United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R04-91/079
October 1990
-tf—"-
Superfund
Record of Decision
Petroleum Products, FL
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50272-101
REPORT DOCUMENTATION 11. REPORTNO. I ~ 3. RecIpient'. Acce88ion No.
PAGE EPA/ROD/R04-91/079
4. Tille and SlA>dlle 5. Report Date
SUPERFUND RECORD OF DECISION 10/05/90
Petroleum Products, FL
6.
First Remedial Action
7. Author(.) 8. Perfo""lng Org8lllzadon Rept. No'
9. Perfo""lng Org8lniDdon Name and Addre.. 10. ProjBct/TuklWork Unit No.
11. ContrIIct(C) or Gr8lll(G) No.
(C)
(G)
1~ ~orIng Org8lliutlon Name and Addre88 13. Type of Report" Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Suppl8ment8ry No...
16. Abatr.ct (Umlt: 200 word.)
The Petroleum Products site is an inactive oil processing plant in Pembroke Park,
Broward County, Florida. The area surrounding the site is highly developed with
industrial, commercial, ahd residential properties. The Petroleum Products (PPC) site
lies within the radius of two major municipal well fields. Current site features
include an industrial warehouse complex, a fenced area with several dozen drums of
investigation - derived waste, a french drain system, and several monitoring and
abandoned storm drainage wells. PPC began onsite operations as a processor and broker
of waste oil in 1958. Several tanks were located in a tank farm area bounded on the
east and north by several large areas of standing water, that served as a culvert
drainage system. Sludge generated during oil refinery processes were disposed of
onsite in unlined disposal pits. In 1970, a major rainfall caused the onsite disposal
pit to overflow, producing an oil slick on the lakes of a nearby trailer park.
Subsequently, all disposal pits were filled in, but. it is suspected that sludge was
mixed with clean fill and returned to the pit or spread over the property. Drainage
at the site was then upgraded to a french drain system and drainage wells, which
(See Attached Page)
17. Document Analyal. L De8cripto18
Record of Decision - Petroleum Products, FL
First Remedial Action
Contaminated Medium: gw
Key Contaminants: metals (chromi um, lead), oils
b. Identifier8lOpen-Ended Tenne
Co COSA 11 ReIdIGrlq)
18. Av1ilablity St8tement 19. SecurIty CI888 (Thi8 Report) 21. No. of P.gea
None 24
20. SecurIty a... (Thi8 Page) n PrIce
Nonp
27214-71}
(See ANSl-139.18)
See IMtrucllona on lis"",.
(Form8fIy NTJS.35)
Department of Commerce
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EPA/ROD/R04-91/079
Petroleum Products, FL.
First Remedial Action
Abstract (Continued)
relieved flooding of the site and permitted flushing of former disposal pit contamination
into the groundwater. In 1971, PPC ended all onsite refining operations. The property
was subsequently used as a storage and distribution facility. In 1979, at the request of
the County, PPC cleaned up portions of the site including two oil-soaked areas. In 1983,
the State required PPC to remove additional waste oils and submit a detailed site
sampling plan. Subsequent sampling identified that the groundwater had been contaminated
by oils, VOCs, petroleum hydrocarbons, and inorganic compounds. In addition, a State
investigation, conducted in 1984 revealed that 20,000 to 60,000 gallons of free oil was
present in a ground water plume centered on the tank farm area and that fluctuations in
the water table had led to soil contamination by these oils. In response to an 1985
Administrative Order (AO), PPC emptied, cleaned, and rendered inoperable all tanks;
tested all oil, water, and sludge before disposal or recycling; removed and encapsulated
asbestos from a boiler house; and transported 262 drums of sludge offsite. In 1985, the
State installed a free product recovery system to recover oil floating under the site,
and a concrete pit was installed in an onsite warehouse to contain free oil seeping up
through the floor. This Record of Decision (ROD) addresses the first operable unit
(OU1), enhancement of the free product recovery system as an interim remedy. A future
ROD will address source control and ground water treatment. The primary contaminants of
concern affecting the ground water are metals, including chromium and lead; and oils.
The selected remedial action for this site includes abandoning the damaged monitoring
wells that remain onsite; abandoning the storm drainage wells onsite, which put the
Biscayne aquifer at risk; monitoring private wells in the vicinity; enhancing the present
free product recovery system to remove a larger volume of oil and to contain the
contaminated ground water plume; and disposing of waste oil offsite at an approved
refinery. The estimated capital cost for this remedial action is $660,000, with an
estimated O&M cost of $83,000.
PERFORMANCE STANDARDS OR GOALS: This interim remedy
recovery system and reduce the threat of contaminant
therefore, clean-up goals were not provided.
will enhance the free product
migration into municipal wells;
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INTERIM ACTION RECORD OF DECISION
SITE NAME AND LOCATION
Petroleum Products Corporation Site
Operable Unit #1
Pembroke Park, Broward County, Florida
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected interim remedial action
for the Petroleum Products Corporation (PPC) Site, Pembroke Park,
Florida which 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 (SARA), and, to the extent practicable, the National Contingency
Plan (NCP). This decision is based upon the administrative record
for the Site.
The State of Florida has concurred with this interim action.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this Site,
if not addressed by implementing the response action selected in this
Interim Action Record of Decision (IAROD), may present a current or
potential threat to public health, welfare, or the environment.
DESCRIPTION OF SELECTED REMEDY
This Petroleum Products Corporation interim remedial action is the
first to be taken at the Site. This alternative calls for the design
and implementation of interim response measures which will protect
human health and the environment. The principal threat at this time
involves the potential migration of the plume away from the Site and
into the drinking water. The goal of this remedial action is to
contain the groundwater contaminant plume; modify the waste oil
recovery system; prevent further flushing of contaminants into the
groundwater from on-site drainage and degraded wells; and to collect
data on aquifer and contaminant response remediation to ensure that
the future final action is effective. Upon completion of the
Remedial Investigation and Feasibility Study (RIfFS), this system
will be incorporated into the design of the Site remedy specified in
the final action Record of Decision (ROD).
The ultimate goal of remediation is to return the groundwater to its
beneficial uses, in this case, drinking water. However, EPA
recognizes that the selected remedy may not achieve this goal because
of the technical difficulties associated with removing contaminants
to groundwater cleanup levels. These measures are intended to
prevent further migration of contaminants, and will provide hydraulic
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:~:=rmation necessary to determine the final reme~y, during the
c~-soing RIfFS process.
~~~ major components of the selected remedy for this interim remedial
a:::.ion include:
Decommissioning damaged or nonoperating water and monitoring
wells.
Redirecting the drainage from the Site.
Closing culvert drainage wells on-Site.
Post warning signs on the site.
Preventing access to the concrete dike area in the warehouse
rental unit by closing the unit for rental.
Sampling selected wells in the area for the presence of
contaminants in the drinking water.
Modifying the current waste oil recovery system.
Off-site disposal of the waste oil into an approved refinery.
.,...
S~ATUTORY DETERMINATION
This interim action remedy is protective of human health and the
env:ronment, complies with Federal and State applicable or relevant
and appropriate requirements directly associated with this action,
and is cost-effective. This interim remedial action utilizes
permanent solutions and alternative treatment (or resource recovery)
technologies, to the maximum extent practicable, given the limited
scepe of the action. Because this interim remedial action does not
constitute the final remedy for the Site, the statutory preference
for remedies that employ treatment that reduces toxicity, mobility,
or volume as a principal element will be addressed by the final
response action. Subsequent actions are planned to fully address the
principal threats posed by this Site.
Date
o~ ~ /990
I
~fY1~
~Greer C. Tidwell
Regional Administrator
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Danner
4WD-SFB
Tobin
4-WD
Farmer
4WD-SFB
Johnson
4-0RC
Tidwell
4-RA
Heard
4-0RC
Sasine
4-0RC
Mundrick
4WD-SFB
Barker
4-0RC
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1.0
2.0
3.0
4.0
5.0
6.0
7.0
8.0
9.0
10.0
11.0
12.0
TABLE OF CONTENTS
SITE LOCATION AND DESCRIPTION
............................ .
SITE HISTORY
........ ... ..............
. . . . . . . . . . . . . . . . . . . . .
HIGHLIGHTS OF COMMUNITY PARTICIPATION
. . . . . . . . . . . . . . . . . . . . .
SCOPE AND ROLE OF THE OPERABLE UNIT
SITE
5.1
5.2
5.3
5.4
5.5
5.6
5.7
. . . . . . . . . . . . . . . . . . . . . . .
CHARACTERISTICS ..........
Soil Gas Investigation...............................
Oil Sampling..................
Surface Water and Sediment Investigation .............
Ground Water.......................... . . . . . . . . . . .
Surface Soil.........................................
Surface Water . . . . . . . . . . . . . . . . . . . . . . . .
Air. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . .
. . . . . . .
......
......
. . . . . . . . . .
.....
HUMAN EXPOSURE PATHWAYS
......
. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
SUMMARY OF SITE RISKS .............
7.1 On-site Con~aminants .........
7.2 Off-site Contaminants
. . . . . . . . . . . . .
. . . . . .
. . . . .
. . . . . . . . . . . . . . . . . .
. . . . . .
. . . . . . . . . .
. . . . . . . . . . . . .
. . . . .
DESCRIPTION OF ALTERNATIVES
8 . 1 Al ternati ve 1 - No Action............................
8.2 Alternative 2 - Relief from Water Infiltration .......
8.3 Alternative 3 - Relief from Water Infiltration
and Recovery System Modification
. . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . .
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
. . . . . . . . . . .
