HAZARD RANKING SYSTEM (HRS) DOCUMENTATION 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., 11th 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, and 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 (NPL). 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: Jacksonville, 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 delineated 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 represent the initial determination that a certain area 

may need to be addressed under the Comprehensive Environmental Response, Compensation, and 

Liability Act (CERCLA). Accordingly, EPA contemplates that the preliminary description of facility 

boundaries at the time of scoring will be refined as more information is developed as to where the 

contamination has come to be located. 

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

1 
WORKSHEET FOR COMPUTING HRS SITE SCORE 

S Pathway S2 Pathway

Ground Water Migration Pathway Score (Sgw) NS NS

Surface Water Migration Pathway Score (Ssw) NS NS

Soil Exposure Pathway Score (Ss) 100 10,000

Air Migration Pathway Score (Sa) NS NS

S2

gw + S2sw + S2s + S2a 10,000

(S2

gw + S2sw + S2s + S2a) / 4 2,500

√ (S2

gw + S2sw + S2s + S2a) / 4 50.00

Note: 

NS = Not scored

2 
3 

TABLE 5-1 --SOIL EXPOSURE PATHWAY SCORESHEET

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 Score (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 Scorec (Ss), [lines (11+21)/82,500, subject 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) 

L
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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 ") 

")

")

#* 

")

Pullman Court FWT-39-SF-FY FWT-40-SF-FY #* " 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 #* 

Element WT-G08-SS-B 

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 Street 

Fairfax Street 

") 

WT-G12-SS-B 

WT-G13-SS-A

WT-G13-SS-B	 WT-G14-SS-A

WT-G14-SS-B 

Pullman 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 A
 

Date 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 Treaters 

R.V. Daniels 

Elementary 

School 

Susie Tolbert 

Elementary 

School 

Shared 

Play Area 

CSX Transportation 

Fairfax Street 

Pullman Avenue 

West 17th Street 

West 16th Street 

West 15th Street 

West 14th Street 

Pullman Court 

West 15th Street 

West 17th Street 

West 19th Street 

West 20th Street 

Spires Avenue 

FWT-00-SB-A2 

WT-BG-SF-01 

WT-BG-02-SS-A WT-BG-02-SS-B 

MA AB BFSSSWSAPARA
Fairfax St. 

Wood Treaters 

R.V. Daniels 

Elementary 

School 

Susie Tolbert 

Elementary 

School 

Shared 

Play Area 

CSX Transportation 

Fairfax Street 

Pullman Avenue 

West 17th Street 

West 16th Street 

West 15th Street 

West 14th Street 

West 13th Street 

Pullman Court 

West 15th Street 

West 17th Street 

West 19th Street 
8 

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 StreetMap, 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/cerclisquery.get_report?pgm_sys_id=FLD000623041. 

6. Tetra Tech. Project Note to File with Attachments. 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 Chemicals 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 (FDEP). 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 Assessment 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 Environmental 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-05-003-0114. 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 Plan, 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. Subject: 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 Scientist, and Denise Goddard, Chemist, EPA Region 4 

SESD, Quality Assurance Section. January 6, 2009, Updated December 1, 2011. 1 Page. 

25. Tetra Tech. Record of Telephone Conversation. Subject: Definitions of Minimum Reporting Limit, 

Minimum Quantitation Limit, Contract Required Quantitation Limit, and Sample Quantitation Limit. 

Between Shanna Davis, Environmental Scientist, and Charlie Appleby, Quality Assurance Section, 

Management and Technical Services Branch, EPA Region 4 SESD. July 9, 2008. 1 Page. 

26. Tetra Tech. Project Note with Attachments. Subject: Summary of J-Qualified Data. Attachment: 

J-Qualified Data Adjustment Calculations. 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 Technology Innovation. Contract Laboratory Program 

National Functional Guidelines for Inorganic Superfund 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 Wood, 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/images/nplmedia/pdfs/jaxvilflwaterfaxs072011.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 Waste Management, with Attachments. Subject: 

Notice of Contamination beyond Property Boundaries, 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-Dannals, Superintendent, Duval County School District. Regarding: 

Susie E. Tolbert Elementary School, 1925 W. 13th St, Jacksonville. October 17, 2008. 6 Pages. 

