&EFVV United States United Metals, Inc.

&EFVV United States Environmental Protection Agency

Explanation of Significant Differences United Metals, Inc. Superfund Site

Site Name:

United Metais, Inc. Superfund Site

CERCLA ID #. FLD098924038

Site Location:

1690 Highway 71, Marianna, FL

Lead Agency: EPA, Region 4

Support Agency: Florida Department of Environmental Protection

UM'I'CD META LS. I N C .

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I. Introduction

This decision document presents an Explanation of Significant Differences (ESD) for the United Metals, Inc. Superfund Site (Site), located in Marianna, Florida. The Record of Decision (ROD) addressed by this ESD was signed on September 28, 2006.

The ESD is issued in accordance with ? 117(c) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), 42 U.S.C. ? 9601 et seq., as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), ? 300.435(c)(2)(i). The Director of the Superfund Division has been delegated the authority to sign this ESD.

This ESD will become part of the Administrative Record for the United Metals, Inc. Superfund Site (NCP 300.825(a)(2)), which has been developed in

SiteLor.ihouM.ip

Marianne, Florida

accordance with ? ll3(k) of CERCLA, 42 U.S.C. ? 9613(k).

The Administrative Record is available for review at the Jackson County Public Library, 2928 Green Street, Marianna, Florida, 32446, 850-482-9631 (Hours Mon-Thurs 9 am - 8 pm, Friday 9 am - 6 pm, Saturday 9 am - 3 pm, Sunday closed).

II. Statement of Purpose

The purposes of this ESD are (1) to provide an explanation of an exceedence in the amount of antimony allowed in the Synthetic Precipitation Leaching Procedure (SPLP) leachate from stabilized/solidified contaminated soil as specified in the ROD (2) a clarification that the 36 mg/kg lead concentration for ecological sediment remediation is an average concentration rather than a not-toexceed value.

The Environmental Protection Agency (EPA) prepares an ESD when it is determined by the

Agency that changes to the original selected remedy are significant, but do not fundamentally alter the remedy selected in the ROD with respect to scope, performance, or cost.

III. Site History and Contamination

Site History The United Metals Inc. Site is a former battery recycling facility located approximately 2.5 miles south of Interstate 10 and about 1,000 feet east of State Route (SR) 71 south of Marianna, in Jackson County, Florida. The land belonging to the Site covers a total of about 180 acres of which approximately 24 acres were used for the facility operations.

The battery recycling facility began plant operations in November 1979. The company was known as United Metals, Inc. All operations at the battery recycling facility ceased in July 1991.

Operations at the Site consisted of recycling used batteries, primarily lead-acid batteries but also nickel-cadmium batteries. The operations processed 10,000 to 12,000 batteries per week, resulting in the production of 2,500 to 5,000 gallons per day of acidic wastes. Generally, the used batteries were off-loaded and the plastic casings were then separated from the lead plates. The plastic casings were crushed and pelletized and sent to an off-site extruding facility. The lead components and lead oxide from the batteries were transported to an off-site lead smelting facility.

The liquid in the batteries drained to a reservoir through a series of concrete basins where the wastewater was neufralized and sent to an unlined holding pond located to the east of the recycling operations building. It was reported that some of the wastewater flowed directly to the holding pond, bypassing the concrete settling basins. A system was subsequently devised to store the wastewater in tanks, neufralize the acidic water, and recycle the water back into the plant

operations thereby eliminating discharge to the holding pond.

The United Metals, Inc. Site property is currently owned by Faircloth Properties, Inc. In 1998, Faircloth Properties, Inc. purchased the property pursuant to a tax sale for delinquent taxes.

There have been a number of investigations of the soil, sediment and groundwater at the Site since the early 1980s. The Site Inspection (SI) Report was completed in March, 1994. The Expanded Site Inspection (ESI) Report was completed on June 1, 1995. The ESI Report found elevated metals contamination in the soil, sediment and groundwater. It was determined that further CERCLA action was required.

The results ofthe ESI also lead to a limited removal action by EPA in 1996 in which six 55 gallon drums of hazardous waste were removed from and disposed of offsite, and several hundred gallons of sulfuric acid sludge were solidified and disposed of offsite.

In the summer of 2006, an EPA removal action was conducted. Approximately 2500 cubic yards of the waste pile, that had been stored in the Materials Storage Building, were separated into soil and debris. The approximately 400 cubic yards of debris (battery casing chips, etc.) were disposed of at a hazardous waste landfill. The remaining soil in the waste pile was freated to render it non-hazardous and disposed of at an offsite landfill.

The Site was proposed to the NPL in September 2002. On April 30, 2003 the Site was listed on the NPL.

