PB94-964011
EPA/ROD/R04-94/177
July 1994
EPA Superfund
Record of Decision:
Standard Auto Bumper Corp,
Site, Hialeah, FL
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DECLARATION STATEMENT
RECORD OF DECISION - OPERABLE UNIT TWO
STANDARD AUTO BUMPER CORPORATION SITE
Site Name and Location
Standard Auto Bumper Corporation Site
Hialeah, Dade County, Florida
Statement of Basis and Purpose
This decision document presents the selected remedial action for
the Standard Auto Bumper Corporation site, in Hialeah, Dade County,
Florida, which was chosen in accordance with the requirements of
the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), as amend~d by the Superfund
Amendments and Reauthorization Act of 1986 (SARA) and to the extent
practicable, the National Oil and Hazardous Substance Pollution
Contingency Plan. This decision is based on the Administrative
Record for this site. The State of Florida, as represented by the
Florida Department of Environmental Protection (FDEP), has been the
support agency during the Remedial Investigation (RI) and
Feasibility Study (FS) process for the Standard Auto Bumper Co.
site. In accordance with 40 CFR 300.430, as the support agency,
FDEP has provided input during this process. Based upon comments
received from FDEP, it is expected that concurrence will be
forthcoming; however, a formal letter of concurrence has not yet
been received.
Assessment of the Site
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in the Record of Decision (ROD), may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
Description of the Selected Remedy
The response action described in this document addresses the second
and final operable unit for the site, the contaminated groundwater.
The major components of the selected remedy include the following:
.
Natural attenuation
.
Groundwater use controls
.
Groundwater monitoring
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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 utilizes permanent
solutions and alternative treatment (or resource recovery) .
technology to the maximum extent practicable for this site. Based
on the limited area of the groundwater plume; the apparent low
mobility of groundwater contaminants due to site-specific
hydrogeologic factors; the groundwater contaminants present and
their concentrations, relative to drinking water quality standards;
and the fact that the source of the contamination, the soil, will
be removed this year, EPA concluded that it was impracticable to
treat the groundwater effectively. Thus, this remedy does not
satisfy the statutory preference for treatment as a principal
element.
This remedy will serve to mitigate the threat to human health
through the natural attenuation of hazardous substances released
from the site. Because this remedy will result in hazardous
substances remaining onsite above health-based levels, a review of
the remedial action will be conducted within five years after the
initiation of the remedy to ensure that the remedy continues to
provide adequate protection to human health and the environment.
The review will be performed every five years thereafter until
health-based levels are achieved.
~mJ~
Patrick M. Tobin
Acting Regional Administrator
~ /0) /97'3
Date
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SECTION
TABLE OF CONTENTS
TOPIC
THE DECISION SUMMARY
1.0
2.0
3.0
4.0
5.0
6.0
7.0
8.0
9.0
10.0
Site Description
Site History
Highlight of Community Relations
Scope and Role of Remedial Action
Site Characteristics
5.1 Geology
5.2 Hydrogeology
5.3 Subsurface Features
5.4 Sampling Results
5.4.1 Groundwater
5.4.2 Surface Water and Sediments
Summary of Site Risks
6.1 Chemicals of Concern
6.2 Exposure Assessment
6.3 Toxicity Assessment
6.4 Characterization of Risk
6.5 Environmental Risks
6.6 Remediation Goals'
Description of Alternatives
7.1 Alternative 1 - No Action
7.2 Alternative 2 - Natural Attenuation and
Institutional Controls
7.3 Alternative 3 - Extraction and Discharge
7.4 Alternative 4 - Extraction, Treatment and
Discharge
Summary of Comparative Analysis of Alternatives
Selected Remedy
9.1 Groundwater Remediation
9.2 Performance Standards
9.3 Compliance Testing
Statutory Determinations
10.1 Protection of Human Health and Environment
10.2 Compliance with ARARs
10.3 Cost-Effectiveness
10.4 Utilization of Permanent Solutions and
Alternative Treatment Technologies or
Resource Recover Technologies
to the Maximum Extent Practicable (AMEPA)
10.5 Preference for Treatment as Principal Element
Appendix A
Appendix B
Fourth Round Groundwater Analytical Data
Responsiveness Summary
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NUMBER
1
2
3
4
5
6
7
8
LIST OF TABLES
TABLE
Groundwater Regulatory Levels
Contaminants Detected in Groundwater Samples
Contaminants of Concern
Noncarcinogenic Toxicity Values for
Contaminants of Concern
Hazard Quotients for Ingestion of Groundwater
for Future Hypothetical Residents
Remediation Goals for Groundwater
Evaluation Criteria for Remedial Alternatives
Remedial Alternative Cost Estimates
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PAGE
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35
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NUMBER
1
2
3
4
5
6
7
8
9
10
LIST OF FIGURES
FIGURE
Dade County Location Map
Topographic Location Map
Site Base Map
Shallow Aquifers in Southern Florida
Concentrations of Selected Inorganic Analytes
Detected in Groundwater from the Existing Wells
During the Preliminary Sampling Phase
Concentrations of Selected Inorganic Analytes
Detected in Groundwater from Temporary Monitoring
Wells During the Phase 1 RI
Concentrations of Selected Inorganic Analytes
Detected in Groundwater from Permanent Wells
During the Phase 1 RI
Concentrations of Selected Inorganic Analytes
Detected in Groundwater From
Permanent Wells During the Phase 2 RI
Concentrations of Selected Inorganic
Detected in Groundwater From
Permanent Wells During the
Fourth Round of Sampling
Analytes
Nickel Concentration Monitoring Well MW-2S
111
PAGE
2
3
4
10
14
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THE DECISION SUMMARY
1.0
SITE DESCRIPTION
The Standard Auto Bumper Corporation site is located in an
industrialized area of northeast Dade County, Florida at 2500 West
3rd Court, approximately six miles northwest of downtown Miami
(Figure 1) and is defined as all contamination associated with and
emanating from the site. Standard Auto Bumper Corporation was a
chromium and nickel plating facility which operated at this Hialeah
address from 1959 until late 1992/early 1993. The property area is
approximately 42,000 square feet and is geographically located at
25°50'40- N latitude, 80°17'15- W longitude. The site is shown in
Figure 2 on the Hialeah, Florida USGS 7.5 minute topographic
quadrangle map.
Standard Auto Bumper is bordered on the north by Quality
Manufacturing Products, Inc. and World Metals; on the east, across
West 3rd Court by Nela Junk Yard; on the south by Fernandez
Transport Corporation; and on the west, across the railroad track,
by the Gilda Bakery (Figure 3). The Red Road Canal is located
approximately 300 feet west of the site running parallel to West
3rd Court and the railroad.
