Environmental Protection
Agency
Emergency end
Remedial Response
tPA/ROD/R04-82/001
September 1982
Superfund
Record of Decision:
Miami Drum Services
Site, FL
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TECHNICAL REPORT DATA
(Please read InstructIOns on Jhe re~'erse before comr/etlng;
1. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO
EPA/ROD/R04-82/001 -
4. TITLE AND SUBTITLE 5 REPORT DATE
09/13/82 I
SUPERFUND RECORn 0'P DECISI0N
Miami O,rum Services Site, FL 6. PERFORMING ORGANIZATION CODE
7. AUTHORCSI 8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT ~O
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U. S. Environmental Protection Agency pin::.l Rlln D=~~~+-
401 M Street, S.W. 14. SPONSORING AGENCY CODE
Washington, D.C. 20460
800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Miami Drum Services site is a one acre inactive drum recycling
facility located in Dade County, Florida. The soils on site were con-
taminated by phenols, heavy metals, oil and grease, pesticides, and
other materials from the drum cleaning operation. A plume of unde-
ter:nined composition has been identified in the groundwater underlyi,
the are a, which has a high (one to three feet) water table. A 1981
suit, filed by Dade County against MDS, I nc ., seeks injunctive
relief, recovery of all funds spent for site cleanup, compensatory
damages for harm to natural resources, and punitive damages.
The cost-effective remedial alternatives selected for this site
includes: soil excavation to the extent dictated by engineering and
scientific judgment, and transportation and off-site disposal of
contaminated soils, as the First Operable Unit. The Second Operable
Unit will address the groundwater contamination plume through a
cooperative agreement work plan to conduct an RI/FS. The capital cost
for the selected alternative was estimated to be $1,568,660.09.
17. KEY WORDS AND DOCUMENT ANAL YSIS
a. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
--
Record of Decision
Miami Drum Services Si te, FL
Key contaminants: solvents, heavy
metals, oil and grease, pesticides,
mercury
Contaminated media: gw, soil
18. DISTRIBUTION STATEMENT 19. SECURITY CLASS (T/us Report) 21. NO. OF PAGES
None 8
20. SECURITY CLASS (This pagel 22 PRICE ,
None
EPA Form 2220-1 (Ru. 4-77)
PREVIOUS EDITION IS OBSOLETE
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"
INSTRUCTIONS
REPORT NUMBER .
Insert Ihe EPA reporl number as it appealS on Ihe cover of Ihe publil:alion,
2.
3.
LEAVE BLANK
RECIPIENTS ACCESSION NUMBER
Reserved for use by eadl reporl recipient.
4.
TITLE AND SUBTITLE
Title should indicale dearly and briefly Ihe subje!:1 !:overa~!: of Ihe reporl, and be disl,lay,'d promin..nlly. S,'I slIhlilk, if IIS."I, ill ~mali.'r
type or otherwise subordinale illo main lille. When a report is prepared in mon° Ihan un,' v'llum!:, r",,,,allh,' primary IiiI.'. ...1.1 vullllm'
number and include subtitle for the specific lille,
6.
REPORT DATE
Each report shaU cury a.dale indica ling alleasl monlh and year. Indkale Ihe hasis 011 whkh il \\a.. ,de,'I,'d (I'.t>:.. Jtllc' i'l;uICc', Jtllc' ell
tlpprolltll. dillt 01 prtfKlrGlion. tIC.),
PERFORMING ORGANIZATION CODE
Leave blank,
8.
7.
AUTHORISI
Give name(sl in convenlional order (John R. Doc, J. Robal Doc', ('11'.), lisl aUlhor's affilialloll if il .lilh'rs frum Ih., I,,'rfurminj: ,"'j:ani.
zation.
8.
PERFORMING ORGANIZATION REPORT NUMBER
Insert if performing organization wishes 10 assign Ihis number.
9.
PERFORMING ORGANIZATION NAME AND ADDRESS
Give name. streel. cily. slale, and ZIP code. lisl no more Ihan Iwo levels of an or~anilaliollal hir!:ard.y,
10. PROGRAM ELEMENT NUMBER
Use the program elemenl number under whi!:h the report was pr!:pared, Subordinale numb.:r, ilia)' be indl",,"d III "ar"lIlh,'"",
11. CONTRACT(GRANT NUMBER
Insert conUact or granl number under which report wa~ prepared.
