United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R04-90/062
July 1990
Superfund
Record of Decision:
Munisport Landfill, FL
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50272-101
REPORT DOCUMENTATION 11. REPORT NO.
PAGE EPA/ROD/R04-90/062
2.
3. Reclpient'a Acc:e88lon No.
4. TlII8 and SubIIII8
SUPERFUND RECORD OF DECISION
Munisport Landfill, FL
First Remedial Action - Final
7. Au1hor(a)
5. Report D8t8
07/26/90
6.
8. Perfonring Organization Rept. No.
8. Perlonring Orgelnizatfon Narne end Addr..a
10. Projec:tlTaaklWork Unil No.
11. Conltac:t(C) or GrantlG) No.
Ic)
(G)
12. Sponaoring OrganlZ8lion Narne and Add....
U.S. Environmental Protection
401 M Street, S.W.
washington, D.C. 20460
13. Type 01 Reporl & Period Covered
Agency
800/000
14.
15. Supp""""\ary No.8
16. Ab8tracl (Umll: 200 worela)
The 291-acre Munisport Landfill site, including a 170-acre, inactive municipal landfill,
is within the city of North Miami, Dade County, Florida. The site is adjacent to the
State Mangrove Preserve, a wetlands area that is tidally connected to Biscayne Bay. To
minimize contaminated surface water runoff from the landfill, a dike was installed
through the Mangrove swamp at the southeast edge of the site. This dike has
hydrologically altered the fauna and flora of the inland wetlands area. The Biscayne
aquifer underlies the Munisport property and is the sole source of drinking water for
Dade County; however, the ground water in the portion of the aquifer located directly
under the site is non-potable due to high salt concentrations. The city of North Miami
leased 291 acres to Munisport for recreational development in 1971 which begin filling
low-lying areas of the site with clean fill and construction debris. In 1975, a
temporary permit allowed solid waste to be used as fill above the water table However,
in 1976, a State inspection found twelve 55-gallon drums that were leaking wastes
onsite; a violation was issued, and these drums were removed offsite by the city. In
1977, Munisport applied for a 404 permit modification to dump additional solid wastes in
the wetlands. EPA opposed the modification and in 1981, issued a CWA 404(c) veto
(See Attached Page)
17. Documenl Ana/yal8 L Deacriptora
Record of Decision - Munisport Landfill, FL
First Remedial Action - Final
Contaminated Medium: gw
Key Contaminants: VOCs (benzene, toluene), other organics,
chromium, lead), and other inorgariics
metals (arsenic,
b. IdenlifieralOpen-Ended T erma
Co COSA TI ReldlCiloup
18. Ayallability Statement
18. Secwlty Claaa (Thla Report)
None
21. No. 01 Pign
185
I
20. Security Cia.. (Thia Plge)
None
22. Price
(See ANSI Z38.18)
See Inatrucuona on Reve-
I"ORM 272 (4-11)
(Formerly NTl5-35)
DepartmenlofComnMKCe
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EPA/ROD/R04-90/062
Munisport Landfill, FL
First Remedial Action - Final
Abstract (continued)
followed by an Administrative Order (AO) that prohibited any additional filling and
required removal or realignment of the diking at the Mangrove Preserve to restore the
altered wetland area. In 1981, the State directed Munisport and the city to provide
final closure of the landfill. Landfilling operations ceased in 1981, but closure has
not yet taken place. Leachate from the landfill waste still poses a significant
threat to the aquatic organisms in the Mangrove Preserve. The ground water is no
longer used for potable purposes as a result of salt water intrusion. The
contaminants of concern affecting the ground water include VOCs such as benzene and
toluene; other organics; metals, such as arsenic, chromium, and lead; and other
inorganics.
The selected remedial action for the site includes intercepting, collecting, and
treating the leachate-contaminated ground water prior to its emergence into tile
Mangrove Preserve, with onsite discharge of treated ground water; initiating landfill
closure proceedings by the State; conducting hydrologic, water quality, and
treatability studies as part of the remedial design. Based on the studies, the less
favored alternative remedy may include intercepting the leachate-contaminated ground
water plume by constructing a hydraulic barrier using negative pressure; treating the
contaminated ground water with air stripping, adjusting the pH, and discharging the
treated effluent into onsite shallow subsurface trenches or onsite surface water to
enhance the treatment process; and making hydrologic improvements to the Mangrove
Preserve and the altered wetlands. Alternatively, the site may be treated by using
positive infiltration to provide the hydraulic barrier, biological treatment to reduce
the contaminants, and discharging treated effluent to an onsite trench to maintain a
hydraulic barrier. The estimated total present worth cost for the negative-pressure
remedial action is $6,166,000, which includes an annual O&M cost of $430,000.
PERFORMANCE STANDARDS OR GOALS: Treated effluent will meet appropriate Clean Water
Act and State standards for discharge to ground water or surface water, as
appropriate; however, no chemical-specific goals were provided.
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RECORD OF DECISION
DECLARATION
SITE NAME AND LOCATION
Munisport Landfill Site
North Miami, Dade County, Florida
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the
Munisport Landfill site in North Miami, Florida. This action was
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) and the
National Contingency Plan (NCP). This decision is based on the
administrative record (AR) file for this site.
The State of Florida as represented by the Department of
Environmental Regulation (FDER) has been consulted and concurs with
the selection of this remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the site,
if not addressed by implementing the response action selected in this
Record of Decision (ROD), may present an imminent and substantial
endangerment to the environment. There is no observed threat to
public health from this site.
DESCRIPTION OF THE REMEDY
This remedy is the first, and is intended to be the final, remedial
action at the site. The remedial action will reduce risks to the
environment and address the principal threat posed by the exposure of
aquatic life in the State Mangrove Preserve to toxic leachate
emanating from the Munisport Landfill. The response action will
reduce the risks through the interception, collection, and treatment
of leachate-contaminated groundwater.
Major components of the selected remedy include the following:
- Hydrologic, water quality, and treatability studies as part of
remedial design to aid in the selection of the appropriate
method of leachate interception and collection and to aid in
the design of the selected remedial action,
- Interception of the leachate-contaminated groundwater plume
prior to its emergence into the State Mangrove Preserve through
construction of a hydraulic barrier. The barrier will be
constructed using negative pressure (e.g., recovery wells) or
positive infiltration.
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Treatment of contaminated groundwater by air stripping (or a
similar technology compatible with the method used to construct
the hydraulic barrier) to reduce toxicity and ammonia
concentrations,
- Discharge of treated effluent into shallow subsurface trenches
on the landfill proper to enhance the treatment process or
discharge of treated effluent to surface water (or to a trench
for the maintenance of a hydraulic barrier if positive
infiltration is determined the most appropriate). The
appropriate method of effluent disposal will be selected based
on the results of the hydrologic study,
- Hydrologic improvements to the State Mangrove Preserve and
hydrologically altered wetlands. The scope of improvements
will be based on the results of the hydrologic study,
- The total Present worth cost for the selected remedy is
$6,166,000.
The scope of this remedy was developed based on the best available
information. However, additional studies (e.g., hydrologic,
treatability, water quality) are necessary and will be conducted
during the remedial design phase of this project to determine the
most appropriate technology for construction of the hydraulic barrie~
and to aid in the remedial design. The use of wells to construct a
hydraulic barrier through negative pressure is considered a proven
technology. EPA considers positive infiltration an innovative
technology that warrants further consideration since it may
ultimately be more implementable and cost effective than negative
pressure (e.g., recovery wells). Hence, EPA in consultation with
FDER and other appropriate agencies will select the most appropriate
technology to use for the construction of the hydraulic barrier after
the completion of the hydrologic study. The public will be notified
if the final selection with regard to the construction of the
hydraulic barrier and of any significant changes to the selected
remedy.
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. This remedy uses permanent solutions
and alternative treatment technologies to the maximum extent
practicable, and satisfies the statutory preference for remedies that
employ treatment that reduce toxicity, mobility, or volume as the
principal element.
This remedy will serve to mitigate the threat to the environment
through the irtterception, collection, and treatment of hazardous
substances released from the landfill. As required by the NCP, a
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review of the remedial 'action will be conducted within five years
after the commencement of the remedial acti.on to ensure that the
remedy continues to provide adequate protection to the environment.
o?~i ~?,
Da I
/99 t/
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RECORD OF DECISION
DECISION SUMMARY
Hunisport Landfill Site
North Hi ami , Dade County, Florida
Prepared by:
u.S. Environmental Protection Agency
Region IV
Atlanta, Georgia
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TABLE OF CONTENTS
Paae
Section
Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1.0
Location and Description.................................l
Location. . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . .....1
Land Use........................ . . . . . . . . . . . . . . . . . . . . . . . . . 4
Description. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4
2.0
Site
2.1
2.2
2.3
Site History and Enforcement Activities.......................7
3.0
Highlights of Community Participation..... ....................9
Scope and Role of Response Action......... ...............;....11
4.0
5.0
Characteristics. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11
Hydrologic Setting...................................... .12
Environmental Setting................................... .13
Summary of Investigations............................... .14
6.0
Site
6.1
6.2
6.3
Site Ri s ks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
Heal th Risks....................................... 22
Contaminants of Concern........................... 22
Exposure Assessment.... . . . . . . . . . . . . .'. . . . . . . . . . . . . .23
Toxicity Assessment... . . . .. .... . . . . . . . . . . . . . . . .. . .25
Characterization of Risks......................... 28
7.1.4.1 Comparison to ARARs......................30
7.1.4.2 Estimates of Risks Under Current Use.....31
7.1.4.3 Estimates of Risks Under Future Use......33
Summary of Human Health Risks.....................35
7.0
Summary of
7.1 Human
7.1.1
7.1.2
7.1.3
7.1.4
7.1.5
Env ironmental Risks...................................... 37
7.2.1 Receptor Characterization........................ .37
7.2.1.1 Initial Assessment.......................37
7.2.1.2 Subsequent Assessment. ...................38
7.2.2 Exposure Assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .39
7.2.2.1 Initial Assessment.......................39
7.2.2.2 Subsequent Assessment................... .39
7.2.3 Environmental Risks Assessment. ...................39
7.2.3.1 Initial Assessment.......................39
7.2.3.2 Subsequent Assessment................... .41
7.2.4 Environmental Risks Summary.......................41
7.2
8.0
Description
8.1 Common
8.2 Scope
8.2.1
8.2.2
8.2.3
o f Al t e rna t i va s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2
E 1 emen t s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
of Al terna ti ves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .44
Al ternati ve 1 (No Action)....... . . . . . . . . . . . . . . . . . .44
Alternative 2 (Groundwater Recovery/
Mechanical and Biological Treatment)..............44
Alternative 3 (Groundwater Recovery/
Mechanical Treatment)............................. 50
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l --.
9.0
10.0
11.0
-ii-
8.2.4 Alternative 4 (Positive Infiltration
Hydraulic Barrier/Groundwater Recovery/
Biological Treatment.............................. 51
B . 3 ARA.Rs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54
8.4 -' Cleanup Criteria................ .'....................... .57
Summary of Comparative Analysis of Alternatives...............57
9 . 1 Overall Protection....................................... 57
9.2 Compliance with .ARAR.s. . ... ... . . ... .. . .. . . . . . . . .. . . . . . . . . .59
9.3 Long-Term Effectiveness and Permanence...................61
9.4 Reduction of Toxicity, Mobility, or Volume
of the Contaminants through Treatment....................61
Short-Term Effectiveness................................. 61
Implementabil i ty. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61
Co st. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62
9.5
9.6
9.7
9.8
9.9
State Acceptance.............. . . . . . . . . . . . . . . . . . . . . . . . . . . . 62
Communi ty Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62
Selected Remedy............................................... 63
10 . 1 Scope 0 f Remedy.......................................... 64
10.2 Operation of Maintenance of Remedy.......................67
10.3 Cleanup Criteria for Selected Remedy.....................67
10.3.1 Hydraulic Barrier...........................,...... 67
10.3.2 Treatment System.................................. 7r
10.3.3 End-point Criteria................................7.
10.4 Associated Actions.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .73
Statutory Determinations........... . . . . . . . . . . . . . . . . . . . . . . . . . . .75
11.1 Protective of Human Health and
11.2
11.3
11. 4
the Env ironm.ent. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 75
Attainm.ent of A.RAR.s...................................... 75
Cost Effectiveness....................................... 77
Utilization of Permanent Solutions and
Alternative Treatment Technology (or Resource
Recovery) Technologies to the Maximum Extent
Practicable. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .77
11.5 Preference for Treatment as a
Principal Element........................................ 77
12.0 Documentation of Significant Changes..........................78
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Number
1
2
3
4
5
6
7
8
9
10
11
-iii-
FIGURES
Title
Paae
Location Map
2
Site Map
3
Land Use in vicinity of Munisport
Landfill
5
Percent Survival of Inland Silvers ide
at Low Tide
20
Percent Survival of Inland Silverside
at High Tide
21
Observed Groundwater Ammonia Plume
46
Tentative Recovery Well Locations
47
Adjacent Land Areas
49
Hydraulic Barrier
53
66
Treatment System Schematic Diagram
Altered Wetland and Mangrove
Preserve Areas
74
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Number
1
2
3
4
5
6
7
-iv-
TABLES
Title
Chemicals of Potential Concern
Potential Pathways of Exposure to
Contaminants Under Current-Use Conditions
Potential Pathways of Exposure to
Contaminants Under Future-Use Conditions
Health Effects Criteria for Chemicals in
the Surface Water, Soil, and Fish
Comparison of Surface Water Concentrations
with ARARs
Evaluation Criteria
Selected Remedy Preliminary Cost Estimates
paae
24
26
27
29
32
58
68
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APPENDICES
APPENDIX A - October 4, 1989 Federal Register Excerpt
APPENDIX B - Responsiveness Summary
APPENDIX C - Distribution of Chemical Detected
APPENDIX D - Munisport Landfill, Technical Advisory Committee
Report (Draft), March 1990
APPENDIX E - State Concurrence Letter
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1.0
INTRODUCTION
The Munisport Landfill.was included on the National Priorities List
(NPL) in September 1983. It has since been the subject of numerous
studies conducted by local governments and state and federal
agencies. The most recent studies include a 1988 Remedial
Investigation and Feasibility Study (RIfFS) and 1989 Water Quality
and Toxic Assessment Study conducted by the u.S. Environmental
Protection Agency (EPA) in an effort to characterize the risks posed
by the site to public health, welfare, and the environment. Results
from the RIfFS demonstrated that the release of hazardous substances
did not present a threat to public health or welfare. The threat
that this release represents to the environment, however, was
inconclusive.
Based on comments from several Federal agencies and environmental and
citizens groups who expressed concern that the site may present a
threat to the environment, EPA conducted a Water Quality and Toxic
Assessment Study (Mangrove Study) in June 1989. This study was
designed to specifically evaluate the environmental threat that the
site may present to aquatic life in a mangrove swamp adjacent to the
landfill. This mangrove swamp is part of the State of Florida
Biscayne Bay Aquatic Preserve, which was established pursuant to
Chapter 18-18.001 of the Florida Administrative Code (FAC).
Consequently, the mangrove swamp is referred to as the State Mangrove
Preserve. The results of the study conclusively demonstrate that
leachate migrating from the landfill into the State Mangrove Preserve
presents a significant threat to aquatic life. The study also
concluded that, if measures were not taken to abate the threat, the
toxic leachate would severely impair the ecological functions of the
Preserve and preclude the development and maintenance of a balanced
ecological community of aquatic biota. On this basis, EPA has
determined that remedial action is warranted pursuant to Section 104
of the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA) as amended by the Superfund Amendments
and Reauthorization Act of 1986 (SARA).
2.0
2.1
SITE LOCATION AND DESCRIPTION
Location
The Munisport Landfill is an inactive 170-acre municipal landfill
located within the City of North Miami, Dade County, Florida (Figure
1). The landfill is located at latitude N25° 54'09" and longitude
W800 09'05" in Township 52S, Range 42E, Sections 21 and 22. It is
bordered on the north by N.E. 151st Street, on the west by Biscayne
Boulevard (U.S. Route 1), on the south by N.E. 135~ Street, and on
the east by Florida International University and Biscayne Bay. To
the southeast, the Mangrove Preserve separates the main body of the
Munisport property from Biscayne Bay (Figure 2).
This description of the site to be addressed is consistent with
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Source: COM, 1988
SC"Lot 1101 FEET
LOCATION MAP
FIGURE
1
MUNISPORT LANDFILL PROPERTY
NORTH MIAMI, FLORIDA
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Section 105 (a)(8)(B) of CERCLA, which directs EPA to list national
priorities among "known releases or threatened releases" of hazardous
substances, not contiguous portions of community-owned property.
Distinctions between the geographic size of community-owned property
and a release or threatened release of hazardous substances are
further addressed in the October 4, 1989 issue of the Federal
Register (54 FR 41002-03 [FR excerpt contained in Appendix A]).
Results from RIs conducted by EPA have demonstrated that the landfill
is not a discrete source of contamination; rather, hazardous
substances in the form of leachate are emanating from the landfill
and emerging in the adjacent Mangrove Preserve. Thus the site or
facility to be addressed by this ROD consists of the release of
hazardous substances from the landfill into the Mangrove Preserve and
that portion of the landfill needed to ~plement the CERCLA remedy.
The approx~ate boundary of the release (site) includes the eastern
and southeastern most portions of the landfill and the Mangrove
Preserve. (However, this boundary is subject to change if the
contamination is determined to be more widespread, see CERCLA 101(9);
54 FR 41002-3 (October 4, 1989 [FR excerpt contained in Appendix
A] ) ) .
2.2
Land Use
Land uses in the area are pr~arily recreational, residential, and
light commercial (Figure 3). The properties to the north and east
include municipal and State-owned lands that are generally used for
recreational purposes and include the City of North Miami Stadium and
the State-owned Oleta River Recreational Area. To the east is
Florida International University and the State Mangrove Preserve,
which also borders the Munisport property partially on the south.
The properties to the south are pr~arily residential and include
Trailer City and Highland Village Park, both mobile home
developments. Two commercial subdivisions, a residential
subdivision, a KOA campground, and the inactive Boulevard Drive-In
Theater are located along the western boundary. In addition, the
Munisport property is bordered by approx~ately 800 feet of frontage
to t~e west on U.S. Route 1 and over 2,100 feet to the north on N.E.
151~ Street. North of N.E. 151st Street is the North District
Wastewater Treatment Plant, which is owned by the Miami-Dade Water
and Sewer Authority.
2.3
DescriDtion
The 291-acre Munisport property can be divided into four distinct
areas with the following approx~ate acreage: landfill area - 170
acres; upland area - 15 acres; hydrologically altered wetlands within
the dike - 93 acres; and an area ~ediately adjacent to Biscayne Bay
(southeastern section) - 13 acres (Figure 2).
The natural topography of the Munisport property has been altered as
a result of the landfill operation. Eight borrow pits, covering a
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-5-
; ~
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i LEGEND
2Za INDUSTRIAL
1::::::1 MANGROVE PRESERVE
E:J NATURAL VEGETATION
~ RESIDENTIAL
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SCALo( I" FElT
LAND USE IN VICINITY OF MUNISPORT LANDFILL
MUNISPORT LANDFILL PROPERTY
NORTH MIAMI, FLORIDA
FIGURE
3
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-6-
total area of about 16 ~cres, have been excavated to an approximate
depth of 35 feet to provide cover material for the refuse deposited
onsite. The borrow pits have filled with water and now appear as
small lakes or ponds. The refuse has been buried over approximately
170 acres with an average depth of approximately 18 feet and a
maximum depth of approximately 30 feet. This creates a rolling
topography that is more pronounced in the northern portion of the
property than in the southern portion.
The original soils on the Munisport property consisted of Rockdale
fine sand and Perrine marl. Since landfilling operations began at
Munisport, the character of the soils on the landfill portion have
been altered significantly so that the original soil profile no
longer exists. The eastern portion of the property, which has not
been used as a landfill, is still covered by mangrove swamps. A dike
was constructed at the southeastern edge of the property in an
attempt to prevent surface water contaminant migration from the
landfill to the Mangrove Preserve. As shown in Figure 2, the
mangrove swamps occupy two areas. One of these areas is between the
dike and landfilled area and is referred to as the hydrologically
altered wetlands (altered wetlands). The second area is outside of
the dike and is tidally connected with Biscayne Bay. This portion is
part of the Biscayne Bay Aquatic Preserve and is referred to as the
Mangrove Preserve.
The hydrologically altered wetlands are the result of the
construction of a dike through the mangrove swamp that originally
bordered the landfill to the east. The dike was constructed to
prevent contaminated runoff from the landfill from entering and
damaging the mangrove swamps. However, a large section (93 acres) of
the mangrove swamp was cut off tidally from Biscayne Bay,
hydrologically altering that portion of the mangrove swamps. This
has resulted in a radical change in habitat of this portion of the
mangrove swamps. Since there is no tidal connection, water entering
this portion of the mangrove swamps is primarily freshwater. As a
result, this area has been invaded by numerous plant species such as
the Australian Pine and Brazilian Pepper. Since this freshwater
habitat is more conducive to the growth of these exotic species, the
number of mangrove trees within the diked area has been severely
reduced. With regard to the aquatic life in this impounded area,
species of plants and animals indicative of a freshwater habitat have
become predominant. Because this portion of the mangrove swamp has
been isolated from tidal activity, it merely provides habitat for
various freshwater organisms and no longer plays a vital role in the
support of the BiscaYne Bay ecosystem.
Underlying the Munisport property is the BiscaYne aquifer, a shallow
water table aquifer that serves as the potable water source for Dade
County. However, the water quality of the area underlying the
property has been degraded by saltwater intrusion (unrelated to the
activities at the landfill) and the water is not used as a drinking
water source. (This is the primary reason for the absence of a human
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health threat from the site.) The deeper artesian Floridan aquifer
is saline in most of southeastern Florida and is therefore unsuitable
as a regional source of drinking water. The Biscayne aquifer extends
vertically 150 feet at the site. The direction of groundwater flow
in the Biscayne aquifer and site surface drainage is generally to the
east-southeast toward Biscayne Bay.
According to the U.S. Fish and Wildlife Service Atlantic Coast
Ecological Inventory, the aquatic life of Biscayne Bay includes 21
species of fish. According to observations made by the Florida
Department of Environmental Regulation (FDNR) over a 10-year period,
the number of fish species inhabiting Biscayne Bay may be as high as
45. The Ecological Inventory also indicated the presence of numerous
invertebrates, four species of sea turtles, and two species of marine
mammals. The two marine mammals identified include bottle-nose
dolphin and the West Indian manatee. The manatee was reported to
inhabit not only Biscayne Bay, but possibly all waterways adjoining
Biscayne Bay. The four species of sea turtles and the manatee are
protected by the Endangered Species Act.
Biscayne Bay is heavily utilized by both recreational and commercial
fisheries. The mangrove swamps around the bay provide important
breeding and nursery grounds for marine fish and invertebrates that
contribute to the support of offshore fisheries. In addition to
serving as an important marine fisheries resource, the mangrove
swamps also provide protective habitat and feeding areas for numerous
bird species.
The climate in Miami can be described as subtropical marine,
characterized by long, warm summers with abundant rainfall and a
mild, dry winter. The mean annual temperature is 75.50F. The
coldest month is January with an average of 67.0oF, and the warmest
month is August with an average temperature of 82.7oF. The average
annual precipitation is 46 inches.
3.0
SITE HISTORY AND ENFORCEMENT ACTIVITIES
In 1959, Interama, a development corporation, purchased a 1,700-acre
tract of land to develop as a trade and cultural center. During the
mid-1960s, earth-moving activities took place, and a dump was
operated on a few acres of land. Accurate records do not exist as to
the types of wastes landfilled during this period. The principal
fill material was clean fill (e.g., lawn trimmings, construction
debris, etc.), but later municipal refuse was used. The City of
North Miami received title to 350 acres of the property in 1970 in
exchange for floating a $12 million bond issue to allow Interama to
continue development. Approximately one year later, however,
Interama went bankrupt and the city subsequently leased 291 acres to
Munisport, Inc. for the development of a recreational facility.
Munisport, Inc. began operations in 1974 by filling low-lying areas
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with clean fill and construction debris. Although Munisport, Inc.
was the primary operator of the facility, another company, ABC
Demolition, provided the heavy equipment for the landfilling
activities through a lease agreement with Munisport, Inc. Later in
1974, the Florida Department of Pollution Control (FDPC) filed a
"Complaint for Temporary Injunction and Damages" against the City of
North Miami, Munisport, Inc., and ABC Demolition until a hearing
could be held. In 1975, the City of North Miami and Munisport,
Inc. applied for and were granted a Temporary Operating Permit (TOP)
for 15 months, allowing the use of solid waste (i.e., garbage) for
fill above the water table.
The U.S. Army Corps of Engineers (COE) issued Munisport, Inc. a
permit in 1976, pursuant to Section 404 of the Clean Water Act (CWA),
to allow the filling of "waters of the U.S." (wetlands) with (,;lean
fill and construction debris. Later in 1976, Munisport, Inc.
received a revised TOP from the Florida Department of Environmental
Regulation (FDER), (formerly FDPC), allowing more time for the
evaluation of a full operating permit.
During a 1976 inspection of the facility by the Metropolitan Dade
County Department of Environmental Resources Management (DERM),
twelve 55-gallon drums (labeled as containing tricresyl phosphate,
ethyl cyanoacetate, and acetone) were observed leaking onto the
ground surface in the eastern portion of the landfill. A Notice of
Violation (NOV) of the TOP was issued to Munisport by DERM for the
disposal of hazardous waste at a sanitary landfill. The drums were
later removed by a contractor for the City of North Miami.
In 1977, Munisport, Inc. applied for a modification of the 404 permit
to allow the use of solid waste (garbage) for fill in the wetlands.
EPA opposed the modification and, in 1981, issued a CWA 404(c) veto
prohibiting the filling of the wetlands with solid waste.
Subsequently, the EPA Region IV Administrator issued an
Administrative Order that prohibited any additional filling of
wetlands and required some wetlands restoration. The Order provided
for the removal and/or realignment of the diking between the landfill
and the Mangrove Preserve such that the hydrologically altered
wetlands could be restored. This Order has not been complied with by
the City of North ~ami. In 1981, FDER directed Munisport, Inc. and
the City of North Miami to provide final closure of the landfill.
Landfill operations ceased in 1981. However, closure in accordance
with State law has not taken place.
In 1982, EPA evaluated the Munisport site as a potential candidate
for the National Priorities List (NPL). The site was evaluated using
the Hazard Ranking System (HRS; Appendix A of 40 CFR 300), and
received a score of 32.37. EPA proposed the site for inclusion to
the NPL and solicited public comment on the proposed listing in the
December 30, 1982 issue of the Federal Register (47 FR 58484). The
only comment received was from the U.S. Department of Interior (DOI)
concerning the potential presence of manatees in the site area.
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DOI did not oppose the listing, and the site was added to the final
NPL in the September 8, 1983 issue of the Federal Register (48 FR
40673) .
In 1986, the City of North Miami petitioned EPA for the deletion of
the site from the NPL. EPA refused to delist the site and noted its
policy of not rescoring sites that have been through the rulemaking
process and listed on the NPL as final (49 FR 37080-81 (Sept. 21,
1984]). Consistent with that policy, EPA decided to conduct an RI of
the site and noted that the site may be deleted if it did not pose a
significant threat to public health or welfare, or the environment,
as provided in the Code of Federal Regulations (40 CFR
300.66(c)(7)(iii) (1985]). Based on results contained in the 1988
Camp Dresser and McKee, Inc. (CDM) RIfFS report, EPA determined that
the Munisport site presented no significant threat to public health;
however, the threat to the environment was inconclusive.
Because of a potential threat to the environment, EPA issued a
Proposed Plan in July 1988 that recommended closure of the landfill
in accordance with Florida's Landfill Closure Law. All alternatives,
with the exception of "no action," were considered acceptable.
Subsequent to this publication, EPA reevaluated the potential
environmental threat posed by the site and issued a revised Proposed
Plan in November 1988. The revised Plan stated that an alternative
of "no action" under CERCLA was appropriate given the limited
environmental threat. The public was notified of EPA's recommended
change to the Proposed Plan and solicitation of comment through a
public notice published in local newspapers. The proposal of "no
action" under CERCLA was opposed by local citizens, several
environmental groups, the National Oceanic and Atmospheric
Administration (NOAA), and the U.S. Fish and Wildlife Service.
Essentially, members of the public and several government agencies
felt that the results from studies were not sufficient to assess
potential impacts to aquatic life in the Mangrove Preserve.
In response to the public's concern, the EPA Environmental Services
Division (ESD) conducted a subsequent study in June 1989 that focused
on the potential threat to the adjacent State Mangrove Preserve.
Results of this study conclusively demonstrated that leachate from
the landfill poses a significant threat to the aquatic organisms in
the Mangrove Preserve. Thus, pursuant to the authority granted in
Section 104 of CERCLA, EPA determined that remedial action is
appropriate in order to protect the environment.
4.0
HIGHLIGHTS OF COMKUNITY PARTICIPATION
In recent years, the public has been provided the opportunity to
comment on the results of several studies and proposed remedial
actions. The first of these include the EPA 1988 RIfFS reports and
the EPA 1988 Proposed Plan for remedial action. The Proposed Plan
explained that all of the alternatives, with the exception of "no
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action," were appropriate to mitigate the threat to the environment.
These documents were made available to the public in both the
Administrative Record .(AR) file and an information repository
maintained at 1) the EPA, Region IV Docket Room and 2) the North
Miami Public Library. The Notice of Availability of these documents
was published in the Miami Herald on July 24, 1988. A public comment
period was held from July 20 through August 17, 1988 for a total of
28 days which was consistent with the 1988 NCP requirements. In
addition, a public meeting was held on July 27, 1988 at the Highland
Village Community Center in North Miami. At this meeting,
representatives of EPA, FDER, and DERM were available to answer
questions about the problems at the site and the proposed remedial
action.
After the comment period and public meeting on the RIfFS and Proposed
Plan, a notice was issued to the public announcing a change to the
plan. This notice was based on further evaluation of the data by EPA
that indicated the threat to the environment did not appear
significant. This notice was published in the Miami Herald on
November 27, 1988 and explained that no remedial action "under
CERCLA" was appropriate at this time since the site, as demonstrated
by the 1988 RIfFS, did not constitute a threat to public health or
welfare, or the environment. Proper closure of the landfill by the
State under State law was still recommended.
EPA received substantial comment from the public and other regulatory
agencies expressing concern that the leachate from the landfill does
pose a threat to the Mangrove Preserve. An additional study of the
site was therefore conducted by EPA in June 1989 to further define
the environmental threat. The subsequent report, Munisport FS
Addendum (1990, CH2M HILL), and EPA Proposed Plan for remedial action
were made available to the public in both the AR file and information
repository maintained at the EPA Region IV Docket Room and the North
Miami Public Library. The Notice of Availability of these documents
was published in the Miami Herald on March 16 and 25, 1990. Public
notice was also given in the New Times, a local paper, on March' 21,
1990. A public comment period was held from March 16 through April
14, 1990 for a total of 30 days which was consistent with the 1990
NCP requirements. In addition, a public meeting was held at Florida
International University in North Miami on March 29, 1990.
Representatives of EPA, FDER, NOAA, and DERM were available at this
meeting to answer questions about the problems at the site and the
proposed remedial action.
A response to the comments received on the RIfFS, FS Addendum, and
most recent Proposed Plan is included in a Responsiveness Summary,
which is included in this Record of Decision (ROD) in Appendix B.
This ROD presents the CERCLA remedial action for the Munisport NPL
site in North Miami, Florida. This action has been chosen in
accordance with CERCLA, as amended by SARA and, to the maximum extent
practicable, the National Contingency Plan. The decision for this
site is based on the AR.
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5.0 SCOPE AND ROLE OF RESPONSE ACTION
Results of the EPA Mangrove Study demonstrated that leachate-
contaminated groundwater is migrating from the Munisport Landfill to
the southeast and emerging in the State Mangrove Preserve. The study
further demonstrated that the leachate is both acutely and
chronically toxic to aquatic life.
In response to this threat, the Agency has determined that a response
action designed to abate the threat to the environment is necessary
and prudent. The response action will be designed to protect aquatic
life in the Mangrove Preserve by intercepting, collecting, and
treating the leachate-contaminanted groundwater prior to its
emergence in the Mangrove Preserve. Toxic leachate will thus be
prevented, to the extent necessary, from migrating into the Preserve
and adversely impacting aquatic life.
The remedy will also ~prove the circulation of tidal water in the
Preserve and the hydrologically altered wetlands by modifying the
culvert structures which presently restrict exchange with water in
the bay. By promoting tidal mixing, additional mitigation will be
provided. Moreover, this ~proved tidal connection will allow the
altered wetlands to resume their function as an integral part of
Biscayne Bay and the environment.
The landfill will be closed at the direction of FDER, pursuant to
Florida's Landfill Closure Law, Florida Administrative Code (FAC),
Chapter 17-701. The State is in receipt of preliminary landfill
closure documents from the Potentially Responsible Party (PRP).
This is an appropriate step, consistent with the planned CERCLA
action. Landfill closure under EPA's direction is unnecessary and
would s~ply duplicate the State's effort. However, EPA will consult
with the State and local officials during the closure process to
ensure that the Federal and State actions are consistent with the
CERCLA remedy and timely. In the event that additional data
collected prior to or during the remedial design indicates that a
larger portion of the landfill is needed to implement the CERCLA
response action, EPA will retain jurisdiction over this larger
portion of the landfill (54 FR 41002-3 (October 4, 1989). Finally,
if proper closure under State law is not accomplished by EPA's first
5-year review of the site, EPA will consider whether further action
is warranted under CERCLA.
6.0
SITE CHARACTERISTICS
The land on which the Munisport Landfill is located was originally
planned as a recreational complex for local residents. Since much of
the land consisted of low-lying areas with elevations near sea level,
it was necessary to fill many such areas to make development
possible. Although the use of clean fill such as construction debris
was originally planned for these areas, the use of solid waste
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(garbage) for fill began in late 1974 and continued into 1981. This
resulted in the disposal of an estimated 5 million cubic yards of
waste and soil cover.
A review of disposal records indicates that the property was
essentially operated as a solid waste landfill. This determination
is further supported by data collected from the numerous sampling
investigations, including analyses of soil, groundwater, sediment,
and surface water samples which show no evidence of significant
contamination.
Although numerous organic compounds and inorganic constituents have
been detected among the samples, the data set, when reviewed as a
whole, indicates that the substances detected are indicative of
materials associated with common household wastes. The substances
detected and their respective concentrations are not indicative of a
hazardous waste site. Further, as noted in Section 2.3 above, the
groundwater beneath site is not suitable for drinking (for reasons
unrelated to the landfill operations). Based on the results of the
RI, EPA determined that the substances detected in the soil,
groundwater, sediment, and surface water samples collected on and
around the landfill proper do not present a threat to public health
or welfare.
However, study of the impacts of the landfill leachate on the
Mangrove Preserve has shown that the release of this leachate into
the groundwater and its subsequent emergence in the Mangrove Preserve
represents a significant threat to the environment. This threat
results from the release of hazardous substances from the landfill in
leachate combined with the improper placement of the landfill in a
very complex hydrologic setting and sensitive ecologic system. The
following sections describe the hydrologic and ecologic systems in
which the site is located. The following sections also provide an
overview of the results of studies that have been conducted at this
site.
6.1
Hvdroloaic Setting
The Munisport Landfill lies at the southern tip of the Florida
peninsula, the portion of the Floridan plateau which is exposed above
sea level. The property is located on the edge of the Atlantic
Coastal Ridge as it declines in elevation toward BiscaYne Bay. The
ridge extends several miles inland and has an average elevation
between 8 and 10 feet above mean sea level '(msl). The elevations at
the Munisport property range from 30 feet above msl to elevations
near sea level. The maximum elevations exceed those found on
adjacent properties due to the landfill activities that occurred on
the Munisport property. Excavations were also made on the property
to provide a source of soil cover during landfilling activities.
Some of the borrow pits were excavated to depths as great as 30 feet
below land surface.
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The Munisport property is underlain by the Biscayne aquifer. This
aquifer is a shallow water table aquifer and serves as the sole
source of potable water for Dade County. Within the vicinity of the
Munisport property, however, the aquifer has been impacted by
saltwater intrusion and no longer serves as a source of potable
water. The aquifer extends vertically from near surface to
approximately 150 feet deep in the area of the Munisport property and
is typically contained within the permeable portions of several sand
and limestone formations. The stratigraphic formations which
comprise the Biscayne aquifer include, in desending order, the
pamlico Sand, Miami Limestone, Anastasia, and Tamiami. The lower
portion of the Tamiami serves as the lower confining unit separating
the Biscayne aquifer from the Floridan aquifer.
Groundwater flow in the Biscayne aquifer in the vicinity of the
Munisport property is typically toward the east and southeast. The
direction of flow is highly influenced on a local basis by drainage
canals, lakes, rivers, and Biscayne Bay. Surface water features in
proximity, in addition to Biscayne Bay, that may affect the local
groundwater flow include the Southern Canal and the Oleta River.
Tidal dynamics associated with Biscayne Bay further influence the
direction and rate of groundwater flow in the Biscayne aquifer. A
final influence on the hydrogeology is the physicochemical effects
resulting from the mixing of saline water from the bay with the
relatively fresh water in the aquifer.
6.2
Environmental Settinq
The Munispvrt property is located in a coastal area adjoining
Biscayne Bay. Other adjoining surface waters include the the Oleta
River to the north and the Southern Canal to the south. In addition
to these surface water bodies, extensive wetland areas are present
that are typically composed of stands of several species of
mangroves. These mangrove stands represent ecological communities
that playa vital role in the environment. As with most
environments, these communities are very sensitive to contamination
and their ecological function is often severely impaired if
contaminated.
The majority of the Munisport property is situated on top of former
wetlands and the eastern border of the landfill currently adjoins
wetland areas, part of which is a State Mangrove Preserve. This
mangrove preserve is also part of the Biscayne Bay Aquatic Preserve.
Both preserves were established by the Florida State Legislature with
the intent that they be preserved in an essentially natural condition
so that their biological and aesthetic value maybe enjoyed by future
generations.
In addition to the aesthetic value of these preserves and the other
adjoining wetland areas, these wetlands play many other important
roles in the environment. One paramount function of the wetlands is
their support of the aquatic food chain. These wetland areas provide
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a source of detritus, which is a food source for many of the smaller
aquatic organisms such as invertebrates, various shellfish, and
forage fish. These organisms in turn provide a source of food for
many of the larger predatory fish caught recreationally and
commercially in BiscaYne Bay and the Atlantic Ocean. In addition,
these wetlands serve as breeding and principal nursery areas for many
of the fish species found in the bay and ocean. Other important
functions of these wetlands include fish, birds, and other wildlife
habitat, water quality improvement, flood protection, and shoreline
erosion control.
Finally, in addition to the wetland areas adjacent to the Munisport
property, BiscaYne Bay, along with several other adjoining water
bodies, serves as a habitat for four species of sea turtles and the
manatee, which are protected by the Endangered Species Act.
The rapid decline of many of these wetland areas as a result of the
urbanization of the Miami area makes their protection imperative.
The Mangrove Preserve adjacent to the Munisport Landfill is one of
the last native stands of mangroves in the Miami area. Measures must
be taken at the Munisport site to prevent the further demise of
additional areas within this important natural resource.
6.3
Summarv of Investigations
Since 1975 numerous investigations have been conducted at the
Munisport Landfill area to determine the potential threat to the
public and environment. To date, five major studies have been
conducted by various local governments and State and Federal
agencies. The scope of each of these studies is briefly outlined in
the following:
I.
FDER/DERM Groundwater, Surface Water, and Leachate Monitoring
(1975-1983)
o
Monitoring of 14 groundwater wells located on and around the
landfill site,
o .
Monitoring of surface waters in eight onsite lakes (former
borrow pits), wetland area, a ditch leading to BiscaYne
Bay, and the Mangrove Preserve,
Monitoring of leachate emerging in the Northwest Lake
(former borrow pit).
II. EPA Site Investigation (1984)
o
o
Collection of groundwater samples from seven existing
monitoring wells located on and offsite and one temporary
well located onsite,
o
Collection of 12 surface water samples from onsite
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III.
-15-
o
lakes and the Mangrove Preserve,
Collection of 13 sediment samples from onsite lakes
(former borrow pits) and the Mangrove Preserve,
o
Collection of two soil samples from locations on the
landfill proper. -
H. R. Ross Associates Landfill Closure Study (1986) (PRPfState
Sponsored)
o
Installation of five wells and collection of groundwater
samples from each,
Collection of 15 surface water samples from five of the most
contaminated lakes (Northwest, North, East, East Central,
and Southeast) - (former borrow pits),
o
o
Analysis of groundwater and surface water samples for
ammonia as an indicator of contamination.