38. FDEP. Letter to Fairfax Land Management, Inc. Regarding: 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-05-001-0151. July 22, 2011. 22 Pages. 

45. Tetra Tech. Project Note to File with Enclosures. Subject: July 2011 Removal Confirmation and 

Residential Sampling Activities at Fairfax St. Wood Treaters in Jacksonville, Florida. Enclosures: 

Sampling Locations, Data Tables, Logbook Notes, Field QC Review, and Data Packages. October 

27, 2011. 152 Pages. 

46. Tetra Tech. Project Note to File with Attachment. 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 Attachments. Subject: Removal Activities and Confirmation 

Samples Collected at Fairfax St. Wood Treaters 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: Fairfax St. Wood Treaters Retention Pond. January 17, 

2012. 1 Page. 

50. EPA. Action Memorandum. Subject: Request for 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: Terry 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/Bankruptcy/BankruptcyBasics/Chapter11.aspx. 

52. Tetra Tech. Project Note to File. Subject: 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 Establishing Bar Dates and Notice by the Clerk of 

Meeting of Creditors and Appointment of Trustee. Case No. 3:09-bk-01895-PMG. Dated July 26, 

2010. 2 Pages. 

56. Tetra Tech. Project Note to File with Enclosure. 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). More 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 recorded in the Comprehensive Environmental Response, 

Compensation, and Liability Information System (CERCLIS) 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 using the wood treating preservative chromated copper 

arsenate (CCA) (Refs. 7, p. 1; 15, p. 2). The FSWT site comprises contaminated soil at and adjacent to 

the FSWT facility (Refs. 17, pp. 10 through 16, Appendix 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 (Refs. 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 14th 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 shared with its neighboring R.V. Daniels Elementary 

School (RVDES) (see Figure 2 of this HRS documentation 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 FSWT 

property (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 other 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 have 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 using 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 composed 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 arsenic 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 140 to 150 pounds per square 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 was 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 berms, and a lined retention pond (Ref. 13, p. 9). The 

type of liner is believed to be high-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, resulting in a CCA solution (Ref. 11). CCA-contaminated 

stormwater from the drip pad was diverted to an underground sump located adjacent 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 was 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 (Ref. 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 pond 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 stormwater 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 FSWT 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 converted 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, LLC. 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, EPA 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 

27 
 14 

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). One waste sample was collected from each of the six 
 15 

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 boundaries 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 the 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. The 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 secondary containment area was cleaned (Ref. 22). On the 

STES property, sediments in the STES retention pond were removed and replaced 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, backfilled 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 conducted 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 level 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 13th Street. After each 

excavation, Tetra Tech collected 5-point confirmation 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-sodded 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 selecting the observed contamination samples evaluated 

in this HRS documentation record (see Section 5.0.1). 

FSWT installed the lined retention pond on the northwestern corner of the operations area on the property 

in 1990 as part of its stormwater collection and retention 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 retention pond. At the time of the ER in August 

2010, the retention pond was a bright lime green color, characteristic of CCA contamination (Refs. 11; 

15, Appendix C, p. C-4). The retention pond is connected 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 August 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 investigation. 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 contained 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 Facility 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 criteria 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 surrounding 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 documentation 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 storing treated material on gravel along the northern, 

western, and southern portions of the FSWT property (Refs. 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 that 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, this 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 14th 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 uncontrolled 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 reported 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) soil samples were collected from the FSWT property 

and the STES and RVDES properties in locations where 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, Appendix 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 FWT-01-SF, located near the fence line separating the 

STES property and the FSWT property (Ref. 16, Appendix A, p. A-3, Appendix B, p. B-2). 

