PB94-964052
EPA/ROD/R04-94/181
September 1994
EPA Superfund
Record of Decision:
BMI-Textron Site,
Lake Park, FL,
8/11/1994
-------
RECORD OF DECISION
FOR THE
' BMI-TEXTRON SITE
THE DECLARATION
SITE NAME AND LOCATION
BMI-Textron Site
Lake Park, Florida
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action
for the Basic Microelectronics, Incorporated (BMI)-Textron Site
(BMI-Textron Site or the Site), in Lake Park, Florida, chosen in
accordance with the Comprehensive Environmental Response
Compensation, and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA),
42 U.S.C. Section 9601 et.seq. and the extent practicable, the
National Oil and Hazardous Substance Pollution Contingency Plan
(NCP). This decision is based on the administrative record for
this Site.
The State of Florida, as represented by the Florida
Department of Environmental Protection (FDEP), has been the
support agency during the Remedial Investigation and Feasibility
Study (RI/FS) process for the Site. In accordance with 40 CFR
300.430, as the support agency, FDEP has provided the
Environmental Protection Agency (EPA) with input. While EPA
expects written concurrence will be forthcoming from FDEP, a
letter formally recommending concurrence of the remedy has not
yet been received.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from
this Site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare,
or the environment.
DESCRIPTION OF THE REMEDY
This remedy addresses the contaminated principal threat of
ground water at the Site. This remedy addresses the principal
threat remaining at the Site, by using existing institutional
controls, and monitoring ground water contaminated with arsenic,
cyanide, sodium and fluoride. Transport modeling indicates that
natural attenuation of on-site ground water contaminants to
drinking water standards should occur within 3 years. The ground
water will be monitored quarterly for one year to verify modelled
-------
decrease of contaminant concentration. During the remaining two
years, EPA would conduct by an annual review of monitoring
frequency. Selected wells within the existing monitor well
network would be used to provide confirmation of historical data
and modeling transport data that indicates the contaminant of
potential concerns (COPCs) will naturally degrade and/or
attenuate with time. However, EPA reserves the right to increase
monitoring frequency should sampling data indicate the necessity.
If after the three years of monitoring, data shows that
Performance Standards are achieved, then the Site will be
considered for deletion from the National Priorities List (NPL) .
Should monitoring indicate that the Site has contaminants at
concentrations greater than Federal and State standards, EPA in
consultation with the State of Florida, will reconsider the
protectiveness of the selected alternative.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. Due to the documented
naturally occurring attenuation of ground water contamination at
the Site, this remedy can be considered as = permanent solution
that satisfies the statutory preference for reduction of the
toxicity, mobility and volume of hazardous substances. Based on
the limited area of the ground water plume; the ground water
contaminants present and their concentrations, relative to
drinking water quality standards; and the fact that the source of
the contamination (the soil) , was removed in 1984 and 1990, EPA
concluded that it was impracticable to treat the ground water
effectively. This remedy does not satisfy the statutory
preference for treatment as a principal element since treatment
would be impracticable in this matter.
This remedy will serve to mitigate the threat to human
health through the natural attenuation of hazardous substances
released from the Site. Because this remedy may result in
hazardous substances remaining on-Site above health-based levels,
a review of the remedial action will be conducted within five
years after the initiation of the remedy to ensure that the
remedy continues to provide adequate protection to human health
and the environment unless drinking water standards are achieved
prior to the five-year period.
EPA has determined that its response at this site is
complete. Ground water monitoring will be conducted to insure
the effectiveness of natural attenuation. Therefore, the site now
qualifies for inclusion on the Construction Completion List.
turn
John H. Hankinson, Jr. Date
Regional Administrator
-------
Record of Decision
Summary of Remedial Alternative Selection
BMI-Textron Site
Lake Park, Florida
Prepared by:
U.S. Environmental Protection Agency
Region IV
Atlanta, Georgia
-------
TABLE OF CONTENTS
Section Page
1. 0 Site Location and Description 1
2 . 0 Site History and Enforcement Activities 1
3.0 History of Community Participation 5
4.0 Scope and Role of Response Action 5
5.0 Summary of Site Characteristics 5
5.1 Regional Hydrogeology 6
5.2 Site Soils and Hydrogeology 8
5.3 Summary of Remedial Investigation Results 8
5.3.1 Soils 9
5.3.2 Ground water 13
5.3.3 Well Inventory 18
5.4 Human Population Survey 18
5.5 Ecological Assessment 21
6.0 Summary of Site Risks 21
6.1 Contaminants of Potential Concern 21
6.2 Exposure Assessment 21
6.2.1 Conceptual Site Model 22
6.2.2 Exposure Point Concentrations 22
6.2.3 Human Intakes . . . 22
6.3 Toxicity Assessment 26
6.4 Risk Characterization 26
6.5 Current and Future Use Site Risk ; 30
6 . 6 Uncertainties :' 30
6.7 Remedial Goals 31
7.0 Description of Alternatives 31
7.1 Alternative 1: No Action 31
7.2 Alternative 2: Institutional Controls and Monitoring 31
7.3 Alternative 3: Institutional Controls, Monitoring,
Ground Water Recovery, On-Site Treatment, and Off-
site Discharge 32
7.4 Alternative 4: Institutional Controls, Monitoring,
Ground Water Recovery, On-Site Treatment, and
Discharge 34
8 . 0 Comparative Analysis of Alternatives 34
8.1 Comparative Analysis of Human Health and the
Environment 35
1. Overall Protection of Human Health and the
Environment 35
2. Compliance with ARARs 36
3. Long-Term Effectiveness and Permanence 36
4. Reduction of Toxicity, Mobility or Volume .... 39
5. Short-Term Effectiveness 39
6. Implementability 39
i-2
-------
TABLE OF CONTENT (continued)
Section Page
'..7. Cost 40
8. State Acceptance. 40
9. Community Acceptance 40
8.2 Synopsis of Comparative Analysis of Alternative ... 40
9.0 Selected Remedy 41
A. Ground Water Remediation 41
A.I Components of Ground Water Remediation for
Implementation 42
A.2 Performance Standards 42
B. Compliance Testing 42
10.0 Statutory Determinations 43
10.1 Protection of Human Health and the Environment ... 43
10 .2 Compliance with ARARs 43
10 .3 Cost-Effectiveness 43
10.4 Use of Permanent Solutions 44
10.5 Preference for Treatment as a Principal Element .. 44
11.0 Documentation of Significant Changes 44
APPENDIX
i-3
-------
FIGURES
Figures Page
Figure 1 2
Figure 2 •; 3
Figure 3 7
Figure 4 14
Figure 5 15
Figure 6 17
Figure 7 19
Figure 8 20
Figure 9 23
i-4
-------
TABLES
Tables
Table 1 :
Table 2 .".
Table 3
Table 4
Table 5
i-5
-------
RECORD OF DECISION
The Decision Summary
BMI-Textron Site
1.0 SITE" LOCATION AND DESCRIPTION
The Basic Microelectronics, Incorporated (BMI)-Textron Site
(the Site) is a 3.4 acre area located within the Tri-City
Industrial Park on Silver Beach Road in Lake Park, Palm Beach
County, Florida. A Site location map is provide as Figure 1.
The Site is comprised of several buildings and paved areas.
Industrial areas surround the Site to the north, east and west.
and a residential area is located south of,the Site across Silver
Beach Road. A Site plan is shown in Figure 2.
Presently, most of the surface-area on the Site is either
paved or covered by buildings. The average rainfall in this
portion of Palm Beach County is 60 inches per year and more than
70 percent of the rain falls between May and October. Storm-
water runoff is directed to shallow swales located along the
streets. Excessive stormwater runoff flows south (toward Silver
Beach Road) then either east or west, further down from the Site.
The nearest known surface-water body is the Barman River situated
about one mile north of the Site.
The nearest residents are located to south (across from
Silver Beach Road) of the Site and there are no known private
drinking-water supply wells within the vicinity. The nearest
known drinking-water production well is Riviera Beach Utility
Supply Well #16 located approximately 3,000 feet (ft) south-
southeast of the BMI Textron Site. A recovery well, screened
between 100 and 125 ft below land surface (bis) to capture a.
release of volatile organic compounds (VOC), is currently
operated at the Trans-Circuit plant situated in an area which
could be considered slightly downgradient and about 3CO ft north-
northwest of the BMI-Textron Site. No other wells are known to
exist in the immediate downgradient area - The nearest known
wells that would be considered downgradient of the BMI Textron
Site are the two Price Funeral Home irrigation wells.
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
BMI began manufacturing operations in Lake Park, Florida in
October 1969. Textron Inc. acquired BMI in January 1981 and
began operating the Site as BMI-Textron. The facility
manufactured chromium-backed glass plates used in the production
of electronic components. The actual process involved cutting,
cleaning, and polishing glass plates prior to chromium
deposition. Liquid waste from the process was disposed of on
Site through a combination of percolation ponds and drainfields.
BMI discharged cyanide containing wastes into Percolation Pond
(PP)-l which was abandoned in August 1984. Permit compliance
sampling required by Florida Department of Environmental
-------
*
o
6
i
o
i
s
SITE LOCATION
i \
-T " I fcgujfo? J^kAfc<<*
t»«- 1 I • »^. » • 3 v v^ • r 3n ; _
r --v-
i \. \(:
A -~i
•ASC MAP «OURC£:U » 6.t 1.4 MINUTE SENIE*
BEACH CMIADRAWOLt.
SOME
OK3KZHZHZKD 2000
FEET
I
FIGURE
LOCATION MAP
FORMFR BMJ-TEXTRON SITE
LAKE PARK. FLORIDA
-------
IOWC DATC: 14SEP93 I PRJCT NO.: Pf045IOJC IFILC NO.: BWI I DRAWING: 45101-SP I CHECKED: D.LEONARD I APPROVED: W.VOCElSONG I DRAFTER: B.OLIVA
MILLER WAY
CD
ce
t'.'.'.\ . f.-.•.•.•.•! f.•.•.•!
REEO RO.
LEGEND
H DOMESTIC WASTE ORAINFtELO LOCATION
|3 PERCOLATION POND LOCATION
3 UNCOVERED AREAS
•- PROPERTY BOUNDARY
O
cc
UJ
2
BRANT RD.
SITE PLAN
FORMER BMI-TEXTRON SITE
LAKE PARK. FLORIDA
FIGURE
-------
Protection (FDEP), formerly Florida of Department Environmental
Regulation (FDER), revealed cyanide contamination of the soil and
ground water at the Site.
BMI-Textron and the FDEP entered into a Consent Agreement to
remove contaminated soils at the Site, in December 1984 .
Pursuant to the agreement, approximately 680 cubic yards of
cyanide contaminated soil were removed to a hazardous waste
facility regulated under Subtitle C of the Resource Conservation
and Recovery Act. The excavated soil was taken from PP-1,
formerly located at the center of the north end of the Site.
Analytical data from samples taken by FDEP in 1986 showed
elevated concentrations of cyanide and fluoride in three on-Site
monitoring wells and in the soil near PP-2 (see Figure 2). On
November 18, 1986, BMI-Textron and FDEP entered into another
Consent Agreement to develop a ground water remediation plan. In
April 1990, as part of the ground water remediation plan and in
compliance with the second Consent Agreement, Textron removed 206
cubic yards of soil. Concentrations of chromium and cyanide were
removed from PP-2.