IV. EPA RIfFS (1988)
V.
o
Installation and collection of groundwater samples from 29
wells located on and around the landfill,
o
Collection of 29 surface water and 8 sediment samples from
locations among onsite lakes, wetland areas including the
Mangrove Preserve, BiscaYne Bay, Oleta River, Southern
Canal, and a lagoon east of the site,
o
Collection of 25 soil samples from locations on the
landfill, unfilled areas along the dike and the edge of
the landfill, and background areas,
Performance of 15 separate bioaccurnulation tests among six
different species of aquatic vertebrates and invertebrates
collected from onsite and background locations,
o
o
Bioassays on aquatic organisms using 11 surface water
samples collected from several onsite lakes (former
borrow pits), tidal and impounded mangrove areas, and the
Oleta River,
o
Bioassays on aquatic organisms using groundwater samples
collected from four monitoring wells, three of which were
located on the landfill and one located upgradient of the
landfill,
EPA Water Quality and Toxic Assessment Study, Mangrove
Preserve (1989)
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o
Evaluation of the emergence of leachate in surface water in
the Mangrove Preserve through monitoring of tidal cycles and
ammonia concentrations at numerous locations in the Mangrove
Preserve and vicinity,
o
Assessment of potential toxic effects of emerging leachate
on aquatic life in the Mangrove Preserve through bioassays
on four different kinds of aquatic organisms using surface
waters collected from 11 stations located in the Mangrove
Preserve and vicinity,
o
Evaluation of potential nutrient enrichment effects of
surface water discharged from the Mangrove Preserve into
Biscayne Bay through bioassays on a unicellular algal
species using surface waters collected from four stations
located in the Mangrove Preserve and vicinity.
A brief summary of the results from
Detailed accounts of the results of
actual reports which are maintained
repository for this site.
these studies is provided below.
the studies can be found in the
in the AR file and information
I.
FDER/DERM Groundwater, Surface water, and Leachate Monitoring
(1975-1983)
o
Low levels of various metals were detected among the
groundwater samples collected from the site. The highest
concentration of a metal detected was for lead at a
concentration of 0.90 mg/l. Groundwater samples were not
analyzed for the presence of organic compounds.
Surface water samples collected from areas on and adjacent
to the landfill indicated the presence of ammonia-nitrogen
(NH3-N), nitrates, and/or nitrites. In January 1975, nine
of ~he twelve surface water samples contained levels of
nitrite/nitrate ranging from 0.02 to 1.86 parts per
million (ppm). Results from August 1979 sampling (by DERM)
of surface water along the western edge of the Mangrove
Preserve indicated the presence of ammonia-nitrogen ranging
in concentration from 6.6 to 9.6 ppm. Waters along the
western edge of the Preserve were resampled in January 1980
and indicated the presence of NH3-N at concentrations
ranging from 3.1 to 4.1 ppm. .
o
Results from analysis of three leachate samples collected by
DERM from an area near the Northwest Lake indicated the
presence of NH3-N in two of the three samples at
concentrations greater than 510 ppm.
II. EPA Site Investigation (1984)
o
o
Results from analysis of a select number of wells indicated
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the presence of metals characteristic of a carbonate
aquifer. Results from organic analysis of samples collected
onsite indicated the presence of numerous organic
compounds. Concentrations, however, were typically low,
often at or below detection limits. The one exception was
the detection of chloroethane, which was detected at a
concentration of 130 ug/l in a groundwater sample collected
in the northwestern section of the landfill. The highest
concentrations of ammonia and total Kjeldahl nitrogen were
reported in a sample collected from a location downgradient
of the east central side of the landfill with concentrations
at 160 mg/l and 145 mg/l, respectively.
o
Results from analysis of surface water samples collected
from onsite lakes (former borrow pits) indicated the,
presence of metals that are characteristic of a carbonate
rock environment. Results from organic analysis indicated
the presence of numerous organic compounds with low
concentrations, ranging from 5.3 to 13 ug/l. Concentrations
of ammonia and total Kjeldahl nitrogen were relatively low.
o
Results from analysis of sediment samples indicated the
presence of metals that are characteristic of carbonate rock
environments with the exception of arsenic. Arsenic was
detected in a sample collected from the Mangrove Preserve
near the west culvert at a concentration of 26 mg/kg.
Results from organic analysis of sediment samples typically
indicated the presence of a relatively small number of
compounds at low concentrations, with the exception of
samples collected from two former borrow pits (North Lake
and East Lake). Numerous organic compounds were detected in
these two samples, with the highest number and
concentrations detected in the sample collected from the
North Lake. The organic compounds consisted of chlorinated
pesticides, polychlorinated byphenyls (PCBS), and
polynuclear aromatic hydrocarbons (PAHs). Concentration
ranges are as follows: pesticides - 3.4 to 120 ug/li PCBs
500 to 900 ug/kgi and PAHs - 500 to 3,000 ug/kg. Since
these organics were detected in the sediments of the former
borrow pits, and considering the insoluble nature of these
organics, risks to human health or the environment from
exposure to these organic compounds would likely be
negligible.
o
Results from analyses of the two soil samples collected from
the site area indicated the presence of ' metals
characteristic of a carbonate rock environment. Results
from organic analysis did not indicate the presence of any
target compounds at significant concentrations.
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III.
IV.
-18-
H. J. Ross Associates Landfill Closure Study (1986)
o
Ammonia was detected among the groundwater samples at
concentrations ranging from 7.3 to 561 mg/l, with the
highest concentration reported in the sample collected
a well adjacent to the Northwest Lake.
Ammonia was detected among the surface water samples at
concentrations ranging from 3.3 to 59.6 mg/l with the
highest concentration reported in a sample collected from a
mid-depth in the East Lake.
from
o
EPA RI/FS (1988)
o
Results from analysis of groundwater samples indicated the
presence of a variety of organic and inorganic chemicals.
However, most of these contaminants were detected at low
concentrations with a few of the chemicals exceeding Federal
and State water quality public health-based standards.
Since the water in the vicinity of the site is not used for
potable or irrigation purposes, it was determined that the
contaminants in the groundwater present insignificant risk
to public health. A distribution of chemicals detected
among groundwater samples collected from the site is
provided in Appendix C (Tables C-l and C-2).
o
Analyses of surface water and sediment samples indicate
low-level contamination by a variety of mostly inorganic
chemicals typical of a non-hazardous waste landfill.
Concentrations of several of these chemicals exceeded
applicable water quality standards among the samples
collected. Moreover, concentrations of several of the
chemicals exceeded acute and/or chronic EPA Ambient Water
Quality Criteria and/or FDER Water Quality Criteria. The
distribution of chemicals detected among surface water and
sediment samples collected from the site and surrounding
areas is provided in Appendix C (Tables C-3 through C-7).
Analyses of soil samples indicated the presence of
chemicals typically associated with non-hazardous
municipal landfills. Samples collected from unfilled areas
indicated little contamination. Samples collected from the
landfill surface and northeast portion of the landfill,
however, contained several contaminants at concentrations
above background. The distribution of chemicals detected
among soil samples collected from the site is provided in
Appendix C (Table C-8 through C-IO).
o
o
Results from the bioassays and bioaccumulation tests
revealed varying degrees of toxicity. Acute toxicity tests
conducted on the four groundwater samples indicated severe
toxicity in the two samples collected from the north and
-------
---
v.
-19-
central portions of the landfill. The other two samples
revealed no significant acute toxicity. Chronic toxicity
was typically_observed among the aquatic species exposed to
groundwater samples collected from the landfill area.
Acute toxicity tests conducted using surface water samples
collected from the landfill and bay side of the dike
demonstrated very low or possibly no toxicity. However,
short-term chronic effects were observed in two of the
organisms exposed to the surface water samples.
Chemical contaminants responsible for the observed toxic
effects were difficult to identify due to the complex
chemical mixture represented in the samples. Among the
chemicals identified, ammonia was present in concentrations
that co~ld have caused the toxicity shown in the bioassays.
Other chemicals present at concentrations in excess of water
quality criteria may have contributed to the toxicity.
However, ammonia appeared to be the best indicator of the
toxicity.
Results from the bioaccumulation study did not provide any
conclusive evidence that chemicals associated with the
landfill are bioaccumulating in the tissue of indigenous
fish and invertebrates at concentrations above those found
in the same species collected elsewhere in Biscayne Bay.
EPA Water Quality and Toxic Assessment Study, Mangrove
Preserve (1989)
o
Results of the bioassays in which aquatic test organisms
were exposed to surface water collected from the Mangrove
Preserve demonstrated severe adverse effects in three of the
four marine species tested. The observed toxic effects
appeared to be limited to excessive levels of un-ionized
ammonia and other unknown toxicants of the leachate.
o
Significant levels of both acute and chronic toxicity were
observed in three of the four reference points, including
Biscayne Bay, Biscayne Creek, and Dania Cutoff Canal.
However, in comparison to the toxicity observed in surface
water samples collected from the Mangrove Preserve, the
toxicity was considerably lower. -This is evidenced by
Figures 4 and 5, which compare observed toxicities among
surface water samples collected from the Mangrove Preserve
and Biscayne Bay. Figure 4 illustrates toxic effects that
were observed using samples collected at low tide, while
Figure 5 illustrates effects using samples collected at high
tide. As evidenced by the figures, the most severe toxic
effects were observed at low tide. In either case, toxic
effects in the sample collected from Biscayne Bay were
significantly less than that observed in samples collected
-------
-20-
N
.
-. LEVEE WITH UNIMPROi£D
~
--. MOSQUITO DlTtHES
NH,.N'm;/1 ('1. SURVIVAU
. I
EA;Q
LAC;
F.I.u.
13(0%)
.... .......
APTS.
-
-
. . . .....
, r
flrlnn
BlSCAYNE
BAY
I
-
<0.1(iii>-.. .
,~
Source: EPA, 1989
FORTY-EIGHT HOUR PERCENT SURVIVAL OF INLAND SILVERSIDE RELATIVE TO
TOTAL AMMONIA CONCENTRATION AT LOW TIDE IN MANGROVE PRESERVE,
MUNISPORT JUNE 1989
MUNISPORT LANDFILL PROPERTY
NORTH MIAMI, FLORIDA
FIGURE
4
-------
-21-
N
.
IGH TCE SAW\.ING "&.£G£HO.
-" LEVEE WITH UNIMPRo.rED
ROAD
--" MOSQUITO DITCHES
No! ON''''O/II'IroiAL.I
EAS
-------
-22-
from the Mangrove Preserve.
o
Tidal stage was determined to be a primary factor affecting
the emergence of leachate in the Mangrove Preserve. On each
ebbing phase of the tide, upwelling of leachate increased to
levels that were severely toxic to aquatic life. During the
flooding stage, the effects were reduced through dilution,
but not eliminated.
o
Assessment of potential nutrient enrichment effects of
surface water from the Mangrove Preserve on Biscayne Bay
could not be completed due to the severe toxic effects of
the Preserve surface water on the marine test alga.
The previous discussions provide a brief overview of the findings of
the major studies that have been conducted at the site to date. As
discussed earlier, a more detailed discussion of these results can be
found in the investigation reports that are maintained in the AR file
and Information Repository for this site. Overall, these results
show that contaminants present in samples collected from various
media at the landfill do not represent a threat to public health or
welfare, as more fully explained in section 7.1. However, samples
collected from onsite surface waters and water from the Mangrove
Preserve in addition to groundwater samples collected from numerous
locations contained contaminants, primarily un-ionized ammonia, at
concentrations that are severely toxic to aquatic life.
7.0
SUMMARY OF SITE RISKS
The following sections summarize the risks to human health and the
environment that are or may be posed by the Munisport site. The
human health section evaluates the risks in terms of contaminants of
concern, exposure, toxicity, and risks. The environmental section
evaluates the contaminants of concern, characteristics of the
environment, and biological factors.
7.1
Human Health Risks
Risks to human health were evaluated using data collected as part of
the EPA RI/FS conducted during the period 1986 through 1987.
7.1.1
Contaminants of Concern
Results from analyses of groundwater, surface water, sediment, and
soil samples collected from locations on or near the Munisport
Landfill were reviewed to determine the contaminants of concern.
In locations such as municipal landfills where the nature of disposed
wastes is unknown, it is difficult to determine whether or not the
chemicals detected are a direct result of specific waste disposal
activities that occurred at the facility. In some instances, the
chemicals detected may be the direct result of municipal waste
-------
-23-
containing hazardous constituents or they may be a by-product of the
environment in which the facility is located. As a result,
contaminants of concern are typically identified on the basis of
concentrations that are elevated above background concentrations for
the area. A complicating factor is the nature of background in an
urban area such as this. Hence, contaminants that were detected in
samples collected from the landfill at concentrations above
background were identified as potential contaminants of concern. A
list of these contaminants is provided in Table 1. Appendix C
contains data tables that summarize contaminant concentrations on
which the risk assessment is based.
Among the chemicals listed in Table 1, only those with adequate
toxicity information were assessed for potential contribution to
overall risks. While specific health-based criteria were not
available for a number of. the contaminants of concern, analysis (or
assessment) of the existing/available data indicates a relatively low
order of toxicity. When compared to other contaminants of concern,
which are known to have potential for adverse health-effects, the
compounds of low toxicity do not appear to pose a significant
incremental risk and are not included in the risk assessment.
Toxicity data that were used in the toxicity assessment included
environmental standards, criteria, ARARs from Federal and State
environmental laws, and/or critical toxicity values such as reference'
doses for non-carcinogens and cancer potency factors for
carcinogens. ARARs are those cleanup standards, standards of
control, and other substantive environmental protection requirements
promulgated under Federal or State law that specifically address a
hazardous substance, pollutant, contaminant, remedial action,
location, or other circumstance at a Superfund site, or that address
problems or situations sufficiently similar to those encountered at
the Superfund site that their use is well suited to the particular
site. ARARs identified for this site are used to establish cleanup
standards for the remedial action. -
7.1.2
Exposure Assessment
Based on an evaluation of various environmental factors affecting the
migration of contaminants, such as hydrogeologic or physicochemical
conditions of the environment and the physicochemical characteristics
of the contaminants, two methods by which contaminants may
realistically migrate from the Munisport La~dfill were identified.
The first method identified was the leaching of organic chemicals
that do not readily bind to soils and the leaching of ammonia from
soils or wastes into the groundwater. The second method identified
was the transport of contaminants with the groundwater flow and
subsequent discharge into nearby surface waters.
Under current conditions, it was determined that the only viable
route of human-exposure to the contaminants of concern was via the
ingestion of fish obtained from surface waters on or near the
-------
-24-
Soil
Table 1
Chemicals of Potential Concern at the Munisport Property
Surface Water Sediment Groundwater
Inorganic Chemicals Inorganic Inorganic Inorganic Chemicals
Chemicals Chemicals
Aluminum Aluminum Aluminum Aluminum
Ammonia Ammonia Ammonia Ammonia
Arsenic Arsenic Arsenic Antimony
Chromium . Barium Cadmium Arsenic
Cyanide Calcium Calcium Barium
Iron Chromium Chromium Calcium
Magnesium Copper Cobalt Chromium
Mercury Cyanide Copper Cobalt
Potassium Iron Iron Copper
Sodium Lead Lead Iron
Tin Magnesium Magnesium Lead
Manganese Manganese Magnesium
Mercury Mercury Manganese
Nickel Nickel Mercury
Potassium Potassium Nickel
Silver Silver Potassium
Sodium Sodium Sodium
Strontium Vanadium Strontium
Vanadium Zinc Vanadium
Zinc Zinc
Organic Chemicals Organic Chemicals Organic Chemicals Organic Chemicals
Acetone Acetone Benzene Acetone
Benzylbutylphthalate Carbon disulfide Benzoic Acid Benzene
Beta-BHC 4,4'-DDE Carbon disulfide Benzylbutylphthalate
Chloroform PCBs Chloroform Carbon disulfide
bis( 2- Ethylhexyl )phthala te Phenol 4-Methylphenol Chlorobenzene
CPAH NCPAH Chloroform
4-Methylphenol Pentachlorophenol Delta-BHC
NCPAH Phenol bis(2- Ethylhexyl )phthalate
Pentachlorophenol 4-Methylphenol
PCBs NCPAN
Toluene Pentachlorophenol
Phenol
Toluene
Source: CDM, 1988
dbt077/007.51
-------
-25-
Munisport property. Other exposure pathways (i.e., exposure to
chemicals of concern in the groundwater, soil, or sediments) were
also evaluated. However, these pathways were determined not to be
viable exposure pathways due to a lack of receptors, such as people
currently using area groundwater for potable or irrigation purposes.
A summary of the potential pathways of exposure under current site
conditions is provide in Table 2.
Future 'exposures were also evaluated based on several different
scenarios regarding future use of the Munisport property. The
exposure pathways that may be viable and significantly contribute to
risks in the future include dermal contact and ingestion of surface
waters by future swimmers in the area and dermal contact and
incidental ingestion of soil by future residents, workers, and
recreational users of the area. Swimming exposure was quantified for
swimmers in the onsite lakes. Soil exposure was quantified for
future residents 'potentially living in three different areas of the
Munisport property. Exposure of future workers and recreational
users was quantitatively evaluated. The potential for future
groundwater exposure was not assessed since it was determined that
the quality of the groundwater with regard to total chloride content
(as a result of saltwater intrusion) will not likely improve in the
future to a degree that area groundwater could be used for potable
purposes. Finally, other pathways were not evaluated because they
were determined not to be viable or were determined not to contribut~
significantly to overall exposure and risk. A summary of the
potential pathways of exposure under future conditions is provided in
Table 3.
7.1.3
Toxicity Assessment
To assess the possible toxicological effects from exposure to
hazardous substances, health effects criteria are derived from a
review of health and environmental standards and published
toxicological studies.
For assessment purposes, individual pollutants are separated into two
categories of chemical toxicity, depending on whether they exhibit
carcinogenic (cancer-causing) or noncarcinogenic effects. This
distinction relates to the current scientific opinion that the
mechanism which produces each effect is different and distinct.
Carcinogens:
Cancer potency factors (CPFs) have been developed by EPA's Carcinogen
Assessment Group for estimating excess lifetime cancer risks
associated with exposure to potential carcinogens, in an effort
to provide an upper-bound estimate of the lifetime cancer risk
associated with exposure at a particular intake level. The term
"upper bound" reflects the conservative estimate of the risks
calculated from the CPF. Use of this approach makes underestimation
of the actual cancer risk highly unlikely. Cancer potency factors
-------
Tabll' Z
Polentlal PathwaY!' 0' F..xposun to Contaminant.. O~lnaUna.t the Munl..port Property
IJnder c.urrent-II~ Conditions
Exposure Potential Potenlial Potential for
Medium Routes of Exposure Receptors Pathway Complete? Substantial Exposure
Soil (surface) Dermal absorption, incidental Trespas.~ers No. Site is densely vegetaled. The only area NA
ingestion where soil is exposed was not land filled.
Air Inhalation of volatile organics and/or Trespassers, nearl1y No. On-site air monitoring indicates volatile NA
fugitive dust residents organics are not present in the air at above
background concentralions. Dense vegetation
cover prohibils soils from becoming airborne.
Surface Dermal absorption, incidental TrespaAAers swimming in No. Trespas.'iCrs have not been observed NA
waterlSediment ingestion onsite lake swimning in the lakes. Lakes are deep with steep
sides that would make contact wilh sediment
difficult.
Uptake by fish with subsequent Trespassers fishing in Yes I.ow I
tV
ingestion by humans surface waters on and near 0\
I
the site
People fishing in nearby Yes Negligible
surface water bodies
Recreational users of other Yes Negligible
nearl1y surface water bodies
Groundwater Ingestion, inhalation, dermal Local residents No. Groundwater is not currently being used for NA
absorption II potahle supply in the vicinity of the site nor is it
being used 10 any significant extent for other uses
(e.g., watering lawns)
NA = Not applicable, pathway not complete.
Source: CDM, 1988
dhI077\009.51
-------
Tablr J
Potenllal Pathways 01 ":xposun 10 Contaminants Orl,!:llIalln~ allhe MunLspori Properly
tJ ndn "'ulun-' Isr (:ondilions
Exposure
Medium
POlential for
Suhstantial Exposure
Potential
Routes of Exposure
POlential
R ccept or.;
Palhway Complete?
Low
Soil
Dermal absorption, incidental
ingeslion
Air
Inhalation of volatile organies and/or
fugitive dust
Surface
water/sedimenl
Dermal absorption, incidental
ingeslion
Groundwater
Ingestion, inhalation, dermal
absorption
Worker.; or future user.; of
the sile (residents)
Worker.; or future user.; of
the site
Future recreational user.;
of the sile (swimming in
lakes)
/..ocal residents
Yes, if subsurface disturhance occurs.
Yes, if disturbance occurs in an area containing
contaminaled subsurface soil.
Yes
No. Municipal waler is supplied to local
residents; there is no development f,etween site
and groundwater discharge point. (the RiSCllyne
Bay) and saltwater inlrusion prevents
developmer.t of groundwater in the vicinity of the
site.
Low
Low
NA
NA = Not applicable, pathway not complete.
Source: CDM,I988
dht077\OOR51
I
N
-...J
I
-------
-28-
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.
Non-carcinogens:
Reference doses (RfDs) have been developed by EPA to indicate the
potential for adverse health effects from 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 humans, including sensitive individuals (e.g., children, elderly
people, etc.). 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
animal studies to which uncertainty factors have been applied (e.g.,
to account for the use of animal data to predict effects on humans)
or directly from human epidemiological studies. These uncertainty
factors help ensure that the RfDs will not underestimate the
potential for adverse non-carcinogenic effects to occur.
The health effects criteria for carcinogens and non-carcinogens that
were determined to be appropriate for this site are provided in Table
4. This table presents health effects criteria that were used to
evaluate risks posed by carcinogens present in surface water, soils,
and fish. No health effects criteria for exposure to site-related
contaminants through inhalation or exposure to contaminants found in
groundwater or sediments are included in Table 4. Considering the
contaminant concentrations, exposure pathways, and receptors, it was
determined that risks from exposure of those contaminants would be
negligible. Finally, although criteria were not available for some
of the contaminants of concern, the available data indicate that
these chemicals have relatively low toxicity in comparison with many
of the other chemicals being evaluated and consequently, do not
appear pose a significant incremental risk.
7.1.4
Characterization of Risks
Risks from the exposures identified in the two previous sections were
evaluated first by comparing concentrations of chemicals in the
contaminated exposure medium (i.e., surface water and soil) at points
of potential exposure with State of Florida and Federal environmental
standards, criteria, or guidance that were identified ARARs.
However, ARARs were not available for all chemicals in all media. A
complete quantitative assessment of risks associated with human
exposures to chemicals of potential concern in surface water and in
soil could not, therefore, be performed. Quantitative risk
assessment involves estimating intakes (doses) by potentially exposed
populations based on the assumed exposure scenario. These intakes
are then combined with cancer potency factors or compared with RfDs
to assess lifetime cancer risks or derive estimates of
noncarcinogenic hazards, respectively, to the potentially exposed
populations.
-------
-29-
Table 4
Health Effects Criteria for Chemicals in the Surface Water, Soil and Fish
At the Munisport Property
Chemical
Reference Dose (RID)
(mg/kg/dayil
Cancer PotenC\'
Factorb .
(mglkg/dayri
Weight
of Evidencec
Organics
Acetone
beta-BHC
Bis(2-ethylhexyl) ph thalate
urbon disulfide
Chloroform
4.4' -DDEe
PAHs (carcinogenic/
PCBs
Pentachlorophenol
Toluene
d1.Ox1O-1 D
1.84 C
2.Ox1O-2 6.84x1O-4 B2
LOx 10-1 D
LOx 10-2 8.1x1O-2 B2
5.Ox1O-4 3.4x1O-1 B2
11.5 B2
7.00 B2
3.Ox1O,2 D
d3.Ox1O'l D
Inorganics
Arsenic
Barium
Chromiumg
Copper
Cyanide
Lead
Manganese
Mercurv
Nickel
Phenol
Silver
Tin
Zinc
Vanadium
1.5
A
D
D
D
D
D
D
D
D
D
D
D
D
D
5.7xlO-2
5.OxlO-3
4.OxlO,2
2.9x1O-2
h6.Ox 1O"~
d2.2xlO,l
i2.OxIO-4
d LOx 10,2
4.OxlO-2
3.Ox 10-3
d6.4x1O-1
d2.IxlO-1
2.OxlO-2
a Except where noted. verified reference dose developed by EP A and reported in Integrated Risk
b Information System (IRIS) (EPA 1987a). ,
Oral cancer pOtency factors developed by EP A urcinogen Assessment Group and reponed In IRIS
(1987). Values in brackets are inhalation pOtency factors.
C EP A carcinogenic weight-of-evidence classification.
d RID derived from Health Effects Assessment for this chemical (EPA 19800).
e Values presented are for DDT.
f .
Values presented are for benzo[a] pyrene. These values are currently suspended by EPA pending
reevaluation of the data. However, these values will be used in this assessment to provide some
estimate of risk. .:
g Values presented are for chromium (VI).
h RID derived from EP A Office of Drinking Water analysis in support of the Maximum Concentration
. Level Goal (MCLG) (EPA 1985a).
I RID derived from EP A Office of Drinking Water analysis in support of the Heallh Advisory (EP A
1987d).
-- No criterion developed for this chemical and this type of toxicity.
Source: CDM. 1988
dbt077\047.51
-------
-.30-
Excess lifetime cancer risks are determined by multiplying the intake
level by the cancer potency factor. These risks are probabiliti~s
that are generally expressed in scientific notatiog (e.g., 1x10-
or 1E-6). An excess lifetime cancer risk of 1x10- indicates that
as a plausible upper bound, an individual has a one in a million
chance of developing cancer above the background risk as a result of
site-related exposure to a carcinogen over a 70-year lifetime under
the specific exposure conditions at the site.
Potential concern for non-carcinogenic effects of a single
contaminant in a single medium is expressed as the hazard quotient
(HQ) (or the ratio of the estimated intake derived from the
contaminant concentrations in a given medium to the contaminant's
reference dose). By adding the HQs for all contaminants within a
medium or across all media to which a given population may reasonably
be expected to be exposed, the hazard index (HI) can be generated.
The HI provides a useful reference point for gauging the potential
significance of multiple contaminant exposures within a single medium
or across media.
The Aiency normglly considers a range of cancer risks between 6
1x10- to 1x10- as protective, but uses a risk level of 1x10-
as a point of departure for s~tting cleanup levels at Superfund
sites. Consequently, a 1x10- risk level (i.e., one excess cancer
per million population exposed for a lifetime) was used as a
benchmark for this assessment.
The major conclusions of this human health risk assessment for the
Munisport site are summarized below.
7.1.4.1
Comparison to ARARs
Chemicals detected in samples collected from various groundwater and
surface water locations on and near to the Munisport property were
compared to their chemical-specific ARARs. Pursuant to Section
121(d)(2)(A) of CERCLA, as amended, ARARs are defined as Federally or
State promulgated cleanup standards, standards of control, and other
substantive environmental protection requirements. As such, only
Federally and State promulgated standards were used in the
comparison. Other local standards were not included as ARARs in this
comparison.
Although various chemicals were detected in groundwater samples
collected from the site and chemical-specific standards exist for
some of these constituents, the standards were determined not to be
relevant and appropriate. This portion of the Biscayne aquifer is
classified as a Class G-III (non-potable) aquifer pursuant to Section
17-3.401 of the FAC. As a result, drinking water standards such as
Maximum Contaminant Levels CMCLs) or Maximum Contaminant Level Goals
(MCLGS) developed for the protection of human health were not
considered applicable or relevant and appropriate and therefore were
not compared to the chemicals detected in the groundwater.
-------
-31-
With regard to samples collected from surfa~e water bodies located on
or near to the Munisport property, concentrations of chemicals
detected were compared to water quality criteria developed for the
protection of humans arid aquatic life from surface water exposures.
In the onsite lakes (former borrow pits), the mean and maximum
concentrations of un-ionized ammonia and the maximum concentrations
of copper, iron, and zinc exceeded the standards established by the
State of Florida for these chemicals in predominantly fresh waters.
However, it is not clear from the current data if all these chemicals
were truly elevated above background. Although neither copper nor
iron was detected in the background sample, the maximum concentration
of copper in the onsite lakes was close to the background detect~on
limit and the maximum concentration of iron in the lakes was much
lower than the background detection limit. Therefore, the maximum
concentrations of copper and iron in the onsite lakes may be within
the range of typical background levels, albeit at levels that exceed
Florida standards.
In the Oleta River and tributaries, of the available ARARs (e.g., no
ARAR was available for unionized ammonia in saltwater), "the mean and
maximum concentration of copper exceeded the State of Florida
standard for copper in predominantly marine waters. Again, it is not
known if copper was actually elevated above background because copper
was not detected in the background sample from the Oleta River.
Moreover, the detection limit was close to the mean and maximum
sample concentrations.
Finally, in the mangrove areas south and east of the Munisport
property, the maximum concentrations of aluminum, copper, iron, and
silver exceeded the State of Florida standards established for these
chemicals in predominantly marine waters. A comparison of the
concentrations of these chemicals along with their respective ARARs
is provided in Table 5. .
7.1.4.2
Estimates of Human Risk Under Current Use
As discussed in Section 7.1.2, Exposure Assessment, the only viable
pathway of exposure is ingestion of contaminated fish. Direct human
exposure to contaminated groundwater or surface water was not
considered viable since there are no pathways of exposure or
receptors.
For ingestion of fish from the onsite lakes (former borrow pits) and
the Oleta River and tributaries, the hazard index for non-carcinogens
is less than one under the average and plausible maximum cases. No
potential carcinogens were detected in surface water. However, both
carcinogens and non-carcinogens were detected in fish tissue from
mangrove areas south and east of the Munisport property. For
ingestion of fish from the south and east mangrove areas, the excess
lifetime cancer risks under the average agd plausibli maximum cases
based on measured tissue levels are 2xlO- and 2xlO- ,
respectively. Risks under both cases are due to potential arsenic
-------
-32-
Table S
Comparison of Surfar.e Water Concentrations with AR<\Rs
Munisport Landfill Propert~.
(~g/liter )
Concentration
Oleta River and South and
Onsite Lakes Tributaries Eas t Area
Chemical ARAR3 Mean Maximum Mean Maximum Mean Maximum
Aluminum b 1.500 NO NO 169 410 <200 11.800
Ammonia
(un-ionized) c20 160 6.800 NA NA r\A f\A
Copper b15 25 2~ <25 56
c30 16 50
Chromium 1,000 NO NO <10 9.3 NO NO
Cyanide 5 <10 0.04 NO NO NO ND
Iron b300 NO NO 120 3,100
c 1.000 125 1.300
Lead c30 ND ND NA NA NA NA
Manganese dl00 9.3 30 < 15 24 < 15 42
Nickel 100 (100)d NO NO NO NO <40 22
Silver bO.07 NO NO ND NO <10 70
Zinc c30 <2x1O-2 150 NA NA NA NA
3 Unless otherwjse noted, ARAR is the State of Florida criterion for this chemical (Rorida Administrative Code
17-3.051. 17.3.061. and 17-3:121).
b In predominantly marine waters.
c In predominantly fresh waters.
d Ambient water quality criterion for ingestion of fish and shellfish.
ND = Not detected or not detected at concentrations above b&ckground.
NA = Not appropriate; no appropriate criteria are available for comparison of chemical concentrations in these
samples.
Source: CDM. 1988
dbt077\048.51
-------
-33-
and PCB e7.posure. Two factors, however, should be considered in
interpreting these risks levels. First, the exposure scenario is
very conservative in that it assumes a fish consumption amount per
person that may overestimate the risk(s). Secondly, attributing the
two chemicals, for which the risks were calculated, to the Munisport
Landfill is questionable, since there is no documentation concerning
the disposal of arsenic-containing compounds at the landfill nor do
the analYtical data indicate that arsenic is present at the landfill
in quantities that could result in significant fish contamination.
With regard to the attribution of PCBs, they are ubiquitous compounds
characteristic of the effects of urbanization. Furthermore, the
analYtical data do not indicate the presence of quantities of PCB's
that could result in significant fish contamination. Therefore, the
use of these chemicals in the assessment of risks may be
inappropriate.
For non-carcinogenic exposure through fish ingestion, under the
average and plausible maximum case, the individual ratios between the
chronic daily intake (CDI) and RfD, in addition to the cumulative
hazard index, were less than one. This indicates that there is no
significant health risks associated with the consumption of fish
potentially containing non-carcinogenic chemicals.
The conclusion of significant cancer risk associated with the
ingestion of fish from the south and east mangrove areas does not
indicate that these risks are associated with the Munisport
property. As the analysis of the tissue data by the u.S. Fish and
Wildlife Service (FWS) stated, the tissue data do not verify that any
of the compounds detected in fish from the Munisport Landfill are
present at concentrations above those measured in fish taken from
control areas. Therefore, although there may be increased risks
associated with the ingestion of fish from the south and east
mangrove areas, these risks do not appear to be associated with the
Munisport Landfill property.
7.1.4.3
Estimates of Human Risk Under Future Use
In the absence of future remedial actions and institutional actions
limiting access to the site and surrounding area, the routes of
exposure quantified for current use also would apply in the future.
In addition, different land use of the site in the future may result
in additional exposures. As discussed in Section 7.1.2, Exposure
Assessment, potentially viable exposure pathways in the future
include dermal absorption and incidental ingestion of soil by future
residents, workers, and/or recreational users of the site. Dermal
absorption and incidental ingestion of chemicals in surface water by
persons swimming in onsite borrow pits was also considered. Under
the assumed future site uses, soil exposures could occur in any of
the site areas evaluated, particularly if the site is regraded during
future site use; such regrading would expose the soils and wastes at
greater depths.
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Surface Water Exposure
For potential surface water exposures to future swimmers in the
onsite lakes, the hazard index for the combined dermal absorption
and incidental ingestion exposure to noncarcinogenic chemicals
during swimming is less than one. The potential risks from
swimming in the onsite lakes are very conservative since the
exposure assessment assumes that area residents would frequent
the onsite lakes (former borrow pits) for swimming. It is
unlikely that these lakes would actually be used for swimming
since, as former borrow pits, the sides of the lakes have steep
slopes which would make access difficult.
There were no carcinogenic chemicals of potential concern
detected in the surface waters.
Soil Exposure
Residents: For exposures of future residents via direct contact
with soils in the ~andfiI17area, the lifetime excess cancer risk
is less than lxlO- (6xIO-) under the average case and
greater than lxlO-6 (lxIO-4) under the plausible maximum
case. The carcinogenic risk under the plausible maximum case is
due to potential exposure to arsenic and carcinogenic PARs. The
estimation of the risks from the potential exposure to these
contaminants should be viewed as a worst case scenario. The fact
that the chemicals were not detected frequently on or around the
landfill area nor were they typically detected at concentrations
significantly above levels characteristic of urban areas raises
questions as to whether or not potential risks from exposure to
these chemicals are representative of actual landfill
conditions. For exposure to non-carcinogens, the hazard index is
less than one under both the average and plausible maximum
exposure.
For potential exposures to future residents from direct contact
with soils in the landfill per~eter areas, the lifetime excess
cancer 5isk is less than lxlO- under both ;he average
(5xlO-l ) and plausible maximum case (2xIO-). The hazard
index for exposure to non-carcinogens under both the average and
plausible maximum case is less than one.
For potential future residential exposures to soils in
northeast area via dire6t conta,t, the lifet~e excess
risk is less than tX10- (~XIO-) for the average case
greater than lxlO- (6xIO-) for the plausible maximum
exposure. The risk under the plausible maximum case is due to
potential arsenic and PCB exposure. As with risks associated
with exposures to soil in the landfill area, the estimation of
risks should be viewed as a worst case scenario. Due to the
nature of the chemicals used in the assessment and the relatively
infrequent detection at low concentrations, it is questionable as
the
cancer
and
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tQ whether or not the potential risks from exposure to these
chemicals are representative of actual landfill conditions.
Erposures to chemicals exhibiting non-carcinogenic effects result
in a hazard index of less than one under both the average and
plausible maximum cases.
Workers: Exposure of future construction workers to chemicals of
potential concern at the Munisport Landfill was not assessed
quantitatively due to the uncertainty surrounding these potential
scenarios, particularly with respect to the chemicals and
concentrations to which workers might be exposed. Assuming the
reported soil chemicals and concentrations at the depths sampled
are representative of the chemicals and concentrations at the
depth to which future workers would be exposed, exposure and
risks to these individuals from direct contact with soils are
likely to be less than those to future residents because exposure
duration would be one to two orders of magnitude less (i.e., 0.5
to 1 year versus 18 years to a lifetime). However, exposure to
workers in the landfill could be greater than for residents and
may include significant inhalation exposures to volatile
chemicals if workers are exposed to greater concentrations of
chemicals while digging in the landfill. These exposures and
risks cannot be evaluated because of lack of appropriate soil
data from depths greater than 1 foot in the landfill.
Recreational Users: Exposure of future recreational users of the
Munisport property to soil contaminants also was not assessed
quantitatively. Assuming the reported soil concentrations are
representative of the chemical concentrations at the depth to
which future recreational users would be exposed, exposure and
risks to these individuals would likely be less than those to
future residents because exposure durations and frequencies are
likely to be much less.
7.1.5
Summary of Human Health Risks
In summary, the above analysis indicates that for a potential future
scenario for a person living for a lifetime at the landfill and at
the northeast area of the site, and having direct contact with soils
on a ;requent basis, may experience an !xcess lifetime cancer risk of
6xlO- under the average case and lxlO- under the plausible
maximum case. Risks to future workers and recreational users may be
less. Caution should be exercised in interpreting the above risk
estimates. ~though in general there are considerable uncertainties
inherent in risk assessment and it is common to use conservative
scenarios such as lifetime exposure (which is possible but not
likely), there are several aspects of the above risk estimates,
relating to the conditions and assumptions of exposure and the
toxicity criteria, that add an additional degree of uncertainty.
These are outlined below.
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Uncertai.nties 'Reaardipa. EXOOSllTe
The estimates of risk associated with soil exposures in the
future are based on the asswnption that the reported soil
concentrations determined from a limited number of samples
collected from just below the surface of the landfill, and at
approximately two feet in the northeast area are representative
of the actual lateral extent of soil contamination at the
Munisport Landfill, and also are representative of the chemicals
and concentrations at the depth to which future users of the area
may be exposed after any regrading. Between six and eight soil
samples were collected from each of three areas of the Munisport
property (landfill, landfill perimeter, and northeast area). The
area sampled was large (approximately 200 acres) and therefore,
the chemical concentrations determined from the small number of
samples may not be representative of actual concentrations at the
site. Calculation of exposure and risks using the available soil
concentration data may over- or underestimate risk.
The risk estimate for soil exposures in the landfill cover under
the plausible maximum case is due primarily to potential soil
exposures to arsenic and carcinogenic polynuclear aromatic
hydrocarbons (PAHs). Arsenic was detected only once in the
landfill cover area. Assuming the sampling data adequately
describe the lateral extent of soil contamination at the
Munisport property, arsenic is not a prevalent contaminant in the
landfill cover area. Therefore, exposure to the maximum or a
similarly high concentration for a lifetime is not likely to
occur, and the estimate of risk under the plausible maximum case
represents the extreme upper bound of potential exposure. With
respect to PAHs, although PAHs were at concentrations that were
elevated above the sample background level, these concentrations
were well within the background levels of total carcinogenic PAHs
typical of urban areas (100-175 mg/kg). PCBs were detected in
the soil of the northeast area, but these contaminants, like
PAHs, also are ubiquitous contaminants and are generally
indicative of urban contamination.
Many of the uncertainties surrounding estimates of exposure and
risk from direct contact with soil are related to questions of
the adequacy of the soil sampling data to sufficiently
characterize the vertical and lateral extent of contamination at
the Munisport Landfill. These uncertainties are themselves
related to the difficulty inherent in characterizing wastes at
landfills. Full characterization of wastes within a landfill is
nearly impossible because of the heterogeneous distribution of
waste materials throughout the landfill, the variety of waste
materials present, and the physical and chemical diversity of the
contaminants within the wastes.
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uncertainties Reaardina Toxicitv Criteria
There is considerable uncp.rtainty in the scientific community
regarding the cancer potency used to estimate riEks from mixtures
of carcinogenic PAHs. PABs occur in the enviro~~ent as complex
mixtures of many components with widely varying toxic potencies.
Only a few components of these mixtures have been characterized
adequately, and only limited information is available on
potential synergistic effects of the PAH mixture. The approach
adopted by EPA and used in this report as the basis for risk
assessment is to divide the PABs into two subclasses,
"carcinogenic" PAHs and "non-carcinogenic" PAHs, and to apply a
cancer potency factor derived from oral bioassays on
benzo[a]pyrene to the subclass of carcinogenic PAHs. Most
evidence indicates that benzo[a]pyrene is more potent than most
of the other carcinogenic PAHs and a mixture of carcinogenic
PAHsi therefore, this technique probably overestimates risk from
the carcinogenic PABs. However, this overestimation is offset by
the fact that not all carcinogenic PAHs are included in the
target compound list and therefore were not analyzed.
In conclusion, under current site conditions, the site does not pose
a significant threat to public health or welfare. Under future use
conditions, residents living on or adjacent to the northeast section
of the landfill may experience somewhat greater, but still minimal
risks. Future workers or recreational users of the landfill area are
not expected to experience any significant increase in risk due to
their relatively shorter period of exposure in comparison to
residents. Additionally, future risks were based on the absence
any land use restriction or institutional controls. Although it
not known for certain at this time, future land use restrictions
institutional controls may be imposed by State or local agencies
will further reduce future risks.
of
is
or
that
7.2
Environmental Risks
Potential environmental impacts of the chemicals of potential concern
at the Munisport property were also evaluated. This assessment was
initially based upon data collected during the 1988 EPA RI, data
obtained from the literature, and a cooperative study of the
Munisport area conducted by the EPA and the FWS. The results of the
initial assessment were inconclusive and, as a result, a subsequent
study was conducted by EPA in 1989 to further define the threat to
the environment. The general approaches and conclusions of this
environmental assessment are presented below.