In addition, composite surface soil samples were collected from 17 residential properties, including 13 

along Pullman Court and four along West 14th Street. Four surface soil samples were also collected from 

an apartment complex located on West 13th 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 detected 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 property 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 excavation 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 surface 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, Appendix 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 26 

mg/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 (Refs. 44, Appendix B, p. B-1; 45, p. 1). In surface 

soil samples (0 to 6 inches bgs), arsenic 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 (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 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 16th Street (Ref. 45, Enclosure 1, p. E1-

13). 
18 SE – AOC A General Considerations 

The soil samples collected from the FSWT property that establish observed contamination were collected 

from areas where no removal activities occurred or from 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 removal 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 samples 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 residential and school properties located east, south, and west 

of the FSWT property. All of the soil samples collected on residential or school and daycare properties 

used to establish observed contamination for AOC A were 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 selecting 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 documentation 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 land 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 Quality System and Technical Procedures for Soil 

Sampling, SESDPROC-300-R1 (Refs. 16, p. 2, Appendix 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 20th

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 Treaters 
20 SE – AOC A General Considerations

Background Concentrations

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

investigation (Refs. 16, p. 1, Appendix D, p. D-13, Appendix F, pp. F-10, F-28; 17, Appendix A, p. A-4). 

Soil samples collected during the January 2011 removal investigation were analyzed by Environmental 

Conservation Laboratories, Inc. (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, p. F-135). A 

Tetra Tech chemist validated the analytical data in accordance with the EPA Contract Laboratory 

Program (CLP) National Functional Guidelines for Superfund 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 

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 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 1.14J (1.98) mg/kg 1.17 mg/kg

16, Appendix E, pp. E-7, E-97, 

Appendix F, p. F-135; 26, pp. 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

SB Subsurface soil
21 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 removal 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, Appendix 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. Chain-of-custody records are provided in Reference 16, 

Appendix F. The locations of the soil samples collected 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 01/19/2011 
22 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 School
23 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 the analytical data in accordance with the EPA CLP 

National Functional Guidelines for Superfund Inorganic Data Review (January 2010) (Refs. 16, Appendix 

E, p. E-3; 29). The PQLs are listed on the analytical data sheets in Reference 16, Appendix F. Each PQL 

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 

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-125 
24 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 soil
25 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 corner 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 samples collected from AOC A and (2) this sampling location 

appears to be minimally affected by facility operations (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 Treaters 
26 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 CLP 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 performed, as well as for percent moisture. The MRLs are 

equivalent to SQLs (Ref. 25). 

TABLE 7: Analytical Results for AOC 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 adjusted 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 Treaters
27 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 provided 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 Figure 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 14th Street 

0 to 6 05/10/2011 17, p. 12, Appendix A, p. A-5, 

Appendix D, p. D-11; 23, pp. 

WT-SF-02-DUP 0 to 6 05/10/2011 1, 3 

WT-SF-03 

Southeastern corner of 

the FSWT property, 

near West 14th 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. 

WT-SF-05-DUP 0 to 6 05/10/2011 15; 23, pp. 1, 3 

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. 4 
28 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 Treaters 
29 SE – AOC A General Considerations

Contaminated Concentrations

The soil samples listed in Table 9 were collected during the EPA May 2011 Pre-RI (Ref. 17, p. 12, 

Appendix A, p. A-5, Appendix D, pp. D-10, D-11, Appendix E, pp. E-169, E-170). Soil 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 SQLs (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, Appendix 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, pp. i, 2; 27, pp. 8, 18
30 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 adjusted 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 Treaters 
31 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, Appendix B, p. B-1; 45, p. 1, Enclosure 1, p. E1-1). 

The background surface soil samples were collected at depths 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-BG-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 land 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 Reference 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 20th Street and 

Spires Avenue 

0 to 6 07/26/2011 45, p. 1, Enclosure 1, 

p. E1-1, Enclosure 3, 

WT-BG-02-SS-B p. E3-7, E3-8; 46, p. 1 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 Treaters 
32 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, Enclosure 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 performed, 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 adjusted 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 reported 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 Treaters
33 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 Region 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, 

WT-G01-SS-B 18 p. E3-4; 46, pp. 1, 2 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, 

WT-G03-SS-B 18 p. E3-4; 46, pp. 1, 3 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, 8 

