Site Description
Overview of The Remedial Investigation/Feasiblity Study Process
Under the Comprehensive Environmental Resource Conservation Liability
Act/Superfund Reauthourization Act (CERCLA/SARA, or just "Superfund")
the EPA directs the cleanup process based on a complex set of guidelines. The
basis of these guidelines are rooted in seven criteria: cost, overall
protection, legal compliance, implementability, short and long-term
effectiveness, reduction of toxicity, state and community acceptance.
Generally, there is a
preliminary investigation to determine "threats" and
"receptors." Threats are chemical hazards, either poisons or
cancer-causing agents, present in sufficient quantities to be toxic. Receptors
are humans or animals that can come in contact with the threats. Often this
determination process occurs as
part of the listing on the NPL.
The Remedial Investigation (RI) phase is designed to obtain numerical
information on the distribution of threats around the site, and the pathways
that threats can move toward receptors. The goal of the RI is to allow
development of a plan to mitigate those threats.
The Feasibility Study (FS) uses the data from the RI to produce several
cleanup scenarios, or models. Based on the seven criteria of Superfund one model
is chosen for further development.
EPA's legal right to operate within state borders derives from a lawsuit
by EPA against the Responsible Party, who is financially liable for the cleanup
costs. The mechanism for instituting a cleanup is through a Record of Decision
(the "Rod") filed with the Department of Justice, which is signed by a
Federal Judge prior to initiation of the cleanup.
Overview of Site Studies
At this site the main portion of the work occurred well prior to listing
as an NPL site. A variety of studies performed by various contractors were
undertaken beginning in 1987. There is some historic data from sampling wells
dating from the early 1970's when the plant was operating.
Pond Characterizations
The ponds received both solids and suspended solids as byproducts of
elemental phosphorus manufacturing. Studies
were conducted to determine hazardous
metals and organics, the depth to undisturbed soil, and borders of the ponds for
Feasibility Study calculations on remediation volume.
Elemental Phosphorus Characterizations
About 150 soil borings were conducted to locate elemental phosphorus. Most
of these test were centered in the southwestern pond areas near the Anclote
River. A supplemental study was
conducted in 1994 to look for elemental phosphorus in soil and groundwater.
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