Hialeah is an incorporated city that consists of heavy development
with mixed zoning. The city has an approximate population of
188,000 people and a strong manufacturing, wholesale, service and
retail industry. Twenty percen~ of the property within a mile
radius of the site is utilized for commercial and industrial
purposes, sixty percent is residential, and the remaining 20
percent is used for recreational parks and schools. It is
estimated that 11,000 people live or work within a mile radius of
the site.
2.0 SITE HISTORY
Standard Auto Bumper has owned the electroplating portion of the
site since 1959. Prior to 1959, this property was divided into 2
facilities: located on the southern half of the site was a
slaughterhouse, and on the northern half of the property was a
furnace/smelting company (Yacco, 1991). In 1959 Standard Auto
Bumper began chromium and nickel plating operations on the site.
Prior to installation of a treatment system in 1972, the wastewater
from the electroplating and stripping process was discharged to a
drainage ditch/swale area west of the facility. In 1972, the
wastewater treatment system was constructed onsite to con.vert
hexavalent chromium to trivalent chromium. Approximately 5,760
gallons of wastewater per day were processed. Between 1972 and
1979 the effluent from the treatment system was discharged to an
underground, slab-covered drainage trench located adjacent to the
treatment tanks. In 1979, use of this trench was discontinued when
1
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FIGURE 1
DADE COUNTY lOCATION MAP
STANDARD AUTO BUMPER
HIALEAH, FLORIDA
DAAIOHG NOT to $CAlL
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STANDARD AUTO BUMPER SITE
a---
APPROXIMATE SCALE
2000
1000 2000
&EPA
FEET )
1 (net) - 2000ft,
FIGURE 2
TOPOGRAPHIC LOCATION MAP
STANDARD AUTO BUMPER
HIALEAH, FLORIDA
SOURCE: USCS MMjEAM. FtORlEA
^ ttmjTt SERIES OUA0RAMOX. 1888
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FIGURE 3
SITE BASE MAP
STANDARD AUTO BUMPER CORPORATION
HIALEAH, FLORIDA
.. E A~BA$( MAP SOURa:: V.s. [PA, EPIC
AERIAL PHOTO 12/20/8V ANO
lOCATIONS lOCA lto IItLA TI~ TO
~ BOUNOARY SVR~Y 01/02/82
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the Hialeah sewer system
discharge. In early 1993,
and abandoned the facility
drums onsite.
became the receptor for the effluent
Standard Auto Bumper ceased operations
leaving tanks with processing water and
With the implementation of the wastewater treatment system and an
acceptable method of discharge (sewer), releases of hazardous.
substances to the environment diminished. However, numerous
illegal discharges of treated and untreated wastes to the ground"
have been documented by Dade County authorities.
A Metropolitan Dade County Department of Environmental Resources
Management (DERM) inspector observed effluent being discharged to
a soakage trench in the back alley on May 10, 1977. The owner was
ordered to correct the violations. However, on November 16, 1981,
a county inspector observed that metal cleaning waste was being
discharged into an on-site drain. A county inspector on June 4,
1982, found open and leaking drums and discharges of plating
liquids onto the ground. A pipe was also discovered leading from
the facility into an off-site ditch. Laboratory analysis by the
county revealed that water in the ditch contained nickel (160
mgfl), chromium (160 mgfl) and copper (7.52 rngfl).
A county Waste Dumping Citation was also issued to the facility on
June 4, 1982, and subsequent inspections found the facility had not
ceased illegal discharges. A Final Notice of Violation was issued
on October 5, 1983. A county inspector, on March 3, 1985, observed
evidence of untreated wastewater discharges into the city sewer
system from the site.
-
On August 14, 1985 soil and groundwater samples collected onsite
contained numerous contaminants associated with metal plating
activities. On December 3, 1985, waste samples collected by county
officials contained concentrations of total cadmium and nickel
which exceeded county groundwater quality standards. On September
10, 1986, county officials observed illegal discharges and an
overflow pipe leading offsite.
An Expanded Site Investigation (ESI) was conducted at the site in
March 1987 by the NUS Corporation, the U.S. EPA Region IV Field
Investigation Team (FIT). Numerous soil and groundwater samples
were collected at the site as part of the ESI, and were used to
document the Hazard Ranking System (HRS) package data and to
expedite the Remedial Investigation (RIfFS).
The ESI samples were analyzed for the parameters in the Hazardous
Substance List. This list, which was a precursor to the Target
Compound List and Target Analyte List, included organic and
inorganic chemicals. Elevated concentrations of heavy metals were
found in the former disposal areas and other areas of interest.
Similar contaminants were identified in the soils, groundwater, and
waste effluent samples, indicating that the source of groundwater
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contamination is soil leachate from the discharge areas. The
detected organic compounds included polynuclear aromatic
hydrocarbons (PARs) and pesticides. PARs are associated with
creosote products that can be found in railroad ties and asphalt
paving. pesticides are not related to the electroplating process
and were not attributed to the Standard Auto Bumper Corp. site. No
groundwater samples contained concentraticns of any organic
compounds above Federal or State drinking water standards.
The ESI recommended excavation of the contaminated soil from
particular areas on-site to decrease the source of heavy metal
contamination. This report also suggested that the extent and
nature of offsite contamination be ascertained. Groundwater
contamination and its extent to the west, and the impact from a
local canal on groundwater flow should be further defined. The
report noted that even with the high transmissivity of the Biscayne
aquifer and the depth of the confining layer, groundwater
remediation was possible.
The site was proposed for inclusion to the National Priority List
(NPL) list in June 1988 and became finalized in October 1989 based
on the HRS package (1987).
Standard Auto Bumper entered-into a consent agreement with DERM in
1988 to implement a Remedial Action Plan (RAP). The plan's
objectives were to address the extent of contamination; design
plans for soil removal, groundwater monitoring and facility
improvements; and establish time schedules and estimate costs for
remediation. Before work outlined in the- RAP began, an
Administrati ve Order (AO) for Removal (1989) between EPA and
Standard Auto Bumper was developed to remove contaminated soils.
The AO for Removal specified soil clean-up levels based on the
Extraction Procedure (E.P.) Toxicity test method for the
contaminants at the site. During the removal action these clean up
goals were reevaluated based on a site-specific soil partitioning
coefficient and the potential for the soil contaminants to migrate
to the groundwater. A cleanup level of 300 mg/kg for nickel was
calculated using a Maximum Contaminant Level (MCL) of 140 ug/l.
DERM proposed an alternative nickel cleanup concentration of 200
mg/kg. EPA concurred with DERM's suggestion and proposed to change
the AO to reflect the new cleanup goal, which would more likely be
attainable at the site. However, the Potentially Responsible Party
(PRP), Standard Auto Bumper, did not respond to this proposal.