In June 1988, Federal Register (52 No. 122) of the United
Stupes EPA proposed ^isting the BMI-Textron Site on the National
Priority List (NPL). In August of 1990, BMI-Textron was
finalized on the NPL with a hazardous ranking system (HRS) score
of 37.93. On February 26, 1992, EPA Region IV, under the
authority of Section 104(e) of the CERCLA, 42 U.S.C. §9604(E),
issued a Request for Information to Textron. The request
notified Textron of the existence of a Superfund hazardous
substance Site at their former BMI-Textron facility and sought
information regarding Textron's involvement at the Site. Also,
on February 26, 1992, EPA Region IV, issued General and Special
Notice Letters for Remedial Investigation/Feasibility Study
(RI/FS) to previous BMI principal officers (William E. Eaton,
Theodore T. Tarone), and Textron, notifying them of potential
liability as potentially responsible parties under CERCLA and
establishing a period of formal negotiations. The General and
Special Notice Letters initiated a period of negotiation on an
agreement to perform the RI/FS at the Site. On April 24, 1992,
Textron submitted a Good Faith Offer to EPA, stating it was
willing to conduct an RI/FS at the Site.
In June 1992, Textron and EPA entered into an Administrative
Order by Consent (AOC) for the RI/FS. Textron agreed to
undertake all actions required by the terms and conditions of the
AOC for the conduct and implementation of the (RI/FS). The RI/F^
was conducted to evaluate Site risks and technologies available
to respond to these related risks. The RI found arsenic,
cyanide, fluoride, and sodium in ground water beneath the Site.
-------
3.0 HISTORY OF COMMUNITY PARTICIPATION
In February of 1993, EPA started its community relation
efforts by conducting community interviews and holding a public
meeting at the Palm Beach County Library. The meeting was held
to address concerns expressed by the citizens and inform local
residences of EPA's planned RI activities. This meeting was
attended by five citizens of West Palm and two representatives
from FDEP.
A public comment period for the proposed remedial action was
held from April 18, 1994 through May 17, 1994. During this time
a Proposed Plan fact sheet was released to the public in order to
inform the citizens of EPA's findings during the RI/FS event and
of EPA's preferred remedial alternative for Site cleanup. This
event was also held to notify the public that the details of the
RI/FS reports could be found at the Lake Park Library. In
addition, a public meeting was held on April 21, 1994. In the
course of this meeting, EPA answered questions about the
potential risk posed by the Site and the remedial alternatives
under consideration. A response to the comments received during
this period is included in the Responsiveness Summary, which is
part of this Record of Decision (ROD). This decision document
presents the selected remedial action for the BMI-Textron Site,
in Lake Park, Florida, chosen in accordance with CERCLA, as
amended by SARA, and to the extent practicable, the National
Contingency Plan. The decision for this Site is based on the
Administrative Record, located in the EPA's repository at the
Palm Beach County Library and Region IV repository.
4.0 SCOPE AND ROLE OF RESPONSE ACTION
This ROD discloses the planned remedial activities at the
BMI-Textron Site, addressing ground water. The cleanup remedy
will address the ground water contaminants which remain at the
Site. The function of this remedy is to reduce the risks
associated with exposure to contaminated ground water and to
protect the surficial aquifer system present beneath the Site.
The ROD is the only ROD anticipated for this Site since the
contamination present at this Site will be addressed as a single
operable unit.
5.0 SUMMARY OF SITE CHARACTERISTICS
Information on soils, geologic and hydrogeologic conditions
at the BMI-Textron Site are presented in this section, including
the results of the well inventory ecological assessment and human
population survey conducted as part of the RI. Site surface
features and meteorological data were briefly discussed in the
Site Description.
-------
5 .1 Regional Hydroqeoloqy
The geologic formations underlying the area of Palm Beach
County near the former BMI-Textron Site consist of the Pamlico
Sand, the" Anastasia Formation, the Fort Thompson formation, and
the Calaoosahatchee Marl.
The Pamlico Sand (Unit 1) mantles all of eastern Palm Beach
County and consists of sand and shell. The Anastasia Formation
(Unit 2) underlies the surficial sand and is composed of sand,
sandstone, limestone, coquina and shell. The Caloosahatchee Marl
(Unit 4) underlies the Fort Thompson Formation (Unit 3) and is
composed of shelly sand, sandy shell, marl, limestone and
sandstone.
Two surficial aquifers are present in Palm Beach County:
the Turnpike Aquifer and the Sandy Ridge Aquifer. Because the
Turnpike Aquifer is situated greater than 3 miles to the west and
upgradient of the BMI-Textron Site, it is unlikely that this
aquifer has been affected by the Site. This discussion
concentrates primarily on the Sandy Ridge Aquifer. The Sandy
Ridge Aquifer is comprised of sand, shell, sandstone, limestone
or mixtures of these. In the area of the BMI-Textron Site, the
Sandy Ridge aquifer is reported to extend to a depth of
approximately 210 feet below mean sea level (MSL) (See Figure 3).
Regional ground water flow in this aquifer is reported to be
toward the east.
The Sandy Ridge Aquifer can be divided into four hydrologic
units. Unit 1, at the surface, is generally 20 to 40 feet thick
and is composed of sand and layers of shell. Unit 2 is
approximately 60 feet thick and is composed of unconsolidated
sand and shell with occasional sandstone. Unit 3 is
approximately 50 feet thick and consists of very fine sand and
shell and is generally the lowest in permeability of the four
units. Unit 4 is approximately 100 feet chick and consists of
firmly cemented calcareous sand and shell with occasional layers
of marl. Most of the drinking water supply (DWS) wells in the
area of this Site are completed within Unit 4 because it is the
thickest and generally the most permeable section in the aquifer.
This zone may have a hydraulic leaky confined aquifer, but is
still considered a component of the shallow ground water system.
According to the FDEP, along the Coastal Ridge (the area of
the BMI-Textron Site) the hydraulic conductivity of the sediments
is estimated to range between 1 and 50 feet/day; the
transmissivity of the Sandy Ridge Aquifer as a whole, estimated
from pump test data, is 7,000 feetVday and the transmissivity of
Unit 4 is estimated as 4,000 feetVday.
The Sandy Ridge Aquifer is underlain by approximately 250 to
350 feet green, shelly clay that is a unit of the Hawthorn Group.
-------
I DWC DATE: 28JAN9J I PRJCT NO.: PF4510I I'
RAWING: 4510ICCS I
SAND.SHELLS AND OCCASIONAL
LAYERS OF SANDSTONE
VERY FINE
SANO AND SHELLS
CEMENTED SANO AND SHELLS
AND OCCA90NAL MARL LAffRJ
BEOS OF VtRY
FINE SANO AND SHELLS
AND LIMESTONE,USUALLY INTERBEOOEO WITH
MARL AND CLAY
BASE Of SHALLOW
AQUIFER
MOSTLY CLAY AND SANDSTONE
o t MILE
-JOO
400
400
SOURCE: FOER RMERA BEACH WELLFIELO CONTAMINATION REPORT (WATTS tt BROWN 1985).
GERAGHTY
& MILLER, INC.
Environmental Services
GEOLOGIC CROSS SECTION OF THE SANDY RIDGE AQUIFER
FORMER BMI-TEXTRON SITE
LAKf PARK. FLORIDA
FIGURE
3
-------
This forms the main confining unit that separates the Sandy Ridge
Aquifer from the underlying Floridan Aquifer. The top of the
Floridan Aquifer is approximately 1,000 feet below land surface.
In the area of the BMI-Textron Site, the Floridan Aquifer is not
an important water supply because the water is brackish (i.e.,
1,000 milligrams per liter [mg/L] to 4,000 mg/L of chlorides).
5.2 Site-Soils and Hydroqeology
The BMI-Textron Site is situated on the Coastal Ridge
physiographic province on soils of the Paola series. The Paola
soil consists of nearly-level, excessively drained, deep sandy
soils.
The Site is underlain predominantly by unconsolidated, fine-
to medium-grained sand to a depth of 210 feet below land surface
(bis). The top 20 to 40 ft of subsurface material consists of
sand with occasional layers of sandstone and limestone.
The hydraulic conductivity in the uppermost portion of this
aquifer ranges from 30 to 50 feet per day (ft/day). Values of
transmits si vity (35,000 gallons/day-foot) and storage coefficient
(O.2) were obtained for the deeper sections of the aquifer at
this Site from the performance of short-term (two day) pumping
test performed at a near-by facility which FDEP has investigated.
In April 1987 a recovery well screened between 100 and 125 bis
was pumped continuously at a rate of about 45 gallons per minute
(gpm). The calculated values are consistent with range of
transmissivity and storage coefficients presented in the Riviera
Beach Well Field Contamination Report prepared by the FDEP in
September 1985.
Based on the three rounds of (February 19, April 5 and July
15, 1993) water-level data, collected during the RI, the dominant
flow direction in both the upper and lower zones of the surficial
aquifer, is to the north/northeast; the depth to ground water
ranged between the 15 and 20 feet bis; little or no variation in
the water-level elevations between the upper and lower surficial
aquifer zones, indicating a lack of a downward ground water flow
component. The data also indicated a flatter hydraulic gradient
and slower ground water movement than indicated in previous Site
investigations; and average hydraulic gradient at this Site of
about 0.0004 ft/ft was calculated from this information; the
ground water velocities at this Site averaged about 0.05 feet/day
or 19.5 feet/year.
5.3 Summary of Remedial Investigation Results
Sampling conducted during the RI at the Site indicates the
primary contaminated media is ground water which contains
cyanide, fluoride, arsenic, and sodium.
-------
The absence of surface water bodies in the immediate
vicinity of the Site eliminated the need for surface water and
sediment sampling. The lack of exposed surface soils preclude
the generation of dust containing the inorganic constituents
disposed of at the Site.
5.3.1 Soils
Soil samples were conducted during the months of February
and March 1993, sampling event. Twelve soil borings were
installed, and 14 soil samples were collected from those borings.
The borings were placed at, or as close as possible to, the
suspected source areas including the three percolation ponds,
reverse Osmosis (R.O.) Drainfield, two septic tanks and six
domestic waste drainfields. Soil samples also were collected
from two soil borings in areas hydraulically upgradient of the
Site to develop background soil quality conditions. Sample
location are shown in figure 4.
The results of the analyses of the soil samples from the
source areas were compared to twice the average concentration of
the constituents detected in the background soils. For metals,
the results also were compared to the concentration of the
constituent that is common to the South Florida area. If a
constituent was detected in some but not all of the background
soils, then the average was calculated using the detected results
and one-half the detection limit concentration for those
background samples that were free from the constituent. If a
constituent was not detected in any background sample, the
results of the analysis of the soil sampled from the source areas
were compared against the average detection limit of the
background samples.
Organics Constituents
As shown in Table I, out of the list of TCL constituents
analyzed .only acetone and fluoranthene were present above
detection limits. Acetone was reported above twice the average
background concentration in the soil samples collected from Soil
Borings 93-2 and 93-3 (81 M-9/kg and 170 Jig/kg, respectively) .
Fluoranthene was reported to be present in the soil sample from
only one Soil Boring, 93-3. The concentration reported was 7
|ig/kg. The low detection frequency of organic constituents (3
detections) and the low concentrations reported do not appear to
indicate that, at the locations sampled, the waste disposal areas
investigated are a consequential source of organic constituents.
