Overview

The first draft of the Workplan for the Jacksonville Ash Site Remedial Investigation/ Feasibility Study has been received for review. A Remedial Investigation using this Workplan will not find all sources of contamination. The plan is especially likely to miss contamination located in and around homes on private property. Too few samples are taken, and too few laboratory tests are planned for the investigation to be considered thorough.

Both the State of Florida Department of Environmental Protection and the U.S. Environmental Protection Agency have reviewed the Workplan and asked for extensive changes in sampling and methodology. Unless these changes are made, there may be unsafe levels of toxins remaining behind after remediation is complete.

Site Description

The Jacksonville Ash Sites are composed of three areas:

The Forest Street Incinerator Site

The main area includes portions of Forest, Margaret, and Goodwin Streets, and McCoy Creek Boulevard. An incinerator operated in the Northeast corner of the site from the 1940’s through the 1960’s, with ash buried all around the area. Pockets of buried ash found east of I-95 and farther north of McCoy Creek are not indicated on charts provided in the Workplan. There may be additional areas of surface soil contamination from past burning operations that extend even further.

The 5^th and Cleveland Incinerator Site

This incinerator also operated from the early 1940’s through 1969. Buried ash deposits have been detected at numerous “offsite” places in and around residences. An area of contaminated soil may also be present at this site from ash “fallout” during incinerator operations.

Lonnie C. Miller, Sr. Park Site

This site, which contains ash material from the 5^th and Cleveland Incinerator; covers more than 100 acres in the vicinity of Price, Moncrief and Soutel Roads. In contrast to the other sites this area may also have buried septic sludge. Some reports place the ash deposits at 15 feet thick in places. Elevated levels of dioxins are also noted.

Remedial Process Overview

Up until this point, work has involved determining if the site met the definition of a “Superfund” site. Samples were collected to determine the type of chemical toxins, the level of toxicity and whether the site poses a hazard to people or the environment. The Jacksonville Ash Site does meet the Superfund criteria and is a threat to the community. The studies performed so far are in no way complete enough to begin designing a cleanup plan.

The next step in the process is to conduct a full Remedial Investigation or “RI” to find out five things:

1) The full spectrum of chemical hazards (How many different chemicals are there?);

2) The environmental phases where chemicals are found (Are they in water, subsurface soil, soil, or air?);

3) The “areal” extent (Where is the contamination along the ground in terms of north to south, and east to west?);

4) The depth extent (How deep is it buried?); and

5) The highest levels of each toxin.

The next phase is actually two tasks, the Human and Environmental Baseline Risk Assessments and the Feasibility Study. The Baseline Risk Assessments use three pieces of information from the RI. The types of pollutants, the nature of occurrence (water, subsurface soil, soil, or air) and their highest levels are used to develop a mathematical model for establishing Remediation Goals.

The Feasibility Study also uses three pieces of data from the RI and one from the Risk Assessments. The Remediation Goals are used to map pollution for treatment, then the areal extents (contaminated land surface area) are multiplied by the depth extents (contaminated land depth) to get the cleanup volume, usually expressed in cubic yards.

Remedy Selection is supposed to use this information to design a system for destroying, removing or immobilizing toxic waste. Given the complexity of this site, there will probably be several different remedies applied to the waste.

Obviously, the success or failure of the remedy depends in a large part on the quality of the Remedial Investigation data.

Workplan Overview

The Workplan provided for review reads more like a “mini” Remedial Investigation rather than a plan to collect samples for defining exposure routes and estimating remediation volumes. Much of the draft Workplan content is irrelevant and serves no useful purpose. Of the proposed field experiments that are described, there are too few samples planned for analysis to provide definitive borders of the contamination or establish the known depths. Further, the plan seems to have a built-in bias towards assuming the waste has remained in place rather than eroded and moved. Finally, attempts to define volume estimations or remedy technologies using “background” sampling are not appropriate at this time and in this document.

There are essentially four different forms contamination can take at these sites:

1) Buried ash or waste extending from the surface, or just beneath the topsoil, down several feet;

2) Topsoil contaminated with ash “fallout” from burning, which should form a “doughnut” shape of contamination around the site;

3) “Runoff” contamination where chemicals have spread (by migration or erosion), usually downslope from contaminated areas, as surface contamination or drainage sediment; and;

4) Contaminated groundwater from dissolved contamination moving as a plume.

Each of these forms has a specific pattern that requires a different approach to testing. A bona fide search for waste in these forms was not proposed in the first draft of the Workplan.

Buried ash and waste

Ash was buried in different areas over the several decades the incinerators operated. The composition of the ash in each area will reflect the nature of the waste burned. Older waste, before the late 1950’s, can be much lower in petroleum-based organic waste since many plastics had not been invented or found widespread use in disposable food packaging. Much of the dioxin and chlorine-carbon waste associated with landfills may be related to plasticizers and polyvinylchloride (PVC) products, which are more prevalent after the late 1950’s. Also, there is eyewitness information that some solid wastes were buried without burning. Since the waste came from both commercial and residential addresses, there is the possibility of chemical sources in buried containers. The draft Workplan provided for review would not find these contaminants.

