Facility!.Superfund Site Date Saved: 11/30/2011 2:40:34 PM User: andrew.dye Path: S:\GIS_Workspace\Fairfax_St_Wood_Treaters\mxd\Figure_1_Site_Location.m xdFLGAALDuval County

45 CSX Transportation FWT-44-SF " FWT-42-SF-CG ) WT-G04-SS-A
WT-G04-SS-A-DUP
WT-G04-SS-B
WT-G04-SS-B-DUP 

### Legend

Reference Po 

### ! .

" )



### # * int

" ) FWT-43-SF-BY ) " " ) WT-SF-06 WT-G01-SS-A FWT-41-SF-BY WT-G01-SS-B WT-G02-SS-B")

FWT-41-SF-FY FWT-40-SF-BY 

### # * WT-SF-04

" ) WT-SF-19 " )")")") 

### # *

" ) FWT-39-SF-FY FWT-40-SF-FY 

### # Pullman Court 

### * " WT-G05-SS-A FWT-37-SF-FY )

WT-G05-SS-B WT-G03-SS-A
WT-G03-SS-B") 

### # *

WT-SF-05
WT-SF-05-DUP

" ) " )") 81° 41' 11.02" West
30 21 14.73 North

° ' "
FWT-39-SF-BY FWT-35-SF-BY FWT-38-SF-BY 

### . West 17th Street " ) " ) " ) 

### ! West 17th Street " ) WT-G06-SS-A January 2011 Soil Sampling Location

May 2011 Soil Sampling Location

July 2011 Soil Sampling Location

July 2011 Sampling Grid

Process Area

AOC A

Selected Parcels

Fairfax St. Wood Treaters Facility

Drainage Ditch

FWT-37-SF-BY FWT-36-SF-BY 

### # *

FWT-SF-20



### # * FWT-02-SF ) "

WT-RP-SF-06

R.V. Daniels WT-G08-SS-A 

### # *

WT-G08-SS-B Element
Schoo ary l P Shared lay Area

West 15th Street West 15th Street

FWT-17-SF
FWT-30-SF WT-G11-SS-B""))")"""))) WT-RP-SF-05

WT-G07-SS-A
WT-G07-SS-B

Wood Trea t . ers

WT-G09-SS-A

WT-G10-SS-A Fairfax St West 16th StreetFairfax Street

" )

WT-G12-SS-B WT-G13-SS-A
WT-G13-SS-B WT-G14-SS-A
WT-G14-SS-BPullman Avenue WT-G15-SS-A

Susie Tolber

El WT-SF-01")")")



### # WT-SF-02-DUP 

### * ement 

### # * * # West 14th Street Schoo ary l " )

FWT-49-SF

West 13th Street t WT-SF-02")

WT-SF-03 Map Notes:
AOC - Area of Observed Contamination bgs - Below ground surface BY - Backyard CG - Community garden DUP - Duplicate
FWT - Fairfax St. Wood Treaters FY - Front yard
G - Grid
SF - Surface soil SS - Soil Sample
WT - Fairfax St. Wood Treaters

A = Sample depth of 0 to 6 inches bgs B = Sample depth of 18 to 24 inches bgs

Sources: Aerial Photograph - Aerials Express, 2010 Parcel Boundaries - Duval County Property Appraiser's Office References 4, 6, p. 3; 17, Appendix A, pp. A-2, A-4, A-5; 20, p. 15; 45, p.1, Enclosure 1, p. E1-1

100 200 

# /

0

Feet

United States Environmental Protection Agency

FAIRFAX ST. WOOD TREATERS JACKSONVILLE, DUVAL COUNTY,
FLORI

TDD No.TTEM I DA

-05-003-0103



### FIGURE 2
AREA OF OBSERVED

CONTAMINATION ADate Saved: 1/20/2012 2:59:37 PM User: andrew.dye Path: S:\GIS_Workspace\Fairfax_St_Wood_Treaters\mxd\Figure_2_AOC_Map.mxd"  )#*")Fairfax St.Wood TreatersR.V. DanielsElementarySchoolSusie TolbertElementarySchoolSharedPlay Area C S X T r a n s p o r t a t i o n Fairfax Street

Pullman AvenueWest 17th StreetWest 16th StreetWest 15th StreetWest 14th StreetPullman CourtWest 15th StreetWest 17th StreetWest 19th StreetWest 20th Street

Spires AvenueFWT-00-SB-A2WT-BG-SF-01WT-BG-02-SS-AWT-BG-02-SS-BUnited StatesEnvironmental Protection AgencyFAIRFAX ST. WOOD TREATERSJACKSONVILLE,DUVAL COUNTY,FLORIDATDD No.TTEMI-05-003-0103FIGURE 3BACKGROUND SAMPLINGLOCATIONSMap Notes:A - Sample deoth of 0 to 6 inches bgsA2 - Sample depth of 0 to 12 inches bgsB - Sample depth of 18 to 24 inches bgsBG - BackgroundFWT - Fairfax St. Wood TreatersSB - Subsurface soilSF - Surface soilSS - Soil SampleWT - Fairfax St. Wood TreatersSources:Aerial Photograph - Aerials Express, 2010,Property Boundary - Duval County PropertyAppraiser's OfficeReferences 6, p. 3; 17, Appendix A, pp. A-4,A-5; 45, Enclosure 1, p. E1-1/0 100200FeetLegend")January 2011 SoilSampling Location#*May 2011 SoilSampling Location

"  )July 2011 SoilSampling LocationFairfax St. WoodTreaters Facility Date Saved: 11/30/2011 1:42:03 PM User: andrew.dye Path: S:\GIS_Workspace\Fairfax_St_Wood_Treaters\mxd\Figure_3_Background_Samp ling_Locations.mxd

6Fairfax St.Wood TreatersR.V. DanielsElementarySchoolSusie TolbertElementarySchoolSharedPlay Area C S X T r a n s p o r t a t i o n Fairfax Street

Pullman AvenueWest 17th StreetWest 16th StreetWest 15th StreetWest 14th StreetWest 13th StreetPullman CourtWest 15th StreetWest 17th StreetWest 19th StreetUnited StatesEnvironmental Protection AgencyFAIRFAX ST. WOOD TREATERSJACKSONVILLE,DUVAL COUNTY,FLORIDATDD No.TTEMI-05-001-0103FIGURE 4EPA REMOVAL AREASMap Notes:BGS - Below ground surfaceSources:Aerial Photograph - Aerials Express, 2010Parcel Boundaries - Duval County TaxAssessor's Office.References 22; 47, pp. 1, 6, 11, 18/0 100200FeetLegendExcavation Areas6 inches BGS1 foot BGS1.5 feet BGS2 feet BGSExcavated and Restored Pond Date Saved: 11/30/2011 1:59:41 PM User: andrew.dye Path: S:\GIS_Workspace\Fairfax_St_Wood_Treaters\mxd\Figure_4_EPA_Removal_Are as.mxdMap FeaturesFairfax St. WoodTreaters FacilitySelected Parcels

78 REFERENCES

1. U.S. Environmental Protection Agency (EPA). Hazard Ranking System, Title 40 Code of Federal Regulations Part 300, 55 Federal Register 51532. December 14, 1990. 138 Pages.

2. EPA. Superfund Chemical Data Matrix (SCDM). January 2004, Updated December 2011. Excerpt, 75 Pages. A complete copy of SCDM is available at: http://epa.gov/superfund/sites/ npl/hrsres/tools/scdm.htm

.

3. Tetra Tech EM Inc. (Tetra Tech). Map: Soil Exposure Pathway, Level I and Level II Properties. Source of Map: Aerial Photograph - Aerials Express, 2010; Property Boundaries - Duval County Property Appraiser’s Office; Street Names - ESRI Str eetMap, digital road data. Scale, 1:1,200. 1 Map.

4. Tetra Tech. Project Note to File with Attachment. Subject: Coordinates for Fairfax St. Wood Treaters. Attachment: Google Earth Map. September 12, 2011. 2 Pages.

5. EPA. Envirofacts, CERCLIS. Site Name: Fairfax St. Wood Treaters. Data Extracted on September 9, 2011. Accessed on September 12, 2011. 2 Pages. Accessed on-line at: http://iaspub.epa.gov/enviro/cerclisque ry.get_report?pgm _sys_id=FLD000623041

.

6. Tetra Tech. Project Note to File with Attachment s. Subject: Parcel Information and Maps for the Fairfax St. Wood Treaters Property. Attachments: Tax Record and Parcel Map. August 18, 2011. 4 Pages.

7. Ed Harris – PE Services. Site Assessment Report (SAR) — Susie Tolbert Elementary School Stormwater Retention Pond System. June 13, 2008. 115 Pages.

8. CCAResearch.Org. What is CCA-Treated Wood? Accessed October 18, 2010. 2 Pages. Accessed

on-line at: http://www.ccaresearch.org/about_cca.htm

.

9. Oklahoma State University, Oklahoma Cooperative Extension Service. Basics of Pressure Treatment of Wood. By Salim Hiziroglu, Assistant Professor, Forestry. Accessed November 22, 2011. 2 Pages. Accessed on-line at: http://pods.dasnr.okstate.edu/docushare/dsweb/Get/Rendition2654/unknown

.

10. Ohio State University. Wood Preserving Chemi cals and Procedures. By Robert D. Louse, Extension Forester, Ohio State University. Copyright 1986. 13 Pages.

11. Tetra Tech. Project Note. Subject: Fairfax St. Wood Treaters Stormwater Containment Process. October 18, 2010. 1 Page.

12. Florida Department of Environmental Protection (F DEP). Letter with Attachment. Regarding: Wood Treaters, LLC. From: Jabe Breland III, Environmental Specialist III, Hazardous Waste Section. To: Mr. Stan Hill, CEO, Wood Treaters, LLC. Attachment: FDEP Hazardous Waste Inspection Report. June 9, 2009. 17 Pages.

13. Ed Harris – PE Services. Site Assessment Report Addendum (SARA) —Wood Treaters, LLC and Susie Tolbert Elementary School Properties. April 24, 2009. 100 Pages.

14. Ed Harris – PE Services. Second Site Assess ment Report Addendum (SARA2), Additional Sampling of Wood Treaters, LLC Property, Adjacent Off-Site Properties, STES Property, & Properties & Background Definition Studies. August 25, 2010. 61 Pages.

15. Tetra Tech. Final Comprehensive Environmen tal Response, Compensation, and Liability Act Emergency Response Report for the Fairfax Street Wood Treater Response, TDD No. TTEMI-05- 001-0132. May 6, 2011. 85 Pages.9 16. Tetra Tech. Final Removal Investigation Letter Report, Fairfax Wood Investigation, Jacksonville, Duval County, Florida, TDD No. TTEMI-05-00 3-0114. March 11, 2011. 837 Pages.

17. Tetra Tech. Revised Final Integrated Site Inspection Report, Fairfax Street Wood Treaters, Jacksonville, Duval County, Florida, TDD No. TTEMI- 05-003-0103. August 22, 2011. 612 Pages.

18. Tetra Tech. Final Quality Assurance Project Pl an, Fairfax Street Wood Treater, Jacksonville, Duval County, Florida, TTEMI-05-003-0103. May 3, 2011. 31 Pages.

19. Tetra Tech. Project Note to File. Subject: May 2011 Pre-Remedial Investigation Sampling Activities at Fairfax St. Wood Treaters. June 23, 2011. 1 Page.

20. Wood Treaters, LLC. Contingency Plan. Last Revision January 4, 2007. 15 Pages.

21. EPA, Region 4. Fairfax St. Wood Treaters Site Update Fact Sheet. August 2011. 4 Pages.

22. Tetra Tech. Project Note to File. Subject: Removal Activities at Fairfax St. Wood Treaters in Jacksonville, Florida. January 25, 2012. 1 Page.

23. Tetra Tech. Project Note with Attachment. S ubject: May 2011 Pre-Remedial Investigation Chainof-Custody (COC) Records. Attachment: EPA Contract Laboratory Program (CLP) Inorganic Chain-of-Custody Record, Fairfax St. Wood Treater, Project No. 11-0409, Case No. 41330, COC No. 05/12/11-0003, Date Shipped: May 12, 2011. January 19, 2012. 7 Pages.

24. Tetra Tech. Record of Telephone Conversation. Subject: Data Review, Validation, and Verification Conducted at the Science and Ecosystem Support Division (SESD), Analytical Support Branch. Between Sandra Harrigan, Environmental Scientis t, and Denise Goddard, Chemist, EPA Region 4 SESD, Quality Assurance Section. January 6, 2009, Updated Decembe r 1, 2011. 1 Page.

25. Tetra Tech. Record of Telephone Conversation. Subject: Definitions of Minimum Reporting Limit, Minimum Quantitation Limit, Contract Required Quan titation Limit, and Sample Quantitation Limit. Between Shanna Davis, Environmen tal Scientist, and Charlie Appleb y, Quality Assurance Section, Management and Technical Services Branch, EPA Region 4 SESD. July 9, 2008. 1 Page.

26. Tetra Tech. Project Note with Attachments. S ubject: Summary of J-Qualified Data. Attachment: J-Qualified Data Adjustment Calculati ons. November 9, 2011. 6 Pages.

27. EPA Office of Emergency and Remedial Response. Using Qualified Data to Document an Observed Release and Observed Contamination. Quick Reference Fact Sheet EPA-540-F-94-028. November 1996. 18 Pages.

28. EPA, Region 4 SESD. Operating Procedure, Soil Sampling, SESDPROC-300-R1. November 1, 2007. 22 Pages. Accessed on-line at: http://www.epa.gov/region4/sesd/fbqstp/Soil-Sampling.pdf

.

29. EPA, Office of Superfund Remediation and Technol ogy Innovation. Contract Laboratory Program National Functional Guidelines for Inorganic S uperfund Data Review, OSWER 9240.1-51, USEPA540-R-10-011. January 2010. 110 Pages.

30. Environmental Conservation Laboratories, Inc. (ENCO). Laboratory Results for Fairfax Road Wood, ENCO Workorder: B003769. August 20, 2010. 21 Pages.

31. ENCO. Laboratory Results for Fairfax Road W ood, ENCO Workorder: B003754. August 20, 2010. 31 Pages.

32. Tetra Tech. Record of Telephone Conversation. Between Jessica Vickers, QA Manager, and Chris Tompkins, Project Manager, ENCO. Subject: Fairfax Street Wood Treaters PQL Definition. August 10, 2011. 1 Page.10 33. EPA. Jacksonville Health Zone 1, Superfund Update Fact Sheet. July 2011. 5 Pages. Accessed online at: http://www.epa.gov/region4/waste/sf/imag es/nplmedia/pdfs/jaxv ilflwaterfaxs072011.pdf

.

34. EPA. Project Note to File. Subject: Stormwater Runoff from the Fairfax St. Wood Treaters Facility. August 18, 2011. 1 Page.

35. Ed Harris – PE Services. Letter to FDEP, Division of Waste Management, with Attachment. Subject: Notice of Contamination beyond Property Boundaries, Wood Treaters LLC — Jacksonville, FL. Attachment: ENCO Analytical Data Package. January 13, 2009. 61 Pages.

36. Wood Treaters, LLC. Letter to FDEP, Division of Wa ste Management, with Attachments. Subject: Notice of Contamination beyond Property Boun daries, Wood Treaters LLC — Jacksonville, FL. Attachments: Summary Table, Figure, and ENCO Analytical Data Package. September 29, 2009. 87 Pages.