7.2.1
Receptor Characterization
7.2.1.1
Initial Assessment
In this assessment, the environmental receptors potentially affected
by the chemicals associated with the Munisport Landfill were
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ij2ntified. In general, it is not considered feasible to assess
L~pac.~s to all receptors associated with CERCLA sites, as in the case
of ~he Munisport Landfill site. Rather, EPA selects representative
habt~cts or representative species from these habitats as indica.tors
of pot8ntial impacts. For the aquatic systems, the mangrove areas
and the Oleta River and other tributaries to Biscayne Bay were
selected as representative habitats for saltwater species. The
onsite lakes were selected as representative habitats for freshwater
species. Resident birds of the mangrove areas and resident mammals
of the upland areas adjacent to the landfill were selected as
receptors for terrestrial systems. A fifth category of potential
receptor was the endangered and threatened species of the Munisport
area.
7.2.1.2
Subsequent Assessment
Results from the initial assessment indicated that the ecological
community associated with the State Mangrove Preserve southeast of
the landfill may be adversely affected by contaminants migrating from
the landfill. The Mangrove Preserve not only supports one of the
last native stands of predominantly red and black mangroves in
Biscayne Bay, but also an aquatic community that plays an paramount
role in the support of the Bay ecosystem.
Wetland systems such as these perform numerous functions such as fish
and wildlife habitat, water quality improvement, flood protection,
shoreline erosion control, and recreation and aesthetics. With
regard to this system, one of the more important functions is the
support it provides in terms of food for the marine food chain and
habitat for numerous larval and juvenile fish species indigenous to
Biscayne Bay and the Atlantic Ocean. As vegetation (e.g., leaves and
stems) from the mangroves dies and falls into the water, it
decomposes into small particles of organic material known as
detritus. This nutrient-enriched material serves as the primary food
for many of the small aquatic invertebrates, shellfish, and fish that
serve as food for larger predatory fish. Many of these shellfish and
larger predatory fish are then harvested, either recreationally or
commercially, for human consumption. With regard to habitat, the
mangroves provide habitat for many different species of shellfish and
fish indigenous to Biscayne Bay and the Atlantic Ocean. Typically,
the larval and juvenile stages of many larger fish species harvested,
either recreationally or commercially from Biscayne Bay or the
Atlantic Ocean, require habitats such as the mangrove area during the
initial phase of their life cycle. Without habitats such as these
mangrove communities, the recreational and commercial value of many
of these fish species is severely impaired.
Finally, as more wetland areas are lost, the for survival pressure on
the few remaining organisms increases significantly.
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7.2.2. ~xpo~~re Assessment
7.2.2.1
Initial Assessment
Exposure to aquatic life in the surface water on and near the
Munisport property was initially assessed using the mean and maximum
concentrations of the chemicals of potential concern in surface
water. Exposure to chemicals of potential concern in fish was
estimated using data on contaminants present in fish collected from
the south and east areas, as reported by the FWS and EPA. Exposure
in birds was estimated using the great blue heron as a representative
receptor. It was assumed that a heron obtained 50% of its daily food
intake from the south and east area. Daily exposure intakes of
chemicals in fish collected from the mangrove areas were averaged
over the entire diet. Exposure to mammals in the upland areas of the
Munisport Landfill site was assessed assuming that a mammal may drink
from the onsite lakes and consume daily an amount of water equivalent
to 1% of its body weight. Exposure to the endangered and threatened
species of the area was qualitatively discussed. No other exposure
pathways were assessed for aquatic life, birds, mammals, or other
wildlife because, in most cases, adequate data to quantify exposure
or toxicity were not available.
7.2.2.2
Subsequent Assessment
As a part of the subsequent study conducted by EPA in June 1989, the
potential for exposure of various aquatic organisms to contaminants
migrating from the landfill was assessed. It was dt:::termined that
leachate-contaminated groundwater was emerging in the surface waters
of the Mangrove Preserve. Moreover, tidal stage was determin~d to
significantly affect the emergence of leachate in the Preserve. With
each receding of the tide, the upwelling of leachate-contaminated
groundwater increased to levels that were severely toxic to aquatic
life. Aquatic life potentially affected by this leachate includes
the eggs, larval, and juvenile stages of shellfish and fish that
migrate into the Preserve.
7.2.3
Environmental Risk Assessment
7.2.3.1
Initial Assessment
The available toxicity data for the chemicals of potential concern
for which exposure was initially assessed were reviewed to identify
toxicity values potentially useful in estimating risks to receptors.
Risks to aquatic life were assessed by comparing the surface water
concentrations to the State of Florida or Dade County criteria
established for Class III surface water or Ambient Water Quality
Criteria developed by EPA. Risks to birds ingesting contaminants in
fish were estimated only for surface water contaminants including
arsenic, chromium, 4,4'-DDE, mercury, and nickel, since adequate
toxicity data exist only for these chemicals. Estimated dietary
concentrations were compared to the selected toxicity value. Risks
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to mammals were estimated only for cyanide, manganese, phenol, and
vanadium because toxicity data were only available for these
chemicals. Again, risks were estimated by comparing the estLmated
dosages from drinking water with the selected toxicity value.
Absolute conclusions regarding the potential environmental impacts of
CERCLA sites often cannot be made. In the case of the Munisport
Landfill areas, it is difficult to determine if the chemicals and
concentrations observed are directly related to the landfill due to
the nature of the disposal activities occuring at this site. Also,
there are additional significant uncertainties surrounding estimates
of exposure and toxicity. Hence, upper bounds are established which
incorporated a margin of safety in order to be protective of
toxicologically sensitive species or weaker individual a of a
particular species.
Given the available data and limitations, several general conclusions
about the potential for endangerment of fish and wildlife in the
Munisport area were initially made.
2)
1)
The concentrations of chemicals in the surface water at the
Munisport property exceeded the acute and/or chronic AWQC or
the FDER or Dade County criterion for several chemicals.
Based on the potential for toxic effects to occur in these
waters, EPA conducted acute toxicity tests with water
collected from East Lake. These tests resulted in
significant mortality in fish and invertebrates. Chronic
toxicity tests conducted with samples collected from
Northeast Lake and the hydrologically altered wetlands
demonstrated toxic effects on sea urchins and macroalgae.
Although contaminants in these lakes are at levels that are
toxic to various aquatic life, these lakes or borrow pits
were created as a result of former landfill activities.
Typically, soil was excavated from depths as great as 30
feet below land surface for cover material. The groundwater
then filled these excavations, creating the lakes. As a
result, the depth of the lakes, the separation from natural
water bodies, and the physicochemical properties of the
water preclude the development and maintenance of a
beneficial aquatic community. Therefore, in the absence of
an aquatic community, the presence of normally toxic levels
of chemicals in the lakes does not represent a threat to the
environment associated with these man-made lakes on the
Munisport property.
The predicted concentrations of chemicals in the diet of
birds feeding on fish from the mangrove swamp adjacent to
the Munisport Landfill are one to three orders of magnitude
below the levels known to cause toxic responses in other
bird species, and adverse effects resulting from intakes of
these chemicals via the animal diet are not likely.
Exposure via other food items, water, air, and through the
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skin, will probably not result in any adverse effects.
Risks were estimated only for exposures to a subset of
chemicals measured in fish because adequate toxicity data
were available only for these chemicals. Other chemicals in
the swamp, however, may contribute to overall risk; the
magnitude of this contribution could not be estimated.
3)
The concentrations of cyanide, manganese, phenol, and
vanadium in the onsite lakes (former borrow pits) should not
be toxic to mammals that may ingest the lake water. The
estimated dosages for mammals for each chemical are well
below (five to six orders of magnitude) the selected
critical toxicity value. However, lakes or exposures via
different pathways may increase risks to mammals that may
frequent the Munisport property.
7.2.3.2
Subsequent Assessment
The results from the EPA Water Quality and Toxic Assessment Study
served to quantitatively and qualitatively assess risks to aquatic
organisms in the Mangrove Preserve. The study demonstrated that as a
result of the emergence of leachate-contaminated groundwater in the
Preserve, aquatic life was severely impacted. Both chronic and acute
toxicity tests were used to measure the effects of the leachate on
aquatic life. The results of these tests indicated significant
adverse effects in three of the four test species. The most severe
effects were observed using surface water samples collected at low
tide. Typically, there was no survival among the test organisms
exposed to water samples collected from the backwater portion of the
Preserve in comparison to approximately 70% survival among test
organisms exposed to water samples collected from background
locations in Biscayne Bay.
7.2.4
Environmental Risks Summary
Although the initial environmental assessment did not conclusively
demonstrate that the Munisport Landfill was a threat to the
environment, it identified several potential threats to the
environment. One such potential threat was to the aquatic life in
the Mangrove Preserve. Additional study by EPA of aquatic life in
the Preserve conclusively demonstrated that leachate-contaminated
groundwater from the landfill was emerging in the Preserve at a
concentration toxic to aquatic life. The results further measured
the toxic effects of the contaminants on the aquatic life. The study
concluded that, unless abated, the leachate will continue to
"severely impair the ecological functions of the Preserve and
preclude the development and maintenance of a balanced community of
aquatic biota".
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8.0
DESCRIPTION OF ALTERNATIVES
On the basis of past studies, including the 1988 EPA RI/FS and the
1989 EPA Water Quality and Toxic Assessment Study, it has been
determined that the Munisport property presents a significant threat
to the environment. The studies also established that the Munisport
Landfill represents no current or foreseeable threat to human health
or welfare. However, under State closure, cover of the landfill may
be necessary to reduce the likelihood of fires, odors, and/or safety
hazards.
The environmental threat is the result of leachate migrating from the
Munisport Landfill into the groundwater and subsequently migrating to
and surfacing in the Mangrove Preserve southeast of the site.
Consequently, EPA has developed a set of remedial action alternatives
specifically designed to abate the threat to the aquatic organisms in
the State Mangrove Preserve.
The objective of each of these remedial action alternatives is to
intercept the leachate-contaminated groundwater prior to its
emergence in the Preserve, collect the leachate-contaminated
groundwater, treat the contaminated groundwater to render it
non-toxic, and then return the treated effluent to the environment.
As presently designed, each of the remedial action alternatives will
accomplish this objective and ultimately be protective of the
environment. The differences associated with these alternatives
center primarily around ARARs, implementability, and costs. These
factors are discussed in detail in the comparative analysis section
of this document. To provide the reader with an adequate
understanding of the remedial action alternatives and to allow an
adequate comparative analysis of the alternatives, this section of
the ROD has been divided into several subsections. These subsections
address common elements among alternatives, scope of alternatives,
ARARs, and cleanup criteria.
8.1 Common Elements
An element common to all of the remedial action alternatives are
hydrologic improvements to the hydrologically altered wetland areas
and the Mangrove Preserve. The objective of these improvements is
the restoration of the full tidal connection between the Mangrove
Preserve and Biscayne Bay. Breaches will also be made in the dike
separating the altered wetlands and the Mangrove Preserve. These
breaches will serve to restore the tidal connection between the
altered wetlands with the Preserve and Bay.
A second element common to all of the alternatives is the closure of
the landfill proper under State authority. Although the landfill
closure will be conducted concurrently with the CERCLA remedial
action, the closure will be conducted under the authority of the
State since the landfill has not been shown to present a significant
threat to either human health or welfare or to contain a
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discrete source of contamination. Thus, EPA has determined that
action is not necessary under CERCLA to close the landfill; indeed,
such action would be duplicative of the ongoing State action. At the
same time, EPA believes that closure of the landfill is appropriate
in order to reduce the potential for future fires, reduce odors, and
minimize safety hazards. Thus, although FDER will direct this
closure, EPA will consult with FDER to ensure that the landfill
closure and Superfund response action are compatible. In the event,
however, that additional data collected prior to or during the
remedial design indicates that a larger portion of the landfill is
needed to implement the CERCLA response action, EPA will retain
juristiction over this larger portion of the landfill (54 FR 41002-3
(October 4, 1989 [FR excerpt contained in Appendix A]». Finally,
within five years of the completion of the CERCLA remedial and State
landfill closure actions, EPA will review the entire response to
ensure that the threat to the environment has been eliminated, as
required in CERCLA, Section 121(c). If the landfill has not been
properly closed by that time, EPA will consider further action under
CERCLA, if the situation so warrants.
Since each of the remedial alternatives will include actions taken
under CERCLA and State authority, an attempt will be made in the
discussion of the alternatives to identify which portions of the
landfill, Mangrove Preserve, and hydrologically altered wetlands will
be included in the Superfund response action. Consistent with the
definition of "on-site" in the National Contingency Plan (NCP), the
amount of land included in the CERCLA response action will include
the extent of the release of hazardous substances into the Mangrove
Preserve and that area on the landfill proper needed for the
construction of the various components to effect the response action
(40 CFR 300.400(e». Aside from the area of the Mangrove Preserve,
the estimated amount of land on the landfill proper required for the
CERCLA remedial action is approximately 30 acres. Of course, should
it be determined as a result of the hydrologic study that more area
is needed to implement the CERCLA remedy, the area of CERCLA response
will be expanded as appropriate. This ROD does not require action
under CERCLA for the remaining 140 acres of the landfill at this
time. (The significance of EPA's decision to address only part of a
larger site is discussed at 54 FR 41002-3 (October 4, 1989 [FR
excerpt contained in Appendix A]).
Each of the alternatives was developed as part of the 1990 FS
Addendum to identify and evaluate remedial 'action alternatives needed
to respond to the environmental threat. An initial set of
alternatives was first developed by a Technical Advisory Committee
(TAC). This TAC was organized to assist EPA and' FDER in developing
criteria for the CERCLA remedial action and State landfill closure,
respectively. The applicability and successfulness of the treatment
methods specified in the remedial alternatives were evaluated on the
basis of data collected from similar applications in industry or
remedial actions in which the same treatment method specified in the
remedial alternative was used.
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The treatment systems considered could not be evaluated using
site-specific data, site-specific hydrologic studies, treatability
studies, or pilot tests due to the lack of this information.
Therefore, a site-specific hydrologic study will be conducted during
remedial design for all of the alternatives (except "no action") to
develop information necessary to properly design the remedy. EPA
will consult with the TAC on the planning and review of the results
of the hydrologic, water quality, and other studies as appropriate.
These studies will be conducted to ensure that the selected remedy is
appropriate in view of local hydrologic conditions and that the
treatment system successfully removes the toxicity from the
contaminated groundwater. Only after these studies demonstrate the
expected performance will the response action proceed.
If data collected from the hydrologic study, treatability study,
and/or pilot tests demonstrate that the selected remedial action
needs to be modified, the necessary modifications will be made. The
modifications may include changes to the selected remedy or, if
necessary, the selection of a different remedy. EPA will consult
with the appropriate federal, state, local governments, and the TAC
before making significant modifications. The public will be notified
of any significant changes in the performance or cost of the remedy.
8.2
Scope of Alternatives
The following sections review each of the alternatives in terms of
the scope of the remedial action, treatment technologies, and cleanup
goals.
8.2.1
Alternative 1
(No Action)
CERCLA requires that a "No Action" alternative be evaluated at every
site to establish a baseline for comparison. This alternative would
include annual monitoring of the site but no further remedial action
under CERCLA. Although the landfill would be closed under State
authority, much of the waste below the water table would be expected
to generate and release leachate which would continue to adversely
affect .the aquatic life of the Mangrove Preserve.
The total present worth cost of this alternative including operation
and maintenance is estimated at $366,000. The amount of time needed
implement the monitoring system is estimated at six months.
8.2.2
Alternative 2
Treatment)
The scope of this remedial action alternative includes the
interception and collection of leachate-contaminated groundwater
using a series of recovery wells. Contaminated groundwater would be
treated using a mechanical pre-treatment system followed by
(Groundwater Recovery/Mechanical and Biological
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biological treatment in a constructed wetlands treatment system to
complete the removal of the toxicity from the contaminated
groundwater. The non-toxic treated effluent would then be discharged
to the State Mangrove Preserve. The treated effluent would also be
periodically monitored to ensure that applicable water quality
standards were met prior to discharge.
Leachate migrating from the landfill toward the southeast to the
Mangrove Preserve would be intercepted by an array of recovery wells
constructed along the landfill side of the Mangrove Preserve dike. A
total of 17 wells were estimated as necessary to effectively capture
both the vertical and lateral extent of the contaminant plume
projected in the EPA RI. The projected lateral extent of the plume
as modeled using ammonia as the indicator chemical is shown in Figure
6. Figure 7 shows the tentative positioning of the wells as
projected using contaminant fate and transport modeling computer
programs. It is likely that the wells would have total depths of
approximately 40 feet below land surface (bls) and be essentially
screened throughout the entire depth to ensure that the leachate is
adequately intercepted. In order to intercept the leachate, the
wells are expected to withdraw an estimated 1.2 million gallons per
day (mgd) of groundwater. It should be noted, however, that the
exact number, position, depth, screen interval, and pumping rate of
the wells would be defined on the basis of the data collected from
the site-specific hydrologic study. This could result in an increase
or decrease in the number or depth of the wells, and in the amount of
extracted groundwater that would require treatment and disposal.
Treatment would include both mechanical and biological treatment
processes. Since the leachate toxicity seems to be primarily related
to excessive levels of un-ionized ammonia, biological treatment in a
constructed wetlands treatment (CWT) system would be effective.
However, the amount of land required for construction of a wetlands
treatment system that would effectively remove contaminants to a
level at or below applicable water quality standards would be .
significantly greater than the amount of land available. Hence, some
form of pre-treatment would be needed to lower the influent ammonia
concentration and thereby reduce the acreage required for a CWT
system.
Air stripping of the leachate-contaminated groundwater is considered
a compatible method of pre-treatment. The groundwater would be
treated using a series of air stripping towers. The pH of the
influent would be raised to shift the ammonia to the free NH3-N
form, which would then be removed by passing an air stream (provided
by an onsite air blower) through the leachate in a series of
stripping towers. It is estimated, based on currently available
data, that five 14-foot diameter towers, each at about 20-foot column
height, would be required to reduce the ammonia concentration to an
acceptable concentration for continued treatment in a CWT system.
The actual number and size of towers would be determined based on the
results of the hydrologic and treatability studies and pilot tests.
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MUNISPORT'LANDFILL PROPERTY
LEGEND
— 10 — AMMONIA CONCENTRATION
CONTOUR (mg/l)
Source: COM, 1988
OBSERVED GROUNDWATER AMMONIA PLUME
MUNISPORT LANDFILL PROPERTY
NORTH MIAMI, FLORIDA
FIGURE
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Compliance with applicable air emission standards would be included
as part of the design criteria for the treatment system. Estimates
on influent and effluent concentrations associated with the air
stripping pond and land requirements for the CWT system are described
in detail in the FS Addendum (1990).
Based on experience at both municipal and industrial wastewater
treatment plants, biological treatment using a CWT system is an
effective method for lowering total ammonia nitrogen (NH3-N)
concentrations. Biological treatment depends on a process that
occurs in nature known as nitrification. Nitrification is a process
by which the microorganisms natural to wetlands chemically transform
NH3-N to nitrite (N02-N) and eventually to nitrate (N03-N), a
plant nutrient. A CWT system that would completely treat the
leachate would require an area for the treatment system of
approximately 100 acres. However, by pre-treating the influent to
reduce the ammonia concentration by approximately SO%, the amount of
land required for the CWT system would be reduced to approximately 40
acres.
It is anticipated that the CWT system would be constructed in the
hydrologically altered wetland area north of the Mangrove Preserve.
Figure 8 denotes adjacent land areas potentially available for the
construction of the CWT system. The areas are denoted in order of
preference in the figure along with the estimated size of the land
area.
Treated effluent from the CWT would be discharged to the Mangrove
Preserve. Prior to discharge, however, effluent from the CWT would
be monitored to ensure that ambient water quality criteria are met.
Finally, it is anticipated that, once the treatment is complete and
aquatic organisms in the Mangrove Preserve no longer experience toxic
effects, the dike separating the two areas would be breached and the
full tidal connection between the hydrologically altered wetlands and
Mangrove Preserve with Biscayne Bay restored. The timing of the.
hydraulic improvements relative to the CERCLA remedial action would
be assessed and determined based on the results of the hydrologic
study conducted prior to remedial design.
A contingency plan would be developed as part of the remedial
design. This contingency plan would consider the potential for
system malfunctions, power failures, and other adverse conditions
that could cause the recovery wells and/or .treatment system to become
inoperable. The contingency plan would provide mechanisms that would
keep the total system in an operable state and continue to mitigate
the toxic effects of the leachate-contaminated groundwater on aquatic
life of the Preserve until the primary components of the system could
be restored.
The total present worth cost for this alternative, including cost for
operation and maintenance over a IS-year period, is estimated at
$7,988,000. It is estimated that 18 months would be needed to
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3: 20 acres
4: 10 acres
5: 26 acres
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construct and implement the remedial action.
8.2.3
Alternative 3
(Groundwater Recovery/Mechanical Treatment)
This alternative incorporates the same method of leachate collection
and interception as described in Alternative 2. Contaminated
groundwater would be mechanically treated in an air stripping pond to
remove toxicity. Air stripping towers alone were not considered an
effective method of treatment due to the potential fouling of the
tower packing by high concentrations of total dissolved solids in the
groundwater to be treated. The non-toxic treated effluent may be
cycled back through the landfill to enhance the treatment process or
discharged to surface water. Results from the hydrologic and
treatability studies would be used to determine which of these two
methods will be the most appropriate for disposal of the treat~d
effluent. Either of the disposal methods selected would be designed
to comply with all ARARs.
Since treatment of ammonia with air stripping towers alone is not
considered an effective means of complete treatment, an alternate
approach is to conduct the air stripping in an onsite stripping
pond. Preparation of the influent would be similar to that required
for a tower, although a higher quantity of chemicals may be required
to maintain the pH. The stripping pond would be constructed on the
landfill proper and would likely require an area approximately four
to six acres in size. The pond would be located as close to the
recovery wells as possible; however, the precise location of the pond
would be determined during the conceptual design phase. The pH of
the influent to the pond would be increased to maximize the
percentage of ammonia in the free NH3-N form. Agitation and/or
spray systems would then be used to facilitate the air stripping of
the ammonia.
One possible method for disposal of the treated effluent would be to
cycle it back through the landfill to enhance the treatment process.
A second method would be to discharge it to adjoining surface waters,
such as the Southern Canal or the hydrologically altered wetlands.
If discharged to surface water, the effluent would be monitored to
ensure that the quality of water discharged complies with all
applicable standards.
The approach for cycling the effluent back through the landfill would
be to pump the effluent into one or more of. the existing lakes
(assuming they are not filled during landfill closure) on the
upgradient side of the landfill or into a series of shallow
subterranean trenches constructed in the northeast section of the
landfill. Neither option would be expected to have any adverse
effects on the groundwater since the contaminants would be removed
during treatment. Based on currently available data, this method of
disposal is a feasible approach. The exact method of discharge
(lakes or subterranean trenches) would be selected based on the
results of the site-specific hydrologic study and State
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requirements for closure of the landfill.
The appropriate method for disposing of the treated non-toxic
effluent (surface water or groundwater) would be selected on the
basis of the hydrologic and treatability studies conducted prior to
the remedial design. If surface discharge is selected as the most
appropriate, the effluent would be monitored, and if necessary
further treated, to ensure that ARARs are met.
A contingency plan would be developed as part of the remedial
design. This contingency plan would consider the potential for
system malfunctions, power failures, and other adverse conditions
that could cause the recovery wells and/or treatment system to become
inoperable. The contingency plan would provide mechanisms that would
keep the total system in an operable state and continue to mitigate
the toxic effects of the leachate-contaminated groundwater on aquatic
life of the Preserve until the primary components of the system could
be restored.
The total present worth cost for implementation of this remedial
alternative is estimated at $6,166,000. This estimate is based on a
1S-year period of operation and maintenance. The estimated time for
construction and implementation of this remedy is 18 months.
8.2.4
Alternative 4 (Positive Infiltration Hydraulic
Barrier/Groundwater Recovery/Biological Treatment)
The basic approach for Alternative 4 was developed by the TAC under
the supervision of FDER. This alternative was evaluated by EPA and
was included in the group of potential remedial alternatives on the
basis of its technical merit. Although the objective of the
alternative was well defined, in some instances, various elements of
the scope contained several different approaches to accomplish the
same task. Because it was necessary for EPA to prepare a cost
estimate for Alternative 4 and conduct a comparative analysis of
costs among all of the alternatives, it was incumbent upon the Agency
to assume certain features to properly evaluate the alternative. The
Agency recognizes that many of the elements of this alternative have
technical merit and may warrant further consideration. As a result,
a complete description of this alternative as recommended by the TAC
is provided in Appendix D.
Alternative 4 relies on techniques similar to those described in
Alternative 3 in that it would employ a hydraulic barrier in
conjunction with landfill leachate collection and treatment to
protect the Mangrove Preserve. The hydraulic barrier, however, would
rely on positive infiltration rather than withdrawal of the
groundwater. To ensure that the contaminated groundwater is not
merely contained or diverted to another area, the contaminated
groundwater would be withdrawn using a series of recovery wells
located in areas on the landfill exhibiting the highest levels of
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contamination. Treated effluent would then be discharged to surface
water. The basic approach to this alternative was developed and
recommended by the TAC. for the abatement of the threat to the aquatic
life of the State Mangrove Preserve. However, for purposes of
analyzing costs and implementability of the alternative, it was
necessary for EPA to modify certain elements of the approach.
The hydraulic barrier would be c~eated along the landfill side of the
Mangrove Preserve by constructing a diked, open trench, and
continually pumping uncontaminated water into the trench. A
tentative location for the trench is shown in Figure 9.. This would
maintain a level of water in the trench higher than that in the
Preserve and Biscayne Bay. This would, in essence, force down a
constant wedge of water into the aquifer, preventing the migration of
contaminated groundwater into the Preserve. This same effect may
also be accomplished by flooding the hydrologically altered wetland
area between the landfill and the Mangrove Preserve. The actual
method for construction of the barrier would be determined during
conceptual design after the collection and evaluation of
site-specific hydrologic data.
It is anticipated at this time that the water for the hydraulic
barrier would initially be obtained from some of the relatively
uncontaminated lakes along the south side of the landfill that remain
unfilled after landfill closure. Pumping of groundwater from these
lakes for the maintenance of the hydraulic barrier may effectively
induce a local groundwater gradient toward these lakes. Although
these lakes are relatively clean at present, this induced gradient
may result in the migration of contamination to the south and
subsequent contamination of these lakes. In the event the'lakes
become contaminated to the point that the water quality no longer
complied with applicable standards, the water would be treated prior
to use in maintaining the hydraulic barrier.
Although the hydraulic barrier could effectively prevent the
migration of leachate-contaminated groundwater from the landfill to
the Mangrove Preserve, it would merely contain or possibly divert the
contaminated groundwater around the Preserve to other areas.
Therefore, contaminated groundwater would be recovered from areas on
the landfill exhibiting the highest levels of contamination. The
method of leachate collection may include the pumping of groundwater
from wells or from the onsite lakes. The method of leachate
collection would be determined during the remedial design phase as a
result of the data collected during the hydrologic study. If
recovery were determined to be the appropriate method for groundwater
recovery, it is estimated that a total of 15 wells, pumping at a rate
of 1.3 MGD, would be required to effectively capture the
leachate-contaminated groundwater. A tentative location for the
groundwater recovery system is shown in Figure 9..
Since the groundwater recovered from the landfill area for treatment
would be expected to have a higher concentration of ammonia, and
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FLORIDA
INTERNATIONAL
UNIVERSITY
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possibly lower salinity, conventional biological treatment could be
used. This system would effectively treat organic compounds and
convert the ammonia to nitrite. However, it is anticipated that a
sufficient quantity of organic compounds would not be present in the
influent to complete the conversion to nitrate. The conversion would
be completed in a 10- to 20-acre CWT system constructed in the upland
areas on or adjacent to the landfill. According to FDER, the
leachate collection and treatment system would be required as part of
landfill closure under Florida's Landfill Closure Law.
If an effective leachate collection and treatment system is required
by FDER in the landfill closure, the extent of the Superfund response
action would be the construction of the hydraulic barrier along the
Mangrove Preserve dike. In the event that biological treatment is
determined not to be appropriate based on the results of the
hydrologic and treatability studies, an alternate method of leachate
treatment would be identified by FDER in consultation with EPA. If
treatment of leachate were not being performed in an adequate and
timely manner, EPA would evaluate whether action under CERCLA is
warranted.
A contingency plan would be developed as part of the remedial
design. This contingency plan would consider the potential for
system malfunctions, power failures, and other adverse conditions
that could cause the recovery wells and/or treatment system to become
inoperable. The contingency plan would provide mechanisms that would
keep the total system in an operable state and continue to mitigate
the toxic effects of the leachate-contaminated groundwater on aquatic
life of the Preserve until the primary components of the system could
be restored.
The total present worth cost for implementation of this remedial
alternative is estimated at $11,567,000. As discussed in the EPA FS
Addendum (Draft, 1990), this estimate was developed using currently
available information and is subject to change after the collection
of site-specific hydrologic data. As reported by FDER, the
hydrologic study may demonstrate that the scope of this alternative
is more cost effective than originally estimated in the EPA FS
Addendum. Furthermore, depending on the scope of the landfill
closure requirements identified by FDER, Alternative 4 may
incorporate elements that will fulfill some of the landfill closure
requirements and possibly reduce the total costs of the CERCLA
response and landfill closure actions. Finally, the estimate is
based on a 15-year period of operation and maintenance and projects a
construction and implementation time of 24 months.
8.3
ARARs
In addition to the issues associated with use of the hydrologically
altered wetland as part of the treatment system, there are several
ARARs and non-promulgated environmental standards or criteria to be
considered with the implementation of this remedy. These ARARs and
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environmental criteria to be considered (TBC) are listed as follows.
ARARs
- Federal
o Clean Water Act (CWA) , Ambient Water Quality Criteria for
surface water discharge.
o EPA Ambient Saltwater Quality Criteria for un-ionized
ammonia (EPA 440/5-88-004).
o CWA Section 402 NPDES Permit, Substantive Requirements.
o CWA Section 404, Permits for dredged or fill material.
- State of Florida
o Florida Water Quality Provisions, General and Class III
(both numeric and narrative) for all contaminants in
discharge.
o Florida Statutes (Chapter 258.397) which specify that
"no waste or effluent that would substantially inhibit thetl-
accomplishment of this section shall be discharged into
the preserve". This is an encompassing qualitative
criterion which would require that discharge from the
remedial action into any portion of the Biscayne Bay
Aquatic Preserve (including the Mangrove Preserve) not
result in any degradation of these areas.
o Pursuant to FAC Chapter 18-18.001, the effluent discharged
from the treatment system must not present a threat to the
accomplishment of the goals for the protection and
enhancement of the biological and aesthetic values of the
Biscayne Bay Aquatic Preserve (including the Mangrove
Preserve) .
o Pursuant to FAC Chapter 17-3, effluent entering the
Biscayne Bay Aquatic Preserve (including the Mangrove
Preserve) must meet Outstanding Florida Water Quality
Criteria, e.g., no discharge of contaminants above
background concentrations. .
o Pursuant to FAC Chapter 373, criteria are developed by the
South Florida Water Management District (SFWMD) to ensure
that the use of an aquifer is reasonable and beneficial,
and does not cause any adverse impact on users. These
criteria potentially apply to the recovery of
groundwater for treatment and the discharge of treated
effluent to groundwater.
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o Chapter 40E-3 and 40E-30, Florida Administrative Code,
contains standards for the construction of wells. The
substantive requirements for these standards will be
considered and used to supplement, if determined to be
more stringent, the EPA guidance for the construction of
wells. Moreover, no well construction permit will be
obtained from the SFWMD pursuant to Section 121(e}(1} of
CERCLA.
TBC
- Federal
Endangered Species Act, Section 7(a}, requires
consultation with the National Oceanic and Atmospheric
Administration (NOAA) and the Department of Interior (DOl)
to ensure that remedial actions taken pursuant to CERCLA
do not jeopardize or adversely modify or destroy critical
habitats of endangered or threatened species.
o Costal Zone Management Act, requires federal agencies to
conduct their activities in a manner that would be
consistent with local costal zone management plans.
o
o Applicable Air Quality Criteria. Potential volatile
organic compound (VOC) emissions should be limited to 3
pounds per hour, 15 pounds per day, or 10 pounds per year
(OSWER Directive 9355.0-28).
-State of Florida
o Chapter 17-701, Florida Administrative Code (FAC) ,
provides regulations for closure of landfills. These
regulations will be considered during the design of the
Superfund remedial action to ensure that the two actions
are compatible.
o Substantive requirements of the SFWMD stormwater runoff
regulations, FAC 17-25, will be considered during the
design of the Superfund remedial. action. No permits will
be obtained, however, pursuant to Section 121(e}(1} of
CERCLA.
- Dade County
o Dade County Criteria for Surface Waters (Dade County Code,
Chapter 24, Section II), total ammonia (500 ug/l) and
un-ionized ammonia (20 ug/l) (un-ionized ammonia for
predominantly freshwater).
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o Dade County Criteria for Groundwater (Dade County Code,
Chapter 24, Section 11), total ammonia (500 ug/l) and
un-ionized ammonia (20 ug/l), both expressed as N.
o Air Quality Standards (Air Stripping).
o Dade County Wellfield Protection Plan mandates no net
loss of water from the BiscaYne aquifer. .
8.4
Cleanup Criteria
The objective of this Superfund remedial action is to remove the
toxicity associated with the groundwater that is currently emerging
in the State Mangrove Preserve. This would be accomplished by
incorporating two elements. First, the leachate-contaminated
groundwater would be intercepted before it could emerge in the
surface water of the Preserve. Second, this contaminated water would
be collected and treated to remove its toxicity. Since the
contamination is resulting from a continual release of contaminants
from the landfill, and since it would be infeasible to completely
remove the source of contamination (i.e., the 170-acre landfill),
monitoring of surface water and groundwater during and after the
remedial action would be necessary to measure the effectiveness of
the remedial action and to determine the point at which the remedial
action is complete.
This basic criteria for cleanup of the site are the same for all of
the remedial alternatives that include remedial action at the site.
Since the details for meeting the cleanup criteria vary among the
alternatives, a detailed description of the cleanup criteria is
provided only for the selected remedy. The detailed discussion is
provided in section 10.3 of this ROD.
9.0
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
This section provides the basis for determining which alternative
provides the "best balance" of trade-offs with respect to the
evaluation criteria. A glossary of the evaluation criteria is
provided in Table 6.
9.1
Overall Protection
All of the alternatives, with the exception of the "no action"
alternative, would provide adequate protection of the environment by
eliminating, reducing, and/or controlling the threat to the
environment through treatment and engineering controls. With the
exception of the "no action" alternative, all of the alternatives
would intercept, collect, and treat the leachate-contaminated
groundwater, thus reducing the toxicity to aquatic organisms in the
State Mangrove Preserve. Because the "no action" alternative would
not be protective of the environment, it is not considered further in
this analysis.
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TABLE 6
EVALUATION CRITERIA
Overall Protection of Human Health and the
Addresses whether or not a remedy provides
and describes how risks posed through each
eliminated, reduced, or controlled through
controls, or institutional controls.
Environment -
adequate protection
pathway are
treatment, engineering
Compliance with ARARs - Addresses whether or not a remedy will
meet all of the applicable or relevant and appropriate
requirements of other Federal and State environmental statutes
and/or provide grounds for invoking a waiver.
Lona-Term Effectiveness and Permanence - Refers to the magnitude
of residual risk and the ability of a remedy to maintain reliable
protection of human health and the environment over time once
cleanup goals have been met.
Reduction of Toxicitv. Mobilitv. or Volume Throuah Treatment -
Refers to the anticipated performance of the treatment
technologies that may be employed in a remedy.
Short-Term Effectiveness - Refers to how quickly the remedy
achieves protection, as well as potential adverse impacts on
human health and the environment that may occur during
construction and implementation of the remedy.
Implementabilitv - Refers to the technical and administrative
feasibility of a remedy, including the availability of materials
and services needed to implement the chosen solution.
Cost - Includes capital and operation and maintenance costs.
State Acceptance - Indicates whether, based on its review of the
RI/FS and Proposed Plan, the State concurs with, opposes, or has
no comment on the preferred alternative.
Communi tv Acceptance - Assessed in the Record of Decision
following a review of the public comments received on the RI/FS
report and the Proposed Plan.
Source: 40 CFR 300.430(e)(9) (1990) and 55 FR 8849
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9.2
Compliance with ARARs
All of the alternatives would meet their respective ARARs of Federal
and State environmental laws.1 The planned remedial action
complies with the standards of the CWA, including Section 404(b)(1),
standards (40 CFR Part 230), and the Section 404(c) standard (no
acceptable adverse effects on municipal water supplies, fish and
shellfish areas, wildlife or recreation).
The distinction among the alternatives, with respect to ARARs, is
with the number of ARARs that must be complied with for each
alternative. Each of the alternatives would require discharge of
treated effluent. Effluent associated with Alternative 2 (recovery
wells/CWT system) would be discharged to surface water. Alternative
3 may discharge treated effluent to surface water or groundwater.
Effluent associated with Alternative 4 would be discharged only to
groundwater through the positive infiltration system. As indicated
in section 8.3, there are a significant number of ARARs that must be
complied with if treated effluent is discharged to surface water.
The most stringent include the state r~gulations such as Outstanding
Florida Water'Quality Criteria and the General and Class III Waters
Criteria.
These criteria provide for no degradation of water quality through
requirements such as no toxicity and compliance with numerical
standards. These criteria would apply not only to ammonia, but all
of the chemicals present in the groundwater that may potentially be
discharged to surface water. .
Since the groundwater in the vicinity of the site is saline and not
potable, it has no reasonable potential as a future source of
drinking water. This portion of the BiscaYne aquifer is classified
as a Class G-III (non-potable) aquifer pursuant to Section 17-3.401
of the FAC. As a result, drinking water standards (MCLs or MCLGs)
developed for the protection of human health are not applicable or
relevant and appropriate. .
Criteria contained within the FAC, Section 17-3.401, also provide for
the protection of aquatic life in surface water at the point of
discharge from groundwater. The FDER criteria would be considered
relevant for the contaminants present in groundwater. Alternative 3,
with groundwater discharge of treated effluent, would effectively
comply with this ARAR. Treated effluent would be cycled back through
the landfill and recollected by the recovery wells for additional
treatment. By recycling the treated groundwater through the
1 The CWA 404(c) action taken in 1981 allows the excavation of up
to 19 acres of wetland areas for landfill cover. The CERCLA action
will involve considerably less impact on the wetlands than is
permitted under the 404(c) action.
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aquifer, groundwater from the site area would be prevented from
discharging into nearby surface water, and thus the alternative would
comply with the FDER ARAR. Since Alternative 4 relies on the
discharge of treated effluent to groundwater to help maintain the
hydraulic barrier, the potential exists for groundwater from the
hydraulic barrier to migrate eastward toward (and surface in) the
waters of the Mangrove Preserve. As a result, treated effluent would
have to be monitored prior to discharge to the hydraulic barrier to
ensure compliance with the applicable water quality standards.
In addition to ARARs, two other regulations were identified for
consideration. The first of these is the State of Florida SFWMD
permitting requirements that regulate discharges to groundwater.
Specific concerns of SFWMD at this site are that discharge of
potentially saline water into the aquifer may induce additional
saltwater intrusion. Based on currently available data, EPA has
determined that the saltwater intrusion effects would be minimal, if
any, since the point of discharge to the aquifer is well beyond the
zone of saltwater intrusion. EPA plans to augment available
hydrologic data with additional study during remedial design. These
data will be used to validate the appropriateness of groundwater
discharge of treated effluent. If discharge of treated effluent to
groundwater is determined to be appropriate, pursuant to Section
121(e)(1) of CERCLA, EPA is not required to obtain a permit for the
onsite portion of an Superfund remedial action. Since any discharge
of effluent would occur onsite, the substantive requirements of this
regulation would be met but no permit would be necessary.
The other environmental regulation to be considered pertains to the
protection of the integrity of the freshwater portion of the Biscayne
aquifer. As part of the Dade County Wellfield Protection Plan, there
are provisions that call for essentially no net loss of water from
the Biscayne aquifer as a result of surface water discharges from
groundwater resources. This is considered a water conservation
mechanism that further protects the potable portion of the Biscayne
aquifer from saltwater intrusion. Alternatives 3 (with groundwater
discharge option) and 4 would both comply with this county
regulation. Alternative 2, which includes surface discharge of
treated effluent, would not comply with this regulation.
In summary, Alternative 3 (recovery wells/air stripping/groundwater
discharge) would have the least number of ARARs with which to
comply. Alternative 4 (positive infiltration) would have to comply
with the FDER water quality standards for discharge of treated
effluent to groundwater. The substantive requirements of the State
of Florida SFWMD regulations concerning groundwater discharge would
be considered, but no permit would be required due to the onsite
nature of the actions and minimal effects on saltwater intrusion.
