1. U.S. ENVIRONMENTAL PROTECTION AGENCY
PROPOSED PLAN FOLLOW-UP
PREFERRED REMEDY FACT SHEET
September 2010
Cabot Carbon/Koppers Superfund Site Gainesville, Alachua County, Florida
Introduction
This fact sheet, issued by the U.S. Availability Session
Environmental Protection Agency (EPA) Date: October 6, 2010
provides clarification and additional information Time: 6:00 PM to 9:00 PM
about the preferred remedy in the Proposed Plan
for the Cabot Carbon/Koppers Superfund Site Location: Eastside Community Center
(Site), Gainesville, Alachua County, Florida. 2841 East University Avenue
EPA presented the preferred remedy for the Site Gainesville, Florida 32601
during a public meeting held on August 5th,
2010. The EPA determined that it should The community is invited to a public availability
provide more details and clarification of the session regarding the Cabot Carbon/Koppers Site.
preferred remedy in response to questions and Representatives from EPA, the Florida Department
concerns voiced by the community during that of Health (FDOH), and the Alachua County
meeting. A separate fact sheet for off-Site soil Environmental Protection Department (ACEPD)
cleanup activities is being prepared. will be available to provide information and answer
questions about upcoming activities at the Site.
This fact sheet provides a brief Site summary,
addresses specific components of the preferred The Administrative Record file for the
Cabot Carbon/Koppers Site is available at the
remedy, and discusses community concerns following location:
relating to remedial activities. Off-site soil
cleanup concerns are addressed in a separate fact Alachua County Library
sheet 401 E. University Ave.
Gainesville, FL 32601
(352) 334-3900
Site Summary www.aclib.us/locations/headquarters
The Cabot Carbon/Koppers Superfund Site is
located in a commercial and residential area of
the northern part of the Gainesville city limits,
Alachua County, Florida. This Site was continue to collect sampling data for
originally two Sites: Cabot Carbon in the groundwater, soil, sediment, and surface water to
southeast portion of the Site, and Koppers on the
evaluate the effectiveness of the remedy over
western portion of the Site (Figure 1). Cabot
time.
Carbon was a pine tar and charcoal generation
facility, but is now commercial property.
From this point forward, the word “Site” will
Koppers was an active wood-treating facility
refer to the Koppers portion of the Cabot
until December 2009. Although remedial
Carbon/Koppers Superfund Site, unless
investigations at the Cabot Carbon/Koppers Site
otherwise specified. The Site remedial action
began in 1983 and are now completed, EPA will
will also address off-Site areas contaminated
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3. by Site-related activities, including residential site soil cleanup concerns are addressed in a
and industrial areas surrounding the Site and separate fact sheet.
Hogtown and Springstead creeks to the north and
west of the Site. Site contamination is a result Preferred Remedy Community
of releases of wood-treatment chemicals. Four Concerns
potential source areas have been identified at the
Site (Figure 2). Site contaminants are associated On-site Soil and Groundwater Cleanup
with the historical use of creosote for wood The public has expressed concern about the
treating and include mobile and/or residual dense proposed on-site remedy. EPA is aware of the
non-aqueous phase liquids (DNAPLs). DNAPLs public’s concerns and in an effort to provide
are organic substances that do not mix with and additional information has prepared the
are heavier than water. Site contaminants also following specific responses to community
include arsenic, polycyclic aromatic questions.
hydrocarbons (PAHs), and dioxins/furans in soil
sediment and groundwater. The most Why not dig up all DNAPL-impacted soil?
predominant contaminant in groundwater is Excavation of source area soils containing
PAHs. The Feasibility Study (FS) and Proposed DNAPL was evaluated in comparison with other
Plan provide for additional details. options during the FS process. The preferred on-
site remedy, summarized on Table 1, was
Preferred Remedy Description determined to be the optimal alternative based on
The selected alternative is the result of years of key criteria including remedy protectiveness.
