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Site Number: |
B4E8 |
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Contract Number: |
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D.O. Number: |
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Action Memo Date: |
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Response Authority: |
CERCLA |
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Response Type: |
Time-Critical |
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Response Lead: |
EPA |
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Incident Category: |
Removal Assessment |
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NPL Status: |
Non NPL |
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Operable Unit: |
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Mobilization Date: |
11/17/2009 |
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Start Date: |
9/1/2009 |
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Demob Date: |
11/20/2009 |
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Completion Date: |
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CERCLIS ID: |
FLN000410641 |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
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FPN#: |
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Reimbursable Account #: |
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1.1.1 Incident Category
1.1.2 Site Description
1.1.2.1 Location
1.1.2.2 Description of Threat
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
Hemlock Street Battery Site (the Site) was once part of the former Musselman Steel Corporation, formerly Musselman Steel Fabricators, Inc. (Musselman Steel) operated at the site as early as 1951 until late 1992. The Site is located at 1710 South 20th Street in Tampa, Hillsborough County, Florida. The company was primarily a metal fabrication business which engaged in metal forming, welding and finishing for various industries. The Site is located on Hookers Point, a peninsula bound by McKay Bay to the east, Sparkman Channel to the west, and Hillsborough Bay to the south.
The area around the site is a mix of heavy industrial/commercial industries of Tampa which has extensive rail yards, port terminals, and above ground storage tank (AST) farms. Homes are located approximately 300 feet northeast of the Site.
In April 1992, the Environmental Protection Commission of Hillborough County (EPC) received an anonymous complaint regarding the Site. During an investigation by EPC, large amounts of solid waste including empty drums and crushed battery casings were observed throughout Site. EPC requested that a solid waste removal and limited excavation of wastes be conducted at the Site. In May 1992, Musselman Steel removed three 1,000-gallon fuel underground storage tanks (USTs) and excavated some contaminated soils.
In January 1993, Musselman Steel submitted a Contamination Assessment Report (CAR) to the EPC which identified a solvent plume in the UST area at the Site. The plume contained elevated levels of lead, benzene, vinyl chloride and other toxic organic compounds which exceeded Florida's Maximum Contaminant Levels (MCLs). The Site was then referred to the Florida Department of Environmental Protection (FDEP). By October 1993, Musselman filed for bankruptcy protection.
In October 1996, FDEP prepared a Preliminary Assessment (PA) to gather and evaluate existing file material and determine the potential for a release at the Site. Subsequently, the FDEP submitted a Preliminary Contamination Assessment Report (PCAR) to EPA recommending no further action under CERCLA regarding the lead contaminated soils at the Site. In February 1997, EPA conducted a PA and determined that no further action was necessary.
In June 1999, the FDEP delisted the Site from the state Hazardous Waste Cleanup Program. Later that year, the FDEP recommended that the Site be returned to its Southwest District office in order to pursue further investigation and enforcement of potentially responsible parties (PRPs).
In 2005, the FDEP approved the Site for state-funded cleanup under the Petroleum Cleanup Program in order to remediate lead in the groundwater. In 2006, a current property owner submitted an Additional Assessment and Source Removal report to FDEP and in 2008, requested a site status of No Further Assessment after groundwater treatment was conducted. The FDEP denied the request.
In June 2009, FDEP again referred the Site to EPA to address any contaminated soils.
During the week of November 17, 2009, the United States Environmental Protection Agency (EPA) Region 4 On-Scene Coordinator (OSC) and Superfund Technical Assessment and Response Team (START) began a Removal Site Evaluation (RSE) of Hemlock Street Battery Site. All activities were undertaken pursuant to Section 300.410 of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). The purpose of the RSE was to delineate previously identified lead and arsenic contamination in the soil. A portable x-ray fluorescence (XRF) instrument was employed during field screening down to a maximum depth of 12 inches below ground surface (bgs).
Soil was screened for lead and arsenic at a total of 22 (11 surface and 11 subsurface) locations from 2 grids. Four samples were submitted to a laboratory for XRF confirmation purposes.
Confirmatory laboratory results for lead ranged from 2,250 mg/kg to 23,100 mg/kg. Analytical results for lead exceeded EPA’s industrial/commercial removal action level (RAL) for lead of 2,000 mg/kg.
Confirmatory laboratory analytical results for arsenic ranged from 3.5 mg/kg to 18.8 mg/kg. The analytical results for arsenic did not exceed EPA’s industrial/commercial removal action level (RAL) for arsenic of 177 mg/kg.
Lead present in on-site surface and subsurface soils pose the following threats to public health or welfare as listed in Section 300.415 (b)(2) of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP):
Section 300.415 (b)(2)(i) Actual or potential exposure to nearby human populations, or the food chain from hazardous substances pollutants or contaminants; Investigation of the Site has documented that lead concentrations in surface soil exceed Removal Action Levels (RALs) of 2,000 mg/kg for commercial/industrial landuse settings. Approximate values for lead were screened as high as 127,000 ppm. Confirmation laboratory analysis showed concentrations lead concentration as high as 72,900 mg/kg.
The majority of contaminated soil remains within a poorly maintained fenced area with at least one observed breach that could be accessed by trespassers who may become exposed to the soil. Anyone entering the Site may be exposed via inhalation of windborne dust, inadvertent ingestion of contaminated soil, and direct contact with the contaminated surface soils. Off-site migration of lead via erosion or airborne dust may lead to the exposure of nearby residents.
Section 300.415 (b)(2)(iv) High levels of hazardous substances or pollutants or contaminants in soils largely at or near the surface that may migrate; Analytical results reveal that lead levels are present at or near the surface creating a potential for migration to off-site locations. Lead concentrations exceed the RALs of 2,000 ppm, and were confirmed through on-site XRF analysis and laboratory analysis.
Section 300.415 (b)(2)(v) Weather conditions that may cause hazardous substances or pollutants or contaminants to migrate or be released; As stated above, contamination of soils along the Site boundaries increases the possibility of contaminated soils being transported off-site via runoff. Heavy rainfall could potentially carry contaminated soils east towards retention ponds that empty into McKay Bay. Heavy rainfall could also potentially carry contaminated soils west towards an intermittent creek located along the western boundary of the site which empties into Sparkman Channel.
Due to the threat and/or future threat to human health and the environment, from the identified hazardous substance, this Site achieves removal eligibility based on the removal criteria listed above.
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