Moreover, these two alternatives would comply with Dade County water
conservation policy. Alternatives 2 (recovery wells/CWT system) and
3 (recovery wells/air stripping/surface water discharge) would comply
with the numerous State and Federal water quality criteria. These
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two alternatives, which incorporate surface discharge of treated
effluent, would comply with the SFWMD regulation concerning saltwater
intrusion, but not the Dade County water conservation policy. In
consideration of all of" the ARARs and TBCs, Alternatives 3, with
groundwater discharge, would achieve the best balance.
9.3
Lona-Term Effectiveness and Permanence
All of the remedial action alternatives would effectively mitigate
the release of toxic leachate from the Munisport Landfill to the
State Mangrove Preserve. It should be noted, however, that the
effectiveness and permanence of Alternative 4 (positive infiltration
hydraulic barrier) would be contingent on the incorporation of a
leachate collection and treatment system as part of the landfill
closure requirements. Without this requirement for Alternative 4,
the remedial action would only contain or divert the contaminants and
would result in a- lesser degree of long-term effectiveness and
permanence than Alternative 3.
9.4
Reduction of Toxicity, Mobility, or Volume of the Contaminants
throuah Treatment .
All of the alternatives would reduce the toxicity of the leachate"
through interception, collection, and treatment. The alternatives
would also reduce the mobility and volume of the contaminants by
intercepting and treating the leachate-contaminated groundwater. It
should be noted, however, that the ability of Alternative 4 to
effectively reduce the toxicity, mobility, and volume of contaminants
present in the leachate would be contingent on the incorporation of a
leachate collection and treatment system as part of the landfill
closure requirements. Without this requirement for Alternative 4,
the remedial action would only contain the contaminants and not serve
to reduce their toxicity or volume. Moreover, without collection and
treatment of the contaminated groundwater, the potential exists for
contaminants to be diverted further into the Mangrove Preserve or to
other surface waters.
9.5
Short-Term Effectiveness
Factors affecting the short-term effectiveness of the alternatives
mainly include administrative considerations common to each of the
remedial alternatives. Moreover, each of the alternatives would
require the same type of design studies prior to construction of the
remedy. Hence, no significant distinction can be made among the'
alternatives on the basis of short-term effectiveness.
9.6
ImDlementabilitv
The main distinctions among the alternatives center around the
methods of treatment and disposal of treated groundwater. Treatment
methods include air stripping or biological treatment, or some
combination of the two. Disposal methods for the treated groundwater
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include discharge to surface water or groundwater. Since each of
these methods of treatment and disposal have unique implementation
concerns, it is difficult to identify the most implementable
alternative.
Finally, Alternative 4 has several contingencies associated with the
remedy. For example, in order for the remedy to be effective in
maiLtaining the hydraulic barrier, it must have a constant supply of
uncontaminated water. Moreover, landfill closure requirements must
provide for the collection and treatment of leachate-contaminated
groundwater so that it would result in an permanent solution that is
protective of the environment.
9.7
Cost
Cost estimates were based on presently available data and are
dependent on paramaters such as leachate content and concentration,
salinity, and volume, in addition to actual cost of CWT construction.
Alternative 3 (recovery wells/air stripping) represents the lowest
total present worth cost of the alternatives at $6,166,000. This
alternative also represents the lowest capital cost among the
alternatives at $2,895,000. Operation and maintenance (O&M) costs
over a 15-year period are also the lowest among the alternatives
evaluated with a present worth cost of O&M of $3,271,000.
Alternative 2 (recovery wells/CWT system) would represent the next
lowest total present worth cost at $7,988,000. Alternative 4
(positive infiltration/biological treatment) represents the least
cost-effective alternative with a total present worth cost of
$11,567,000. However, as discussed previously, the results from the
hydrologic study may indicate that the scope of Alternative 4
warrants modification such that the remedy may be as, or more, cost
effective than the other two remedial alternatives considered.
Furthermore, depending on the scope of the landfill closure.
requirements identified by FDER, Alternative 4 may incorporate
elements that will fulfill some of the landfill closure requirements
and possibly reduce the total costs of the CERCLA response and
landfill closure actions.
9.8
State Acceptance
The State of Florida, as represented by FDER, has been consulted and
concurs with the selection of this remedy. . The State concurrence
letter is included in this ROD as Appendix E.
9.9
Community Acceptance
Based on comments made by citizens at the public meeting held in
North Miami on March 29, 1990 and comments received during the public
comment period, there was general concurence that the leachate should
be intercepted and treated to remove the toxicity before it emerges
in the Preserve. From a technical standpoint, no real preference was
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indicated with regard to the best alternative to accomplish this
task. Comments provided by the citizens did indicate opposition to
surface discharge of the treated effluent. Concern was also
expressed that the landfill proper presented a threat to public
health and should be addressed in the remedial action. A
presentation of all comments received from the general public and
various government agencies and EPA's response to these comments is
provided in the Responsiveness Summary section (Appendix B) of this
document.
10.0
SELECTED REMEDY
Based on a comprehensive review of currently available data and
careful consideration of comments provided on the remedial action
alternatives, EPA has determined that the most appropriate method of
remedial action to abate the threat to the aquatic life of the
Mangrove Preserve is to intercept, collect, and treat the
leachate-contaminated groundwater prior to its emergence into the
Preserve. This remedial approach may be accomplished through the
implementation of either Alternative 3 which incorporates a
demonstrated technology or Alternative 4 which incorporates an
innovative technology. .
Alternative 3 will provide for the abatement of the environmental
threat to the Mangrove Preserve. It will achieve substantial risk
reduction through the interception, collection, and treatment of
leachate-contaminated groundwater. Implementation of this remedy
will be in compliance with all ARARs. Based on currently available
information, Alternative 3 represents the alternative with the lowest
present worth cost and will be the most implementable. It is,
therefore, determined that Alternative 3 will provide the best
balance of trade-offs among alternatives with respect to the nine
evaluation criteria. However, as discussed in the following,
Alternative 4 may ultimately prove to be as, or more, cost effective
and implementable that Alternative 3 after the collection' and review
of additional hydrologic data. .
The remedial action approach contained in Alternative 4 is similar to
Alternative 3, with the primary difference centering around the
method used to effect the hydraulic barrier. Alternative 4 uses a
technology referred to as positive infiltration to effect the
hydraulic barrier. EPA views this as an innovative technology with
regard to the control of releases of hazardous substances at
Superfund sites. Since EPA lacks the site-specific hydrologic data
to definitively assess the appropriateness of this technology and
since this method may be ultimately be more cost effective and
implementable than the proven technology of recovery wells, EPA has
determined that this innovative technology warrants further
consideration as a method to construct the hydraulic barrier.
Pursuant to the NCP, specific criteria are provided for the
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evaluation of innovative technologies in comparison to proven
technology (55 FR 300.430(a)(1)(iii)(E)). The criteria enable EPA to
select the use of innovative technologies over demonstrated
technologies when it can be shown that the innovative technology
"offers the potential for comparable or superior treatment
performance or implementability, fewer or lesser impacts than other
available approaches, or lower costs for similar levels of
performance than demonstrated technologies. Hence, the innovative
technology will not be appropriate if the results from the hydrologic
study indicate that the innovative technology does not achieve the
same level of performance, implementability, protection, or cost
effectiveness as the demonstrated technology.
Although two acceptable technologies exist at this time regarding the
construction of a hydraulic barrier, EPA determined that it would be
appropriate to provide a discussion in the following section that
addresses the remaining components (i.e., treatment, effluent
disposal) of the selected remedy in the event that the demonstrated
technology (e.g., recovery wells) is determined to be the most
appropriate technology for construction of the hydraulic barrier.
However, if the results of the hydrologic study demonstrate that the
innovative technology (i.e., positive infiltration) is the most
appropriate method to construct the hydraulic barrier, the other
components of the remedy may change accordingly. The other
components to the remedy such as treatment and disposal of the
effluent will likely be the same as that provided in the discussion
of Alternative 4 in Section 8.2.4. However, the treatment and
effluent disposal methods may be modified based on the results of the
hydrologic design study. .
As previously discussed, the actual location and specific design of
this remedy will be determined based on site conditions documented
during the hydrologic study. The most appropriate location of the
remedial action will be determined in remedial design and will be
subject to review by FDER. Furthermore, the design and placement of
the remedial action will be designed to minimize the migration of
leachate beyond the "the zone of compliance" pursuant to State of
Florida landfill closure regulations. The selected remedy is
discussed below in terms of the scope of the remedy, operation and
maintenance, cleanup criteria, and associated actions.
10.1
Scope of Remedv
Leachate migrating from the landfill to the southeast will be
intercepted by an array of recovery wells constructed along the
landfill side of the Mangrove Preserve dike. Using currently
available data, it was estimated that a total of 17 wells would
effectively capture both the vertical and lateral extent of the
contaminant plume projected in the EPA RI. The projected lateral
extent of the plume as modeled using ammonia as the indicator
chemical is shown in Figure 6. Figure 7 shows the tentative
positioning of the wells as projected using contaminant fate and
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I
-65-
transport modeling computer programs. Its is likely that the wells
will have total depths of approximately 40 feet below land surface
(bls) and be essentially screened throughout the entire depth to
ensure that the leachate is adequately intercepted. In order to
intercept the leachate, the wells are expected to withdraw an
estimated 1.2 mgd. It should be noted, however, that the exact
number, position, depth, screen interval, and pumping rate of the
wells will be defined on the basis of the data collected from a
site-specific hydrologic study to be conducted during the remedial
design.
Contaminated groundwater recovered from the wells will be pumped to
the treatment system located on the landfill proper, the exact
location of which will be selected during the remedial design phase
of the project. Major components of the treatment system include a
pH adjustment tank, an air stripping pond, and a pH readjustment
tank. A schematic diagram of the treatment system is provided in
Figure 10. Based on estimates using currently available hydrologic
data, it is anticipated that the air stripping pond will be 4 to 6
acres in size and lined with a compatible material to prevent the
seepage of water from the pond into the ground. The pH of the
influent to the treatment system will be adjusted chemically to
between 11.0 and 11.5 to maximize the removal of the ammonia. The pH
of the effluent from the stripping pond will then be readjusted, if
needed, prior to disposal. As with the placement of the recovery
wells, the sizing of the various treatment components will be based
on the data collected from the site-specific hydrologic study and a
treatability study to be conducted prior to the remedial design.
The treated effluent will then be pumped to a series of shallow
subsurface trenches constructed in the northwest section of the
landfill or to nearby surface waters for disposal. The most
appropriate method for disposal of the effluent will be selected
based on the results of the hydrologic and treatability studies
conducted prior to remedial design. If groundwater disposal is
determined appropriate, the treated effluent will be allowed to
infiltrate through the landfill and back into the aquifer. This will
potentially enhance the treatment process and should not have any
adverse effects on the groundwater nor the microbial action within
the landfill since the contaminants will be removed during
treatment. Moreover, the high sulfide content naturally occuring in
marine environments is such that the metals potentially present in
the landfill will be bound in a metallic precipitate and retained in
the landfill. The surface area required for infiltration of the
effluent is less than one percent of the total landfill area
and, as such, will likely have minimal effects on the hydrology,
leachate generation, or microbial action of the landfill.
Based on currently available data, groundwater disposal is a feasible
approach. The exact method of discharge (lakes or subterranean
trenches) will be selected based on the results of the site-specific
hydrologic study. However, if the results from the hydrologic and
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SEF64014.Pf-
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Recovery
Well (Typical)
i
Aeration with Mechanical
Agitation or Spray Aeration
Air Stripping Pond
PRELIMINARY PROCESS FLOW DIAGRAM
MUNISPORT lANDFill PROPERTY
NORTH MIAMI, FLORIDA
pH Adjustment
:"I':
Infiltration
Area
I
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I
FIGURE
10
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treatability studies demonstrate that discharge to nearby surface
waters such as the hydrologically altered wetlands or the Southern
Canal is more appropriate, the treated non-toxic effluent will be
discharged to surface water. The effluent will be monitored and, if
necessary, treated further prior to discharge to ensure that ARARs
are met.
10.2
Operation and Maintenance of Remedv
The O&M will include the monitoring of system controls to ensure that
the system is operating properly. The routine O&M procedure would
require that an operator be present onsite periodically to monitor
the performance of the recovery, aeration, and discharge system
components. Efficient operation of an air stripping system requires
periodic cleaning. or replacement of system components (such as the
spray irrigation heads) to avoid accumulated biological growth or
precipitated matter that could clog the system and reduce
efficiency. Periodic monitoring of the groundwater and surface water
as described in section 10.3 will also be required as part of the O&M
of the remedial action. To document that the groundwater recovery,
treatment, and disposal system is operated and maintained properly,
an O&M log will be maintained throughout the period of the remedial
action and made available to EPA for periodic review.
A preliminary cost analysis for the construction and O&M of the
remedial action, as currently designed, is provided in Table 7. As
discussed earlier, as a result of the data provided from the
site-specific hydrologic and treatability studies, modifications to
the conceptual design may be required. These modifications will be
made by EPA, after consultation with other Federal, State and local
agencies. The public will also be notified of any significant
changes to the remedial design. This cost breakdown does not include
the cost associated with the required monitoring as defined in the
cleanup goals section. Based on historical information regarding the
amount of time required for organic refuse in sanitary landfills to
decompose, it is estimated that the groundwater recovery, treatment,
and disposal system may have to operate for a period of 15 to 25
years; cost estimates, however, were based on 15 years of O&M.
10.3
Cleanup Criteria for Selected Remedv
The effectiveness of the remedial action during the period of
operation will be measured on the basis of toxicity and other
chemical and physical indicators. Three separate protocols, as
discussed below, will be used to measure the effectiveness of the
hydraulic barrier and the treatment system and to determine the point
at which the remedial action is complete.
10.3.1
Hydraulic Barrier
Based on hydrologic principles and available hydrologic data, the
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Table 7
Selected Remedy Preliminary Cost Analysis
Munisport Landfill Property
Leachate Collection wlEastem Recovery Well Array
Construction Cost
$ 535,000
65,000
Annual O&M Costs
Onsite Treatment in Stripping Pond
Construction Cost
$1,425,000
Annual O&M Costs
25': ;000
Enhanced Flushing North of Landfill 2,000 LF
Construction Cost
$ 745,000
75,000
Annual O&M Costs
Monitoring
Construction Cost
Annual O&M Costs
$190,000
35,000
Total Annual O&M Costs
$2,895,000
$430,000
Total Construction Cost
Total IS-Year Present Worth
(Including O&M)
$6,166,000
dbt077\O 12.51
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groundwater recovery system will produce a hydraulic barrier to
groundwater movement. This should effectively intercept leachate
that migrates through the landfill that is with in the cone of
influence of the recovery well system. This basis, however, would be
validated by the measurement of various chemical and physical
parameters.
Chemical parameters will include un-ionized ammonia and total
chlorides in surface water samples collected from various locations
within the Mangrove Preserve and BiscaYne Bay. Since
leachate-contaminated groundwater migrating from the landfill is
contaminated by significantly elevated levels of un-ionized ammonia,
the hydraulic barrier should effectively intercept this contaminated
groundwater and result in a significant decrease in the concentration
of un-ionized ammonia in the surface water samples collected from the
Preserve. If the hydraulic barrier is effectively intercepting the
leachate, concentrations of un-ionized ammonia present in surface
water samples collected from the Preserve should be comparable to
those from Biscayne Bay.
A second chemical measurement will be based on a gradient of total
chlorides present in samples collected from the groundwater recovery
system and surface water collected from the Mangrove Preserve and
BiscaYne Bay. Since the hydraulic barrier should effectively remove
any input of freshwater (lower total chlorides) into the Mangrove
Preserve, the concentration of total chlorides should increase to a
level comparable to that of BiscaYne Bay. This would be expected
since the Bay has a higher concentration of total chlorides and would
be the primary influence on the concentration of chlorides present in
the Mangrove Preserve.
Another method of judging effectiveness of the hydraulic barrier will
be based on physical measurements of groundwater levels and
groundwater modeling of the data. A baseline will be established
prior to implementation of the hydraulic barrier. Measurements will
be made periodically thereafter to evaluate the effectiveness of the
hydraulic barrier. .
Physical and chemical parameters will be measured periodically to
validate the effectiveness of the hydraulic barrier. The frequency
of these measurements will be based on the effectiveness of the
hydraulic barrier and will likely decrease with tLme. It is
anticipated that measurements will be made on a quarterly basis
during the first two years of operation to calibrate the system.
Assuming that the barrier is effectively intercepting the leachate-
contaminated groundwater migrating into the Mangrove Preserve, the
the monitoring interval will be increased to a semi-annual
frequency. It is anticipated that this monitoring frequency will be
maintained for an additional five years of operation, and then
increased to an.annual monitoring frequency for the duration of the
remedial action, assuming that the system is still fulfilling its
design objective. If the data collected from any of thes~ periods of
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monitoring indicate that the system is not effectively capturing the
leachate-contaminated groundwater prior to its emergence to the
Mangrove Preserve, a contingency plan will be Lmplemented to further
evaluate the effectiveness of the hydraulic barrier and to determine
the need for design modifications.
This contingency plan will consist of monthly monitoring of the three
indicator parameters. This monitoring will be conducted for four
consecutive months. The resulting data will be used to assess the
effectiveness of the hydraulic barrier and to determine what actions
are needed, if any, to modify the design of the groundwater recovery
system. The determination that modifications to the design are
warranted will be made by EPA, in consultation with state and local
governments. The public will be notified of any modifications to the
design of the groundwater recovery system that significantly altered
the original objective of the system. Once the determination had
been made by EPA as to the appropriate actions to be undertaken
regarding the performance of the groundwater recovery system, the
monitoring plan as previously discussed will resume.
10.3.2
Treatment System
The effectiveness of the treatment system in removing the toxicity
from the leachate-contaminated groundwater will be monitored
throughout the duration of the remedial action. The success of the
treatment system will be based on a comparison of two indicator
parameters measured using the influent to and effluent from the
treatment system. These parameters will include toxicity and
un-ionized ammonia. "
Toxicity tests will be conducted periodically using a water sample
collected from the influent to the treatment system and the effluent
from the system after treatment. The result should be a significant
reduction in toxicity for the effluent sample. Although a "no
toxicity" level in the effluent sample would be desirable, the Agency
realizes that this may not be technically feasible, especially during
the start-up and calibration of the system. A level of "no apparent
toxicity" (as defined later) should be achieved with time as the
groundwater is remediated and the toxic components of the
leachate-contaminated groundwater are removed.
To ensure that the maximum degree of protection for the environment
is achieved through this treatment system, "aquatic organisms that
experienced the most severe toxic effects during the EPA Water
Quality and Toxic Assessment Study will be used in the toxicity
tests. These organisms include a marine red macroalgae Champia
parvula and a small marine fish Menidia bervllina. Toxicity tests in
which Champia are used will be based on chronic exposure while
toxicity tests using Menidia will be based on acute exposure. The
frequency at which these tests will be conducted will be the same as
previously outlined for the monitoring of the hydraulic barrier. It
is anticipated that these test organisms will be compatible with the
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. --
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salinity range of the groundwater collected for these tests. If not
compatible, EPA will specify another test species that would be
expected to represent a similar degree of sensitivity to
contamination but is more tolerant of the salinity range of the test
medium.
A second indicator used to evaluate the effectiveness of the
treatment system will be a concentration differential for un-ionized
ammonia in samples collected from the influent to and effluent from
the treatment system. Since the pr~ary component of the leachate's
toxicity has been shown to be un-ionized ammonia, a significant
reduction in the concentration of un-ionized ammonia should be a
favorable indication that the treatment system is effectively
reducing the toxicity of the contaminated groundwater. Monitoring of
the influent to and effluent from the treatment system will follow
the same regimen as established for the toxicity tests and the
hydraulic barrier.
In the event that a significant reduction in the toxicity is not
observed, in either the toxicity tests or measurement of un-ionized
ammonia, the same type of contingency plan as described in the
discussion for the hydraulic barrier would be implemented. This
would include monthly monitoring for a period of four months. EPA
would then review the data, evaluate the treatment system, and
determine whether or not modifications to the system design or
evaluation criteria are warranted. EPA would then determine the
appropriate actions to be undertaken regarding the performance of the
groundwater treatment system, and the monitoring plan as previously
discussed would resume.
10.3.3
End-Point Criteria
The primary objective of this remedial action is to abate the toxic
effects on aquatic life in the Mangrove Preserve that are resulting
from the release of leachate-contaminated groundwater from the .
Munisport Landfill. Because the most severe toxic effects were
observed at low tide, a point at which dilution effects from BiscaYne
Bay are minimized, it was concluded that the leachate-contaminated
groundwater surfacing in the Mangrove Preserve is the most
significant element contributing to the toxicity in the Preserve. As
a result, EPA has determined that a level of "no apparent toxicity"
for the groundwater that is surfacing in the Mangrove Preserve must
be achieved. The complete removal of the toxicity from the
leachate-contaminated groundwater is necessary in order to protect
the aquatic life present in the Mangrove Preserve during all tidal
stages. Once a level of "no apparent toxicity" is achieved for the
leachate-contaminated groundwater, the remedial action for this site
will be judged complete.
Monitoring for the end-point of the remedial action will be based on
toxicity tests conducted using water samples collected from the
groundwater recovery system (before groundwater enters the treatment
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system). As with the toxicity tests for the treatment system
monitoring, the aquatic organisms determined to be the most sensitive
to the leachate (i.e., Champia parvual, Menidia bervllina) will be
used in the toxicity tests. Toxicity tests in which Champia is used
will be based on chronic exposure while toxicity tests using Menidia
will be based on acute exposure.
Toxicity tests will be conducted on a semi-annual basis throughout
the performance of the remedial action. As discussed earlier, the
remedial action will be judged complete once a level of "no apparent
toxicity" is achieved. EPA recognizes the variation in survival of
test organisms among control samples; this variation is, therefore,
reflected in the following definitions for "no apparent toxicity"
with regard to acute and chronic toxicity tests. For acute toxicity
tests, "no apparent toxicity" is defined as test results that have an
average mortality of no more than 10%. With regard to chronic tests,
"no apparent toxicity" is defined as an average mortality of no more
than 20%, relative to the average percent mortality of test controls.
Once no toxic effects are observed, for both test species, for at
least four consecutive monitoring intervals (i.e., 24 months), the
hydraulic barrier and groundwater treatment system will be shut
down. A long-term monitoring program will then be instituted for the
groundwater. This program will include annual toxicity tests using
groundwater samples collected from the groundwater recovery system
and the same two aquatic organisms. The annual monitoring will be
conducted for a period of five years, at which point EPA will
evaluate the completeness of the remedial action. The Agency will
then make a determination whether or not additional long-term
monitoring is warranted or that the remedial action is complete and
thereby initiate the NPL deletion process for the site. If toxic
effects are observed during the long-term monitoring, the toxicity
test will be replicated. If the effects are still observed, EPA will
determine whether or not to re-start the groundwater recovery and
treatment system or continue the long-term monitoring. The NPL
deletion process will not be initiated until EPA has determined that
the cleanup criteria in this ROD have been satisfactorily met.
If the groundwater recovery and treatment system has been operated
for a sufficient period of time, such that it is apparent that a
maximum degree of toxicity reduction in the groundwater has been
achieved and that any additional reduction in toxicity is technically
infeasible, EPA may elect to modify the end-point criteria. This may
include the identification of an acceptable level of toxicity in the
groundwater or the use of the EPA saltwater quality standard for
un-ionized ammonia to establish the end-point criteria. Conversely,
if at any point during the remedial action the EPA determines that
the cleanup criteria are not providing for adequate protection of the
environment, the Agency may elect to make modifications to the
criteria to ensure that the remedial action will result in adequate
protection of the environment. These modifications to the end-point
criteria will be made in consultation with State and local
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governments. The public will also be notified of any modifications
to the end-point criteria.
Closure of the landfill proper will be conducted under State
authority in accordance with FAC, Chapter 17-701. The closure will
proceed concurrently with the CERCLA action and EPA will consult with
FDER on the requirements for closure to ensure that the two actions
are compatible. As discussed previously in Section 2.1 of this
document, the site or facility to be addressed by this Superfund
remedial action is the of release of hazardous substances into the
Mangrove Preserve and that parcel of land (approximately 30 acres) on
~he landfill proper needed to construct the remedial action. That
portion of the landfill not included in the Superfund remedial action
(approximately 140 acres) and the remaining parcel of land on which
the landfill is located are not included in the "release" or "site"
to be addressed under this ROD. However, should it be determined as
a result of the hydrologic study that more area is needed to perform
the CERCLA remedy, the CERCLA response action will be expanded as
appropriate.
10.4
Associated Actions
Concurrently with the construction of the recovery well and treatment
system, hydrologic improvements will be made to the Mangrove Preserv(
and the hydrologically altered wetlands west and north of the
Mangrove Preserve (Figure 11). The hydrologic improvements to the
Mangrove Preserve will be accomplished by restoring the full (100%)
tidal connection between Biscayne Bay and the Preserve. The EPA
Mangrove Preserve showed that the two culverts (east and west
culverts) connecting the Preserve with Biscayne Bay were inadequately
sized and reduced the flow of water into the Mangrove Preserve by as
much as 40%. As part of the hydrologic design study, the degree by
which the tidal connection between the Bay and Preserve has
diminished will be studied further to determine the best method for
restoring the connection. Possible methods for restoring the full
tidal connection include enlarging the existing culverts, adding
additional culverts, or removing the culverts and expanding the
connection to that of the original drainage canal size, or providing
additional tidal connection with Biscayne Bay.
With regard to hydrologic improvements to the hydrologically altered
wetlands, the dike separating the altered wetlands from the Mangrove
Preserve will be breached in strategic places to restore the full
(100%) tidal connection with the Preserve and Biscayne Bay. The
timing and location of these breaches will be dependent on the effect
this water may have on the groundwater recovery system located in the
southern section of the hydrologically altered wetlands. As part of
the site-specific hydrologic study, potential effects that the
flooding of the hydrologically altered wetlands may have on the
recovery syste~ will be evaluated. The method and timing of the
hydrologic improvements to the hydrologically altered wetlands will
be based on the results of the hydrologic study. Based on the
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-75-
results of this study, EPA, in consultation with State and local
agencies, will determine the scope of hydrologic improvements to be
made to the altered wetlands.
11.0
STATUTORY DETERHINATIONS
The EPA has determined that the selected remedy will satisfy the
statutory requirements of Section 121 of CERCLA. The remedy will be
protective of the environment, attain ARARs, be cost-effective, and
will utilize permanent solutions and alternative treatment
technologies to the maximum extent practicable. No short-term risks
or cross-media impacts will be caused by implementation of this
remedy. Finally, implementation of this remedy will comply with the
CERCLA, Section 121(b)(1), preference for treatment.
11.1
Protective of Human Health and the Environment
The selected remedy will provide adequate protection of the
environment through the interception, collection, and treatment of
leachate-contaminated groundwater prior to its emergence in the
Mangrove Preserve. Treatment of the leachate will remove the
toxicity, thus reducing risks to the environment. The results from
the RI/FS have demonstrated that the site does not represent a
significant threat to human health or welfare.
As discussed previously, one of the criteria for selecting the
innovative technology (i.e., positive infiltration) over the
demonstrated technology (i.e., recovery wells) to effect the
hydraulic barrier is that the innovative technology must provide a
comparable level of protection to the demonstrated technology.
Hence, if the selected remedy incorporates the innovative technology
as the most appropriate technology, it will provide the same level of
protection to the environment as the the demonstrated technology.
11.2
Attainment of ARARs
Implementation of the remedy as presently defined in which the
hydraulic barrier will be accomplished using the demonstrated
technology and in which disposal of the treated effluent will be
through the discharge to the aquifer through the infiltration of
effluent through subsurface trenches will comply with all ARARs and
other environmental criteria or policies "to be considered" (TBC).
As discussed previously, comparable levels of performance and
protectiveness to the demonstrated technology must be met by the
innovative technology. For the innovative technology to be selected
it must meet all ARARs. For the purposes of review and assurance of.
compliance of ARARs, ARARs associated with the CERCLA remedial action
in which the demonstrated technology (i.e., recovery wells) is used
is discussed in the following.
Pursuant to FAC Chapter 373, use of an aquifer must be reasonable and
-------
r---
I
I
-76-
beneficial and not result in any adverse impact on other users of the
aquifer. SFWMD has expressed concern that the discharge of the
potentially saline effluent on the upper portion of the aquifer may
have an adverse effect on the aquifer in the form of additional
saltwater intrusion. EPA has considered this concern and has
determined that no adverse long-terms effects will occur for several
reasons. First, the area of infiltration of effluent back into the
aquifer is well seaward of the zone of saltwater intrusion currently
defined by the u.s. Geological Survey. Moreover, this portion of the
Biscayne aquifer is classified by FDER as a Class G-III aquifer (FAC
Chapter 17-3.401), which means that it is not suitable for potable
purposes. Moreover, the degree of saltwater intrusion is controlled
by the elaborate network of canals that serve to maintain a higher
inland hydraulic head. As such, changes with respect to the regional
hydrology are not anticipated. Finally, to confirm EPA's
determination, the impact of the remedial action on the regional
hydrology will be further evaluated using data collected from the
hydrologic study. This will ensure that EPA's remedy will meet all
environmental regulations that are either applicable or relevant and
appropriate.
In the event that the results from the site-specific hydrologic study
indicate that discharge of the treated effluent to surface water is
appropriate, there are several other environmental laws to be
considered. The surface waters of the Mangrove Preserve and
adjoining waters are classified as Class III, (FAC 17-3.121) and, as
such, there are certain criteria that must be met with regard to the
discharge. These criteria not only establish numerical limits for
various contaminants in the effluent but also toxicity criteria that
must be met. Moreover, the Mangrove Preserve is part of the Biscayne
Bay Aquatic Preserve for which Outstanding Florida Water Quality
Criteria apply. This essentially means that contaminants present in
discharges to the Preserve must be at concentrations at or below
background. Finally, Federal Ambient Water Quality Criteria also
apply to discharges to surface waters of or contiguous with the
Mangrove Preserve. The criteria associated with these State and
Federal environmental laws are determined to be relevant and
appropriate and will be complied with if effluent from the treatment
process is discharged to the Mangrove Preserve or other adjacent
surface waters.
Pursuant to Section 402 of the CWA, effluent discharges from
treatment systems are required to be permitted under the National
Pollutant Discharge Elimination System {NPDES} program. Although
Section 121(e}{1} of CERCLA exempts EPA from the requirement to
secure NPDES permits for Superfund sites, the remedial action is
required to comply with the substantive requirements of the NPDES
program. These requirements include both numeric and narrative
criteria against which the effluent must be monitored. Since there
are several environmental statutes that apply to surface discharge of
effluent from the treatment system, many of which overlap with regard
to criteria, the most stringent criteria will be used to monitor the
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-77-
effluent.
In addition to Federal and State water quality criteria, Dade County
has established criteria (i.e., TBC) for the protection of surface
water resources. However, given the stringent requirements provided
for in Federal and State environmental statutes, the intent of the
County criteria will be complied with, although the actual criteria
will not be included in the monitoring criteria. Finally, as part of
the Dade County Wellfield Protection Plan, no net loss of water from
the Biscayne aquifer is mandated to help maintain sufficient
potentiometric pressure in the aquifer in order to prevent saltwater
intrusion. Implementation of this remedy, in which effluent from the
treatment process may be discharged to surface water, would not
comply with the Wellfield Protection Plan.
11.3
Cost-Effectiveness
Alternative 3, the selected alternative, is the most cost-effective
remedy analyzed in terms of capital, O&M, and total present worth
costs. The total present worth cost is $6,166,000. EPA has
determined that the selected remedy is proportionate to the overall
effectiveness and is a reasonable value for the money.
As discussed previously, one of the criteria for selecting the
innovative technology (i.e., positive infiltration) with regard to
the Lmplementation of the hydraulic barrier is that it be comparable
as cost effectiveness as the demonstrated technology (i.e., recovery
wells). Hence, if the innovative technology is selected, there will
be essentially no difference in cost effectiveness.
11.4
Utilization of Permanent Solutions and Alternative Treatment
(or Resource Recovery) Technoloaies to the MaxLmum Extent
Practicable
The selected remedy uses permanent solutions and treatment
technologies to the maximum extent practicable. By intercepting,
collecting, and treating the leachate-contaminated groundwater, the
toxicity, mobility, and volume of contaminants will be significantly
reduced both in the short and long-term. As discussed previously,
one of the criteria for selecting the innovative technology over the
demonstrated technology is a comparable level of performance with the
demonstrated technology. Selection of the innovative technology will
be evidence that the remedy has been reviewed and determined that
implementation of the remedy using the innovative technology will
achieve the same degree of permanence and use of alternate treatment
technologies as the demonstrated technology.
Finally, the expected duration of the remedial action will between 15
and 20 years, after which the threat to the aquatic organisms should
be permanently abated. Furthermore, this is the most cost-effective
remedy.
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11.5
Preference for Treatment as a Principal Element
The statutory preference for treatment will be met since a principal
element of the remedial action is to actively treat the contaminated
groundwater through air stripping to remove the toxicity. Risks to
the environment will be mitigated through the implementation of this
remedy. This will apply whether the method used to effect the
hydraulic barrier is the innovative or demonstrated technology.
12.0
DOCUMENTATION OF SIGNIFICANT CHANGES
Shortly after the public meeting EPA received a draft of the TAC
report which contained a recommendation concerning a method for
performing the CERCLA remedial action and closure of the landfill.
After review of the TAC report and consultation with FDER, EPA
determined that the TAC report contains elements that warrant further
consideration and possible incorporation into the selected remedy.
As previously discussed, the TAC report recommended the use of a
positive infiltration hydraulic barrier to intercept the
leacate-contaminated groundwater. Although EPA's Proposed Plan
recommended the use of negative pressure (e.g., recovery wells) to
effect the hydraulic barrier, EPA, in consultation with FDER has
determined that the positive pressure technology is feasible and
warrants further consideration.
EPA will carry both methods forward through the hydrologic study as
options in the selected remedy. As discussed previously, EPA
considers the positive infiltration technology an innovative
technology not typically used for the control of releases of
hazardous substances at Superfund sites. Therefore, EPA will
evaluate the innovative technology using the criteria set forth in
the NCP. The performance, implementability, protectiveness, and cost
effectiveness will be measured against that of the demonstrated
technology. A comparable degree of each of these criteria must be
achieved before the innovative technology can be selected.
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APPENDIX A
OCTOBER 4, 1989 FEDERAL REGISTER EXCERPT
-------
41000
Fc4eraI aepter I VoL 54. No. 191 I Wednesday, October" 1989 I Rules and Rep1attons
IIMRoHMENTAL PROTECTION
AGENcY
40 CFR Part 300
IFRL-3155-4 )
National Prtorttl.. Uat for
Uncontrolled Hazardous Waste 5It8"-
final Rule Convertng SItes Subject to
the Subtitle C CorrectIve ActJon
A~~of~.R~U~
Conservation and Recovery Act
ACEHCY: Environmental Protection
Agency.
ACTION: Final rule.
SUMMARY: The Enviror.m~ntal Protection
Agency ("EPAOO) is amending th!! ,
National Oil and Hazarcous Substances
Pollution Contingency Plan ("NCP"). 40
CFR part 300. which was promulgated
on July 16. 1902. pursuant to section 105
of the Comprehensive Environmental
RespollSe. Compensation. and Liability
Act of 1980 ("CERCLA"). CERCLA bas
lince been amended by the Superfund
Amendments and Reauthorization Act
of 1986 ("SARA") and is implemented
by Executive Order 12580 (52 FR 2923.
January 29. 1987). CERa.A requiru that
the NCP include a list of national
priorities amsmg the bown releases or
threatened releases of hazardous
8ubstances. polJutants. or CO:1taminants
throughout the United States. and that
the list be revised at least ann:laUy. The
National Priorities List ("NPL"). initially
promulgated as Appendix B of the NCP
on September 6. 1983 (48 FR 40658).
constitutes this list and i8 being revised
today by the addition of Z3 sites. Based
on a review of public comments. EPA
bas decided that 13 of these sites. which
are subject to the corrective action
authorities of Subtitle C of the
Resources CollJervatioa and Recovery
Act ("RCRA"). meet the listing
requirements of the NPL. This rule also
adds 5 RCRA sites on which no
comments were received. and adds 5 no-
comment sites which rued RCRA permit
applications as a precaution and are not
subject to RCRA corrective action
authorities. Finally. todaY'8 action
remOVe8 27 RCRA sites from the
proposed NPL EPA has reviewed public
comments on the removal of these sites
and has decided not to place them on
the NPL because they are subject to the
lubtitle C corrective action authorities
of RCRA. and do not. at this time.
appear to come within tire categories of
RCRA facilities that EPA ~onsiders
appropriate for the NPL Information
.upporting tbese action8 i8 contained in
tbe Superfund Public Docket
Elsewhere in today's Federal Regiater
is another final rule that adds 70 sites.
bv-huIl"I 11 Federal FacWt)' .... to the ~ aDd ~tJ Retpoue (~
NPL and drop. 4 .ita from the.. ,188M -). U.s. EDYironmental Protection
NPL These two rules result in allD8l AcencY. 401 M Street, SW. WuhiDgton.
NPL of 981 lites. 52 of th8ll11D .. DC. 2Ot6O. or the Superfund Hotline.
Federallection: Zl3 litel are ~d JIIaone (800) 4U-«H6 (38Z-3000 in the
to the NPL. 83 of them in the Federal W.8hingtOn. DC. metropolitan area).
section. Final and propo8ed litel DQW ~AIIY INFOfaIAnoN:
total 1.194.
IFFECTIVI DAn: The effective da1e for Table of CaDtuti
this amendment to the NCP lban be L fAIrodDcti,on .
November 3. 1989. CERCLA sectic8 30S D. '-Pole and Implemcn:ation of the NFL
provides for a legislative veto of m. NPL Update ProceSl
regulations promulgated under CERa.A. IV. Statutory RequUementi and Listing
Although INS v. Chadha. 462 U.s. 918, Policiu .
103 S. Ct 276-1 (1983). cast the validity of V. Development of the !,;'PL/RCRA Policy
th I . I VI. Response to Public Commentl
.e 88111 ative veto into questioa. EPA vn. Disposition of Sites in To(bY'1 Final Rule
has transmitted a copy of thi8 resulaticm vm. Diapolition of aU Proposed Sites/
to the Sec:-et:uy of the Senate 8Dd the P8d8ral Facility Sites
Clerk of the House of Repre8entatiges. If DC. Coatentl of the NPL
any action by Congresl ca11a the x. Regulatory Impact A:1alysis
effective date of this regulation iDtD XL Regulatory Flexibility Act Anal)'sis
questio.n. the Agency will publiah . L Introduction
notice of clarification in the FecI8aI
Regi8ter. . Background
ADDRESSES: Addresse8 for the In 1980. Coagresa enacted the
Headquarters and Regional doc:bts Comprehensive Environmental
follow. For further detail8 on what theM Re8ponse. Compensation. and Liability
dockets contain. lee lectionl of the Act. 42 U.S.C. lections 9601-9657
"SUPPLEMENTARY INFO'UIAT1Off'" partiGa. ["CERCLA" or the "Act"). in response to
of this preamble. tM dangers of uncontrolled or
Tina Maragousis. Headquartera. U.s. EPA abandoned hazardous waste sites.
CERCLA Docket Office. Watersic18 WaD. CERCLA was amended in 1986 by the
401 M Street SW.. Washington. DC 2D4eO. Saperfund Amendments and .
202/382-3046. . .Reauthorization Act ("SARA"). Public
Evo Cunha. Region 1. U.S. EPA W88te Law No. 99-499. Stat 1613 et seq. To
Management Records Center. HES-CAN 8. implement CERCLA. the U.S.
John F.I(~nnedy Federal Buildin& BoataD. EDYironmental Protection Agency
MA 02203. 817/585-3300 .L
U.S. EPA. Region 2. Document Control (-VA- or "we Agency") promulgated
Center. Superfund Docket. Z8 Pecl8ral the revi8ed National Oil and Hazardous
Plaza. 7th Floor. Room 740. New Yadr. NY Substances Pollution Contingency Plan
10278. Latchmin Serrano. %12/264-&'540. ("NCP") 40 CFR Part 300. on July 16.
Ophelia Brown. 212/264-1154 1JE2 (47 FR 31180) pursuant to CERCI.."-
Diane McCreary. Region 3. U.S. EPA Ubrvy. Metion 105 and Executive Order 12316
5th Floor. 841 Chestnut Buildi.ns.ltha (46 FR42.Z37. August 20. 1981). The NCP.
Chestnut Streeta. Philadelphia. PA 1910'1. further revised by £FA on September 16.
213/5117-0580 19B5 (SO FR 37624) and November 20.
Cayte Alston. Region 4. U.S. EPA IJbra7. 1885 (SO FR 47912). 8ets forth gw'delines
Room C-6. 345 Courtland S~t NIL. .
Atlanta. CA 30365. 404/347~8 aDd procedures needed to respond
Cathy Freeman. Region 5. Us. EPA. ~u. aader CERCLA to releases and
230 South Dearborn Street. ChiC88Qo II. . threatened releases of hazardous
50604. 3U/aa&-e214 ~~. nbstances. poUutanta. or contaminants.