37. FDEP. Letter to Mr. Ed Pratt-Da nnals, Superintendent, Duval County School District. Regarding: Susie E. Tolbert Elementary School, 1925 W. 13 th St, Jacksonville. October 17, 2008. 6 Pages.

38. FDEP. Letter to Fairfax Land Management, Inc. Re garding: Wood Treaters. February 20, 2009. 1 Page.

39. Tetra Tech. Final Sampling and Analysis Plan for the Fairfax Wood Investigation, TDD No. TTEMI-05-003-0114. January 11, 2011. 99 Pages.

40. Environmental Data Resources, Inc. (EDR). The EDR Radius Map Report with GeoCheck for Fairfax St. Wood Treaters. September 9, 2011. 183 Pages.

41. Tetra Tech. Project Note to File with Attachment. Subject: Soil Map for Fairfax St. Wood Treaters. September 13, 2011. 4 Pages.

42. EPA. Memorandum. Subject: Information for the Fairfax Wood Treaters Site. To: Cathy Amoroso, Remedial Project Manager. From : L’Tonya Spencer, Community Involvement Coordinator. January 20, 2012. 1 Page.

43. FDEP. Letter to Norfolk Southern Railway Co. Regarding: Norfolk Southern RR ROW at Fairfax St. February 20, 2009. 3 Pages.

44. Tetra Tech. Final Quality Assurance Project Plan, Fairfax Street Wood Treaters, Jacksonville, Duval County, Florida, TDD No. TTEMI-05-00 1-0151. July 22, 2011. 22 Pages.

45. Tetra Tech. Project Note to File with Enclosur es. Subject: July 2011 Removal Confirmation and Residential Sampling Activities at Fairfax St. Wood Treaters in Jacksonville, Florida. Enclosures: Sampling Locations, Data Tables, Logbook Notes, Fi eld QC Review, and Data Packages. October 27, 2011. 152 Pages.

46. Tetra Tech. Project Note to File with Attachme nt. Subject: July 2011 Removal Confirmation and Residential Sampling Event COC Records. Attachment: EPA, CLP Inorganics Chain of Custody Record, Case No. 41599, Project No. 11-0506, Date Shipped: July 28, 2011. January 19, 2012. 9 Pages.

47. Tetra Tech. Project Note to File with Attachme nts. Subject: Removal Activities and Confirmation Samples Collected at Fairfax St. Wood Treat ers in Jacksonville, Florida – October 2011. Attachments: Logbook Notes and Analytical Data Packages. November 21, 2011. 54 Pages.

48. USDA, Soil Conservation Service. Soil Survey of the City of Jacksonville, Duval County, Florida. Issued May 1978. Annotated excerpt 15 Pages.11 49. Tetra Tech. Project Note to File. Subject: Fa irfax St. Wood Treaters Retention Pond. January 17, 2012. 1 Page.

50. EPA. Action Memorandum. Subject: Request fo r a Ceiling Increase and Exemptions to the $2 Million Statutory Limit and the 12-Month Statutory Limit, Fairfax St. Wood Treater Site, Jacksonville, Duval County, Florida. From: Te rry Tanner, On-Scene Coordinator, Emergency Response and Removal Branch. To: Franklin E. Hill, Director, Superfund Division. February 15, 2011. 12 Pages.

51. USCourts.gov. Federal Courts, Bankruptcy Basics, Chapter 11, Debtor in Possession. Accessed January 23, 2012. 2 Pages. Accessed on-line at: http://www.uscourts.gov/FederalCourts/Ba nkruptcy/BankruptcyBasics/Chapter11.aspx

.

52. Tetra Tech. Project Note to File. Subjec t: January 2011 Removal Investigation Sample Nomenclature. January 17, 2012. 1 Page.

53. Tetra Tech. Electronic Mail Correspondence. Subject: Fairfax St. Wood Treaters – Info on FDEP Oversight. Between: Quinn Kelley, Environmental Scientist, and Merrilee L. Palcic, P.E., Waste Cleanup Section – Northeast District, FDEP. January 18, 2011. 1 Page.

54. United States Bankruptcy Court, Middle District of Florida, Jacksonville Division. Wood Treaters, LLC Voluntary Petition – Chapter 11 Bankruptcy. Case No. 3:09-bk-01895-PMG. Filed March 16, 2009. 6 Pages.

55. United States Bankruptcy Court, Middle District of Florida, Jacksonville Division. Wood Treaters, LLC Order Converting Case to Chapter 7 and Esta blishing Bar Dates and Notice by the Clerk of Meeting of Creditors and Appointment of Trust ee. Case No. 3:09-bk-01895-PMG. Dated July 26, 2010. 2 Pages.

56. Tetra Tech. Project Note to File with Enclosur e. Subject: EPA Guidance Used by the ESAT Work Team During the Performance of Data Review for Fairfax St. Wood Treaters in Jacksonville, Florida. Enclosure: USEPA Region 4 SESD Data Validation Standard Operating Procedures for CLP Inorganic Data by Inductively Coupled Plasma – Atomic Emission Spectroscopy and Inductively Coupled Plasma – Mass Spectroscopy. January 26, 2012. 36 Pages.12 

### SITE DESCRIPTION

The Fairfax St. Wood Treaters (FSWT) facility encompasses about 12.49 acres of land and is located at 2610 Fairfax Street, Jacksonville, Duval County, Florida (Refs. 5; 6, p. 3) (see Figure 1 of this Hazard Ranking System [HRS] documentation record). Mo re specifically, the geographic coordinates, as measured from the FSWT entrance, are latitude 30° 21 ' 14.73" north and longitude 81° 41' 11.02" west (Ref. 4). The EPA identification number, as record ed in the Comprehensive Environmental Response, Compensation, and Liability Information System (C ERCLIS) database, is FLD000623041 (Ref. 5). From 1980 to 2010, FSWT operated a wood treating facility that pressure treated utility poles, pilings, heavy timber items, and plywood lumber products usi ng the wood treating preservative chromated copper arsenate (CCA) (Refs. 7, p. 1; 15, p. 2). The FSW T site comprises contaminated soil at and adjacent to the FSWT facility (Refs. 17, pp. 10 through 16, Appendi x A, pp. A-4, A-5, Appendix B, pp. B-8 through B-19, B-23, B-25, B-27, B-29 through B-33; 44, p. 5; 45, p. 1, Enclosure 2).

Features of the FSWT facility include an office building, a former feed building, parking lot, drip pad, drainage ditches, and retention pond (R efs. 17, Appendix A, p. A-2; 20, p. 15). Access to the facility is restricted by a fence, which surrounds the former operations area of the property. A portion of the FSWT property that extends west of the FSWT retention pond is not fenced (Ref. 19). FSWT is bordered to the north by CSX Transportation railroad tracks, to the east by Fairfax Street and residential properties beyond, to the south by West 14 th Street and residential properties beyond, and to the west by Susie E. Tolbert Elementary School (STES) and by Pullman Court residential properties (see Figure 2 of this HRS documentation record). The play area of STES is shar ed with its neighboring R.V. Daniels Elementary School (RVDES) (see Figure 2 of this HRS documenta tion record). The topography of the FSWT property and the surrounding area is generally flat (Ref. 40, p. 133) (see Figure 1 of this HRS documentation record).

Area of observed contamination (AOC) A is contaminated soil on the northern, western, and southern FSWT property boundaries, as well as on residential and school properties surrounding the FSWTproperty (Ref. 17, pp. 10 through 16, Appendix A, pp. A-4, A-5, Appendix B, pp. B-8 through B-19, B23, B-25, B-27, B-29 through B-32). Uncontrolled overland runoff from FSWT prior to 1990, periodic flooding and runoff from the storage yards along the northern, western, and southern portions of the FSWT property, and wheel spray from trucks or ot her vehicles exiting the FSWT facility all likely contributed to contaminant migration from the FSWT facility and the former operations area to surrounding properties within AOC A (Refs. 7, p. 7; 13, p. 9; 14, p. 26; 15, p. 21; 20, p. 15; 21, p. 1). Hazardous substances arsenic, chromium, and copper ha ve been detected in AOC A (see Section 5.0.1, General Considerations and Figure 2 of this HRS documentation record).

OPERATIONAL HISTORY

From 1980 to 2010, FSWT operated a wood treating facility that pressure treated utility poles, pilings, heavy timber items, and plywood lumber products us ing the wood treating preservative CCA. FSWT has never treated wood products with creosote or pentachlorophenol (Refs. 7, p. 1; 13, p. 9; 15, p. 2). CCA is characterized by a bright green color and is compo sed of waterborne oxides, or salts, of chromium, copper, and arsenic (Refs. 9, p. 5047-3; 10, p. 6). The copper serves as a fungicide, the arsenic serves as an insecticide, and the chromium binds the copper and arsen ic to the wood (Refs. 8, p. 1; 10, p. 6). In a typical pressure treatment process, wood is placed into horizontal cylinders or tanks. The air is then evacuated from the tanks, creating a vacuum. Later, the tanks are filled with the preservative chemical and the pressure is increased to 14 0 to 150 pounds per s quare inch (psi) for several hours, forcing the wood treating chemical into the wood. After that step is complete, the preservative is drained from the tanks, and a vacuum is once again applied to clear any excess preservative left on the surface of the wood. This process takes approximately 6 hours to complete (Ref. 9, pp. 5047-1, 5047-2). After treatment, the water evaporates, leaving only the salts (Refs. 8, p. 1; 10, p. 6). The salts react with the wood surface and become insoluble (Ref. 10, pp. 6, 9).13 During operations at FSWT, the wood was transferred to the drip pad after treatment to drip dry. Once the wood stopped visibly dripping, it was transferred to the storage yard to complete the drying process (Refs. 11; 12, p. 1; 15, p. 5). The storage yard w as composed of gravel areas along the northern, western, and southern FSWT property boundaries (Refs. 15, pp. 33, 36, 40, 56; 20, p. 15).

Prior to 1990, stormwater flow from the FSWT property was uncontrolled (Refs. 7, p. 7; 13, p. 9). A

conduit was used to route some of the stormwater to the STES retention pond (Ref. 7, p. 7). In 1990, FSWT operators installed a stormwater collection and retention system, including grading and paving for drainage, stormwater collection swales, diversion berm s, and a lined retention pond (Ref. 13, p. 9). The type of liner is believed to be hi gh-density polyethylene (HDPE) (Ref. 49). At that time, the conduit from FSWT to the STES retention pond was closed off (Ref. 7, p. 2). CCA deposited onto the drip pad during the drip-dry process mixed with stormwater, resulti ng in a CCA solution (Ref. 11). CCA-contaminated stormwater from the drip pad was diverted to an u nderground sump located adj acent to the storage tanks (Ref. 11). Once the stormwater inside the sump reached a specified volume, a pump transported the stormwater to one of two effluent tanks, where it w as recycled into the high-concentrate CCA treatment solution for re-use in the wood treating process (Refs. 11; 12, p. 1).

Stormwater that collected in areas other than the drip pad was diverted to ditches located along the northern, western, and southern property boundaries (R ef. 11). These ditches drain into the retention pond at the northwestern corner of the property’s operations area, immediately east of the property’s panhandle (Refs. 11; 20, p. 15). An overflow pipe is located in the retention p ond so that water overflows into the pipe and discharges approximately 1,000 feet west of the pond into nearby Moncrief Creek, a tributary of the Trout River, when the pond reaches a certain volume (Refs. 11; 15, pp. 8, 9, 18; 49).

The retention pond was designed to contain stormw ater runoff; however, the facility was abandoned, leaving all systems in place, when FSWT filed for Chapter 7 bankruptcy in July 2010 (Refs. 11; 55). After several rain events, the FSW T facility’s waste containment system overflowed into the retention pond. The retention pond is connected to a pipe that leads to Moncrief Creek (Refs. 11; 49). Prior to August 2010, the pond had not been sampled.

In March 2009, Wood Treaters, LLC (FSWT) filed for Chapter 11 bankruptcy, but continued to operate until July 2010 when the company’s bankruptcy case was c onverted to Chapter 7 (Refs. 51, p. 1; 54, p. 1; 55, p. 1).

PREVIOUS INVESTIGATIONS

From February 2008 to March 2010 , PE Services conducted several investigations at the FSWT property on behalf of the property owner, Wood Treaters, LL C. The Florida Department of Environmental Protection (FDEP) provided oversight and approval of activities conducted at FSWT (Ref. 53). After FSWT filed for Chapter 7 bankruptcy in July 2010, EP A conducted several investigations at and in the vicinity of the property (Refs. 15, p. 8; 16, p. 1; 17, p. 1; 44, p. 1; 55). Table 1 lists the previous investigations at FSWT, including the hazardous substances detected in the samples collected.

TABLE 1: Summary of Previous Investigations

Company/

Agency Investigation Date Samples

Collected Hazardous

Substances

Detected References

PE Services Site Assessment Report (SAR) – STES

Stormwater Retention Pond System February 2008 to May

2008 Soil, ground water, and

surface water Arsenic Copper

Chromium 7, pp. 1, 6, 8, 9, 21 through

2714 TABLE 1: Summary of Previous Investigations

Company/

Agency Investigation Date Samples

Collected Hazardous
Substances

Detected References

PE Services Site Assessment Report Addendum (SARA) – Wood Treaters, LLC and STES Properties October 2008

to March

2009 Soil and ground

water Arsenic

Chromium Copper 13, pp. 1, 8, 9, 33 through

43

PE Services Second Site Assessment Report Addendum (SARA 2) – Additional Sampling of Wood Treaters, LLC Property, Adjacent Off-Site Properties, STES Property and Properties, and Background

Definition Studies September

2009 to

March 2010 Soil and ground

water Arsenic

Chromium Copper 14, pp. 1, 6, 7, 8 through 11, 35 through 47

EPA Emergency Response August 2010 Soil, surface water, sediment,

and waste Arsenic

Cadmium

Total chromium

Chromium III

Chromium VI Copper

Lead

Zinc 15, pp. 1, 8 through 14, 24 through 28

EPA Removal Investigation January 2011 Soil, surface water, and

sediment Arsenic

Chromium Copper 16, pp. 1, 2, 3, 4, Appendix B, pp. B-2 through B-11

EPA Pre-Remedial Investigation (Pre-RI) May 2011 Soil, ground water, and

concrete Arsenic

Cadmium

Chromium Copper

Lead Manganese

Nickel 17, p. 12, Appendix B,pp. B-23, B25, B-27, B29 through B36

EPA Removal Confirmation

and Residential Sampling Event July 2011 Soil and air Arsenic

Cadmium

Chromium Copper

Lead Manganese

Nickel

Zinc 44, p. 5; 45, p. 1,

Enclosure 2

Notes: EPA U.S. Environmental Protection Agency STES Susie Tolbert Elementary School

During the August 2010 emergency response (ER), EPA collected waste samples from six steel tanks that contained wood treating products. Four of the six steel tanks were full, and the other two tanks contained

minimal volume. The combined volume of the four full steel tanks at the time of the August 2010 ER was 77,000 gallons (Ref. 15, pp. 11, 23, 24, 25). On e waste sample was collect ed from each of the six15 tanks. Waste samples contained arsenic (up to 17,900 milligrams per liter [mg/L]), cadmium (up to 30.8 mg/L), chromium III (up to 3,700 mg/L), chromium VI (up to 17,000J+ mg/L), copper (up to 12,100 mg/L), and manganese (up to 10.7J mg/L), among others (Ref. 15, pp. 24, 25).