In 1989, under the removal AO, the PRP excavated the soil, and
sludge in the bottom of the slab-covered trench and sent it to the
Chemical Waste Management facility in EmelIe, Alabama for disposal.
Soils excavated from the drainage ditch and south areas of the site
were not deemed hazardous waste and were sent to the local
landfill. Confirmatory samples of the soil remaining in the ground
after excavation contained nickel above the cleanup concentration.
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The PRP did not continue excavating and the soil remained in the
ground. This remaining soil was .the focus of the operable unit
(OU) one RI/FS.
On February 28, 1990 an AO by Consent was signed between Standard
Auto Bumper and BPA to implement the RIfFS. Pursuant to the 1990
RIfFS AO, Standard Auto prepared and subroitted a RIfFS Work Plan,
which was approved by the EPA. However, prior to implementing the
work outlined in the plan, the company indicated that they were
financially unable to continue the RIfFS. Subsequently, EPA took
over the site activities anc;l Region IV, Atlanta, performed an
in-house RI/FS. In 1991 EPA conducted soil, sediment, surface
water and groundwater sampling as part of the RIfFS.
The FS for the soil, OU one, was completed in September 1992 and
the ROD issued on September 28, 1992. The ROD determined that all
soil containing concentrations of total chromium, hexavalent
chromium or nickel above 519 ppm, 52 ppm or 370 ppm, respectively,
would be excavated and disposed at a Florida Class I Landfill.
Groundwater monitoring was also specified to determine the
effectiveness of the source remedy.
On October 14, 1992 the EPA issued a notice letter to the PRP,
pursuant to Section 122 (a.) of CERCLA, for the Remedial
Design/Remedial Action (RD/RA). The PRP did not respond and EPA
began the remedial design for the OU one source removal in early
1993. EPA is currently negotiating a State Superfund Contract with
the State of Florida to assure t~e State's cost share of the soil
remedy in accordance with the requirement for a state to share 10%
of the cost of a remedial action which uses Superfund monies.
Emergency Response Contract Support (ERCS) is planning to conduct
the remedial action for EPA. Confirmatory sampling during OU one
will determine that all contaminated soil above cleanup goals
stated above is excavated.
In addi tion to these current remedial acti vi ties, an emergency
removal is being conducted at the site to address the immediate
threats of the drums and tanks left at the abandoned facility.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
Prior to the site-wide RI/FS the EPA conducted an Information
Availability session to introduce the Superfund process and the
site to the community, explain the activities planned for the site,
and answer any questions. The meeting, held on January 10, 1991
in a local school, was publicized in local papers and by do~r to
door canvassing in the community. At the completion of the RIfFS
for OU one, the RI/FS Report and Proposed Plan for the soil were
released to the public in August 1992. Similarly at the completion
of the RI/FS for au two, the RIfFS Report and Proposed Plan for the
groundwater were released to the public in August 1993. All
documents were made available to the public in both the
7:
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Administrative Record and an information repository maintained at
the EPA Records Center in Region IV and the John F. Kennedy
Memorial Library in Hialeah.
The notice of availability for the documents for the second OU was
published in the Miami Herald on August 26, 1993, and the Spanish
newspaper, Diario Las Americas, on August 24 and. 31, 1993.
The Proposed Plan for the groundwater was sent to approximately 500
people in the community, government, and media. A public comment
period was held from August 24 to September 23, 1993. A public
meeting, announced in the public notices and in the Proposed Plan,
was held in the library on September 2, 1993. The purpose of the
meeting was to present the proposed plan and answer questions. No
Hialeah citizens attended the public meeting. One staff member
from DERM attended the meeting and provided a written comment to
EPA in a letter dated August 31, 1993. This comment was the only
comment recei ved during this period and is included in the
Responsiveness Summary, which is part of this ROD (Appendix B) .
4.0 SCOPE AND ROLE OF OPERABLE UNIT TWO
As with many Superfund sites, studying and addressing contaminated
media in the most efficient manner can be a difficult endeavor, due
to complex characteristics of each site. As a result, EPA
organized the site into two OUs: one to address contaminant source
areas (OU one) and the other to evaluate groundwater conditions (OU
two). OU two includes the contaminated groundwater associated with
and emanating from the site. This decision document presents the
selected remedial action for OU two of the Standard Auto Bumper
Corporation Superfund Site, chosen in accordance with CERCLA, as
amended by SARA. The decision for this site is based on the
Administrative Record.
The groundwater poses a principal threat to human health and the
environment due to ingestion of contaminated groundwater by future
residents. The remedial objectives for this au are to prevent
current or future exposure to the groundwater contaminated with
nickel and other inorganic compounds through groundwater use
controls and to restore groundwater to health-based levels through
natural attenuation. .
5.0 SITE CHARACTERISTICS
The nature and extent of the contamination at the site was
investigated during the RIfFS. Based on these studies, a s~ry
of the geology, hydrogeology, subsurface features, and the sampling
results are provided in this section. The discussion on the
sampling studies includes groundwater, surface water and sediment
sampling results.
5.1 GeoloQY
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In south Florida, the upper 3,000 feet of rocks are composed
chiefly of limestone, dolomite, sand, clay, marl, and shells.
Geologically, the Biscayne Aquifer is composed of soils of Holocene
age and rock ranging in age from Pleistocene through Pliocene. The
1987 ESI documented mostly unconsolidated surficial deposits at the
site consisting of calcareous sands and gravels to a depth of
approximately 28 feet below land surface and quartz sands to a
depth of approximately 48 feet. A harder, consolidated bedrock
unit was reportedly encountered below the surficial deposits and
was described as cavity-riddled, fossiliferous, marine limestone.
At the site, the Biscayne Aquifer extends to a depth of
approximately 110 feet below sea level.
Solution cavities occupy a significant volume of the limestone in
the Biscayne Aquifer, causing it to have high horizontal and
vertical peTImeabilities. The lower part of the oolitic limestone
is also cavity riddled and is identified by the presence of
bryozoans. A hard cavernous limestone underlies the bryozoan
layer. Because of the extremely high peTImeability of this
limestone, all large capacity wells are completed in this part of
the aquifer, generally 40 to 100 feet below the land surface.
5.2 Hydrogeology
The uppeTImost hydrogeological water bearing unit in the study area
is the Biscayne Aquifer. The Biscayne Aquifer is the major source
of all the municipal water for the residents of the southeast -coast
of Florida from Boca Raton southward and is composed of limestone,
sandstone, and sand.
The major aquifers in south Florida are composed primarily of
limestone and supply varying yields of potable and non-potable
brackish water for municipal and irrigation water use in southern
Florida. The aquifers, ranging from highest to lowest yield, are:
the Biscayne Aquifer of southeast Florida, the Shallow Aquifer of
South West Florida, and the Coastal Aquifer of Palm Beach and
Martin Counties (Figure 4). Underlying these aquifers is a thick
confining layer composed of relatively impermeable beds of clay and
marl which overlie the Floridan aquifer. .