WT-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, 

WT-G05-SS-B 18 p. E3-6; 46, pp. 1, 3 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, 

WT-G07-SS-B 18 p. E3-6; 46, pp. 1, 3 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, 

WT-G08-SS-B 18 p. E3-6; 46, pp. 2, 3 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. 3 
34 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, 

WT-G13-SS-B 18 p. E3-4; 46, pp. 2, 4 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, 

WT-G14-SS-B 18 p. E3-4; 46, pp. 2, 4 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 Treaters 
35 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 performed, 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. E5-42
36 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. E5-55
37 SE – AOC A General Considerations 

Notes: 

( ) Concentrations shown in parentheses were adjusted 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 reported 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 Treaters
38 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 using the wood treating preservative CCA. FSWT did 

not treat wood products with creosote or pentachlorophenol (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 composed 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 (Refs. 7, p. 2; 40, p. 133) (see Figure 1 of this 

HRS documentation record). A conduit was used to route some of the stormwater to the STES retention 

pond. In 1990, FSWT installed a stormwater collection 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 closed off at this time (Refs. 7, 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 for re-use in the wood 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. These ditches drain into the retention pond at the 

northwestern corner of the operations area of the property. An overflow pipe is located in the retention 

pond so that 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; 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 when the FSWT facility retention pond was under 

construction (Ref. 35, pp. 1, 3). CCA contamination 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 property, 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 during the EPA August 2010 ER (Ref. 15, p. 44). The 

topography of the FSWT property and the surrounding area 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). Furthermore, the concentrations of arsenic, chromium, 

and copper detected in soil at FSWT and the surrounding properties show a gradient that decreases with 

distance from FSWT. The hazardous substances listed 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 water, 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 eventually overflowed from the sump to the secondary 
39 SE – General Considerations-Attribution 

containment area surrounding the tanks. The secondary containment area overflowed onto the parking 

lot, where the stormwater ditches eventually 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 the 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 from 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 manganese (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 from 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 from 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, Appendix D, pp. D-4, D-8). Nearby residential properties 

on Pullman Court and West 14th 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 13th 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 pre-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 eight of the nine residential soil samples collected, 

ranging from 20 mg/kg (WT-RP-SF-06) to 71 mg/kg (WT-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 Services, 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 below 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), arsenic 
40 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 collected 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 16th Street (Ref. 45, Enclosure 2, pp. E2-13 through E2-18). 

Because FSWT is located in a metropolitan city, there are many state and federal regulated facilities 

located within 1 mile of FSWT, including Resource Conservation and Recovery Act (RCRA) hazardous 

waste generators, state hazardous waste sites, facilities with underground and above ground storage tanks 

(USTs and ASTs), brownfields sites, and dry cleaners (Ref. 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 the 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 5th & 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 5th & 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 FSWT 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 electrical substation of the Jacksonville Electric Authority 

(JEA), surrounding single-family homes, and multiple 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 about 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 pesticide formulating, packaging, and distributing facility. Contaminants 

associated with these operations include dissolved metals, 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 

Copper 
41 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 detected 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 contained 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 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 (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 through 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 [ft2

]): >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 zero, but undetermined (Ref. 1, Section 5.1.2.2). 

 HWQ Value: >0
44 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 Characteristics Factor Category Value 

The waste characteristics factor category was obtained by multiplying the toxicity and HWQ factor 

values. Based on this product, a value was assigned 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 105

Waste Characteristics Factor Category Value: 18 

(Ref. 1, Table 2-7) 
5.1.3 RESIDENT POPULATION THREAT TARGETS

The soil samples listed in Table 17 were collected during the EPA January 2011 removal investigation and the EPA May 2011 pre-

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 (

Level I Concentrations

During the EPA January 2011 removal investigation, soil samples were collected from residential properties along Pullman Court (3; 17, Appendix A, p. A-4). Composite surface soil (0 to 6 inches bgs) samples were collected from the front and back yards of resfeet 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 reco

this event were analyzed by ENCO, a Tetra Tech-procured laboratory, and were validated by a Tetra Tech chemist (Ref. 16, p. 4, AEPA May 2011 pre-RI, grab surface soil samples (0 to 6 inches bgs) were collected from school/daycare and residential properties 