SELECTED REMEDY
. . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
STATUTORY DETERMINATIONS
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
RESPONSIVENESS SUMMARY
12.1 Overview.......<
12.2 Background
12.3 Summary of
and Public
Additional
12.4
. . . . . . . . . . . . . . . . . . .
. . . . . . . . . .
. . . . . . .
~ . . . . . . . . . . . . . . . . . .
. . . . . . . . . .
. . . . . . .
on Community Involvement .................
Comments Received During Public Meeting
COIDIDent Period...........................
Conun.ents .................................
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1
1
6
6
7
8
9
9
14
23
23
23
23
24
24
24
25
25
26
26
27
29
30
30
30
31
32
41
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LIST OF FIGURES
Figure 1-1 Location of Petroleum Products
Corporation (PPC) Site 2
Figure 1-2 Vicinity Map - PPC Site 3
Figure 1-3 PPC Site Map 4
Figure 3-1 Locations of Soil Gas Samples Exhibiting
Peaks on OVA-GC 10
Figure 3-2 Location of Oil Samples (PWS01 and PWS01D) 12
Figure 3-3 Locations of Lake Water (PLW01 - PLW05) and
Sediment (PLS01-PLS05) Samples 15
Figure 3-4 Soil Sampling Locations 16
Figure 3-5 Lead Concentrations (ppm) in Shallow Soil
Composite Samples and Shallow Split-Spoon
Soil Composites 17
Figure 3-6 Lead Concentration Areas Based on Shallow Soil
Composite Samples and Shallow Split-Spoon
Soil Composites 18
Figure 3-7 Chromium Concentrations (ppm) in Shallow Soil
Composite Samples and Shallow Split-Spoon
Soil Composites 19
Figure 3-8 Actual Total Organic Concentrations (ppm) in
Shallow Soil Composite Samples and Shallow
Split-Spoon Soil Composites 20
Figure 3-9 Total Organic Concentration Areas Based on
Adjusted Concentrations in Shallow Soil
Composite Samples and Shallow Split-Spoon
Composites 21
Figure 3-10 Lead, Chromium, and TPHC (ppm) Concentrations
in Deep Split-Spoon Soil Samples (PTS01A-D;
PTS05A-G) 22
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Table 1.
Photo # 1
LIST OF TABLES
Soil Gas Survey Results .............. 11, 12
LIST OF PHOTOS
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
8
-iii-
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RECORD OF DECISION
DECISION SUMMARY
1.0
SITE LOCATION AND DESCRIPTION
The PPC Site is located in Pembroke Park, Florida, approximately 0.2
miles west of Interstate 95, 1.5 miles north of the Broward
County-Dade County line. The area surrounding the Site is highly
developed and contains a high-density residential population in
addition to a variety of commercial/industrial activities. The Site
~ies within the radius of influence of two major municipal well
fields: the Hallandale Municipal Well Field, approximately 2000 and
3700 east of the Site, and the Hollywood Municipal Well Field, less
than two miles northwest of the Site. A third proposed wellfield for
Broward County will belocated approximately 7500 . feet west of the
Site. See Figures 1-1 and 1-2. .
The Site currently is occupied by a commercial/industrial warehouse
complex known as the pembroke Park Warehouses. A fenced area in the
southeastern portion of the Site is the only area of the previous PPC
facility that has been left unpaved. The fenced area contains a few
drums of waste generated during the RI fieldwork and an oil recovery
system well. This well has recoved approximately 6900 gallons of oil
since 1985. Refer to Figure 1-3.
2.0
SITE HISTORY
PPC has been reported to have started operations in 1958. In
September 1958, several tanks were staged an area bounded on the east
and north by large areas of standing water serving as a drainage
system. From 1966 to 1968, PPC was experiencing maximum operation as
a refinery of waste oils. During this two year period the residents
in the area began complaining of overflow of the oils onto the
trailer park property located adjacent to and south of the Site.
In 1970, PPC initiated major changes in its operation after a large
rainfall caused the disposal pit to overflow, producing an oil slick
on the trailer park lakes. After increased community pressure at the
time of the spill, PPC began preparations to sell the property. The
disposal pits were filled in and it is suspected that the sludges
were mixed in with clean fill, returned to the pit and/or spread over
the property.
In 1971, PPC ended the operation of refining the waste oils and began
operating as a storage and distribution facility. Mr. Jerry Blair,
owner and operator of the PPC facility, sold the majority of the
property to Dr. Robert Cornfeld, who holds the property in four land
trusts of which he is the beneficiary. The southeastern corner of
the property is still owned by the Petroleum Products Corporation.
-1-
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iTWrte i i
s&^'V-Whi LsJJj
M^tff Xiil 'i ni!gf°mi**'T *5
&'/<*•-•,. .-f •L* • «h C ::
fHff * •*•' -*• ^^^^^- 17 • II '/ '* v\ \ IV
•*'/» HOLLYWOOD T«li I « I/ / "A ^ S
J|n WELL FIELD feL | p3 f A^f |"
' '••
SOURCE.
• U.S.G.S. Fort L«ua«rd«i* South (1M3) «na North Miami (1972) QuMr«ngiM.
SCALE
1 MILE
1 KILOMETER
Figure 1-1 LOCATION OF PETROLEUM PRODUCTS CORPORATION
(PPC) SITE
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1-
ORANGE BROOK GOLF COURC...~
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Pembroke R08d
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Figure 1-2
VICINITY MAP - PPC SITE
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....... Bouncl8l'Y of Old Oi.,o..1 Pit
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Syn.m
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Figure 1- 3
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-......... ....
R
CAROLINA ROAO
RAMBO -rAAD'" TAr"A PAA.
PPC SITE MAP
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Warehouses were constructed by PPC and Dr. Cornfeld on the northern
and western sections of the property. Site conditions have remained
essentially the same from 1972 to 1984.
In 1979, PPC cleaned up portions of the Site in response to two
warning notices from Broward County Environmental Quality Control
Board. The two oil-soaked areas and rehabilitating two other areas.
In 1983, the FDER Southeast Florida District Office issued a Notice
of violation requesting that PPC remove additional waste oils from
the Site and submit a detailed sampling analysis plan. PPC hired
Dames and Moore, Inc., an environmental consulting firm, to conduct
sampling at the Site. The sampling revealed a layer of oil floating
on the groundwater table. In addition, the groundwater contained
varying amounts of oil and grease, petroleum hydrocarbons, volatile
organic compounds, and several inorganic compounds. In 1984, Florida'
Department of Environmental Regulation (FDER) hired Environmental
Science and Engineering, Inc. (ESE) to determine the extent of free
hydrocarbon contamination at the PPC Site. ESE est~ated that 20,000
to 60,000 gallons of free oil was present in a groundwater plume
centered on the tank farm area. The plume appeared to be slowly
migrating to the east-southeast. The extensive saturation of the
soils with oil has been attributed to the fluctuation of the water
table.
In 1985, EPA collected samples from the storage tanks on-site and an
area away from the tanks. The samples exhibited levels of lead (244
ppm), oil and grease (1,000,000 ppm), and toluene at (240 ppm). EPA
issued an Administrative Order to PPC on March 1, 1985. PPC agreed
to work under a consent order where PPC would undertake the required
cleanup action under the direction of an EPA On-Scene Coordinator.
The order stated that all tanks were to be emptied, cleaned and
rendered inoperable; all oil, water and sludges were to be chemically
tested prior to disposal; the oil properly disposed of or recycled;
and the asbestos in the boiler house removed or encapsulated. Two
hundred sixty-two drums of sludge were removed from the property in'
October, 1985. .
In 1985, FDER hired a contractor to install a free-product recovery
system which consisted of a 30-inch diameter, 23-foot-deep extraction
well, with a 25 gallon-per minute (gpm) drawdown pump and an oil
skimming unit for the recovery of floating oil underneath the Site.
The recovery system has been in operation since 1985, and has
recovered approx~ately 6900 gallons of oil to date.
In 1986, FDER contracted Ecology and Environment to preform the RIfFS
for the Site. The RI indicated that contamination was still present
at the PPC site. The draft FS was presented to EPA in March, 1988.
-5-
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EPA was unable to accept the FS as final before FDER" expended all
funding available for the FS. FDER and EPA are jointly investigating
the remedy selection with plans to present a soil and groundwater
contamination remedial action in 1991.
3.0
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RI and Interim Action Proposed Plan for the Petroleum Products
Corporation Site were released to the public in July 1990. These
documents were made available to the public in both the
administrative record, and in information repositories maintained at
the EPA Docket Room in Region 4 and at the Broward County Main
Library. The notice of availability for the documents was published
in the Sun Sentinel on August 1, 1990. A public comment period was
held from July 31, 1990 through August 30, 1990. In addition, a
public meeting was held on August 14, 1990. At this meeting,
representatives from EPA and FDER answered questions about problems
at the Site and the remedial alternatives under consideration. EPA
granted a 30 day extension to the public comment period in response
to requests from the Potential Responsible Party's. The public
comment period ended on September 30, 1990. A response to the
comments received during this period is included in the
Responsiveness Summary, which is part of this Interim Action Record
of Decision. This decision document presents the selected interim
remedial action for the PPC Site, in Pembroke Park, Florida, chosen
in accordance with CERCLA, as amended by SARA and, to the extent
practicable, the National Contingency Plan. The decision for this
Site is based on the administrative record.