The Floridan Aquifer in southern Florida is composed of peTImeable
limestone and contains non-potable brackish water. The impeTImeable
beds separating the shallow aquifers and the deeper Floridan
aquifer shield against the upward intrusion of brackish water.
However, there is no shield against the lateral encroachment of
seawater.
Recharge to the Biscayne Aquifer is primarily by local rainfall.
Infiltration is rapid in the areas covered by sand, or where soil
is absent. In the site vicinity, the soil type consists of fine
quartz sand. Discharge is by evapotranspiration, canal drainage,
coastal seepage, and pumping.
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LEGEND
2z
- BSCATNE AQUlFtR. MCM IIOO
• SHALLOW AQUIFER OF SOUTH WEST FLORIDA.
MODERATE TO MICH T1CLD
• COASTAL AQUIFER Of PALM BEACH AMD
MARTIN COUNTIES. MODERATE YIELD
- LOCAL, DISCONTINUOUS. WATERBEARING
MATERIAL. LOW YIELD
• UNE Or EQUAL DEPTH OF BASE Of AQUIFER
FEET BELOW SEA LEVtL (NCVD29)
(EOUffXSTANCE - 20 FEET - 6.1 METRES)
FIGURE 4
SHALLOW AQUIFERS
IN
SOUTHERN FLORIDA
&EPA
STANDARD AUTO BUMPER
HIALEAH, FLORIDA
APPROXIMATE SCALE
23 0 12.S 25
(IN MILES)
.1 In. - 25 miles
(UodfUd from KMn on4 otnvm. 1975. 009*
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Transmissivity (T) of the Biscayne Aquifer ranges from 5.4 X 104
ft2/day (581 cm2/sec) where the aquifer is mostly sand to greater
than 1.6 X 106 ft2/day (17,200 cm2/sec) in the limestone-rich areas.
During the ESI conducted in 1987, site specific values of hydraulic
conductivity (K) were determined to range between 42.8 ft/day
(0.0151 cm/sec) to 102 ft/day (0.036 cm/sec) or an average of 62.6
ft/day (0.0221 cm/sec). Using the relationship T=Kb, a site
specific value for the transmissivity of the unconsolidated
calcareous sands and gravels and quartz sand zone can be estimated:
T = 62.6 ft/day X 48 ft = 3000 ft2/day (32.3 cm2/sec). This site
specific value for the transmissivity of the unconsolidated zone is
an order of magnitude lower than the published value for the sandy
portion of the Biscayne Aquifer.
Regional flow of ground water in the Biscayne Aquifer of southeast
Florida is seaward. Locally, however, the direction and rate of
flow may be significantly influenced by the direct surface water
connection of the canal system, other surface water features,
and/or by pumping from well fields.
5.3 Subsurface Features
In the northwest corner of the site there is an unused underground
storage tank. A gas line extends from the east side to the west of
the site on the north edge of the property. No other.underground
structures are known to exist at the site.
5.4 Samplinq Results
The following summarizes groundwater sampling data contained in the
RI Report on Groundwater Conditions at the Standard Auto Bumper
Corporation Site, May 1993. The surface water and sediment
sampling results addressed during OU one are also briefly described
due to the groundwater's potential impact on surface waters. This
information was culled from the RI Report for Standard Auto Bumper
Corporation, July 1992. Both of these documents can be found in
the Administrative Record.
5.4.1
Groundwater
The primary purpose of the groundwater RI/FS was to determine the
condition of the groundwater by intermittently sampling the
groundwater at the site over a year and a half period. From April
1991 through November 1992 four rounds of groundwater samples were
collected from the monitoring wells onsite and offsite.
Similar contaminants were detected in the groundwater during each
of the four sampling events at the site. The sampling phases were
as follows:
.
Preliminary RI Phase in April 1991
Phase I.in January 1992
.
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.
Phase II in May 1992
Phase III in November 1992
.
This periodic sampling provided an accurate determination of
contaminant concentrations and groundwater flow direction. Highest
concentrations of contaminants were consistently found in offsite
monitoring well MW-2S, located downgradient and adjacent to the
drainage ditch on the western side of the building.
During the Preliminary RI Phase all existing monitor wells at the
site were sampled. Federal Maximum Contaminant Levels (MCLs) for
chromium, lead and arsenic and Florida Drinking Water Standards
(DWS) for chromium, copper, iron, lead, manganese, and arsenic were
exceeded in most groundwater samples collected during the
Preliminary RI Phase. The groundwater regulatory levels are shown
in Table 1 and contaminant concentrations are shown in Figure 5.
The Preliminary RI Phase was the only time when the deeper
monitoring wells exceeded MCLs or primary DWS.
During Phase I, the Secondary MCL (SMCL) and secondary DWS for
iron, the MCLs for chromium, nickel, and lead, and the primary DWS
for chromium and lead were exceeded in the temporary monitoring
wells (Figure 6). In the permanent monitoring wells chromium,
nickel and lead concentrations exceeded MCLs (Figure 7).
Hexavalent chromium; the more toxic form of chromium, was not
detected in any of the shallow monitoring wells.
Phase II of the RI yielded results that were a departure from the
earlier observed conditions (Figure 8). No chromium, copper, lead
or zinc was detected in the shallow monitoring wells. Nickel was
the only contaminant which exceeded the MCL in the shallow
monitoring wells. No MCLs or primary DWS were exceeded in the
deeper monitoring wells. Two new deep monitoring wells, that were
installed as part of Phase II, contained the most inorganic
analytes. The RI Report determined that the low concentrations of
chromium, nickel, lead, and zinc slightly above their respective
detection limits and only in these two deep monitoring wells did
not appear to be indicative of representative groundwater
concentrations. It was noted that aluminum levels in these two
monitoring wells were two orders of magnitude higher than in any
other sample. Based on these results, and the sample clarity with
respect to that obtained in the other shallow or deep groundwater
samples, it is likely that the samples were collected prior to
adequate development of the wells.
The fourth and final round of sampling, Phase III, confirmed the
results found during the third round of sampling, Phase II.
