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Cattle Vat Update - floridadep.gov

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Cattle Dip Vats (CDVs)Update 2018
Update to presentation given by Zoe Kulakowski on February 10, 2016
February 14, 2018Presented by:Christi WhittingtonChristi.Whittington@dep.state.fl.us850.245.8880
Talk Outline
Cattle Vat Dipping ProgramAssessmentFDEP Regulatory FrameworkLand Development IssuesCleanup
1906 Extent of Cattle Tick Fever
Vat Dipping Program
Run by Livestock Sanitary Board (LSB, now FDACS)Federal requirement: 0.18% (1,800,000μg/L) arsenicLSB approved other chemicals in later years
Location Issues
Vat locations not recorded3200+ vats constructed at livestock markets, shipping ports, rail depots, state lines and private propertiesOnly 175+ known vat locationsInconsistent naming“Peach Orchard” or “Sink Hole” or “Log Camp”“Alford” in Leon County owned more than 14,000 acres
Vats destroyedburied, dynamited or removed (without the contaminated soil)Revised County boundaries1920 and 1930 County Lines
Contaminants of Concern
Historic analysesEPA 8260/8270, EPA 8080, As,Pb, Cr, Cd, Fe and CuCattle Dip Vat Report, Woodward-Clyde ConsultantsEmpirical resultsAs, organochlorine pesticides, Fe, aromatics andcPAHsPresent analysesAs and organochlorine pesticidesdrive cleanup with regard to extent and CTLsChapter 62-777 CTLs apply
Initial Phase Sampling Plan
Sample water and sludge in the vat
Entry side
drip pad
Drip pen
10 feet
Assessment Findings
Vat soil/groundwater concentrations reflect steady state conditionsOfficial Vat Dipping Program ended in mid 1960’sIn many cases extent of groundwater impacts coincides with extent of contaminated soilSites with long plumes: Walker Ranch, OkeechobeeSome sediment impactsUse SQAGs for delineation/removalsSediment Quality Assessment GuidelinesContact DOH to sample all private wells located near a vatDEP-Drinking Water program provides alternate water supply if concentrations exceed GCTLs
Examples of Vat Sites
Individual parcels to tracts of land proposed for developmentLake Weeks SubdivisionCitizens with a vat on or next to their propertyPublic ownership of land containing a vat9 Vats Within the Kissimmee River Restoration ProjectVats on State PropertiesCleanup through State Owned Lands Cleanup Program (SOLCP)
Regulatory Framework
State:Enforcement stopped in 1993Ch. 376.306, F.S.CDVCh. 403.161, F.S.Pollution PreventionCh. 1013.365, F.SSchool Restriction
Federal:EPA retains full CERCLA LiabilityRCRA farmers exemption applies as long as no sludge/soils exceed TCLP
Chapter 376.306(2), F.S.
Any private owner of property in this state upon which cattle-dipping vats are located shall not be liable to the state under any state law, or to any other person seeking to enforce state law, for any costs, damages, or penalties associated with the discharge, evaluation, contamination, assessment, or remediation of any substances or derivatives thereof that were used in the vat for the eradication of the cattle fever tick. This provision shall be broadly construed to the benefit of said private owner.
Highlights
DEP does not regulate land developmentLocal government land development regulations generally do not cover contaminated mediaLending institutions want their liability defined
Encourage voluntary cleanup before developmentSeek cooperative solutions to eliminate human exposure and environmental impactsArea of contaminated media cannot be enlarged
DEP and DOH concerned with acute and 1E-06 cancer risks
62-780 Cleanup?

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Cattle Vat Update - floridadep.gov