collaborative effort and thorough review on the
part of many organizations, including input from Specific challenges associated with soil
local agencies and the public. The alternative is excavation at the Site are:
robust and protective of human health and the
environment. Remedy selection is the final step 1. Excavation depths and large soil volume
in the Superfund process before cleanup design The two source area excavation alternatives
and action. considered during the remedy selection process
(removal of soil within the Surficial Aquifer or
The preferred remedy will protect human health removal of soil to the Hawthorn Group middle
and the environment by containing, treating, and clay unit) would present significant challenges
controlling contamination associated with the due to the excavation depths and the large
Site. This remedy was selected over other amounts of soil that would be removed. The
options evaluated because as a whole it was Surficial Aquifer soil removal would require
determined to provide the optimal solution based digging to an approximate depth of 25 feet
on Comprehensive Environmental Response, below ground and removing approximately
Compensation and Liability Act (CERCLA) FS 280,000 cubic yards (420,000 tons) of soil. The
evaluation criteria. The selected remedy is Hawthorn Group middle clay soil is deeper and
compatible with the anticipated future use of the removal would require digging to an
property, as described in more detail below. approximate depth of 65 feet below ground and
removing approximately 1,800,000 cubic yards
The selected remedy has three parts that address (2,700,000 tons) of soil. Excavating soil to these
three distinct media groups: on-site media (soil depths would require shoring to keep the
and groundwater above the Upper Floridan
Aquifer [UFA]), groundwater in the UFA, and
off-Site media (soil, sediment, and surface
water). The major components of the three parts
of the remedy are summarized on Table 1 of this
fact sheet. Additional details on the preferred
remedy components are presented below. Off-
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5. Table 1: Preferred Remedial Alternative Summary
On-site Media UFA Groundwater
 Establishment of an on-site soil consolidation area that includes:  Hydraulic containment of contaminated groundwater through extraction
o A single, continuous vertical barrier wall (approximately 65 feet deep) and treatment in areas where chemicals of concern (COCs) exceed
encircling all four source areas from land-surface to the Hawthorn cleanup goals.
Group middle clay.  Construction of additional extraction wells for the network, as necessary.
o Establishment of a low-permeability cap/cover over the consolidation  Monitored natural attenuation (MNA) in areas where concentrations of
area to protect against rain infiltration and contamination migration. COCs do not exceed cleanup goals (subject to demonstration of active
 In place (in-situ) solidification and stabilization (ISS/S) of contamination natural attenuation processes).
in the upper Hawthorn Group zone at all four source areas.
 In-situ biogeochemical stabilization (ISBS) of DNAPL in the vadose-zone Off-Site Media
(the unsaturated zone above the water table) and in the Surficial Aquifer For soil contamination, a range of options are proposed for use on individual
(less than 25 feet below ground surface) at all four source areas through subparcels with the consent of private property owners including:
injection of oxidizing and stabilizing chemicals into the ground surface.  Excavation and removal of impacted soil that exceeds cleanup goals based
This treatment is subject to acceptable performance demonstration during on present use of the land. Excavated soil will be transported and placed
pilot tests or treatability studies). Pilot tests/treatability studies are tests within consolidation area on-site.
conducted with contaminated Site materials and stabilizers to determine if  Engineered controls that prevent contact with impacted soil containing
cleanup goals will be met. contamination that exceeds cleanup goals based on present use of the land
 In-situ injection of oxidizing chemicals or ISBS treatment in the Lower use.
Hawthorn Group at all four source areas, and along the eastern property  Institutional controls to protect accessibility and use of land/properties.
boundary.
 Excavation of soil posing a leachability concern outside of the For surface water and sediment in Hogtown and Springstead Creeks, proposed
consolidation area; placement of excavated soil in soil consolidation area. remedies include:
 Surface grading and cap covers on approximately 83 of 86 acres on the  On-site detention basin to mitigate on-going impacts to surface water
Site property. and sediment.
