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Callaway Drum Recycling (CDR) facility operations began at the Auburndale Site around 1971 and continued until 1977, when the operation was moved 50 miles west to a new facility located in Lake Alfred, Florida. The Auburndale property was abandoned and has remained unoccupied since 1977. After the new Lake Alfred facility was discovered and listed on the National Priorities List (NPL) in 2000, the old Auburndale facility location was brought to the attention of the U.S. Environmental Protection Agency (EPA) and Florida Department of Environmental Protection (FDEP) as a potential source of contamination. Very little historical and operational history was available for the Auburndale facility.
As part of the systematic planning strategy for this Site, FDEP combined the Preliminary Assessment (PA) and Site Investigation (SI) phases. Systematic planning also relied on information from the Lake Alfred facility that had been investigated previously. The FDEP contractor conducted interviews and site walkovers with former CDR employees, reviewed historical aerial photos, and studied the operational and contaminant data from the newer Lake Alfred facility.
FDEP then used a dynamic work strategy (DWS) to conduct an expedited, high-resolution site characterization (HRSC) at CDR Auburndale in the Fall of 2001. This DWS is summarized in the PA/SI Report. The DWS combined on-site data generation with on-site decision making in a flexible approach using low-cost field-based techniques. Total Vapor Analyzer (TVA) and colorimetric test kit analysis in conjunction with direct push soil and groundwater sampling provided the in-field data that were used to identify and quantitate potential contaminants in shorter time frames and at less cost than those needed for sample analysis by offsite fixed laboratories.
Fixed laboratory analysis was limited to 12 biased-hot sampling locations. These samples were selected to represent the most contaminated areas of the Site. A high-density data set (106) of low-cost, field-analysis sampling points were used to increase the sampling coverage of the Site, locate and confirm the hot-spots or source areas, and focus the more costly, definitive, fixed lab-based analysis on the most appropriate areas of the Site.
| Site Name | Callaway Drum Recycling (CDR) Site |
| Location | Auburndale, FL |
| Site Type |
Drum Recycling/Reconditioning |
| Site Regulatory ID |
FLN000407303 |
| Project Lead Organization | Florida Department of Environmental Protection (FDEP), in cooperation with U.S. Environmental Protection Agency (EPA) Region 4 |
| Project Lead Type |
State Lead |
| Regulatory Lead Program |
Superfund Remedial |
| Triad Project Status | Field Program Completed |
| Reuse Objective Identified |
Yes |
| Proposed Reuse: |
Residential, Industrial |
The Auburndale CDR Site is a 10.66 acre, vacant property located on County Road 655 in Auburndale, Polk County, Florida. Located in a rural residential area, the Site has no permanent structures and is densely vegetated. Available information suggested that CDR operated on the property from some time prior to 1971 until approximately 1977. A large excavated area composed of a series of ditches and berms running north-south was located in the northwest section of the Site. For the PA/SI, this area was called Area A. The remains of many drums were observed in Area A during the site reconnaissance and PA/SI field investigation. A similar excavated area with drum remains (called Area B) was observed in the southwest section of the Site. Two large trenches that trend east to west were located in the southeast section of the Site, and a less densely vegetated area was also located in the eastern half of the Site. A former employee indicated that the main drum reconditioning operations were conducted in this area. Remnants of many drums and possible reconditioning equipment were observed in the vicinity of the former reconditioning area. For investigation purposes during the PA/SI, the trenches and drum reconditioning area were grouped together as Area C.
The field-based analysis and decision approach allowed high-resolution delineation of the potential hot spot areas in a cost effective manner, as follows:
After the PA/SI additional assessment and remedial activities were initiated by the property owner's contractor under the FDEP consent order. The extent of the soil and groundwater source areas identified during the PA/SI was further delineated, and remediation is currently underway.
Initial site characterization data were required on a timely basis by the FDEP to complete a CERCLA Hazard Ranking System (HRS) evaluation of the Site. PA and SI phases were combined to save time and reduce costs. The purpose of the PA/SI was to determine contaminant-release history, identify migration pathways, and acquire the soil and groundwater data necessary to define the nature and magnitude of site contamination in support of the HRS scoring. The HRS score for the Site was sufficient to warrant further action under CERCLA. Based on the data collected during the PA/SI, the property owner is currently under a consent order with FDEP for further remedial work at the Site.
The soil assessment objectives within the PA/SI included:
Groundwater assessment objectives included:
The Triad-based, high-resolution approach used at the Site resulted in significant cost savings for the soil and groundwater sampling. A level of increased certainty was achieved in targeting hot spot areas that minimized the number of samples shipped for off-site analysis and ensured the utility of the off-site laboratory data for HRS scoring.