Sampling results are contained in Appendix A. Chromium, copper,
and lead were not detected in any of the ground water samples from
the shallow or deep monitoring wells. In the shallow monitoring
wells, nickel concentrations slightly exceeded MCLs in two onsite
groundwater samples (120 ug/l in MW-4S and MW-11S) and in an
12
-------
TABLE 1
GROUNDWATER REGULATORY LEVELS
MCL SMCL PDWS SDWS
Chemical (ppm)
Aluminum 0.2
Arsenic 0.05 0.05
Chromium 0.1 O.1b
Copper 1.0
Iron 0.3 0.3
Lead O. 015a i 0.05
Manganese 0.05 0.05
Nickel 0.1 0.01
Zinc 5 5
a
b
MCL
SMCL
PDWS
SDWS
ppm
Action Level
level currently being revised from 0.05 to 0.1
Maximum Contaminant Level
Secondary Maximum Contaminant Level
Florida Primary Drinking Water Standard
Florida Secondary Drinking Water Standard
parts per million
13
-------
CHRONIU,", '80
CHRQMUN 880 COPPER '8
C()PPER -- LŁAD --
UAO "0 NICKEL 44
HIALEAH NtCKEl J~ CYANlOt --
AMOCO CYANIOŁ --
S1 A liON
WORLD
METALS
'"
,.
en
....
QUALITY
MANUr ACTURING
PROOUCTS
o
0
,.
en
....
'" ~
8 ~a CHROMIUM 8300
'" COPPER 8'0
0 IIAO 280
~ ,.:o NICKEl 13.000
~~ CVANIOE '.2
0
,. C
Z C MW- 2S
,.
,.. GILDA
. )(
BAKERY
FACILITY
"
~
!ii
0
CHROMIUM '20 ~
COPPER 800
LŁAD 180
NICKŁl 8.100 )(
CY~IDŁ --
MW-3S .
en
'tI
C
"
lJLJ
RIO'S
CONCRETE
Q K K
~ D )(
~ TRI-MOR
GlASS
Ie'
a.
0
8 RAMAS BROTHERS
:0 AUTO REPAIR
....
MW-IIS
.
K
~ON1UN 120
COPPER 20
lEAD --
NICKn. 230
CYAJ.fIDE --
W-7
D
CCJD
I
STANDARD
AUTO
BUMPER
.
- EXISTING MONITORING WELL
- INDUSTRIAL WELL
ALL CONCENTRATIONS IN I1-g/1
D
r
FERNANDEZ
~TRANSPORT
CORPORATION
GRAPHIC
100 0
~~
SCALE
50 100
I_.-J
( IN FEET )
FIGURE 5
CONCENTRA TIONS OF SELECTED
INORGANIC ANAL YTES DETECTED IN
GROUND WATER FROM EXISTING WEllS
DURING THE PRELIMINARY
RI SAMPLING PHASE, (04/91)
STANDARD AUTO BUMPER CORPORATION
HIALEAH, FLORIDA
A E A~9ASC IIAP SOVRCt: u.s. CPA, (PIC
AERIAL PHOTO 12 20 g AND
~/1 LOCA nONS LOCA I{D rrlA n\'[ TO
~ BOUNDARY SURIof:Y DI/02/g2
N ACHON
lUMBER
4
-------
r
e
=->
o
i5
o
~
»
...
~
~~
".0
»=->
~~
c:
D
CHROMIUM
COPPER
LEAD
NICKEL
CYANIDE
HIALEAH 5 LJLJ
=-> RIO'S
AMOCO 6 CONCRETt:
ST A 110N »
WORLD D[q]
METALS X
D )(
~
VI
....
OUALITY TRI-MOR
MANU, ACTURINC ~ CLASS
PRODUCTS I('
CHROMIUM Q.
(") (")
32 0 COPPER g RAMAS BROTHERS
CHROMIUM » LEAD
22 VI '" AU TO REPAIR
COPPER .... NICK EL 21 ....
LEAD 130 CYANIDE
NICKEL 30
CYANIDE
19
8.5
37
o
0
CILDA
BAKERY
06 ,AClLI TY
CHROMIUM 75 '"
1!.
COPPER 48 !ii
LEAD 160 0
NICKEL 66 ~
CYANIDE
CHROMIUM 410
COPPER 27
LEAD 200
T10 NICKEL 100 !(/
CYANIDE c:
'"
T12
CHROMIUM 66 T14
COPPER 27
LEAO
NICKEL 48
CYANIOE
NACHON
LUMBER
)(
I
)(
STANDARO
AUTO
BUMPER
CHROMIUM 16
COPPER 16
LEAD
NICKEL
CYANIDE
310
13
T16
15
X
117
D
o=JD
I
)(-
)(
ED - TEMPORARY WEll
ALL CONCENTRATIONS IN J.Lg/1
CHROMIUM
COPPER
LEAD
NICKEL
C Y ANIOE
J20
110
110
870
GRAPHIC
100 0
~-.......-J
SCALE
50 100
L~
( IN .EET )
FIGURE 6
CONCENTRA TlONS or SELECTED
INORGANIC ANAL YTES DETECTED IN GROUND
WATER mOM TEMPORARY MONITORING
YfrLLS DURING THE PHASE I RI (OI-02{92)
STANDARD AUTO BUMPER CORPORATION
HIALEAH, FLORIDA
oft E R~8ASE MAP SOURCE: U.S. EPA, EPIC
~ AERIAl. PHOTO 12/20/ll~ AND
lOCA nONS lOCA '!to ~ElA n~ TO
80UNDARY SUR~Y 0' ID2/~2
-------
8 QUALITY
MANUF ACruRINC
~ PROOUCTS
....