 Installation of storm water controls and improvements (e.g., retention/  Excavation and removal of impacted sediment in excess of levels
detention pond). shown to likely cause an adverse effect when in direct contact
 Continued operation of the northern perimeter wells of the Surficial (probable effects concentration). Excavated soil will be placed in the
Aquifer extraction and treatment system (outside of the consolidation consolidation area on-site.
area) until cleanup goals are attained.  Monitored natural recovery of remaining impacted sediment until
 Continued operation of the horizontal collection drains of the Surficial concentrations reach threshold effects concentrations (contaminant
Aquifer extraction and treatment system as needed to contain potential concentrations above these levels could adversely effect a plant or
migration of ground water contamination (hydraulic control). animal) or background levels.
 Expansion of the Surficial Aquifer and Hawthorn Group monitoring
network.
 Institutional controls such as deed restrictions to prevent future digging
that would result in contact with contaminated media.
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6. excavation walls from falling in on workers, and 4. On-site construction of above ground
dewatering to remove groundwater that would landfill challenges
flow into the excavation area during excavation. If the excavated soil is placed in an on-site
constructed landfill instead of being returned to
Groundwater collected from the excavation area the excavation or transported off-Site, the
would require treatment and disposal. resulting mound would be much larger than the
Construction of a staging/temporary storage mound considered for the gently sloped
area may be required. Excavated soil would consolidation area. This would have serious
require management as listed hazardous waste. technical and permitting challenges, would limit
All of these challenges, in turn, result in short- redevelopment opportunities, and would not be
term health and safety risks to remedial workers a welcome sight for the community.
and the nearby community and significant
additional costs to the remedial effort. 5. Risk reduction not significantly different
with excavation
2. Off-Site disposal challenges Actual long-term human health and
Finding one or more disposal facilities that will environmental risk reduction resulting from
accept the large quantities of contaminated soil source area excavation would not be
would present a challenge. Land Disposal significantly different than in-situ treatment.
Restriction (LDR) and Best Demonstrated Short-term risks would be significantly higher
Available Technology (BDAT) rules for soil excavation. Soil removal will not
establishing treatment standards for land significantly reduce groundwater concentrations
disposal may require that contaminated soils at potential receptors, including the Murphree
from the Site be sent to one of the few Well Field. A long-term groundwater remedy
hazardous waste incinerators that accept wood- would still be required. There is also a risk that
treatment listed waste. It may also be necessary residual DNAPL will move through the
to treat soils on-site prior to off-Site disposal. groundwater during excavation activities.
Transporting the contaminated soils to an off-
Site facility would require either about 15,000 Why consolidate excavated soils on-
(Surficial Aquifer excavation) or 95,000 site?
(Hawthorn Group middle clay excavation) truck Because of the issues described above,
loads. More than 100 dump truck loads per day containing soils on-site is the optimal solution
of contaminated soil could be driven through the for the community’s needs. The soil
areas surrounding the Site resulting in consolidation area will be designed to contain
significant transport-related safety and the soil contamination and prevent human
environmental risks, as well as a significant contact and migration in groundwater off-Site.
nuisance to the surrounding areas for over 2.5 The soil consolidation area is conceptually
years. shown on Figure 2 and Figure 3.
The most contaminated soil (principal threat
3. On-site treatment challenges waste [PTW]) will be treated within the
If the material is treated on-site (by any method) consolidation area. There will be a gentle slope
and returned to the excavation, the risk on the containment area to prevent surface water
reduction and volume treated is very similar to from accumulating. Other storm water
the in-situ treatment options, but with management controls such as rerouting and
substantially greater short-term risk, engineering detention basins will be used to reduce the
challenges, effort, time, and cost. likelihood of surface water contact with
potentially contaminated soil.