In March 2011, EPA initiated removal activities at the FSWT property and the adjacent STES and RVDES shared play area. A liner was encountered on the FSWT property about 6 to 8 inches bgs along the northern, western, and southern property boundari es that are not covered with concrete (Ref. 22). EPA scraped these areas down to about 1.5 feet bgs and separated the fines from the gravel (Ref. 22). The fines were sampled and results did not exceed th e toxicity characteristic leaching procedure (TCLP); therefore, the fines were disposed of as nonhazardous waste (Ref. 22). The gravel was power washed and spread back on top of the excavation surface. Th e FSWT retention pond was drained and the sediments were partially excavated (Ref. 22). EPA cleaned and cut up or crushed the tanks (six steel tanks and one fiberglass tank, seven in all) in the tank farm; the metal from the six steel tanks was taken to a recycler (Ref. 22). Once the tanks were removed, the secondar y containment area was cleaned (Ref. 22). On the STES property, sediments in the STES re tention pond were removed and re placed with clean fill material, and the area surrounding the pond was re-sodded (Ref. 22). In addition, a small area on the STES and RVDES shared playground — where arsenic had been detected at a concentration exceeding its EPA removal action level of 39 mg/kg — was removed, b ackfilled with clean material, and re-sodded (Refs. 16, p. 4; 17, Appendix B, p. B-13; 22; 50, p. 6).

In October 2011, removal activities were also conducte d at three residential properties located east and south of FSWT (Ref. 47, p. 1). Soil samples collected from these properties in May 2011 contained arsenic above or just below its EPA removal action le vel of 39 mg/kg (Refs. 17, Appendix B, pp. B-31, B-32; 47, p. 1; 50, p. 6). The top 6 inches of soil was excavated in the front and back yards of two properties on Fairfax Street and only the backyard of one property on West 13 th Street. After each excavation, Tetra Tech collected 5-point confirma tion composite soil samples at 6 inches below ground surface at each of the three residential properties (Ref. 47, pp. 1, 6, 11, 13, 18). Arsenic was detected in confirmation samples up to 6.43 mg/kg (Ref. 47, pp. 27, 38, 49). The excavated areas were backfilled with clean topsoil and either re-s odded or mulched (Ref. 47, pp. 1, 9, 14, 16). EPA removal action activities were completed in December 2011 (Ref. 22).

Removal activities were taken into account when selec ting the observed contamination samples evaluated in this HRS documentation record (see Section 5.0.1).

FSWT installed the lined retention pond on the northw estern corner of the operations area on the property in 1990 as part of its stormwater collection and re tention system. The pond was designed to contain stormwater runoff; however, the facility was abandoned, leaving all systems in place, when FSWT filed for Chapter 7 bankruptcy in July 2010 (Refs. 7, p. 7; 11; 15, p. 14; 55). After several rain events, FSWT’s waste containment system overflowed into the re tention pond. At the time of the ER in August 2010, the retention pond was a bright lime green colo r, characteristic of CCA contamination (Refs. 11; 15, Appendix C, p. C-4). The retention pond is connect ed to a pipe that leads to Moncrief Creek (Refs. 11; 49). One surface water sample, WTI-POND, was collected from the retention pond in August 2010. This sample contained arsenic (23,000 μg/L), chromium III (500 μg/L), chromium VI (31,000J+ μg/L), copper (16,900 μg/L), and zinc (243 μg/L), among others (Refs. 15, pp. 9, 28; 17, Appendix A, p. A-3). Prior to August 2010, there is no evidence that the pond had been sampled. Sediment sample FRW-SED03 was also collected from the retention pond in Au gust 2010. This sample contained arsenic (2,840 mg/kg), cadmium (6.75 mg/kg), chromium III (5 ,389 mg/kg), copper (3,380 mg/kg), and zinc (371 mg/kg), among others (Refs. 15, pp. 14, 26; 17, Appendix A, p. A-3). The FSWT retention pond was sampled again during the January 2011 removal inves tigation. Two sediment samples and four surface water samples (including one duplicate) were collected from the FSWT retention pond (Refs. 16, pp. 3, 5; 17, Appendix A, p. A-4). The sediment samples cont ained arsenic (up to 3,560 mg/kg), chromium (up to 10,700 mg/kg), and copper (up to 5,540 mg/kg). The surface water samples also contained arsenic (up to 1,430 μg/L), chromium (up to 468 μg/L), and copper (up to 401 μg/L) (Ref. 16, Appendix B, pp. B-10, B11).16 SE – AOC A General Considerations 5.0 SOIL EXPOSURE PATHWAY

5.0.1 General Considerations

Letter by which this area is to be identified: A

Name and description of the area: FSWT Facilit y and Surrounding School and Residential Properties (Contaminated Soil Area A)

Location of the area, with reference to a map of the site:

Soil sample locations meeting observed contamination cr iteria were used to delineate AOC A. AOC A is located in a primarily residential area of Jacksonville, Duval County, Florida (Refs. 5; 6, p. 3) (see Figure 2 of this HRS documentation record). AOC A consists of contaminated soil along the northern, southern, and western portions of the FSWT property, as well as residential neighborhoods east, south, and west of FSWT, and one elementary school property (STES) directly west of FSWT and the Faith Deliverance school and daycare directly east of FSWT (see Tables 4, 5, 8, 9, 12, and 13 of this HRS documentation record). The play area of STES is shared with its neighboring school, RVDES. AOC A is depicted on Figure 2 of this HRS documentation record.

The topography of the FSWT property and the surroundi ng area is generally flat; the facility’s elevation above mean sea level is 26 feet with slight decreases in elevation in a 1⁄2 mile radius to the east, south and west (Ref. 40, p. 133) (see Figure 1 of this HRS doc umentation record). Contaminated soil on the FSWT property resulted from uncontrolled stormwater runoff prior to 1990, leaks of CCA from cracks in the drip pad, and contamination from drip drying and st oring treated material on gravel along the northern, western, and southern portions of the FSWT property (Ref s. 12, pp. 1, 16; 20, p. 15; 21, p. 1). In 1990, FSWT installed a stormwater collection and retention system, including grading and paving for drainage, stormwater collection swales, diversion berms, and an HDPE-lined retention pond (Refs. 13, p. 2; 22). CCA deposited onto the drip pad during the drip-dry process mixed with stormwater, resulting in a CCA solution. CCA-contaminated stormwater from the drip pad was diverted to an underground sump located adjacent to the storage tanks. Once the stormwater inside the sump reached a specified volume, a pump transported the stormwater to one of two effluent tanks, where it was recycled into the high-concentrate CCA treatment solution (Refs. 11; 12, p. 1).

Stormwater that collects in areas on the FSWT property other than the drip pad is diverted to ditches located along the northern, western, and southern property boundaries. These ditches drain into the retention pond at the northwestern corner of the property (Refs. 11; 17, Appendix A, p. A-2; 50, p. 7). An overflow pipe is located in the retention pond so th at water overflows into the pipe and discharges into nearby Moncrief Creek, a tributary of the Trout River, when the pond reaches a certain volume (Refs. 11; 49).

The topography of the FSWT property is generally flat and, prior to 1990, stormwater flow from the FSWT property was uncontrolled (Refs. 33, p. 1; 40, p. 133). A conduit was used to route some of the stormwater to the STES retention pond. In 1990, th is conduit was closed off when FSWT installed the stormwater collection and management system (Ref. 7, p. 2). The FSWT property is bordered to the north by CSX Transportation railroad tracks, to the east by Fairfax Street and residential properties beyond, to the south by West 14 th Street and residential properties beyond, and to the west by STES and by Pullman Court, with RVDES beyond (see Figure 2 of this HRS documentation record). These areas of contaminated soil became contaminated by uncontro lled stormwater runoff from FSWT prior to 1990 and periodic flooding and runoff from the storage yards along the northern, western, and southern portions of the FSWT property. Nearby residents have reporte d that stormwater runoff currently flows from the FSWT property onto their properties during heavy rain events (Refs. 21, p. 1; 34; 36, p. 2; 37, pp. 1, 2; 38; 43, pp. 1, 2, 3; 50, p. 7).17 SE – AOC A General Considerations In January 2011, EPA conducted a removal investigation at the FSWT property, the STES and RVDES properties, and residential properties south and west of the FSWT property (Ref. 16, p. 1). Surface (0 to 12 inches bgs) and subsurface (12 to 24 inches bgs) so il samples were collected from the FSWT property and the STES and RVDES properties in locations wher e children were observed playing (Ref. 16, pp. 2, 3, 4, Appendix D, pp. D-4, D-8). The northern portion of the FSWT property contained the highest concentrations of arsenic (377 mg/kg in FWT-02- SB-A2), chromium (1,260 mg/kg in FWT-03-SB-A2), and copper (405 mg/kg in FWT-02-SB-A2) (Ref. 16, Appe ndix A, p. A-3, Appendix B, p. B-7. On the shared play area, the highest concentrations of arsenic (64 mg/kg), chromium (237 mg/kg), and copper (110 mg/kg) were detected in surface soil sample FW T-01-SF, located near the fence line separating the STES property and the FSWT property (Ref. 16, Appe ndix A, p. A-3, Appendix B, p. B-2).

In addition, composite surface soil samples were co llected from 17 residential properties, including 13 along Pullman Court and four along West 14 th Street. Four surface soil samples were also collected from an apartment complex located on West 13 th Street that contains 12 occupied units (Ref. 16, p. 3, Appendix A, p. A-3, Appendix F, pp. F-9, F-10). The highest concentrations of arsenic (30.4 mg/kg), chromium (127 mg/kg), and copper (70.6 mg/kg) were detect ed in observed release soil sample FWT-39-SF-BY, collected from a residential property along Pullman Court (Ref. 16, Appendix B, p. B-5).

Removal activities were initiated at the FSWT pr operty in March 2011 (Ref. 22). A liner was encountered about 6 to 8 inches bgs in areas along the northern, western, and southern property

boundaries that are not covered with concrete (Ref. 22). EPA scraped these areas down to about 1.5 feet, removing the liner, and separated the fines from the gravel (Ref. 22). The fines were analyzed and disposed of as non-hazardous waste (Ref. 22). These areas were excavated down to 1 foot or 1.5 feet during the EPA removal action and were not backfilled with soil (Ref. 22). The gravel was power washed and spread back on top of the excava tion surface for dust control (Ref. 22).

In May 2011, EPA conducted a pre-RI at the FSWT property. In total, 22 soil samples (including two duplicates) were collected from the FSWT property (Ref . 17, p. 12). The highest arsenic concentration (130 mg/kg) was detected in observed release surfa ce soil sample WT-SF-19, which was collected along the western FSWT property boundary in an area where yellow soil was observed, an indication of arsenic contamination (Refs. 17, p. 12, Appendix A, p. A-5, Appendix B, p. B-29, Appendix C, p. C-3; 19). The highest concentration of chromium (1,300 mg/kg) was detected in surface soil sample WT-SF-07, collected beneath the drip pad (Ref. 17, Appendix A, p. A-5, Appendix B, p. B-25).

Nine surface soil samples (0 to 6 inches bgs) were also collected from residential properties located east and south of the FSWT property (Ref. 17, pp. 12, 13, A ppendix A, p. A-5). Observed releases of arsenic, chromium, and copper were detected in residential surface soil samples. Arsenic concentrations ranged from 6.5 mg/kg (WT-RP-SF-05) to 64 mg/kg (WT-RP-SF-08), chromium concentrations ranged from 26mg/kg (WT-RP-SF-02) to 130 mg/kg (WT-RP-SF-08), and copper ranged from 20 mg/kg (WT-RP-SF06) to 71 mg/kg (WT-RP-SF-08) (Ref. 17, Appendix A, p. A-5, Appendix B, pp. B-23, B-25).

In July 2011, EPA conducted a removal confirmation and residential sampling event at the FSWT property. Removal activities included the excavation of gravel and soil down to 1.5 feet bgs along the northern, western, and southern property boundaries. Post-excavation composite soil samples were collected from the northern, western, and southern property boundaries at 0 to 6 inches below excavation surface and 18 to 24 inches below excavation surface (Ref s. 44, Appendix B, p. B-1; 45, p. 1). In surface soil samples (0 to 6 inches bgs), arsenic concentra tions ranged from 5.5J mg/kg (WT-G01-SS-A) to 44J mg/kg (WT-G03-SS-A), chromium concentrations ra nged from 47 mg/kg (WT-G02-SS-A) to 280J mg/kg (WT-G04-SS-A-DUP), and copper was detected at 300 mg/kg (Ref. 45, Enclosure 1, p. E1-1).

Composite surface soil (0 to 6 inches bgs) samples were also collected from the front and back yards of 10 residences west, east, and south of the FSWT prope rty (Ref. 45, p. 1). Arsenic was detected in residential surface soil samples. The highest arsenic concentration (11J mg/kg) was detected in sample

WT-RP-11-SF-BY collected from a residential property on West 16 th Street (Ref. 45, Enclosure 1, p. E1- 13).18 SE – AOC A General Considerations The soil samples collected from the FSWT property th at establish observed contamination were collected

from areas where no removal activities occurred or fro m 0 to 24 inches bgs after excavation activities and below the gravel layer. The soil samples collected from residential properties that establish observed

contamination were collected from areas where no re moval activities have occurred (Refs. 17, Appendix A, pp. A-4, A-5; 22; 45, Enclosure 1, p. E1-1) (see Figure 4 of this HRS documentation record). All soil samples used to establish observed contamination were compared to background. Background soil samples collected in January, May, and July 2011 were collected from two areas surrounding FSWT. Background concentrations of arsenic ranged from non detect (1.8U mg/kg) to 1.6J (2.78) mg/kg; chromium ranged from 5.47 mg/kg to 14J (18.06) mg/ kg; and copper ranged from 5.6J (6.83) mg/kg to 37 mg/kg (see Tables 3, 7, and 11 of this HRS documentation record).

AOC A is determined by observed contamination sampl es contained in Tables 4, 5, 8, 9, 12, and 13 of

this HRS documentation record. AOC A is defined as contaminated soil (down to 24 inches) below the excavated surface along the northern, western, and southern FSWT property boundaries, as well as the

FSWT-owned area north of Pullman Court and south of the CSX Transportation railroad tracks (Refs. 16, Appendix D, pp. D-12, D-13; 17, Appendix A, pp. A-4, A-5, Appendix D, p. D-11). Also included in AOC A is soil (down to 24 inches bgs) on residentia l and school properties located east, south, and west of the FSWT property. All of the soil samples collect ed on residential or school and daycare properties

used to establish observed contamination for AOC A we re collected within 200 feet of the associated residence or school/daycare building (Refs. 17, Appendix A, pp. A-4, A-5; 20, p. 15) (see Figure 2 of this HRS documentation record).

