United States Environmental Protection Agency
Region IV
POLLUTION REPORT

Subject: 

On July 19, 2005, an area business owner contacted the City of Tampa regarding the dumping of an unknown material in a drainage ditch along Channelside Drive.  The dumping was estimated to have occurred on July 16, 2005.  On July 25, 2005, additional material was found to have been dumped in the ditch.  The City of Tampa requested Hillsborough County Environmental Protection Commission (HCEPC)assistance.

On August 02, 2005, the Florida Department of Environmental Protection (FLDEP) was contacted by HCEPC.  FLDEP found approximately 100 yards of the drainage ditch was covered with a black sludge-like material.  On August 12, 2005, FLDEP sampled the material.  Analytical results indicate the material has high levels of lead. Based on the levels of lead and scope of the spill, FDEP requested EPA assistance.

On September 14, 2005, OSC Stilman mobilized to the Site to conduct a removal site evaluation with the FLDEP Bureau of Emergency Response.  A black sludge-like material was found all along the storm water ditch.  The drainage ditch flows to Hillsborough Bay.  FLDEP sampling shows lead levels of the sludge as high as 2,060 parts per million (ppm) lead.  The waste also failed TCLP for lead.  Lead is a CERCLA hazardous substance. Access to the Site is unsecured.

Based on FLDEP analytical results and the removal site evaluation the following NCP criteria applies with regard to release or threat of release of a hazardous substance with regard to the Site:

From section 300.415 (b)(2) of the NCP,

300.415(b)(2)(i)  "Actual or potential exposure to nearby human populations, animals, or the food chain from hazardous substances or pollutants or contaminants":  The Site is unsecured, accessible and the waste material is on the surface of the ditch.

300.415 (b)(2)(ii): "High levels of hazardous substances or pollutants or contaminants in soils largely at or near the surface, that may migrate": Lead contamination over EPA’s removal action criteria, above 400 ppm, has been found in surface soils at the Site.  The Site is not secured.

300.415(b)(2)(v) "Weather conditions that may cause hazardous substances or pollutants or contaminants to migrate or be released": With each successive rain event, contamination may continue to be released to Hillsborough Bay.

300.415(b)(2)(vii) "Availability of other appropriate federal or state response mechanisms to respond to a release." Given the potential size and scope of the action, State funds are insufficient.  No other governmental entity has funds available to conduct the necessary removal activity.

Threats to the Environment:

Lead contaminated sludge and sediments at the Site pose a significant threat to the environment.  Uncontrolled release of contamination, transported via the surface water pathway during major rain events, may pose a threat to aquatic species in Hillsborough Bay.  Manatee live in and around Hillsborough Bay and Tampa Bay.  The Manatee is a federal and state listed endangered species.  Continued migration of the hazardous substance from known source areas at the Site to this fresh water resource could have potential long term, negative impacts.


ENDANGERMENT DETERMINATION

Actual or threatened releases of hazardous substances from this site, if not addressed by implementing the removal action selected in this Action Memorandum, may present an imminent and substantial endangerment to the public health or welfare or the environment.  


EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED OR NOT TAKEN

A delay in action or no action at this Site would increase the actual or potential threats to the public and the environment.

APPROVAL

This decision document represents the selected removal action for this Site, developed in accordance with CERCLA as amended, and
not inconsistent with the National Contingency Plan.  This decision is based on the administrative record for the site.

Conditions at the site meet the NCP section 300.415(b)(2) criteria for a removal and through this document, the OSC approves the proposed removal actions.  The total project ceiling is
$250,000, of which, $ 200,000 will be funded from the Regional removal allowance.

EPA OSC Stilman initiated an emergency removal action to stabilize and secure the contaminated material, and prevent further impact, establishing a $250,000 ceiling.  The Project Ceiling has been approved by the OSC as documented in this Action Memo/Initial Pollution Report.  ERRS contractor WRS has been mobilized to conduct the removal as directed by the OSC.  The FLDEP and HCEPC are also on site to assist with the response.

The specific tasks involved in the proposed response to the threats include:
                
Emergency stabilization of the contaminated material;

Extent of contamination sampling;

Excavation and disposal of contaminated material;

Confirmation Sampling; and,

Restoration        


Contribution to remedial performance

The proposed actions will, to the extent practicable, contribute to the efficient performance of any long-term remedial action at the site.

Description of Alternative Technologies

N/A
                    
ARARs

The Federal ARARs identified for the site include:
RCRA Treatment, Storage and Disposal

Project schedule

The initial emergency action to stabilize the site is expected to be of a short duration (weeks).

Upon procurement of a disposal facility, excavation and disposal of contaminated material will commence.