-------
TABLE i AeeuRaoftheAnalyeleof ftubeurfaoe Sol temptee for the
Jormer BMMextren We, Lake Par*. Florida
Pag« 1 of 2
PARAMETER I/
Volatile Organic Compound*
TEST
METHOD UNfTS
CLP
(OC/MS)
DATE
Q&MIO
SAVANNAH ID
2/25/03
03/1-14-16
57708
2/24/93
Dup (93-1-14/16)
OBfl-2
57700
2/24/03
03/2-13-18
87707
2/24/93
03/3-10-12
57704
2/24/03
03/4-13-18
57708
2/24/03
03/5-13-16
87706
2/23/03
03A-0-12
59109
2/23/93
03/7-10-12
5S104
Acetone
Ba*e Neutral and Add btracufcle
Organic Compound*
DMhytphthalale
Phenanthrene
Anthracene
Carbazol*
DVn-burylphthalate
Fluoranthene
Pyrene
Butytbenzylphthalale
B*nzo(a)anltuac«ne
Chry*ene
bejCZ-EthythexyOphthatate
Ol-n-odylphthaUie
Benzo(b)fluoranlhene
Benzo(k)nuoranthene
Benzo(a)pyr*ne
lndeno(1 ,2.3-cd)pyrene
DK»rtz(a,h)»n4hracene
Banzo(g.h.l)perylene
21
11
170
12
CLP
(QC/MS)
(15) U
lie] u
(11)
[18] UJ
m j
IS) UJ
(13) UJ
(7) UJ
lie] u
(is) u
(14) U
(12) U
"O/Xfl
"ft/Kfl
Inorganic Conetltuenu
Aluminum
Artenlc
Barium
Cadmium
Calcium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Sodium
Vanadium
Zinc
Cyanide
CLP
(CP)
(QFAA)
(CP)
(CP)
(CP)
(ICP)
(CP)
(CP)
(OFAA)
(CP)
(CP)
(CV)
(CP)
(CP)
(CP)
(ICP)
CLP
^QM>Q
nx^sQ
mg/Kg
mg/Kg
mg/Kg
mg/Kg •
mgA
-------
TABLE] HMUte0ltMAfMly*WOt«uMunBC*So«Mfn|»OTK»in*
Form«r BMI-T««roo Silt, Late Par*, nortd*
Page 2 of 2
PARAMETER 1/
Volatile Organic Compound*
Ac* lone
Base Neutral and Add Extractable
Organic Compound* '
Dlelhytprtthalate
Phenanthrene
Carbczoto
Ot-n-bufytpWhaUte
Fluoranthen*
Pyren*
Burytbenzytphthalate
B*nzo(a)anfhr*«*ne
Chrysene
bls(2-Elhy1hexyf)Dhrhalate
Dt-n-odytphthatate
Benzo(b)nuoranmene
Benzo(k)fluoranthen*
Benzo(a)pyr*n*
lndeno( 1 .2.3-od)pyrene
Obenz(*..h)anthracene
B*nzo(g,h,l)perytene
Inorganic ConstKuents
Aluminum
Arsenic
Barium
Cadmium
Calcium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Sodium
Vanadium
Zinc
Cyanide
TEST
METHOD
CLP
(QC/MS)
CLP
(QC/VS)
CLP
(CP)
(QFAA)
(CP)
(CP)
(CP)
(CP)
(CP)
(CP)
(OFAA)
(CP)
(CP)
(CV)
(CP)
(CP)
(CP)
(CP)
CLP
DATE 2/24/03 2/2403 2/24/03
Q&MO 03*11-13 03/0-0-11 03/10-6-10
UNfTS SAVANNAH 10 57701 57703 57702
ug/Kg
U0*0
ug/Kg
ug>Kg
ug/Kg
ug/Kg
ug/Kg
u^Kfl
UQ^CQ
ug/Kg
ug/Kg
ug/Kg
ug/Kg
ug/Kg
ug/Kg
ug/Kg
ug/Kg
"9«0
mg/Kg
mgtKQ
mg/Kg
mg/Kg
mgflvg
mg/Kg
mg/Kg
m0*7
0.68 1.3 1.5
(41.4) U (45.0) U (41.3] U
(0.07) U |1.7] U (2.4) UJ
.
(1.5) U (1.1) U (1.4) U
(12.2) U • (10) U
(1.5) |1.6] |1.5]
5.1 U (1.0) U |4| U
.
2/22/03 2/2203
03-11-0/2 03/11-10-12
55106 6S107
(50)
(Si
18)
(is)
(ISO)
(120)
PI
(54)
(85)
|14]
(71|
(71)
(64)
(46)
117)
[50]
47.5
•
(0.46)
•
(1771
(0.63)
(0.56)
78.3
4
•
(1.8)
•
2
(4.0)
.
30
J
J
J
J
UJ
J
J
UJ
J
J
U
J
J
J
J
J
J
U
U
u
u
u
J
u
u
28
•
P3J UJ
-
-
•
•
•
•
•
002
(2.0)
•
(78.5) U
f4.8J U
•
724
UJ
(47.6) U
(1.1) UJ
-
(1.2)
(8.0) U
11.3)
4.0 U
'
2/22/03 2/22/03
Cup (03/12-O-2)
BV12-0-2 8BR-1
65101 M103
•
•
•
-
67.1 U
(.74) U
1650
(.55) U
.
126
\2
PA] u
42 J
112.3] U
(2.5) U
.
(18) UJ
(!)
PI OJ
(8) UJ
.
W uj
•
-
833
-
(.02) U
4870
.
138
\2
(11.6) U
3.4
.
.
(44) U
(3.3) U
2/2203
03/12-10-12
&9102
•
.
(14) UJ
.
(5J
-
.
|80| UJ
-
.
•
702
(2) U
.
(215) U
5.4
.
676
U
(33.6) U
3.0 J
.
18.1) U
1.1
134 U
FOOTNOTES:
I/ Cortttluentt not detected In any cample are not inown.
21 ••' IndlcatM the oorwkuenl waa not detected.
UJ Anafyte waa not delected or hat been quaflted as undetected.
»fth turtner daaeMcaUon a» quaftajlve.
J Value na* been claM«led *a qualitative.
U Ana^le waa not delected or haa been cUssHted a* undeledtd.
-------
Although di-n-butylphthalate was detected in several samples
at concentrations up to 18 |ig/kg, this compound was also detected
in the equipment/field and laboratory blanks. Therefore, the
reported .concentrations for this constituent have been classified
as undetected. Likewise, the concentrations of pyrene (9 ng/kg),
butylbenzylphthalate (13 ug/kg) and bis(2-ethylhexyl)phthalate (7
Hg/kg) reported in the soil sample collected from SB-93-3 have
also been classified as undetected, due to the presence of these
compounds in the associated blank analyses.
Inorganic Constituents
As shown in Table 1, the concentrations of inorganic
constituents present in the subsurface soil samples were
relatively low. Of the constituents measured, aluminum, arsenic,
barium, calcium, iron, lead, magnesium, manganese, and vanadium
were detected at concentrations slightly above twice the average
background concentration in soil sample 93/ 1-14-16. This sample
was collected from soil boring SB-93-2. The depth interval
sample is below the fill material used to fill the excavation
associated with the removal action conducted a PP-2 in 1990.
Traces of one to three metals were detected at
concentrations above twice the background concentration in soil
samples collected from five of the remaining eight borings. The
soil borings and the associated concentrations are presented
below:
SB-93-3 arsenic (1.2 mg/kg), and cadmium (0.39 mg/kg)
SB-93-3 arsenic (1.1 mg/kg)
SB-93-3 arsenic (0.89 mg/kg)
SB-93-3 chromium (13.5 mg/kg).manganese (4.7 mg/kg), and
nickel (3 mg/kg)
SB-93-3 calcium (3,140 mg/kg), manganese (5.0 mg/kg), and
mercury (0.11 mg/kg)
Samples collected from the three soil borings SB-93-8, SB-93-9
and SB-93-10 did not contain concentrations of metals or cyanide
above twice the background levels.
As discussed above, cyanide, which is not normally found in
soils, was also detected in the soil sample collected from Soil
Boring SB-93-2 (2.2 mg/kg). This low concentration of cyanide in
the soils at PP-2 as well as the lack of cyanide in the sample
collected from SB-93-1, associated with PP-1, is consistent with
the levels of cyanide detected during confirmation sampling
conducted after the removal actions associated with the two
sources.
Several metals were reported to be present in samples as
well as in the associated equipment/field or laboratory blanks.
This led to classification of several metals results as
12
-------
undetected. The metals affected and the maximum concentration of
each metal that was qualified are barium (1.9 mg/kg), calcium
(796 mg/kg), chromium (17.8 mg/kg), magnesium (64.9 mg/kg),
manganese (3.5 mg/kg), nickel (1.8mg/kg), sodium (42.2 mg/kg),
and zinc "(9.8 mg/kg). Because concentrations reported in the
samples that were qualified were at trace levels, the
qualification of the data does not compromise the evaluation of
the nature and extent of impacted soil nor is qualification of
the data expected to impact the confidence level of the
conclusion developed from the risk assessment.
The analysis revealed: 1) low concentrations, <200
micrograms per kilogram (ug/Kg) , of a very limited number of
organic constituents in only a few soil samples; 2) several
inorganic constituents (primarily metals) in concentration
slightly above twice the average background level; and 3) cyanide
and fluoride above background levels. The data collected during
the RI indicates that previous soil removal efforts done by
Textron Inc., has significantly reduced any risk due to soil
contamination.
5.3.2 Ground Water
Ground water sampling was conducted in two events. Ni-.eteen
existing monitor wells and two new monitor wells were sampled in
the first event in March 1993. The second event was conducted in
June 1993 and consisted of installing and sampling four new
monitoring. Thus making the total number of samples consist of
five off-Site monitoring wells and 23 monitoring wells (including
monitor wells previously sampled). Monitor Wells locations are
shown in figure 5.
There were no organics found at concentrations greater than
Federal or State standards. Concentrations of several inorganics
were detected in the monitoring well samples, however, only two
metals, arsenic and sodium, and two inorganics, cyanide and
fluoride, were detected in concentrations that exceeded twice the
average background concentration and/or the State of Florida
primary drinking water Maximum Contaminate Level (MCL).
Sodium was found to exceed the State primary drinking water
MCL of 160,00 micrograms per liter (flg/L) in only one monitor
well MW-35. The concentration of sodium detected in that sample
was 298,000 Hg/L. Arsenic was found to exceed the primary
drinking water MCLs of 50 \ig/L in only monitor well, MW-38,
during the March 1993 sampling event. Arsenic was detected in
samples from only three monitor wells (MW-36A, MW-36B, and MW-35)
during the June 1993 sampling event which utilized the modified
ground water sampling procedure discussed in the Final RI Report.
Arsenic was not detected in monitor well MW-38 during the June
1993 sampling event, this procedure reduced the turbidity of
samples and minimized the influence of sediments in the sample.
13
-------
SB-93-11
— MILLER WAY
SB-93-?
[sB-93-S |
O
CC
ffi
ft
SB-93-
r
-- REEO RO.
LEGEND
« Rl SOIL BORING LOCATION
® Rl BACKGROUND SOIL BORINC LOCATION
E£gp DOMESTIC WASTE ORAINFIELO LOCATION
gggg PERCOLATION POND LOCATION
—— LINE OF GEOLOGIC CROSS SECTION
UJ
z
TKANS-ClRCUl!
PLAN!
i BRANT RO.
GERAGHTY
& MILLER, INC.
.EnvironmentaJ Services
LOCATION OF SOIL BORINGS INSTALLED DURING THE Rl
FORMFR RMI-TFXTRON SITF
FIGURE
A
-------
MILLER WAY
MW
-93-1
BLOC e
(NOT BMI)
SEPTIC TAWK
CD
-
MW-93-2
H_:E
i
BLOC 9
B
IR.O.