Removal activities were taken into account when selec ting the observed contamination samples evaluated in this HRS documentation record (see pages 19 through 37 of this HRS documentation record).19 SE – AOC A General Considerations EPA January 2011 Removal Investigation

Background Sample

The background soil sample listed in Table 2 was collected during the EPA January 2011 removal investigation (Refs. 16, pp. 1, 2, Appendix D, p. D-13, Appendix F, pp. F-10, F-28; 17, Appendix A, p. A-4; 39, pp. 7, 8). The background soil sample was collected from the Raymond E. Davis Park, north of the FSWT property, at a depth of 0 to 12 inches bgs (Refs. 16, p. 2, Appendix D, pp. D-4, D-13; 17, Appendix A, p. A-4) (see Figure 3 of this HRS docum entation record). This location was chosen to represent background conditions because (1) the soil type at the location of FWT-00-SB-A2 is similar to the soil types at the locations of samples collected from AOC A and (2) this sampling location is about 535 feet north of FSWT and appears to be minimally affected by facility operations (Refs. 16, p. 2, Appendix D, p. D-13; 17, Appendix A, p. A-4; 41, pp. 1-4; 48, p. 21, Sheet Number 32) (see Figure 3 of this documentation record).

Background and contaminated soil samples were collected during the same sampling event, from the same type of soil (sandy soils, Pelham-Urban la nd complex), and in accordance with similar sampling procedures (Refs. 17, Appendix A, p. A-4; 41, pp. 1 through 4; 48, p. 21, Sheet Number 32). The background surface soil sample was collected in accordance with the EPA Region 4 Science and Ecosystem Support Division (SESD) Field Branches Qua lity System and Technical Procedures for Soil Sampling, SESDPROC-300-R1 (Refs. 16, p. 2, Appendi x D, p. D-3; 28). The location of the background soil sample is depicted in Reference 17, Appendix A, Figure 4, page A-4. Chain-of-custody records are provided in Reference 16, Appendix F. Logbook notes are provided in Reference 16, Appendix D.

TABLE 2: AOC A Background Soil Sample Description – January 2011

Sample ID Sample Location Depth (inches bgs) Date Sampled References

FWT-00-SB-A2 Raymond E. Davis Park, north of the FSWT property

at the corner of West 20 th
Street and Spires Avenue 0 to 12 01/19/2011 16, p. 2, Appendix D, pp. D-4, D-13, Appendix F, p. F-10; 17, Appendix A, p. A-4

Notes:

A2 Sample depth of 0 to 12 inches (Ref. 16, Appendix D, p. D-4)

AOC Area of observed contamination bgs Below ground surface

FSWT Fairfax St. Wood Treaters

FWT Fairfax St. Wood Treaters

ID Identification number

SB Subsurface soil

WT Fairfax St. Wood Treaters20 SE

– AOC A General Considerations Background Concentrations

The background soil sample listed in Table 3 was collected by EPA during the January 2011 r emoval

i nvestigation (Refs. 16, p. 1, Appendix D, p. D

- 13, Appendix F, pp. F

- 10, F

- 28; 17, Appendix A, p. A

- 4)

. S oil samples collected during the January 2011 removal investigation were analyzed by Environmental Conservation Laboratories, Inc. (ENCO), a Tetra Tech

- procured laboratory, for arsenic, chr omium, and copper using EPA SW

- 846 Method 6010C (Ref. 16, p. 4, Appendix E, p. E

- 3, Appendix F, p. F

- 135). A Tetra Tech chemist validated the analytical data in accordance with the EPA Contract Laboratory Program ( CLP ) National Functional Guidelines for S uperfund Inorganic Data Review (January 2010) (Refs. 16, Appendix E, p. E

- 3; 29). The practical quantitation limits (PQL) are listed on the analytical data sheets in Reference 16, Appendix F. Each PQL is sample

- specific and corresponds to the lowest

quan titative point on the calibration curve; it is adjusted for the amount of sample prepared and any dilutions performed, as well as for percent moisture. The PQLs are equivalent to sample quantitation limits ( SQL ) (Ref. 32).

TABLE 3 : Analytical Results for AOC A Background Soil Sample

– January 2011

Sample ID Hazardous
Substance Concentration PQL References

FWT

- 00

- SB

- A2 Arsenic 1. 1 4J ( 1.98 ) mg/kg 1.17 mg/kg 16, Appendix E, pp. E

- 7, E

- 97, Appendix F, p. F

- 135; 26, p p

. i,

1

FWT

- 00

- SB

- A2 Chromium 5.47 mg /kg 1.17 mg/kg 16, Appendix F, p. F

- 135

FWT

- 00

- SB

- A2 Copper 10.1 mg/kg 1.17 mg/kg 16, Appendix F, p. F

- 135

Notes:

( ) Concentrations shown in parentheses were adjusted in accordance with References 26 and 27.

A2 Sample depth of 0 to 12 inches ( Ref. 16, Appendix D, p. D

- 4 )

AOC Area of observed contamination

FWT Fairfax St. Wood Treaters

ID Identification number

J The analyte was positively identified; the associated value is the approximate concentration of the analyte in the sample (Ref. 16, Appendix E , pp. E

- 3, E

- 97)

. mg/kg Milligrams per kilogram PQL Practical quantitation limit

S B Subs urface soil21 SE – AOC A General Considerations Contaminated Samples

The soil samples listed in Table 4 were collected from the FSWT property, as well as from school and residential properties during the EPA January 2011 re moval investigation in accordance with the EPA Region 4 SESD Field Branches Quality System and Technical Procedures for Soil Sampling, SESDPROC300-R1 (Refs. 16, pp. 1, 2, Appendix D, p. D-3; 17, Appe ndix A, p. A-4; 28; 39, p. 7) (see Figure 2 of this HRS documentation record). Soil samples were collected between 0 and 6 inches bgs (Ref. 52). Logbook notes are provided in Reference 16, Appendix D. Chai n-of-custody records are provided in Reference 16, Appendix F. The locations of the soil samples coll ected from the residential and school properties are depicted on page A-4 of Reference 17, Appendix A.

TABLE 4: AOC A Soil Sample Descriptions – January 2011

Sample ID Sample Location Depth (inches bgs) Date Sampled References

FSWT Property

FWT-42-SF-CG FSWT property

between Pullman

Court and CSX railroad tracks, just

west of the FSWT retention pond 0 to 6 01/19/2011 16, p. 3, Appendix D, p. D12, Appendix F, p. F-10; 52

FWT-44-SF FSWT property

between Pullman

Court and CSX

railroad tracks 0 to 6 01/19/2011 16, p. 3, Appendix D, p. D13, Appendix F, p. F-12; 52

School Property

FWT-02-SF STES and RVDES shared play area,

north of the STES retention pond 0 to 6 01/17/2011 16, p. 3, Appendix D, p. D-7, Appendix F, p. F-6; 52

FWT-17-SF Northwest of STES buildings 0 to 6 01/17/2011 16, p. 3, Appendix D, pp. D7, D-8, Appendix F, pp. F-7, F-8; 52 FWT-30-SF 0 to 6 01/17/2011

Residential Properties

FWT-35-SF-BY FWT-35 0 to 6 01/19/2011 16, p. 3, Appendix D, p. D12, Appendix F, p. F-9; 52

FWT-36-SF-BY FWT-36 0 to 6 01/19/2011 16, p. 3, Appendix D, p. D12, Appendix F, p. F-9; 52

FWT-37-SF-FY FWT-37 0 to 6 01/19/2011 16, p. 3, Appendix D, p. D12, Appendix F, p. F-9; 52 FWT-37-SF-BY 0 to 6 01/19/2011

FWT-38-SF-BY FWT-38 0 to 6 01/19/2011 16, p. 3, Appendix D, p. D12, Appendix F, p. F-10; 52

FWT-39-SF-FY FWT-39 0 to 6 01/19/2011 16, p. 3, Appendix D, p. D12, Appendix F, p. F-10; 52 FWT-39-SF-BY 0 to 6 01/19/2011

FWT-40-SF-FY FWT-40 0 to 6 01/19/2011 16, p. 3, Appendix D, p. D12, Appendix F, p. F-10; 52 FWT-40-SF-BY 0 to 6 01/19/201122 SE – AOC A General Considerations TABLE 4: AOC A Soil Sample Descriptions – January 2011

Sample ID Sample Location Depth (inches bgs) Date Sampled References

FWT-41-SF-FY FWT-41 0 to 6 01/19/2011 16, p. 3, Appendix D, p. D12, Appendix F, p. F-10; 52 FWT-41-SF-BY 0 to 6 01/19/2011

FWT-43-SF-BY FWT-43 0 to 6 01/19/2011 16, p. 3, Appendix D, p. D13, Appendix F, p. F-10; 52

FWT-49-SF FWT-49 0 to 6 01/20/2011 16, p. 3, Appendix D, p. D15, Appendix F, p. F-12; 52

Notes:

AOC Area of observed contamination bgs Below ground surface BY Backyard CG Community garden

FSWT Fairfax St. Wood Treaters

FWT Fairfax St. Wood Treaters FY Front yard

ID Identification number RVDES R.V. Daniels Elementary School

SF Surface soil STES Susie Tolbert Elementary School23 SE – AOC A General Considerations Contaminated Concentrations

The soil samples listed in Table 5 were collected during the EPA January 2011 removal investigation (Refs. 16, pp. 2, 3; 17, Appendix A, p. A-4; 39, p. 7). Soil samples collected during the January 2011 removal investigation were analyzed by ENCO, a Tetra Tech-procured laboratory, for arsenic, chromium, and copper using EPA SW-846 Method 6010C (Ref. 16, p. 4, Appendix E, p. E-3, Appendix F, pp. F-15, F-16, F-17). A Tetra Tech chemist validated th e analytical data in accordance with the EPA CLP National Functional Guidelines for Superfund Inorganic Data Review (January 2 010) (Refs. 16, Appendix E, p. E-3; 29). The PQLs are liste d on the analytical data sheets in Reference 16, Appendix F. Each PQL is sample-specific and corresponds to the lowest quan titative point on the calibration curve; it is adjusted for the amount of sample prepared and any dilutions performed, as well as for percent moisture. The PQLs are equivalent to SQLs (Ref. 32).

TABLE 5: Analytical Results for AOC A Soil Samples – January 2011

Sample ID Hazardous

Substance Concentration PQL Reference

FSWT Property

FWT-42-SF-CG Arsenic 36.3 mg/kg 0.992 mg/kg 16, Appendix F, p. F-132

FWT-42-SF-CG Chromium 76.7 mg/kg 0.992 mg/kg 16, Appendix F, p. F-132

FWT-42-SF-CG Copper 54.0 mg/kg 0.992 mg/kg 16, Appendix F, p. F-132

FWT-44-SF Arsenic 27.9 mg/kg 0.908 mg/kg 16, Appendix F, p. F-148

FWT-44-SF Chromium 53.5 mg/kg 0.908 mg/kg 16, Appendix F, p. F-148

FWT-44-SF Copper 60.8 mg/kg 0.908 mg/kg 16, Appendix F, p. F-148

School Property

FWT-02-SF Arsenic 12.3 mg/kg 0.585 mg/kg 16, Appendix F, p. F-83

FWT-02-SF Chromium 28.5 mg/kg 0.585 mg/kg 16, Appendix F, p. F-83

FWT-17-SF Chromium 18.1 mg/kg 2.44 mg/kg 16, Appendix F, p. F-98

FWT-17-SF Copper 49.9 mg/kg 2.44 mg/kg 16, Appendix F, p. F-98

FWT-30-SF Chromium 16.6 mg/kg 2.33 mg/kg 16, Appendix F, p. F-111

FWT-30-SF Copper 74.5 mg/kg 2.33 mg/kg 16, Appendix F, p. F-111

Residential Properties

FWT-35-SF-BY Arsenic 7.33 mg/kg 1.20 mg/kg 16, Appendix F, p. F-119

FWT-36-SF-BY Arsenic 12.4 mg/kg 1.20 mg/kg 16, Appendix F, p. F-121

FWT-36-SF-BY Chromium 36.3 mg/kg 1.20 mg/kg 16, Appendix F, p. F-121

FWT-36-SF-BY Copper 53.3 mg/kg 1.20 mg/kg 16, Appendix F, p. F-121

FWT-37-SF-FY Chromium 17.5 mg/kg 1.16 mg/kg 16, Appendix F, p. F-122

FWT-37-SF-BY Chromium 17.3 mg/kg 1.19 mg/kg 16, Appendix F, p. F-123

FWT-37-SF-BY Copper 47.6 mg/kg 1.19 mg/kg 16, Appendix F, p. F-123

FWT-38-SF-BY Arsenic 15.0 mg/kg 1.16 mg/kg 16, Appendix F, p. F-125

FWT-38-SF-BY Chromium 52.4 mg/kg 1.16 mg/kg 16, Appendix F, p. F-12524 SE – AOC A General Considerations TABLE 5: Analytical Results for AOC A Soil Samples – January 2011

Sample ID Hazardous
Substance Concentration PQL Reference

FWT-38-SF-BY Copper 33.7 mg/kg 1.16 mg/kg 16, Appendix F, p. F-125

FWT-39-SF-FY Arsenic 7.18 mg/kg 1.13 mg/kg 16, Appendix F, p. F-126

FWT-39-SF-FY Chromium 23.3 mg/kg 1.13 mg/kg 16, Appendix F, p. F-126

FWT-39-SF-BY Arsenic 30.4 mg/kg 1.19 mg/kg 16, Appendix F, p. F-128

FWT-39-SF-BY Chromium 127 mg/kg 1.19 mg/kg 16, Appendix F, p. F-128

FWT-39-SF-BY Copper 70.6 mg/kg 1.19 mg/kg 16, Appendix F, p. F-128

FWT-40-SF-FY Arsenic 10.2 mg/kg 1.09 mg/kg 16, Appendix F, p. F-127

FWT-40-SF-FY Chromium 29.9 mg/kg 1.09 mg/kg 16, Appendix F, p. F-127

FWT-40-SF-BY Arsenic 22.4 mg/kg 1.18 mg/kg 16, Appendix F, p. F-129

FWT-40-SF-BY Chromium 71.8 mg/kg 1.18 mg/kg 16, Appendix F, p. F-129

FWT-40-SF-BY Copper 58.4 mg/kg 1.18 mg/kg 16, Appendix F, p. F-129

FWT-41-SF-FY Chromium 23.5 mg/kg 1.11 mg/kg 16, Appendix F, p. F-130

FWT-41-SF-BY Arsenic 28.7 mg/kg 1.16 mg/kg 16, Appendix F, p. F-131

FWT-41-SF-BY Chromium 58.0 mg/kg 1.16 mg/kg 16, Appendix F, p. F-131

FWT-41-SF-BY Copper 44.0 mg/kg 1.16 mg/kg 16, Appendix F, p. F-131

FWT-43-SF-BY Arsenic 7.69 mg/kg 1.17 mg/kg 16, Appendix F, p. F-134

FWT-43-SF-BY Chromium 22.7 mg/kg 1.17 mg/kg 16, Appendix F, p. F-134

FWT-43-SF-BY Copper 36.1 mg/kg 1.17 mg/kg 16, Appendix F, p. F-134

FWT-49-SF Arsenic 5.99 mg/kg 1.05 mg/kg 16, Appendix F, p. F-154

FWT-49-SF Copper 42.5 mg/kg 1.05 mg/kg 16, Appendix F, p. F-154

Notes:

AOC Area of observed contamination CG Community garden BY Backyard

FSWT Fairfax St Wood Treaters

FWT Fairfax St Wood Treaters FY Front yard

ID Identification number mg/kg Milligrams per kilogram PQL Practical quantitation limit

SF Surface soil25 SE – AOC A General Considerations EPA May 2011 Pre-RI

Background Sample

The background soil sample listed in Table 6 was collected during the EPA May 2011 pre-RI (Refs. 17, p. 12, Appendix A, p. A-5, Appendix D, p. D-11; 23, p. 3). The background soil sample was collected from a location about 1,600 feet west of the northwestern co rner of the old feed building (Ref. 17, Appendix A, p. A-5) (see Figure 3 of this HRS documentation record). The background surface soil sample was collected at a depth of 0 to 6 inches bgs (Refs. 17, p. 12; 18, p. 6, Appendix B, p. B-1). This location was chosen to represent background conditions because (1) the soil type at the location of WT-BG-SF-01 is similar to the soil types at the locations of sampl es collected from AOC A and (2) this sampling location appears to be minimally affected by facility opera tions (Ref. 41, pp. 1 through 4) (see Figure 3 of this HRS documentation record).