12. SPONSORING AGENCY NAME AND ADDRESS
Include ZIP code,
13. TYPE OF REPORT AND PERIOD COVERED
Indicale interim final, etc,. and if applicable. dales covered,
14. SPONSORING AGk:NCY CODE
Insert appropriate code.
16. SUPPLEMENTARV NOTES
Enter information not included elsewhere bUI useful, such as:
To be published in. Supersedes, Supplements. eiC.
16. ABSTRACT
Include a brief (200 words or less) faclual summary of the mosl sillnifi,'anl informalion ,'onlaim'd ", 110,' "'I'url. II Ih,' "'1'011 "'"11;""' a
significant bibliography or literature survey. mention il here,
Prepared ill ...ooperalion wllh, '( ran,la 111'" .., , 1"""'111".1 al ""111"1\'11\,\' ,.1,
17. KEV WORDS AND DOCUMENT ANAL VSIS
la) DESCRIPTORS. Seleel from the Thesaurus of Engineerir.1! and S...ienlilk Terrm Ihe proper aulh..,i,,'d krill' Ihalldenlify Ihe majur
concepl of Ihe research and are sufficienlly specific and precise to be u~ed as inde!o, enlrie~ for .....Ialoj:lnj:.
(b) IDENTIFIERS AND OPEN,ENDED TERMS, Use identifiers for projeci nam..s, cude names, eljulpmenl dC'Ij:nalors, elc, Usc 0l'en.
ended terms written in descriptor form for those subjects for which no descriplor exists.
(c) COSA TI FIELD GROUP, Field and group assignments are to be laken from the 1965 COSh TI Suhj,'," ('all'j!ury Ust. Sine.. Ihe nla.
jority of documenls are multidisciplinary in nature. Ihe Primary Field/Group assignmenlfs' win be spl"'in,, dis...plin,', arl'a III' hUllwn
endeavor. or Iype of physical object. The applicalion(s) will be crus~.rcferenced wilh SCl'ondary I idd/( ;rlllll' a"'j:lUnell" Ihal lA'ili fullulA
the primary posling(sl,
18. DISTRIBUTION STATEMENT
Denote releasabilil)' 10 the public or limilalion for reasons olher Ihan security for example "Kekasc 1;"hlllill"I." ('ii" allY avail;II,ilil)' 10
the public, wilh address and price,
19..20, SECURITY CLASSIFICATION
DO NOT submit classified reports 10 the Nalional Technicallnformalion servil:e.
21. NUMBER OF PAGES .
Insert the lotal number of pages, including Ihis one and unnumbered pages, bUI exclude dislribuliun IiSI, it any.
22. PRICE
Insert Ihe price set by Ihe National feehnicallnformation Service or Ihe Governmenll'rinling Office, if known,
EPt. Form 2220-1 (Rn, .-77) (R....,..)
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Record of Decision
Remedial Alternati.ve Selection
Site:
Miami Drum Services, Dade County, Florida
Analyses Reviewed:
I have reviewed the following documents describing the analysis of cost
effectiveness of remedial alternatives for -the Miami Drum site:
- Report titled -The Feasibility of Abating the Source of Ground Water
Pollution at Miami Drum Services, Dade County, Florida,- December 8,
1981.
- Report titled MEva1uation of the Cleanup Activities Already -
Undertaken at the Miami Drum Services Hazardous Waste Site, Dade
County, Florida," September 1, 1982.
Staff summaries and recommendations
- Recommendation by Florida Department of Environmental Regulation
Declarations
Consistent with the Comprehensive Environmental Response, Compensation
and Liability Act of 1980, and the National Contingency Plan, I have
determined that the excavation of contaminated soils and debris and their
transportation to an EPA approved landfill for secure burial provides an
appropriate level of clean up. The action taken is a cost-effective remedy,
and it effectively and reliably mitigates and minimizes damage to, and
provides adequate protection of public health, welfare and the environment.
I have also determined that the action taken is appropriate when balanced
against the need to use Trust Fund money at other sites. In addition, the
chosen remedy complied with the requirements of section 101(24) of CERCLA
because off-site disposal is more cost-effective than potential on-site
remedies.
/)
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Rita M. - Lave,',e
Assistant Administrator
Office of Solid Waste & Emergency
Response
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTONj"C.C. 20460
SEP , 3 lSS2
OFFICE OF
SOL.IO WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT:
Record of Decision for the Miami Drum Services
Site, Dade County, Florida.