The proposed Workplan will do a poor job of fully identifying the buried ash and waste. Essentially, the plan looks for two types of waste: glass pieces with lead contamination, and glass without lead contamination. There are not enough samples planned to actually show the extent of waste buried or migrated. Only a few samples were planned for full testing, most are just quickly examined for lead above the PRG (Preliminary Remedial Goal) of 400 ppm. The data obtained in this manner would be inadequate for planning purposes, both in terms of designing a remedy and for baseline health effects. The draft Workplan would likely not locate buried halocarbon and dioxin materials.

Text Box: Residential Cleanup Standards (ppm)
EPA State PRG
Arsenic 0.43 0.8 2.6.
Lead 400 400 400
Mercury ? 3.4 2.35
Dioxins 0.001 0.000007 ? Ash deposits that do not contain toxins above the Cleanup Standard action level are considered solid waste, not toxic waste. It is unclear at this time if the presence of solid waste will be reported.

Comments by both the State of Florida Department of Environmental Protection (DEP) and the Environmental Protection Agency (EPA) make the point that the sites will need to be better characterized. Both DEP and EPA remarked that the site maps provided in the Workplan misrepresented the known extent of buried ash, omit some areas, and failed to provide a plan for locating unknown deposits of ash onsite. EPA’s remarks call for geophysical mapping of some areas of the site. This usually means Ground Penetrating Radar that can locate buried objects and invisible deposits. Magnetic detection may also be used if drums of waste or buried metal junk are suspected.

Sampling along a periodic grid is needed to locate those areas where burned and buried trash came from plastics. The information is critical for long-term remedy.

Ash “Fallout”

When the incinerators were operating a plume of smoke carrying heavy metal ash particles was injected into the air. In still air the plume would extend upwards, settling back to the ground near the source, but as the winds increased the plume would settle further and further away. Over years this would produce a “doughnut” shaped area of contamination around the incinerator. This type of contamination would be different than buried ash. There would be no telltale bits of glass, and the contamination will be near the surface.

Text Box: Remediation Terms

1 ppm: 1 parts-per-million, or “one part in a million parts” (applies to liquids and solids)

1 mg/kg: “one milligram per kilogram” equals 1 ppm. (applies to solids)

1 mg/L: “one milligram per liter” also means 1 ppm (applies to liquids)

ppm and mg/kg or mg/L are used interchangeably

1 ppb: ”one part per billion”
1 ppm equals 1,000 ppb’s.

1 ppt: “one part per trillion”
or 1/1000 of a part per billion

Cubic yards: the length times the width of the surface area, times the depth of the buried waste (L x W x D). Used to determine the extent of the cleanup and estimate it’s cost.

Background: the amount of the chemical found “naturally” in the areas around the site.

Bias: Influencing the data, either positively or negatively (includes false positives, false negatives, and statistical anomaly).

Risk: Cancer Risk is based on a model with a range of between 1 in one-million chance of a new case of cancer (1 x 10-6, or 1E-6), and a 1 in ten-thousand chance of a new case in cancer (1 x 10-4, or 1E-4). 1x10-4 is 100 times “riskier” than 1 x 10-6.
Non-cancer risk is based on a hazard index where above 1 is grounds for remediation.

Sample frequency: The number of samples taken in an area, or number of samples taken from a boring. Too few or too many creates bias in the results.

Sample grid size: Applies to composite sampling. “Composite” means taking 4 or 5 “discrete” individual samples close together and combining then for a single analysis. Composites can improve accuracy, and reduce cost, but may introduce bias.

Synergy: When two chemicals interact to produce an effect that is greater (or lesser) than expected.

The proposed plan would start at the edge of the “known” contamination and move outward looking for lead concentrations above 400 ppm. They would stop upon reaching a “clean area.” This practice can miss surface contamination from ash fallout, which may begin some distance from the site.

A modeling study is needed to define the areas likely to be impacted by fallen ash. Knowing the smoke stack height and prevailing winds, engineers can predict where most of the ash would have settled in the neighborhoods during the decades the incinerators were in operation. The center of the ring should be sampled, moving inward toward the source and outward from the center of the ring. For these studies only the surface needs to be characterized.

“Runoff” soil migration

Lead, mercury and arsenic are elements that do not break down in nature. Further, lead and mercury are heavy metals that can accumulate in downslope areas from the erosive actions of rain. There has been considerable construction activity in these areas, which leads to soil disturbance and increases erosion. Accordingly, there may be creek and drainage areas in the neighborhoods that are now contaminated from the effects of erosion.

A modeling study is needed to better identify local streams and locate potential surface contamination from runoff.