CHROI.IIUI.I
CHROMIUM 840 COPPER
COPPER 110 LEAD
:» ~ LEAD J8 NICKEL 100
8 NICKEL 260 CYANIDE
:» ~~ CYANIDE
0 :r0
/5 ,.:0 CHROI.IIUI.I
Sl ~~ COPPER 29
c: LEAD
z .!:}
~ NICKEL
GILDA " :CYANIDE
BAKERY
fACILITY
CHROMIUM '"
~
COPPER !ii
LEAD 7.9 0 STANDARD
NICKEL 140 ~ AUTO
CY ANIOE BUMPER
03S "
x
CHROMIUM III CHROMIUM "J
" COPPER
COPPER 125 c LEAD "
LEAD '"
NICKEL 4SR NICKEL 220
CYANIDE CYANIDE
-x
C 0
~ FERNANDEZ
TRANSPORT
CORPORAnON
NACHON
LUM8ER
CHROMIUM
COPPER
LEAD
NICKEL
CYANIDE
15
UU'
RIO'S
CONCRETE
Dl~ . 0
><
WORLD
METALS
CHROMIUM
COPPER
LEAD
NICkEL
CYANIDE
TRI-MOO
ClASS
RAMAS BROJHERS
AUTO REPAIR
D
fIJD
--~
CHROMIUM
COPPER
LEAD
NICKEL
CYANIDE
J.EW!Q
. - EXISllNC MONITORINC 'M:LL
. - INDUSTRIAL WELL
ALL CON CENTRA TIONS IN JJ.g/i
GRAPHIC
100 0
~-......-1
( IN FEET )
SCALE
50 100
L---1
FIGURE 7
CONCENTRAll0NS OF SELECTED
INORGANIC ANAL YTES DETECTED
IN GROUND WATER FROM PERMANENT
WELLS DURING THE
PHASE 1 RI, (01-02/92)
STANDARD AUTO BUMPER CORPORATION
HIALEAH. FLORIOA
A E ~~9A$[ IIAP SOURCC: u.s. CPA, EPIC
~ AERIAL PHOTO 12/20/89 AND
lOCA liONS LOCATED m:lA 1111( TO
BOUNDARY SURlI(y 01/02/92
16
-------
IlIr
HIALEAH
AMOCO
STAtiON
5
:0
6
»
o
0
»
(II
-<
CHROMIUM
COPPER
:0 ~ LEAD
13 NICKEL 300
:o ..i:! CYANIDE
0 !To
~ »:0
0 ~~
~ c:
l!- !:J
GILDA
BAKERY
rACILITY
CHROMIUM '"
~
COPPER ~
LEAD 0
NICKEL 35 c;
CYANIDE 10
OJS "
CHROMIUM (II
COPPER "
12S c:
LEAD :0
NICKEL
CYANIDE
CHROMIUM 52
COPPER
LEAD 6.2
NICKEL 25
CYANIDE
NACHON
LUMBER
CHROMIUM
COPPER
LEAD
NICKEL
CYANIDE
WORLD
METALS
QUALITY
MANUr ACTURING
PRODUCTS
CHROMIUM
COPPER
LEAD
NICKEL
CYANIDE
CHROMIUM
COPPER
LEAD
NICKEL
CYANIDE
STANDARO
AUTO
BUMPER
CHROMIUM
COPPER
LEAO
4SR NICKEL
CYANIDE
67
~ rERNANOEZ
TRANSPORT
CORPORATION
17
LJU
RIO'S
CONCRETE
Dl~ . D
iE
Ie'
a.
CHROMIUM
COPPER
LEAD
NICKEL
CY ANIOE
TRI-MOR
GlASS
RAMAS BROTHERS
AUTO REPAIR
65
x
D
[DO
--~
"J
"
. -
~
EXISTING MONITORING M:LL
INDUSTRIAL WELL
CHROMIUM
COPPER
LEAD
NICKEL
CYANIDE
. -
ALL CONCENTRATIONS IN 11-9/1
14D
CHROMIUM
COPPER
LEAO
NICKEL
CYANIDE
GRAPHIC
100 0
~-..-J
82
SCALE
50
I
100
I
'4
( IN FEE T )
flCURE 8
CONCENTRATIONS OF SELECTED INORGANIC
ANAL YTES OETECTED IN GROUND WATER FROM
PERMANENT WELLS DURING
THE PHASE 2 RI, (05/92)
STANDARD AUTO BUMPER CORPORATION
HIALEAH, flORIDA
.. E R~8As( MAP SOURCE: U.S. [PA. EPIC
~ AERIAL PHOTO 12/20/89 AND
lOCATIONS lOCATID IIE1ATlIIE TO
bOUNDAAY SURIlEY 01/02/82
-------
offsite groundwater sample (270 ug/l in MW-02). Secondary DWS for
aluminum and iron were exceeded in the shallow monitoring wells
also.
In all four deeper monitoring wells and the one onsite industrial
well, nickel was undetected and all contancinants were below the
MCLs and primary DWS. The fact that secondary DWS for iron were
exceeded in all the deep monitoring wells, the industrial well, and.
seven of the eight shallow monitoring wells may indicate that high
iron levels are widespread in this industrial area. The secondary
DWS for aluminum was only slightly exceeded in one deep monitoring
well. Table 2 contains a sununary of the results of the groundwater
analysis during the fourth round of sampling, including the
contaminants detected, the range of concentrations, frequency of
detection, detection limit (DL) and background/control levels.
Because the shallow and deeper aquifers lacked any definitive
hydrogeologic layer separating the contaminants detected, the
groundwater sampling data from both the shallow and deeper wells
were combined. Selected groundwater contaminant concentrations for
the final round of sampling are depicted in Figure 9.
The RI data indicates a trend towards decreasing chromium
concentrations, particularly in the monitoring well where most of
the high contaminant levels-- have been found, MW-02. Offsite
chromium migration in the groundwater was not observed. The RI
Report determined that nickel is the only one of the five chemicals
selected in the report as the contaminants of interest (chromium,
copper, lead, nickel, and cyanide) that currently impacts the
groundwater. The DWS for nickel was only slightly exceeded in the
two onsite monitoring wells during the fourth and final round of
sampling. . Nickel exceeded its DWS in one offsite monitoring well
(MW-2S), approximately 20 feet from the site, during the last
sampling event; however, the level was the lowest concentration for
that well detected during any of the sampling events. There has
been a noticeable decrease in the nickel concentration during each
sampling event as shown in Figure 10. The RI report stated that
there was a change in sampling method between April 1991, and
January 1992, that may have accounted for a majority of this
decrease. However, after January 1992, sampling methods remained
the same and the decrease continued. No vertical migration was
observed during the sampling events. Horizontally, nickel appears
to be somewhat localized to the site, but is influenced by the
fluctuating groundwater flow direction.
The RI documented fluctuating directions and rates of groundwater
flow in the Biscayne Aquifer. The groundwater movement in the
aquifer appears to be directly influenced by the canal system
(particularly nearby Red Road Canal) and the pumping from wells in
the vicinity of the site.
The data confirmed that the source of groundwater contamination is
most likely the contaminated soil in the former drainfield area
18
-------
TABLE 2
CONTAMINANTS DETECTED IN GROUNDWATER SAMPLES
(ug /l)
CONTAMINANT
DETECTED
CONCENTRATION
RANGE
DETECTION
LIMIT
AVERAGE
CONCENTRATION
OF DETECTED
BACKGROUND
LEVEL
DETECTION
FREQUENCY
--
---
---
---
---
--
Bariwn 12 - 36 NA 19.8 17 12/12
Nickel 26 - 270 20 134 20U 4/12
Strontiwn 360 - 870 NA 726 830 13/12
Titaniwn 11 - 15 10 13 10U 2/12
Zinc 12 - 81 10 24.2 17 11/12
Alwninwn 120 - 460 100 278 100U 4/12
Manganese 11 - 50 10 24.3 23 11/12 .
Calciwn 57000 - 89000 NA 76499 94000 12/12
Magnesiwn 2700 - 10000 NA 7325 7200 12/12
Iron 180 - 2700 NA 1031 2300 12/12
Sodiwn 17000 - 45000 NA 35916 37000 12/12
potassiwn 2100 - 3200 2000 2481 2800 8/12
NA: Not Available
Sources:
Final Baseline Risk Assessment for the Groundwater Pathway,
Standard Auto Bumper S~te
Remedial Investiqation Report on Ground Water Conditions at the
Standard Auto Bwnper Corporatlon S~te
19
-------
IAr
e
:v
o
~
~
z
,.