Background and contaminated soil samples were collected during the same sampling event, from the same type of soil (sandy soils, Pelham-Urban land complex), and in accordance with the same sampling procedures (Refs. 17, p. 12, Appendix A, p. A-5; 41, pp. 1 through 4; 48, p. 21, Sheet Number 32). The background surface soil sample was collected in accordance with the EPA Region 4 SESD Field Branches Quality System and Technical Procedures for Soil Sampling, SESDPROC-300-R1 (Refs. 17, p. 12, Appendix D, p. D-9; 18, p. 6; 28). The location of the background soil sample is depicted in Reference 17, Appendix A, Figure 5, page A-5, and is described in Reference 19. Chain-of-custody records are provided in Reference 23. Logbook notes are provided in Reference 17, Appendix D.

TABLE 6: AOC A Background Soil Sample Description – May 2011

Sample ID Sample Location Depth (inches bgs) Date Sampled References

WT-BG-SF-01 Collected from the

northwestern corner of the RVDES property 0 to 6 05/10/2011 17, p. 12, Appendix A, p. A-5, Appendix D, p. D-11; 19; 23, p. 3

Notes:

AOC Area of observed contamination BG Background bgs Below ground surface

ID Identification number RVDES R.V. Daniels Elementary School

SF Surface soil

WT Fairfax St. Wood Treaters26 SE – AOC A General Considerations Background Concentrations

The background soil sample listed in Table 7 was collected during the EPA May 2011 pre-RI sampling event (Refs. 17, p. 12, Appendix A, p. A-5, Appendix D, p. D-11; 23, p. 3). Soil samples collected during the May 2011 pre-RI were analyzed under the EPA C LP for Total Analyte List (TAL) metals using EPA CLP Statement of Work (SOW) ISM01.2 (Ref. 17, p. 8, Appendix E, p. E-167). EPA Region 4 SESD reviewed all data according to the CLP SOWs and EPA guidelines (Refs. 17, Appendix E, p. E-167; 24). The MRLs are listed on the analytical data sheets in Reference 17, Appendix E. Each MRL is samplespecific and corresponds to the lowest quantitative point on the calibration curve; it is adjusted for the amount of sample prepared and any dilutions perform ed, as well as for percent moisture. The MRLs are equivalent to SQLs (Ref. 25).

TABLE 7: Analytical Results for AO C A Background Soil Sample – May 2011

Sample ID Hazardous

Substance Concentration MRL References

WT-BG-SF-01 Arsenic 1.8U mg/kg 0.82 mg/kg 17, Appendix E, p. E-199; 56, p. i

WT-BG-SF-01 Chromium 6.7 mg/kg 0.82 mg/kg 17, Appendix E, p. E-199

WT-BG-SF-01 Copper 5.6J (6.83) mg/kg 2.0 mg/kg 17, Appendix E, p. E-199; 26, pp. i, 1; 27, pp. 8, 18

Notes:

( ) Concentrations shown in parentheses were adju sted in accordance with References 26 and 27.

AOC Area of observed contamination BG Background

ID Identification number J The identification of the analyte is acceptable; the reported value is an estimate (Ref. 17, Appendix E, p. E-6). mg/kg Milligrams per kilogram MRL Minimum reporting limit

SF Surface soil U The analyte was not detected at or above the associated value (Refs. 17, Appendix E, p. E-199; 56, p. i).

WT Fairfax St. Wood Treaters27 SE – AOC A General Considerations Contaminated Samples

The soil samples listed in Table 8 were collected from the FSWT property, as well as from residential properties and a school/daycare property during the EPA May 2011 pre-RI in accordance with the EPA Region 4 SESD Field Branches Quality System and Technical Procedures for Soil Sampling, SESDPROC-300-R1 (Refs. 17, p. 12, Appendix A, p. A- 5, Appendix D, pp. D-9, D-10, D-11; 18, p. 6; 28) (see Figure 2 of this HRS documentation record). Soil samples were collected from 0 to 6 inches bgs (Refs. 17, p. 12; 18, p. 6, Appendix B, p. B-1, B- 3, B-4; 19). Logbook notes are provided in Reference 17, Appendix D. Chain-of-custody records are pr ovided in Reference 23. The locations of the soil samples collected from the FSWT property, and residential and school properties are depicted in Reference 17, Appendix A, page A-5 (see Figur e 2 of this HRS documentation record).

TABLE 8: AOC A Soil Sample Descriptions – May 2011

Sample ID Sample Location Depth (inches bgs) Date Sampled References

FSWT Property

WT-SF-01 Southwestern corner of the FSWT property 0 to 6 05/10/2011 17, p. 12, Appendix A, p. A-5, Appendix D, p. D-11; 23, p. 1

WT-SF-02 Southern portion of the FSWT property,

near West 14 th Street 0 to 6 05/10/2011 17, p. 12, Appendix A, p. A-5, Appendix D, p. D-11; 23, pp. 1, 3 WT-SF-02-DUP 0 to 6 05/10/2011

WT-SF-03 Southeastern corner of the FSWT property,

near West 14 th Street 0 to 6 05/10/2011 17, p. 12, Appendix A, p. A-5, Appendix D, p. D-11; 23, p. 1

WT-SF-04 Storage yard,

northeastern corner of the FSWT property 0 to 6 05/10/2011 17, p. 12, Appendix A, p. A-5, Appendix D, p. D-11; 20, p. 15; 23, p. 1

WT-SF-05 Storage yard, northeastern portion of the FSWT property 0 to 6 05/10/2011 17, p. 12, Appendix A, p. A-5, Appendix D, p. D-11; 20, p. 15; 23, pp. 1, 3 WT-SF-05-DUP 0 to 6 05/10/2011

WT-SF-06 Storage yard along

northern FSWT property boundary,

east of the retention pond 0 to 6 05/10/2011 17, p. 12, Appendix A, p. A-5, Appendix D, p. D-11; 20, p. 15; 23, p. 1

WT-SF-19 Storage yard, northcentral portion of the FSWT property, south of the retention pond 0 to 6 05/10/2011 17, p. 12, Appendix A, p. A-5, Appendix D, p. D-11; 20, p. 15; 23, p. 6

WT-SF-20 Storage yard along the western portion of the FSWT property 0 to 6 05/10/2011 17, p. 12, Appendix A, p. A-5, Appendix D, p. D-11; 20, p. 15; 23, p. 6

School/Daycare Property

WT-RP-SF-05 Faith Deliverance Church School/Day

Care 0 to 6 05/10/2011 17, p. 13, Appendix A, p. A-5, Appendix D, p. D-10; 19; 23, p. 428 SE – AOC A General Considerations TABLE 8: AOC A Soil Sample Descriptions – May 2011

Sample ID Sample Location Depth (inches bgs) Date Sampled References

Residential Property

WT-RP-SF-06 WT-RP-06 0 to 6 05/10/2011 17, p. 13, Appendix A, p. A-5, Appendix D, p. D-10; 19; 23, p. 4

Notes:

AOC Area of observed contamination bgs Below ground surface DUP Duplicate

FSWT Fairfax St. Wood Treaters

ID Identification number RP Residential property

SF Surface soil

WT Fairfax St. Wood Treaters29 SE

– AOC A General Considerations Contaminated Concentrations

The soil samples listed i n Table 9 were collected during the EPA May 2011 Pre

- RI ( Ref. 17, p. 12, Appendix A, p. A

- 5, Appendix D, p p

. D

- 10, D

- 11, Appendix E, p p . E

- 169 , E

- 170 ). S oil samples collected during the May 2011 pre

- RI were analyzed under the EPA CLP for TAL metals using EPA CLP SOW ISM01.2 (Ref. 17, p. 8, Appendix E, p. E

- 167). EPA Region 4 SESD reviewed all data according to the CLP SOWs and EPA guidelines (Refs. 17, Appendix E, p. E

- 167; 24). The MRLs are listed on the analytical data sheets in Reference 17, Appendix E. Each MRL is sample

- specific and corresponds to the lowest quantitative point on the calibration curve; it is adjusted for the amount of sample prepared and any dilutions performed, as well as for percent moisture. The MRLs are equivalent to SQL s (Ref. 25).

TABLE 9 : Analytical Results for AOC A Soil Samples

– May 2011

Sample ID Hazardous
Substance Concentration MRL References

FSWT Property

WT

- SF

- 01 Arsenic 100 mg/kg 0.75 mg/kg 17, Appendix E, p. E

- 177

WT

- SF

- 01 Chromium 480 mg/kg 1.5 mg/kg 17, App endix E, p. E

- 177

WT

- SF

- 01 Copper 170 mg/kg 1.9 mg/kg 17, Appendix E, p. E

- 177

WT

- SF

- 02 Arsenic 70 mg/kg 0.71 mg/kg 17, Appendix E, p. E

- 178

WT

- SF

- 02 Chromium 190 mg/kg 0.71 mg/kg 17, Appendix E, p. E

- 178

WT

- SF

- 02 Copper 87 mg/kg 1.8 mg/kg 17, Appendix E, p. E

- 178

WT

- SF

- 02

- DUP Arsenic 56 mg/kg 0.99 mg/kg 17, Appendix E, p. E

- 179

WT

- SF

- 02

- DUP Chromium 130 mg/kg 0.99 mg/kg 17, Appendix E, p. E

- 179

WT

- SF

- 02

- DUP Copper 62 mg/kg 2.5 mg/kg 17, Appendix E, p. E

- 179

WT

- SF

- 03 Arsenic 110 mg/kg 0.90 mg/kg 17, Appendix E, p. E

- 180

WT

- SF

- 03 Chromium 200 mg/kg 0.90 mg/kg 17, Appendix E, p. E

- 180

WT

- SF

- 03 Copper 98 mg/kg 2.2 mg/kg 17, Appendix E, p. E

- 180

WT

- SF

- 04 Chromium 120 mg/kg 0.72 mg/kg 17, Appendix E, p. E

- 181

WT

- SF

- 05 Arsenic 3.3 mg/kg 0.74 mg/kg 17, Appendix E, p. E

- 182

WT

- SF

- 05 Chromium 24 mg/kg 0.74 mg/kg 17, Appendix E, p. E

- 182

WT

- SF

- 05

- DUP Arsenic 5.8 mg/kg 0.80 mg/kg 17, Appendix E, p. E

- 183

WT

- SF

- 05

- DUP Chromium 190 mg/kg 0.80 mg/kg 17, Appendix E, p. E

- 183

WT

- SF

- 06 Arsenic 18 mg/kg 0.80 mg /kg 17, Appendix E, p. E

- 184

WT

- SF

- 06 Chromium 98 mg/kg 0.80 mg/kg 17, Appendix E, p. E

- 184

WT

- SF

- 06 Copper 35 mg/kg 2.0 mg/kg 17, Appendix E, p. E

- 184

WT

- SF

- 19 Arsenic 130 mg/kg 1.0 mg/kg 17, Appendix E, p. E

- 197

WT

- SF

- 19 Chromium 500 mg/kg 1.0 mg/kg 17, Appendix E, p. E

- 197

WT

- SF

- 19 Copper 220J (180.3) mg/kg 2.5 mg/kg 17, Appendix E, p. E

- 197 ; 26, p p

. i

, 2 ; 27, pp. 8, 1830 SE – AOC A General Considerations TABLE 9: Analytical Results for AOC A Soil Samples – May 2011

Sample ID Hazardous
Substance Concentration MRL References

WT-SF-20 Arsenic 6.7 mg/kg 0.72 mg/kg 17, Appendix E, p. E-198

WT-SF-20 Chromium 460 mg/kg 1.4 mg/kg 17, Appendix E, p. E-198

Residential and School/Daycare Properties

WT-RP-SF-05 Arsenic 6.5 mg/kg 0.78 mg/kg 17, Appendix E, p. E-214

WT-RP-SF-06 Arsenic 8.5 mg/kg 1.0 mg/kg 17, Appendix E, p. E-215

Notes:

( ) Concentrations shown in parentheses were adju sted in accordance with References 26 and 27.

AOC Area of observed contamination DUP Duplicate

FSWT Fairfax St. Wood Treaters

ID Identification number J The identification of the analyte is acceptable; the reported value is an estimate (Ref. 17, Appendix E, p. E-6). mg/kg Milligrams per kilogram MRL Minimum reporting limit RP Residential property

SF Surface soil

WT Fairfax St. Wood Treaters31 SE – AOC A General Considerations EPA July 2011 Removal Confirmation and Residential Sampling

Background Samples

The background soil samples listed in Table 10 were collected during the EPA July 2011 sampling event (Refs. 44, Appendix B, p. B-1; 45, p. 1). The background soil samples were collected from the Raymond E. Davis Park, north of the FSWT property (Refs. 44, Appe ndix B, p. B-1; 45, p. 1, Enclosure 1, p. E1-1). The background surface soil samples were collected at de pths of 0 to 6 inches bgs and 18 to 24 inches bgs (Refs. 44, Appendix B, p. B-1; 45, p. 1). This location was chosen to represent background conditions because (1) the soil type at the location of WT-B G-02-SS-A and WT-BG-02-SS-B is similar to the soil types at the locations of samples collected from AOC A and (2) this sampling location is about 535 feet north of FSWT and appears to be minimally affected by facility operations (Refs. 15, p. 72; 41, pp. 1 through 4) (see Figure 3 of this HRS documentation record).

Background and contaminated soil samples were collected during the same sampling event, from the same type of soil (sandy soils, Pelham-Urban la nd complex), and in accordance with similar sampling procedures (Refs. 28; 44, p. 5; 45, p. 1, Enclosure 3, p. E3-2; 48, p. 21, Sheet Number 32). The location of the background soil samples is depicted in Refere nce 45, Enclosure 1, page E1-1 and is listed in Reference 44, Appendix B, page B-1. Chain-of-custody records are provided in Reference 46. Logbook notes are provided in Reference 45, Enclosure 3.

TABLE 10: AOC A Background Soil Sample Descriptions – July 2011

Sample ID Sample Location Depth (inches bgs) Date Sampled References

WT-BG-02-SS-A Collected from Raymond E. Davis Park, north of the FSWT property at the corner

of West 20 th Street and Spires Avenue 0 to 6 07/26/2011 45, p. 1, Enclosure 1, p. E1-1, Enclosure 3, p. E3-7, E3-8; 46, p. 1 WT-BG-02-SS-B 18 to 24 07/26/2011

Notes:

A Sample depth of 0 to 6 inches (Ref. 45, p. 1)

AOC Area of observed contamination B Sample depth of 18 to 24 inches (Ref. 45, p. 1) BG Background bgs Below ground surface

FSWT Fairfax St. Wood Treaters

ID Identification number SS Soil sample

WT Fairfax St. Wood Treaters32 SE – AOC A General Considerations Background Concentrations

The background soil samples listed in Table 11 were collected by EPA during the July 2011 sampling event (Refs. 44, Appendix B, p. B-1; 45, p. 1, Enclosure 1, p. E1-1, Enclosure 3, pp. E3-7, E3-8). Soil samples collected during the July 2011 sampling event were analyzed under the EPA CLP for TAL metals using EPA CLP SOW ISM01.2 (Ref. 45, Encl osure 5, pp. E5-2, E5-5). EPA Region 4 SESD reviewed all data according to the CLP SOWs and EPA guidelines (Refs. 24; 45, Enclosure 5, p. E5-2).The MRLs are listed on the analytical data sheets in Reference 45, Enclosure 5. Each MRL is samplespecific and corresponds to the lowest quantitative point on the calibration curve; it is adjusted for the amount of sample prepared and any dilutions perform ed, as well as for percent moisture. The MRLs are equivalent to SQLs (Ref. 25).