ORMNntLO
Bl.OC 6
COVERED
WALKWAY
Tl
BLOC 7
8
a*
180
*
BLOC j
!L
It
34A.B
BLOC I
32«
A5S*
A*
PP-3
PP-1
BLOC 4
5C55»
5C
PP-2'
•33
36A.B •
§§
§g
BLOC 2
-35
MW-93-J
'*B '
• 37
38 I I SCPTll
SCPTlC TANK
-- REED RD. --
I
j LEGEND
• EXISTING MONITOR WELL LOCATION
(g) MONITOR WELL LOCATION INSTALLED DURING THE Rl (FEBRUARY 1993)
© MONITOR WELL LOCATION INSTALLED DURING THE Rl (JUNE 1993)
(1H DOMESTIC WASTE ORAINFIEl.D LOCATION
KS«J PERCOLATION POND LOCATION
MW-93-7 MW-93-6
MW-IOA*
MW-10B*
.-I
o
f£
z.
<
5
5
TRAMS- CIRCUITS
M-7
BRANT RO.
MW-93-4
%!)WW-93-5
GERAGHTY
MILLER, INC.
Environmental Services
LOCATION OF MONHTOR WELLS/OFFSfTE MONfTOR WELLS
FORMER BMI-TEXTRON SITE
LAKE PARK. FLORIDA
FIGURE
-------
The arsenic concentrations detected in the three monitor wells in
June 1993 were below the primary drinking water MCL 50
|ig/L. Arsenic was detected at a maximum concentration of 18.1
ug/L, which is below the State and Federal standards. Cyanide
was found to exceed the primary drinking water MCL of 200 (ig/L at
two monitor well locations, MW-35 and MW-38, during the March
and June 1993 sampling events. Both monitor well locations are
in the vicinity of Percolation Pond PP-2. The data indicate the
extent of ground water impacted with cyanide above the MCL is
limited to the upper zone (upper 20 feet ) of the surficial
aquifer in the immediate vicinity of Percolation Pond PP-2.
Cyanide was detected at levels as high as 2170 to 3190.
Fluoride was found to be slightly above the primary drinking
water MCL of 4000 |J.g/L in samples from four monitor wells during
both sampling events. Three of these monitor wells (MW-35, MW-
36A, and MW-38) are located in the vicinity of Percolation Pond
PP-2. The fourth monitor'well (MW-3) is located immediately east
of PP-3. The data indicate ground water impacted with fluoride
above the MCL is localized in the upper zone of surficial aquifer
in the immediate vicinity of PP-2 and PP-3. Area of
contamination is shown is figure 6.
Manganese concentrations also exceeded twice the average
background concentration at\on monitor well, MW-32; there is no
primary drinking water MCL for manganese (the secondary MCL for
manganese is 50 Hg/L) . Because the location of -MW-32 is cross
gradient to the identified locations of waste disposal, and other
constituents such as cyanide known to be associated with the
disposed waste were not detected, it appears that the elevated
manganese concentration reported is an isol'ated occurrence and
not attributable to previous waste management practices.
16
-------
I DWC
DATE: 3/10/94 I PRJCT NO.: PF045I.OJC |FILENO.:BMI I DRAWING: ACYU0793.0CE I CHECKED: W.VOCELSONC I APPROVED: W.VOCELSONC |DRAFTER:BJH
MILLER WAY
MW-93-1,
Q
I
CD
a
LEGEND
• EXISTING MONITOR WELL LOCATION
® MONITOR WELL LOCATION INSTALLED DURING THE Rl (FEBRUARY 1993)
© MONITOR WELL LOCATION INSTALLED DURING THE Rl (JUNE 1993)
| •'" 1 DOMESTIC .WASTE DRAINFIELD LOCATION
jgggj PERCOLATION POND LOCATION
• > MCL ISOIINE CYANIDE
^ ^» > MCL ISOLINE SODIUM
> MCL ISOLINE FLUORIDE
REED RD.
MW-93-6
MW- 10A«
o
a
£
z
• .
B2N
BRANT RO.
'MW-93-4
GERAGHTY
& MILLER, INC.
Environmental Services
ISOLINES FOR COPC's DETECTED IN GROUNDWATER SAMPLES ABOVE MCLs
UPPER ZONE OF THE SURFICIAL AQUIFER
FORMER BMI-TEXTRON SITE
LAKE PARK. FLORIDA '
FIGURE
6
-------
The table below is a summary of the COPCs found at during
the ground water investigation portion of the RI event.
BMI TEXTRON Site GROUND WATER SUMMARY
GROUND WATER
Arsenic
Sodium
Cyanide
Fluoride
Phase
1
MCD
(H9/L)
64.4
298,000
2170
6200
Phase
II
MCD
(H9/L)
18
NA
3,190
4800
Federal/State
MCL
(pg/L)
50/50
- / 160,000
200/200
4000/4000
Note: MCD - Maximum Concentration Detected in Site Groundwater
MCL - Maximum Contaminant Level
NA - Not Analyzed
5.3.3
Well Inventory
BMI-Textron conducted a well inventory within a two mile
radius of the Site. A review of South Florida Water Management
District files and a door-to-door survey in areas lying within
1000 feet of the Site were performed. All permitted potable
wells (a total of 30) within this area were identified and
plotted on Figure 7.
No unpermitted or exempt potable wells were found to exist
in the area surveyed. The nearest permitted potable well found
in this survey is Public Supply Well #16 for the City of Riviera
Beach (Well #21 on Figure 7). A total of 14 irrigation wells
identified in the survey area are shown on Figure 7. Seven of
the irrigation wells were found to exist in the residential
neighborhoods south, southeast and east of the Site. Well
construction information was not available for the other 5 wells
in the vicinity of the former BMI-Textron Site. The closest
irrigation well (Well #7) is approximately 100 feet south of the
southern property boundary. The RI has revealed no Site related
well contamination within the two mile survey.
5.4 Human Population Survey
A survey of specific demographic data within a two-mile
radius of the BMI-Textron Site was performed. The nearest
residential community lies south of Silver Beach Road as shown on
Figure 8. The Site is surrounded by a locked, chain-link fence
which inhibits access by the community.
18
-------
*
o
i
: • ii •/""•I '• 'P*
: ...V'-r7^ **V?^M I
-. fi !
SITE LOCATION
JET
2000
BASE MAP SOURCE: U.S.C.S. 7.5 MINUTE SERIES (TOPOCRAPHK)
RMERA BEACH QIMOMMCU.
WELL MVENTORY MAP
FORMEB BMI-TEXTRON SITE
LAKE PARK, FLORIDA
FIGURE
7
-------
\
k
21
21
200
Silver dtacn xoca
3ES1DENTW. AREA .
T
BUILDING INVENTORY
i. OR. JOHN'S AUTO CLINIC
2. a. AERO PRECISION (FM REPAIR STATION)
3. HOUSE OF CUSTOM CUSHIONS
4. VACANT BUILDING
5. KARDRIVES (PAVING COMPANY)
6. FIRESIDE DISTRIBUTORS
7. BEACH MIRROR It CUSS/ANDERSON MASONRY
8. SIGNING AMERICA CORP.
9. GLOBAL ELECTRIC
10. TRI-CITY LUMBER
11. A&M AUTO. INC.
13. OAKS AUTOMOTIVE
54. PARK CARPET
15. PARK CLASS
is. BARON SIGN CO.
^7. BEACH A/C
-.8. LAKE & BAY BOATS
•.9. DUN RIGHT MFC.
20. DETAILING & WINDOW T:"T
21. U6C. REPAIR SHOPS (Auro. ETC.)
22. VACANT BUILDING (FORMERLY TRANS CIRCUITS. JNC.)
23. ACTION BOLT ft TOOL
24. THOUSANDS OF PARTS AUTO JUNKYARD
25. PALM BEACH X-RAY
26. SPECIALTY WOODWORKS (NT. CABINETS)
27. CARRIER A/C
28. J&R WELDING
29. NEVER WEAR ASPHALT SEALER
30. MILES OF SOUND (CAR STEREOS)
31. WELDING BY DAN
32. NEW IMAGE AUTO BODY
33. LUCOO BROTHERS (CABINETS)
AREA VICINITY MAP
BMI-TEXTRON SITE
LAKE PARK, FLORIDA
RGURE NO.
8
-------
5.5 Ecological Assessment
The BMI-Textron Site is in an industrial park, with the area
surrounding the Site consisting of a locked, chain-link fence. A
grass-covered drainage swale, approximately 5 to 10 feet wide,
located on the perimeter of the property. The majority of the
Site is covered by building, asphalt pavement, and concrete which
reduces exposure pathways (see Figure 2). Although the area is
paved or covered with a building, the ecological assessment
concluded that no visual evidence exists that indicate biota at
the Site and surrounding areas have been adversely impacted by
operations at this Site.
6.0 Summary of Site Risks
CERCLA directs EPA to conduct a Baseline Risk Assessment
(BRA) to determine whether a Superfund Site poses a current or
potential threat to human health and the environment in the
absence of any remedial action. The BRA provides the basis for
taking action and indicates contaminants and the exposure
pathways that need to be addressed by the remedial action. This
section of the ROD contains a summary of the results of the BRA
conducted for this Site. The completed BRA is located in the
BMI-Textron repository, located in the Palm Beach County Liorary.
6.1 Contaminants of Potential Concern
The objective of contaminant identification is to screen the
information that is available on hazardous /substances present at
the Site and to identify COPC in order to focus subsequent
efforts in the risk assessment process. COPC are selected based
upon their toxicological properties, concentrations and frequency
of occurrence at the Site. During the Risk Assessment for the
BMI-Textron Site, the following chemicals were identified as
contaminants of potential concern in the ground water: arsenic,
sodium, cyanide and fluoride. Arsenic was listed as a COPC
during the first round of sampling done in February and March
1993, however, in a second round of sampling the arsenic
concentration level was below federal and state MCLs.
6.2 Exposure Assessment
Exposure assessment is conducted to identify pathways
whereby human receptors may be exposed to Site contaminants and
to estimate the frequency, duration and magnitude of such
exposures. Exposure assessment is a multiphase process that
involves (1) characterization of the exposure setting; (2)
identification of exposure pathways; and (3) quantification of
exposure.
21
-------
6.2.1 Conceptual Site Model
The primary source of contamination at the BMI-Textron Site
was wastewater/sludge in Percolation Ponds (PP-1, PP-2 and PP-3).
These contaminant sources were removed through previous soil
removals during Percolation Pond Closures, in December 1984 and
April 1990. The primary release mechanism for previously
existing contamination is to ground water. The medium available
for human contact is ground water.
Ground water and subsurface soils beneath the BMI-Textron
Site became contaminated through the disposal of the
sludge/wastewater in the Percolation Ponds infiltration of
rainwater also caused ground water contamination through the
leaching of contaminants from subsurface soil to ground water.
Analytical results collected during the RI from both on and off-
Site monitoring wells confirm the presence of contamination in
ground water both beneath the Site and downgradient (G&M, 1993).
The potential exposure pathways are diagrammed in the conceptual
Site model, Figure 9.
6.2.2 Exposure Point Concentrations
Reasonable maximum exposure (RME) point concentrations for
ground water were calculated using the lesser of the 95 percent
upper confidence limit (UCL) on the arithmetic average for a
lognormal distribution or the maximum detected value. Where a
COPC was not detected, one-half the quantitation limit was used
as a concentration. RME concentrations for the surficial aquifer
reveal that exposure point concentrations for future use at the
Site are oral exposure to contaminants. Concentrations of
exposure route are presented in Table 2.