....
CHROMIUM
COPPER
I.ŁAO
NICKEL
CYANIDE
HIAIŁAH
AMOCO
ST A 110N
~
~~
:70
,.",
2~
c
.!:)
CHROMIUM
COPPER
lEAD
NICKEL
CYANIDE
CHROMIUM
COPPER
LEAD
NICKEL
CYANIDE
125
NA
NACHON
LUMBER
GILDA
BAKERY
r ACILITY
5
'"
6
,.
26
-NA
:v
~
r;;
o
~
OJS
111
"
C
:tI
NA
CHROMIUM
COPPER
LEAD
NICKEL
CYANIDE
NA
WORLD
ME T AlS
QUALITY
MANur ACTURING
PROOUCTS
CHROMIUM
COPPER
IŁAD
NICK EL
CYANIDE
x
CHRQMIUM
COPPER
LEAD
NICKEL
CYANIDE
NA
STANDARD
AUTO
BUMPER
x
CHROMIUM
COPPER
IŁAD
4SR NICKEL
CYANIDE
120
NA
x
b- rERNANDEZ
TRANSPORT
CORPORA 110N
20
LjLJ
RIO'S
CONCRETt
Dl~ . D
:E
I('
Q.
CHROMIUM
COPPER
LEAD
NICKEL
CYANIDE
120
NA
x
x
I
x-
x
CHROMIUM
COPPER
LEAD
NICKEL
CYANIDE NA
f
CHROMIUM
COPPER
LEAD
NICKEL
CYANIDE NA
..
TRJ-MOR
GLASS
NA
RA~IAS BROTHERS
AUTO REPAIR
D
r=cJ 0
~;~
ill.E.!::!Q
. - EXISl1NG MONITORING 'M:LL
. - INOUSTRIAL WELL
ALL CONCENTRATIONS IN Jl.9/1
GRAPHIC
100 0
~-...,rJ
SCALE
50
I
100
I
( IN FEET)
FIGURE 9
CONCENTRA 110NS or SELECTED
INORGANIC ANAL YTES DETECTED
IN GROUNDWATER rROM PERMANENT
WELLS DURING THE rQURTH
ROUND or SAMPLING, (11/92)
STANDARD AUTO BUMPER CORPORATION
HIALEAH, FlORIDA
.. E A~eAs[ IIAP SOURCE: U.S. EPA. EPIC
~ AERIAl. PHOTO 12/20189 AND
LOCATIONS lOCATtD IItlAT1\1: TO
BOUNDARY SUR\IŁY 01/02/92
-------
Concentration (ppb)
14,000
12,000
FIGURE 10
Nickel Concentration
Monitoring Well MW-2S
"....... """"""'''''''''......,.....,.......,.............."[[["""""""""""""""""""""""""""'"""""""""""""""""""""''''''''''''''''''''""""""""""""""""""''''''''
10,000 ."........................ [[["..""''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''""""''''''''''''''''''''''''''''''''''''''''''''''''''''''''''[[[
8,000 """""""""'"'''''''''''''''''''''''' [[["""""""""'"''''''''''''''''''''''''''''''''''''[[["......"''''''''''''''''''''''''''''''''''''''''''''''''''''''''''
6,000 """"'"'''''''''''''''''''''''''''''''''''''''''''''''''''' ",,""""""''''''''''''''''''''''''''''''''''''''''''''''""""'"''''''''''''''''''''''''''''''''''''''''''''''''""'"''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''"''''''''''''''''''''''''''''
4,000 ""'"'''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' """"""""""''''''''''''''''''''''''''''''''''''''''"'"''''''''''''''''''''''''''''''''''''''''''''''''''''''""",,,,,,,,"""'"''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''
-------
north of the building and the surface drainage areas west and south
of the facility building, as determined during the soil
investigation for OU one. During OU one, contamination was found
in some of these areas in soil located six feet below the surface
where soil interfaces with groundwater.
5.4.2
Surface Water and Sediment
Three sediment samples and surface water samples were collected in
Red Road Canal and analyzed for TCLfTAL and TAL , respectively. The
sediment samples contained metals which did not appear to be
related to the site, with the exception of lead at a maximum
concentration of 120 mgfkg. The surface water samples from the
same location contained no detectable chromium, copper, cadmium,
nickel, lead, arsenic, or cyanide.
The RI for the soils concluded that surface water data could not be
correlated with the soil and groundwater data for the site. Also
the upgradient surface water concentrations were nearly identical
to the downgradient concentrations.
6.0 SUMMARY OF SITE RISKS
As part of the RIfFS, EPA prepared a Baseline Risk Assessment for
the Standard Auto Bumper Corp. site. This risk assessment was
carried out to characterize, in the absence of remedial action
(i.e., the "no-action" alternative), the current and potential
threats to human health and the environment that may be posed by
exposure to contaminants migrating from the groundwater. Results
are contained in the Final Baseline Risk Assessment report, July
1993. The assessment considers environmental media and exposure
pathways that could result in unacceptable levels of exposure now
or in the foreseeable future. Data collected and analyzed during
the RI provided the basis for the risk evaluation. The risk
assessment process can be divided into four components:
contaminant identification, exposure assessment, toxicity
assessment, and risk characterization.
6.1 Contaminants of Concern
Contaminants of concern (COCs) are contaminants that are detected
in the groundwater and that may pose health risks to humans coming
in contact with them. The contaminants of concern identified for
this site are shown below in Table 3. Estimates are also made for
concentrations of COCs used to estimate the uptake by exposed
populations. In general, the 95% upper confidence limit (UCL) of
the arithmetic average is used as the exposure concentration value
unless the 95% UCL exceeds the maximum concentration of the COCo
For this risk assessment, maximum concentrations of the COCs were
used for all exposure point concentrations. The range of detected
concentrations, which includes the maximum values for these COCs
are included in Table 2 presented earlier in this document.
22
-------
TABLE 3
CONTAMINANTS OF CONCERN
GROUNDWATER
Barium
Manganese
Nickel
Zinc
6.2 Exposure Assessment
The exposure assessment estimated potential adverse health effects
that may result from exposure to hazardous constituents in the
groundwater at the site. The analysis identified and quantified
risk for four different potential exposure receptors, the current
onsite worker, the current site visitor, the hypothetical future
adult resident and future child resident. The EPA, OSWER Directive
9355.0-30, April 22, 1991, asserts that "The potential land use
associated with the highest level of exposure and ri'sk that can
reasonably be expected to occur should be addressed in the baseline
risk assessment. Further, this land use and these exposure
assumptions should be used in developing remediation goals".