TABLE 11: Analytical Results for AOC A Background Soil Samples – July 2011

Sample ID Hazardous

Substance Concentration MRL References

WT-BG-02-SS-A Arsenic 1.6J (2.78) mg/kg 0.53 mg/kg 26, pp. i, 1; 27, pp. 8, 18; 45, Enclosure 5, p. E5-9

WT-BG-02-SS-A Chromium 14J (18.06) mg/kg 1.1 mg/kg 26, pp. i, 2; 27, pp. 8, 18; 45, Enclosure 5, p. E5-9

WT-BG-02-SS-A Copper 37 mg/kg 2.6 mg/kg 45, Enclosure 5, p. E5-9

WT-BG-02-SS-B Chromium 2.2 mg/kg 1.1 mg/kg 45, Enclosure 5, p. E5-10

WT-BG-02-SS-B Copper 3.0 mg/kg 2.7 mg/kg 45, Enclosure 5, p. E5-10

Notes:

( ) Concentrations shown in parentheses were adju sted in accordance with References 26 and 27. A Sample depth of 0 to 6 inches (Ref. 45, p. 1)

AOC Area of observed contamination B Sample depth of 18 to 24 inches (Ref. 45, p. 1) BG Background J The identification of the analyte is acceptable; the reporte d value is an estimate (Ref. 45, Enclosure 5, p. E5-7).

ID Identification number mg/kg Milligrams per kilogram MRL Minimum reporting limit SS Soil sample

WT Fairfax St. Wood Treaters33 SE – AOC A General Considerations Contaminated Samples

The soil samples listed in Table 12 were collected from the FSWT property by EPA during the July 2011 sampling event in accordance with the EPA Regi on 4 SESD Field Branches Quality System and Technical Procedures for Soil Sampling, SESDPROC-300-R1 (Refs. 28; 44, Appendix B, p. B-1; 45, p. 1, Enclosure 1, p. E1-1, Enclosure 3, pp. E3-2, E3-4, E3-6). Soil samples were collected from 0 to 6 inches bgs and from 18 to 24 inches bgs (Refs. 44, Appendix B, p. B-1; 45, p. 1). Logbook notes are provided in Reference 45, Enclosure 3. Chain-of-custody records are provided in Reference 46. The locations of the soil samples collected from the FSWT property are depicted in Reference 45, Enclosure 1.

TABLE 12: AOC A Soil Sample Descriptions – July 2011

Sample ID Sample Location Depth (inches bgs) Date Sampled References

WT-G01-SS-A Grid 01, northeast portion of the FSWT
property 0 to 6

07/25/2011 45, p. 1, Enclosure 1, p. E1-1, Enclosure 3, p. E3-4; 46, pp. 1, 2 WT-G01-SS-B 18 to 24

WT-G02-SS-B Grid 02, northern portion of the FSWT
property 18 to 24 07/25/2011 45, p. 1, Enclosure 1, p. E1-1, Enclosure 3, p. E3-4; 46, p. 2

WT-G03-SS-A Grid 03, northern portion of the FSWT
property 0 to 6

07/25/2011 45, p. 1, Enclosure 1, p. E1-1, Enclosure 3, p. E3-4; 46, pp. 1, 3 WT-G03-SS-B 18 to 24

WT-G04-SS-A Grid 04, northwestern portion of the FSWT property, south of the retention pond 0 to 6

07/26/2011 45, p. 1, Enclosure 1, p. E1-1, Enclosure 3, p. E3-6; 46, pp. 1, 3, 8WT-G04-SS-ADUP 0 to 6

WT-G04-SS-B 18 to 24

WT-G04-SS-B-DUP 18 to 24

WT-G05-SS-A Grid 05, western portion of the FSWT
property 0 to 6

07/26/2011 45, p. 1, Enclosure 1, p. E1-1, Enclosure 3, p. E3-6; 46, pp. 1, 3 WT-G05-SS-B 18 to 24

WT-G06-SS-A Grid 06, western portion of the FSWT
property 0 to 6 07/26/2011 45, p. 1, Enclosure 1, p. E1-1, Enclosure 3, p. E3-6; 46, p. 1

WT-G07-SS-A Grid 07, western portion of the FSWT
property 0 to 6

07/26/2011 45, p. 1, Enclosure 1, p. E1-1, Enclosure 3, p. E3-6; 46, pp. 1, 3 WT-G07-SS-B 18 to 24

WT-G08-SS-A Grid 08, western portion of the FSWT
property 0 to 6

07/26/2011 45, p. 1, Enclosure 1, p. E1-1, Enclosure 3, p. E3-6; 46, pp. 2, 3 WT-G08-SS-B 18 to 24

WT-G09-SS-A Grid 09, western portion of the FSWT
property 0 to 6 07/26/2011 45, p. 1, Enclosure 1, p. E1-1, Enclosure 3, p. E3-6; 46, p. 2

WT-G10-SS-A Grid 10, western portion of the FSWT
property 0 to 6 07/26/2011 45, p. 1, Enclosure 1, p. E1-1, Enclosure 3, p. E3-6; 46, p. 2

WT-G11-SS-B Grid 11, western portion of the FSWT
property 18 to 24 07/26/2011 45, p. 1, Enclosure 1, p. E1-1, Enclosure 3, p. E3-6; 46, p. 334 SE – AOC A General Considerations TABLE 12: AOC A Soil Sample Descriptions – July 2011

Sample ID Sample Location Depth (inches bgs) Date Sampled References

WT-G12-SS-B Grid 12,

southwestern corner

of the FSWT
property 18 to 24 07/26/2011 45, p. 1, Enclosure 1, p. E1-1, Enclosure 3, p. E3-6; 46, p. 3

WT-G13-SS-A Grid 13, southern portion of the FSWT
property 0 to 6

07/25/2011 45, p. 1, Enclosure 1, p. E1-1, Enclosure 3, p. E3-4; 46, pp. 2, 4 WT-G13-SS-B 18 to 24

WT-G14-SS-A Grid 14, southern portion of the FSWT
property 0 to 6

07/25/2011 45, p. 1, Enclosure 1, p. E1-1, Enclosure 3, p. E3-4; 46, pp. 2, 4 WT-G14-SS-B 18 to 24

WT-G15-SS-A Grid 15, southeastern

corner of the FSWT
property 0 to 6 07/25/2011 45, p. 1, Enclosure 1, p. E1-1, Enclosure 3, p. E3-4; 46, p. 2

Notes:

A Depth of 0 to 6 inches bgs (Ref. 45, p. 1)

AOC Area of observed contamination B Depth of 18 to 24 inches bgs (Ref. 45, p. 1) bgs Below ground surface DUP Duplicate

FSWT Fairfax St. Wood Treaters

G Grid

ID Identification number SS Soil sample

WT Fairfax St. Wood Treaters35 SE – AOC A General Considerations Contaminated Concentrations

The soil samples listed in Table 13 were collected by EPA during the July 2011 sampling event (Ref. 44, Appendix B, p. B-1; 45, p. 1, Enclosure 1, p. E1-1, Enclosure 3, pp. E3-4, E3-6). Soil samples collected during the July 2011 sampling event were analyzed under the EPA CLP for TAL metals using EPA CLP SOW ISM01.2 (Refs. 45, Enclosure 5, pp. E5-2, E5-5, E5-6; 46, pp. 1, 2, 3, 4, 8). EPA Region 4 SESD reviewed all data according to the CLP SOWs and EPA guidelines (Refs. 24; 45, Enclosure 5, p. E5-2).The MRLs are listed on the analytical data sheets in Reference 45, Enclosure 5. Each MRL is samplespecific and corresponds to the lowest quantitative point on the calibration curve; it is adjusted for the amount of sample prepared and any dilutions perform ed, as well as for percent moisture. The MRLs are equivalent to SQLs (Ref. 25).

TABLE 13: Analytical Results for AOC A Soil Samples – July 2011

Sample ID Hazardous

Substance Concentration MRL References

Surface Soil Samples (0 to 6 inches bgs)

WT-G01-SS-A Chromium 78 mg/kg 1.2 mg/kg 45, Enclosure 5, p. E5-12

WT-G03-SS-A Arsenic 44J (25.29) mg/kg 0.57 mg/kg 26, pp. i, 2; 27, pp. 8, 18; 45, Enclosure 5, p. E5-18

WT-G03-SS-A Chromium 170 mg/kg 3.4 mg/kg 45, Enclosure 5, p. E5-18

WT-G03-SS-A Copper 300 mg/kg 2.8 mg/kg 45, Enclosure 5, p. E5-18

WT-G04-SS-A Arsenic 18J (10.34) mg/kg 0.58 mg/kg 26, pp. i, 2; 27, pp. 8, 18; 45, Enclosure 5, p. E5-21

WT-G04-SS-A Chromium 230 mg/kg 4.7 mg/kg 45, Enclosure 5, p. E5-21

WT-G04-SS-A-DUP Arsenic 23J (13.22) mg/kg 0.59 mg/kg 26, pp. i, 3; 27, pp. 8, 18; 45, Enclosure 5, p. E5-22

WT-G04-SS-A-DUP Chromium 280J (217.05) mg/kg 1.2 mg/kg 26, pp. i, 3; 27, pp. 8, 18; 45, Enclosure 5, p. E5-22

WT-G05-SS-A Arsenic 35J (20.11) mg/kg 0.57 mg/kg 26, pp. i, 3; 27, pp. 8, 18; 45, Enclosure 5, p. E5-27

WT-G05-SS-A Chromium 210 mg/kg 4.6 mg/kg 45, Enclosure 5, p. E5-27

WT-G06-SS-A Arsenic 16J (9.20) mg/kg 0.57 mg/kg 26, pp. i, 3; 27, pp. 8, 18; 45, Enclosure 5, p. E5-30

WT-G06-SS-A Chromium 120 mg/kg 3.4 mg/kg 45, Enclosure 5, p. E5-30

WT-G07-SS-A Chromium 82 mg/kg 1.1 mg/kg 45, Enclosure 5, p. E5-33

WT-G08-SS-A Arsenic 24J (13.79) mg/kg 0.56 mg/kg 26, pp. i, 3; 27, pp. 8, 18; 45, Enclosure 5, p. E5-36

WT-G08-SS-A Chromium 120 mg/kg 3.4 mg/kg 45, Enclosure 5, p. E5-36

WT-G09-SS-A Arsenic 34J (19.54) mg/kg 0.57 mg/kg 26, pp. i, 4; 27, pp. 8, 18; 45, Enclosure 5, p. E5-39

WT-G09-SS-A Chromium 90 mg/kg 1.1 mg/kg 45, Enclosure 5, p. E5-39

WT-G10-SS-A Arsenic 31J (17.82) mg/kg 0.57 mg/kg 26, pp. i, 4; 27, pp. 8, 18; 45, Enclosure 5, p. E5-4236 SE – AOC A General Considerations TABLE 13: Analytical Results for AOC A Soil Samples – July 2011

Sample ID Hazardous
Substance Concentration MRL References

WT-G10-SS-A Chromium 81 mg/kg 1.1 mg/kg 45, Enclosure 5, p. E5-42

WT-G13-SS-A Arsenic 27J (15.52) mg/kg 0.55 mg/kg 26, pp. i, 4; 27, pp. 8, 18; 45, Enclosure 5, p. E5-51

WT-G13-SS-A Chromium 91 mg/kg 1.1 mg/kg 45, Enclosure 5, p. E5-51

WT-G14-SS-A Arsenic 22J (12.64) mg/kg 0.55 mg/kg 26, pp. i, 4; 27, pp. 8, 18; 45, Enclosure 5, p. E5-54

WT-G14-SS-A Chromium 200 mg/kg 4.4 mg/kg 45, Enclosure 5, p. E5-54

WT-G15-SS-A Arsenic 28J (16.09) mg/kg 0.55 mg/kg 26, pp. i, 4; 27, pp. 8, 18; 45, Enclosure 5, p. E5-57

WT-G15-SS-A Chromium 99 mg/kg 1.1 mg/kg 45, Enclosure 5, p. E5-57

Subsurface Soil Samples (18 to 24 inches bgs)

WT-G01-SS-B Chromium 12 mg/kg 1.2 mg/kg 45, Enclosure 5, p. E5-13

WT-G01-SS-B Copper 13 mg/kg 2.9 mg/kg 45, Enclosure 5, p. E5-13

WT-G02-SS-B Chromium 10 mg/kg 1.1 mg/kg 45, Enclosure 5, p. E5-16

WT-G03-SS-B Chromium 46 mg/kg 1.1 mg/kg 45, Enclosure 5, p. E5-19

WT-G03-SS-B Copper 31 mg/kg 2.8 mg/kg 45, Enclosure 5, p. E5-19

WT-G04-SS-B Chromium 18 mg/kg 1.2 mg/kg 45, Enclosure 5, p. E5-23

WT-G04-SS-B Copper 15 mg/kg 2.9 mg/kg 45, Enclosure 5, p. E5-23

WT-G04-SS-B-DUP Chromium 26J (20.16) mg/kg 1.1 mg/kg 26, pp. i, 4; 27, pp. 8, 18; 45, Enclosure 5, p. E5-24

WT-G04-SS-B-DUP Copper 16 mg/kg 2.8 mg/kg 45, Enclosure 5, p. E5-24

WT-G05-SS-B Chromium 15 mg/kg 1.1 mg/kg 45, Enclosure 5, p. E5-28

WT-G07-SS-B Chromium 26 mg/kg 1.1 mg/kg 45, Enclosure 5, p. E5-34

WT-G08-SS-B Chromium 8.9 mg/kg 1.1 mg/kg 45, Enclosure 5, p. E5-37

WT-G11-SS-B Chromium 21 mg/kg 1.1 mg/kg 45, Enclosure 5, p. E5-46

WT-G11-SS-B Copper 11 mg/kg 2.8 mg/kg 45, Enclosure 5, p. E5-46

WT-G12-SS-B Chromium 64 mg/kg 1.1 mg/kg 45, Enclosure 5, p. E5-49

WT-G12-SS-B Copper 23 mg/kg 2.8 mg/kg 45, Enclosure 5, p. E5-49

WT-G13-SS-B Chromium 37 mg/kg 1.1 mg/kg 45, Enclosure 5, p. E5-52

WT-G13-SS-B Copper 15 mg/kg 2.8 mg/kg 45, Enclosure 5, p. E5-52

WT-G14-SS-B Chromium 34 mg/kg 1.1 mg/kg 45, Enclosure 5, p. E5-55

WT-G14-SS-B Copper 21 mg/kg 2.8 mg/kg 45, Enclosure 5, p. E5-5537 SE – AOC A General Considerations Notes:

( ) Concentrations shown in parentheses were adju sted in accordance with References 26 and 27. A Depth of 0 to 6 inches bgs (Ref. 45, p. 1)

AOC Area of observed contamination B Depth of 18 to 24 inches bgs (Ref. 45, p. 1) bgs Below ground surface DUP Duplicate

G Grid J The identification of the analyte is acceptable; the reporte d value is an estimate (Ref. 45, Enclosure 5, p. E5-7).