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8. Is the soil consolidation area in violation ground). Because the Hawthorn Group middle
of Florida laws? clay layer does not readily transmit water due to
The soil consolidation area being created on-site its low permeability and the surface cover/cap
at the Koppers property is not considered a minimizes water from entering below the
landfill that is has to meet land disposal surface, the vertical barrier wall creates a
restrictions (LDRs). The soil will be subsurface containment area designed to
consolidated within an Area of Contamination completely surround the contaminated soil and
(AOC). The National Contingency Plan (NCP) groundwater in the surficial aquifer and Upper
policy (55 FR 8758-8760) allows EPA to Hawthorn sediments.
designate an AOC as an existing area of
continuous contamination of varying amounts 2. Low permeability Hawthorn middle clay
and types. LDRs will not apply if material is The Hawthorn Group middle clay unit transmits
moved within an AOC, treated in place, or very little groundwater as evidenced by pressure
consolidated within an AOC. Establishment of measurements above and below this clay unit.
an AOC facilitates remediation of contaminated Working together, the vertical barrier wall and
sites. the middle clay layer will limit downward
movement of contamination.
How will groundwater be protected?
Given that digging up all the soil in source areas 3. Low permeability surface cover/cap
is impracticable and ineffective as detailed The consolidation area will be covered with a
above, containment of source area materials is low-permeability cap/cover that is a minimum
required for protection of groundwater. Source of two feet thick and is constructed of clean
area materials within the on-site soil material. This cover/cap will be gently sloped
consolidation area will be contained (Figure 3). to promote storm water runoff and prevent
PTW within the area will be treated by in-situ pooling. The intent of the cap will be to prevent
methods and a robust containment system will surface exposure to contaminated soil and limit
be put in place to prevent migration away from rainfall from entering the subsurface within the
the area. This strategy has been used consolidation area.
successfully at many other Superfund Sites. At
the Koppers Site, the contaminants will be 4. In-Situ Treatment
contained by the following methods: In-situ treatment of contaminated soil and
groundwater within the consolidation area
1. Continuous vertical barrier wall above the Hawthorn Group middle clay will
The entire consolidation area will be surrounded reduce volume and toxicity of contaminated
by a continuous vertical subsurface barrier wall media and the potential for contaminant
constructed of a cement/bentonite slurry (Figure migration.
3). Slurry walls often are used in environmental
remediation where contaminants that move 5. Groundwater monitoring
through groundwater may pose a potential threat The EPA will monitor the groundwater in and
to a source of drinking water. They have been around the soil consolidation area. Although it
used for decades as long-term solutions for is unlikely, if increasing contamination
controlling seepage. Slurry walls are typically concentrations are observed outside of the
constructed of a soil, bentonite (clay), and water containment area, additional remedial actions
mixture. However, a cement/bentonite (such as may be evaluated for implementation.
proposed at the Koppers Site) or other mixture
may be used for greater structural strength and 6. Groundwater pump and treat system
to reduce degradation due to chemical Groundwater pump and treat systems will be
interactions. The barrier wall will be joined to operated in the Surficial Aquifer and the UFA to
the top of the low permeability Hawthorn Group prevent contaminated on-site groundwater from
middle clay unit (approximately 65 feet below moving off-Site.

9. 7. Soils removal What institutional controls will be
Soils outside the containment area with applied at the Site?
concentrations high enough to pose a Institutional controls will be applied at the Site
concern due to leaching to groundwater will to prevent exposure to subsurface soil and
be removed and placed within the groundwater contamination. The institutional
containment/consolidation area. During the controls are controlled by local authorities and
remedial design additional leachability studies will become part of the property deed. They
will be done to assess areas for soil removal. will prevent digging without formal plans to
mitigate exposure to contaminants (via permits,
How will cleanup goals be met for soil etc.).
outside of the soil consolidation area?