Deborah Va\I8hD-Wriaht. Region 8. U.a. EPA.. CD December Zl. 1988 (53 FR 51394).
1445 Rosa Avenue. Man Cocie 8H-MA. EllA proposed revision8 to the NCP in
Dalla.. TX 75202-2733. 214/855-8740 . N8pODM to SARA.
Brenda Ward. Region 7. U.S. EPA l.ibr87. 72IS Sec:tIaD 105(a)(8)(A) of CLA. as
Minnesota Avenue. Kansa. City. a 88101. amended by SARA. requires that the
813/23&-Z828
Dolores Eddy, Region 8. Us. EPA UInry. 898 NCP include "criteria for determin..ing
18th Street. Suite 500. Denver. CO ~ prioritie8 among relea8es or threatened
2405.303/293-1444 releases throughout the United Ststes
Linda Swmen. Re;ion 9. Us. EPA. Libz8r7. for the purpole of taking remedial action
8th Floor. %15 Premont Street. Sm aDd. to the extent practicable taking into
FrancilCO. CA 94105. 415/97+-8083 account tbe potential W'1!ency of such
David Bennett. Region 10. U.s. EPA.1th flOGI'. ac:don. for the purp08e of taking removal
1200 8th Avenue. Mail Stop HW~ 8CtiOIL" Removal action involves
Seattle. WA 98101. 208/442-:103 deauap or other actions that are taken
FOR FURTHER INFORMATION COII'r'K'r. ia l'8IpOD8e to releases or threats of
Henry Stevens. HazardoUi Site reJeue8 on a 8hort-term or temporary
Evaluation Division. Office of buis (CERCLA 8ection 101(23J).
-----
"--.edi
ore '
::.hi
feme
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~.
Fed8a1 R8tiP-r I VoL ~ No. 181 I W ~ '-
..'0dab8r ~ t- I Rul.. ad Rep1aticms
in 1888 of 8IL ""J~" ~ pgIk:,.. ~
OD the NPL certaiD c:a..., - 01.....
regu1ated aDder die Ra8G8C8
Coa8erYaticm uci ~ Ad
("RCRA-) (um-nu-.-d em faDe 10. U88
(51 FR 2:1054) anA farther ~ aD
June 24. 1988 (53 Fa 23878» (the "'NPL/
RCRA policy'"). The 38 lites WIn
.identified 88 poeaib)y Abject to the
Subtitle C ........ctiYe .c:tiaa .utbu.~ti-
of RCRA. and therefore J*8ibiJ lu.b;ect
to the NPLIRCRA pcN8cy. 8ecIrue die
. public had Dot beeD afforded DOti.c:e aDd
. opportuDity to ..........cDt aD the
application 01 thi8 potic:y to tbae mtes.
the A8f!!IJC1.~~ the .ites (13 to
be u.ted. 28 10 be ~~ em Jme Z4.
1988 aDder the .-wf poticy cd at
the 8IDDe time 8Olk:ited oommeD18 OD the
propo8ed actioa8 853 f'R Dr'lB). NiDe
RCRA lites propG8ed in NPL Update'"
(53 FR 238B8. fane Z4. UE) .. one lite
propwed ID Update *8 (54 fR 111626.
May 5. 1989) are aJao beiDs lidded to the
NPL ill this 6Dal nile: tbese me. were
proposed under the NPL/RCRA poticy.
but received DO ClDllllDeat8.1D 8ddition.
one RCRA site )IO..,.c»ed iD Update #7 i8
being dropped ill tbis fiDaJ rule becaulM!
of a change in i18 RCRA ....tua. . '
EPA bas carefuDy C1ODRd".ed an the
public comments submitted OD the ~
prevWwdy proposed RCRA sites. bOth in
response to the orisinal proposal of the
sites. as welJ as in response to.t}re
application of the NPL/RCRA policy to
the specific tites. The ~cy has made
some modifications in this final rule in
response to those comment.. In
addition. the /\1J!nr:y is dropping one
proposed Update #7 site in response to
comments concerning the site's RCRA
status.
The Agency has responded to a
number of major c:ommt!nts 011 the
policy for listing RCRA &ites in this
notice. Responses to man! site-specific
listing policy iuoes. as wen as
comments on HRS scores. &r'I! preseuted
in the ''So.pport Docameut far the
Revised National Ptioritia List-linal
Rule Covering Sita Subject txJ tb"e .
Subtftle C Corrective ActiOD Aathorities
of the Resource Ccm8erntfGD and
Recovery Act. October. t9lJlr which i. a
8eparate docameut available in the
Headquarters and Rqianal pub1fc
dockets (see Addresaes portiao of thia
notice).
Tbia rule. together with the fina1 rule
appeariDg elsewhere in today. Fedua1
Register. resultJ in. ba1 NPL or 9a1
sites. 52 or them in the Federal aection;
213 .ites are in proposed .tab1I. 83 oC
them in the Federal aecUoD. F'mal and
proposed .ite. DOW tot£11.1£K,
EPA _I.on-a QD the NPL aiau at
which there are or have bun re.leuea or
Remedial a.c:tiaA .-. to be ~-I \ala in
nature 8Dd iD¥Olv. I~ ~ 8ICtiaDa
which 81'8 eon-.",~ wtaD a p-~t
remedy f. . reI8&M (CERCIA 88dioa
101(24}}. Criteria r. d8t.. . .,
prioritiea for po..ible I~ lit.) actions
financed by the Truat FUDd a&abliabed
under CERCLA are iDduded iD the
Hazard RaaAiDg SyNm nfRSj. which
EPA promulgated u Apr-ndiT A 0( the
NCP (47 FR 31219. July 18. 1982).
On .December 23. 1988 t 53 F'R 51982).
EP A proposed reYi.i0D8 to the HRS in
response to CERCA 8eCtiOD 105(c).
added by SARA. E])A inteud8 to isne
the reviled HRS..IOOD.S posIribie.
However. IDltil FPA bas l'e"Viewed pubtic
commenU and the p~ rnomons
have beeD put into effect. EllA will
continue to propose aDd promulBate
8ites using the current HRS. in
accordance with CERClA section
105(c)(1) and Congres.!ional intent. as
explained in 54 FR 13299 (March 31.
1989).
Based in large part 00 the HRS
criterion. and pursuant to section
105(a)(8)(B) of CERCLA. as amended by
SARA. EPA prepared Ii list ot'national
priorities among the known releases or
threatened releases of hazardous
substances. pollutants. or col1taminants
throc.gout the United States. The list.
which is Appendix B of the NCP. is the
National Priorities List (""NPL j.
CERCLA section 105(aJ(8)(B} also
requires that the NPL be revised at least
annually. A site can undergo CIA.
financed remedial actiClD only after it is
placed o.n the NFL as provided in the
r.;CP at 40 CFR 3OO.66(c)(Z}. and.
300.68(a}. .
AI! original NFL of 400 aites was
promulgated on September a.. 1S8J (4.8
FR 40658). The NFL haa heeD expanded
since then. most recently on Match:n.
1989 (54 FR 13296}. The Agenq has also
published a number of pI'OIX]sed
ruleID,,~ingq to add aites to the NPL
most recently a special update of two
sites 011 August 18. 1989 (54 FR 33&46}.
EP A may delete lites when DO fartb.er
response is appropriate. - proYided iD
the NCP at 40 CFR 3OOJI8(c)(1). To date
the A8enCY bas deleted 28 aitu from the
NPL. most recently on September 22.
1989 (54 FR 38994) wbeD the Cec:il
Lindsey .ite. Newpon. Mans.... wes
deleteci.
Of the .ites in this Nle. 30 were
originally proposed in the first four
updates to the NPL.' prior to publiartion
~ -
a Update *' (411 F'R 4087~ Sqa&ember &. 1m\.
Update -: (411 F'R 4Q3.1Q. OctQbar U. W&4~ Upd&l8
n (SO f'R 1UU. April UL 1118S1 uad Upaate M (:;0
F'R 3:"9SO. September 1&. 19116}.
41001
thr - ir' 01"- ....
88h.b.. . paR &io-.
11M di8c. - ~. or cODtaztzuDlb
-r.l -I..... betow ID8Y mft ttJ .
8Ue8 or dlratal8d ra...e.-
~fj ~::=~ - or al&ema\1vUr. ... ~ly
a«UI- or ".u..-
Informatian A Pf117abll!! to the Ptrblif:
The Headquarters and RepoDal public
doclteu for the NPL (see ADoaau
POrtiOD of this notice) COIltaiD
. document.l rela ting 10 the 8COriDg and
evaluation of ,ites in this final rule. Tbe
dockets are available (or vi~ -b~'
appointment only- after the appearance
of thia notice. The hours 01 ope~ation for
the Headq~rters docket are from 9:00
a.m. to 4:00 pm.. Monday thro~ Friday
excluding Federal holidays. Please
contact individual Regional dockets for
hotD"S.
The Headquarters dowt contains a
memorandum-to-the-record describing
the RCRA atatus of the sites. HRS score
sheets for each final lite. a
Documentation Record for each ttnal
lite describing the information used to
compute the scores. a list of docmnents
referenced in the Documentation
Record. comments received. and the
Agency', response to those commerwl
(the "Support Documentj. ; ~
Each Regional docket includes ail .
information available in the
Headquarters docket for sites in that
Region. as wen a5 the actt1al referer.ce
documents. which contain the dGta upoc
which EPA principally relied upon in
calculating or evalu.ating the HRS scores
for sites in the Region. These reIeretlce
documents are available only in the
Regional d.oWts. They may be viewed
"by appointment only" in the
appropriate Regional docket or
Superfund Branch affice.. Request.> !or
copies may be directed to the
appropriate Regional docket or
Superlund Branch. .
AI! informal written requesL rather
thal1 a formal request. sbould be the
ordinary procedure (or obta.ining copies
of any of these documents.
IL PIK...- ad ~tioa of the
NPL
Purpose
The ~ ~ of the NPL is
Ilated in the leplative history of
CERCA (R.epart of die Committee on
~.d.......e:D1 and Public Work.. Senate
Report No. ~ 88th CcDg.. 2d Sesa.
110 l1_»):
1h priority rim ~primaiJy
inf'orm8ticlMJ JNI1'088o JUntifytnr for ~
State. &Ad dill puWic 111- f8ci1i1Ma &lid we..
or other reJe- wDdI .",.. II' .,8lftJIf
remedia! ac::tio... JDdai.- 01 . JK.iaty 01' aiU .
on the Uat dou DO( ill ilMII refJec:I a judpl2m
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..!1002
federal JleIi8ter I VoL Sol. No. 191 I Wednesday, October 4. 1989 I Rulel and Regulationa
.01 the ac:tiYitiel 01 IbI 0WII8I' or operator. It
doea Dot requin thoee perIODJ to andertake
aD)' ac:tioD. nor don It aAiiD liability to aD)'
pel'SOD. SubeequeDt ,ovemzD8Dt action in the
form of remedial action. or enforcement
actioDi will be necellary in order to do '0.
and the.. actioDi will be attended by all
appropriate proc:edural.aleguarda.
The purpose of the NPL. therefore. is
primarily to serve &8 an informational
and management tool. The initial
identification of a site for the NPL is
intended primarily to guide EPA in
determining which sites warrant further
investigation to assess the nature and
extent of the public health and
environmental riska associated with the
lite. and to determine what CERCLA-
financed remedial action(s). if any. may
be appropriate. The NPL 8.lso serves to
notify the public of sites EPA believes
warrant further investigation.
Federa.1 facility sites are eligible for
the NPL pursuant to the NCP at 40 CFR
3OO.66(c)(2), and are included on the NPL
even if there are RCRA hazardous waste
management units within the facility
boundaries. consistent with the Federal
facilities listing policy (54 FR 10520.
March 13. 1989). However. 8ection
111(e)(3) of CERCLA. as amended by
SARA. limits the expenditure of
CERCLA monies at FederaUy-ovmed
facilities. Federal facility sites are also
subject to the requirements of CERCLA
lection 120, added by SARA.
Implementation
A site can undergo remedial action
financed by the Trust Fund established
under CERCLA only after it is placed on
the final NPL as outlined in the NCP at
40 CFR 3OO.66(c)(2) and 300.68(a).
However. EPA may take enforcement
actions under CERCLA against
responsible parties regardless of
whether the site is on the NPL. The fact
that the .A-6ency may defer the listing of
a lite subject to RCRA Subtitle C does
not preclude the use of CERCLA section
104 to respond to a release or CERCLA
lection 106 to compel action by multiple
partie8 at such a 8ite. EPA also hal the
authority to take removal actions at any
lite. wbether listed or not. that meeu
the criteria of the NCP at 40 CFR 300.65-
61.
EPA'I policy i8 to punue cleanup of
NPL lites U8ing the appropriate response
and/or enforcement actions available to
the Agency. including authorities other
than CERCLA (e.g.. RCRJ\). Usting a 8ite
will lerve &8 notice to any potentially
responsible party that the Agency may
initiate CERCLA.financed remedial
action. The Agency will decide on a site-
by-site basi. whether to take
enforcement or other action under
CERCI.A or other statutory authorities.
to proceed dJnct1y with CERCA-
financed re8pODH actiona and aeek to
recover re.ponae costl after cleanup. or
to do both. To the extent feuible. once
lite. are 00 the NPL EPA will determine
high-priority candidates for Superfund-
financed response action and/or
enforcement action through both State
and Federal initiatives. The8e
determinationa will take into account
which approach is more likely to moat
expedinously accomplish clelUJUp of the
lite while using CERClA'I limited
resources 88 efficiently 88 pos8ible,
Remedial response actions will not
nece8larily be funded in the lame order
as a site'l ranking on the NPL-that is.
its HRS Icore, The information coUected
to develop HRS .corel 11 not aufficient
in itseU to determine either the extent of
contamination or the appropriate
response for. particular lite, EPA relies
on further. more detailed investigation.s
undertaken during the remedial
investigation/feasibility ltudy (RIfF'S) to
addresa these concerna.
The RIfF'S determine8 the type and
extent of contamination. It al80 takes
into account the amount of . .
contaminants in the environment. the
risk to affected populations and the
environment. the cost to correct
problems at the site. and the response
actions tha t ha ve been talen by .
potentially responsible parties or others.
Decisions on the type and extent of
action to be taken at these litel are
made in accordance with the criteria
contained in Subpart F of the NCP. After
conducting these additional studies.
EPA may conclude that it i8 not.
desirable to initiate a CERCLA remedial
action at some sites on the NPL because
of more pressing needs at other lites. or
because a private party cleanup is
already underway pW'luant to an
enforcement action. Given the limited
resource8 available in Superfund. the
Agency must carefully balance the
relative needl for response at the
numerous lite. it has ltudied. It i8 alao
possible that EPA will conclude after
further ualysia that the lite doel not
wammt remedial action.
Revisions to the NPL IUch al todaY'1
rulemaking may move IOme previously
listed lites to a lower polition on the
NPL. However. ilEPA has initiated
action lUeb 81 an RIfF'S at a lite. it does
not intend to cease lueb actions to
determine if a lub.equently listed site
Ihowd have a higher priority for
funding. Rather. the Ageocy will
continue funding lite ltudiel and
remedial actionl once.they have been
initiated, even if higher acoring litel are
latt;r added. to the NPL
RI/FS at Proposed Sites. -An RIfF'S
can be performed at proposed sites (or
8Y8D non-NPL litea) purnant to the
A8encT1 removal authority under
CERQ.A, u outlined in the NCP at 40
CFR 3OO.88(a1(1). Secti0I110\(Z3) of
CERCLA definel "remove" or "removal"
to include "auch actiona al may be
Deceu8l)' to monitor, UIeII and
evaluate the releue or threat of release
. . ." The definition of "removal" alao
includel "actioD taken under Section
. 100\(1) of thi8 Act. . . ." whicb
authorize8 the Agency to perform ,
ltudies. inveltigations. and other
information-gathering activities.
Although an RIfFS il generally
conducted a t a .ite &her the si te bas
been placed on the NPL. in a number of
circumatancel the Asency elects to
conduct an RIfF'S at a proposed NPL site
in preparation for a poasible CERCLA-
financed remedial action. such as when
the Agency believes that a delay may
create unnecessary risks to human
hea.1th or the environment. In addition.
the Agency may conduct an RI/FS to
a88ilt in determining whether to conduct
. removal or enforcement action at a
'ait ~.
FaCJ1ity (Site) Boundarl s. The
number of
inquiries concerning whether EPA could
(or would) revise NPL site boundaries.
The issue frequently arises where a
landowner seeks to sell an allegedly
uncontaminated portion of an fI,'PL site.
The Agency's position is that it is
neither feasible nor consistent with the
limited purpose of the NPL (as the mere
identification of releases). for the
Agency to describe precise boundaries
of releases.
CERCI.A lection (8)(8)(13) directs EP.-\
to Ii.t national priorities among the
known "releasel or threatened releases"
of hazardoul 8ubstances. Thus. the
purp08e of the NPL I. merely to identify
releases of hazardous substances that
are priorities for further evaluation.
'. Although a CERCLA "facility" is
.) ". broadly defined to include any area
. where a hazardous 8ubstance release
"come to be located" (CERCLA Section
101(9)), the lilting procesl iUeU il not
intended to define or reflect the
boundaries of IUch facilities or
rele88el.- Of coW'le. HRS data upon
which the NPL placement was based
will to lome extent. describe which
release is at iuue; that is, the NPL
release would include all releases
evaluated .s part of that HRS analysis
a AJtbouab CERa.A aection 101(111 Nt. out !be
definition or "raciliry" and DOl "relua.." 1110411
terma are oh.n u8ld jnlel"dluaub.lity. (Se.
CERa.A MeUW 105(a)(8)(91. which de/inft Ibe NP!.
a. a li.1 of "telea..." a. well II tbe highest pnonty
-racilil1ea. "J (Few UN or reference. EPA also U8d
the lenn "relelle" and "racility.")
*',
i ~
~
d~L
alu;
polic)'
\983n
Bee
defUlf
(or ai I
DO ad
allege
'NPL!
conta
locatt
consl.:
venn.
Furth
signif
liabil:
Se.nI :
Publi
96th (
48FR
party
disc: .
so if I
actio!
coW
that t
. .EP.
"nat\.
pres€
dete~
info r:
?Ilt"
aw.
_'~all
reqw
thel'
indei
More
di~
conte
prior
s tuw.
inde€
cont£
chan.
will :
bour.
At
Ager:
or DE
indi c
conti
cons.
~
time.
(aDd
butt
100 2
user,
othe:
rom.
"T,
10 foli
\cor
~.
\,"'\a:""~
-------
Federal aaliM- I VoL M. No. un I WAIl
C---=udiaa ~t;p-. _t ...
-;valuated 1IDdu"" NPl. ~
...-.olicy.... 48 FIl40e63 ~ L a.
1983}J.
BecagM the AtJ8I=Y ... 8IIIt farmally
define the geosraPhic ata1 of n1euea
(or sites) at the time of Ii..m,. d8e is
no admiDiatrative proce88 to ..deIi8t"
allegedly UDCODtamiDat.ed area ola
NPL eite (or to expand IIite8 ID fallow the
contaminatioOD where it hu came ~ be
located).' ScIeb. proceu woWd be time-
corusumiDg. wbiecl to con-t..nl re-
verification. aDd wuteful of rucrarces.
Further. the NPL iI cmJy allimiled
eignificance. u it does DOt al8igD
liability to an)' party. ~ Report of the
Senate Committee on FnviromDeDt and
Public Worb. Se.oate Rep. No. 9&-84B.
96th Cong.. 2d Sea.. 60 (U80). q&Gted at
48 FR 40659 (September a. 1983). If 8
party conteata liability for reIe.uea OIl
discrete pan:ea of property. it may do
so if and when the A"as:y briDp an
action agaiDat that party to recant'
coata or to compeJ a teSF ao.e actiOD at
that property.
EPA reguiatioDa do provide thai the
"nature and extent of the thre8t
presented by a releaae" will be
determined by an RIlFS .. IDOft
information is deve10ped on lite
contamination (40 CFR 300.88(d}J.
. However. tlUa inquiry foc:ue6 em an
valuation of the threatpoeed: it ia not a
requirement to defiDe the bouDdarie8 of
the releue. and in any event ia
indepeod.ent of the NPL listing.
Moreover, it i8 senerally impoMikde to
discover the full extent of where the
contamination "baa come to be kx:ated"
prior to COIIIpletioo of all Deceuay
studies and remedial work.t. aite~
indeed. the boundaries of the
contamination can be expected to
cha.age over time. 11ms. in. JIIG8t cues. it
will be impouib1e to deMZibe tbe
boundaries of a rele88e with certai:Dty.
At the laDle time. however. Ibe
Agency not.e.8 that the Rl/FS or Record
or Deci.ion (ROD) may offeT a ..ml
indication to the public of. the areas of
contamination at which Ibe ~ ia
consideriD8 t.akina a respaaae 8CtiOD.
based on iDformatiOD JuJotna at""
time. For example. EPA may enIaate
(aDd li8t) a re!eue 0¥8 a tGO-ecre area.
but the ROD may lelect . remed, ...er
100 acres caly. Thi8 iafanaati8a ID8J be
useful to alaDdowner aeekiD8ao ..n tbe
other 3OO.au. but it woaJd ra\&h in DO
formal c.banse in th~ fact that a me..
1 The A,ency baa all'88dJ ~ b 8III6arity
10 rollow contamiDatiOD .. rar.. It....... ~e8
10 coftlider the rele... or ladli" fill ........
J~ 10 be thl IDUn un wll8atfla h_~l.1
..1mance8 n- - '" be IDc8ml ,. f'K nzI8
iarch 31. 1889).
kF. Octo- ~ 1911 I RuIn ad Rep!atiou
41883
... iDdIId8ci.. the NPL. 'D8"" . -~
(aad .. JNbUc) ac.MI...... ....
. CII88 d8at If furdter 8tDdJ (ar Ibe
remedial coutnldiaa b:88If) I8ft88 that
the camtuliDatiem. kM:atllO CIII ar""
.pread to other ueu. the AptJq DI.J
addre8a tho. are.. .. ..n.
Thia view of the NPL U 811 iDitiAl
identification of a releae that i8 DOt
lubjec:t to COl1JtaDt re-naluation'"
conailtent with the AgeDCJ'1 policJ of
DOt ~1'I8 NPL sitea:
EPA r~ that the NPL proeea
C8DDII8 be p8Ifect. ad it" po8IfbM that
8rT'Ol'I exilt or that liew data will aha
prt!"I'iu8 ,....., I I"""" 0Dc8 tile ilDUaI
ICOrq e:ffurt II CIIIIIIp...IIowwv.., tb8 foay
vf EPA actiYitJ aaat be 011 ilrr'8RlptiDllitn
in d.et8il ud deeaumillllbe 8JIPIGIIria18
I~ New data ar8mll'l CIID be
~ed In that procaa. . . rJ1be NPL
8ftftI U . pia. ID EPA.. cb8 liot
determiDa UabiJitJ or tb8 Deed far !'II8pCIDI&
49 FR 37081 (September %L 1984}..
In. NPI. Updal8 PrOCI888
'I'here are three me~"Yt'--.. far
plac:in& uta OD the NPI. The priDcipat
medaADiam ia the appW:atioD of the
fiRS. Toe HRS 8eI"V'ea 88 . ~
device to evaluate the relative potential
of UDCODtrolled hazardoaa IGbataJ1cea to
cause human health OZ' wety probWu.
01' ecological or enviroDmutal d......V
The HRS acore ... c..I~,ldM by
estimating rilb preleD1ed in three
potential "pathways" of human or
environmental e.xpoewe: pu water,
aur£ace water. and. air. Within each
pathway of expoaure. tba HRS .--..idA-
three categoriel of fadGm '"that ara
designed to e.n.campaulDOllt apeda of
the likelihood of upolare to &
hazardous lubatance thro9 a re1ease
and the magnitude or degree of lw:m
from such f!xpoaUJ'e": (l} facIms that
indi.ca.te the prelence OIIikeIihood Clf a
re~ase to the envirooment (%] rac:foz:a
that indicate the nab1re aud quantity or
the lubatanceS prnmtiog the potmtial
threat and (3) factDrl that fodica te !be
human or eDViroameI1fa} '"tarJeta- :'.
poteatiaUy at riak rro. the IitL P8ct.mr
witbiD neb of these three cateaodes are
8Ssiped . aumericaI "... 8CCICIrdIag fa
a .et ec:aIe. Once ..........lic:aJ nIue. are
co~ for each fac:tar. die HRS use.
. Sea aI80 City of 6....- Wile. Y. rr.s.llPA..
858 P. III~. m (D.car.2I8t
CertaiDl,.IPA GRId Mn pmdIId Can!I8r
~QI . w~IIIIIIIII(-...,..d
NPL~ II&aI8r -.......... .
f8nII8r -- at tb8 Ae-:r" ..w 11&".
dletapad a dn!aafaaCloa at tile S1 pdarity
a...a..d wCIIt ....... Yilt. . .... NI'L ~
atmply . rousb lilt ~ -~....... qaid:f"
aM ............ III ....... wtIIt c..p..'
1D8Dda1a rear 1M "..".., 10 lAb 8CaI88
.trailbl8W8J.- &z,1..l'fdlttr {IIII/tIItri8.. D'Al II
7W P. at 1m.11t _,",.car. !111571.
;;.. ~ ~ ~ ~... aII8ct tb8
ID,-..... L'.... or the Y8rIaa ~
to 8IIhw .. . ..... --
of 0 to.- --.. -- 8aIre - . 8eUe
- "- ftl~1Ioan HItS 8COnI
rep~ta .. --'t8 fIf tM Iftathoe
"probebWty ad. ~.,.{~. 01 baa tD
the human population or MI1Iitin
environment from exposure to
hazard01l8 IUblbmcee a. a realt of the
COIrlamiDauon of Iiround water. .m.c;e
water. or air'" (47 PR 311.S1. July 18.
1982). nose litee that ICOre 28.50 or
greatl!r on the fiRS are eliglbfe for the
M'L.
UDder the lecon.d mechaniam rQr
adding lites to the NPL. each State may
deefgnate . lingle lite u ita top priority.
regardI.ua or the HRS lCOre. This
mecbaoism II provided by .ectiDn
lOS(a}(98{B} of CERa.A. as amended by
SARA. which requirel that. to the extent
practU:able. the NPL indnde within the
100 highest priorities. one 1acility
designated by eech State representins
the greatest daopr to pubUc health.
welfare. or the enviraome.n1 among
known f.~1in- in the State.
. The third ~.dIan;1I!ZI for lLIting.
~cl,Jded iA the NCP at 40 CFIl ,
300.86(b)(4) (50 FR 316:U. September 1A
15185). h.. beeD \A8ed only in I'8J'e ! t .
inaW1.cea.lt allow. certaia lites with
HRS 8CCII'8 below 2&SO to be elisibIe {or
the NPL if all of the follDwiDg occur:
. The AweDCY for Toxic SubelaJ1(:n
and Di8ea1e ~try of the u.s.
Deputmeut of Health and Haman
Service. baa iaaled a bnlth admary
which recammeDda di.x:iatian of
iDdividualt &ma the releue.
. EPA detemzin.e8 that the release
pOSe8 a. eignificant tbzeat to public
health.
. EPA etidpata that it will be more
cost-effective to 1188 ita remedial
authority than to use iu removal
authority to respond tCl the rel.ease..
All of the eites in today'e final rule
have been placed on the NPL based on
fIRS ecare8.
States Itaft the primary I'e8pOrusibility
_ldeatIfJiDI DOD-Federalmes.
computiDr HRS tCOre'S, and nbmittmg
candfda1e mee 10 the fPA Regional
offices. EPA RegtaaaI otfien c::onduct a
quaiit)' c:oatrof revieW of the States'
cadidate IfIes. 8Dd may aaUt in
imebtip~ nmptiDg. mODttorms. and
8C:IDriDr 8fIIes. Resioaal ofIicu ID8J also
comldef ca.adid.ate liles m addfticm to
thoae-nbmitted by States. EPA
Headquartftl CODducts further quality
UlUl8DCe aadIts tD eD8UI'8 8CC11rWcy arJd
co....Lb..:.y IID!OIIIf t!nf..no. EPA cuJ
State aI1it:e8 pcfk:ip,-lD dr. u:milIg.
The ~ dla prapo8e8 die ritn 6!at
meet one of ttJe three criteria for listing
-------
.41004
Feci-a! Resister I VoL M. No. 191 I Wednesday, October 4. 1989 I Rules and Regu!atiOD8
(ud £PA'. UatiDI pol1det) ud 80lidta
pubUc: c:ommenta on the propoaaJ. Baaed
on theM CODUDenta ad further review
by £PA. the Ap1x:y determ1aea final
HRS acorn and placet those litet that'
ltilI qualify on tha fiaat NPl-
IV. SlabltOfJ Requirem8Dta 8Dd IJatiq
PoUciet
CERCLA restricts EPA's authority to
respond to certain categories of releases
of hazardous lubstances. pollutants, or
. CO!ltAmh'l"nt8 by expressly excluding
.ome IUbstances. such a. petroleum.
from the responae program. Ia additioD,
CERCLA section 105(a)(8)(B) directs
EPA to list priority sites "among" the
known releases or threatened releases
of hazardous IUbstances, pollutants. or
contamiDants. and section 105(a)(8)(A)
d..irectl EPA to conaider certain
enumerated and "other appropriate"
factors in doing so. Thus. as a matter of
policy. EPA has the discretion not to use
CERCLA to respond to certain types of
releate.. For example. EPA haa chosen
not to list sites that result from
contamiDation usociated with facilities
licensed by the Nuclear Regulatory .
Commission (NRC). on the grounds that
the NRC has the authority and expertise
to clean up releases from those facilities
(48 FR 40661. September 8.1983). Where
'other authorities exist. placing the site
on the NPL for possible remedial action
under CERCLA may not be appropriate.
Therefore. EP A has chosen not to
consider certain types of sites for the
NPL even though CERCLA may provide
authority to respond. If. however. the
Agency later determines that sites not
listed as a matter of policy are not being
properly responded to. the Agency may
place them on the NPL.
The listing policy of relevance to this
final rule applies to sites subject to the
corrective action authorities of RCRA
Subtitle C.
V. Development of the NPL/RCRA
PoUey.
Since the first NPL final rule (48 FR
40658. September 8. 1~) the Agency'l
policy heaS been to defer listing .ites that
could be addressed by the RCRA
Subtitle C corrective action authorities,
even though EPA ba. the .tatutory
authority to list all RCRA .ite. that meet
the NPL eligibility criterion (t.a.. . aeoN
of 28.50 or greater under the HRS). Until
1984. RCRA corrective action authorities
were limited to facilities with relea.es to
ground water from .urface
impoundmentt. waste piles. land
treatment areas, and landfilla that
received RCRA hazardous waste after
luly 26. 1982. Site. which met these
criteria were listed only.if they were
abandoned or lacked sufficient
NIOUI'C88. Subtitle C cornc:tiY8 action
authoriti88 cn1d not be enforced. or a
IipificaDt portion of the releue came
from noaresu1ated unitt.
On November a. 19M, the Hazardous
and Solid Wute Amendmenta (HSWA)
were enacted. HWSA gready expanded
RCRA Subtitle C comctive action
authorities u followa: .
. SectiOD 300t(u) requiret permita luued
after the enactmeDt of HSW A to iDdude
correctivi actiOD for aU rei.... of buardOUI
w.lte or CODIUtueDta from IOlid wu18
m8D8lemat UDiti It a treatmal. Itorqe. or
diIpOI&I facility H8kiD8 a permit.
. SectiOD 3OOI{v) requireI corrective action
to be taka beyoad the facility boaadary
where D8C8IIII'Y to protect humaa health and
the envtroDment UDleu the owner/operator
of the fleWty demonItret81 that delpite the
owner or operator'l belt e£fortl. the owner or
operator WII _ble to obtam the necelllUy
permillioD to undertake aueb .ction.
. Section 3008(b) luthorizel the
Admini8trator of EPA to llaue an order
requiriD8 corrective action or .uc:h other
relpotl8e meuurea .1 deemed neceaaary to
protect human health or the environment
wheDever It II determined thlt there it Dr hal
heeD I relea.. of huardOUI waite into the
environment from I f.aity with Interim
Ita t\I8.
As a result of the broadened Subtitle
C corrective action authorities of
HSWA. the Agency sought comment on
a policy for deferring the listing of non-
Federal .ites subject to the Subtitle C
corrective action authorities (SO FR
14117. April 10. 1985). Under the draft
policy. the listi.n& of IUch sites would be
deferred unless and until the Agency
determined that RCRA corrective action
was not likely to succeed or occur
promptly due to factora such as:
. The inability or unwillingness of the
owner/operator to pay for addressing
the contamination at the site.
. laadequate financial responsibility
guarantees to pay for .uch costs.
. EPA or State priorities for
addressing RCRA .ite,. .'
The intent of the policy wu to
ma,nm". the number of site responses
achieved through the RCRA corrective
action authorities. thus preserving the
CERCLA Fund for .ites for which no
other authority II available. Federal
facility .itn were not considered in the
development of the policy at that time
because the NCP prohibited placing
Federal facility .ite. on the NPL.
On June 10. i988 (51 FR 21057), EPA
announced componenta of a policy for
the listing. or the deferral from listing. of
several catetorie. of noa-Federal .ites
.ubject to the RCRA Subtitle C
corrective action cuthoritie.. Under the
policy. RCRA site. not subject to
Subtitle C corrective _ction authorities
would ooatiDQe to be placed on the I
Examplea of auch aitea inc:1ude;
. FacWtie8 that ceued treating.
.toring. or cIiapoaq of hazardous waste
prior to November 1i. 1980 (the effective
date of Pbue I of the RellA
regulatioal), and to which the RCRA
corrective action or other authorities of
Subtitle C C8IIDot be applied.
. . Sitn at which only materials
. exempted from the .tatutory or
regulatory definition of .olid waste or
hazardous wute were'managed.
. RCRA huardous waste handlers to
which RCRA Subtitle C corrective
action authorities do not apply. such as
hazardous waste 8f!nerators or
transporters not required to have interim
status or a final RCRA permit.
Further, the policy stated that certain
RCRA sites at which Subtitle C
corrective action authorities are
available may also be listed if they meet
the criterion for listing (i.e.. an HRS
ICore of 28.50 or greater) and they faU
within one of the following categories:
. Facilities owned by persons who
have demonstrated an inability to
finance a cleanup as evidenced br their
invocation of the bankruptcy lawl.
. Faciliti81 that have lost ~ ~
authorization to operate and for which
there are additional indication, that
owner or operator will be unwiUing
undertake correctlve action.
Authorization to operate may be lost
when issuance of a corrective action
order under RCRA aection 3008(h)
terminates the interim status of a facility
or when the interim status of the facility
is terminated as a result of a permit
denial under RCRA section 3005(c).
AlBo. authorization to operate is lost
through operation of RCRA section
3OO5(e)(2) wben an owner or operator of
a land disposal facility did not certify
compliance with applicable ground
water monitoring and financial
responsibility requirements and submit
a Part B permit application by
November a. 1985-el.o known in
HSW A a. the Lo.. of Interim Status
Provtaion (LOIS)).
. Fadlitie. that have not lost
authorization to operate. but which have
a clear history of unwillingness. These
.ituationa are determined on a case-by-
case ba.i.8.
. On June 24. 1988 (53 FR 23978) !fA : . .' .
amended the June 10. 1988 policy (S1 PH
21057) to iDdude four additional -
categoriea of RCRA lites as appropriate
for the NPL. Thele categories are:
. NQJI- or late filera.
. Convenel'l.
. Protective mers.
. Site, holding permits issued bef(
the enactment of HSW A.
.,,1
-------
APPENDIX B
RESPONSIVENESS SUMMARY
-------
RESPONSIVENESS SUMMARY
MUNISPORT LANDFILL NPL SITE
CITY OF NORTH MIAMI, FLORIDA
U.S EPA
August 20, 1990
CH2M HILL, under contract to the U.S. Environmental Protection
Agency (EPA), compiled this report and along with EPA prepared the
technical responses contained herein. The legal and regulatory
interpretations, opinions, and recommendations contained in this
document are those of the U.S. EPA. All material in this
Responsiveness Summary was reviewed and approved by the U.S. EPA.
-------
CONTENTS
Section
1
Overview
2
Background on Community Involvement
3
Summary of Comments Received and Agency Responses
Part I: Local Community Concerns
Part II: Legal and Technical Issues
4
Remedial Design/Remedial Action Concerns
Attachment A:
Community Relations Activities at the Munisport
Site
dbt077\061.51
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Section 1
~e~i~
The U.S. Environmental" Protection Agency (EPA) completed a
Remedial Investigation and Feasibility Study (RIfFS) for the
Munisport Property located in North Miami, Florida. During the
RI, information was gathered on the nature and extent of contam-
ination, and, as part of the FS, alternatives for remedial action
(RA) were developed and evaluated. The RIfFS identified no sig-
nificant public health threat posed by the landfill; however, the
information regarding the potential environmental threat was
inconclusive. At the conclusion of the FS, EPA prepared a
Proposed Plan for remedial action to respond to the potential
environmental threat. The July 1988 Proposed Plan recommended
CERCLA remedial action that included landfill closure in
accordance with Florida law.
After further review of the data, EPA concluded that no
significant threat to the environment existed and issued a Notice
of Change to the Proposed Plan in November 1988 stating that no
CERCLA action would be taken at Munisport and the landfill would
be closed under State authority. This course of action was op-
posed by some members of the public, environmental groups, the
National Oceanic and Atmospheric Administration (NOAA), and the
U.S. Fish and Wildlife Service due to the potential threat to the
environment.
In 1989, EPA, in response to these comments, conducted a Water
Quality and Toxic Assessment Study at the Mangrove Preserve
adjacent to the landfill. According to this study, "the emergence
of toxic leachate in the Florida State Mangrove Preserve will
remain a long-term problem of water quality. The toxicity as-
sociated with the landfill leachate will severely impair the
ecological function of the Preserve and preclude the development
and maintenance of a balanced community of aquatic biota." The
study recommended that action be taken to control the dispersion
0.£ leachate from the landfill and preclude its emergence into the
surface waters in the Mangrove Preserve.
As a result of the Water Quality and Toxic Assessment Study, EPA
concluded that a release of hazardous substances to the environ-
ment has occurred and poses a significant threat to aquatic life
in the Preserve. Pursuant to Section 104 of the Comprehensive,
Environmental Response, Compensation and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and Reauthori-
zation Act of 1986 (SARA), EPA determined that remedial action is
warranted to abate this threat. EPA prepared a Proposed Plan
dated March 1990 that identifies alternatives for remediating the
environmental threat to the Mangrove Preserve.
dbt077\062.51
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Potential alternatives to remediate the environmental threat to
the Mangrove Preserve were initially identified by the Munisport
Technical Advisory Committee (TAC) in conjunction with the Florida
Department of Environmental Regulation (FDER) and EPA. These pre-
liminary alternatives were further evaluated by EPA based on nine
criteria found in EPA guidance documents, including considerations
such as feasibility, implementability, cost, and statutory
requirements. As a result, several of the preliminary alterna-
tives were determined not to be appropriate and were subsequently
not included in the Proposed Plan. A total of three viable alter-
natives, in addition to a "no action" alternative were included in
the Proposed Plan.
The remedial action alternatives include the interception of
leachate-contaminated groundwater migrating from the landfill to
the Preserve using a hydraulic barrier in conjunction with recov-
ery and treatment of the leachate-contaminated groundwater.
Methods of groundwater treatment include biological, mechanical,
or both. Disposal options for treated groundwater include dis-
charges to surface water or groundwater. The selected remedy also
includes hydraulic improvements to the Mangrove Preserve. This
will assist in mitigating the effects of the leachate on aquatic
life that inhabits the Preserve. Since the proposed remedy would
not recover contaminants already present in the Preserve, improve-
ments to the tidal connection between the Biscayne Bay and the
Preserve are expected to lessen the impact on aquatic organisms.
The Proposed Plan presented four alternatives for addressing the
leachate-contaminated groundwater at the Munisport Property.
Alternative 1 was for no action. The Superfund program requires
that the "No Action" alternative be evaluated at every site to
establish a baseline for comparison. This alternative would
include annual monitoring of the site but no further remedial
action. Under this alternative, leachate would continue to be
released and aquatic organisms would continue to be adversely
affected. .
Alternative 2 includes leachate collection followed by mechanical
pre-treatment and biological treatment in constructed wetlands.
Leachate migrating from the landfill to the southeast would be
intercepted by approximately 17 recovery wells. Treatment would
include both mechanical and biological processes. Mechanical
treatment would be by air stripping and biological treatment would
be conducted in a constructed wetlands treatment system.
Alternative 3 would use air stripping for removal of ammonia
followed by discharge of treated groundwater to surface or ground-
water. This alternative includes the same leachate interception
method as Alternative 2, or possibly a positive hydraulic barrier
if the hydrologic study indicates that it is appropriate. Treat-
ing the ammonia with air stripping towers alone is not an
dbt077\062.51
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efficient treatment in this case due to the potential fouling of
the air stripping towers. Air stripping in a pond requiring three
to four acres is feasible and potentially more effective.