ID Identification number mg/kg Milligrams per kilogram MRL Minimum reporting limit SS Soil sample

WT Fairfax St. Wood Treaters38 SE – General Considerations-Attribution Attribution

From 1980 to 2010, FSWT operated a wood treating facility that pressure treated utility poles, pilings, heavy timber items, and plywood lumber products us ing the wood treating preservative CCA. FSWT did not treat wood products with creosote or pentachlorophe nol (Refs. 7, p. 1; 15, p. 2). CCA is characterized by a bright green color and is composed of waterborne oxides, or salts, of chromium, copper, and arsenic. The copper serves as a fungicide, the arsenic serves as an insecticide, and the chromium binds the copper and arsenic to the wood (Ref. 8).

During operations at FSWT, the wood was transferred to the drip pad to drip dry after treatment. Once the wood stopped visibly dripping, it was transferred to the storage yard to complete the drying process (Refs. 11; 12, p. 1). The storage yard was compo sed of the soil and gravel areas along the northern, western, and southern FSWT property boundaries (Refs. 15, pp. 21, 33, 36, 40, 56; 20, p. 15).

The topography of the FSWT property and the surrounding area is generally flat and, prior to 1990, overland flow across the FSWT property was uncontrolled (R efs. 7, p. 2; 40, p. 133) (see Figure 1 of this HRS documentation record). A conduit was used to r oute some of the stormwater to the STES retention pond. In 1990, FSWT installed a stormwater collecti on and retention system, including site grading and paving for drainage, stormwater collection swales, diversion berms, and an HDPE-lined retention pond. The conduit from FSWT to the STES retention pond was clos ed off at this time (Refs. 7, p. 2; 22). CCA deposited onto the drip pa d during the drip-dry process mixed with stormwater, resulting in a CCA solution. CCA-contaminated stormwater from the drip pad was diverted to an underground sump located adjacent to the storage tanks. Once the stormwater inside the sump reached a specified volume, a pump transported the stormwater to one of two effluent tanks, where it was recycled into the high-concentrate

CCA treatment solution for re-use in the w ood treating process (Refs. 11; 12, p. 1).

Stormwater that collects in areas other than the drip pad is diverted to ditches located along the northern, western, and southern property boundaries. Th ese ditches drain into the retention pond at the northwestern corner of the operations area of the proper ty. An overflow pipe is located in the retention pond so that water overflows into the pipe and dischar ges into nearby Moncrief Creek, a tributary of the Trout River, when the pond reaches a certain volum e (Refs. 11; 17, Appendix A, p. A-2; 49).

Contamination of the railroad right-of-way north of the FSWT facility has been attributed to the deposition of contaminated soils excavated wh en the FSWT facility retention pond was under construction (Ref. 35, pp. 1, 3). CCA contamina tion found on residential and municipal properties surrounding the FSWT facility resulted from migration of hazardous substances via uncontrolled overland runoff from FSWT prior to 1990, periodic flooding and runoff from the storage yards along the northern, western, and southern portions of the FSWT propert y, and wheel spray from trucks or other vehicles exiting the FSWT facility (Refs. 7, p. 7; 13, p. 9; 14, p. 26; 15, p. 21; 20, p. 15; 21, p. 1). A breach in the containment wall of the drip pad was observed durin g the EPA August 2010 ER (Ref. 15, p. 44). The topography of the FSWT property and the surrounding ar ea is generally flat, and nearby residents have reported that stormwater runoff currently flows from the FSWT property onto their properties during heavy rain events (Refs. 7, p. 7; 13, p. 9; 21, p. 1; 34; 36, p. 1; 37, pp. 1, 2; 38; 40, p. 133; 43, pp. 1, 2, 3) (see Figure 1 of this HRS documentation record). Fu rthermore, the concentrations of arsenic, chromium, and copper detected in soil at FSWT and the surroun ding properties show a gradient that decreases with

distance from FSWT. The hazardous substances liste d below have been documented in AOC A (see Tables 5, 9, and 13 in Section 5.0.1, General Considerations, of this HRS documentation record).

The FSWT property owner filed for Chapter 7 bankruptcy in July 2010 (Ref. 55). In August 2010, after closure of the FSWT facility, EPA, at the request of FDEP, conducted ER activities at the facility that included pumping out the water contained in the secondary containment area and retention pond, removing product in tanks, and collecting soil, surface wa ter, sediment, and waste samples (Ref. 15, pp. 5, 6, 7). Stormwater collected from the drip pad was no longer being used for the treatment process; however, the sump continued to pump stormwater into the tanks. Once the effluent tanks became full, pumping from the sump ceased and stormwater eventu ally overflowed from the sump to the secondary39 SE – General Considerations-Attribution containment area surrounding the tanks. The secondary containment area overflowed onto the parking lot, where the stormwater ditches ev entually transported contaminated stormwater to the retention pond. The walls and floor of the secondary containment area and sump were observed to be covered in a green

crust of condensed CCA solution. Water within th e secondary containment area and the retention pond was a bright green color, signifying the presence of CCA (Refs. 11; 15, pp. 5, 6, 34, 50, 51).

During the ER, grab waste samples were collected fr om six tanks that contained wood treating product and from the secondary containment area surrounding the tanks (Refs. 15, pp. 8, 47; 17, Appendix A, p. A-3; 30, p. 21; 31, p. 31). Waste sample WTI-T2 contained the highest concentrations of arsenic (17,900 mg/L), cadmium (30.8 mg/L), chromium III (3,700 mg/L), chromium VI (17,000J+ mg/L), total chromium (20,700 mg/L), copper (12,100 mg/L), and manganese (10.7J mg/L) (Ref. 15, pp. 24, 25).

Also in August 2010, EPA collected four surface soil samples from the FSWT property. These samples contained arsenic (up to 4,300 mg/kg), cadmium (up to 5.61 mg/kg), chromium III (up to 7,640 mg/kg), copper (up to 3,980 mg/kg), and manga nese (up to 822 mg/kg (Refs. 15, pp. 1, 7, 10, 27; 17, Appendix A, p. A-3). In January 2011, EPA also collected soil samples from the FSWT property. These samples contained arsenic (up to 377 mg/kg), chromium (up to 1,280 mg/kg), and copper (up to 405 mg/kg) (Refs. 16, pp. 2, 3, Appendix B, p. B-7; 17, Appendix A, p. A-4). Additional soil samples were collected from the FSWT property during the May 2011 pre-RI, some fro m beneath the concrete that covers the majority of the property. On-facility soil samples contained arsenic (up to 130 mg/kg), chromium (up to 1,300 mg/kg), and copper (up to 220J mg/kg) (Ref. 17, p. 12 , Appendix A, p. A-5, Appendix B, pp. B-25, B-29, B-30).

In January 2011, soil samples were collected fro m the adjacent STES and RVDES properties as well as from nearby residential properties (Refs. 16, pp. 2, 3; 17, Appendix A, p. A-4). Soil samples collected from the school properties contained arsenic (up to 64 mg/kg), chromium (up to 237 mg/kg), and copper (up to 110 mg/kg) (Ref. 16, Appendix B, p. B-2) . These samples were collected from areas where children were observed playing (Ref. 16, p. 4, Append ix D, pp. D-4, D-8). Nearby residential properties

on Pullman Court and West 14 th Street, including a 12-unit apartment complex, were also sampled (Refs. 16, p. 3; 17, Appendix A, p. A-4). Soil samples collected from residential properties contained arsenic (up to 36.3 mg/kg), chromium (up to 127 mg/kg), and copper (up to 70.6 mg/kg) (Ref. 16, Appendix B, p. B-5).

In May 2011, five surface soil samples were collected from residential properties on the eastern side of Fairfax Street, across from the FSWT entrance. Four soil samples were collected from an apartment building south of the FSWT property on West 13 th Street to confirm results collected during the January 2011 removal investigation (Refs. 18, p. 2; 19). Arsenic, chromium, and copper were detected in residential soil samples collected during the May 2011 pr e-RI. Arsenic was detected in all residential soil samples ranging from 6.5 mg/kg (WT-RP-SF-05) to 64 mg/kg (WT-RP-SF-08). Chromium was detected in seven out of the nine residential soil samples collected, ranging from 26 mg/kg (WT-RP-SF-02) to 120 mg/kg (WT-RP-SF-08). Copper was detected in ei ght of the nine residential soil samples collected, ranging from 20 mg/kg (WT-RP-SF-06) to 71 mg/kg (W T-RP-SF-08). The highest concentrations of arsenic, chromium, and copper were detected in sample WT-RP-SF-08, which was collected from a residence on Fairfax Street, across from and slightly north of the entrance to FSWT (Ref. 17, p. 13, Appendix A, p. A-5, Appendix B, pp. B-31, B-32, B-33). In 2010, PE Serv ices, on behalf of Wood Treaters, LLC (FSWT property owner), concluded that the contamination present along the eastern side of Fairfax Street, across from the FSWT entrance, was due to past exposure from the wheel spray of trucks or other vehicles exiting the FSWT facility (Ref. 14, p. 26).

In July 2011, EPA conducted a removal confirmation and residential sampling event at the FSWT property. Composite soil samples were collected from the northern, western, and southern property boundaries post-excavation at three depth intervals: 0 to 6 inches below excavation surface, 18 to 24 inches below excavation surface, and 36 to 42 inches be low excavation surface (Refs. 44, Appendix B, p. B-1; 45, p. 1). These areas were excavated down to 1 foot or 1.5 feet during the EPA removal action and were not backfilled with clean soil (Ref. 22). In surface soil samples (0 to 6 inches bgs), arsenic40 SE – General Considerations-Attribution concentrations ranged from 5.5J mg/kg (WT-G01- SS-A) to 44J mg/kg (WT-G03-SS-A), chromium concentrations ranged from 47 mg/kg (WT-G02-SS-A) to 280J mg/kg (WT-G04-SS-A-DUP), and copper was detected at 300 mg/kg (WT-G03-SS-A) (Ref. 45, Enclosure 2, pp. E2-1 through E2-4). Composite surface soil (0 to 6 inches bgs) samples were also coll ected from the front and back yards of 10 residences west, east, and south of the FSWT property (Ref. 45, p. 1). Arsenic was detected in residential surface soil samples. The highest arsenic concentration (11J mg/kg) was detected in sample WT-RP-11-SF-BY, collected from a residential property on West 16 th Street (Ref. 45, Enclosure 2, pp. E2-13 through E2-18).

Because FSWT is located in a metropolitan city, th ere are many state and federal regulated facilities located within 1 mile of FSWT, including Resour ce Conservation and Recovery Act (RCRA) hazardous waste generators, state hazardous waste sites, f acilities with underground and above ground storage tanks (USTs and ASTs), brownfields sites, and dry cleaners (R ef. 40, pp. 7, 8, 9, 12). None of these facilities are wood treating operations and, with the exception of Brown’s Dump (discussed later in this section), none of these facilities have reported arsenic, chromium , or copper as a contaminant of concern (Ref. 40, pp. 45 through 96, 107).

The FSWT property is located within the EPA Region 4 Jacksonville Health Zone 1 (Ref. 33, pp. 1, 4). Other Superfund sites within this zone include th e Jacksonville Ash Sites, Brown’s Dump, Kerr McGee Jacksonville, and the Picketville Road Landfill (Ref. 33, p. 4). The Jacksonville Ash Sites are made up of three facilities: the Forest Street Incinerator (located about 2 miles south of FSWT), the 5 th & Cleveland Incinerator (located about 1 mile southeast of FSWT), and the Lonnie C. Miller Sr. Park (located about 3.5 miles northwest of FSWT) (Ref. 33, pp. 1, 4). The Forest Street and 5 th & Cleveland Incinerators operated as the City of Jacksonville’s municipal solid waste incinerators from the 1940s until the 1960s. Combustion ash, clinker, and ash residues were disposed of on each of the incinerator properties and also on the land that was later redeveloped into the Lonnie C. Miller Sr. Park. Contaminants associated with these sites include lead, arsenic, and dioxins (Ref. 33, p. 1).

Brown’s Dump is located about 0.7 miles north of FS WT and is approximately 80 acres in size. Brown’s Dump was an operating landfill from the late 1940s until the mid-1950s and was used to deposit ash from the City of Jacksonville’s municipal incinerators (Ref. 33, pp. 1, 2). This site now consists of the former Mary McLeod Bethune Elementary School, an electri cal substation of the Jacksonville Electric Authority (JEA), surrounding single-family homes, and multip le family complexes (Ref. 33, pp. 1, 2).

Contaminants associated with this site include lead, arsenic, other inorganic substances, and dioxins/furans (Ref. 33, p. 2). The FSWT retention pond discharges into Moncrief Creek, which flows north to the Trout River (Ref. 17, pp. 22, 23). Brown’s Dump is located along Moncrief Creek about 0.5 to 1 mile north (downstream) of FSWT (Ref. 33, p. 4). Ongoing cleanup at the Brown’s Dump site includes stabilization of the banks of Moncrief Creek (Ref. 33, p. 2).

The Kerr McGee (Jacksonville) site is located a bout 2 miles southeast of FSWT along the western shoreline of the St. Johns River and encompasses approximately 31 acres. From 1893 to 1978, Kerr McGee operated a fertilizer and pestic ide formulating, packaging, and distributing facility. Contaminants associated with these operations include dissolved me tals, pesticides, and polychlorinated biphenyls (PCB) (Ref. 33, pp. 2, 4).

The Picketville Road Landfill, located about 3.25 miles northwest of FSWT, began operations in 1968 and occupies approximately 52 acres. Initially, all types of waste were disposed of at the site, including municipal and industrial wastes. However, in 1971, municipal waste was diverted to other municipal landfills and the Picketville Road Landfill was dedicated for disposal of hazardous wastes. A ground water plume of volatile organic compounds (VOC) and other contaminants is currently being remediated (Ref. 33, pp. 3, 4).

Hazardous Substances in the Release

Arsenic

Chromium Copper41 SE – Resident Population Threat 5.1 RESIDENT POPULATION THREAT

5.1.1 LIKELIHOOD OF EXPOSURE

Table 14 lists surface soil samples collected in January and May 2011 from residential and school properties contained in AOC A (Refs. 3; 16, Appendix D, pp. D-7, D-8, D-12, D-13, D-15; 17, Appendix A, pp. A-4, A-5, Appendix D, p. D-10) (see Figure 2 of this HRS documentation record).