The PA/SI and the resulting report saved the FDEP significant amounts of time and money by providing them with the data they needed to negotiate a Consent Order with the property owner. As a result, the FDEP minimized the resources they needed to invest in the Site and remediation activities have begun much sooner than would have otherwise occurred.
Although no quantitative estimates of cost or time savings have been developed by the project team, there is general concurrence among the stakeholders that the Triad produced a cheaper, faster, and better PA/SI than the conventional approach could have produced. Unlike many PA/Sis, the project was performed in a single mobilization, with a significant reduction in analytical cost due to the small number of samples shipped to the fixed laboratory for off-site analysis.
PA/SI work-plan development involved systematic planning to build a CSM. Although very little information was available regarding the Auburndale CDR facility, the known operational details of the newer facility at Lake Alfred (listed on the NPL in May 2000) provided critical clues that were used to address operational history data gaps and identify likely contaminants at the Auburndale Facility. The preliminary CSM also incorporated information gleaned from former-employee interviews, site walkovers, and historical aerial-photo reviews. A pathways analysis indicated that groundwater, surface soil, and subsurface soil were of potential concern. The preliminary CSM was used to develop a streamlined, cost-efficient, field-based decision approach that focused on specific classes of contaminant compounds and tailored specific real-time measurement technologies. The TVA and Color-Tec test kit methods were identified as collaborative field-based technologies that could be used in combination (for greater data defensibility) to delineate the anticipated contaminants.
EPA Region 4
Florida Department of Environmental Protection (FDEP)
Ecology and Environment, Inc. (E & E), a FDEP contractor. The multidisciplinary team provided by E & E included:
Direct-push profiling techniques, combined with real-time measurement technologies, allowed for a larger number of proposed samples to increase data density for the Site and to locate source areas. Although the number of laboratory-based samples was fixed, the number of samples for field-based analysis was flexible.
The initial target sampling frequency proposed in the Work Plan was approximately 30 to 40 sampling locations for all three areas of the Site combined. Soil was collected from each location at 2 foot vertical intervals. Groundwater was collected at 5 foot vertical intervals. On this basis, the Work Plan allowed for up to 440 samples to be collected for field-based analysis. Through refinement of the sampling approach in the field, however, the project team found that only 106 samples were needed to locate and determine the nature of the source areas.
Because this investigation was a PA/SI, the principal decision made in the field was where to collect samples for laboratory analysis that would be used for HRS scoring. Sampling locations were selected by the field team judgmentally based on visual observations of potential source areas and on previous real-time data points. Where the field methods indicated potential sources or hot spots, samples were generally collected for off-site laboratory analysis to provide accurate "worst case" data for site scoring. More information on field based decision-making for the investigation is summarized in the Field Based Decision Approach presentation.
Direct-push technology was used for all sampling. Continuous core soil samples (surface to water table) were collected, with "grab" groundwater samples collected at and below the water table. Permanent monitoring wells (small diameter, pre-packed screens) were also installed based on the field data.
The field-based analyses methods included a TVA for headspace testing for soil samples that was equipped with both a flame ionization detector (FID) and a photoionization detector (PID). In addition, Color-Tec test kit analysis was performed on all soil and groundwater samples. This method combination was selected for use at the Site because a variety of chlorinated solvents and petroleum compounds were present at the CDR Lake Alfred facility. Since FID/PID does not distinguish between these compound classes, a field-based method specific to chlorinated solvents was required to increase the decision-making power of the field data set. Color-Tec was selected because it detects only chlorinated alkenes/alkanes, it has a very low per-sample cost ($8), and it does not require additional field personnel or intensive training to operate.
The Foxboro TVA-1000 is available through field equipment vendors:
Color-Tec test kits are available from the following vendor:
TQRS not prepared
For the Color-Tec method, field quality assurance/quality control (QA/QC) consists of the following:
Additional information on QC protocols for the Color-Tec is available in the Standard Operating Procedures (SOP). QC for the TVA-1000 consisted only of routine calibration requirements in accordance with vendor recommendations.
The fixed-base laboratory data confirmed the field-based analytical results. Since there were only 12 samples analyzed by both the Color-Tec method and Laboratory methods, detailed statistical analysis of the comparison data was not performed. Such analyses also were not required, because the HRS scoring process depends on conservative values (such as maximum concentrations) from a data set rather than statistical parameters.
The PA/SI was conducted October 1 through October 6, 2001.
904-488-3935
Joseph.McGarrity@dep.state.fl.us 850-574-1400 pkelso@ene.comTo update this profile, contact Cheryl T. Johnson at Johnson.Cheryl@epa.gov or (703) 603-9045.