6.2.3 Human Intakes
Currently, no drinking water wella are known to be
contaminated. Additionally, surface soil contamination that did
exist has been removed. Since there are no current complete
exposure pathways, there is no risk to human health based on
current use of the Site.
In the future use scenario, new wells might be installed
within the contaminant plume and utilized by workers or by
potential residents. The variables used in calculating oral
intakes are presented below:
1. Residents
Ingestion rate 1 L/day-child (conservative
estimate); 2 L/day-adult
Exposure frequency 350 days/year
22
-------
03
m
CONTAMINANT/
SOURCE
PRIMARY RELEASE/ AFFECTED &POSURE.
TRANSPORT MECHANISM M5PW £2^
ELECTRONIC
COMPONENT
PRODUCTION
WASTES
Leaching
Groundwater
"-•:?*
Onsite
.
Ingestion
'i!
Resides
Workers
-------
Exposure duration 6 years-child, 30 years-adult
Body weight 15kg-child, 70 kg-adult
Averaging time 70 years for cancer
effects, 6 years-child and 30
years-adult non-cancer effects
2. Workers . N
Ingestion rate 1 L/day
Exposure frequency 250 days/year
Exposure duration 25 years
Body weight 70 kg
Averaging time 70 years for cancer effects, 25
years non-cancer effects
Calculated intakes of ground water from the surficial
aquifer for a child resident, an adult resident and a worker are
presented in Table 2.
24
-------
Table 2
Summary of Reasonable Maximum Exposure Concentrations for a Future Hypothetical Receptor Exposed
to Ground Water
BMI-Textron Site
Lake Park, Florida
Arsenic
Sodium
Cyanide
Fluoride
17.4
298000
1933
6200
1.1E-03
1.9E+01
1.2E-01
4.0E-1
9.5E-05
1.6E+00
1.1E-02
3.4E-02
4.8E-04
8.2E+00
5.3E-02
1.7E-01
2.0E-04
3.5E+00
2.3E-02
7.3E-02
1.7E-04
2.9E+00
1.9E-02
6.1E-02
6.1E-05
1.0E+00
6.8E-03
2.2E-02
Notes:
RME Reasonable Maximum Exposure
ADD Average Daily Dose
LADD Lifetime Average Daily Dose
25
-------
6.3 Toxicity Assessment
The purpose of a toxicity assessment is to weigh available
evidence•regarding the potential of the contaminants of concern
to cause "adverse effects in exposed individuals and to provide an
estimate likelihood of adverse effects. The toxicity assessment
is based on toxicity values which have been derived from
quantitative dose-response information. Toxicity values for
cancer are known as slope factors (SFs) and those determined for
non-carcinogenic effects are referred to as reference doses
(RfDs) ..
Slope factors (SFs), which are also known as cancer potency
factors (CPFs), have been developed by EPA's Carcinogenic
Assessment Group for estimating excess lifetime cancer risks
associated with exposure to potentially carcinogenic chemicals.
SFs, which are expressed in units of (mg/kg-day)"', are
multiplied by the estimated intake of a potential carcinogen, in
mg/kg-day, to provide an upper-bound estimate of the excess
lifetime cancer risk calculated from the SF. Use of this
approach makes underestimation of the actual cancer risk highly
unlikely. SFs are derived from the results of human
epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied. SFs for the contaminants of concern at BMI-Textron are
listed in Table 3.
Reference doses (RfDs) have been developed by EPA for
indicating the potential for adverse health effects for exposure
to chemicals exhibiting non-carcinogenic effects. RfDs, which
are expressed in units of mg/kg-day, are estimates of lifetime
daily exposure levels for human, including sensitive individuals.
Estimated intakes of chemicals from environmental media (e.g. the
amount of a chemical ingested from contaminated drinking water)
can be compared to the RfD. RfDs are derived from human
epidemiological studies or animal studies to which uncertainty
factors have been applied (e.g. to account for the use of animal
data to predict effects on humans). These uncertainty factors
help ensure that the RfDs will not underestimate the potential
for adverse non-carcinogenic effects to occur. RfDs for the
contaminants of concern at BMI-Textron Site are found in Table 3.
6.4 Risk Characterization
Human health risks are characterized for potential
carcinogenic and non-carcinogenic effects by combining exposure
and toxicity information. Excess lifetime cancer risks are
determined by multiplying the estimated daily intake level with
cancer risks with cancer potency factor. These risks are
probabilities that are generally expressed in scientific notation
(e.g., IxlO"6) . An excess lifetime cancer risk of IxlO"6
indicates that, as a reasonable maximum estimate, an individual
26
-------
Table 3
Cancer Slope Factor and Reference Doses for Contaminants of Concern
BMI-Textron Site
Lake Park, Florida
Arsenic
Sodium
Cyanide (free)
Fluoride (child)
Fluoride (adult)
.75E+00
NA
NA
NA
NA
NA
NA
NA
NA
NA
3E-04 (1)
3.4E+01 (2!
2E-02 (1)
6E-02 (1)
1E-01 (1)
NA
NA
NA
NA
(1) IRIS, 1993
(2) ECAO, 1992
CSF - Cancer Slope Factor
RfD - Reference Dose
NA - Not Applicable
27
-------
has a one in one million additional (above their normal risk)
chance of developing cancer as a result of Site-related exposure
to a carcinogen over a 70-year lifetime under the assumed
specific exposure conditions at a Site. EPA considers individual
excess cancer risks in the range of IxlO''1 to IxlO"6 as
protective; however, the IxlO"6 risk level is
generally used as the point of departure for setting cleanup
levels at superfund Sites. A summary of cancer and non cancer
Risks is listed in Table 4.
The potential for non-carcinogenic effects is evaluated by
comparing an exposure level over a specified time period (e.g.,
life-time) with a reference dose derived for a similar exposure
period. The ratio of exposure to toxicity is called a hazard
quotient (HQ). An HQ<1 indicates that a receptor's dose of a
single contaminant is less than the RfD, and that toxic non-
carcinogenic effects from that chemical are unlikely. The Hazard
Index (HI) is generated by adding the HQs for all chemical(s) of
concern that affect the same target organ (e.g., liver) within a
medium or across all media to which a given population may
reasonably be exposed. An HI<1 indicates that, based on the sum
of all HQ's from different contaminants and exposure routes,
toxic non-carcinogenic effects from all contaminants are
unlikely.
The HQ is calculated as follows:
Non-cancer HQ=CDI/RfD
where:
CDI=Chronic daily intake
RfD=reference dose
GDI and RfD are expressed in the same units and represent
the same exposure period (i.e., chronic, subchronic, or short-
term) .
To characterize the overall potential for non-carcinogenic
effects associated with exposure to multiple chemicals, EPA has
developed a HI approach. This approach assumes that
simultaneous subthreshold chronic exposures to multiple chemicals
that effect the same target organ are additive and could result
in an adverse health effect. The HI is calculated as follows:
28
-------
Table 4
Summary of Cancer and Noncancer Risks
BMI-Textron Site
Lake Park, Florida
Mult . worker
Cancer
ftigk
HI
Surficial Aquifer
2E-04
13.8
4E-04
5.9
1E-04
2.1
HI Hazard Index (non-cancer risk)
29
-------
Hazard Index = ADDj/RfD, + ADD2/RfD2 + . .
where: ADD; = Average Daily Dose (ADD) for the toxicant
= Reference Dose for the toxicant
The term ADDj/RfD; is referred to as the Hazard Quotient
(HQ) . Calculation of a HI in excess of unity indicates the
potential for adverse health effects. Indices greater than one
will be generated anytime intake for any of the chemicals of
concern exceeds its RfD. However, given a sufficient number of
chemicals under consideration, it is also possible to generate a
HI greater than one even if none of the individual chemical
intakes exceeds it respective RfD.
6 . 5 Current and Future Use Site Risk
EPA has discovered no current complete exposure pathways.
Thus, there is no risk to human health based on current use of
the Site. Future risks posed by the Site consider consumption of
drinking water from a well screened within the contaminant plume
of the surfioial aquifer. Examination of the above hypothetical
risk is consistent with the philosophy expressed in the NCP,
which is to treat ground water as a valuable resource to be
protected and restored. Cancer and non-cancer risks
attributable to drinking water from the surficial aquifer for a
child resident are presented in Table 4. The maximum cancer risk
estimate for ingestion of drinking water for an adult resident is
4xlO~4, with a hazardous index of 5.9. The maximum HI calculated
was 13.8 for the child resident scenario. Estimate of cancer
risk greater than 1 x 10~4 and non cancer risk greater than one,
are outside EPA's acceptable target range for risk at Superfund
sites (explaination of risk values can be found in section 6.4 of
the ROD) . Actual or threatened releases of hazardous substance
if not addressed by implementing the response action selected in
this ROD, may present an imminent and substantial endangerment to
human health.
6.6. Uncertainties
Reference dose factors and carcinogenic slope factors for
the COPCs were derived from the IRIS, EPA's chemical toxicity
database. All values in IRIS have been peer-reviewed and
approved for use. For sodium which is not included in IRIS,
toxicity data were obtained for EPA's Environmental Criteria and
Assessment Office.
The calculated RfD is likely overly protective, and its use
results in an overestimation of non-cancer risk. Similarly, the
cancer slope factor developed by EPA are generally conservative
and represent the upper-bound limit of the carcinogenic potency
of each chemical . The use of the conservative assumptions and
models and the conservatism built into the toxicity values are
30
-------
believed to result in an overestimate of risk. Therefore, actual
risk may be much lower than the estimates presented in previous
tables, but is not likely to be greater.
6.7 Remediation Goals
The risk assessment determined Site-specific remediation
goals for the ground water to initially establish levels suitable
for drinking. Because all the COPCs have MCLs, the MCL values
were utilized as remedial goals for this Site. The remediation
goals for the COPCs are included in the table listed on page 14,
under Federal and State MCLs.
7.0 Description of Alternatives
The following Site specific alternatives represent a range
of distinct actions addressing human health and environment. The
analysis presented below reflects the fundamental components of
the various alternatives considered feasible for this Site. The
transport model used for establishing timeframe for each of the
ground water alternative is called SEFTRAH. This model reflects
a relative comparison of remedial alternatives and does not
necessarily reflect the actual remedial periods. A more detailed
discussion of this model can be found in the Contaminant
Transport Modeling section of the FS report.
.Four ground water alternatives have been identified for
evaluation and are listed below:
Alternative
Alternative
Alternative
1: No Action
2: Institutional Controls and Monitoring
3: Institutional Controls, Monitoring,
Groundwater Recovery, On-Site Treatment, and
Off-Site Discharge
Alternative 4: Institutional Controls, Monitoring, Gro^ncl
Water Recovery, On-Site Treatment, and
Discharge
7.1 Alternative 1; No Action
Under the "No Action" alternative, no proactive steps
(including monitoring) will be taken to clean up the affected
media, which in this case is ground water. This means that the
Site will be left as is without monitoring of any kind or deed
notices or restrictions to restrict exposure to the affected
ground water.
7.2 Alternative 2: Institutional Controls and Monitoring
Alternative 2 incorporates the use of institutional controls
along with periodic Site monitoring to achieve Federal and State
31
-------
ground water standards without any remedial construction. This
alternative would include the following:
• Natural Degradation/Attenuation of COPCs;
• "Water Well Controls and Regulatory Restrictions;
• Site Security; and
• Monitoring.