4.0
SCOPE AND ROLE OF THE OPERABLE UNIT
The major goal of this interim action is to contain the plume within
the boundaries of the Site. Preventing further water infiltration
into the area of the disposal pits by preventing infiltration of
water into the soils and increasing the recovery of waste oil from
the groundwater. There are a number of wells that were installed
on-site in the past that have degraded. These wells are not useful
for monitoring or pump and treat activities. The wells are sources
of infiltration of stormwater and commercial wastewater from the
Site. Drainage on the Site consists of a french drain system
relieving run- off over the entire property. These drains allow for
flushing of the former PPC disposal pit contamination into the
groundwater.
The warehouse complex and surrounding area support a variety of small
commercial/industrial operations. Many of the current operations use
solvents and other chemicals that represent a continuing source of
soil and groundwater contamination via leakage from the surface water
drainage system or direct infiltration in unpaved areas. Area
businessmen have stated that small-scale dumping of industrial
chemicals is common in this area.
-6-
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The PPC Site and the surrounding neighborhood are in a
topographically flat area which results in a drainage problem.
Extensive local ponding occurs after periods of substantial
rainfall. The property owner of the PPC Site installed a drainage
system for the property which consists of a number of drainage wells
and storm sewers. The intake of some of these wells extends about
one foot above the collection sump, which essentially skims the
water. The drains are actually french drains allowing stormwater
containing waste oils from the PPC sludge pits as well as dumped
wastewater from the industries within the warehouses to be released
directly into the groundwater. A method by which the drains and
wells are closed out while the run off from the Site is diverted to
another area would slow down the water infiltration as well as limit
the flushing effect the wells and drainage system have on the closed
disposal pits.
Inoperable wells in the immediate plume vicinity are potential
pathways for migration of contaminants from the shallow soils.
Identification of damaged or inoperable wells should be conducted and
those wells decommissioned. This interim remedial action will be
consistent with any planned future actions, to the extent possible.
Source control and groundwater treatment will be addressed as a
subsequent Operable Unit. .
The FDER RI report presented to EPA provides information to indicate
that the following activities should be implemented at the Site:
Discontinue on-site, small-scale dumping by area businesses;
Modify the surface drainage system;
Modify the free-product recovery system;
Post local wells; and
Decommission non-operating water and monitoring wells.
In warehouse number 261, located northwest of the center of the
former disposal pit, free oil was found to have seeped from the
ground upward through the floor. A concrete dike of about 1 square
yard was installed in the warehouse to contain the oil. See Photo #
1.
The present waste oil recovery system should be improved to recover
more of the waste oil from the groundwater. Numerous operation and
maintenance problems have prevented the system from achieving maximum
recovery rates.
5.0
SITE CHARACTERISTICS
The Petroleum Products Corporation Site formerly contained a tank
farm and two unlined disposal pits. Soil, sediment, groundwater and
surface water samples were collected in and around the Site.
Although the Remedial Investigation (RI) identified areas of
-7-
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Photo II 1.
Warehouse 261.
Free oil concrete dike.
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contamination, it did not sufficiently define the extent of
contamination in the groundwater and soils. The treatability studies
presented in the FS were also not sufficient to determine which
alternative would best suit the source control at the Site.
Therefore, EPA and the State of Florida have begun studies and
sampling activities to determine the appropriate alternative for the
second operable unit remedy. The remedy for source control or
contaminated soil remediation will be set forth in a separate Record
of Decision and will be conducted as a second operable unit at the
Site. The first operable unit will focus on containment of the plume
from the Site into surrounding areas.
5.1
Soil Gas Investiaation
Soil gas sampling was performed to determine the extent of
hydrocarbon contamination in the vadose zone and shallow
groundwater. Sampling locations in addition to those samples that
exhibited a gas chromatograph (GC) peak are. indicated on Figure 3-1.
The data from this survey was utilized in determining the areas for
soi1 sampling and placement of groundwater monitoring wells.
Examination of the results presented in Table 1 did not reveal any
clear pattern as to GC peak types. There was very little correlation
between GC peak and the down-pipe readings or the open-hole
readings. Some samples that exhibited high open-hole readings did
not exhibit GC peaks and some samples that exhibited GC peaks did not
exhibit high down-pipe readings. Despite the problems, the soil gas
survey provides an indicator of areas most likely contaminated with
the exception of samples lA, 3A, 41, 55 and 51.
5.2.
Oil SamDlinq
Two oil samples, PWSOI and duplicate PSW01D, were collected from a
concrete impoundment. The impoundment, in warehouse 261, had been
constructed to restrain the spreading of oil that seeped through the
warehouse floor to a depth of one to two feet. Figure 3-2 shows the
oil sample location.
Lead (2,050 parts per million (ppm», calcium (1,540 ppm), sodium
(533 ppm), magnesium (178 ppm) and boron (81.5 ppm) were detected.
These concentrations reflect the calcareous soils and associated
groundwater contact with the reprocessed waste oil in the
subsurface.
5.3.
Surface Water and Sediment Investiqation
In general, lake waters in the area exhibited minimal metal
contamination. Magnesium, calcium, sodium and boron were the primary
metals detected. The presence and detected concentrations of these
metals are not unusual, given that these man-made lakes are excavated
calcareous terrain. Lead was the primary metal contaminant
associated with the PPC Site at 8 parts per billion (ppb) from a
-9-
-------
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"'"
o
Q
.(
:;)
o
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CII
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...
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21
.
29
.
41
...
55
...
.
41A
.
.. -'.
KEY:
....... Bound..y 0' Old DIlDo", Pit
~ W..enou-
- F..c.
*
o
o
20
... $011 G- Sample m8t exhibited P..k
. Soli G.. Sample t1'18t did not exhibit P..k
eAiftinll F,.. ProduCt Aecov...,
$VftMn .
100
SCALE
200 300
.0
80
~o F...
i
100 120 l1li",...
60
Figure 3-1 LOCATIONS OF SOIL GAS SAMPLES EXHIBITING PEAKS ON
0'/ ~- G~
-------
. . Table 1
SOIL GAS SURVEY SUMMARY RESULTS
Down-Pipe Readings
Sample
No.
1A
3
6
6A
7
8
9
10
11
12
13
14
15
15A
16
17
18
19
21
22
22A
22B
23
2k
24A
25
26
27
27P
27A
28
29
30
31
32
33
34
35
36
37
39
40
41
41A
42
Background
(ppm)
2-3
10
2
2-3
2-3
1
10
2-3
10
1
0-1
1
2-3
3
1-2
1-2
1-2
1-2
1-2
2-3
2-3
2-3
1-2
1-2
2-3
1-2
2-3
3-4
3-4
3-4
2-3
2
2-4
10-13
0-1
2-3
3
0
1
1-2
0-1
0-1
0
2
1
Initial
(ppm)
1000»»
1000**
6
10
1-
2
3-10
4-8
30-50**
2-3
120**
3
5
3
10-80
1000**
1000**
1000
6
10-40**
1-2
2-3
1-2
1-15
30-100
100-200**
2-3
60-100
10-20
300
10-60
3-8
2-4
10-13
20-100
30-100
5-10
0-10
1000**
2-10
3-10
20-100**
400-1000**
10-20
1000**
P re-Sampling
(ppm)
1000**
1000**
3
4-6
300-1000
100
0-5
2-3
40**
2-3
40-100**
0-1
6
500-1000
20-85
300-700**
200-1000**
200-1000
8
10-75**
20-100
20
1-2
8-20
60-100
100**
1000
800
1000
300
10-60
2-3
1000
10-13
0-1
1000
3
1-10
1000**
2-4
3-10
50-100**
200-600**
5-15
1000**
Open-Hole
Reading
(ppm)
20
15
1000
2-3
300-600
1000
1000
7
2
2-3
2-3
0-1
30
3
75
5
0-1
200-500
10-30
2-3
2-3
2-3
30-60
200-300
.150-200
6-7
1000
1000
1000
1000
200-1000
30-800
1000
14
0-1
1000
3
1
1
1
3-10
4
0-5
8
0-1
GC Peak
Types*
3
3
1
—
1
1
2,4
'
__
—
—
—
—
—
1,4
1,3
—
1,3
—
—
__
—
1,4
2,4
—
1,4
1
2,4
2,4
2,3
—
—
1
2
—
»
—
__
--
— _
3
__
—
-------
Table 1 (Cont.)
Down-Pipe Readings
Open-Hole
Sample Background Initial Pre-Sampling Reading
No. (ppm) (ppm) (ppm) (ppm)
43 3 1000- 1000" 0-1
44 0-1 1000" 1000" 0-1
45 1 10-30 1 1
47 0 1-10 1-5 2
48 0-1 70-100" 100-400- 8
49 2-3 1-10 2-3 2-3
50 2-3 1000- 200-1000" 2-3
51 15 1000" 1000" 25
52 2-3 200-1000- 15-50- 2-3
53 0-1 1000" 1000" 0-1
54 2-3 50-100" 50-100" 5
55 0 1000" 1 00- 900--. 0
Source: Ecology and Environment, Inc., 1987.
.GC Peak Types are 8S follows:
GC Peak
Types.
3
1 = Large, 8harp peak within 10 seconds after injection.
2 = Same as 1, but with long, sloping tail that itself occasionally
exhibited peaks.
3 = Rounded peak of varying amplitude with a retention time of 110-120
seconds (Sample 27A exhibited a similar peak with a retention time of
190 seconds).
4 = Sharp peak immediately after initiation of back flush.
-Anomalously high reading compared with the subsequent open-hole readings;
may reflect the residual presence of the isopropanol used to decontaminate
the pipes.
Note:
lIhere a range is given for the down-pipe and open-hole readings, the
higher value usually represents the initial maximum level, whereas the
lower value represents the level at ..nich the readings stabilized.