Effluent from the treatment system would be used to provide
enhanced flushing of the landfill.
Alternative 4 would utilize a positive hydraulic barrier with
landfill leachate collection and treatment. The hydraulic barrier
would be created along the landfill side of the Mangrove Preserve
by constructing a dike and open trench and continually pumping
fresh water into the trench. The water in the trench would be
maintained at a higher elevation than the water level in the
Preserve and Biscayne Bay. This would prevent the migration of
contaminated groundwater into the Preserve. Treatment of the
contaminated groundwater would be similar to Alternative 3.
EPA's preferred alternative for abating the environmental treat to
aquatic organisms in the State Mangrove Preserve is Alternative 3,
consisting of leachate interception and collection, treatment by
air stripping, and discharge. to groundwater or surface water.
This alternative best fulfills the nine criteria that EPA uses to
evaluate remedial alternatives. These criteria are specified in
the EPA document Guidance for Conducting Remedial Investigations
and Feasibility Studies Under CERCLA, Interim Final, October 1988
(OSWER Directive 9355.3-01). The criteria were developed based on
the statutory requirement specified in Section 121 of CERCLA. The
nine criteria are as follows:
/
overall protection,
compliance with ARARs,
long-term effectiveness and permanence,
reduction of toxicity, mobility, or volume
contaminants through treatment
short-term effectiveness
implementability
cost
state acceptance
community acceptance
In addition, the use of a positive hydraulic barrier in lieu of
interception wells will be assessed based on information generated
during hydrologic and hydrogeologic testing .at the site. The
information, along with data generated during water quality analy-
ses, will be used to confirm or refine the selected alternative.
A treatability test will also be conducted to evaluate the
selected alternative's effectiveness in treating the leachate and
the impact of the remedial action on the environment. The site
that will be subject to the CERCLA remedial action will be the
leachate plume emanating from the landfill and portions of the
landfill necessary for the implementation of groundwater recovery
and treatment. The landfill will be closed under State authority.
.
.
.
.
of the
.
.
.
.
.
dbt077\062.51
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Public participation in Superfund projects is required in the
National Oil and Hazardous Substances Contingency Plan (NCP).
Comments received from the public are considered in the selection
of remedial actions for sites. This Responsiveness Summary sum-
marizes the comments received during this project. This document
is organized to address the comments regarding the July 1988 Pro-
posed Plan, the November 1988 Notice of Change to the Proposed
Plan, and the March 1990 Proposed Plan separately. Part I of
Section 3 of the Responsiveness Summary addresses local community
comments of those people who have identified themselves as living
in the immediate vicinity of.the site. Part II will be a com-
prehensive response to significant comments. Each part has been
divided according to the major subject. Those individuals or
groups providing comments have been identified.
In general, the public and environmental groups favored EPA
involvement in the CERCLA remedial action and supported the
preferred alternative. Significant discussion, however, was
documented regarding the types of contamination at the site, the
level of contamination, and the threat to public health and the
environment. With regard to the types of contamination, resi-
dents, concerned citizens, and environmental groups questioned
whether asbestos, petroleum products, raw sewage, medical wastes,
heavy metals, pesticides, PCBs, and other organics were present at
the site. There were a significant number of comments related to
the presence of these chemicals.
A review of disposal records indicates that the property was
essentially operated as a solid waste landfill. At this time, EPA
has found no evidence that hazardous waste was disposed at the
site. This determination is further supported by data collected
from the numerous sampling investigations, including analyses of
soil, groundwater, sediment, and surface water which show no
evidence of significant contamination.
Although numerous organic and inorganic compounds have been
detected among the samples, the data set, when reviewed as a
whole, indicates that the substances detected are indicative of
materials associated with common household wastes. The substances
detected and their respective concentrations are not indicative of
a hazardous waste site.
During the 1988 RIfFS, a variety of organic and inorganic
chemicals were detected in the groundwater. Most of these,
however, were detected at low concentrations with a few of the
chemicals exceeding Federal and State water quality standards.
Since the groundwater in the vicinity of the site is not used for
potable purposes, it was determined that the contaminants in the
groundwater present no risk to public health.
dbt077\062.51
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With regard to metals, water and sediment samples analyzed for
metals indicate that the metals detected were at levels commen-
surate with most marine systems and are probably not caused by
leachate at this time. The concentrations of these metals may
vary based on the amount of rainfall depending on whether the
material was buried above or below the water table.
PCBs were detected at a few locations. Based on this infrequent
detection and relatively low concentrations, EPA determined that
PCBs do not present a significant threat to the public or the
environment.
Analyses of surface water and sediment samples indicate low-level
contamination by a variety of mostly inorganic chemicals typical
of a nonhazardous waste landfill. Concentrations for several of
these chemicals exceeded applicable water quality standards affi~ng
the samples collected. Analyses of soil samples indicated the
presence of chemicals typically associated with nonhazardous muni-
cipal landfills. Samples collected from unfilled areas indicated
little contamination. Samples collected from the landfill surface
and northeast portion of the landfill contained several
contaminants at concentrations above background.
The risk assessment contained in the RIfFS also examined other
exposure pathways for this site. Based on the results of this
study, however, the Agency concluded that a significant threat to
public health or welfare did not exist. However, the determina-
tion of the threat to the environment was inconclusive. Public
participation, as was stated earlier, caused EPA to look closer at
the threat to aquatic life in the Mangrove Preserve. The results
of that study conclusively demonstrated a significant threat to
the environment posed by leachate from the landfill.
dbt077\062.51
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Section 2
Background on Community Involvement
The Munisport Landfill is an inactive solid waste landfill located
within a 291-acre tract in northeastern Dade County. Landfilling
activities encompassed approximately 170 acres. Landfilling acti-
vities began in the mid-1960s when a few acres of land were used
to dispose of unknown types of wastes. In the early 1970s the
City of North Miami leased the 291 acres of land to Munisport,
Inc. for the development of a recreational facility. Munisport
began filling low lying areas with construction debris and other
solid wastes.
The Florida Department of Pollution Control (FDPC) granted a
temporary operating permit in 1975 to allow Munisport to fill
portions of the landfill with solid waste above the water table.
In 1976, Munisport received a "clean fill" permit to fill wet-
lands, and an extension to the temporary operating permit to con-
tinue solid waste disposal. The site was evaluated by EPA in
1982 using the Hazard Ranking System and received a score of
32.37. As a result, EPA proposed the Munisport Landfill for
inclusion on the National Priorities List (NPL) in the Decem-
ber 30, 1982 Federal Register. The landfill was finalized on the
NPL in September 1983.
The City of North Miami petitioned EPA to delist the site from NPL
in 1986; however, EPA determined delisting was inappropriate at
that time and that an RIfFS was necessary to evaluate the threat
to the public and tne environment. The RIfFS did not identify a
significant public health threat, however, findings regarding the
environmental threat were inconclusive. EPA issued its Proposed
Plan in July 1988 recommending closure of the landfill based on
the potential environmental threat posed by the landfill. The
Notice of Availability of these documents was published in the
Miami Herald on July 24, 1988. A public comment period was held
from July 20, 1988, through August 17, 1988. A Public Meeting was
held on July 27, 1988. The comments received at the meeting and
during the month following the meeting expressed the following
concerns:
.
Some citizens and interest groups indicated that the
landfill should be included on the NPL.
.
Some citizens indicated that the landfill posed no
threat and the City should continue to seek delisting.
The reliability of current landfill closure plans and
technologies were questioned.
.
dbt077\063.51
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.
The source of funding for the remedial action was
questioned.
In November 1988, EPA, after further review and evaluation of the
RIfFS data, issued a Notice of Change to the Proposed Plan (Miami
Herald, November 27, 1988) in which the "no action" alternative
was recommended because EPA had determined there was no signifi-
cant threat to the environment. This notice was published in the
Miami Herald on November 27, 1988, explaining that no remedial
action "under CERCLA" was appropriate. However, EPA still recom-
mended that landfill closure by the State under state law was
appropriate. Some members of the public, environmental groups,
the NOAA, and the U.S. Fish and Wildlife Service opposed the
change due to the potential environmental threat.
EPA addressed these public comments by conducting the Water
Quality and Toxic Assessment Study in 1989 at the Mangrove
Preserve adjacent to the landfill. The study recommended that
action be taken to control the dispersion of leachate from the
landfill and preclude its emergence into the surface waters in the
Mangrove Preserve. As a result, EPA published its Proposed Plan
in March 1990 which evaluated alternatives for treating leachate
migrating to the Mangrove Preserve. These documents were made
available in the Administrative Record file and information
repository maintained at the EPA Region IV Docket Room and the
North Miami Public Library. The Notice of Availability of these
documents was published in the Miami Herald on March 16 and 25,
1990. Public notice was also given in the New Times, a local
paper, on March 21, 1990. A public comment period was held from
March 16 through April 14, 1990. A Public Meeting was held on
March 29, 1990 at Florida International University. As with the
first plan, some citizens and groups favored EPA involvement,
whereas, others did not. In addition, additional health threats
were cited due to the recent fire at the landfill.
dbt077\063.51
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Section 3
SUMMARY OF COMMENTS RECEIVED AND AGENCY RESPONSES
This section of the Responsiveness Summary is intended to
summarize comments received during the public comment period from
interested parties, including citizens' groups or individuals in
the community, local officials and technical advisors. The Re-
sponsiveness Summary serves two vital functions in that it pro-
vides decision makers with information about the views of the
public, government agencies and potentially responsible parties
regarding the proposed remedial action and other alternatives.
Second, it documents how comments have been considered during the
decision making process.
In an effort to provide clear, 'candid responses, this section has
been divided into two major parts. Part I will be a summary of
major issues and concerns raised by the local community. Local
community will be considered those individuals who have iden-
tified themselves as living in the immediate vicinity of the
Superfund site. The intent of Part I is to provide clear, and
concise answers to local concerns.
Part II will be a comprehensive response to significant comments
comprising mostly legal and technical questions. The responses
in this part will contain, as necessary, details regarding issues
that may have been briefly discussed in Part I. Parts I and II,
therefore, may address overlapping issues. Any points of con-
flict or ambiguity between the two parts will be resolved in
favor of the detailed technical and legal presentation in
Part II.
Each part of this section has been divided into three comment
periods as described previously. These are specifically related
to the July 1988 Proposed Plan, the November 1988 Notice of
Change to the Proposed Plan, and the March 1990 Proposed Plan.
PART I:
LOCAL COMMUNITY CONCERNS
COMMENTS REGARDING THE JULY 1988 PROPOSED PLAN
Public Health and the Environment
1.
A local citizen and the National Oceanic and Atmospheric
Administration (NOAA) expressed concern that releases of
hazardous substances to the adjacent wetland areas and
Biscayne Bay may adversely affect the wildlife of the area.
They requested that EPA require remedial action at the site
that will prevent the release of contaminants to the envi-
ronment and be protective of area wildlife.
dbt077\064.51
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4.
EPA Response: These concerns prompted EPA to conduct a
Water Quality and.Toxic Assessment Study at the site.
Results from EPA's Water Quality and Toxic Assessment Study,
Mangrove Preserve (June 1989) demonstrated that leachate was
migrating from the landfill into the adjacent State Mangrove
Preserve, adv~rsely affecting the aquatic life of the
Preserve. Based on this threat to the environment, EPA is
taking remedial action pursuant to Section 104(a) of CERCLA
to prevent the release of leachate into the Preserve and
protect the environment. The CERCLA remedial action will
collect and treat contaminated groundwater until the
decomposition of waste in the landfill is complete and toxic
leachate is no longer released into the environment.
2.
A participant at the Public Meeting expressed concern
that the manmade lakes that were created to provide
cover for the landfill areas overflow and asked what
would be done .to correct this during the remedial ac-
tion. He indicated that this overflow is a nuisance
and likely transports contaminants to resident's
property.
3 .
EPA Response: When this comment was made, the Proposed
Plan was for the lakes to be filled in and the site
capped as part of a Superfund remedial action, which
included landfill closure. Since the original plan was
developed, a decision has been made to allow the State
to execute the closure of the landfill under State
authority pursuant to Florida Administrative Code (FAC)
17-701. Concerns regarding the landfill, therefore,
should be expressed to the Florida Department of
Environmental Regulation (FDER) so that they can be
addressed during the closure design.
A local resident cited perceived adverse health effects
caused by the presence of the landfill. In addition,
the resident was concerned that closure operations
would cause additional problems due to the smell and
dust.
EPA Response: As stated previously, closure activities
now will be cond~cted under State authority in accor-
dance with FAC 17-701. These concerns are documented
here, but will need to be addressed by the State during
its closure design and construction.
A local citizen who also is a representative of the Izaak
Walton League, Mangrove Chapter, expressed support for the
listing the landfill on the NPL. Concern was expressed
that, if the landfill is delisted, it will not be properly
dbt077\064.51
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closed and consequently, the public and environment not
adequately protected.
EPA Response: Based on the results of EPA's recent study of
the Mangrove Preserve, it is apparent that hazardous sub-
stances are being released from the landfill in the form of
leachate and that these substances represent a significant
threat to the environment. Hence, EPA has determined that
remedial action pursuant to Section 104 of CERCLA, as amend-
ed, is warranted and that delisting of the leachate site
from the NPL is not appropriate.
It should be noted, however, that EPA is directed by
Section 105(a)(8)(B) of CERCLA, as amended, to list national
priorities among "known releases or threatened releases" of
hazardous substances, not contiguous portions of community
owned property. Consistent with this definition and the
National Contingency Plan (NCP), the Munisport release, at
this time, only includes the area in the Mangrove Preserve
in which the release has been documented and the amount of
land (approximately 30 acres) needed to implement the CERCLA
remedial action. The remaining portion of the landfill is
similar to other municipal landfills operated in a similar
time period and should remain under State jurisdiction and
closed in accordance with State landfill closure rules.
Florida's landfill closure requirements are among the most
stringent in the nation. A proper closure under State law
should alleviate any concerns about the landfill.
5 .
A local resident telephoned EPA to express an opinion
that the landfill did not pose a health threat and that
the City should be allowed to use the site. The citi-
zen did not believe that hazardous wastes were at the
landfill.
EPA Response: The Agency agrees that the landfill does
not pose a significant threat to public health based on
the results of the 1988 Remedial Investigation (RI).
The landfill, therefore, will be closed under State
authority. The State will have jurisdiction regarding
the future use of the site.
Funding
1.
A local citizen questioned EPA on the availability of
Federal funds to finance the cleanup of the Munisport site.
EPA Response: Superfund was established for the cleanup of
uncontrolled abandoned hazardous waste sites where there is
no responsible party (RP) to fund the cleanup or the re-
sponsible party is either financially unable or unwilling to
dbt077\064.51
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finance the cleanup. In the case of Munisport, potentially
responsible parties have been identified and EPA will pursue
negotiations with the PRPs to fund the remedial action. In
the event the PRPs do not fund the remedial action, EPA may
elect to fund the remedial action with monies from Super-
fund. Pursuant to Section 107 of CERCLA, EPA can pursue
recovery of the remedial action costs from the RP through
legal actions.
2.
A local resident has observed an improvement in the
condition of the landfill and expressed a desire to let
natural processes solve the problem and avoid spending
the money required to close the landfill.
EPA Response: Closure of a landfill does rely on
natural processes to decay buried materials. A closure'
is intended to mitigate the effects of the landfill on
surrounding areas.
COMMENTS REGARDING THE NOVEMBER 1988 NOTICE
OF CHANGE TO PROPOSED PLAN
Jurisdiction of the Remedial Action
1.
Representatives of the Highland Village Residents; The Izaak
Walton League of America; The Izaak Walton League, Mangrove
Chapter; The Sierra Club, Miami Group; Friends of the Oleta
River State Park; Keystone Point Homeowners Association and
several local residents commented in support of continued
EPA involvement and jurisdiction at the Munisport Landfill.
EPA Response: Since the closure of the comment period in
which these comments were made, and in response to the
comments EPA has obtained additional data from the 1989
Mangrove Study. This data demonstrates that the release of
leachate from the Munisport Landfill represents a signifi-
cant threat to the environment. Hence, EPA has determined
that remedial action is warranted to abate the threat to
aquatic life in the Mangrove Preserve. EPA will retain
jurisdiction and implement the action concerning the release
of hazardous substances to the environment. The "Superfund
site" is the extent of the release of hazardous substances
from the landfill and that portion of the landfill proper
needed to implement the CERCLA remedial action. Based on
the current evidence, EPA considers the remaining portion of
the landfill similar to other municipal landfills operated
in a similar time period and, as such, should remain under
State jurisdiction and properly closed in accordance with
Florida law.
dbt077\064.51
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2.
Local residents, a local commercial property owner, a
member of the Florida House of Representatives (at the
time of the comment period), a representative of the
Westside Property Owners Association, two former mayors
of the City of North Miami, the mayor of North Miami
(at the time of the comment period), and a represen-
tative of the North Miami Chamber of Commerce commented
in favor of State jurisdiction regarding remedial ac-
tion or closure actions at the Munisport Landfill. The
mayor of North Miami (at the time of the comment peri-
od) also commented that the site was improperly placed
on the NPL due to an error in the preparation of the
Hazard Ranking System score and that the results from
the RI did not identify any risks to human health or
the environment. Hence, the site should be removed
from the NPL and the City be allowed to close the land-
fill under State authority in accordance with FAC
Chapter 17-701, landfill closure rules.
EPA Response: As discussed in a previous response, EPA has
obtained additional data from its 1989 Mangrove Study which
demonstrates that hazardous substances are being released
from the Munisport landfill and surfacing in the Mangrove
Preserve. While the results of the 1988 RI did not demon-
strate a threat to public health and was inconclusive re-
garding the threat to the environment posed by the landfill,
the 1989 Mangrove Study conclusively demonstrated that the
emergence of leachate in the Mangrove Preserve is resulting
in significant toxic effects on the aquatic life in the
Preserve. EPA has determined that these toxic effects rep-
resent a significant threat to the environment and that
CERCLA remedial action is warranted. Hence, delisting of
the site is not appropriate at this time.
Furthermore, it is appropriate for EPA to retain jurisdic-
tion regarding the remediation of the release of hazardous
substances. However, the "Superfund site" is the extent of
the release of hazardous substances from the landfill and
that portion of the landfill proper needed to implement the
CERCLA remedial action. Based on the current evidence, EPA
considers the remaining portion of the landfill similar to
other municipal landfills operated in a similar time period
and, as such, should remain under State jurisdiction and be
properly closed in accordance with Florida law.
Public Health and the Environment
1.
The Highland Beach Residents Committee, a
Representative of the Dade County Department of
Environmental Resources Management, The Izaak Walton
League of America, Incorporated, The Miami Group of the
dbt077\064.51
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Sierra Club, Friends of the Oleta River State Park, The
Florida Division of the Izaak Walton League of America,
and The Izaak Walton League Mangrove Chapter expressed
concern that lea~hate from the landfill has an adverse
impact on the adjacent wildlife habitat and recreation
areas of the Mangrove Preserve, Biscayne Bay and the
Oleta River.
EPA Response: The Agency agrees with the concern.
expressed by the groups listed above. To evaluate the
threat of leachate on the downgradient systems, in par-
ticular the Mangrove Preserve, EPA conducted a Water
Quality and Toxic Assessment Study. The results of the
study demonstrated that the leachate migrating from the
landfill into the Mangrove Preserve presents a
significant threat to the environment. Given the data
found in the RI, there was no basis for concern that
the landfill affected the Bay or the Oleta River.
2.
Two local residents, The Friends of the Oleta River
State Park, and the Izaak Walton League Mangrove Chap-
ter expressed a concern that toxic substances from the
landfill could adversely affect the health of local.
residents and students at Florida International Uni-
versity which is located adjacent to the site.
EPA Response: The Health Assessment in the RI/FS
indicates there is no significant threat to human
health posed by the landfill under its current use.
Proper closure of the landfill under Florida law, with
the appropriate amount of cover material and land use
restrictions, should eliminate health threats to future
users. It is presumed that FDER will consider the
health of its citizens in directing the closure of this
landfill.
3.
A local resident expressed concern that if the site was
delisted and no remedial action taken, heavy rains or a
tidal surge would transport contamination to residen-
tial areas.
EPA Response: The possibility cannot be ruled out that
a pulse of more concentrated leachate might be gener-
ated as a result of heavy rainfall or a hurricane
surge. There is no indication that the leachate so
generated would be toxic, except to aquatic organisms.
The overall concern expressed by this comment that no
remedial action could cause adverse consequences has
been addressed in that the leachate from the landfill
will be treated and the landfill will be closed under
State law.
dbt077\064.51
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COMMENTS REGARDING THE MARCH 1990 PROPOSED PLAN
Fire at the Landfill
1.
During the public meeting, a member of the North Miami City
Council asked EPA to explain the role of local versus fed-
eral agencies responsible for the protection of public
health in the case of the smoke hazards caused by the fire
at the landfill.
EPA Response: EPA indicated during the meeting that there
are no known Federal agencies charged with the protection of
public health in the case of municipal landfill fires. The
protection of the public in the case of hazards due to fires
is within the jurisdiction of local authorities.
In the absence of a release or threatened release of
hazardous substances, or a release or threatened release of
a pollutant or contaminant that poses an imminent and sub-
stantial threat to public health or the environment, EPA
does not have any response authority under CERCLA. In the
case of Munisport Landfill, the Agency does not have evi-
dence, nor do the data indicate, that hazardous waste was
disposed at the landfill. Therefore, the Agency determined
that the fire at the landfill did not constitute a threat of
release of hazardous substances. To allay public concern,
EPA conducted two separate air monitoring events during the
course of the fire. The results indicated that hazardous
substances were not being released to the atmosphere at
levels that would be a risk to the public. Therefore, EPA
did not have the authority to require the City of North
Miami to extinguish the fire.
Funding the Remedial Action
1.
During the public meeting, the "mayor for the City of North
Miami asked if funds were available for cleanup through
Superfund.
EPA Response: EPA responded during the meeting that
Superfund is designed to primarily address public health
threats at uncontrolled abandoned hazardous waste sites.
Although the funding for Superfund is considerable, it is
limited due to the number of sites EPA must address. Due to
this constraint, funding for sites must be prioritized based
on the severity of the threat to public health. Since the
Munisport Landfill does not pose a threat to public health,
the priority for funding would be much lower than other
sites that pose a significant threat to public health.
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At the completion of" the Record of Decision (ROD), EPA plans
to give the City of North Miami the opportunity to perform
the remedial design (RD) and remedial action (RA). If the
City does not elect to conduct the RD/RA, EPA may decide to
proceed with the RD/RA and recover the cost for performing
the remedy from the City at a later date.
Identification and Assessment of PRPs
1.
During the public meeting, a local resident asked if other
parties exist that may be also liable for the cleanup of the
site. Specifically, could the former operator of the
facility be identified as a potentially responsible party
and held liable for part of the costs of remedial action.
EPA Response: The evidence that the Agency currently
possesses does not show that the operator of the landfill
operated anything other than a municipal landfill. There is
no evidence that the landfill was operated as a hazardous
waste disposal facility. Hence, based on the current in-
formation, the former operator of the landfill does not ap-
pear to be liable for part of the remedial action cost of
the landfill at this time. EPA will continue to gather
information regarding the prior generators and operations at
the site.
Since the public meeting, numerous individuals stated that
they observed or had knowledge of the disposal of hazardous
waste at the landfill. EPA agreed to investigate the matter
further. Shortly after the public meeting, EPA sent a civil
investigator to North Miami, Florida to meet with local
residents and review documents to determine whether or not
additional PRP's exist. The Agency's efforts to date, have
not yielded new evidence that could be used in the
identification of additional PRPs.
Response and Cleanup Time
1.
The Mayor of the City of North Miami and a North Miami
resident, expressed concern that little progress has been
made in cleaning up the site in 7 years and asked when
cleanup would begin. A local resident also asked how soon
financing would be resolved and cleanup would begin.
EPA Response: The ROD will be followed by a negotiation
period to give the City of North Miami the opportunity to
enter into an agreement for performing cleanup prior to
Superfund involvement. After the negotiations are complete,
the conceptual design should begin.
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2.
A local resident asked what period of time would be required
to complete cleanup of the site.
EPA Response: Based on observation at other landfills, the
estimated cleanup time for the landfill leachate is between
about 15 and 40 years. It is not possible to estimate the
exact cleanup duration at this time. However, once cleanup
has begun, the actual performance of the recovery and treat-
ment system can be used to better predict the rate of clean-
up. Additionally, closure of the landfill portion by the
State may take considerably less time.
Preferred Remedial Action Alternative
1.
A resident of North Miami expressed concern about odor
associated with an air stripper discharge and, speci-
fically, if the combined effect from the Dade County
sewer plant north of the landfill has been considered.
2.
EPA Response: At this time, the combination of discharges
from the proposed air stripper and the Dade County Waste-
water Plant are not expected to cause a problem. However,
pilot testing, including evaluation of air quality in the
area, will be conducted prior to construction. The final
design will be modified, if necessary, to correct inade-
quacies observed during the pilot test.
The president of Highland Village residents committee,
expressed concern over potential airborne releases of
unknown pollutants, PCBs, lead, and silver from the air
stripping system.
3.
EPA Response: Air stripping is an effective means of
removing volatile organic compounds (VOCS) from water, but
under normal operating conditions, will not remove less
volatile contaminants such as PCBs, silver, lead. Water
effluents from the treatment system will be monitored regu-
larly for the presence of these and other contaminants. If,
during operation, new contaminants are identified or dis-
charges exceed ARARs, the system will be expanded or modi-
fied to achieve compliance.
A resident of North Miami, asked if aeration ponds would be
monitored so that there would not be a detrimental effect on
the wildlife in the area.
EPA Response: The anticipated performance of the proposed
alternatives have been evaluated against nine criteria
specified by the EPA. These criteria include: 1) overall
protectiqn of human health and the environment,
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2) compliance with ARARs, and 3) reduction of toxicity,
mobility, or volume through treatment. As discussed in the
Draft Feasibility Study Addendum, all of the action alter-
natives satisfy these criteria. Consequently, the preferred
alternative is anticipated to be protective of the environ-
ment. The effluent from the treatment system, however, will
be monitored to assess compliance and protection of wild-
life. EPA will take steps to protect wildlife if
detrimental effects of the aeration ponds are detected.
4 .
A North Miami resident asked
area to be used for leachate
he is interested in building
property.
for verification of proposed
collection and treatment since
a golf course on the landfill
EPA Response: The leachate collection system will likely' be
along the southeastern perimeter of the landfill, or along
the dike separating the landfill and the Mangrove Preserve,
using a series of approximately 17 recovery wells or
hydraulic barrier. The air stripping pond will be con-
structed on the landfill property near the recovery wells.
Consequently, the area currently proposed for the treatment
system does not include much of the landfill property.
Funding, remedial design issues, and State and local con-
cerns, need to be resolved before this land can be
designated for other uses.
5 .
A North Miami resident asked if the proposed lagoon would
destroy the altered wetlands, and a large area of white
mangroves, at the northeast corner of the site.
EPA Response: Alternative 2 proposed building air stripping
towers on the landfill portion of the site, and using the
plants in the mangrove area to treat the ammonia through
nitrification.
6 .
Due to some public and jurisdictional concerns over the use
of the mangrove areas as part of the treatment system,
A~ternative 3 is recommended by EPA. Alternative 3 would
not include the wetlands as part of the treatment system.
A North Miami resident suggested building a dike separating
the white mangroves from the northeast corner of the site.
EPA Response: A dike, if required, will be addressed as a
later activity. Dredging or filling in the wetlands could
create some jurisdictional problems. Alternative 3, how-
ever, minimizes disturbing the wetlands and a dike would not
be required.
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7 .
A North Miami resident asked if the properties surrounding
the landfill would be made available for other uses.
EPA Response: The acreage required to implement the
remedial action varies with each of the proposed alterna-
tives, but, at this point, there are no plans to construct a
treatment system outside of the 170-acre tract associated
with the landfill. The recovery system would affect a 2000-
3000 foot strip along the west sides of the existing Man-
grove Preserve dike or just south and east of the landfill
boundary. Additionally, it is estimated at this time that
the treatment system will be no larger than about 30 acres.
Should the results of the hydrologic study indicate that
more area is needed to effect the remedy, the size of the
site will be expanded as needed.
Public Health and the Environment
1.
During the public meeting, a local citizen provided EPA with
a list of approximately 25 people that reside or have
resided near the landfill and have either died from or have
cancer. The local citizen was concerned that this is an
abnormally high number of cancers for a local area and felt
that they were related to exposures from wastes in the
landfill.
EPA Response: EPA had the Agency for Toxic Substances and
Disease Registry (ATSDR) review the list of cancer cases and
documents characterizing the waste that could be expected at
the Munisport.Landfill. ATSDR reported that the number of
cancer cases reported by the local citizen is consistent
with national statistics regarding cancer cases. Moreover,
ATSDR concurred with EPA's determination that wastes
characteristic of the Munisport Landfill do not represent a
threat to public health.
PART II:
LEGAL AND TECHNICAL ISSUES
COMMENTS REGARDING THE JULY 1988 PROPOSED PLAN
Jurisdiction of the Project
1.
A representative of the Izaak Walton League Mangrove
Chapter, expressed concern that if the Munisport Landfill
property was delisted from the National Priorities List
(NPL) and allowed to be sold for development, it would not
be cleaned up to a degree that would be protective of public
health or the environment. It was, therefore, the request
of the League that the property not be delisted from the
NPL.
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2.
EPA Response: Based on the results of the EPA Water Quality
and Toxic Assessment Study, Mangrove Preserve (June 1989),
EPA has determined that remedial action pursuant to Sec-
tion 104(a) of CERCLA is warranted to protect the Preserve
from leachate. The Munisport "release" will remain on the
NPL, however, the area of Superfund remedial action is
estimated at 30 acres. The scope of remedial action does
not include closure of the landfill. Landfill closure will
be accomplished under State authority. .
The City of North Miami and NOAA expressed support for the
closure of the landfill under State authority as the appro-
priate method of remedial action.
EPA Response: Since the period in which these comments were
made EPA has obtained new data that have prompted the devel-
opment and selection of a new method of remedial action,
however, this comment is still relevant. The new data
obtained from the 1989 EPA Mangrove Study demonstrated that
there is an uncontrolled release of hazardous substances
from the landfill into the adjacent State Mangrove Preserve.
As a result, EPA has determined that CERCLA remedial action
that includes the interception, collection, and treatment of
the hazardous substance prior to emergence into the Mangrove
Preserve is warranted. Since the RIfFS did not reveal the
presence of any hazardous wastes in the landfill that
represents a significant threat to public health or the
environment and that the release. of hazardous substances
(primarily ammonia) appear to be the result of the decom-
position of municipal waste disposed in the landfill, EPA
has determined that closure of the landfill proper under
State authority is appropriate, and therefore agrees with
the comment.
3.
Representatives of the Friends of the Everglades, Dade
County Chapter, The Sierra Club, Miami Group, and the Izaak
Walton League expressed concern that it is necessary for EPA
to remain involved and retain jurisdiction in the remedial
action activities at the site.
EPA Response: Since the period in which these comments were
made, new data has warranted a change in the scope of the
CERCLA remedial action, however, these comments are still
relevant. EPA will retain jurisdiction over the remedial
actions taken pursuant to CERCLA. These actions will be the
interception, collection, and treatment of leachate prior to
its emergence in the Mangrove Preserve. Closure of the
landfill will be conducted under State Authority pursuant to
FAC Chapter 17-701, Landfill Closure Rules. With regard to
landfill closure, EPA will consult with FDER on the compati-
bility of the two actions. EPA will review the two actions,
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within five years of the completion of the construction of
the two actions and determine if additional action may be
warranted.
4 .
Counsel for the City of North Miami submitted a
document entitled Proposed Findings of Fact and Con-
clusions for the Record of Decision for the Munisport,
Florida, Superfund Site. This document outlines his-
torical data on the landfill property and cites reasons
for EPA to take action in delisting the site from the
National Priorities List (NPL). Among the reasons
outlined are the following:
.
Scoring error led to the original listing and the fact
that EPA has the legal authority to correct the error.
.
Case law sets precedents for agencies correcting errors
and modifying actions.
.
Congressional debate cited scoring error at Munisport.
.
Delisting proposed by Mr. Henry Longest, Director of
EPA's Office of Emergency and Remedial Response, if the
RI concludes that there is no significant threat to
human health and environment.
.
Results of RI indicated no significant threat of harm
to human health and environment.
EPA Response: The proposed rulemaking that included the
first NPL appeared in the Federal Register on December 30,
1982. The announcement was a major media event with wide-
spread national and local coverage. It was a significant
issue in Florida, fueled somewhat by an interim list of 115
sites released by EPA in October 1981 that included 18
Florida sites, more than any other state. On December 21,
1982, the first NPL was front page news in The Miami Herald
which published an article on the new proposal and mentioned
the Munisport site three times.
EPA held a formal 60 day public comment period follow-
ing the publication of the proposed list in the Federal
Resister and considered late comments well beyond the
end of the formal period. The final rule decision for
the first NPL, including the Munisport site, appeared
in the Federal Register on September 8, 1983. EPA
received no comments from the City of North Miami, the
State of Florida, or anyone else other than the U.S.
Department of Interior mentioning concerns about endan-
gered species in the Biscayne Bay that could be poten-
tially affected by the Munisport site. Furthermore,
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the City of North Miami did not challenge the site's
final listing in the D.C. Circuit during the 90-day
jurisdictional review period commencing September 8,
1983.
On September 21, 1984, EPA published in the Federal
Register its policy on rescoring sites. This policy
stated that EPA's resources and efforts should be
focused on further investigation of threats and de-
termining appropriate cleanup, not rescoring.
In July, 1986 North Miami petitioned EPA to delist the
site based on the alleged scoring error. This was ap-
proximately three and one-half years after the proposed
listing.
EPA decided to take a course of action consistent with
the 1984 policy and initiated a remedial investigation
to determine the threat and response options before
considering deleting the site. EPA's position is that
the public should be provided a sound technical basis
before summarily removing sites from the NPL.
EPA agrees that it has the authority to correct its own
errors or otherwise modify its actions. However, North
Miami's reliance on the A.L. Laboratories v. EPA 674
F.Supp, 894 (D. D.C. November 23, 1987) is not dispo-
sitive in this case for three main reasons. One, the
lists in the two cases are of different significance.
The inclusion of four substances on the Extremely
Hazardous Substances List had immediate impacts on the
plaintiffs in the case cited. Inclusion on this list
subjected those who store sufficiently large quantities
to notification, reporting, and planning requirements
under Title III of the Superfund Amendments and
Reauthorization Act (SARA), otherwise known as the
"Community Right-to-Know Act". Potential fines for
failure to comply range from $25,000 to $75,000, and
may be assessed daily.
The NPL, on the other hand, is merely an informational
list of those sites to which EPA has assigned a high
priority. Listing does not mean that remedial action
will be taken, or that any particular party is liable.
In enacting CERCLA, Congress specified that the NPL was
intended to serve a narrow purpose:
The priority lists serve primarily informa-
tional purposes, identifying for the States
and the public those facilities and sites or
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other releases which appear to warrant
remedial actions. Inclusion of a facility or
site on the list does not in itself reflect a
judgement of the activities of its owner or
operator, it. does not require those persons
to undertake any action, nor does it assign
liability to any person. Subsequent govern-
ment action in the form of remedial actions
will be necessary in order to do so, and the
actions will be attended by all appropriate
procedural safeguards. (S. Dep. No. 848,
96th Congress, Second Session 60 (1980).)
EPA has affirmed this language in numerous preamble
statements to NPL rulemakings (see e.g., 48 Federal
Register, 40658, 40659, September 8, 1983, and 52
Federal Register, 27620, 27621, July 22, 1987) and in
its regulations (see 40 CFR 300.66(c)(2)). Listing on
the NPL simply makes a site eligible for remedial ac-
tion financed by the Superfund established under
CERCLA.
Two, the plaintiffs in A.L. Laboratories raised their
objections in a timely manner (i.e. within the comment
period). The courts have indicated that challenges to
the HRS scores not raised during the public comment
period may not be raised later (Northside Sanitary
Landfill v. EPA, 849 F.2d 1516, 1521, D.C. Cir. 1988;
Eagle-Picher Industries v EPA, 822 F.2d. 132, 146, D.C.
Cir. 1987.).
Three, in AL Labs, EPA never made a finding that the
substances in question were hazardous. By contrast,
EPA has made a finding that there is a release of
hazardous substances from the Munisport site and that
the site does pose a significant threat to the envi-
ronment.
The Congressional colloquies simply confirm EPA's
discretionary authority to rescore sites and in this
instance EPA has chosen not to do so.
The decision to take remedial action at this site is
consistent with the representations made by Mr. Henry
Longest in 1987. Mr. Longest stated that EPA would
promptly delete the site if there were no significant
threats to human health or the environment. While the
RIfFS indicated there was no human health threat, it
was unclear as to the environmental threat. Concerns
expressed by the local citizens, environmental groups,
NOAA, the U.S. Fish and Wildlife Service, and Florida
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Department of Natural Resources (FDNR) during the pub-
lic comment periods prompted EPA to do a more thorough
investigation of the leachate problem. The Agency's
change of position is an affirmation of the public
participation in the CERCLA decisionmaking process.
The commenter also stated that the RI indicated no
significant threat of harm to human health or the en-
vironment. The Agency agrees that the results of the
RI did not demonstrate a threat to public health due to
the release of hazardous substances from the landfill.
The RI, however, was inconclusive with regard to the
threat that a release posed to the environment. Based
on comments from several Federal agencies and envi-
ronmental groups who expressed concern that the site
may present a threat to the environment, EPA conducted
a Water Quality and Toxic Assessment Study. This study
was designed to specifically evaluate the environmental
threat that the site may present to aquatic life in the
Mangrove Preserve adjacent to the landfill. The re-
sults of the study demonstrated that leachate migrating
from the landfill into the Preserve presents a
significant threat to aquatic life.
COMMENTS REGARDING THE NOVEMBER 1988 NOTICE
OF CHANGE TO PROPOSED PLAN
Jurisdiction of the Property
1.
Representatives of the Highland Village Residents; Izaak
Walton League of America; Izaak Walton League, Mangrove
Chapter; Sierra Club, Miami Group; Friends of the Oleta
River; Keystone Point Homeowners Association and several
local residents commented in support of continued EPA in-
volvement and jurisdiction at the Munisport Landfill. The
representative of the Izaak Walton League, Mangrove Chapter
expressed concern that flaws identified by EPA's consultant
in the City of North Miami and FDER Landfill closure plan
are indicative of a lack of genuine interest in the proper
closure of the landfill.
EPA Response: Since the closure of the comment period in
which these comments were made, EPA has obtained additional
data from the 1989 Mangrove Study. This data demonstrates
that the release of leachate from the Munisport Landfill
represents a significant threat to the environment. Hence,
EPA has determined that CERCLA remedial action is warranted
to abate the threat to aquatic life of the Mangrove
Preserve. EPA will retain jurisdiction over the CERCLA
remedial action. Based on the current evidence, EPA
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considers the remaining portion of the landfill similar to
other municipal landfills operated in a similar time period
and, as such, should remain under State jurisdiction and
properly closed in accordance with Florida landfill closure
rules, Chapter 17-701, FAC. FDER has expressed strong
interest in ensuring that this landfill is closed properly.
Public Comment Period
1.
The Florida Division of the Izaak Walton League of America,
and the Izaak Walton League, Mangrove Chapter, commented
that an inadequate comment period was held for the Notice of
Change to the Proposed Plan.
EPA Response: EPA has provided significant opportunities
for public participation at this site. After the first
proposed plan a comment period and hearing were held and a
second comment period was offered for the public to comment
on the proposed change. The Agency does not believe that a
second public meeting was required due to the change in the
proposed plan. Indeed CERCLA Section 117(b) contemplates
that significant changes in the proposed plan be discussed
in the final plan. In this case, EPA went further and
provided the public an opportunity to comment on the plan
before a final decision was made and influenced EPA to
conduct further studies. This second comment period is
consistent with EPA guidance (Draft Guidance on Preparing
Superfund Decision Documents: Proposed Plan and ROD).
While the Agency appreciates the League's concern for a
lack of time for adequate comment, Section 300.67 of
the NCP (at the time of the comment period (1988)) only
required a comment period and public meeting for the
initial release of EPA's proposed plan. Furthermore,
EPA policy and guidance at the time of the meeting only
required an additional comment period in situations
where EPA, through the review of comments on the
proposed plan or from the receipt of additional data,
EPA selects a remedy that was not presented as an
alternative in the proposed plan nor was it a logical
outgrowth from the information contained in the Admin-
istrative Record (AR) file for the site. Since the
alternative that the Agency selected was discussed in
the proposed plan and since the change was based on
information contained in the AR, EPA was only required
to document the justification for selection of a new
remedy in the ROD. However, due to the high level of
public interest in this site, the Agency determined
that it would be appropriate to notify the public of
the selection of a new alternative and to allow an
additional period for public comment. EPA has
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fulfilled all statutory or regulatory requirements for
public comment.
2 .
A representative, of the Izaak Walton League, Mangrove
Chapter, requested that a public hearing be held so
that the League and other interested parties could
present their positions regarding the change in EPA's
proposed plan for CERCLA remedial action.