This alternative is considered, based on ground water
transport modeling, which indicates a reduction of COPCs to
federal and state standards in approximately 3 years due to
natural attenuation mechanisms. During the 3 years, ground water
will be monitored quarterly for one year to verify modelled
decrease of contaminant concentration. During the remaining two
years an annual review of monitoring frequency. Selected wells
within the existing monitoring well network would be used to
provide confirmation of historical data and modeling transport
data that indicates the COPCs will naturally degrade and/or
attenuate with time. However, EPA reserves the right to increase
or decrease monitoring frequency should sampling data indicate
the necessity. If after the three years of monitoring, data
shows that Performance Standards are achieved, then the Site will
be considered for deletion from the National Priorities List
(NPL). However, should monitoring indicate that the Site has
contaminants above standards, EPA in consultation with the State
of Florida, will reconsider the protectiveness of the
"Institutional Controls and Monitoring" alternative.
Institutional controls associated with this Site include
established regional well controls and use of existing well
permitting regulations administered through the South Florida
Water Management Department (SFWMD), the Palm Beach County Health
Department (PBCHD), and FDEP. A Consumptive Use Permit and Water
Well Construction Permit, each approved by the SFWMD, and a
property inspection are required for installation of any public
water supply well and for any private well if the casing diameter
is six inches or larger. All other well installations require
well permits approved by the SFWMD.
Ground water monitoring would be used in association with
the institutional controls to document natural
degradation/attenuation of affected ground water. These measures
would be required until cleanup goals is achieved for a minimum
of two consecutive sampling periods.
7.3 Alternative 3; Institutional Controls. Monitoring. Ground
Water Recovery. On-Site Treatment, and Off-Site Discharge
This alternative includes actions outlined in Alternative 2,
along with ground water recovery, on-Site treatment for cyanide,
and off-Site discharge to the City of Palm Beach Wastewater
Treatment Plant (POTW). Based on ground water modelling this
32
-------
alternative would reach Federal and State ground water standards
within one year after installation. This alternative includes
the following:
Installation of Recovery Well near Monitor Well MW-38;
Installation of a Recovery Well near Monitor Well MW-3;
Performance of an Aquifer Pump Test to Establish
Discharge Concentrations;
On-Site Treatment of Cyanide;
Off-Site Discharge of Recovered Ground water to. a
nearby Manhole for Transfer to the POTW;
Pumping, Treatment, and Discharge Systems Operation;
Water Well Controls and Regulatory Restrictions;
Site Security (fencing); and
Monitoring
The contaminant transport model indicates that installation
of a recovery well near MW-38 pumping at an estimated rate of 3
gallons per minute (gpm) , and installation of a second recovery
well near MW-3 pumping also at an estimated rate of 3 gpm, would
effectively capture the contaminated ground water. The low yield
recovery system would be designed to pump until the
concentrations of COPCs reach federal and state standards or
asymptotic levels are achieved, at which time the pumping would
cease until equilibrium is achieved, and then pumping would
resume. The pumping system would be used in conjunction with
institutional controls and periodic monitoring, low yield
recovery would be an effective, implementable approach to
lowering the concentrations of COPCs to acceptable levels..
To implement this alternative, an aquifer pump test would be
performed during remedial design to establish discharge
concentrations of COPCs. The pump test would involve pumping the
two recovery wells at an estimated total flow rate of 6 gpm, with
the recovered ground water discharged into an on-Site, portable
storage tank. Based on current data, anticipates that the
concentrations of COPCs in the extracted ground water will be
acceptable for discharge to the POTW, with the exception of
cyanide which may require treatment to reduce the total cyanide
concentration to the POTW pretreatment standard of 0.7mg/L.
Ground water collected by the recovery well near Monitor Well MW-
38 would be treated by appropriate technology as determined by
the screening criteria to meet the POTW pre-treatment standard
for cyanide. Ground water collected by the second recovery well
near Monitor Well MW-3 would by pass the treatment system since
the anticipated concentration of cyanide from this well is non-
detect and below the remediation goal. Ground water treatment
would be preformed using a package alkali-chlcrination treatment
system, including controls and instrumentation.
The treated ground water would be collected on-Site in a
33
-------
portable storage tank for transfer to the local POTW. Two
options for transfer of the ground water to the POTW are
considered: 1) construction of a pipeline approximately 1600
feet long ..with connection to an existing sewer system (manhole) ,
or 2) trucking of the ground water to the local POTW. The chosen
option would be design during pre-design activities.
Ground water monitoring would also be used to document the
reduction in concentrations of COPCs. The transport model
indicates that with continuous pumping of the recovery wells the
remediation goals would be achieve in approximately 1 year from
installation. However, should remediation goals not be reached
in prescribed time, pumping will continue until goals are
reached.
7.4 Alternative 4: Institutional Controls, Monitoring, Ground
Water Recovery. On-Site Treatment, and Discharge
This alternative also incorporates the actions outlined in
Alternative 2, and on-Site disposal of the water to a recharge
gallery. This -alternative includes the following:
Installation of a Recovery Well near Monitor Well MW-
38;
Installation of a Recovery Well near Monitor Well MW-3;
Performance of an Aquifer Pump Test to Establish
Discharge Concentrations;
On-Site Treatment of Cyanide, Fluoride, and Sodium;
Installation of a Recharge Gallery;
Pumping, and Discharge Systems Operation;
Water Well Controls and Regulatory Restrictions;
Site Security (fencing); and
Monitoring.
As with Alternative 3, this alternative includes the
utilization of a recovery well which would be installed near
monitor Well MW-38, a second recovery well which would be
installed near monitor well MW-3, along with the pumping strategy
of 3 gpm each well.
The treated ground water would be collected in an on-Site,
portable storage tank and a gravity feed system would be used to
discharge treated water from the tank to the recharge gallery.
The recharge gallery would be located upgradient of PP-2.
Remedial standards are expected to be achieve approximately 1
year after installation.
8.0 Comparative Analysis of Alternatives
The alternatives are evaluated against one another by using
the following nine criteria:
34
-------
Overall protection of human health and the environment.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs).
' Long term effectiveness and permanence.
"Reduction of toxicity, mobility, or volume through
treatment.
Short term effectiveness.
Implementability.
Costs.
State acceptance.
Community acceptance.
The NCP categorized the nine criteria into three groups:
(1) Threshold criteria: the first two criteria, overall
protection of human health and the environment and
compliance with ARARs (or invoking a waiver), are the
minimum criteria that must be met in order for an
alternative to be eligible for selection;
(2) Primary balancing criteria: the next five criteria are
considered primary balancing criteria and are used to weigh
major trade-offs among alternative cleanup methods; and,
(3) Modifying criteria: state and community acceptance are
modifying criteria that are formally taken into account
after public comment is received on the proposed plan.
State and community acceptance is addressed in the
responsiveness summary of the ROD.
8.1 Comparative Analysis of Human Health and the Environment
The comparative analysis of the alternatives proposed for
this Site are presented in this section.
1. Overall Protection of Human Health and the Environment
With the exception of the Alternative 1, all of the
alternatives would provide protection for human health and the
environment. Alternative I and 2 rely on natural
degradation/attenuation mechanisms to remediate the COPCs.
Alternative 2 is more protective than Alternative 1, since it
includes periodic monitoring of the natural processes.
Alternative 2 also uses institutional controls to restrict use of
ground water.
With regard to aquifer remediation, Alternative 1 and 2 use
natural mechanisms while Alternative 3 and 4 include ground water
recovery and treatment. Based on the current information
available, there is evidence to suggest that natural
degradation/attenuation is occurring. The basic contaminant
35
-------
transport model suggests that both Alternatives 3 and 4 would
require approximately I year from installation to remediate the
plume while Alternatives 1 and 2 would each require 3 year
without construction. Alternative 3 would require on-Site O&M,
including sludge handling, system operators and also provides for
additional treatment at the POTW. Alternative 4 requires
increased on-Site O&M and sludge handling which complicates the
system management and creates a greater risk for on-Site operator
exposure and accidental spillage.
2. Compliance with ARARS
Table 5 presents a comparison of the applicability of the
potential chemical-specific, location-specific, and action-
specific ARARs to each of the four remedial alternatives for the
former BMI-Textron Site. All four alternatives have the
potential to be in compliance with ARARs. Alternatives 1 and 2
rely on natural degradation/attenuation mechanisms to remediate
the impacted ground water. Based on the current information
available, including transport modeling, there is evidence to
suggest that natural degradation/attenuation is occurring.
However, Alternative 1, does not provide a mechanism such as
ground water monitoring to demonstrate compliance with ARARs.
rhe pumping options, Alternatives 3 and 4 will comply with ARARs
through ground water treatment. If the natural remediation
processes, Alternatives 1 and 2, are found to be ineffective in
reducing constituent concentrations, then Alternatives 3 and 4
would, at a minimum, come closer to reaching remediation
standards since these alternatives would remove at least some of
the COPCs.
Part 141, Subparts B,F and G; Maximum Contaminat Levels
(MCLs) and Maximum Contaminant Level Goals (MCLGs) promulgated
under the authority of the SDWA are specifically identified in
Section 121 of CERCLA as well as in the NCP as remedial action
objectives for ground waters that are current or potential
sources of drinking water supply. The ground waters underlying
this Site are classified as Class IIA ground water (i.e., as
potentila sources of drinking water) under the EPA Guidelines for
Ground-Water Classification. MCLs and all non-zero MCLGs aree
'therefore relevant and appropriate for use as remedial action
objectives for ground water cleanup at this Site and will have to
be attained. In that FDEP is authorized to adiminister the SDWA,
the MCLs and non-zero MCLs estabished under FDEP law are the
relevant and appropriate standards for this Site.
3. Long-Term Effectiveness and Permanence
All of the alternatives, with the exception of the
Alternative 1, would reduce potential risks and/or environmental
impacts. The remaining alternatives would utilize ground water
monitoring results to document actual effectiveness.
36
-------
Table 5 . Applicability of Potential ARARs to Each Remedial Alternative for the Former BMI-Textron Site; Lake Park, Florida.
Page 1 of 2
POTENTIAL ARARs
ALTERNATIVE I
NO ACTION
ALTERNATIVE 2
INSTITUTIONAL CONTROLS AND
MONITORING
ALTERNATIVE 3
INSTITUTIONAL CONTROLS. MONITORING.
OROUNOWATER RECOVERY. ON-SITE
TREATMENT. AND OFF-SITE DISCHARGE
ALTERNATIVE 4
INSTITUTIONAL CONTROLS,
MONITORING. GROUNOWATER
RECOVERY. AND ON-SITE TREATMENT
AND DISCHARGE
CHEMICAL-SPECIFIC
ARARS1
1. 40CFR 141.11-141.16 Safe
DrtnWng Water Act Maximum
ContatntnAnt Lsvots.
2. 33 USC12S1 dean Water Act;
Section 303 • water quality
staiNiBrda Including State
water quality ttandards. and
S«cBon 304 • Federal water
Quality criteria.
3. Florida Administrative Code
FAC Me* 17-3 and 17-550
Flofioa drtnWnQ water
standards and monitoring
frequencies for contaminants
Ingroundwater.
According to groundwater modeling
results, this alternative win achieve the
chemical-specific ARARs. but It Includes no
monitoring to demonstrate achievement of
the chemical-specific ARARs.
According to groundwater modeling
results, this alternative will achieve the
chemical-specific ARARs, and It Includes
monitoring to demonstrate achievement of
the chemical-specific ARARs.
According to groundwater modeling
results, this alternative will achieve the
chemical-specific ARARs. and rt Includes
monitoring to demonstrate achievement of
the chemical-specific ARARs.