-------
1--
PEMBROKE
ROAD
~~
-'e:
0<
t.:)A,
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KEY:
....... Sound8f'Y of Old 01..0..1 Pit
~ W.,."ou-
. Location of 011 Sampla.
.......--. F., c.
*
exin'ng Fr.. PrOdUCt R8CO""'Y
Synam
o
100
SCALE
200 300
c
20
40
60
80
400 FH't
I
100 120 Met...
Fi~ure 3-2
LOCATION OF OIL SAMPLES (PWS01 AND PWS01D)
-------
sample from the Orange Brook Golf Course. The location of the lake
water and sed~ent samples are shown on Figure 3-3. Calcium,
magnesium, sodium, and boron were detected in lake sediment saples
reflecting the calcareous fraction of the peat-rich sediment.
Aluminum, copper, manganese, iron and zinc were also present. Lead
was detected in the Bamboo Paradise Trailer Park lakes located south
of the Site in three samples (19.8 ppm, 31.4 ppm, and 100 ppm). The
lead concentration found in these lakes may be attributed to the
runoff from the disposal pit.
Surface water runoff samples were collected from three drainage
culverts on the southern half of the Site. The data showed that
surface water runoff from the Site includes a variety of dissolved
constituents. Lead contamination varied from 198 ppb to 320 ppb.
TPHC was also detected at concentrations of 8,600 ppb to 18,000 ppb.
Consequently, surface water runoff provides a potential pathway of
continuing contamination of soils, groundwater and surface waters
(lakes).
Soil investigations indicated that only lead, aluminum, barium,
chromium, copper, iron, and zinc appear to be of significance in the
soil contamination. Lead concentrations varied in the disposal pit
soils from 957 ppm to 7,660 ppm, and total organic compound (TOC)
concentrations ranged from 306 ppm to 4,652 ppm. Refer to Figures
3-4, 3-5, 3-6, 3-7, 3-8, 3-9 and 3-10.
5.4
Groundwater
Groundwater beneath the Site consists of the surficial zone and
intermediate zone of the BiscaYne aquifer, and Floridan aquifer. The
surficial zone is heavily contaminated with waste oil, lead,
chromium, aluminum, iron, manganese and benzene. The metals found in
the surficial zone are also found in the intermediate aquifer at the
PPC Site at lower concentrations. The Floridan aquifer at the Site
is not contaminated. The off-site surficial and intermediate zones
of the BiscaYne aquifer were found to be contaminated with s~ilar
contaminants in the areas south, east and west of the PPC Site.
The surficial zone is located in the soft limestone bedrock. Soil
boring results from 20 - 30 foot depths indicated ~hat this limestone
is interbedded with higher percentage of sand, silt, and shell
fragments.
A deep well boring shows little lithologic variation between 30 feet
and 200 feet. In deep wells, drilling mud had to be added
continually to prevent loss of circulation, suggesting the presence
of voids and cavities. Contaminated water from the upper aquifers
into the Floridian aquifer will likely occur in the near future.
-14-
-------
I
Ir.
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; I !! II i III I !
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,
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ORANGE BROOK G01..F CO~
hmbrok. . Road
. I
4
.
KEY: 1-5 Semple De8i9netion Number
Figure 9-~
. Wet.r Sempl. L.oc81lon
. Sediment Semple Aliquot Collection Point
o 200 .00
- -
o 50 100
SCA1.E
800
1200
11100 FEET
£00 METE PIS
.
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; ~
LOCATIONS OF LAKE WATER (PLW01-PLW05) AND SEDIMENT
(PLS01-PLS05) 'SAMPLES
200
300
-------
,--
PCSQ9
PCSOS
PEMBROKE
"':.e
..-
c-
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\
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APPROXIMATELY
3000 FT. S.
PSS01 'T
PSS02
KEY:
....... Bound....., Of Old DIlDo". Pit
-
- w.",ou.
~ F8nC8
*
o
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S.,-
100
SCALE
200 300
£00 Feet
:
120 Mete..
100
o
20
&0
60
80
Figure 3-4
ROAD
n PSS05
PCS01" 18 PSS06
BAMBOO PDA'''' PARK
-~
- ,~
A OisPo.1 Pit Split-Spoon Soil Composites
(PBSOI-PBS051
. Sh8110w Soil Composites (PSSOI-PSS22;
PPS01-PPS051
. Sh8110w Spllt.Spoon Soil Composites
(PCSO' -PCS 191
00..0 Solit.Sooon Soil Compolit..
(PTSOI-PTS051
SOiL S~MPLING LOCATIONS
-------
"'11:
"'1:
Cc(
CQ"
c(w
:W
c:>
<,
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OW
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6.2
1:8
PEMBROKE
ROAO
c.
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ROXIMATEL Y
3000 FT. S-SW
1.52.5
8.3 8
~ 8.1 20
OAIillbe 'rAD'" TArLER ,...
5.7
9.1 .
r-l
LAKE
.1
KEY:
....... Bouno...., of 010 01_' I'lt
~
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- ~..c.
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8 S"'8Ilow Soli ComPGSltw 'I'S$01-P5522:
PPS01-I'PS051
. S"'.Uow Sl;llIt.Spoon SOU Compoait..
'I'CS01-PCS1g) .
Ex,ft'nv ~r- "roouCt Fleeo"...,
Syft8m
( I Oupllc:8t.
.JU1. - A 'nterv.1
0.0 - B Interval
100
SCALE
200 300
o
20
80
.00 ~8ft
I
100 120 Menn
Figure 3-5
.0
60
LEAD CONCENTRATIONS (ppm) IN SHALLOW SOIL COMPOSITE
SAMPLES AND SHALLOW SPLIT.SPOON SOIL COMPOSITES
-------
iJr
PEMBROKE
ROAC
~
...J
o
C
~
C
c
UI
i:
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""""°lAADISE TArUR PARK
KEY:
....... Sou no.., of Olel 0,__1 "It
~ W.,..,ou-
. Shallow Soil Comoo8i- 1,"5501-"SS22:
,"PS01 -1"PS05)
- F...C8
. Shall- split.Sooon Soi' Comoo..t..
IPCS01-PCS1SI
*
E,,,".", Fr.. "POauCt Aeco"..,
SlI'ft....
-
>1000 C'C''''
>500 00'"
20
4&0
60
80
4&00 F-
I
100 120 M_.
I//!
>100 00'"
o
100
SCALE
200 JOO
o
Figure 3-6
LEAD CONCENTRATION AREAS BASED ON SHALLOW SOIL
COMPOSITE SAMPLES AND SHALLOW SPLIT-SPOON SOIL COM.
P~::ITES
-------
PEMBROKE
ROAD
...¥
~-
c-
c:;:
ct,
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Ow
we:
...
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3.4
4.0
...
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en
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APPROXIMATELY
3000 FT. S-SW
2.99 <5
r-==--~1j
II I
! LA /(£ ~
.1
I
2.86 n.7.17
<2:5. 6.74
.""BOG "[RADISE "'j'LER PARK
14.6 7.70
KEY:
....... BoundWV 01 Old OIC081 Pit
~
~ W...,.ou-
- F.,C8
. Shallow Soil Compa8itft IPSSC)1-PSS22:
'PPSO'-I"PS05)
. Shall- SQllt.Spoon Soil Compo.in.
,..eso, -fOes, 9)
*
'.
I I DuplUt8
JlJJ- A IntWV8'
0.0- B IntWv8'
e",It,no F,- Product RecoV8'V
SVatem
o
100
SCALE
200 300
. <&00 F~
o
20
60
60
80
100 120 Met...
Figure 3-7
CHROi'vllUM CONCENTRATIONS (ppm) IN SHALLOW SOIL COM-
;:.:--::-: S.~j\p:"=S .A.i'jC, SiiALLOW SPL!T-SPOON SOIL COMPOSITES
-------
"-- -
~x
-c:
Co(
c~
CIII
:1111
Q:>
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IIIC:
I-
398
F
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C
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Q
III
APPROXIMATELY
3000 FT. s-sw
0.26 1.
PEMBROKE
ROAD
I
[.
C ~
Cu
o f .65
= . .-. 878
., ..- "
[ji'-)/
158--
.
I
.1908 (16081
2.2 n .1.31 _I
;:0. 0.88
BAM""" TRAD'" TArLER PAR.
0.03 - 3.21
r
\
j L.A KE
.
.1
KEY:
....... lovnd.Y of Old 01_1 ~It
~ W._U8
- F..C8
"*
o
. Sh8110w Soil Co,"DO..-I~SS01-JOSS22:
~~01-~S051
. Shallow Sollt-So-" Soil CoIftD08-
(~CS01~CS1g)
E,,,ftj,,. F~- ~~uCt Aecovwy
SV8nrn
( I Ouolic8n
.aJI-'" . "tWV81
0.0- B I "farv.'
'00
SCALE
200 300
8 Ph... II TPHC Conc8~8tion
o
20
40
60
80
400 Feet
I
100 120 M_~.
Figure 3-8
ACTUAL TOTAL ORGANIC CONCENTRATIONS (ppm) IN SHAL-
LOW SOl L COMPOSIT~ S~MPLES AND SHALLOW SPLIT. SPOON
SGi L COMPOSITES
-------
,-
PEMBROKE
ROAD
110.111:
...=
c<
t;:~
10,000 pp,"
- F..C8
..c;:"/"" " >1000 ppm
o
o
- -
- - -
100
SCALE
200 300
.u0 F.,
1///1 >100 ppm
20
.u
60
80
100 120 M~
Figure 3-9
TOTAL ORGANIC CONCENTRATION AREAS BASED ON ~DJl'STED
CONCENTRATIONS IN SHALLOW SOIL COMPOSITE 5k::~:_=":;
AND SHALLOW SP1..IT.SPOON 501 L COMPOSITES
-------
11.7 2.84
2.80 6.00
1900 160
5 5
B B
362 1..6
5.01 10.2
2000 52.6
10 10
C C
38.1 1.5
3..s 2.84
1100 33..