The green area on Figure 2 outside of the Will in-situ stabilization be effective?
consolidation area that will be regarded and a In-situ stabilization/solidification (ISS) is
clean soil cover of at least two feet thick will be proposed to treat source area contamination in
placed over almost the entire property. The the upper Hawthorn Group. In-situ
process of Site grading which is necessary for biogeochemical stabilization (ISBS) is proposed
Site reuse preparation and stormwater to treat source area residual DNAPL in the
management will result in the excavation of vadose-zone (above the water table) and
impacted surface soil. This soil will be moved Surficial Aquifer. In-situ chemical oxidation or
to the consolidation area (blue area) of Figure 2. ISBS is proposed to treat contamination in the
The clean cover with institutional controls will lower Hawthorn Group at source areas and
prevent contact with soils that may contain a along the eastern property boundary as an
low level of contaminants. additional treatment method for groundwater
migrating off-Site.
Why aren’t residential cleanup goals
selected for on-site soil? EPA has demonstrated the effectiveness of in-
EPA is required to look at reasonably situ stabilization at other wood treatment sites
anticipated future land uses in determining what with soil contaminated by DNAPL and mixed
cleanup criteria to apply at a Superfund Site. wastes. During the remedial design of this
EPA has determined that unrestricted residential remedy, treatability studies will be conducted to
use is not a likely or practical future land use for determine the appropriate type and quantity of
the Site. However, a remedy that in effect in-situ stabilizer that will bind the contaminated
meets Florida residential default cleanup soil and meet requirements for effective
standards has been selected. The remedy calls stabilization. Treatability testing will use
for clean soil to be placed over almost the entire contaminated soils from the site to determine
Site. EPA has made its reasonably anticipated the type and amount of stabilizer needed.
land use determination based on several factors
including property owner Beazer East’s planned A pilot test of ISBS has been conducted at the
retention of Site ownership and its indicated Site.
future use of the Site as commercial,
recreational or mixed use with a residential Off-Site Creek Cleanup
component. Therefore, the EPA has determined Community concerns and details regarding off-
that the reasonably anticipated future land use of Site cleanup of nearby creeks are addressed
the Koppers portion of the Site is likely to be below. Off-site soil cleanup activities are
commercial, recreational or mixed-use with a detailed in a separate fact sheet.
residential component.

10. How are Hogtown and Springstead Koppers Site generated during the remedial
Creeks being addressed? design phase of the project, will be signed and
The selected remedy address citizen concerns sealed by a professional engineer registered in
with the creeks in two distinct ways. First, to the State of Florida. The remedial design of the
address previous contamination of the sediments selected remedy will occur after the Record of
in each creek, sediments that have contaminant Decision (ROD) is signed.
concentrations associated with either former
Cabot Carbon or Koppers that exceed the When will the Community Involvement
threshold effects concentrations (i.e. Plan be updated?
contaminant concentrations in excess of levels EPA developed the Community Involvement
that would adversely effect animal life) are Plan (CIP) to serve as a framework for
required to be excavated and replaced with community involvement and outreach efforts
clean fill material. Assessment of creek associated with the Cabot Carbon/Koppers
sediments is ongoing. To address possible Superfund Site. The CIP addresses the
future impacts on sediments, the former relationship between the Site, the community,
Koppers facility is required to construct and and EPA; provides a background of the
operate a detention/retention pond(s) to capture community; presents EPA’s community
storm water from the former Koppers Site prior involvement program; and provides a listing of
to allowing it to be discharged to the tributary to resources. The goals of the CIP are to inform
Springstead Creek. The detention/retention the public of planned and ongoing site activities;
pond(s) will be designed, including placement, maintain open communication about site
during the remedial design of the on-site remediation; ensure that former concerns are
remedy. acknowledged and addressed; provide interested
parties with useful information; provide citizens
Although future migration of contaminated soils with opportunities to comment on and be
due to storm water flow is highly unlikely due involved in technical decisions; and encourage
to the implementation of Site surface covers and and assist local citizens in providing input to
consolidation of contaminated materials beneath agency decisions that will have long-term
a low-permeability cover/cap, storm water effects on the community. Information
capture will allow potentially contaminated discussed during community interviews is
sediment to settle so that it will not be released essential in developing the CIP. The CIP update
to the creeks. is expected to be complete by late September
2010.