According to groundwater modeling
results, this alternative will achieve the
chemical-specific ARARs, and rl Includes
monitoring to demonstrate achievement
ol the chemical-specific ARARs.
LOCATION-SPECIFIC
ARARs;
1. 29 USC 651/29 CFR 1910.120
Occupational Safety and
Hearth Act of 1970 worker and
public health requirements.
2. Palm Beach County
Environmental Control Rule 2
requirements for permitting
and Installing wets, mandated
by the Palm Beach County
Public Health Department.
3. Florida Administrative Code
FAC 40(e)3 • South Florida
Water Management District
rules regarding well
construction.
4. FAC Rules 17-4 and 17-531
Regarding permits and water
weds.
None ol these location-specific ARARs are
applicable to this alternative.
AD ol these location-specific ARARs are
applicable to this alternative since It
Includes Institutional controls and
monitoring. Location-specific ARAR No. 1.
Is applicable during monitoring events.
location-specific ARAR No. 4 Is applicable
for construction of the monitoring wells.
and the remaining location-specific ARARs
are applicable as Institutional controls In
limiting the Installation of wells at or near
the former BMI-Textron site.
Alt ol these location-specific ARARs arc
applicable to this alternative since It
Includes Institutional controls, monitoring. ,
and on-slte workers. Location-specific
ARAR No. V Is applicable during
monitoring events and operation of the
treatment system; location-specific ARAR
Nos. 1 and 4 are applicable during
construction and operation ol the
groundwater recovery and treatment
system: and the remaining location-specific
ARARs are applicable as Institutional
controls In limiting the Installation ot wells
at or near the former BMI-Tcrtron site.
AM of these location-specific ARARs are
applicable to this alternative since It
Includes Institutional controls, monitoring.
and on-slte workers. Location-specific
ARAR Ho. 1. Is applicable during
monitoring events and operation ol the
treatment system; location-specific ARAR
Nos. 1 and 4 are applicable during
construction and operation ol the
groundwater recovery and treatment
system: and the remaining location-
specific ARARs are applicable as
Institutional controls In limiting the
Installation ol wens at or near the former
BMl-Textron site.
f:\proJ\pf4S1\arartbl.wS1
-------
Table 5 '.' Applicability of Potential ARARs to Each Remedial Alternative for the Former BMI-Textron Site; Lake Park, Florida.
Page 2 of 2
POTENTIAL ARARs
ALTERNATIVE 1
NO ACTION
ALTERNATIVE 2
INSTITUTIONAL CONTROLS AND
MONITORING
ALTERNATIVE 3
INSTITUTIONAL CONTROLS. MONITORING.
OROUNOWATER RECOVERY. ON-SITE
TREATMENT. AND OFF-SITE DISCHARGE
ALTERNATIVE 4
INSTITUTIONAL CONTROLS.
MONITORING, QROUNOWATER
RECOVERY. AND ON-SITE TREATMENT
AND DISCHARGE
ACTION-SPECIFIC
ARARs:
1. 40 CFR 122.44(8) Use ol best
available or best conventional
pollution control technology to
control poflutants.
2. 40 CFfl 128.41(1) Discharge
monitoring to assure
compliance using test
method* approved under 40
CFR 138.1 • 136.4.
3. 40 CFR 284.601 Design and
operating standards for
miscellaneous unit* In which
hazardous waste Is treated.
4. 40 CFH 122.41(0 Proper
operation and maintenance, of
the recovery and treatment
system.
5. Resource Conservation and
Recovery Act (RCRA)
requirements for shidge
handling and disposal.
6. 40 CFR 403.3 Prohibition of
. discharge of pollutants that
pass through • POTW without
treatment Interfere with POTW
operation, contaminate POTW
sludge, or endanger the health
and safety of POTW workers.
7. City of West Palm Bench
Wastewater Treatmem
System (POTW) ore-treatment
standard* Including monitoring
and reporting requirements.
6. FACRufr 17-520 Qroundwater
classes, standards, and
exemptions regarding
groundwater classification and
criteria for discharge to
groundwater.
9. Palm Beach County Bunding
Department building permits.
Only actlon-speeHIc ARAR No. 8 Is
applicable to this alternative, and the
groundwater at the former BMI-Textron
site Is considered a Class II groundwater.
Only action-specific ARAR No. 6 Is
applicable to this alternative, and the
groundwater at the former BMI-Textron
site Is considered a Class II groundwater.
Action-specific ARARs No. 1. 3. 4. 5. 6. 7.
8, and 9 are applicable to this alternative
with respect to design, construction.
operation, and maintenance ol the
recovery and treatment system: discharge
to the POTW: and groundwater being
considered Class II.
Actlcn-specmc ARARs No. 1. 2. 3. 4. 5. 8,
and 9 are applicable to this alternative
with respect to design, construction.
operation, and maintenance ol the
recovery and treatment system: discharge
to the recharge gallery: and groundwater
being considered Class II.
f:\pror\pMS1\arartbl.w51
-------
Alternatives 2, 3 and 4 would also incorporate institutional
control to protect human health. Alternatives 1 and 2 uses
natural degradation. Alternatives 3 and 4 would accelerate
degradation, once treatment is initiated.
4. Reduction of Toxicitv, Mobility or Volume
Alternatives 1 and 2 would reduce (to some degree) toxicity,
mobility and volume of ground water impacted by COPCs, through
the uses of natural degradation/attenuation of constituents with
time, as predicted by the transport model. Through pumping,
alternative 3 and 4 would contain the area of impacted ground
water while reducing the volume of COPCs. Alternatives 3 and 4
would use ground water recovery to lessen the time frame for
reduction of concentrations to occur, and would limit the
migration of COPC.
5. Short-Term Effectiveness
Alternatives 1 and 2 depend on the natural
degradation/attenuation mechanisms, which ground water modeling
indicates will happen in approximately 3 years. Based on
transport modeling Alternatives 3 and 4 may achieve remediation
standards in approximately 1 year following construction of the
treatment system. However, prior to completion of construction
activities EPA will negotiate a Consent Decree with Textron, a
design would be prepared, and the system must be built. These
activities could take up to two years to complete.
Consequently, based on the relative time fo/r remediation,
Alternatives 3 and 4 would be similar to that of Alternative 2.
Alternative 3 and 4 have some inherent risks related to ground
water handling and discharge which Alternatives 1 and 2 do not
have. These risks which potentially include such things as
accidental spillage of impacted water, pass-through of untreated
water, and potential exposure to on-Site system operators, would
be considered when developing a Health and Safety Plan for
construction activities.
6. Implementabilitv
Alternative 1 is the easiest to implement, yet it provides
no protection of human health and environment. Alternatives 2 is
also easily implemented. This alternative relies on
institutional controls that are already in place and enforced by
PBCHD, SFWMD, and FDEP. Furthermore, a network of monitoring
wells already exists both on-Site and off-Site to periodically
sample and analyze ground water for COPCs. Alternative 3 is
similar to alternative 4, however, implementation is contingent
upon: 1) approval from the cities of Lake Park and Riviera Beach
for accessing the public right-of-ways adjacent to Reed Road and
Silver Beach Road, for installation of the pipeline from the Site
to the nearest manhole; 2) approval from Riviera Beach Utilities
39
-------
to tie-in and discharge to their manhole; 3) approval from the
City of West Palm Beach POTW to discharge ground water to their
facility, and 4) enforcement of institutional controls and
obtaining deed restrictions. In addition, system operation
maintenance would require trained personnel assigned to run the
system. Implementation of alternative 3 is contingent upon
enforcement of institutional controls, 1.5 years for system
design, POTW approval, EPA approval, and construction. This
system would also require trained personnel assigned to run the
system.
7.
Cost
A summary of the present worth costs, including O&M, for
each of the alternatives is presented below:
Alternatives
Alternative I
Alternative 2
Alternative 3
Alternative 4
Total Cost
$0
$253,800
$755,000
$654,200
8.
State Acceptance
The State of Florida, as represented by the FDEP, has been
the support agency during the Remedial Investigation and
Feasibility Study process for the BMI-Textron Site. In
accordance with 40 CFR 300.430, as the support agency, FDEP has
provided EPA with input during the process. Based upon comments
received from FDEP, it is expected that written concurrence will
be forthcoming; however, a letter formally recommending
concurrence with the preferred remedy has not yet been received.
9. Community Acceptance
There have been very few comments from the local community.
Comments indicated that residents wish to remain informed of the
progress of remedial efforts.
8.2 Synopsis of Comparative Analysis of Alcernatives
All of the alternatives, with the exception of the "No
Action", would provide acceptable degrees of overall protection
40
-------
of human health and environment and would comply with ARARs.
Alternative 2 is considered the best alternative based on the
criteria used to evaluate remedies. This alternative is believed
to be pro-tective of human health and the environment, would
attain ARARs, and is cost effective.
9.0 Selected Remedy
Based upon consideration of the requirements of CERCLA, the
NCP, the detailed analysis of alternatives and public and state
comments, and the results of the RI report, EPA has determined
that no active remediation is necessary for the soil at the Site.
With respect to ground water cfontamination, the previous data
gathered from Textron along with the RI/FS and Risk Assessment
results indicated that natural degradation/attenuation is
occurring at the Site. However, because the future potential
risk to human health and the environment from exposure to
contaminated ground water at the Site is at a level which EPA may
consider taking action, the ground water at and around the Site
will be monitored quarterly for one year to confirm that the
modelled decrease of contaminant concentrations to the drinking
water standards are indicative of an actual decrease of
contaminants on the Site. Quarterly monitoring for the first
year. During the remaining two years EPA would conduct an annual
review of monitoring frequency will be conducted. Selected wells
within the existing monitoring well network would be used to
provide confirmation of historical data and modeling transport
data that indicates the COPCs will naturally degrade and/or
attenuate with time. The monitoring program also would be used
to provide confirmation that no off-Site migration of COPCs at
concentration greater than the remediation goals is occurring.
The total present worth cost of the selected remedy, is
estimated at $253,800. There is no capital cost associated with
this remedy. However, total annual O & M is $79,200, present
worth of annual O&M cost is $207,800 and present worth of
verification of goals cost $46,000.
A. Ground Water Remediation
Natural degradation/attenuation will be the method of ground
water remediation. The progress of this natural attenuation will
be monitored with periodic ground water sampling. Existing
institutional controls will be relied upon to protect against
possible exposure to contaminants and to confirm that the Federal
and State standards are obtained. Monitoring will use existing
wells and, if necessary, the construction of additional wells.
Ground water usage will be restricted via institutional controls
until such time as ground water reaches the goals specified in
9.A.2. for a minimum of two consecutive monitoring events.
41
-------
A.1 Components of Ground Water Remediation for
Implementation
a. -Institutional controls for the former BMI-Textron Site
consist of existing regional well control which
includes restrictions and permitting requirements for
installation of any water supply wells in the vicinity
of the impacted areas.
b. Ground water monitoring of the COPCs would be
implemented to track the movement and natural
attenuation degradation of the COPCs.
A.2 Performance Standards
The cleanup standards for the BMI-Textron Site are
presented in the following table.
BMI TEXTRON Site GROUND WATER REMEDIATION STANDARDS
GROUND WATER
Arsenic
Sodium . •'
Cyanide
Fluoride
Federal
H9/L
50
—
200
4000
State
H9/L
50
160,000
200
4000
Note: MCL - Maximum Contaminant Level
— No Federal Standard Exists
It may become apparent during the implementation of this
alternative that contaminant levels have ceased to decline and
are remaining constant at levels higher than the above standard.