15 15
D D
6.1. 121001 1.5
2..7 110..1 5.51
86 /27.0001 ..0
20 5 20
PTS02 B PTS01
10
C
5 15
B D A
(e.G1 Pb 10.700 Pb 7920
16.571 Cr 19.. Cr 26.7
116.0001 TPHC 1.0.000 TPHC 25.000
10 20 5
C PTS03 B
12.2
3.0
250
15 10
D C
Pb 55.8
Cr 3.0
TPHC 1000
20 15
PTSOC D
572
88.8
1300
20
E
2015
...7
1000
25
F
7..,
..67
1100
30
G
91.2
6.29
1COO
35
KEY:
Pb L88Ct
Cr Chromium
TPHC TOt.' Pftroleum Hydroc.rbon"
1 Duplicate
LOCATIONS ARE NOT TO SCALE
Figure 3-10 LEAD CHROMIUM, AND TPHC (ppm) CONCENTRATIONS IN DEEP SPLIT.
SPOON SOIL SAMPLES (PTS01A.D TO PTS04A-D; PTS05A.G)
-------
5.5
Surface Soil
Surface soil (0-20 feet) at the PPC Site is highly contaminated with
lead. High off-site lead contamination was found at the corner of
Carolina Road and S.W. 31st Avenue (near the tank farm area).
Arsenic concentrations were of health concern at the south and west
areas of the Site. The Site and surrounding areas are developed and
landscaped, therefore, inhalation of wind blown contaminated soil is
not a current concern. This would be a concern during the removal of
contaminated soils from the Site.
5.6
Surface Water
Pembroke Park is a relatively flat area, with a few man-made
high-lying land areas. The elevation of the PPC Site was raised
about 5 inches when the waste oil pit was refilled. No disposal
ponds or ditches are located on-site. Surface water at the Site is
collected by drainage wells. The drainage water showed high
concentrations of lead and moderate concentrations of chromium and
manganese. Off-site surface water samples from the nearby trailer
park lakes, however, showed low levels of copper" zinc, and iron in
several samples. The metals analyses suggest that contamination
associated with the PPC Site is not currently affecting the water
quality of the surrounding lakes. The PPC Site is located in a
flooding area (the average annual rainfall is 60 inches per year).
The contaminants found may be carried by surface water run-off into
the lakes at the Bamboo Trailer Park, Ted's Aqua Golf course, and
into the business complex at the PPC Site.
5.7
Air
Analytical results of air sampling are not reported in the Remedial
Investigation. However, the Remedial Investigation report did
mention that a strong smell of solvents were present from the open
monitoring wells. Monitoring wells are normally capped, except the
monitoring/recovery well in the fenced area. The air exposure
pathway at the PPC Site has not been fully evaluated. During
remediation, the potential may be increased for the air exposure
pathway to become an environmental pathway of concern.
6.0
HUMAN EXPOSURE PATHWAYS
The above mentioned contaminated environmental media constitutes the
following potential human exposure pathways.
Contaminated groundwater presents ingestion, dermal absorption and
inhalation exposure pathways. Surficial and intermediate zones of
the Biscayne were shown to be contaminated at the PPC Site, off-site
areas, southwest, and east of the Site. According to the FDER files,
there are reports that people became ill after drinking water
supplied by several of the private wells in the area. All drinking
water in the area is presently provided by the Hallandale well field
according to the FDER remedial investigation report. Dermal
-23-
-------
absorption and ingestion of contaminants in the ground water could
occur to residents in the area who have irrigation wells.
7.0
SUMMARY OF SITE RISKS
Analytical results of the remedial investigation indicate that
off-site contamination appears to be in the groundwater and the soils
in the south, east and west areas adjacent to the site. Aluminum,
chromium, iron, lead, manganese, trichloroethylene and arsenic are
the contaminants in the off-site and on-site areas. At this time,
the contamination from the site has not entered into the well
fields. However, if the contaminants are allowed to remain, the
potential for human exposure exists.
7.1
On-site
Contamination
Contaminants of concern on-site consist of the following:
Media Contaminant Ranae (Unit)
surficial zone
of the BiscaYne Lead 0.0246 - 22,400 ppm
(Black oil in Chromium <0.01 1. 1 ppm
18" - 20" Aluminum 0.647 376 ppm
thickness) Manganese 0.0571 0.308 ppm
The current maximum contaminant level for lead is 50 ppb and was
promulgated as an interim drinking water regulation in 1975. In
1985, EPA began the process of revising the standard for lead by
proposing a maximum contaminant level goal (MCLG) of 20 ppb. The
high levels of lead found in the soil and groundwater raise special
concerns though we have no numbers by which to quantitfy the risk
from exposure to lead. EPA headquarters has recently recommended that
15 ppb of lead in drinking water not be exceeded, due to central
nervous system effects occurring at very low blood levels of this
metal.
7.2 Off-site Contamination
Analytical results of the RI
appears to be in groundwater
areas adjacent to the Site.
the following.
indicate that off-site contamination
and soils in the south, east and west
The contaminants of concern consist of
MEDIA
LOCATION
CONTAMINANT
RANGE ( UNIT)
(ug/L)
Surficial
Zone of the
BiscaYne
Aquifer
South
Aluminum
Chromium
Iron
Lead
Manganese
44,100
139
11,700
58
77.6 -
- 202,000
474
27,600
161
99.6
-24-
-------
Shallow Soil
South
Chromium 468
Aluminum 169,000
Iron 34,600
Lead 219
Manganese 99.6
Al uminum 10,500
Iron 5,250
Lead 1,800
Manganese 97.2
Trichloroethylene 5.1
Aluminum 1,440
Iron 757
Aluminum <200 2,560
Iron 175 598
Arsenic <1.5 4.38
Lead <1.5 5.090
Lead 3.87 - 1,860
Arsenic <1.5 1.58
East
West
Intermediate
Zone of
the Biscayne
Aquifer
South
East
East
West
8.0
DESCRIPTION OF ALTERNATIVES
Alternative 1 - No Action
Alternative 2 - Relief from Water
Alternative 3 - Relief from Water
Modifications
Infiltration
Infiltration with Recovery System
The alternatives chosen for this activity provide for a phased
approach. Alternatives chosen for this interim action will limit the
amount of contamination continuing to be released from the Site.
8.1
Alternative 1 - No-Action
Estimated Capital Cost: $-0-
Estimated Operation and Maintenance (O&M):
Months to Implement: 1 month
$63,000
The no-action alternative is required by the National Contingency
Plan (NCP) to be considered through the nine point criteria. It
provides a baseline for comparison of other alternatives. Under the
no-action alternative, no source control remedial measures would be
undertaken at the Petroleum Products Corporation NPL Site at the
present time. Potential health risks would remain associated with
current exposure by ingestion to surface soil and exposure to surface
water by ingestion.
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Although no action would entail groundwater monitori~g as operation
and maintenance (O&M), unremediated soils would continue to release
contaminants into this Class I aquifer, thereby extending the period
of time over which the drinking and groundwater treatment systems
will be required to operate and the amount of soil requiring
remediation.
8.2
Alternative 2 - Relief from Water Infiltration
Estimated Capital Cost: $480,000
Estimated Operation and Maintenance (O&M):
Months to Implement: 3
$63,000
Alternative 2 recommends decommissioning of non-operating water and
monitoring wells; redirecting the drainage from the Site; closing
culvert drainage wells that are on-site; and, conducting a public
well survey to post wells in the area for sampling and analysis the
presence of contaminants in the drinking water. Other Site
activities would include posting warning signs identifying the Site
as an NPL Site, preventing access to the concrete dike area in the
warehouse rental unit, and imposition of institutional controls (land
use restrictions). The activities recommended will diminish the
amount of contaminants .flushing into the groundwater and locate
contaminated water sources that could be presently utilized by the
public. At the present time, the storm drainage wells have an intake
about one foot above the collection sump which essentially skims the
water. The wastewater and wash water from the surrounding
industrial/commercial businesses flows into the wells and down into
the groundwater, increasing the problem. Limiting the number of
conduits into the aquifer in the area of the disposal pits limits the
mobility of contamination into the area. The public well survey
would define the number of individuals presently on private wells.
The transportation. and disposal of recovered waste oil from the Site;
design and installation of drainage systems for the Site; and the
construction and closure of wells shall comply with appropriate
Federal and State ARARS. Maximum contaminant levels (MCLS) for
groundwater remediation will not be met in this interim action,
however, they will be addressed in the final remediation of the
groundwater.
8.3 Alternative 3 -
System Modification
Relief from Water Infiltration and Recoverv
Estimated Capital Cost: $660,000
Estimated Operation and Maintenance (O&M):
Months to Implement: 4
$83,000
This alternative includes all items discussed in Alternative 2 and
includes the modification of the current oil recovery system to
increase the amount of oil recovered. FDER has hired a local
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contractor to dispose of the oil at a recycling facility. The
purpose of closing out the damaged wells and drainage system is to
prevent the possible increase in contamination and migration of
contaminants from the Site. Many of the drainage wells are from 42
to 75 feet in depth. With these wells open to the aquifer,
contamination of the drinking water and groundwater is possible.
The exact modification to the present system has not been
investigated at this time although this could be accomplished during
the remedial design phase. Modifying the present oil recovery system
should be an easily implemented interim action.