William N. Hedeman, Jr., Director~.nO ~-'A~~
Office of Emergency and Remedial ~~S~8j
Rita M. Lavelle, Assistant Administrator
Office of Solid Waste and Emergency Response (WH-S62-A)
FROM:
TO:
I am forwarding for your approval a Record of Decision for the Miami
Drum Services Site. The Record of Decision is based upon our review of the
remedial action undertaken by Dade County during December 1981 through
January 1982. The findings conclude that the remedial action provides an
adequate level of clean-up to effectively mitigate and minimize damage to,
and provides adequate protection of public health, welfare and the
envi ronment.
Further, the actions taken are consistent with CERCLA program
If you feel the need for a briefing on the contents of the
requirements.
Record of Decision, I can do 50 at your convenience.
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Executive Summary
Record of Decision
Mi ami Drum Se rvi ces ~ Dade County, Flori da
During December 1981 through January 1982, Dade County proceeded with
the excavation and disposal of highly contaminated soils at the Miami Drum
Services, Inc. site. The State submitted a cooperative agreement on
December 11, 1981 and a request for a deviation from the Grant Regulations
to allow pre-award costs to be paid upon final award. A Superfund
allocation for the pre-award costs and for a feasibility study was approved
in an Action Memorandum on June 1, 1982. The award is based upon the
. satisfactory completion and acceptance by the State of several conditions
described in a memorandum from Rita M. Lavelle, Assistant Administrator for
Solid Waste and Emergency Response to Charles R. Jeter, Regional
Administrator, Region IV, of June 2, 1982. The Record of Decision provides
EPA's determination that the remedial action undertaken by Dade County was
conducted in accordance with CERCLA program requirements meeting the first
condition of the June 2nd memorandum.
The Record of Decision contains the following information:
.
Briefing Sheet summarizing the technical findings and conclusions
of the Dade County remedial action
Action Memorandum dated June 1, 1982, allocating Superfund monies
to the Miami Drum site
Memorandum dated June 2, 1~82 concerning the approval of CERCLA
expenditures at the Miami Drum Services Site and outlining the
conditions that must be met
.
Memorandum dated July 8, 1982, from William N. Hedeman requesting
a deviation from 40 CFR Part 30.345 (4) to allow pre-award costs
Memorandum from Charles R. Jeter dated August 26, 1982, providing
Region IV's concurrence with the technical evaluation report on
the Dade County remedial action .
.
Memorandum from Terry Cole, Assistant Secretary, State of Florida
Department of Environmental Regulation, dated September 1, 1982,
providing the State's acceptance and approval of the technical
evaluation report on the Dade County remedial action.
Final Report -Evaluation of the Clean-up Activities Already
Undertaken at the Miami Drum Services Hazardous Waste Site, Dade
County, Florida,. September 1, 1982
.
Field Investigation Team report, -The Feasibility of Abating the
Source of Ground Water Pollution at Miami Drum Services, Dade
County, Florida,. December 8, 1981
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Miami Drum Services
Dade County, Florida
Briefing Sheet
Purpose
o The purpose of this briefing is to request approval for the remedial
action recommended by Region IV and the State of Florida for the Miami
Drum Site. A IIRecord of Decision" has been prepared to document this
approval. This presentation completes the first condition contained in
the Lavelle to Jeter memorandum of June 2, 1982.
Background
o Miami Drum Services (MDS) is an approximately 1 acre inactive drum
recycling facility. The soils were contaminated by phenols, heavy
metals, oil and grease, pesticides and other materials from the drum
cleaning operation. Resistivity measurements identified a plume of
undetermined composition in the ground water underlying the area.
o In April 1981, Dade County filed a suit against Miami Drum Services, Inc.
for cleanup of the site. The court granted the County preliminary relief
and ordered the company to cease operations. Miami Drum Services
subsequently filed a motion to dismiss the case. The motion was denied,
but the company appealed the denial. The County.s suit against Miami
Drum seeks injunctive relief, recovery of all funds spent for cleanup,
compensatory damages for harm to natural resources, and punitive
damages.