Street (Ref. 17, pp. 12, 13, Appendix A, p. A-5). Samples collected during the May 2011 sampling event were analyzed by an EPA 

by 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 Concentrations 

Sample ID 

Hazardous 

Substance 

Hazardous 

Substance 

Concentration

Background 

Concentration 

Benchmark 

Concentration Benchmark R

FWT-36-SF-BY Arsenic 12.4 mg/kg 1.14J (1.98) mg/kg 0.43 mg/kg CRSC 2, p. BII-13; 16, Appen

F, pp. F-121, F-135; 26

FWT-39-SF-FY Arsenic 7.18 mg/kg 1.14J (1.98) mg/kg 0.43 mg/kg CRSC 2, p. BII-13; 16, Appen

F, pp. F-126, F-135; 26

FWT-39-SF-BY Arsenic 30.4 mg/kg 1.14J (1.98) mg/kg 23 mg/kg RDSC 2, p. BII-13; 16, Appen

F, pp. F-128, F-135; 26

FWT-41-SF-BY Arsenic 28.7 mg/kg 1.14J (1.98) mg/kg 23 mg/kg RDSC 2, p. BII-13; 16, Appen

F, pp. F-131, F-135; 26

WT-RP-SF-05 Arsenic 6.5 mg/kg 1.8U mg/kg 0.43 mg/kg CRSC 2, p. BII-13; 17, AppenNotes: ( ) Concentrations shown in parentheses were adjusted in accordance with References 26 and 27. mg/kg Milligrams per kilogram AOC Area of observed contamination RDSC Reference Dose Screening ConcentratioBY Backyard RP Residential property CRSC Cancer Risk Screening Concentration SF Surface soil FWT Fairfax St. Wood Treaters U The analyte was not detected at or above FY Front yard Appendix E, p. E-6) ID Identification WT Fairfax St. Wood Treaters J The analyte was positively identified; the associated value is the approximate concentration  of the analyte in the sample (Ref. 16, Appendix E, p. E-3).

45 
46 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, Appendix E, pp. E-7, E-97, Appendix 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 property 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 counted 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 Concentrations 

The soil samples listed in Table 19 were collected during the EPA January 2011 removal investigation sampling event (Ref. 17, ApLevel II Concentrations

During the EPA January 2011 removal investigation, soil samples were collected from the STES property (near the school buildingproperty 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 

were collected from the STES property within 200 feet of the school building, and composite soil samples were collected from the 

residential property within 200 feet of the residence (Ref. 16, p. 3, Appendix A, p. A-4) (see Figure 2 of this HRS documentation reduring this event were analyzed by ENCO, a Tetra Tech-procured laboratory, and were validated by a Tetra Tech chemist (Ref. 16, through E-7). 

TABLE 19: AOC A Level II Concentrations 

Sample ID 

Hazardous 

Substance 

Hazardous 

Substance 

Concentration 

Background 

Concentration

Benchmark 

Concentration Benchmark 

FWT-17-SF Chromium 18.1 mg/kg 5.47 mg/kg 230 mg/kg RDSC 2, p. BII-15; 16, AFWT-30-SF Chromium 16.6 mg/kg 5.47 mg/kg 230 mg/kg RDSC 2, p. BII-15; 16, AFWT-37-SF-FY Chromium 17.5 mg/kg 5.47 mg/kg 230 mg/kg RDSC 2, p. BII-15; 16, AFWT-37-SF-BY Chromium 17.3 mg/kg 5.47 mg/kg 230 mg/kg RDSC 2, p. BII-15; 16, A

Notes: AOC Area of observed contamination BY Backyard FWT Fairfax St. Wood Treaters FY Front yard ID Identification mg/kg Milligrams per kilogram RDSC Reference Dose Screening Concentration SF Surface soil

47 
48 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 investigation 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: 0 
50 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 concern 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).