Increasing the oil recovery system should aid in the capture of waste oil
from the groundwater. These recovery wells could be utilized in the
future in the event that a large scale groundwater pump and treat system
is to be constructed on-site. Also, the wells could be used as a
monitoring location for groundwater contamination in the area.
9;0
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
A detailed analysis was performed on the three alternatives using the
nine evaluation criteria in order to select a site remedy. The
following is a definition and brief summary of each alternatives'
strengths and weaknesses with respect to the nine evaluation
criteria. These nine criteria are: 1) overall protection of human
health and the environment; 2) compliance with applicable or relevant
and appropriate requirements (ARARS); 3) short-term effectiveness; 4)
long-term effectiveness and permanence; 5) cost; 6) reduction of
toxicity, mobility and volume; 7) implementability; 8) State
acceptance; and 9) community acceptance.
Overall protection of human health and the environment addresses
whether a remedy provides adequate protection and describes how risks
posed through each pathway are eliminated, reduced or controlled
through treatment, engineering controls or institutional controls.
Compliance with applicable or relevant and appropriate requirements
(ARARS) addresses whether a remedy will meet all of the ARARs of
other Federal and State environmental laws and/or justifies a waiver.
Long-term effectiveness and permanence refers to expected residual
risk and the ability of a remedy to maintain reliable protection of
human health and the environment over time, once clean-up goals have
been met.
Reduction of toxicity, mobility or volume through treatment .is the
anticipated performance of the treatment technologies a remedy may
employ.
Short-term effectiveness addresses the period of time needed to
achieve protection and any adverse impacts on human health and the
environment that may be posed during the construction and
implementation period, until cleanup goals are achieved.
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Implementability is the technical and administrative feasibility of a
remedy, including the availability of materials and services needed
to implement a particular option.
Cost includes estimated capital and O&M costs, as well as
present-worth costs.
State/support agency acceptance indicates whether, based on its
review of the RI and Proposed Plan, EPA and FDER agree on the
preferred alternative.
Community acceptance indicates the public support of a given
alternative.
Overall Protection.
All of the alternatives, with the exception of the "no action"
alternative, would provide protection of human health and the
environment by reducing risk through engineering controls or
. institutional controls. Alternatives 2 & 3 offer reduction of
contaminants into the groundwater by removing the infiltration
the aquifer of run-off .from on-site businesses and rainfall.
into
Because the "no-action" alternative offers no reduction in risk to
human health and the environment, it is not considered further in
this analysis as an option for this Site.
Lona~Term Effectiveness and Permanence.
None of the alternatives provides for a long-term remedy in that the
goal of the interim action is to contain contaminant migration prior
to implementing the large scale remedy to follow at a later date.
Short-Term Effectiveness.
There should be no adverse effects to human health and the
environment from either of the alternatives under consideration. The
short-term effect will be to address the removal of the waste oil
from the groundwater and prevention of plume migration in Alternative
3 until a final remedy is undertaken.
Implementability.
All alternatives are easily implemented for the Site. There'should
be no problem in securing the equipment and materials for the
decommissioning of wells and modification to the present recovery
system as stated in Alternative 3.
Community Acceptance.
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Community acceptance of the preferred alternative has been very
positive. During the public meeting, many of the residents and local
officials agreed with Alternative 3 as an appropriate remedy for the
interim action.
Compliance with ARARs.
There are very few ARARs that are associated with will be met in the
initiation of either of the remedies. No MCLs will be met. The
alternatives are only containment remedies; not a final remedy for
the Site. Federal and State regulations in regard to the closure and
construction of wells, implementation of drainage systems and
transportation and disposal of recovered waste oils will be addressed
by both alternatives.
Of the above criteria, the following apply in limited capacity to the
Interim Action Record of Decision: 1) Overall protection of human
health and the environment; 2) Compliance with ARARs; 3) Reduction of
toxicity, mobility or volume through treatment; 4) Implementability;
5) Costs; 6) State acceptance; and 7) Community Acceptance. All
ARARs will not be met since the containment of the contamination
plume is the primary goal of the remedy for this action. There is no
long-term or short-term effectiveness to be addressed with this
interim action. All of the nine criteria will be addressed to the
fullest extent in the final remedy. The interim action is not meant
to address the final cleanup of the Site nor is the intent to address
clean-up standards or regulations in regard to groundwater. This
remedy mitigates a threat posed by the potential migration of the
plume into drinking water wells and limiting the environmental
factors that contribute to plume migration.
Alternative 3 is the most cost-effective alternative that effectively
provides protection to public health and the environment at this
time. There are few ARARs to be met by this alternative or any of
the other alternatives presented. There is a reduction in mobility
of the contamination plume which would occur from the limiting of the
groundwater as well as rainwater to flow near the contaminated soils
in the area of the disposal pit locations. Alternative 3 is the only
alternative that provides for a modification to the present oil
recovery system which would decrease the potential for the
contamination to migrate off-site and into the well fields nearby.
As stated previously this Interim Action Alternative addresses the
plume migration and factors that enhance the migration of
contaminants away from the Site.
10.0
SELECTED REMEDY
Alternative #3 has been selected as the appropriate remedy for the
Site as an interim remedial action. This first operable unit
addresses the containment of the contamination until the time that
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EPA and FDER has had the opportunity to evaluate and test
alternatives for source control at the Site. The selected remedy is
to decommission the nonoperating wells that remain on-site, close out
the storm drainage wells that are on-site which deposit wastewater
and stormwaters in to the lower zone of the Biscayne aquifer, conduct
a private water well survey to identify present users of the
groundwater in the affected area, and modify the present recovery
system in an effort to remove a larger volume of oil from the
groundwater and contain the plume. Specific design protocols and
criteria will be determined by bench scale or pilot testing during
the remedial design. This remedy will only address the continued
release of contamination into the groundwater through infiltration of
wastewater and flushing of the contaminants into the groundwater from
drainage wells and drainage systems at the Site. Operable unit two
will address source control of the contamination at the Site and
final groundwater action.
11.0
STATUTORY DETERMINATIONS
EPA had determined that this interim remedy will not satisfy all of
the statutory requirements of providing permanent protection of human
health and the environment, or attaining applicable or relevant and
appropriate requirements of other environmental statutes. However,
this interim remedy will limit the continued migration of
contaminants into the groundwater and will utilize resource recovery
technologies to the maximum extent practicable. An interim remedy
waiver is requested for this Site. The final remedy will comply with
the ARARs for the Site.
12.0
12.1
RESPONSIVENESS SUMMARY
Overview
In August 1990, the United States Environmental Protection Agency
{EPA) selected a preferred alternative for remediating soils at the
Petroleum Products Corporation (PPC) site in Pembroke Park, Florida.
The preferred alternative is referred to as U.S. EPA's Interim Action
Proposed Plan. The proposed plan was developed as a phased approach
to site remediation. The first phase of remediation, known as
Operable Unit One, involves containing the ground-water plume and
~peding the release of site contaminants to the ground-water.
Operable Unit One will be implemented through the following
activities: (1) discontinue on-site dumping by area businesses; (2)
redirect surface water drainage; (3) expand the existing oil recovery
system; (4) identify and monitor local wells and; (5) decommission
nonoperating water and monitoring wells.
EPA conducted a public meeting regarding the proposed plan
14, 1990, and a 30-day public comment period was held from
August 30, 1990. A 30-day extension of the public comment
granted so that all citizens had sufficient time to review
on August
July 31 to
period was
the
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proposed plan and submit any questions or concerns regarding the plan
to EPA.
The purpose of this responsiveness summary is to identify the
comments and concerns of the local community and potentially
responsible parties (PRP) regarding the Interim Action Proposed Plan,
and to document how EPA considered these comments and concerns during
the selection of a remedial alternative. This responsiveness summary
is organized into the following sections:
Background on Community Involvement
Summary of Comments Received during the Public Meeting
and Public Comment Period and Agency Responses
Additional Comments Received
12.2.
Background on Community Involvement
PPC operated as a processor and broker of waste oil from 1958 through
1971. Sludges generated from the oil refining process were disposed
of in unlined pits located on the site property. From 1966 to 1970,
residents of the nearby Bamboo trailer parks lodged a series of
complaints against PPC with municipal authorities after sludges
overflowed from the disposal pits onto the trailer park property.
Also, overflow from the disposal pits after heavy rains produced oil
slicks on trailer park lakes. In 1970 and 1971, PPC conducted site
development activities in anticipation of selling the property. In
1971, a majority of the PPC property was developed as the currently
existing commercial and industrial warehouse complex known as the
Pembroke Park Warehouses. Several of these warehouses were
constructed over abondoned disposal pits, and contaminated soils were
left on-site during development. PPC continued to operate a portion
of the site property until 1985.
Community involvement with thePPC site was most active during the
late 1960s and early 1970s when the sludges from the PPC facility
were overflowing into nearby residential areas. After redevelopment
of the PPC property in 1971, community concern about the PPC property
decreased markedly: however, some residents felt that redevelopment
of the property should not have been allowed until some type of
cleanup action was taken regarding the waste oil on the property.
Since redevelopment in 1971, community interest in the PPC site has
remained low. Newcomers to the area are unaware of the site and most
long-time residents and individuals working near the site are not
concerned with the site, and expressed little or no concern regarding
potential health problems associated with the site.
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The concerns of local government officials are focused on the effect
the site may have on drinking water sources. City water supplies are
obtained from well fields located near the site. Government
officials are concerned with the possible migration of contaminants
from the PPC site into these nearby drinking water supplies.