Other Community Concerns
General community concerns not covered in the How will EPA evaluate the cleanup
previous sections of this fact sheet relating to process and what happens if it is
the Koppers remedial action are addressed unsuccessful?
below. EPA will evaluate the progress of the cleanup
through confirmation sampling of soils and
Why was the FS not certified by a sediments once a remedy has been
professional engineer? implemented. Groundwater sampling will
The NCP regulations found at 40 Code of continue after remedy implementation has taken
Federal Regulations (CFR) Part 300, contains place. Groundwater data will be evaluated to
the EPA regulations for implementing ensure that contaminant levels are reduced over
CERCLA, as well as governance on documents time until target cleanup levels are met. Surface
to be submitted to the agency. Per EPA FS water discharges will also be sampled and
guidance, the FS is a conceptual document that analyzed on a quarterly basis to ensure that
supports the design of selected remedies. The permitted levels are met. In addition, EPA is
NCP requires certification of engineering design required to evaluate remedial action
documents; therefore, design documents for the effectiveness once every five years in a Five-

11. Year review to determine if the remedy is EPA provides information to the community
functioning as intended. If the remedy does not regarding Site cleanup through fact sheets,
function as intended, EPA will update the public meetings, local Site information
remedy to include additional measures so that repository, and the Administrative Record file.
the updated remedy is effective. Copies of data and reports generated during Site
investigations for use in the remedy selection
What is being done to ensure no process are located in the Administrative
contamination has been missed at the
Record file. This fact sheet will become part of
Site?
A work plan is being developed for the remedial the Administrative Record file for the cleanup
design phase of the project to identify if there decision for the Cabot Carbon/Koppers
are possible buried drums or other primary Superfund Site. The public may review this file
source areas on the Site. In addition, soil, at the Alachua County Library.
groundwater, and sediment sampling and
analyses will continue as the footprint for EPA will be providing an additional opportunity
installation of all the remedial technologies is for the community to address any remaining
refined. After additional sampling and analyses questions they may have about Site cleanup
occur and the remedial action is implemented, during an availability session that will be held
the proposed on-site actions will ensure from 6:00 PM until 9:00 PM on October 6,
exposure at the surface has been mitigated. 2010, at the Eastside Community Center, 2841
East University Avenue, Gainesville, Florida
How are vapor intrusion possibilities 32601.
being addressed?
The Site groundwater contaminant plume does
not consist of significant concentrations of
highly volatile components such as solvents or
BTEX compounds. The primary concern in Site
groundwater is low concentrations of
naphthalene which are only partially volatile.
Vapor intrusion is unlikely at wood-treatment
sites, and is not anticipated to create a hazard at
the Koppers Site.
What studies are being conducted to
assess Site-related human health
concerns?
Human health risks due to exposure to on-site
contaminants have been assessed. Human
health risk assessments typically look at the
types of activities that may expose people to
Site contaminants. In general, Site media
concentrations are compared to various
riskbenchmarks to determine whether the type
of contaminant at its concentration present a
risk. Contaminants that present a significant
risk are included as Site chemicals of concern
(COCs). COCs were listed in the Proposed
Plan.

12. Availability Session Mailing List
An availability session for the Cabot Carbon/ Anyone wishing to be placed on the mailing list
Koppers Superfund Site will be held from 6:00 for this Site should send his/her request to Ms.
PM until 9:00 PM on October 6, 2010, at the LaTonya Spencer, EPA Community
Eastside Community Center, 2841 East Involvement Coordinator, at the above address.
University Avenue, Gainesville, Florida 32601. You may also call Ms. Spencer with your
request at (800) 435-9234 or (404) 562-8463
Information Repositories
Information concerning the Cabot Carbon/
Koppers Superfund Site may be found at the
following location:
Alachua County Library
401 E. University Ave.
Gainesville, FL 32601
(352) 334-3860
www.aclib.us/locations/headquarters