EPA Response: The League request for a public hearing on the
change in alternatives is now moot. Based on new data
collected by EPA, the Agency has determined that the
original proposed plan and the change to the plan are no
longer an appropriate response pursuant to CERCLA. The
Agency developed an addendum to the original Feasibility
Study and new proposed plan. The public was allowed to
comment on these documents for 30 days and also discuss
their concerns with EPA, FDER, DERM and other government
agencies at a public meeting held during this comment
period.
3 .
A representative of the Izaak Walton League, Mangrove
Chapter,. requested that EPA issue a draft of the ROD (based
on the no CERCLA remedial action) be issued and it be
available for public review and comment.
EPA Response: The NCP at the time of the comment
period (November 1988) (and the current NCP) required
that EPA publish a proposed plan based on the findings
of the RIfFS and identify the Agency's preferred alter-
native. The Agency was not required (nor is it cur-
rently required) to provide a copy of the draft ROD to
the public for review and comment. Moreover, pursuant
to EPA policy, draft documents are considered
"pre-decisional" and not subject to public review.
Pursuant to current EPA guidance and the NCP, public
comments received on the proposed plan are reviewed by the
Agency and used to develop the ROD. Significant changes in
the selection of the preferred alternative from the proposed
plan are documented in the ROD along with a summary of how
the Agency responded to the public's comments on the pro-
posed plan.
Public Health and the Environment
1 .
The Izaak Walton League of America expressed a concern
that leachate from the landfill degraded the quality of
the groundwater supply beneath the landfill.
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EPA Response: The Agency agrees that leachate from the
landfill has impacted the quality of the groundwater at
the site. The groundwater in the vicinity of the Muni-
sport property, however, is not used as a drinking
water source due to salt water intrusion.
COMMENTS REGARDING THE MARCH 1990 PROPOSED PLAN
Natural Resources Damages
1.
The Counsel for the City of North Miami requested an
assurance that the Agency would not seek natural
resources damages from the City under CERCLA or any
other federal law, and that NOAA concur with the
alternative.
EPA Response: While the Agency has consulted with and
received concurrence from NOAA on the ROD, the Agency
does not have the authority to assure that no natural
resource damage claims will be assessed. Pursuant to
Section 107(f)(1) of CERCLA, the President delegates
authority to pursue natural resource damage claims. As
contained in Section 300.600 of the NCP, this authority
has been delegated to two federal trustees, the De-
partment of Commerce (through NOAA) and the Department
of Interior (DOl). Two state trustees, FDER and FDNR
have also been appointed. As such, only the trustees
have the jurisdictional authority to assess or seek
natural resource damage claims.
Jurisdiction and NPL Listing of the Site
1.
Counsel for the City of North Miami expressed concern
regarding the potential problems associated with a dual
authority role (i.e., EPA and FDER) regarding future re-
sponse actions at the site. The cornmenter expressed that
dual authority ultimately leads to conflicting requirements
and directions which lead to increases in costs.
EPA Response: EPA is aware of the potential problems that
may occur in dual authority roles and appreciates the com-
menters concerns. Although some sites require a dual au-
thority role to ensure that the appropriate actions are
taken to effect the remedial action, EPA has determined that
dual authority regarding the response actions at this site
is not necessary.
Based on the results from the 1988 RI and the 1989 Mangrove
Study, EPA has determined that the release of leachate from
the Munisport Landfill poses a significant threat to the
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2.
environment and that CERCLA remedial action to abate the
threat is warranted. Since the studies and available file
information do not indicate that the landfill poses a
significant threat to public health or the environment, EPA
has determined that the most appropriate action with regard
to closure of the landfill is for it to be closed under
State law. There will be two separate remedial actions
taken concurrently at the site pursuant to two separate
authorities. Therefore, problems typically associated with
dual authority roles should not occur. Furthermore, EPA
will consult with FDER to ensure that the two actions are
compatible and not duplicative.
Counsel for the Florida Audubon Society and the Tropical
Audubon Society expressed concurrence with EPA's decision
not to delete the Munisport site from the NPL. Counsel,
however, does not concur with EPA's plan to bifurcate the
jurisdictional responsibility for cleanup of the site be-
tween Federal and State authorities. Counsel reasons that
by EPA only addressing the release of leachate and not the
actual source of leachate, the threat to the public posed by
the landfill will be ignored. Finally, Counsel contends
that by only responding to the release of hazardous sub-
stances, EPA is not fulfilling its obligations under CERCLA
to also respond to the threat of release of hazardous
substances in addition to actual releases.
EPA Response: Pursuant to Section 104(1) of CERCLA, EPA is
authorized to respond to the release of any hazardous sub-
stance or if there is a substantial threat of release of a
hazardous substance to the environment. However, based on a
review of evidence concerning the disposal of hazardous
waste at the Munisport Landfill and data collected during
the 1986-87 RI and 1989 Mangrove Study, EPA has determined
that the landfill does not represent a significant threat to
public health or the environment, nor do the conditions
represent a substantial threat of release to the envi-
ronment. This determination was made in consultation with
the EPA Risk Assessment Officer and the Agency for Toxic
Substances and Disease Registry (ATSDR). In the absence of
a significant threat to public health or the environment
posed by the landfill, EPA determined that the most
appropriate course of action would be for Federal response
to the release of hazardous substances to the Mangrove
Preserve and State response regarding the proper closure of
the landfill.
With regard to the proposed method to respond to the release
of hazardous substances in the Mangrove Preserve, the
commenter also indicated that EPA would be remiss by only
responding to the release and not actually removing the
dbt077\064.51
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"\
source of contamination. Based on a review of existing
waste disposal information and analytical data for this
site, EPA has determined that the waste disposed of at this
landfill is consistent with the types of wastes (e.g.,
municipal refuse) disposed of at other regional landfills
operated during similar time periods. The threat to the
environment results from the release of hazardous substances
whereby the decomposition of organic waste in the landfill
(which is a normal occurrence) in combination with the
inappropriate siting of the landfill in a environmentally
sensitive area. This is a unique set of circumstances.
Ammonia, although it is a natural byproduct of the decompo-
sition of organic materials, is being released into an
ammonia sensitive environment at toxic levels. However, the
circumstance under which this release is occurring is not
natural and is the result of man-made activities.
Since EPA has established that the release of leachate from
the landfill represents a threat to the environment and that
the landfill proper does not pose a significant threat to
public health, the Agency has determined that the most
appropriate response action is to collect and treat the
leachate released from the landfill until the decomposition
or organic material in the landfill has progressed enough
that the leachate is no longer toxic to aquatic life.
Although the removal of the source of contamination (i.e.,
removal of the landfill) may appear to be a more straight-
forward approach, it is not the most appropriate method.
Removal of garbage from the landfill would be by far the
least cost effective of the remedies considered and is
unwarranted, especially in the absence of a public health
threat.
3.
Counsel for the City of North Miami submitted a letter
outlining the City's reasons for asking for a delisting
of the site. These reasons included the following:
.
Scoring error led to initial listing on NPL
.
Case law cited as precedent for correcting scoring
error
.
Congressional direction cited during Superfund
reauthorization
4 .
EPA Response: Please refer to similar comments and
responses for the July 1988 comment period (Comment
Number 4 under Jurisdiction of the Project).
Counsel for the City of North Miami commented that the
CERCLA action at the Mangrove Preserve, as proposed by
dbt077\064.51
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EPA, would be in conflict with the existing Clean Water
Act, Section 404(c) veto and the 309(a) Order.
EPA Response: Section 404 of the CWA establishes a permit
program under which the Army Corps of Engineers (Corps) is
authorized to issue permits for the discharge of dredge or
fill material at specified disposal sites. Such sites are
to be specified through application of the Clean Water Act
(CWA) Section 404(b)(1) criteria developed by EPA. To
provide a check on the permitting authority of the Corps,
Section 404(c) of the CWA allows EPA to prohibit, or re-
strict, or withdraw the specification of any defined area as
a disposal site, where EPA determines that discharging at
the site would have "unacceptable adverse effects" on,
interalia, municipal water supplies and fishery areas.
Thus, CWA Section 404(c) establishes, in effect, an
"unpermitting" process.
To the extent that an action is exempt from federal
permitting requirements by the express provision of CERCLA
Section 121(e)(1), it is reasonable to consider any CWA
Section 404(c) prohibition or restriction on permitting at
the site to be ineffective. Further, as noted above, Sec-
tion 404(c) restrictions were intended to serve as a mecha-
nism for EPA to limit permitting decisions by the Co~; in
the CERCLA context, it is EPA itself that is making the
decision of what dredge or fill if discharged are necessary,
and whether there will be an adverse effect from those
discharges.
Hence, EPA has determined that implementation of the CERCLA
response action will not require a modification of the CWA
Section 404(c) veto. Closure of the landfill, however, may
be subject to the veto, and if necessary, may require a mod-
ification of the Section 404(c) veto. With regard to the
CWA Section 309(a) Order, EPA may elect to withdraw the
Order if the Agency determines that the intent of the Order
will be complied with by the PRPs through the implementation
~f the CERCLA response action.
Public Health and the Bnvironment
1.
Counsel for the City of North Miami indicated that
existing reports do not demonstrate a threat to the
public or the environment. In particular, the comment
noted the following points:
1a.
Ammonia was the only hazardous substance
found in Preserve.
dbt077\064.51
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EPA Response: The Agency agrees with the commenter that
ammonia was the only hazardous substance found at sufficient
concentrations to effect a significant environmental threat.
Other hazardous substances were detected, but not at levels
that constitute a threat to public health or the environ-
ment. Under the Clean Water Act (CWA) and CERCLA, ammonia
is defined as a hazardous substance. The release of a
hazardous substance is subject to CERCLA jurisdiction.
lb.
The City photographic and visual evidence
indicates that the Preserve is a healthy
mangrove system.
EPA Response: EPA agrees that the photos are of live
mangroves and that small fish were sighted in the man-
grove preserve. We do not agree that the photos and
fish sightings gives evidence that the aquatic life of
the Preserve is not threatened by toxic concentrations
of the leachate.
EPA views the mangrove preserve as an integral
ecological component of the larger marine system of
Biscayne Bay. As the daily exchange of tidal water
takes place between the Preserve and Bay so does an
exchange of aquatic life. This life mass is comprised
of many kinds of species found in various life stages
of development. A numerical preponderance of the life
forms are early life forms such as fish and shellfish
eggs, larvae, post larvae, and juveniles. Such an
assortment is common since a function of shallow, ma-
rine environments is to provide spawning and nursery
areas for a host of estuarine dependent species. The
abundance and diversity of'these animals fluctuate
yearly, seasonally, and even daily between night and
day. Little is known on the basis for these
fluctuations.
In addition to this natural transient state, each kind of
animal and its associated life stage survives within a range
of physical, chemical and biological constraints of their
environment. Changes in these constraints whether naturally
or through pollution, effects the animal's ability to sur-
vive. As the pollution increases, for example, the animal
is eliminated from the environment according to its sensi-
tivity to the pollutant. Those animals less sensitive to
the pollution that survive may even increase in abundance.
For these reasons, a casual observation is not adequate to
judge the health of a plant and animal community like the
Mangrove Preserve. Those animals or plants sighted may only
represent the survivors and not the original community.
dbt077\064.5l
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. -
,
1c.
The City of North Miami commented that the
bioassays undertaken in the Preserve Study
were so flawed as to provide no reliable
indication of any adverse impact on aquatic
life in the' Preserve from leachate 'ammonia.
The City identifies these flaws as 1) the
test species were not endemic to the Pre-
serve, 2) sa~inity stress in the acute
toxicity tests with Menidia, 3) residual
hydrogen sulfide in the site samples was not
accounted for at the time of toxicity test-
ing, 4) the natural environment of any man-
grove system is not hospitable to non-mature,
sensitive aquatic life.
EPA Response: Results of the Preserve Study demonstrates
that ammonia concentrations in the western region of the
preserve exceeded National Water Quality Criteria. This
criteria was based upon results from the standardized tox-
icity bioassays which involved multiple test species and
sensitivities to ammonia. The criteria was established to
be protective of 95 percent of all marine life including
sensitive species. As indicated in the previous response,
multiple species of aquatic animals and life stages can be
expected to utilize the Mangrove Preserve.
The methods used to assess toxicity in the Preserve Study
were the same standardized protocol used to establish
national criteria. The selection of test species was from
the EPA established suite of approved test species for
marine bioassays. The fact that the selected test species
are found or not found as endemic populations of the man-
grove preserve is not an issue in EPA's toxic control poli-
cies. The selected species are viewed by EPA as a "white
rat" test organism. Their sensitivity to pollutional
effects, ability to be cultured, and suitability to lab-
oratory testing are the over-riding reasons for their use in
the toxicity tests. The purpose of using multiple species
in the bioassays was to attempt to assure that the most sen-
sitive species are evaluated. With this evaluation, it is
assumed by EPA that this test species represents the most
sensitive species or group of species found anywhere and
anytime in the Mangrove Preserve. These sensitive species
would include any life stage whether it be an egg, larvae,
post larvae, juvenile, or adult fish, shellfish, or other
invertebrates.
The species Menidia berylinna which was used in the
bioassays is recognized as a common forage fish in coastal
marine waters. The species is euryhaline thus capable of
surviving in wide ranging conditions of salinity. The batch
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J
of fish (10 to 14 days old) used in the bioassays were ini-
tially cultured and shipped to EPA in saltwater with a sali-
nity of 25 ppt. The bioassays were conducted with samples
from the preserve having a salinity ranging from 31 to 36
ppt. Performance controls were also conducted with marine
water of 25 and 36 ppt salinity. The 11 ppt salinity dif-
ferential between the controls was of no apparent conse-
quence to survival. The City views that in the absence of
acclimating the fish to the greater range of salinity, the
differential between 25 ppt and the site sample range of
31 to 36 ppt as possibly effecting osmoregulatory stress in
the test fish thus making them more susceptible to ammonia
toxicity. EPA does not concur with this view in light of
the natural euryhaline characteristics of the species and
the fact that no effect was seen in the control tests.
Regarding toxicity due to residual hydrogen sulfide in the
bioassay samples, EPA believes there is no basis for this
concern. Hydrogen sulfide is the most reduced form of
sulfur and is subject to rapid oxidation in the presence of
any dissolved oxygen. The City overlooks the fact that the
surface waters tested were not always absent of dissolved
oxygen. Samples collected from the Preserve and shipped to
the Athens laboratory (about 24-hour transient time) were
all aerobic. The samples upon their preparation for testing
never yielded any odors indicating the presence of hydrogen
sulfide. EPA believes hydrogen sulfide was of no conse-
quence to the observed toxicity of the samples.
EPA agrees that "non-mature" Menidia were used in the
toxicity testing. However, we fail to understand how the
results of the toxicity tests corroborates the City's notion
that the natural environment of any mangrove system is not
hospitable to "non-mature", sensitive aquatic life forms.
The Black Point mangrove system, by any measure, is a good
example of natural mangrove system where no toxic effects
were measured in the Athens tests.
The City indicates that toxicity in the Preserve is
associated with an unknown pollutant from the Bay, and
the presence of two inadequately sized culverts.
EPA Response: EPA is equally disturbed with the toxicity
findings which show toxic conditions in reference sites.
However, these findings cannot possibly support the City's
view that the toxicity was due to "back-water" conditions
which naturally result in low dissolved oxygen, high hydro-
gen sulfide and high ammonia concentrations. This is noth-
ing less than speculation on the part of the City. First,
dissolved oxygen or hydrogen sulfide were not reported for
any of the three toxic reference sites. Ammonia was,
ld.
dbt077\064.51
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however, intensely monitored which showed only trace levels
of this substance in these waters.
EPA remains concerned about the observed toxicity associated
with the regional waters of Biscayne Bay. However, we view
this as a different environmental problem from that of the
Mangrove Preserve.
Ie.
The City argues that the cause of the
observed toxicity in the Mangrove Preserve
Study results from an area-wide pollutant or
combination of pollutants and not the
Munisport Landfill. This view is based on
the contention that toxic effects were com-
parable between the Mangrove Preserve and the
three toxic reference sites.
EPA Response: EPA views the toxicity issue of the
reference sites as an environmental prob~em but
separate from the Mangrove Preserve. The Agency does
not dispute the idea that the toxicity of Biscayne Bay
may contribute to the Preserve problem; however, EPA
concluded from the Mangrove Preserve Study that the
observed toxicity in the Preserve was due primarily to
landfill leachate.
As indicated previously, EPA has no reservations that the
ammonia concentrations reported in the western region of the
preserve are a product of landfill leachate emerging in the
surface waters of the Preserve. Other sources of ammonia
are of no significant consequences to the observed ammonia
regime. In Figure 31 of the Preserve Study Report, the
relationship between ammonia concentration and toxicity
clearly demonstrated a high correlation coefficient. The
ammonia content of surface waters in the preserves follows
an increasing concentration gradient from the Bay to the
western boundary of the preserve and the landfill (see
previous response).
The toxic response to this ammonia or leachate gradient is
further indicated in Figure 18 of the Preserve Study which
shows the toxic effects as it is distributed at low tide,
the time when residual bay water is minimally present in the
preserve. At low tide, the toxicity of Biscayne Bay was
significantly less than reported for the Preserve (Table 12
of Preserve Study Report). The City contends that the toxi-
city results were comparable between the Preserve and Bay.
They are not. At high tide, toxicity was greatly reduced
from that observed during low tide sampling by the inflow of
bay water. Clearly, water from Biscayne Bay interacts and
diminishes the toxicity associated with the mangroves hence
dbt077\064.51
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the Bay is viewed as a mediator to toxicants in the Mangrove
Preserve.
1f.
Munisport Landfill is not a significant
contributor to ammonia levels observed in the
Preserve. Concentrations found in the Pre-
serve are derived from in-situ decomposition
of mangrove detritus. The "backwater"
condition and poor circulation of the pre-
serve enhance the production of such high
concentrations of ammonia. The reported con-
centrations of ammonia in the Preserve are of
the same magnitude found world-wide in
mangrove systems.
EPA Response: The City contends that the range and
average concentration of ammonia in the landfill are
less than normal when compared to other landfills and
that the average is too low to support the reported
concentration in the Preserve. A reading of the site
RI will show that the distribution of ammonia in the
site is extremely uneven which simply means that the
garbage was not uniformly spread and that "hot spots"
of ammonia have developed. Because of this haphazard
distribution, the movement of site leachate and the
associated ammonia would not travel in a broad front
with uniform or average concentration of ammonia
emerging in the Preserve. As shown in Figure 9 of
Appendix A in the Preserve Study Report and in Fig-
ure 10 of the Report, the greatest concentrations of
ammonia in Preserve is skewed to the area of Sta-
tion D6. This skewed condition indicates that the
ammonia regime is not a function of average conditions
in the site.
EPA would agree that ammonia production via the anaerobic
decomposition of detritus is a normal biological process of
mangrove systems including those sampled in the Preserve
study. However, EPA disagrees that in-situ processes of
ammonia generation explains the ammonia regime of the
Preserve.
Table 9 of Appendix A provides the results of synoptic
sampling of surface waters throughout the Preserve area.
The sampling included "backwater" and "forewater" areas of
both the western and eastern regions of the Preserve.
Clearly from these data, pronounced gradient of decreasing
concentrations of ammonia extended from the western to the
eastern boundaries of the Preserve. The only feature that
distinguishes the western area from the eastern area of the
Preserve is the proximity of the landfill. In this case the
dbt077\064.51
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landfill fronts the western edge of the Preserve. To assume
the western region of the preserve is better suited for am-
monia production than the eastern region is not justified
since both areas share the same tidal circulation and
mangrove community.
Finally, the sampling of surface waters in mangrove area
outside of the Preserv~ (Biscayne Creek, Dania Canal, and.
Black Point) confirm that in-situ generation of ammonia
results in concentrations grossly less than observed in the
western region of the Preserve. These referenced systems
were sampled hourly for at least 24 hours. Of the 72 plus
samples, only one sample yielded a concentration suffi-
ciently high enough to be above the analytical detection
level. That one sample measured 0.1 ppm which is two
orders-of-magnitude less than the highest value observed. in
the western region of the Preserve.
From these findings, EPA can only conclude that the
Munisport Site is the principle source of ammonia found in
the Preserve.
2.
Council for the City of North Miami contended that
restricted tidal circulation in the Mangrove Preserve likely
causes the reported toxicity. Further, the impaired tidal
circulation will restrict the types of marine organisms that
live in the Mangrove Preserve, even in the absence of high
levels of ammonia.
EPA Response: The undersized culverts restrict only the
high water portion of the tide cycle. High tide represents
the period of limited toxic impact in the Preserve. Con-
versely, low tide represents the period of highest toxic
response. The culverts imposed no restriction to low water
dynamics.
EPA recognizes though that the apparent tidal restrictions
effected by the undersized culverts impairs the full de-
.velopment of the dissolved oxygen budget. Further, we also
recognize that the high concentrations of ammonia not only
are toxic to aquatic life, but also effects a large dis-
solved oxygen demand, via the nitrification processes.
Chemicals, one mg/L ammonia, is equivalent to 4.57 mg/L
carbonaceous biological oxygen demand. The proposed CERCLA
remediation will mitigate the toxic effects of ammonia,
reduce the dissolved oxygen demand associated with the
nitrification process, and remove the restricting effect of
the undersized culverts.
3.
Counsel for the City of North Miami commented ~hat CERCLA
response due to a release of ammonia, a naturally occurring
dbt077\064.5l
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substance, is not appropriate. Section l04(a)(3)(A) of
CERCLA prohibits actions in response to the release or
threat of release "of a naturally occurring substance in its
unaltered form, or altered soley through naturally occurring
processes or phenomena, from a location where it is
naturally found".
EPA Response: While ammonia is a naturally occurring
substance, it is being released under circumstances that are
not naturally occurring in that environment (i.e., municipal
landfills do not naturally occur adjacent to mangrove
swamps). In the absence of the landfill, it would stand to
reason that ammonia would not be present in the Mangrove
Preserve at concentrations toxic to aquatic life. Hence,
EPA has determined that remedial action pursuant to Sec-
tion l04(a)(1) of CERCLA is necessary and appropriate in
order to a abate the threat to the environment.
Record of Decision
1.
Counsel for the City of North Miami requested that EPA
include in its Proposed Plan and Record of Decision all of
the City's correspondence and records of communication with
EPA concerning the Munisport Landfill.
EPA Response: Pursuant to EPA guidance and policy all
written and oral correspondence related to the development
of EPA's decision, including the Proposed Plan and the ROD,
is maintained in an Administrative Record (AR) file for this
site. The AR for this site is maintained in a local re-
pository at the City of North Miami Public Library and the
EPA Records Center in Atlanta. Actual inclusion of these
records in the Proposed Plan or ROD documents is therefore,
not necessary.
Remedial Investigation and Remedial Action Alternatives
1.
A representative of the Munisport Dump Coalition and the
Friends of the Oleta River, expressed concern about effects
of air emissions associated with air stripping and wanted to
know if chlorine would be required for ammonia removal.
EPA Response: Air stripping and chemical oxidation with
chlorine were two of the physical/chemical treatment options
presented in the Draft Feasibility Study Addendum. EPA
currently favors air stripping over chemical oxidation with
chlorine for removal of ammonia due to the potential threat
to aquatic biota associated with the use of chlorine. On
the basis of experience from other installations, ambient
ammonia concentrations would be orders of magnitude below
levels which could represent a health threat. Bench or
dbt077\064.51
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pilot testing will be conducted prior to the final selection
of a treatment alternative to assess risk to human health
caused by airborne release of ammonia.
2.
Counsel for the .Ci ty of North Miami indicated that the
City continues to maintain that the "No Action" alter-
native is the appropriate action to be taken.
EPA Response: The 1988 RIfFS demonstrated that the
release of hazardous substances did not present a
threat to public health or welfare. The threat that
this release represents to the environment, however,
was inconclusive. Based on the comments from Federal
agencies, environmental action groups and local resi-
dents who expressed concern that the site may present a
threat to the environment, EPA conducted a Water Qua-
lity and Toxic Assessment. This study was designed to
specifically evaluate the environmental threat that the
site may present to aquatic life in the Mangrove
Preserve.
This Preserve is part of the State of Florida Biscayne
Bay Aquatic Preserve which was established pursuant to
Chapter 18-18.001 of the Florida Administrative Code.
The results of the study demonstrated that leachate
migrating from the landfill into the Mangrove Preserve
presents a significant threat to aquatic life. The
study also concluded that, if measures were not taken
to abate the threat, the toxic leachate would severely
impair the ecological functions of the Preserve and
preclude development and maintenance of a balanced
ecological community of aquatic biota.
On this basis, EPA has determined that remedial action
is warranted pursuant to Section 104 of CERCLA as
amended by the Superfund Amendments and Reauthorization
Act of 1986. The "No Action" alternative was included
in the Draft Feasibility Study Addendum as mandated.
CERCLA requires that a "No Action" alternative be
evaluated at every site to establish a baseline for
comparison. Implementation of the "No Action" alter-
native in this situation, however, is not appropriate.
3.
Counsel for the City of Miami requested that the
hydraulic barrier developed by the Technical Advisory
Committee (TAC) should be included when considering
alternatives.
EFA Response: Both the positive hydraulic barrier
proposed by the TAC and the negative barrier in
Alternative 3 are considered to be conceptually
dbt077\064.51
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feasible. Both of these alternatives will be con-
sidered during the conceptual design phase of the
project.
Preferred Remedial Action Alternative
1.
A local resident and member of the Friends of Oleta River,
asked if and how often the treatment system will be
monitored to assess the efficiency of the system.
EPA Response: Semiannual testing, in the dry and wet
seasons, has been recommended by FDER. Analysis would
include metals and other potential contaminants. As
discussed in the ROD, quarterly testing during the
start of the remedial action will also be required.
Parameters evaluated will include ammonia, chlorides
and conductivity.
2.
Counsel for the City of North Miami questioned the
selection of recovery wells to intercept the leachate
plume.
EPA Response: The statement quoted from the Addendum;
"Recovery well systems are the most versatile and
flexible of the three groundwater recovery concepts
evaluated herein", is not an expression of bias. It is
a factual statement based on an evaluation of poten-
tially applicable groundwater recovery strategies.
Site hydrogeologic conditions make interceptor trenches
or ditches less suitable than wells for creating a hy-
draulic barrier and capturing contaminated groundwater
as envisioned in the preferred alternative. Trenches,
however, may be equally as suitable as wells for
creating the hydraulic barrier proposed in the TAC
alternative.
3 .
Counsel for the City of North Miami expressed a concern
with the impact of recovery well operation on saline
intrusion at the site.
EPA Response: The strategy of recovery well design,
with respect to well depth, is to complete the wells to
the shallowest depth possible consistent with effective
capture of leachate. The intent is to minimize the sa-
linity of the intercepted groundwater, but also be
consistent with maximum leachate capture. The reason
for this concern is that the salinity of the captured
leachate will have an impact on the costs of treatment
and ultimate disposal of the treated water. It is ac-
knowledged that the workability of Alternative 3 may
dbt077\064.51
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4 .
5.
ultimately depend on the ability to capture relatively
low salinity leachate at the Preserve boundary.
The Florida Department of Natural Resources objected to the
option of disposing treated leachate to the Southern Canal
citing Florida Statutes Chapter 258.397.
EPA Responses: The Proposed Plan did list the Southern
Canal as an option for discharging treated effluent. The
disposal options contained in the ROD contemplate discharge
to groundwater or surface water. The appropriate method of
discharge will be selected on the basis of data collected
from the hydrologic study. An additional criteria used in
the selection of discharge is that it comply with all
federal and state water quality standards.
A representative of the Friends of the Oleta River expressed
the following concerns:
.
The remedial action alternative selection was
determined by economic considerations and incomplete
information.
.
The discharge of treated effluent would be to the
Mangrove Preserve.
.
There are unknown compounds in the leachate that may
not be treated by aeration.
.
The cleanup would not begin soon.
EPA Response: The section evaluates the performance of the
alternatives against the nine criteria specified in the EPA
document Guidance for Conducting Remedial Investigations and
Feasibility Studies Under CERCLA, Interim Final, October
1988 (OSWER Directive 9355,3-01). These nine criteria are:
.
Overall Protection of Human Health and the Environment
Compliance with ARARs
Long-Term Effectiveness and Permanence
Reduction of Toxicity, Mobility, or Volume Through
Treatment
Short-Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
.
.
.
.
.
.
.
.
Economic considerations is one of the criteria, however,
other factors are evaluated during the decision-making
process.
dbt077\064.51
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The second part of the comment regarded the ultimate
discharge of the treated effluent. In the event that the
effluent is discharged to surface water (e.g., Mangrove
Preserve or Southern Canal), the quality of the effluent
will comply with all federal and state water quality
standards.
A water quality assessment will be performed as part of the
conceptual design of the treatment system, 50 that unknown
contaminants can be better defined. In addition, a treat-
ability test will be performed, so that the effectiveness of
the selected remedy can be more accurately assessed.
The issuance of the ROD will be followed by a negotiation
period with the PRP. This period will last at most
120 days. Following the negotiations, the hydrologic study
will be conducted followed by the initiation of the design
process of the treatment systems.
6.
A representative of the Highland Village Residents
Committee contended that data collection from the
Mangrove Preserve Study was conducted during drought
conditions and thus may have under-estimated plume
conditions. In addition, the commenter expressed a
desire that the leachate be tested with appropriate
methods.
EPA Response: EPA agrees that data collection was at a
time of drought conditions. For this reason, the
volume of leachate emerging in the Mangrove Preserve
was probably less compared to normal hydroperiods. At
the time of survey, ground water elevation at well 6
was approximately one foot less compared to previous
elevations reported in the site RI. An increase in
this elevation probably would have effected more mate-
rial in the landfill and resulted in a greater volume
of leachate emerging in the Mangrove Preserve. This
would likely result in an expanded areal extent of the
leachate plume. The quantity, concentration, and
possibly the composition of the leachate could vary
with drought and wet conditions.
7.
In response to the second part of the comment, a water
quality study will be performed prior to beginning concep-
tual design of the treatment system. This study will
involve collecting leachate samples and analyzing them with
standard, proven laboratory techniques.
A representative of the Highland Village Residents Committee
expressed a concern regarding the drilling methods that were
used at the site during the RI.
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i -
EPA Response: This comment refers to concerns that the
airlift drilling technique used may have biased subsequent
sampling results by stripping VOCs from groundwater in the
vicinity of the well. The sampling protocol for air-drilled
wells typically calls for sufficient purging to remove
aerated water before collecting samples. In the Biscayne
Aquifer at the site, waiting a few days before sampling will
serve the same purpose. The aerated water will be carried
away from the well by the natural groundwater flow.
8 .
A participant at the Public Meeting requested information on
considerations used in recommending recovery wells for
Alternative 3.
EPA Response: Within the scope of the EPA remedial
alternatives, the prevention of leachate surfacing
within the Mangrove Preserve is the primary objective
of the recovery system. Capture and treatment of
leachate, as an objective within itself, are other con-
sideration. The locations of the recovery wells were
selected to effectively create a hydraulic barrier to
leachate migration into the preserve, thus meeting the
primary objective. Efficiency of leachate capture,
including both quantity of contaminants removed and
cost of recovery treatment and disposal were considered
in the location and design of leachate recovery wells,
but these issues are subordinant to the primary objec-
tive. Well locations considered were along the land-
ward boundary of the Mangrove Preserve, and at the toe
of the landfill several hundred feet west of the pre-
serve boundary. Extending the line of barrier wells to
the south and north was also considered, as a means of
capturing leachate in these areas. The well config-
uration selected as best meeting the primary objective
of the alternative is a line of wells along the
preserve's western boundary.
9.
The initial well array and pumping rates were
established by estimation. An analytical model was
used to simulate aquifer water levels for a range of
well spacings and pumping rates. The well system
giving the best result is the basis of the conceptual
design presented in Alternative 3.
A participant at the Public Meeting expressed some confusion
regarding the permeability regarding the bottoms of the
lakes, and the impact of this permeability on the migration
of contaminants.
EPA Response: There is no impermeable layer in the
lakes. This comment may reflect a misunderstanding of
dbt077\064.51
3-34
-------
a statement in an earlier report to the effect that the
lakes were excavated through the less permeable middle
layer of the Biscayne Aquifer. The middle layer is
less permeable only in comparison with the extremely
permeable overlying and underlying layers. Otherwise
the middle layer can be characterized as permeable.
dbt077\064.51
3-35
-------
Section 4
Remedial Design/Remedial Action Concerns
This section addresses specifically public concerns raised during
the comment periods which have to do with remedial action.
Remedial Investigation and Remedial Action Alternatives
1.
A representative of the Munisport Dump Coalition and
the Friends of the Oleta River, expressed concern about
effects of air emissions associated with air stripping
and wanted to know if chlorine would be required for
ammonia removal.
EPA Response: Air stripping and chemical oxidation with
chlorine were two of the physical/chemical treatment options
presented in the Draft Feasibility Study Addendum. EPA
currently favors air stripping over chemical oxidation with
chlorine for removal of ammonia due to the potential threat
to aquatic biota associated with the use of chlorine. On
the basis of experience from other installations, ambient
ammonia concentrations would be orders of magnitude below.
levels which could represent a health threat. Bench or
pilot testing will be conducted prior to the final selection
of a treatment alternative to assess risk to human health
caused by airborne release of ammonia.
2 .
A local resident and member of the Friends of Oleta River,
asked if and how often the treatment system will be
monitored to assess the efficiency of the system.
EPA Response: Semiannual testing, in the dry and wet
seasons, has been recommended by FDER. Analysis would
include metals and other potential contaminants. As
discussed in the ROD, quarterly"testing during the
start of the remedial action will also be required.
Parameters would include ammonia, chlorides, and
conductivity.
dbt077\032.51
4-1
-------
Attachment A
Community Relations Activities for the
'Hunisport Property
Community relations activities conducted for the Munisport
property to date have included:
.
Notice of Availability for the RIfFS and July 1988
Proposed Plan published on July 24, 1988, in the Miami
Herald. .
.
Public comment period held from July 20 through
August 17, 1988, regarding the Proposed Plan.
Public meeting held at the Highland Village Community
Center on July 27, 1988.
.
.
Notice of Change to Proposed Plan published on
November 27, 1988, in the Miami Herald. .
.
Notice of Availability for the Water Quality and
Toxicity Study and 1990 Proposed Plan published on
March 16 and 25, 1990, in the Miami Herald, and on
March 21, 1990, in the New Times. .
.
Public comment period held from March 16 through
April 14, 1990, regarding the 1990 Proposed Plan.
.
Public meeting held at Florida International University
on March 29, 1990.
dbt077\033.51
-------
APPENDIX C
DISTRIBUTION OF CHEKICALS DETECTED.
. .
-------
Table c-t
Distribution of Chemicals Detected in Groundwater Samples
Collected from the Shallow A-Wells
Munisport Landfill Propert~'
(All Concentrations in f.1g/l)
Sheet 1 of 2
Frequency Number of
of Estimated Geometric
Detectiona Valuesto Mean Maximum Backgroundf
Inorganics
- AIuminumd 10/11 0 1.380 39,000 530
- Ammonia (total)d 919 3 13.500 180.000 60
- Ammonia (un-ionized)d,e 919 3 6] 99 57
Arsenic 3/11 c1.] 8 43 62
-Barium 7/1] 0 68 190 42
-Calciumd 11:"11 3 236.000 5.400.000 56.OOC'
-Cobalt 1:']] 0 NA 10 <20
.Chromium 311 "' :\A 170
-------
Table C-l
Distribution of Chemicals Detected in Groundwater Samples
Collected from the Shallow A-Wells
Munisport Landfill Property
(All Concentrations in ~g.'I)
Sheet 2 of 2
. Chemicals selected for further evaluation.
a Number of times detected/number of samples (total number may vary as a result of validation or
number of samples analyzed). Wells B.A. 14-A. and 15-A are not included.
b Concentration reponed v.;th a J qualifier. If two values are presented. their total represents the
number of estimated values.
C Presumptive evidence of chemical.
d Detected in city water. equipment rinse. or milli Q water.
e Un-ionized ammonia calculated as presented in Section 4.1.3 of the RI.
r Well MWllA
NA = Not applicable. Mean concentration is Jess than the detection limit.
NR = Not relevant. Use of one-half of the detection limit in calculating the mean results in a
mean concentration that is greater than the maximum.
= Not ana]vzed for.
Source: CDM. 1988
. ~ : .'.
dbt077\050.51
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Table C-2
Distribution or Chemicals Detected in Groundwater Samples
From the Band C Wells
Munisport Landfill Propert~.
(All Concentrations in J.1g!I)
. Frequency Number of
of Estimated Geometric
Chemical Detectiona Valuesl- Mean Maximum Backgroundf
Inorganics
. AJuminumd 9/15 0 487 18.000 840
. Ammonia (total)d 14/14 1 5.000 52.000 250
. Ammonia (un-ionized)d.e 14/14 1 27 225 6
. Antimony 6/15 6 NA 100 <120
. Arsenic 2/15 1 NA 89 <50
.Barium 13/15 0 NA 380 <80
.Calciumd 15/15 6 359.000 810.000 110.000
.Chromium 2,'15 1 NA 42 <40
~Copp(:rJ 2,15 0 !\A 1"7 <~O
. Irono 11/15 4 60 220.000 <400
*LeadJ 2:H '" NA ..- < 120
-"I I
*MagnesiumJ 15/15 0 563.000 1.400.000 7 1.000
* Manganese 13/15 0 39 280 <200
*Potassium 12.'15 6 162.000 370.000
.Sodium 15/15 1 4.463.000 11.000.000 940.000
.Strontium 3/3 0 4.995 17.000 1.800
.Vanadiumd 4/15 0 f\A 29 <40
.Zinc 13:'15 6 59 250 68
Organics
Acetone :;:15 c..., 10 1.700 1~0
-
~Benzyl bUTyl phthalate 1:15 0 !'\A 30 ~o
.delta-BHC 3/12 c1.1 NA 0.071 < 0.062
Bis(2-et hylhexyll-ph thala te 1/15 0 !':A 11 5.900
*Carbon disulfide 1~:'15 7.cl 5~ 290 13
*Chloroform 3;'] 5 3 f\A 4.8 <5
.Phenol U5 1 NA 8J <10
.Toluene V15 1 NA 21 1.9
. Chemicids selected for further evaluation.
a Numher of times detected/number of samples (total number may vary as a result of validation or
number of samples analyzed).
b Concentration reported with a J qualifier. If two values are presented. their total represents the
Dumber of estimated values.
C Presumptive evidence of chemical.
d Detected in city water. equipment rinse. or milli Q water.
e Un-ionized ammonia calculated as presented in Section 4.1.3 of the RI.
f Well 11B.
= Sample not analyzed for this chemical.
NA = Not applicable. Chemical detected in single sample and use of one-half of the detection
limit in calculating a mean results in a mean concentration that is less than the detection
limit.
Source: CDM. 1988
dht077\051.51
-------
Table C-3
Distribution of Chemicals Detected in Surface Water Samples
Collected From On-Site Lakes
Munisport Landnll Propert~.
(All concentrations in ~wliter)
Frequency No. of
of Estimated Geometric
ChemiC31 Detection3 Valuesb Mean Maximum Backgroundc
Inorganics
AJuminumd 218 0 126 410 840
. Ammonia (tOta\)d 718 1 1.300 19.000 250
. Ammonia (un-ionized)d.e 718 1 160 6.800 6
Calciumd 8:'8 1 60,000 87.000 110.000
. Copperd 2/8 0 16 50 <40
.Cyanided 1'8 0 NR O.O~ <~
"Iron': 518 0 125 1.300 <400
Ma,l!nesiumd 8.'8 0 17.500 78.000 i 1.000
. Manganese 2:8 1 9.3 30 <200
.. Potassium 13:13 (1 18.100 65.000
Sodiumd 13/13 0 167.000 570.000 940.000
.Vanadiumd ]l8 0 NR ]6 <40
.Zinc ];/ 0 NA 150 68
,~
Organics
Carbon disulfided 518 4 3.0 8.9 13
"Phenold 2:8 '" NR 2.8 <10
- "
ChemiC3b selected for further evaluation.
a Number of time~ detected/number of samples (total number of samples may vary as a result of
validation or number of samples analyzed).
t> Concentrations reponed v.ith a J qualifier. .
C Data from MW-llB used as background; detection limits are presented if a chemiC31 was not
detected.
" Detected in city water. equipment rinse. and/or milli Q water.
e Un-ionized ammonia C3lculated as presented in Section 4.1.3 of the RI.
= Sample nOt analyzed for this chemiC3l.
1\A = 1\Ot appliC3ble. ChemiC3l detected in single sample. and use of one-half of the detection
limit in calculating the mean results in a mean concentration that is less than the detection
limit.
NR = Not relevant. Use of one-half of the detection limit results in a mean concentration that
exceeds the maximum.