The greatest concern of both local officials and residents is the
length of time between indentifying problems at the site and the
actual response to these problems. Most officials and residents
cannot understand the urgency to clean up the site after the
government has investigated the site for so many years. Most
government officials feel that the site should have been cleaned up
several years ago.
12.3
SUMMARY OF COMMENTS RECEIVED DURING PUBLIC MEETING
AND PUBLIC COMMENT PERIOD
Comments raised during the PPC public comment period and public
meeting on the proposed plan are summarized below. The comments or
questions and the agency responses are categorized by topic.
Remedial Alternative Preference:
1.
PRP Comment: This PRP does not believe that it is cost
effective or consistent with the National Contingency Plan
(NCP) to select a proposed remedy for containment of the
ground-water plume (Operable Unit One) until the remedial
investigation/feasibility study (RI/FS), presently being
supplemented, has been reviewed and finally approved by EPA.
EPA Response: The NCP allows for an interim action prior to
the completion of the RI/FS, therefore, EPA is consistent with
the NCP.
2.
PRP Comment: Although the proposed remedy may indeed limit
both the amount of contamination continuing to be released and
plume migration, it would seem more cost effective and
reasonable to incorporate this function as part of either the
second or third operable units, particularly in view of the
conclusions reached in the 1987 RI.
EPA Response: The proposed remedy does limit the amount of
contamination and plume migration. Delaying the reduction of
the contamination is not viewed as cost effective in terms of
final cleanup costs. The potential for migration and
contamination of ground-water and costs for remediation increase
the longer cleanup is delayed. Postponement of the proposed
activities does not present a more cost effective function of
the second and third operable units.
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3.
PRP Comment: The InterLffi Action Proposed Plan.for the PPC site
does not appear necessary or appropriate to "achieve significant
risk reduction quickly" considering the stability of the system
and the low degree of lateral contaminant migration revealed in
the RI.
EPA Response: The interLffi action will achieve significant risk
reduction with the modification of the existing oil recovery
system. As stated in the NCP, "phased analysis and response is
necessary or appropriate given the size or complexity of the
site." This situation applies to the PPC site, which is complex
and may require many years for Lffiplementation of a final
remedial action plan.
PRP Comment: The Lffiplementation of Operable Unit One as
proposed will not expedite the completion of total site cleanup.
4 .
EPA Response: The interim action is not intended to expedite
total site cleanup. The purpose of the interim remedial action
is to contain the contamination plume by preventing the increase
in the plume size.
5.
Public Comment: .A representative from the Broward County Water
Resources Management Division (WRMD) stated that Broward County
is in favor of EPA's Interim Action Preferred Alternative and
requests that EPA accelerate the implementation of Operable
Units Two and Three to achieve site remediation.
EPA ResPonse: EPA appreciates Broward County's interest in site
remediation and will do everYthing possible to implement
Operable Units Two and Three in a timely manner.
PRP Comment: Why is an interLffi removal being performed when the
RI indicates that no immediate threat exists?
6.
EPA ResPonse: The proposed interim remedial action plan is not
a removal action. There was concern that the waste oil in the
ground-water could potentially migrate off-site into nearby
private wells or the municipal drinking water wells, thereby
endangering the public. The existing oil recovery system had
been reported as recovering approximately 60 gallons of waste
oil per week: however, upon recent site investigations, the
system was found to be operating at a much lower rate. This
recovery system aids in removing a portion of the threat from
ground-water contamination. By Lffiplementing this proposed
interLffi action,an existing problem can be controlled, rather
than persisting until a final remedy is developed. A final
remedy for the site is not expected to be complete for several
years.
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7 .
8.
9.
10.
PRP Comment: The preferred alternative for Operable Unit One
is Alternative 1 or No Action. Site action will neither
improve the existing contamination in upgradient or
downgradient ground-water, nor in soil quality. Because site
contaminants pose no immediate threat to water supplies, there
is sufficient time to implement a remedial action. A remedial
design/remedial action (RD/RA) should be pursued, although an
interim removal action will only prolong the final remedy.
EPA Response: The RD/RA will be pursued for Operable Unit
One. The investigations and activities needed to achieve a
final remedy will in no way be hindered or prolonged by the
implementation of an interim action. To assume that this
interim action would not improve down-gradient soil or water
quality is premature. Although down-gradient soil quality is
not an issue, there has been no indication in previous testing
that down-gradient soil quality has been affected by any of the
former disposal pits on site. Only surface spills have
affected down-gradient soil quality. The interim action is not
meant to remediate all site contamination, nor is it meant as a
substitute for a final remedy. Presently, with the exception
of plume migration possibly affecting municipal wells, the EPA
and/or PRPs have .time to implement the interim action remedy
before public endangerment becomes an issue.
PRP Comment: Why is EPA addressing the sediment contamination
under the No Action alternative?
EPA Response: EPA is not addressing the sediment contamination
in any of the alternatives. EPA stated no further action would
be taken at this time to prevent exposure to the sediment
contamination. The sediment in question is the sludge and soil
contamination which contribute to the ground-water
contamination. Source contaminatlon was not to be addressed in
this interim action, nor was a final remedy to be considered.
with the interim action.
PRP Comment: Alternative 2, via decommissioning damaged or
inoperative wells, closing culvert drains, and redirecting site
drainage, will not achieve the objective of diminishing the
amount of contaminants which flush the ground-water.
EPA Response: Alternative 2 was not the recommended
alternative and does not allow for the removal of waste oil
from the ground-water.
PRP Comment: In regards to locating other contaminated water
sources presently used by the public, a well survey should be
conducted as part of the risk assessment/feasibility study and
not as an interim removal action. Well selection should be
based on the potential influence of PPC contaminants on the
water quality of individual wells.
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12.
13.
EPA ResPonse: Wells will be selected based on the potential of
PPC contaminants to influence water quality. Part of the
supplementary RI was to locate the private wells in the area
that were not addressed in the past and consider them in the
risk assessment. The original RI located these wells and the
individual owners were notified of the need to discontinue
public use as a potable water source. EPA wants to maintain
that decision by posting the identified private wells as
non-potable drinking water sources.
11.
PRP Comment: The proposed plan fact sheet states that the
preferred alternative includes the modification of the current
waste-oil recovery system. However, the exact modification to
this system will be determined during the RD phase. How can
EPA can implement the modified system as part of the proposed
interim removal action?
EPA Response: The proposed interim remedial action is not a
removal action. The Superfund process specifies that the
remedial design will be developed after the public has had the
opportunity to comment on the alternatives and the remedial
Record of Decision (ROD) has been signed. After the remedial
design has been completed, the remedial action will begin.
PRP Comment: EPA has not
redirecting the discharge
identified any applicable
requirements (ARAR) to be
considered the implementability of
of the storm water, since EPA has not
or relevent and appropriate
met. .
EPA Response: EPA has considered the implementability of
redirecting the discharge of storm water. The Broward County
WRMD has been contacted and informed EPA that redirecting the
storm water was an implementable task. EPA has identified
ARARs associated with the preferred alternative (Alternative
3). There are no maximum contaminant levels (MCL) that can be
met by the alternatives. The nature of the interim action does
not require that ARARs be met, since the final remedy will
address the ARARs that apply to ground-water and soil cleanup.
PRP Comment: It is doubtful that the preferred alternative
will reduce the mobility or volume of waste oil in the
ground-water. To stop the mobility of the waste oil in the
ground-water, the ground-water gradient would have to be
reversed or the ground-water flow would have to be cut off. It
appears that the existing system is performing as intended and
was probably designed with the same purposes as the interim
removal.
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14.
EPA Response: Alternative 3 will reduce the mobility and
volume of waste oil in the ground-water. It will not totally
reduce the amount of waste oil present. The performance of the
existing oil recovery system has been decreasing over the years
and is not performing as designed. Recent reports have
indicated that the system is in need of repair or modification.
PRP Comment: The appropriate course of action would be to
select Alternative two.
EPA Response: Alternative two does not address the removal of
any contaminants from the groundwater. Alternative Three
provides for contamination plume containment until the final
remedy can be chosen for the Site. Alternative two does not
protect the public health and the environment as well as
Alternative Three for the purpose of this interim remedial
action.
Technical Ouestions/Concerns Reaardina Remedial Alternative 3
1.
2.
PRP Comment: How will the oil recovery system expansion, well
posting, and inoperative well decommissioning impede the
continuous release of contaminants into the ground-water?
EPA Response: The purpose of the interim action is to contain
the ground-water plume by recovering waste oil from the site
until a final remedy is implemented. Expanding the oil
recovery system will enable more waste oil to be removed from
the ground-water than the existing system is capable of.
Posting wells is a precautionary measure to prevent individuals
unaware of site problems from drinking from private wells
previously not posted. Decommissioning inoperative wells will
remove a source of contamination into the lower aquifer.
Closing these wells will mitigate a direct contamination
pathway into the drinking water. This is recommended by the
EPA, State of Florida, and local officials.
Public Comment: A citizen asked how many nonoperating wells
are located within the site vicinity, where these wells are
located, how they originated, and their purpose.
EPA Response: Many of these wells are old monitoring wells
constructed by the State of Florida. Newer wells will be
constructed in the future to detect lower levels of
contaminants. Other wells on-site are used for stormwater
drainage. These drainage wells range from depths of 42 to 75
feet, and this type of well is commonly used in Florida.
Approximately 13 drainage wells are located at the north end of
the site. These wells serve as direct conduits for site
surface water, and should be closed to decrease the amount of
site contaminants entering the ground-water.
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3.
4 .
5.
6.
7.