Technical Summary
o Given the potential for protracted litigation, there existed an urgent
need for source control action at the site because of:
(1) the serious danger to public health and welfare presented by the
contaminated drums still on site;
(2) the absence of an effective drainage control system;
(3) the amount and -form of hazardous substance present at the site;
(4) the leachable properties of these substances;
(5) the risk of contamination of the drinking water supplies of Dade
Cou nty ;
(6) the hydrogeology of the area which helps in accelerating the
migration of hazardous substances into the aquifer and local
surface water bodies;
(7) the prevailing weather conditions (rainfall) contributing to the
leaching process; and
(8) the absence of natural or man-made barriers at the site to contain
the contamination. .r
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2
o A number of remedial alternatives were considered in the initial
screening. Alternatives identified fell into four general categories:
- No action
- Onsite containment
- Onsite treatment
- Offsite removal and
disposal
A feasibility study performed by an EPA contractor recommended excavation
and relocation of.the contaminated materials to an existing and approved
disposal facility. The no action alternative was determined not to be
protective of public health. Onsite containment was evaluated, but because
of the high ground water table (one to three feet from the surface), the
depth to an aquaclude (100 feet or more), and the solution cavity nature of
the soil, a containment wall would have adverse environmental effects as
well as having serious constructabi1ity problems. Onsite treatment would
involve incineration of the soil and, because the heavy metals would remain.
disposal of the residue. After the expense of incineration, fully 75~ of
the soil volume would still have to be disposed off-site.
o Two levels of cleanup were investigated to determine the most cost
effective remedy:
(c)
Soil Excavation to Extent Dictated by Engineering and
Scientific Judgement
Cost
$1,568,660.09
(d)
Excavation of Soils In Excess of 10 times the State of Florida
"minimum criteria" for Ground Water Based on EP Toxicity
Tests.
Cost
$2,314,000.00+
Alternative C was implemented. The primary difference between C and D is
that D would have required the removal of an additional 3900 cubic yards of
mercury contaminated soil. The soil on the site is more alkaline than the
conditions specified for the EP toxicity test and it was judged that the
mercury would not be as prone to leach from this more basic soil.
Each alternative was determined to effectively mitigate damage to, and
provide adequate protection of public health, welfare and the environment.
o The recommended alternative includes excavation and transportation
offsite of contaminated soil s. The total (unaudited) cost for this is
$1,568,660.09.
o The "Record of Decision" certifies that:
- The selected remedy is a cost effective action for the site
- Monies are available in the Fund to finance the remedy
- Off-site disposal is more cost effective than potential on-site
remedies
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3
Status of Remaining Conditions
o Progress has been achieved in complying with the remaining three
conditions contained in the June 2, 1982 memo:
1. An audit must be performed by the EPA Inspector General to determine the
exact amount of eligible and allowable project costs incurred by Dade
County for the surface cleanup. ,The audit has been performed and a final
report is in preparation. Special language in the' cooperative agreement
will condition the level of funding on the final determination by the
Inspector General..
2. The proper grant procedures for the award of a cooperative agreement must
be completed, including the processing of a deviation from EPA grant
regulations to permit allowable costs prior to execution of the
cooperative agreement. The proper procedures, including a deviation from
EPA grant regulations, have been followed.
3. Use of CERCLA funds to reimburse 90 percent of Dade County's surface
cleanup expenses is conditioned on the County's assigning to EPA its'
claim againt' Miami Drum Services, Inc., up to the amount of reimbursement
from the Fund. Depending on the County's desires, this can be handled'in
one of several ways. The County can dismiss without prejudice its claim
against Miami Drum Services, Inc. and seek a stay of the remaining
proceedings while the Federal government pursues cost recovery.
Alternatively, EPA, the County and perhaps the State, may enter into an
agreement whereby the County will agree to repay the Fund if a monetary
award is obtained from Miami Drum Services in the County's proceedings.
This condition has been addressed as a grant special condition which must
be met before money can flow to the State/County.
Second Operable Unit
o The cooperative agreement work plan includes a remedial investigation and
feasibility study to address the plume identified by resistivity
measurements. Depending on the results of this work, the State may wish
to ammend the cooperative agreement to implement a remedy.
Follow-up Actions
o The following actions are required to move the project to the stage where
the County can receive money from the fund for the action taken:
- approve the remedy -- AA, OSWER
- consumate State Superfund Cooperative Agreement-- Headquarters/Stat~
- Fulfill special conditions -- Region/State/County
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