Source: CDM. 1988
dbt077\052.51
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Table C-4
Distribution of Chemicals Detected in Surface Water Samples
From Areas South and East of the
Munisport Landfill Prope~'
(All concentrations in ~g/liter)
Frequency No. of
of Estimated Geometric Background
Detection3 Valuest- Mean Maximum Range'
lnorganics
. AJuminumd 9/15 0 NA 11.800 150-230
. Ammonia (total)d 13/15 7 1.100 11.000 10-70
Ammonia (un-ionized)dJ 13/15 7 40 3.900 2
.Barium 3/15 0 NR 24 <40
Calciumd 15/15 0 188.000 372.000 370.000-380.000
.Copperd 1] '15 0 NA 56 < 17
* lrono 10/15 0 120 3.100 150-720
*Leadd 5.'7 2 15.4 63 <20
Magnesiumd 15/15 0 283.000 1.120.000 1.2oo.000e
*Manl!anese 6.:15 3 NA 42 <6
*Nick~ld 1/15 1 NA 22 <6
Potassiumd 15/15 0 78.000 400,000 350.000-490.000
* Silver 2/15 0 NA 70 <7-< 10
SOdiumd 15/15 0 2.270.000 9.690.000 9.700.000-10.000.000
Vanadiumd 9;15 0 NA 54 66-110
"Zinc 5;15 0 NA 210 <7
Organics
1/15 1 NA 9.8 <10
. Acetone 13/15 3 42 861 23
"Carbon disulfided 1:'15 1 NR ...... 3.4
Phenold
" Chemicals selected for funher evaluation.
3 Number of times detected/number of samples (total number of samples may vary as a result of
validation or number of samples analyzed).
tI Concentrations reponed with a J qualifier.
C One value is presented when chemical was only detected in one of t\\'o samples. If a chemical was
not detected, the detection limits are presented.
d Detected in city water. equipment rinse. and/or milli Q water.
e Both background samples had the same concentration.
( Un-ionized ammonia calculated as presented in Section 4.1.3 in the RI.
NA = Not applicable. Only detected in one sample. and use of one-half of the detection limit in
calculating the mean results in a mean concentration that is less than the detection limit.
NR = Not relevant. Use of one-half of the detection limit results in a mean concentration that
exceeds the maximum.
Source: CDM. 1988
dbt077,053.51
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Table C-5
Distribution of Chemicals Detected in Sunace Water Samples
From the OJeta River and Tributaries
Munisport Landfill Propert~'
, '(AU concentrations in ~glliter)
Frequency No. of
of Estimated Geometric Background
Chemical Detection3 Values I> Mean Maximum RangeC
In organics
3/5 0 169 410 150-230
Aluminumd 4/5 2 80 500 10- 70
"Ammonia (IOtal)d 4/5 2 7.3 180 2
"Ammonia (un- 3/5 0 NR 57 <40
ionized)dJ 5,'5 0 334.000 380.000 '370.000-380.000
"Barium 1'5 0 NA 9.3 <9
Calciumd 2'5 0 25 28 <17
.Chromium 5,5 0 229 540 150- no
"coPferd ] '5 0 NA 22 <20
Iron 5,5 0 936.000 1.200.000 1.200.000e
. Leadd ] '5 0 !'A 24 <6
Magnesiumd 5'5 0 267.000 360.000 350.000-490.000
"Manganese 5/5 0 7.500.000 9.600.000 9.700.000-10.000.000 '
Potassium 4/5 0 38 66 66-11 0
Sodiumd 1/5 0 NA 46 <7
Vanadiumd
"Zinc
Organics .. '
3:5 10 3~ 23
Cartlon disulfide
3 Number of times detected/number of samples (total number of samples may \'al1' as a result of
validation or number of samples analyzed ),
t- Concentrations reponed \\ith a J qualifier.
C One value is presented when chemical was only detected in one of two samples.
d Detected in city water. equipment rinse. andlor milli Q water.
e Both background samples had the same concentration.
r Un-ionized ammonia calculated as presented in Section 4.1.3 of the RI.
!\A = Not applicable. Only detected in one sample. and use of one-half of the detection limit in
calculating the mean results in a mean concentration that is less than the detection limit.
NR = Not relevant. Use of one-half of the detection limit results in a mean concentration that exceeds
the maximum.
Source: CDM. 1988
dbt077\054.51
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Table C-6
Distribution of Chemicals Detected in Sediment Samples
Collected from Areas South and East of the
Munisport Landfill Propert~.
(Concentrations in mglkg. except as noted)
Frequency Number of
of Estimated Geometric
Chemical Detectiona Values" Mean Maximum Background
Inorganics
. Aluminum 10/10 0 864 1.900 320
. Ammonia (total) 9/10 9 131 620 9
. Arsenic 4/10 2 1.9 19 <1.8
.Cadmium 1/10 0 NA 5 < 1.2
.Calcium 10/10 0 81.300 290,000 49,000
.Chromium 10/10 0 14 ..,.., <2.7
~~
.Cobalt 2/10 0 3.2 23 <2.1
.Copper 2/10 0 3.3 220 <10
. Iron 10,10 0 7,500 ] 7.200 2,200
. Lead 2/8 0 1.1 110 <10
.Magnesium 10/10 0 5,240 12.000 1.100
.Manganese 9/]0 0 20.6 9~ 5.4
. Mercury 1/10 cl NA 4.1 <0.2
.Nickel 1/10 0 NA 37 < 1.8
.Potassium 6/10 0 481 2.400 <150
.Silver J.l1O 1 NA 18 <2.1
.Sodium 7/10 0 5.780 60.000 5,400
Thallium 1/10 0 NA 7 <2.4
.Vanadium 8/10 0 9.6 22 <3.6
. Zinc 2:'1 0 0 3.8 1,600 <20
Organics
. Benzoic Acid 3:10 3 NR d610 d < 2.400
.4-Methylphenol 2/10 2 d165 d360 d<490
. Pentachlorophenol 1/10 1 NR d400 d < 2.400
.Phenol .2/10 2 d173 d260 d<490
. Chemicals selected for further evaluation.
a N\tmber of times detected/number of samples (total number may vary as a result of validation or
number of samples analyzed).
b Concentration reponed \\;th a J qualifier.
C Presumptive evidence of chemical.
d ~g/kg
NA =
Not applicable. Only detected in one sample. and use of one-half of the detection limit in
calculating the mean results in a mean concentration that is less than the detection limit.
Not relevant. Use of one-half of the detection limit in calculating the mean results in a
mean concentration that exceeds the maximum.
NR =
Source: CDM. 1988
dbt077\055.51
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Table C-'
Distribution of Chemicals Detected in Sediment Samples
Collected from the Oleta River and Tributaries
Munisport Landfill Prope~'
(Concentrations in mglkg Except as Noted)
Frequency No. of
of Estimated Geometric
ChemiC31 Detection3 Valuesb Mean Maximum Background
Inorganics
"Aluminum 5/5 0 388 700 320
"Ammonia (toial) 5/5 2 45 350 9
. Arsenic 1/5 0 1.1 29 <1.8
"Cadmium 1,'5 0 NA 4.1 <1.2
Calcium 5.15 0 36.100 97.000 49.000
.Chromium 3'5 0 .,., 7.1 <2,"7
....-
"lron 5;5 0 2.500 17.000 00
"Magnesium 5,'5 0 2,410 13.00c' 1.100
. Manganese 5.15 0 6.3 23 5.4
"Potassium 2.:5 0 322 1.000 < 150
.Sodium 5,5 0 12.600 74.000 5,400
.Vanadium 1:'5 0 NA 7 <3.6
"Zinc 1.'5 0 2.~ 47 <20
Organics
"Benzene 1/5 NR ~.4 c<7.2
"Carbon disulfide 1/5 NA c3.3 ND ,-
.Chloroform 2/5 " c4.2 c18 c5.4
-
3.3-Dichlorobenzidine 1'5 1 !\A ~10 c<980
*Phenol ],'5 1 NA c380 '<490
"p)Tene (NCPAH) 1.'5 0 NR '98 '350
. Chemicals selected for further evaluation.
3 Number of times detected/number of samples (total number may vary as a resuh of validation or
number of samples analyzed). .
b Concentrations reponed \\ith a J qualifier.
c ~g/kg.
r\A = Not applicable. Only detected in one sample. and use of one-half of the detection limit in
calculating the mean results in a mean concentration that is less than the detection limit.
ND = Not detected or not detected at concentrations above background.
NR = Not relevant. Use of one-half of the detection limit gives a mean concentration that exceeds the
maximum.
Source: CDM. 1988
dbt071,056.51
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Table C-8
Distribution of Chemicals Detected in Soil Samples
Collected from the Cover of the
, Munisport Landfill Prope~'
and Background Concentrations
Frequency No. of
of Estimated Geometric Background
Chemical Detectiona Valuesb Mean Maximum Range'
Metals (All concentrations in mg/kg)
* Aluminum 8/8 0 971 2.500 360-880
* Arsenic 118 0 NA 31 <5.2-<9.9
Barium 4/8 0 13 22 37
Calcium 8/8 0 71.000 130.000 80.000-320.000
.Chromium 2/8 1 1.13 24 <3.7-<6.9
Copp~r 3,'8 0 2.8 13 23
Iron 8/8 7 1.440 3.600 110-4.100
Lead 7J7 7 19.8 76 110-180
Magnesium 7/8 0 510 1.200 420-900
Manganese 6/8 0 6.9 22 13-160
*Mereul" 118 el NA 0.09 <0.05-<0.1
Sodium 118 0 NA 450 140- 230
Zinc 7/8 7 18 72 30-51
Organics (All concentrations in ~g/kg)
Carcinogenic P AHs:
Bcnzo (a) anthracene 2/8 0 215 520 <370-<700
Benzo (b) fluoranthened 1/8 1 NA 490 210
Benzo (a) pyrene 1/8 0 NA 440 <370-<700
Chrysene 2/8 I 211 510 < 370- 70U
.TOtal carcinogenic P AHs 817 1.760 705
Noncarcinogenic P AHs:
Fluoranthene
P)Tene 2/8 " 263 1,300 200
~
Phenanthene 2/8 0 233 700 170
.Total noncarcinogenic P AHs 1/8 1 NA 300 <370-<700
700 2,165 535
dbt077,057.51
-------
ontinued)
Table C-g
Distribution of Chemicals Detected in Soil Samples
Collected from the Cover of the
Munisport Landfill Property
and Background Concentrations
Chemical
Frequency No. of
of Estimated Geometric
Detectiona Valuesb Mean Maximum
1/8 0 20 300.000
1/8 1 NA 310
1/8 e] NA 3.200
Background
RangeC
. Acetone
.Benzyl butyl phthalate
-Bis(2-ethylhexyl) phthalate
'Chloroiorm
Methyl ethyl ketone
Methyl isobutyl ketOne
-PCB (Aroclor 1254)
. Pentachlorophenol
-Toluene
< 12-<23
<370-<700
<370-<700
118 1 NA 3
1/8 1 NA 7,100
118 1 NA 390
1/8 1 NR 77
2/8 0 1.811 21.000
118 0 NA 190
< 12-<:!3
< ]2-<23
<]2-<23
<320-<340
4.099
< 12-<23
- Chemical5 selected for further evaluation. .
a Number of times detected/number of samples (tOtal number of samples may vary as a result of validation or
number of samples analyzed).
t> Concentrations reported v.ith a J qualifier.
C One value is presented when chemical was only detected in one of two samples. If a chemical was not
detected in the hackground samples. the detection limits are presented.
d Indistinguishable from benzo(k)fluoranthcne due to analytil.:al technique limitations.
e Presumptive evidence of chemical.
!\A = Not applicable. Mean concentration is less than the detection limit.
NR = Not relevant. Lise of one-half of the detection limit results in calculating the mean results in a mean
concentration that is greater than the maximum.
Source: CD~1. 1988
1 .,
_Jt077\05i.5]
-------
Table C-9
Distribution of Chemicals Detected in Soil Samples
Collected from the Unfilled Areas of the
Munisport Landfill Prope~'
And Background Concentrations
Frequency No. of
of Estimated Geometric Background
Detection8 Valuesb Mean Maximum RangeC
Metals (All concentrations in mg/kg)
. Aluminum 9/9 0 620 1,900 360-880
Barium 4.'9 0 13 38 37
Calcium 9,'9 0 56.000 320,000 80,000-320.000
- Chromium 2:9 1 0.9 7.4 <3.7-<6.9
Copper 1.'9 0 NA 17 23
Iron 99 9 1.500 4.100 1.100-4.100
Lead 6/9 6 4 42 110-180
- Magnesium 7;9 0 620 3.600 420-900
Manganese 7,'9 0 7.7 69 13-160
. MercuT)' lt9 dl NA 0.15 <0.05-<0.1
. PotaSsium 1/9 0 NA 750 < 180-<350
.Sodium 5,'9 0 340 2.900 140- 230
Zinc 5.'9 5 6.7 97 30.51
Organic Chemicals (All concentrations in ~g/kg)
Chlorobenzene 119 ] NA 10 < ]2-<23
-Beta BHC 1:9 0 !\A 53 <16-<17
Dieldrin 1.'9 0 1'A ~ <32-<34
4,4'-DDE 1.'9 0 !\A 110 ]9
4.4'-DDD ].'9 0 NA 61 <32-<34
. Chemicals selected for further evaluation.
a Number of times detected/number of samples (total number of samples may vary as a result of
validation or number of samples analyzed).
b Concentrations reported with a J qualifier.
C One value is presented when chemical was only detected in one of tWo samples. If a chemical was not
detected in the background samples, the detection limits are presented.
d Presumptive evidence of a chemical.
NA = Not applicable. Mean concentration is less than the detection limit.
Source: CDM, 1988
dbt077\059.5 ]
-------
Table C-IO
Distribution of Chemicals Detected in Soil Samples
Collected from the Northeast Area of the
Munisport Landfill Propert~.
Frequency No. of
of Estimated Geometric Background
Detectiona Values1> Mean Maximum Range'
Inorganics (AJI concentrations in mg/kg)
Aluminum 616 0 120 1,500 360-880
> Ammonia 3/6 3 12.3 13 <60-< 110
- Arsenic 3/6 0 2.4 21 <5.2-<9.9
Barium 5/6 0 20 28 37
Calcium 6/6 0 124.000 370.000 80.000-320.000
>Chromium 3:'6 0 1.3 4.8 <3.7-<6.9
Copper 1/6 0 3 41 23
'Cyanid~ 1.4 I !\A 1.: <5.2-<9.9
-Iron 6/6 3 2.760 12. ()()(I 1.1 00-4.100
Lead .U :! 6.7 87 110-180
"Magnesium 6:'6 0 1.450 7.100 420-900
Manganese 5:'6 0 18 79 13-160
>Mercury 2/6 2 0.33 0.7 <0.05-<0.1
- Potassium 1/6 0 NR 240 < 180-<350
"Sodium 5.'6 0 570 1.200 140-230
>Tin 2'6 0 3.7 14 < 15-<29
Zinc 4/6 3 11.4 88 30-51
Organic Chemicals (AJI concentrations in ~g/kg)
"4-Methylphenol 2/6 2 171 280 <370-<700
.PCB (Arodor 1254) 2'6 134 520 <320-<3~O
. Chemicals selected for funher evaluation.
a !\umber of times detected/number of samples (total number of samples may vary as a result of
validation or number of samples analyzed).
1> Concentrations reponed with a J qualifier.
, One value is presented when chemical was only detected in one of two samples. If a chemical was not
detected in the background samples. the detection limits are presented.
NA = Not applicable. Mean concentration is less than the detection limit.
NR = Not relevant. Use of one-half of the detection limit in calculating the mean results in a mean
concentration that is greater than the maximum.
Source: CDM. 1988
dbt077\058.51
-------
APPENDIX D
MUNISPORT LANDFILL
TECHNICAL ADVISORY COMMITTEE REPORT
DRAFT, MARCH 1990
..
-------
~~ISPORT ~~rILL
T£C~:ChL ADVISORY CO~ITTEE REPOR~
Jo'.1.F.CE: 1990
. .
... .. .a. .-
4' . - .... _.
-------
!?::-R~:>:JC'T! 01':
,:':-.~ 7€=~.;-oicc.: J.cvisC':-y Cor.'::o:'.-;tee (ThC) \..as c:-ee~ec e~ ~~e seco;-,::
~€e~~~~ c: c:l pa~tie5 involved in the ~uni5port Lanc~ill i5s~e
~~ic~ ~~s hE:~ ~~ !:c=i~a :~~e~~a~lonal U~~ve~si~y in };C~~~ t~~a~i
s~ ~ ::-.
C:-. J..:;;-...:~~ :~,
lSE~.
Since ~he e~~encen~s a~ the ~ee~inc co~lc not reach an ac:-ee~en~
. .
en e~\' ~e:-ta:'.~i~= i5SU€, end a~te~ both e~~orneys fo~ the Ci~v c:
?;c:-th" ~:::"e~.::" e~::' ~:-je I;:-si:-o;.:!\e:r,~el coalition lee bv The :rlc~icc
h~cobon Socie~v ob~ectec to invclve e p:-ofessional f~cilitatc:- ~o:-
~l~£=r.e~ive C~5?~;e resol~~ic~, ~11 p~~icip~nts a;~eed to e
sug~e5tion by ';o~n Ruddell of D.t.R. to fonn the ThC. The p~_~ose
of ~~e :.h.C. ~as to achieve an en\'i:-o~~en~ally and econo:ically
so~;::: clos'.::-e.
'::r~e ';;..: ~:.~s~ 1:€.":. 0:"1 };o'\'e::-..:,e= 20, lSS~ ct. .);o:-th ~~i2.':7.i c:.-:\. Ea.:l.
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coneep~~c.l Flan fo:- elos\::-e o~ the ~unispo:-'t. Lenc;.:i~l 0-::') "'-hie;-.
...i:~ ::~ C:;:--.Si5':(';-:~ ",":.~:: bot~ the :-eq-..:.:.rements of ,",SEFA gi.::'.:::eli:')~~
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5~e~e ~;e~=~es'~e~ fo~: (') ti~es anc co~cl~de~ it's wo:k vi~h ~his
=Ep:~~'.
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i~;:e~~~~ ~~E ~:~c2 clcs~~e e~~ ~£we~:a~ic~.
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c=~~~=~~~ ~y cO~~~:~~~~5 a~= a;e~=les such ~s the Re~.e~~~:
:~ve~~::'qa~ic~ ~e?=:-~, ~~e ~a~£:- Q~ali~y & Tcxic Assess=e~~ S~~~y
r ",,'--"'-o"e -:::--ec:e-'''' (","""".'C::"-') "'...-= -o"'e S~.e -r"""ves-l''''--l'O- -"'-.........--
g ..c..4~ - 'to .. - - -" -. 'JC ...I-._...~ ~~ ~'- '--'... ..... _4~ '- -=c:..... .. l\.~:-'''''- '-.
J.. ::-ece:--.': s~-..:::y by !:.:F.;'.. ",":-.ic;-j ",'as conc-..:=~e~ i:rj t.he s-..:r.=.e: e: l~£S
(W~?AS~?), c:.re=~e:: ~he ec,:io~s take~ by the re6e~al age~=y ~n:::e~
t~e S~pe:-~~n:: ~=~ ~c~a:-c5 p:-ote=ting the ~angrove prese~'e area
,~= re~edia~ion c: a~verse e~:ec~s on ~he :ang:-oves :ro: lea=ta~e
~en£:-ate::: a~ the ~~.
'!::e '!'J-C ~lso con:::i.J=te~ a s:.a1l scale s~\Jc'\.' on 'trece 1n£-:els ;l:--.
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..vI). " P::-.. .!iarolc wenless,. ~ 1nember... of: -the.-.-iAC concucted. 2,-
p::-eli~ine~y ir.vestiga~ion of 'the topography o~ the s~~~icial
li~e5~cne ke~s~ forr,a~ion in the ~an;rove prese~e area. The ~hC
cc~=-..:c~£::: a 5:.~e to\:: en ~~n~a:-)' 2~, l~SO.
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-------
Y.Ut\ISPORT
TAC
CLOSURE RECOMMENDATION
PR!~~¥.It\hRY D~.FT
CONCEPTUAL PLk1'
The ~h: reco~~ends conceptual plan for containmen~ and treatme~~
of the leacha~e from the Munisport Landfill (MLf) to protect the
hur:.a~1 hea:: th and erwironments in accordance ....i th FD!R 17-701,
F. A. C. to include the Mangrove Preserve and remediation of the
fo~lo~ing elements:
n;fILTAATION SYSTEM BARP.IER
Cc~~a~r~E~~ c~ t~c preser.~ leachate migration from the l~ndfill to
a~~acE~t &rea~ tv creatina hydrolo=ical barriers. The barriers
\.': ~ 1 CO~5::'5~ C f a" p~si ti ve . in! il tration syste~s ",'hich ",'ill inol uc.e
e~~her a ~it~h, channel, infiltra~ic~ galleries cr 5~a::c~
i~jec~ic~ ~€2l~. ~he infiltration system will receive clean ~ater
frc::. clean la}:e.$ c= fro::. treat~ent syste::.s. P= io=' to ir:.?ler1e~,tinc; .
t~c inf:ltra~ion sr5te~s, a hydrogeological stu~y should answe= the
follo~ing questions:
a.
k:.
The vertical extent of leachate conta~ination, the rang~
c~ s'..:.bstrate types and the charac~eris~ios of thEse:
s-..:= ~t=a tes i~ te~s of hvdraulic conducti vi tv, tic.a~>'
flushi~.g studies to establish the regional ~nflux of-
fresh and salt waters, aquifer pumping tests, a!):l .other
ir.fcrr..ation as necessary to develop a practical'.'
~v~=clo=~cal desi~n usina ~o:lels from ~hich the ra~e of ','
lE~=ha~e pu~?ing and nature of the infiltration syste~ .
~::; t.e:-r.s of location areal extent, depth ar.d hy~raulic
gra~i~r.7t can be developed and incorporat.ed into
£'..::::ci€:;.t profes~ional confidence that the intent of the
project as stated is satisfied.
!nstall fully screened wells and profile the ~ater ~ith
tical changes and fresh/salt water interface over
seasonal changes.
c.
Analysis of aquifer response to pumping. Two short-te~
aquifer tests for per.Qeability characteristics.
Baseline Jnonitorinq of the water quality of the mangroves
to establish existing conditions.
d.
e.
Quantity of ~ater needed for barrier systeru.
f.
G~ound pene~rating radar to locate hot spots for ~ell
locations and landfill water quality profiles to verify
lo~est sp~t eleva~io~s.
-------
9.
If economics permits, additional leachate to affect speed
of cleanup of the site and prevent migration of leachate
northward.
!f a pur.iping syster. is determined to be as effective in all
respects ,s in~iltration, then it shall be considered and the costs
~ill becor.e a factor. Some of the pumping wells shall be placec
in the hot spots close to the southern portion of the lancfill to
prevent migration of leachate to the south and depending up~n the
hydrogeolog~y of site and leachate system.
LEACHATE '1'REATMEl\~
Leachate treatment will be provided for two purposes. The first
is to au~ent the cle,n water utilized to form the hydrological
barrier. The othE:- is to speed up the natural biological processes
anc flu£hing actic~ and allo~ a faster end-use of the solid waste
~our.5 are, and the rest of the site. Several treat~ent ~e~hocs
~ill be e.)~lo:-ed en= evaluated by literature research and/o:- via
bench or pilot tes't.s. 'I'reatment methocs to incluc.e: b~..;. net };.,~
lir.ite:: to:
.
.L.
2.
:3 .
!~-la}:e 2Er~~ion
.....cletile o:-ger.ic
C~ in ae:-ation lagoons to reduce a~onia and
cor.pounds (VOC).
In-l,ke biological treatment provides for aerobic-anaerobic
,lte.rnate con~itions to promote nitrification-denitrification
processes. ~he aerobic stage can be created by diffusers and:
the ,nacro~ic stage either by providing an aquatic vegetation
cove.~ 0:- by diverting the water to a created altered ~etland.
The aquatic ~eed can be considered as part of the treatroent,
e.spe::i~llJ' if ha:-vested. The health of the aquatic vegetation
can be used as measure to the residual toxicity in the water. .
since va:-ious acr.:.atic plants are sensitive to specific r;etals
(ie: ",.ater hyacint.hs cannot 9ro",' in a 1 UI:linuw rich
env iron=.ent.) .
Altered wetland, at this time, cannot be used for treatment
as it i9- prohib~ ted by the Clean Water Act. . The poss ibil i ty
of using them fo:- final dispersal of treated water speu.ld to
. be explored.
-
( .
Air strippin? is effective in revolving VOC's and ammonia to
effec~iv~ly r~1rI0'Ye ~h~..a~on_i~.~~ ~!i;~ ..raised- ~9_9.~rtVert_.the ..
ar~on~a ~on to free ammonia 9as. .'
5.
Trickling filters are very effective in removing a~onia if
no significant ar..ount.s of toxic cOJr,pounds area present. They
are less of'fensive in their appearance that air stripping
to~e=s. It is very likely that parallel or different systers
~ill be nee~~d for fresh ~ater and s,line water. ~dditicnal
analyses and treatability tests ~ill have to be performe~.
Since t~e=e ,re l,kes on the site that already contain'significant
.:.:-i:...= :~:-:_' -:::. '":: .-;'~:
-------
a~o~nts of clean ~ater, if feasible the first phase of creating
~he hycrologic barrier ~il1 not have to be delayed till all the
tests associated ",'i th the treatment system are done end the
t:eatment i~ple~ented. The treatment target will aim at levels of
.ater q~ality prior to the declaration of the Biscayne Bay as an
O~tsta~~in; rlorida ~ater and in accordance .ith the States ~les
~i~h apr~icatle end use of the receiving water body.
The La}:es
reur cf t~e la}:es are shallo...' and at the present ti1i,e do net
e~~ibit elevated levels of a~onia. There are the North~est, ~est
Ce::1tra 1, So'.:th",-est and South central lakes. Th~se la}:es ca:1
provide clean fresh water for hydrological barrier. The ",'ater
q-.:ali ty at tr,ese lakes ",'ill have to be constantly JDonitored during
tr.e operation of tt.e syster.s since the withdrawal of large quantity
cf \.-c~€r r:.z.y cause: lec.:::r.ate r.iqration into the lake. If leachate
~i;:atic~ ~i:: c:::=~:r, anyone of the four shallow lakes can be
~~~l~:e~ f~~ tre~~~€~~ as ees:::ribed above.
:~ tt.e~c is a nee: to pu=p ~ater to the hydrological barrier or
F~~~s c: i..:, tr;c. OH'i-' lakes can be utilize:l. It is ve:-y li}:ely
~~tt ..::~ t~is C~5e, t~eatr.ent ~ill be needec. Prior to utilizatio~
c~ the deep lakes, it is i~portant to have the botto~ seci~e:1t
c.~c.ly:€~ ~:::~ pres€::1:::e 0: toxic contar.inants. The res~lts c~ tt~se
~nc!ysE~ ~il! havr bE~ri~; on the utilizatio:1 of the water fro~
t:.€se lcJ:es c~ c;. stet's tr.c.t ~ill have to be ta}:en prier to ~ill:.r.g "
-. - -' or -'~ - co: - - ,. ... ~ r .. '\- . .: 11 "\ 1 f ... ,..
~..: c.- ~.,\;.-t;.. .ial.~- -- ~..e p.ia:1 '\01. ca- 0- .~.
Y.;J;GRO\:: PROTECTION
T~~ ~a~;roves ~:.ll be rretected fro~ the adverse effects of the
le!:::~c.te ty ~eans c~ th~ hydrolo~ical barrier. At so=e p=i~t i:1:
tirE, ~~e~ t~Ere i~ ~c longer a potential for any leachc.te to reach
t~e r.a:-,~ro\'e prese:-vc through surface overflo",', any part e~ the
dike s~~:l be rer:ve~ ~tict is not essential for the treat~ent
5 J" s t C:-..
'1':-.e C::::-.::1ectior.s o~ tidal waters to the mangrove area
, .- .enlarged to s~fficiently enhance the flushing action.
\,;ill be
MONITORING
- -. .-
-. .h- ~oni t~r~ng.. s<;:he~e shall be implemented to analyze the quality of
the ...-ater reaching the mangrove preserve and to measure the success
cf the project. It will include indicator parameters and will be
aesic;ned to proviae pertinent data on trends associated ...-i th
1 ec.c:-.a tc. q-~~l i ty ir.provement and seasonal effects and the
follo~in~: .
c. .
b.
tC' loo}: fer trends and changes of perforr.an:::e
protect h~.an health and the environment
to loo}: for a6equacy cf treatment
e;.~ p=i~t c: project
c.
c:..
. .. .... .
. -'
-------
\o\kTER QUkLITY S~PLING STATI01,S
Sa~rling stations shall be established and ~ith all other areas
pc:tentially affected by the landfill. These stations shall include
sa~plin; cf ~he follo~in;:
a.
b.
c.
c.
leachate prior to treatment
effluent of post treatment
water quality in the mangrove preserve and ground water
for t~o (2) years after the interceptor ~ells or barriers
are discontinued or until statistical analyses indicate
othe~'ise .
water quality prior to each phase of treatment in ~hich
paraI:\eters maJ' be added or deleted during evaluati~n
process .
leacha~e shall be sampled semi-annually (wet and dry
season) fer the first two (2) years for pre anc pos~
tre ~ ~r.c., '\'5. a a cot:posi te sat:\pling of each and also
within 2 weeks after the start up of the treat~en~ sJs~e~
-f.or priority pollutants. If a problem is observed from
the a~.alysis, the list of testing para~eters ",'ill be
r,,\'i~e=. base:' \:;:0:-. the res~lts for pre end post treatt:er.t
te~tir.;:, alon~ \,,'ith the by-products of the contar..inant per
ye~r c ~ the post treated effluent. Freq-I.lency of .all
te~~ing t:ay be revised after 2 years. .
Eioassays sh~ll be conducted four times per year of t~e.
pest treate:l effluent. Frequency of all testing r.~J be .',
revised after 2 years.
e.
~
. .
s: .
h~~iticnal ar.~lyses for pre ~nd post
~s fcllc'.:s:
treated ~ater are
".
---,...-. -
c...-..-..... Co.
caily for 2 ""ee}~s
...
" .
p~
specific concuctivity
disscl ved c>:ygen
cher.ical o>~gen demand
ter.perature
~ .
" .
5.
{,.
Gro~nd ~ater ~cnitoring up to FDBR ground water sectio~
a.
Y~GROVE WATER QUALITY
identi!J' 1 or 2 sampling stations~ fo:: i~~9"t~~.'~a;'pi-i~g.
and other alternative procedures should be explored.
UJ\DFIL!.. Ck?
The CO:1se~s-,;S cf the s\:bcor.-.r..i ttee on "CkP" was that an i1npermeable
to? cap over the entire refuse r.ound is no~ cesireable. It ~ould
i...?e:::e the II influshing action" ",'hich helps the biological
ce~ra~atic~ c~ ~h~ re:use r.aterial.
-------
This site shell be closed pursuant to FAC 17-701. Protected trees
tha~ ~ere e5t~=lished in those locations will be transfe~red and
~~:lize~ in a berm ~hich ~ill protect the Mobil Ho~e park on the
s~~theas~ side of the landfill. The berm shall be designed and
~laced to preven~ stcrm~ate~ runoff from the site to the inh~bited
~~e~s to thE so~~h.
It ~ill be advantaaeous to cover areas around the clean lakes, or
to berm the~ so that runoff from exposed areas doesn't ~ix with the
clean wate~ rende~ing it leachate by SFWY.D definition.
rIG~RI:S
~~ APPE~~ICES WILL BE DISTRIBUTED AT TEE Y~tTING
. .~. .
.. - -. .-
-- -.." - ..."" -.: .-.
. ... .. - -
. . - ..... - -.,.
..... .' -
- - .
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. C: It
Dr: l' ';f\':~~E!:7 C' F [1:\.! ROt\~r:}~; ~L i;E Gt.~ 1...,; ';: C 1~
Sc'..:-:.r,E:as-:. Dis-:.:rict Lab::-:rato~y
2~'~ ~orningsi~e Drive
F:. s~. L~cie FL 3~9~2
I
I
Ii
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1 ..... r. - .,'r.
rrcjec-::
!-~J,:;R:)\"E l..E~VtS
Req'oJested By:
PADYA
site Date Time Depth Log Sa~plers
CO~,ER A *3 ~001C5 1200 3652 Y.EEDtS
NOTt: !r.Jl,:SP:)RT l..F CORNER A - REPLICA'!'E 3
I
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LE:a~, ~i5SC:VE:~ ~;/:
Y.anganese iT". se:::i~n-: ro.;,;:':;'
!:~ckEl in se~i~.c~~ ~g!~:;
Zin: in se~i:E:~-:' ~;/~;
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Co~c Site ID
CO?SER
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1C2S -: or,
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104 ~ ~. 1
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105£ ,::,
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SC~~~E2St ~ist~ict Labc~atc~y
2:~5 ~~~ning5ice D~ive
F~. $~. L~cie TL 3~9~2
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I.
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Project:
1"JJ;GROVE LEAVES
Requested By:
Log Sarnple:-s
36~S Y.!:ED!S
- R!F:"!ChT:E 2
36-<9 M£ED!S
- RI:PLIC~'!'E ::3
3E50 Y.EE:D!S
- RI:F:':: CJ..'!~ 1
3€:1 Y.E~~~~
- ::~:::-::: CJ.::£ ~
Phv\'A
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SitE Date Time Dep~h
CE~=ER B *2 SOOl05 1200
)~O:rE: }-:"Jt'!SPOR'!' LF CENTER B
CENTER B ~3 90C1C5 l200
1\O':~: Y."JI;:rSPORT LF CEt~TER B
CC:;:U;~R ]... n. 900;' C:, 1200
):o:~: 1'~...');:S:=:'::.:- LT CON;~i\ h
C~~:~~. ~;2 SCC:~! :200
Si~e !D
Si~e :D
Site :!~
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I~~ the resus~e~£1cn of botton 6e~i~ent in adjacent aT~a.s l~£lte
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c. Leterui~e tc~ tre6c~1nt versUS re~owint the
enhance recovery cf tbe alterc~ wetlands.
. Sincerely yours,
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Harold F.. ~a~le.s.s
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~:. HO~2r6 Elein
D:. S~~ S~e~~ker
Dr. Leo S~2yze
1-: r. E r ~:: \-: ~ 11 e r
c/o Hydrologic Assoc., USA, Inc.
~~~iE~o:t D~~? Co~litio~
l'?C? Sc. Di~ie H~y, Suite 318
J.:ia~.:, F:. 3::::'/£
P~: 3C~/252-711t
r.::. ':c::. 1.:~:::":.
]':s. 5~5,~ G:-E:!
~:-:;€::-.c:C:
y.::-. ~:.=t.c::: L.
D~;.:E~ b t-:~c.:e
Ci~y of ~cr~h Kia~~
~~: ~EE~ Ca~~~= G~!C~:.~
r ~ . u'
- - '" -.
Eoca F.c~on, F!..
pt: 3C5/2S2-SC70
:.~~:=.2
Dr. ?e~e: Scr.:oece:
EicSY$te:;.s
~~~:s?c=: Du~? Coa:i~::~
1 :;, : ::J S. \.;. 1 c: E Co:; :- t
~ic~i, F~ :::::/E
F~: 3C~/~3:-55CS
D:. Earo:c R. ~anlesE
l"""'~C-:>-" jIP-- C"'_.I';;'~c'"
.-.....-t" ... ""-."r """c---- ...
. 260 Gree~~oo~ Dr.
. - Key EiscC!yne,:L 331~9
Ph: 305/361-4656
Dr. Re~ate H. Skinner, ?h.~.
Regional' Biologist
St2te of Floric2
Dep~. of Na~urcl Resources
P.O. :0>: :2€:28
Key L2rgo, FL 33.037
Pr.: 305/.c51-3005
Dr. DC':1 6eSy2 \" a
!~~~~~;~=~ D~~? CCEli~ic~
12E01 S.w. EC ~venue
~:i~~~, F~ 33156
p~: 305/3€1-~€19
~r. John Lindsey
Y.s. Rebecca Ho!f
NOkh
c/o Emergency Response
USEPA
Region IV
3~5 Courtland Street,
htlanta, GA 30365
Ph: 40~/3'7-223.c
1'.E.
Dr. klin~ SZffic~~
City o! l'cr~h Ki~~i
5~5 s.~. 2S Roa6
1.:i~;:.:, F1, ::212~
Ph: 305/361-4609
Kr. Delbe:t Hicks
US:::FA
Re:ion IV
En~iron~en~al Ser\"icEs D:V
Colle;e Static~ ~~.
~t~ens, GA 30El~-?i;;
Ph: 40~/5'6-2:29~
. -'
~r. Br2~ Jackson
~s. Camilla ~cIre~
US:::?A - Region IV
3~5 Courtland Stree~, G.E.
htlanta, GA 30365
Ph: 404/347-26'3
I':r. y.ike Graha~
JoIDCDERM
111 N.W. First Street
~iQmi, FL 331:28
Ph: SC 445-3321
Dr. "Is en ~:c!;g
Ci~y o! ~orth Ki~~i
515 Date Palm ROcC
Fc:t Pierce, FL 32963
Ph: '07/:231-3786
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Page 2 0: 3
~s. Annette ~ielscn, ~cnage:
Florida DeFt. of ~aturcl Resources
Bureau of A~uatic Reserves
~ivi~ion of State LendE
. P.O. Bo7. <87
Key Lar9c, FL 32C37
Ph: 305/451-<777
Mr. Henry S~ith, tS III
Florida Dept. of ~atural Resource~
Office of Environmental Services
Division of State Lanes
3900 Commonwealth Blva., R~ 206E
Tallahassee, FL 32399
Ph: 904/854-0070
J-:r. ~:!' S E t:".:- c.~:
C!-:~~: Hi! 1
"C:~~ .
L,..I-_.;-.
i:2 ell; . \-:. 1 : t:. F: ace
G,:neE\::!E, F~ 32602
PL: 9C"/3~1:"2".{:
~r. Jack Bateman
~I. Robert Pope -
~unisport Dump Coalition
~iami Daae COi.~uni~y Cullege
S S ~ ~ S~: 1 ~ 1 S':.
Mi ami, FL 331 7 6
Ph: 305/3<7-2<29
~:r. R.J. Sr~nne: III
Ph: B13/E75-1:1~
~r. George Heneersc~, E.k.
F~o=ic:a Dert. of l\at\;Icl .Resource~
Florida ~erine Research !nstitut.
Division of ~2rine Resources
100 Ei9~t ~venue, S.!. . -
St. Petersburg, F~ ~3701-50S~
Ph: SC 523-1011
~=. Gary Vclene:
D a ;7, e s 0. I.:;:. C = ~
City cf ~;:=th ~ia~i
1 ~or~h Dale ~~~E=
S~i~e 70C,
7c~?c, r:. ~~EC~
l;C~ Sc. Cc~;~e~E
.:.',"e:':1.'€
!'::. David James
~=. John Rud~ell
Bureau c~ Waste Clecnu~
FDER
2600 Blair Stone Roa5
Tallahassee, FL 3~399-2~OO
Fh: 90
-------
pa;e 3 cf 3
.
. Qthe~ P2rtici~ants
~=. E. ~llen Ste~a=t III
r-~ F I'~
3300 S.~. 3~ Avenue
s-..:ite 152
Ocala, FL 32674
Ph: SO~/65~-0070
~=. Davie ~olFin, Es~.
City c! ~::th ~ia~~ -
77E ~.E. 125 Street
~o:th ~~a~i, FL 331El
Pr.: 305/c~3-6511
. -... .-
. - .. ..
.--
~s. ~au~een nor~itz, Ese.
Munisport Dump Coalitio~
2390 Bayview ~ane
North Miami, FL 33161
Ph: 305/891-5662
; ....,."
. .
-. - ... .. Ok." ........... - '. .'
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APPENDIX E
STATE CONCURRENCE LETTER
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"='1:-,;'-.~~C
1"-'== ,../";~-
-,-~-;:.-
-.:;.-~ - ~~-
..~
cr»\
~
Florida Department of Environmental Regulation
'tWin 1bwe~ omc~ Bldg. . 2600 Blair StOne Road . U11~ Florida 32399.2400
Bob Martintt. CiO\'etnor
Date ~..chun.M, ~C8ry
John Shearer. A5AiSWlt secretary
september 5, 1990
Mr. Greer Tidwell
Regional Administrator
U.S. Environmental Protection
Region IV
345 courtland Street, NE
Atlanta, Georgia 30365
Dear Mr. Tidwell:
Agency
The Florida nepartroent of Environmental Regulation concurs with
the remedial alternative selected for the Munisport Landfill
Superfund 8i te, as descr ibed in section 10.0 of the Record of
neci8ion.
The selected alternative requires construction of a hydraulic
barrier to prevent discharge of contaminated groundwater t.o the
adjacent state mangrove preserve. The details of the barrier
system will be based on hydrogeologic and treatability studies to
be completed during t.he design phase. The selected alternative
also requires hydrologic improvements to the man~rove preserve
and the altered on-site wetlands. We anticipate that the City of
North Miami will implement the remedy.
The selected remedy addresses only the release of hazardous
substances to the mangrove preserve and pertains only to that
portion of the site needed for implementation of the remedy. We
understand that no action under CERCLA is anticipated for the
remainder of the site. Thus closure of the landfill will be
administered by the atate 1n accorCiance ,,1 th Chapter 17-701,
Florida Administrative Code. EPA and rnER will consult 'with each
other to ensure that the superfund remedy and landfill closure
are compatible. .
We look forward to successful
'on of this remedial action.
nT/XYZ
'::,.-
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