Public Comment: As stated in the proposed plan, site drainage
water will be redirected. One citizen was concerned with the
destination of this redirected water.
EPA Response: The plan for redirecting the site drainage water
is presently in the engineering design phase. As previously
stated, the purpose for redirecting this water is to eliminate
the flow of site contaminants into the ground-water.
PRP Comment: EPA was asked whether the continued releases from
area businesses are related to the former operations of PPC,
and why these releases are not regulated by local agencies.
EPA Response: The continued release of contamination from
local businesses is not related to the former operations of the
PPC site. However, these releases could introduce additional
solvents and oils into the ground-water, thereby contributing
to site contamination. The appropriate local regulatory
agencies are now aware of the releases and are taking action to
terminate the releases. .
PRP Comment: Is. the purpose of redirecting the surface
drainage water to redirect the releases from the area
businesses, or solely to allow storm water runoff.
EPA Response: The purpose of redirecting the surface drainage
water is not to redirect releases from area businesses.
Redirecting the surface drainage eliminates the infiltration of
run-off and large quantities of rain water which flush
contamination into the ground-water from site sludges and
soils.
PRP Comment: Because the fact remains that upgradient
ground-water is contaminated with pollutants from off-site
storm water discharges and natural aquifer fluctations, this
PRP feels that redirecting on-site drainage will not remedy
these existing conditions.
EPA Response: The off-site ground-water contamination is not
included in the discussion for site remediation: however, it
will be considered during final remedy evaluations. Natural
aquifer fluctuation has been considered. The aquifer
fluctuations lend support to the need for removing as much of
the waste oil from the ground-water as possible. The
fluctuation contributes to the release of waste oil into the
ground-water which had been adhering to surficial soils.
Public Comment: A representative from the City of Hollywood
asked how fast the contaminant plume was moving off-site and
wanted to know EPA's proposed method for stopping the flow of
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this plume. The citizen also inquired if a more costly method
would stop the flow of the plume faster than the proposed
method.
EPA Response: Site studies indicate that ground-water flow
through the site and contaminant release to the groundwater are
occuring at a slow rate. The types of site contaminants
include oily sludges and heavy metals, which are both
relatively ~obile materials. The contaminants adhere to
soils and, therefore, do not enter the ground-water very
quickly. Because EPA wants to minimize cleanup costs, the
proposed plan has been evaluated as the most cost efficient and
effective method for controlling the contaminant plume.
PRP Comment: Has EPA considered the potential benefits. of
introducing surface water into the contaminant plume?
8.
9 .
EPA Response: The introduction of surface water from the area
has been contributing to the problems at the site. The
mounding effect produced by surface water introduction causes
the waste oil on the ground-water surface to be forced up
through the asphalt. Pools of waste oil have been observed
on-site after heavy rainfall.
Public Comment: Because the public water supply is obtained
from a major well field located approximately one mile from the
site, a City of Hollywood representative was concerned with
drinking water quality and contolling the existing site
contamination.
EPA Response: EPA understands the water quality concerns of
local residents. Although site studies indicate the
ground-water to be moving off-site at a very slow rate, EPA
wants to eliminate the potential for contamination of drinking
water supplies through the implementation of the proposed plan
and subsequent site remediation plans.
10.
Public Comment: One citizen asked if the possiblity exists for
a site remedy, such as excavation and disposal of contaminated
soil, or if the site will always remain contaminated.
EPA Response: Phase two of site remediation will address soil
contamination (Operable Unit Two). By removing the soil
contamination, the source for ground-water contamination is
also removed. The cost and feasiblity for some type of soil
treatment is currently being evaluated.
11.
Public Comment: A Broward County official asked if the
Department of Environmental Regulation (FDER) currently
regulations for permitting the disposal of
petroleum-contaminated soils.
Florida
has
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EPA Response: FDER does have regulations for the disposal of
petroleum-contaminated soil. Petroleum-contaminated soils are
commonly treated by incineration processes. Because soils at
the PPC site also contain high concentrations of heavy metals,
incineration alone is not an effective treatment method for the
soils. Only soils containing a specific concentration of
metals can be permitted for incineration, and the concentration
of metals in site soils exceeds the allowable level.
12.
PRP Comment: It expansion of the oil recovery system
necessary to immediately minimize risk?
EPA Response: The reduction of the amount of waste oil in the
ground-water will minimize the potential risk, although the
interim remedial action will not totally eliminate the risk
posed by the site.
Costs/Fundina Issues
1.
Public Comment: One citizen representing the town of Golden
Beach asked what the projected costs for site cleanup were.
2.
EPA Response: The projected costs for the three interim action
alternatives are discussed in the Interim Action Proposed Plan
fact sheet. These estimates do not include Operable Units Two
and Three. No total estimate for site cleanup can be given at
this time because costs have not been evaluated for
implementing all phases of site remediation.
Public Comment: A citizen inquired into the liability of
responsible parties for site cleanup and if any federal funds
were available to supplement cleanup costs.
EPA Response: The responsible parties are liable for the
entire cost of site cleanup. Federal money is available.
through the Superfund; however, cost-recovery actions will be
implemented to seek repayment from responsible parties who do
not pay up front for cleanup costs.
3.
Public Comment: How much money has been spent on contractors
and consultants who have been involved in site cleanup work?
EPA Response: An accurate figure for contractor and consultant
fees cannot be estimated at this time; however, preliminary
cost figures for site cleanup and descriptions of cleanup
technologies are presented in the feasibility study, which is
available in the information repository.
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4 .
Public Comment: Is EPA was aware of a newspaper article
stating that all contaminated site soil was to be shipped to
North Carolina at a cost of $40 million?
EPA Response: EPA is familiar with the plan and cost
est~ate. Shipping soils off-site is one of several methods
currently being evaluated for site cleanup. Shipping
contaminated soils off-site has been a common practice in the
past: however, this method is not a permanent solution to the
contamination problem. Developing a soil treatment method to
remove contamination is preferred by EPA. The cost for the
removal alternative cleanup has been est~ated at $26 million.
Enforcement
1.
Public Comment: What will be the liablity of third parties,
that is, those individuals living near the site if site
contaminants happen to migrate onto their property?
EPA Response: Studies indicate that the heavy metals in site
soils are not likely to do not migrate off the site: therefore,
there is a very low potential for site contaminants to migrate
onto adjacent properties. Ground-water contamination is also
moving off-site at a very slow rate. If site-related
contamination is detected off the site, these areas will be
included in the overall cleanup plan. Any future contamination
problems attributed to the site will be addressed by EPA as a
site-specific case.
Public Comment: Does EPA conduct site cleanup negotiations
with the responsible parties in court?
2.
EPA Response: Once EPA selects the best cleanup method for the
site, the responsible parties will be contacted, and EPA will
give these parties an opportunity to settle out of court. Thi~
method of negotiating is the most efficient and cost effective
because the responsible parties are in control of cleanup costs
and no litigation fees are involved.
3.
Public Comment: How does EPA determine how much each
responsible party will pay for site cleanup, and is' there any
set formula EPA applies to the situation?
EPA Response: The PRPs are organized into a steering
committee. This committee will then negotiate among themselves
and EPA to determine what costs will be contributed for site
cleanup. EPA does not dictate to the PRPs what each party will
pay, but the decision is determined among the PRPs.
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Public Participation Process
1.
2.
PRP Comment: Has anyone petitioned for a removal action at the
site; and if not, why did EPA not take action sooner?
EPA Response: The proposed interim action plan is not a
removal action. This comment does not apply to this site.
PRP Comment: Four different PRPs requested a 30-day extension
to evaluate the proposed plan and submit comments.
EPA Response: The comment period was extended. EPA accepted
comments until Monday, October 1, 1990, at the close of
business.
1.
Available Site Information
2.
3.
PRP Comment: A removal site evaluation report should be
required for the PPC site, as stated in the NCP, section
300.410. .
EPA Response: The proposed interim action is not a removal
action. The removal site evaluation does not apply to the
presentation of the Interim Action Proposed Plan. Therefore,
this comment does not apply to this site.
PRP Comment: Where is the location of the supporting documents
that the lead agency used to determine that an imminent and
substantial endangerment exists, as required by the NCP,
section 300.810?
EPA Response: The NCP section 300.810 does not discuss
document requirements to support the determination that an
imminent and substantial endangerment exists at a site. NCP
section 300.810 discusses documents that may be excluded from
the administrative record. For information purposes, the
administrative record supporting site activities completed thus
far is located at the Broward County Main Library, Ft.
Lauderdale, Florida.
PRP Comment: Where is the location of a public health
evaluation report for the site?
EPA Response: The Health Assessment prepared by the state
health office for the Agency for Toxic Substances and Disease
Registry is located in the administrative record at the Broward
County Main Library, Ft. Lauderdale, Florida.
12.4
ADDITIONAL COMMENTS
The following general comments were received from PRPs and local
officials and do not require an EPA response.
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The Broward County WRMD commented regarding the. EPA Interim
Action Proposed Plan fact sheet. The WRMD noted that the only
two operating wells for the City of Hallandale (wells 7 and 8),
which are located approximately 2,000 and 3,700 feet east of
the PPC site, were not mentioned in the fact sheet. A former
City of Hallandale wellfield located approximately two miles
southeast of the site has been closed.
The Broward County WRMD also informed EPA of the current
expansion of Broward County's water supply system. Included in
this expansion is the construction of Wells E and F, located
approximately 7,500 feet west of the site. Figure 1 of the
fact sheet illustrates but does not discuss these wells.
One PRP stated that implementation of Operable Unit One is
consistent with the NCP, and fully supports EPA's interim
removal action plan.
....
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