Site Contamination Surface soil contamination is generally confined to the former operations area (approx. 24 acres) but contamination above human health remedial goals is present in the southwest and western areas, along the access road leading to SR71, in the drainage

ditches along SR71 and in the wetland west of SR71. Lead, antimony, and arsenic are the most significant soil contaminants. Groundwater contamination above MCL, mainly lead and cadmium has spread beyond the north property boundary. The contaminants identified are hazardous substances as defined in ? 101(14) of CERCLA, 42, U.S.C. ? 9601(14), and 40 C.F.R. ? 302.4.

IV. Selected Remedy

The public comment period for the Proposed Cleanup Plan began on August 10, 2006 and ended on September 10, 2006. The public meeting to present the proposed remedy to the community was held on August 15, 2006. The Record of Decision (ROD) for the Site was signed September 28, 2006.

The selected remedy in the ROD included: ? Decontamination and demolition ofthe Battery Plant and Materials Storage buildings including the concrete slabs and other site structures and buildings as necessary ? Recycling of metal debris ? Excavation and stockpiling of contaminated soil and sediments exceeding Remediation Goals ? Ex-situ treatment for stabilization and solidification of contaminated soil and sediments to form a monolith meeting the performance criteria identified in the ROD ? Additional excavation needed to create a site wide disposal area ? Backfilling with clean soil into areas outside the existing fence line where contaminated soil and sediment were removed ? Compaction and disposal of waste (treated soil/sediment and possibly concrete building debris); assuming a 20 percent increase in treated soil/sediment volume due to expansion and stabilization/solidification treatment, into the onsite disposal cell ? Installation of a geosjmthetic clay liner over the treated material monolith in the disposal cell ? Installation of a 1.5-foot clean soil cover over the disposal cell

? Installation of a 6-inch topsoil cover and grass seeding over the disposal cell and soil/sediment excavation area ? Restoration of the remediated wetlands ? Institutional controls such as a restrictive covenant that limits onsite land use activities to those consistent with the remedy to protect the long term integrity of the monolith, and engineering controls to limit access such as 2 feet of uncontaminated soil over the freated soil and fencing. Institutional controls will also restrict the installation of irrigation or potable wells in the area ofthe contaminant plume without the notification and approval of EPA and FDEP ? Implementation of monitored natural attenuation of groundwater contamination or other groundwater monitoring system until the groundwater Remedial Goals are met. In situ treatment of contaminated groundwater may be implemented if 1) groundwater contaminants do not decline to concentrations below Florida's natural attenuation default criteria in a reasonable time following completion ofthe soil remedy; 2) groundwater contamination is determined to be migrating beyond the present know extent of the plume; or 3) the contaminant plume is not attenuating at an acceptable rate of decline or has reached asymptopic levels.

V. Description of Significant

Differences and Basis for the ESD

An ESD is necessary in order: (I) to provide an explanation of an exceedence in the amount of antimony allowed in the SPLP leachate from stabilized/solidified contaminated soil as specified in the ROD. Treatability studies have indicated that antimony may exceed the SPLP performance standard (.006 mg/1) in the ROD for the stabilized/contaminated soil. It was determined that to continue trying to find a soil stabilization formulation to lower the antimony leachate was technically unfeasible and would compromise the formulation's ability to achieve all other stabilization specifications. This change will not result in a change to the groundwater performance standards for antimony as required by the selected

remedy. The added protection ofthe placement of the stabilized/solidified soil above the water table and capping ofthe stabilized/solidified soil with a geosythetic clay liner (GCL) will compensate for the change ofthe antinomy SPLP performance standard because water will typically not come in contact with the stabilized soil. (2) to clarify that the application ofthe 36 mg/kg lead concentration for ecological sediment remediation is an average concentration for sediment rather than a not-to-exceed value. This clarification remains protective ofthe ecological receptors. The 36 mg/kg remedial goal for lead ecological-based sediment remediation was taken from the State of Florida's guidance entitled Development and Evaluation of Numerical Sediment Quality Assessment Guidelines for Florida Inland Waters. According to the guidance, the remediation goal is the most conservative Treshold Effect Concentration (TEC) for lead. In accordance with that guidance, the TEC is applied as an average concentration in the sediments.

five years after the initiation of the remedial action to ensure that the remedy is, or will be, protective of human health and the environment.

VIII. Public Participation

The public participation requirements set out in the NCP ? 300.435(c)(2) have been met by publishing this ESD, making it available to the public in the Administrative Record, and publishing a notice summarizing the ESD in a major local newspaper.

IX. Authorizing Signature

I have determined that the remedy for the Site, as modified by this ESD, is protective of human health and the environment, and will remain so provided that the actions presented in this report are implemented as described above.

This ESD documents the significant changes related to the remedy at the Site. U.S. EPA selected these changes after consultation with the FDEP.

VI. Support Agency Comments

U.S. Environmental Protection Agency

EPA consulted with the FDEP and provided it the opportunity to comment on this ESD in accordance with NCP ? 300.435 (c)(2) and ? 300.435 (c)(2)(i) and CERCLA ? 121(f).

VII. statutory Determinations

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