In such a case, EPA in consultation with FDEP, may re-evaluate
the protection afforded by this alternative.
B. Compliance Testing
During the 3 years, ground water will be monitored quarterly
for one year to verify modelled decrease of contaminate
concentration. During the remaining two years EPA would conduct
42
-------
an annual review of monitoring frequency. Selected wells within
the existing monitoring well network would be used to provide
confirmation of historical data and modeling transport data that
indicates ..the COPCs will naturally degrade and/or attenuate with
time. The monitoring program also would be used to provide
confirmation that no off-Site migration of COPCs at
concentrations greater than the above remediation goals is
occurring. However, should monitoring indicate that the Site has
contaminants at concentrations greater than standards, EPA in
consultation with the State of Florida, will reconsider the
protectiveness of the "Institutional Controls and Monitoring"
alternative .
10 . 0 Statutory Determinations
EPA has determined that the selected remedy will satisfy
the statutory determinations of Section 121 of CERCLA. The
remedy will be protective of human health and the environment,
will comply with ARARs, will be cost effective, and will use
permanent solutions to the maximum extent practicable.
10.1 Protection of Human Health and The Environment
A ground water monitoring remedy has been chosen to protect
human health and the environment by confirming that contaminants
are being reduced or by alerting EPA of potential further
migration of the contaminated ground water and by monitoring the
contaminant concentrations in ground water until the
concentrations are less than or equal to the Performance
Standards. Compliance with MCLs will be protective at this Site.
The long-term cancer risk associated with possible ingestion of
ground water will be reduced to within EPA's acceptable risk
range of IxlO"4 and IxlO"6 and the non-carcinogenic risk would be
reduced to the EPA goal of 1 . Periodic ground water monitoring
will be conducted to evaluate the performance of the natural
degradation/attention process.
10 .2 Compliance with ARARs
Implementation of this remedy will comply with all Federal
and State ARARs and will not require a waiver. The natural
degradation/attenuation mechanism will meet the ground water
performance standards noted in Section 9. A. 2, which are based on
Federal and State MCLs. Federal and State MCLs are considered
relevant and appropriate in the cleanup of contaminated ground
water .
10 .3 Cost -Effectiveness
The selected remedy. Alternative 2, is a cost effective
remedy. The total estimated present worth cost of this
alternative is $253,800, which includes implementation and annual
43
-------
operation and maintenance costs. EPA has determined that the
cost of implementing the remedy is appropriate given the
potential threat posed by the contaminated ground water.
10.4 Use of Permanent Solutions and Treatment Technologies
The selected remedy uses natural degradation/attenuation
mechanisms to reduce the toxicity, mobility, and volume of
contaminants in ground water.
10.5 Preference for Treatment as a Principal Element
The statutory preference for treatment will not be met, because
the selected remedy does not contain an actual treatment.
However, the selected remedy does include Site monitoring to
ensure that the natural degradation/attenuation is occurring and
migration of contaminants does not exist.
11.0 Documentation of Significant Changes
The remedy described in this Record of Decision is the
preferred alternative described in the Proposed Plan for this
Site. There have been no significant changes in the selected
remedy.
44
-------
APPENDIX
-------
RESPONSIVENESS SUMMARY
The -U.S. Environmental Protection Agency (EPA) held a public
comment period from April 18 to May 17, 1994 for interested
parties to comment on EPA's Proposed Plan for the BMI-Textron
Site, which addressed contaminated ground water. During the
comment period, EPA conducted a public meeting at the Riviera
Beach Municipal Complex, in Riviera Beach, Florida on April 21,
1994. During this meeting, representatives of EPA presented the
results of the studies undertaken at the Site and EPA's preferred
alternative for addressing ground water contamination.
A summary of EPA's response to comments received during the
public comment period, known as the responsiveness summary, is
required under Section 117 of CERCLA. EPA has considered all of
the comments summarized in this responsiveness summary in
determining the final selected remedy presented in the Record of
Decision.
This responsiveness summary consists of the following sections-.
A. Background of Community Involvement and Concerns: This
section provides a brief history of community interest
and concerns regarding the BMI-Textron Site.
B. Summary of Manor Questions and Comments Received During
the Public Comment Period and EPA's Responses:
A. Background of Community Involvement and Concerns
In accordance with Section 113 and 117 of CERCLA, EPA has
conducted community relation activities at the BMI-Textron Site
to ensure that the public remains informed on the Site
remediation progress. During the numerous investigative
activities, EPA held meetings and telephone conversations with
city and state officials to advise them of the progress of
activities at the Site.
A community relation plan (CRP) was developed in 1993 to
establish EPA's plan for community participation during the
remedial activities. Prior to the initiation of the Remedial
Investigation/Feasibility Study" (RI/FS), EPA held an Availability
Session in West Palm Beach, Florida to present to the public the
activities scheduled for the RI. Following completion of the
RI/FS, a Proposed Plan fact sheet was mailed to local residents
and public officials in April 1994. The fact sheet detailed
EPA's preferred alternative for addressing the source of
contamination at the BMI-Textron Site. Additionally, the
Administrative Record for the Site, which contains Site related
documents including the RI and FS reports and the Proposed Plan,
was made available for public review at the information
repository in the Lake Park Library. A notice of the
-------
availability of the Administrative Record for the BMI-Textron
Site was published in the Palm Beach Post Newspaper, which serves
Lake Park, Riviera Beach and other surrounding areas, on April
17, 1994, and again on April 24, 1994.
A 30-day public comment period was held for April 18, 199.4, to
May 17, 1994, to solicit public input on EPA's preferred ground
water remediation alternative. Written comments were received
from representatives for Textron Inc. only. Textron agreed with
the selected remedy, but asked for clarification on EPA's
interpretation of the preferred ground water alternative.
In addition to the comment period, EPA held a public meeting
in Riviera Beach, Florida on April 21, 1994, at the Riviera Beach
Municipal Complex to discuss the remedial alternatives under
consideration and to answer any questions concerning the Proposed
Plan for the BMI-Textron Superfund Site. The meeting was
attended by several concerned citizens and representatives of
Textron Inc. EPA's response to the comments received at the
meeting and Textron's written comments are summarized in Section
II below. Additionally, a transcript of this public meeting was
prepared by a certified court reporter, and this document is a
part of the Administrative Record upon which the remedy selected
in the Record of Decision is based.
Following the issuance of the final Record of Decision, EPA
will continue to keep the community informed about progress at
the site through fact sheets and informational meetings as
needed. Additional, design and construction documents pertaining
to the implementation of the ground water remedy will be placed
in the information repository at the Lake Park Library.
,B. Summary of Manor Questions and Comments Received During the
Public Comment Period and EPA's Responses
1. Comment:
The Proposed Plan indicates that Site monitoring would occur over
a three-year period, based on the ground water modeling performed
for the Site. Will remediation standards be reached within that
time period.
Response:
A numerical transport model called SEFTRAN was used to simulate
the movement of contaminant of potential concern (COPC). The
SEFTRAN model is a two-dimensional ground water flow and
contaminant transport model developed to simulate the movement of
contaminants in two dimensions through time in response to ground
water flow. This model reflects a relative comparison of
remedial alternatives and does not necessarily reflect the actual
remedial periods. Site monitoring will be performed for an
-------
anticipated period of three years, however, that period may be
modified based on certain decision criteria. For example, if
after three years, the remedial standards have not been met and
off-Site .concentrations of contaminants of concern reflect an
increase which is likely to exceed remedial standards, EPA would
consider if additional clean-up should take place. The three-
year monitoring period is the time-frame for evaluating changes
in water quality and will not necessarily preclude implementation
of further actions.
2. Comment:
How often will the monitoring occur?
Response
During the 3 years, ground water will be monitored quarterly for
one year to verify modelled decrease of contaminant
concentration. During the remaining two years EPA would conduct
an annual review of monitoring frequency. Selected wells within
the existing monitoring well network would be used to provide
confirmation of historical data and modeling transport data that
indicates the COPCs will naturally degrade and/or attenuate with
time. Any modifications to frequency will be determined by
sampling data.
3 . Comment:
The Proposed Plan states that the monitoring should sample for
cyanide, fluoride and sodium. The commentor did not feel sodium
was related to operations at the Site. Although the
concentrations of sodium are above the state standard, the
concentrations are restricted to a small portion of the Site and •
do not pose a threat to public health or the environment. Why
should this constituent being sampled for when the State of
Florida has been known to waived the State maximum contaminant
level for sodium.
Response:
Sodium was listed as a COPC by the baseline risk assessment
during the RI because in high volumes sodium has been known to
cause problems with human health (i.e. elevated blood pressure).
The State of Florida has not waived the contaminant level for
sodium on this Site.
4. Comment:
The Proposed Plan states that institutional controls applicable
to the Site consist of "the use of existing regional well
controls, and the continuance of FDEP deed restrictions." What
-------
deed restrictions have been imposed on the Site and who has the
authority to do so?
Response:
The restrictions for the site apply to existing regional well
controls to restrict site usage, administered through state and
local agencies. The FDEP is responsible for notifying regulatory
personnel in the SFWMD and the PBCHD of the existence of any
CERCLA or RCRA sites within their respective jurisdiction,
including the BMI-Textron site. Consequently, the permitting
officials would be expected to deny permit applications for
installation potable water wells in the impacted area of the
surficial aquifer.
5. Comment:
How long will Alternative 4 take?
Response:
Following signature of the Record of Decision (ROD) EPA would
negotiate with Textron to conduct the design and construction of
the selected alternative. Remedial deoo.^n for this alternative
is expected to take up to 18 months. Ground water transport
model indicate the remedial standards would to occur within 1
year of installation. Therefore, the cleanup goals could be
reached as soon as 2 1/2 to 3 years from ROD.
6. Comment:
Are there any of potential harmful effects to people that
formerly worked at BMI Facility?
Response:
The primary pathway of exposure or route of exposure in which a
person could come in contact with the COPCs is oral contact. This
means that for a person to be exposed to potentially harmful
compounds the person would have to consume the contaminated
ground water from the site. However, local potable water
supplies obtain their water from uncontaminated sources that are
safe from contamination by the BMI-Textron Site.
7. Comment:
Is there any danger to the residential area south of the Site?
Response:
According to data gathered during the RI, the area of the wells
that showed contamination are east/northeast of the residential
-------
area. Our RI further showed that the area of contamination is
limited to on site. To the north, west and east are industrial
areas which are on city water supply and the nearest residential
area is located to the south which also have city water supplied.
8. Comment:
Is the problem at BMI-Textron Site along the same lines as the
problem found at Soletron?
Response:
No. The two sites are a great distance away from each other and
contain different COPCs. The BMI-Textron Site risk is due to
inorganics percolating into the ground water. Soletron was an
accidental spilling of volatile organics into a sanitary water
system and is being addressed by FDEP.
9. Comment:
Given the location of the Transcircuit Facility and the
similarities of the chemicals associated -A/ith both the BMI and
Transcircuit Facilities, could Trancircuit be the source or
partial source ^f the ground water contamination?
Response:
The Transcircuit facility is located crossgradient to
downgradient (depending on the pumping of the city wells) from
the BMI-Textron Site. The RI has not shown evidence of any kind
of contaminants in the areas that might join the BMI-Textron and
Transcircuit Facilities together. BMI-Textron contains metals
while the Transcircuit Facility contains metals and volatile
organic compounds as contaminants. Our data has not shown metal
and organic contaminants together. Also, the area of
contamination indicated by the RI is located approximately 300
feet downgradient from the Transcircuit Facility.
------- |