The American Creosote Works Superfund site is an 18 acre inactive wood–treating facility in Sanders Beach located about a quarter-mile north of the confluence of Bayou Chico and Pensacola Bay.
The plant operated from 1902 until 1981, when the company filed for bankruptcy. Before 1950, creosote was the primary wood preservative chemical, and after 1950 pentachlorophenol (PCP) became the preferred chemical. Operators sent process wastewater to four holding ponds located in the western portion of the site. The ponds overflowed after heavy rains. Prior to 1970, wastewater in these ponds overflowed through a spillway into local streets and storm drains and Bayou Chico and Pensacola Bay. In later years, the company collected and spread liquid wastes on the ground in designated “Spillage Areas” on site. Additional discharges occurred when heavy rainfall flooded the ponds, which then overflowed their dikes.
EPA DESIGNATES THE ACW AS A SUPERFUND SITE
EPA placed the site on the Superfund program’s National Priorities List (NPL) in 1983 because of contaminated soil and groundwater resulting from facility operations. EPA and the Florida Department of Environmental Protection (FDEP) have investigated site conditions and taken steps to clean up the site to protect people and the environment from contamination. Site contamination does not currently threaten people living and working near the site. Both residents and businesses use the public water system for drinking water; private wells are used for irrigation purposes only. By undertaking Five-Year Reviews (FYR), EPA and FDEP continue to protect people and the environment from site contamination.
The site is in a predominantly residential area, with commercial properties along the northern boundary. Major contaminants in the soil, sediment, and groundwater are volatile organic compounds (VOCs), polycyclic aromatic hydrocarbons (PAHs), PCP, and dioxins and dioxin-like compounds from the former wood-treating processes.
WHAT HAS BEEN DONE TO CLEAN UP THE SITE (SO FAR)
In 1985, EPA issued the cleanup plan (ROD) for the site. However, the Florida Department of Environmental Regulation (FDER, now FDEP) and the EPA were unable to reach agreement regarding the selected cleanup plan and did not implement it.
In 1989, after more site investigations, the EPA issued a second cleanup plan for OU-1. EPA amended the ROD in 1999. The plan included:
- Demolishing, decontaminating and disposing of process area foundations and debris in an off-site landfill;
- Digging up contaminated surface and subsurface soil in residential areas and the Pensacola Yacht Club (PYC) exceeding EPA cleanup goals and consolidating these materials on site;
- Capping consolidated materials and contaminated areas of the site;
- Installing drainage channels, a stormwater retention pond and other drainage improvements;
- Repairing or replacing existing security fencing;
- Periodic sampling of sediment in the PYC drainage ditch;
- Regular mowing and maintenance of the surface cap; and
- Institutional controls to protect the cap and make sure future site uses are compatible with the site’s cleanup approach.
Site contaminants affected the Southeast Ditch, which borders Pine Street, Cypress Street, F Street and a residential driveway. EPA dug up the Southeast Ditch in January 2010 and placed all dug-up soil on site. EPA filled the dug-up area with clean soil and the area was seeded.
In 1994, EPA issued a two-phase cleanup plan for OU-2. Phase 1 includes:
- Enhancing dense non-aqueous phase liquid (DNAPL) collection;
- DNAPL/groundwater separation and groundwater treatment;
- DNAPL transported off site and recycled;
- Injection of treated groundwater back into the ground;
- Periodic groundwater monitoring to evaluate the efficiency of DNAPL collection; and
- Implementation of state-imposed well permit restrictions.
Based on periodic groundwater monitoring data, the EPA will determine whether to continue enhanced DNAPL collection or implement Phase II, which includes:
- Removing and treating contaminated groundwater on site;
- Adding nutrients and hydrogen peroxide to the treated water;
- Injecting the treated and enhanced groundwater into the contaminated portion of the aquifer to stimulate biological treatment;
- De-watering waste sludge from the treatment process and disposing the sludge to an off-site RCRA landfill; and
- Monitoring groundwater and surface water periodically to evaluate the performance of the treatment system.
The Sitewide Record of Decision (ROD) was signed in September 2017. This ROD includes remedies to encapsulate the main source area of creosote with a barrier wall and remove other areas of creosote with thermal extraction. It also includes excavation of all dioxin impacted soil within the exposure units and have it capped onsite.
Some offsite parcels have already been cleaned up and approximately 200,000 gallons of creosote have been removed to date. A Remedial Design (RD) is scheduled to be finished by December 2019. The remedial action (RA) is scheduled to be completed in 2022. The first scheduled action is to clean up residential properties.
Site investigations and cleanup activities have focused on three areas, which EPA refers to as operable units, or OUs. These areas include OU-1: surface and below-ground soil and sediment; OU-2: groundwater; and OU-3: off-site dioxin-impacted soil.
- EPA performed several Five-Year Reviews at the Site in 1995, 2000, 2004, 2011 and 2016.
- The OU-1 cleanup is not yet complete. EPA has undertaken interim cleanup activities at the site. In 2003, EPA moved contaminated soils from surrounding residential areas onto the site and covered the soil with a temporary cap. However, EPA has not installed a final, permanent sitewide cap.
- For OU-2, Phase I of the two-phase DNAPL removal system has been installed. The Mobile District of the U.S. Army Corps of Engineers currently operates the DNAPL system. EPA also installed groundwater monitoring wells at 10 locations in 2007 to begin monitoring and preparation for Phase II cleanup activities. Deeper extraction wells installed in 2009 increased the rate of DNAPL recovery to about double the previous rate. The system has recovered over 185,000 gallons of creosote to date.
- EPA created OU-3 in 2006, based on new risk-based FDEP regulations for dioxin. OU-3 includes all off-site dioxin contamination. The Agency issued a focused Feasibility Study (FS) in July 2010. EPA is incorporating FDEP’s input on the study into the final Focused FS Report. EPA is using the information to complete the sitewide Proposed Plan and ROD for all three OUs. A sitewide ROD was signed in September 2017. This ROD included remedies for all three OUs. The remedy would include a barrier wall around the dense non-aqueous phase liquid (DNAPL) source area, offsite DNAPL treatment, removal of off-facility residential soil and stabilization of the on-facility soil.
- An institutional control, preventing the drilling of any wells on or near the site, is in place and fencing around the facility prevents access to contaminated soil.
ACTIVITY AND USE RESTRICTIONS (CURRENT AND FUTURE)
At this site, activity and use limitations that EPA calls institutional controls are in place. Institutional controls play an important role in site remedies because they reduce exposure to contamination by limiting land or resource use. They also guide human behavior. For instance, zoning restrictions prevent land uses – such as residential uses – that are not consistent with the level of cleanup.
EPA holds regular public meetings to keep the public informed of the status of cleanup. Once the cleanup has been completed, the site has institutional controls in place to prevent the disturbance of the capped soil. The City of Pensacola is looking into turning the site into a park after the cleanup is complete.