Groundwater

Just as plumes of smoke may have contaminated areas in the neighborhood, plumes of groundwater may be carrying toxins to areas tapped by wells. Buried waste is a source for continued contamination of groundwater from leaching organics, and dissolved lead, mercury or arsenic. Any plume may extend a considerable distance before finally becoming diluted. More wells are definitely needed to provide thorough groundwater model for understanding the dynamics of subsurface flow.

Cleanup standards represent the highest concentration of chemicals after cleanup has occurred. Preliminary Remediation Goals (PRGs) are meant to provide a framework for different groups to begin guiding the Feasibility Study process when there is some ambiguity over the toxic threat of a chemical. PRG’s are not really appropriate for arsenic, lead or mercury at this site since these chemicals are well known and the state of Florida has set guidelines for cleaning hazardous waste sites where they are present.

The Workplan uses calculations for PRG’s based on the Jacksonville area background for these chemicals, rather than Risk Assessment Guidelines (RAGS), which are appropriate. The “background” samples may be contaminated from this or other sources, biasing the results.

It is unacceptable for data to be reported based on a PRG. All values reported at this stage must reflect the actual value found during analysis, not just those that exceed the Responsible Party’s (PRP) arbitrarily set threshold.

To get a true three-dimensional view of the distribution of contaminants the plan needs to outline a grid of soil borings with samples taken at depth intervals. The number of sample locations was insufficient in the plan. Additionally, there are too few samples taken from each soil boring. Finally, the samples taken need to be subjected to analysis for a full complement of chemicals.

This study really only uses lead as an indicator of pollution. It is likely that the proposed plan will underestimate the threat.

Offsite versus Onsite

Perhaps the most important issue to resolve at this stage is what is meant by “onsite” and “offsite.” Once the borders are defined, it becomes very difficult to add areas that may need remediation. Often different standards are applied between offsite and onsite, resulting in no cleanup of similarly affected “offsite" areas. In the Workplan, the borders are defined artificially based on anecdotal data, existing property boundaries, and visual inspections. Sampling needs to extend outward from the center of the sources until all areas requiring remediation are found.

Environmental versus Human Health

A “receptor” is person, animal or plant affected by the chemicals on a site. Young, old, and gender classes also constitute different receptors. It is not unusual for one species, or age-class of a species, or gender of a species, to have a very different tolerance to a chemical. So it is not unusual for cleanup standards to be different depending on the species that utilize the area.

The Forest Street site and the 5^th and Cleveland site are urban areas where the primary receptors are people and their pets. Since the ash is buried or distributed around homes in these areas the most sensitive receptor will be children. In the draft Workplan, lead was the predominant factor driving the cleanup, and this may turn out to be true for those areas. However, it is essential at this time to get a complete “snapshot” of chemicals and their distribution to assure that all receptors in those areas are protected.

At the Lonnie C. Miller, Sr. park site there are many more animals using the woodlands than at the other two sites. There are also streams flowing into a nearby river resulting in a greater danger to wildlife than in the urban sites. Accordingly, the Environmental Risk Assessment may be of greater importance at the Lonnie Miller site, and the Human Health Risk Assessment may play a greater role in cleaning up the urban sites. The cleanup methodologies may also be very different.

Obviously there are creeks affected by buried waste and runoff at the two urban sites, but the water quality of those streams is impacted by many sources, not just the waste buried at Forest Street or 5^th and Cleveland. If any chemicals are found in the urban streams that cannot be traced directly back to the ash, they may not be cleaned up under the current EPA-directed procedures, as these chemicals would not be “site” chemicals. Having said that, ash is a complex material and there may be traces of toxic chemicals that register poorly in the analysis used during this process. There is a need for biological toxicity tests on the stream water to gauge the health of the streams. The State of Florida requires discharges into streams and rivers to be non-toxic. It should be a requirement of the cleanup remedy that there are no toxic discharges to any stream or river. It is therefore appropriate to conduct toxicity tests both before and after any remedy.

Lead is toxic to the central nervous system and target organs such as the liver and kidneys. Arsenic is a short-term toxin on the same target organs, and also a long-term human carcinogen. Chemicals such as lead, arsenic and mercury tend to have additive effects, meaning that the effect is the sum of all exposure. Lead is particularly damaging to developing children. These sites are the main playgrounds of neighborhood children where routes of inhalation and ingestion are not only possible, but likely.

Conclusions

This site is in a very early stage of the remediation process. At this time the site description is too inadequate to predict the nature of the remedy or when cleanup can begin. It is clear that both public and private property areas are affected and that children are the likely receptors of a major contaminant. It is not clear at this time if the remedy will encompass all ash deposits, or only those with heavy metal contamination. It is not clear if dioxins or related organics are present.

The Remedial Investigation at this site remains to be accomplished, and should be performed in a manner that provides answers to the public on what contaminates are present, where they are distributed, what concentrations occur, and, if and where they may be spreading.