TABLE 14: Likelihood of Exposure

Sample ID Sample Date Distance of Population

from Area of Observed

Contamination References

FWT-17-SF 01/17/2011 0 feet 3; 16, Appendix D, p. D-7, Appendix F, p. F-98

FWT-30-SF 01/17/2011 0 feet 3; 16, Appendix D, p. D-8, Appendix F, p. F-111

FWT-35-SF-BY 01/19/2011 0 feet 3; 16, Appendix D, p. D-12, Appendix F, p. F-119

FWT-36-SF-BY 01/19/2011 0 feet 3; 16, Appendix D, p. D-12, Appendix F, p. F-121

FWT-37-SF-FY 01/19/2011 0 feet 3; 16, Appendix D, p. D-12, Appendix F, p. F-122

FWT-37-SF-BY 01/19/2011 0 feet 3; 16, Appendix D, p. D-12, Appendix F, p. F-123

FWT-38-SF-BY 01/19/2011 0 feet 3; 16, Appendix D, p. D-12, Appendix F, p. F-125

FWT-39-SF-FY 01/19/2011 0 feet 3; 16, Appendix D, p. D-12, Appendix F, p. F-126

FWT-39-SF-BY 01/19/2011 0 feet 3; 16, Appendix D, p. D-12, Appendix F, p. F-128

FWT-40-SF-FY 01/19/2011 0 feet 3; 16, Appendix D, p. D-12, Appendix F, p. F-127

FWT-40-SF-BY 01/19/2011 0 feet 3; 16, Appendix D, p. D-12, Appendix F, p. F-129

FWT-41-SF-FY 01/19/2011 0 feet 3; 16, Appendix D, p. D-12, Appendix F, p. F-130

FWT-41-SF-BY 01/19/2011 0 feet 3; 16, Appendix D, p. D-12, Appendix F, p. F-131

FWT-43-SF-BY 01/19/2011 0 feet 3; 16, Appendix D, p. D-13, Appendix F, p. F-134

FWT-49-SF 01/20/2011 0 feet 3; 16, Appendix D, p. D-15, Appendix F, p. F-154

WT-RP-SF-05 05/10/2011 0 feet 3; 17, Appendix D, p. D-10, Appendix E, p. E-214

WT-RP-SF-06 05/10/2011 0 feet 3; 17, Appendix D, p. D-10, Appendix E, p. E-215

Resident Population Threat Likelihood of Exposure Factor Category Value: 550 (Ref. 1, Section 5.1.1)42 SE – Resident Population Threat 5.1.2 WASTE CHARACTERISTICS

5.1.2.1 Toxicity

The toxicity values for the hazardous substances detect ed in the area of observed contamination samples

are summarized in Table 15.

TABLE 15: Soil Exposure Toxicity

Hazardous

Substance Toxicity Factor

Value Reference

Arsenic 10,000 2, p. BI-1

Chromium 10,000 2, p. BI-3

Copper 0 2, p. BI-3

Toxicity Factor Value: 10,000 (Ref. 1, Section 5.1.2.1)43 SE – Resident Population Threat 5.1.2.2 HAZARDOUS WASTE QUANTITY

Hazardous Constituent Quantity

The mass of CERCLA hazardous substances containe d in AOC A is not known. The information available is not sufficient to evaluate Tier A, hazardous constituent quantity, as required by Reference 1,

Section 5.1.2.2.

Hazardous Constituent Quantity Assigned Value: NS

Hazardous Wastestream Quantity

The mass of CERCLA hazardous substances, pollutants, and contaminants contained in AOC A is not

known. The information available is not sufficient to evaluate Tier B, hazardous wastestream quantity, as required by Reference 1, Section 5.1.2.2.

Hazardous Wastestream Quantity Assigned Value: NS

Volume

The area of observed contamination is not a surface impoundment, drums, or tanks and containers other than drums, as required to evaluate Tier C, volume, by Reference 1, Section 5.1.2.2, and Table 5-2.

Volume Assigned Value: 0

Area

AOC A consists of contaminated soil along the north ern, southern, and western portions of the FSWT property, as well as residential neighborhoods east, south, and west of FSWT, and one elementary school property (STES) directly west of FSWT and the Fait h Deliverance school and daycare directly east of FSWT (Refs. 17, Appendix A, pp. A-4, A-5, Appendix B, pp. B-13, B-14, B-17, B-18, B-31, B-32; 45, p. 1, Enclosure 1, p. E1-1, Enclosure 2, pp. E2-1 th rough E2-8, E2-13 through E2-18). Areas covered by structures and impervious surfaces are excluded from the AOC. The area of AOC A was not calculated; therefore, the area of AOC A is undetermined, but greater than zero (Ref. 1, Section 5.1.2.2).

Sum (square feet [ft 2 ]): >0 Equation for Assigning Value (Ref. 1, Table 5-2): Area (A)/34,000 Area Assigned Value: >0

Hazardous Waste Quantity Value

AOC A is assigned an HWQ value of greater than zer o, but undetermined (Ref. 1, Section 5.1.2.2).

HWQ Value: >044 SE – Resident Population Threat TABLE 16: Hazardous Waste Quantity

Area of Observed

Contamination Letter Type Area Hazardous Waste Quantity

A Contaminated Soil Undetermined, but greater than zero

The hazardous constituent quantity for AOC A is not adequately determined. The Hazardous Waste Quantity (HWQ) is undetermined, but greater than zero. Per HRS Section 2.4.2.2, for the soil exposure pathway, the HWQ factor value is the higher of either the value from HRS Table 2-6 or 10.

Hazardous Waste Quantity Factor Value: 10 (Ref. 1, Section 2.4.2.2)

5.1.2.3 Calculation of Waste Char acteristics Factor Category Value

The waste characteristics factor category was obtai ned by multiplying the toxicity and HWQ factor values. Based on this product, a value was assi gned in accordance with Reference 1, Table 2-7.

Toxicity Factor Value (see Table 15 of this HRS documentation record): 10,000 Hazardous Waste Quantity Factor Value: 10

Toxicity Factor Value × Hazardous Waste Quantity Factor Value: 1 x 10 5

Waste Characteristics Factor Category Value: 18 (Ref. 1, Table 2-7)5.1.3 RESIDENT POPULATION THREAT TARGETSThe soil samples listed in Table 17 were collected during the EPAJanuary 2011 removal investigation and the EPA May 2011 pre-RI sampling events (Ref. 17,Appendix A, pp. A-4, A-5). Properties included in AOC A that were vacant at the time of sampling were not evaluated as Level I(Ref. 42).Level I ConcentrationsDuring the EPA January 2011 removal investigation, soil sampleswere collected from residential properties along Pullman Court (west of FSWT) (Refs. 16, pp. 2,3; 17, Appendix A, p. A-4). Composite surface soil (0 to 6 inches bgs) samples were collected from the front and back yards ofresidential properties within 200feet of each residence (Ref. 16, pp. 2, 3, 4, Appendix A, p. A-4, Appendix D, p. D-4) (see Figure 2 of this HRS documentation record). Samples collected duringthis event were analyzed by ENCO, a TetraTech-procured laboratory, and were validatedby a Tetra Tech chemist (Ref. 16, p. 4,Appendix E, p. E-3). During theEPA May 2011 pre-RI, grab surface soil samples (0 to 6 inches bgs) were collected from school/daycare and residential properties along the eastern side of FairfaxStreet (Ref. 17, pp. 12, 13, Appendix A, p. A-5). Samples collected during the May 2011 sampling event were analyzed by an EPACLP laboratory and validatedby EPA SESD (Refs. 17, p. 8, Appendix E, p. E-167;24). See Reference 3 for Level I sampling locations.TABLE 17: AOC A Level I ConcentrationsSample IDHazardousSubstanceHazardousSubstanceConcentrationBackgroundConcentrationBenchmarkConcentrationBenchmarkReferencesFWT-36-SF-BYArsenic12.4 mg/kg1.14J (1.98) mg/kg0.43 mg/kgCRSC2, p. BII-13; 16, Appendix E, pp. E-7, E-97, AppendixF, pp. F-121, F-135; 26, p. 1; 27, pp. 8, 18FWT-39-SF-FYArsenic7.18 mg/kg1.14J (1.98) mg/kg0.43 mg/kgCRSC2, p. BII-13; 16, Appendix E, pp. E-7, E-97, AppendixF, pp. F-126, F-135; 26, p. 1; 27, pp. 8, 18FWT-39-SF-BYArsenic30.4 mg/kg1.14J (1.98) mg/kg23 mg/kgRDSC2, p. BII-13; 16, Appendix E, pp. E-7, E-97, AppendixF, pp. F-128, F-135; 26, p. 1; 27, pp. 8, 18FWT-41-SF-BYArsenic28.7 mg/kg1.14J (1.98) mg/kg23 mg/kgRDSC2, p. BII-13; 16, Appendix E, pp. E-7, E-97, AppendixF, pp. F-131, F-135; 26, p. 1; 27, pp. 8, 18WT-RP-SF-05Arsenic6.5 mg/kg1.8U mg/kg0.43 mg/kgCRSC2, p. BII-13; 17, Appendix E, pp. E-199, E-214Notes:( ) Concentrations shown in parentheses were adjusted in accordance with References 26 and 27. mg/kg Milligrams per kilogramAOC Area of observed contaminationRDSCReference Dose Screening ConcentrationBY BackyardRP Residential propertyCRSC Cancer Risk Screening ConcentrationSF Surface soilFWT Fairfax St. Wood TreatersU The analyte was not detected at or above the minimum reporting limit (Ref. 17,FY Front yardAppendix E, p. E-6)ID IdentificationWT Fairfax St. Wood TreatersJ The analyte was positively identified; the associated value is the approximate concentrationof the analyte in the sample (Ref. 16, Appendix E, p. E-3).45SE – Resident Population Threat46 SE – Resident Population Threat 5.1.3.1 Resident Individual

Area of Observed Contamination Letter: A Level of Contamination (Level I/Level II): I References: 1, p. 51647; 2, p. BII-13; 16, Appendi x E, pp. E-7, E-97, Append ix F, pp. F-83, F-121, F128, F-131, F-135; 17, Appendix E, pp. E-199, E-214; 26, p. 1; 27, pp. 8, 18.

Resident Individual Factor Value: 50 (Ref. 1, Section 5.1.3.1)

5.1.3.2 Resident Population

The samples listed in Table 18 below were collected during the EPA January 2011 removal investigation and the EPA May 2011 pre-RI sampling events (see Tables 4, 5, 8, and 9 of this HRS documentation record). Surface soil (less than 24 inches bgs) samples collected from three properties during the EPA January 2011 removal investigation contained arsenic at Level I concentrations. A surface soil (less than 24 inches bgs) sample collected from an additional pr operty during the EPA May 2011 pre-RI contained arsenic at Level I concentrations (does not include properties previously sampled during the EPA January 2011 removal investigation that are already counte d as Level I) (see Table 17 of this HRS documentation record).

5.1.3.2.1 Level I Population

TABLE 18: Level I Resident Population Targets

Area of

Observed

Contamination

Letter Sample ID No. of

Residences Total No. of

Residents/Students References

Faith Deliverance Church School/Day Care

A WT-RP-SF-05 1 75 3; 42

Residences

A FWT-36-SF-BY 1 1 3; 42

A FWT-39-SF-FY 1 4 3; 42 FWT-39-SF-BY

A FWT-41-SF-BY 1 3 3; 42

Notes:

BY Backyard

FWT Fairfax St. Wood Treaters FY Front yard

ID Identification RP Residential property

SF Surface soil

WT Fairfax St. Wood Treaters

Sum of individuals subject to Level I concentrations: 83 Sum of individuals subject to Level I concentrations × 10: 830

Level I Concentrations Factor Value: 830 (Ref. 1, Section 5.1.3.2.1)5.1.3.2.2 Level II ConcentrationsThe soil samples listed in Table 19 were collected during the EPAJanuary 2011 removal investigation sampling event (Ref. 17, Appendix A, p. A-4).Level II ConcentrationsDuring the EPA January 2011 removal investigation, soil samples were collected from the STES property (near the school building), as well as from a residentialproperty along Pullman Court (west of FSWT) (Refs. 16, pp. 2, 3,Appendix A, p. A-4; 17, Appendix A, p. A-4). Grab surface soil samples (0 to 12 inches bgs)were collected from the STES property within 200 feet of the school building, and composite soil samples were collected from the front and back yards of theresidential property within 200 feet of the residence (Ref. 16, p.3, Appendix A, p. A-4) (see Figure 2 of this HRS documentation record). Samples collectedduring this event were analyzed by ENCO, a Tetra Tech-procured laboratory, and werevalidated by a Tetra Tech chemist (Ref. 16,p. 4, Appendix E, pp. E-3through E-7).TABLE 19: AOC A Level II ConcentrationsSample IDHazardousSubstanceHazardousSubstanceConcentrationBackgroundConcentrationBenchmarkConcentrationBenchmarkReferencesFWT-17-SFChromium18.1 mg/kg5.47 mg/kg230 mg/kgRDSC2, p. BII-15; 16, Appendix F, pp. F-98, F-135FWT-30-SFChromium16.6 mg/kg5.47 mg/kg230 mg/kgRDSC2, p. BII-15; 16, Appendix F, pp. F-111, F-135FWT-37-SF-FYChromium17.5 mg/kg5.47 mg/kg230 mg/kgRDSC2, p. BII-15; 16, Appendix F, pp. F-122, F-135FWT-37-SF-BYChromium17.3 mg/kg5.47 mg/kg230 mg/kgRDSC2, p. BII-15; 16, Appendix F, pp. F-123, F-135Notes:AOC Area of observed contaminationBY BackyardFWT Fairfax St. Wood TreatersFY Front yardID Identificationmg/kg Milligrams per kilogramRDSC Reference Dose Screening ConcentrationSF Surface soil47SE – Resident Population Threat48 SE – Resident Population Threat Level II Resident Population Targets

The samples listed in Table 20 below were collected during the EPA January 2011 removal investigation sampling event. Soil samples collected from the STES property and one residential property during the EPA January 2011 removal investiga tion contained chromium at Level II concentrations (see Table 19 of this HRS documentation record).

TABLE 20: Level II Resident Population Targets

Area of

Observed

Contamination

Letter Sample ID No. of

Residences Total No. of

Residents/Students References

Susie Tolbert Elementary School

A FWT-17-SF 1 373 3; 42 FWT-30-SF

Residence

A FWT-37-SF-FY 1 1 3; 42 FWT-37-SF-BY

Notes:

BY Backyard

FWT Fairfax St. Wood Treaters FY Front yard

ID Identification

SF Surface soil

Sum of individuals subject to Level II concentrations: 374

Level II Concentrations Factor Value: 374 (Ref. 1, Section 5.1.3.2.2)49 SE – Resident Population Threat 5.1.3.3 Workers

Table 21 identifies workers whose workplace area is on AOC A or within 200 feet of AOC A on the respective workplace property (Ref. 1, Section 5.1.3).

TABLE 21: Workers

Area of

Observed

Contamination

Letter Location No. of Faculty/Staff References

A STES 40 3; 42

A Faith Deliverance Church School/Day Care 15 3; 42

Total Workers: 55

Workers Factor Value: 5 (Ref. 1, Table 5-4)

5.1.3.4 Resources

Description of Resource(s): No resources identified in HRS Section 5.1.3.4 are documented on AOC A located on and in the vicinity of the FSWT property.

Resources Factor Value: 0

5.1.3.5 Terrestrial Sensitive Environments

No terrestrial sensitive environments have been documented on AOC A located on and in the vicinity of the FSWT property.

Terrestrial Sensitive Environments Factor Value: 050 SE – Nearby Population Threat 5.2 NEARBY POPULATION THREAT

The Nearby Population Threat was not scored because the Resident Population Threat is sufficient to qualify the site for the NPL. This threat is of c oncern to EPA and may be considered during a future evaluation (Ref. 1, Table 5-6). For instance, there are 248 students attending RVDES (Ref. 42).