Based on EPA guidance and the industrial nature of the site and
surrounding businesses, future industrial land use at this site was
primarily considered. However, since residences are located near
the site, future residential land use was evaluated. Businesses
which surround the site include a car repair, a junk yard, a
trucking company, a lumber company, gas stations, a hardware store,
and a bakery. These companies are all located on the same block as
Standard Auto Bumper or are across the street from the site. The
nearest residence to the site is located approximately 350 feet to
the west.
No current exposure routes were identified for the onsite workers
and site visitors because there are no public or private drinking
water wells in the area. Regardless, oral exposures were evaluated
in the risk assessment. Inhalation exposure could not be
determined since metals do not volatilize. Dermal exposure would
produce negligible results since heavy metals do not readily
penetrate skin tissue. Receptors subjected to reasonable maximum
exposure under a future scenario are hypothetical residents who
would live onsite and use the groundwater for drinking and
household purposes. All receptors were exposed to either the
reasonable maximum exposure or the maximum concentration detected.
23
-------
Reasonable maximum exposure point concentrations of contaminants of
concern in the groundwater were estimated to quantify intakes of
chemicals for each exposure pathway. General assumptions for the
calculation of the intake factor regardless of pathway and specific
assumptions for each exposure scenario were used to estimate
intakes. Assumptions for the hypothetical residential exposure.
scenario include: 1) the body weights for the adult and child are
70 kg and 15 kg, respectively, 2) the exposure frequency is 350
days/year, 3) the national upper-bound time at. a single residence
is 30 years for an adult and 6 years for a child, 4) the exposed
skin area for the adult and child is approximately 5300 crn2 and
5000 cm2, respectively, 5) the adult's average time (AT) for
noncarcinogenic chemicals exposure is calculated by averaging 365
days/year over a period of 30 years to yield an AT of 10,950 days,
and 6) the child's AT for noncarcinogens is 6 years x 365 days/year
or 2190 days.
6.3 Toxicity Assessment
To assess the possible toxicological effects from exposure, health
effects criteria are derived from a review of health and
environmental standards and published toxicological studies.
Toxicity values were extracted from the Integrated Risk Information
System. For the risk assessment, contaminants are separated into
two toxicity categories, depending on whether they exhibit
carcinogenic or noncarcinogenic effects. None of the cacs at this
site were carcinogens. Therefore, noncarcinogenic hazard risk
levels were determined for each cac in each exposure scenario.
Toxicity values, which estimate the relationship between the dose
and response, were determined to assess exposure risk levels for
the ingestion of groundwater pathway.
Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects from exposure to cacs
exhibiting noncarcinogenic effects. RfDs, which are expressed in
units of mg/kg-day, are estimates of lifetime daily exposure levels
for humans including sensitive individuals. Estimated intakes of
cacs from environmental media (e.g., the amount of a cac ingested
from contaminated drinking water) can be compared to the RfD. RfDs
are derived from human epidemiological studies or animal studies to
which uncertainty factors have been applied (e.g., to account for
the use of animal data to predict effects on humans). These
uncertainty factors help ensure that the RfDs will not
underestimate the potential for adverse effects to occur. The RfDs
utilized in the risk assessment are listed on Table 4.
6.4 Characterization of Risk
Potential noncarcinogenic and carcinogenic risks posed by the
contaminants of concern in the various exposure pathways were
evaluated for the risk assessment; however, all the cacs for this
site are noncarcinogenic. The potential for noncarcinogenic
24
-------
TABLE 4
NONCARCINOGENIC TOXICITY VALUES
FOR CONTAMINAN'l'S OF CONCERN
CONTAMINANT
INGESTION RfD
(mg/kg-day)
----
Barium
Manganese
Nickel
Zinc
7.0E-02'
S.OE-03'
2.0E-02'
3.0E-01'
1
IRIS (EPA 1993)
-.
Source: Final Baseline Risk Assessment for the Groundwater Pathway, Standard Auto Bumper
25
-------
effects was evaluated by comparing an exposure level over a
specified time period (e.g., life-time) with a reference dose
derived for a similar exposure period. The ratio of exposure to
toxicity is called a hazard quotient. Hazard quotients were summed
in order to screen for possible cumulative effects due to exposure
to yield a hazard index. If either the hazard quotient or the
hazard index exceed one, the potential for adverse health effects
exists.
The noncarcinogenic risk levels for the groundwater are presented
in Table 5. All COCs have hazard quotients less than one for the
future hypothetical adult resident; therefore, the hazard index is
below one. Barium and zinc posed cumulative hazard quotients below
one for the future hypothetical child resident. However I manganese
and nickel exceeded the acceptable hazard quotients for the child
resident scenario, contributing to an overall hazard index of 3.07.
By combining the hazard quotients of the adult and child
residents, it is possible to determine an overall future hazard
index. The noncarcinogenic hazard index for the hypothetical
resident associated with ingestion of groundwater is 3.728.
In summary, an unacceptable noncarcinogenic risk is present,
primarily from nickel and manganese at this site. Actual or
threatened releases of hazardous substances from this site, if not
addressed by implementing the response action selected in this ROD,
may present an imminent and substantial endangerment to public
health, welfare, or the environment.
6.5 Environmental Risks
As discussed earlier, this site is located in an
industrial/commercial setting and was expected to have limited
environmental impacts. The primary habitats identified at the site
and surrounding areas are limited grass areas. This site does not
provide many habitat resources for wildlife, due to the industrial
nature of the site. Canals in proximity to the site also serve as
habitats. The site and canal sampling data and the nature of the
relationship of the canal to the site do not indicate there is an
offsite environmental risk. Contaminants identified in the Red
Road Canal have not been determined to be from the site and
upgradient surface water samples were similar to downgradient
concentrations. Sediments indicate minor levels of contamination
that are not necessarily linked to the site, i.e. lead exceeded its
Effects Range-Low (ER-L) concentration in sediments, but lead was
.not detected in the three monitoring wells west of the site during
the past two groundwater sampling events. DERM has been made aware
of these results for the canal. It is likely that the lead and
zinc could be a result of traffic or industrial influences and not
the site. Contamination from the site via surface water discharge
is not likely due to the businesses, elevated railroad, and four-
lane road located between the site and the canal.
26
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. CONTAMINANT
TABLE 5
HAZARD QUOTIENTS FOR INGESTION OF GROUNDWATER
FOR FUTURE HYPOTHETICAL RESIDENTS
AVERAGE
DAILY INTAKE
(mg/kg-day)
ORAL
REFERENCE DOSE
(mg/kg-day)
HAZARD
QUOTIENTS
~
-----
----
Barium
Manganese
Nickel
Zinc
Łhili
Barium
Managanese
Nickel
Zinc
Source:
----
-----
9.86E-04
1.37E-03
7.26Ł-03
2.22E-03
7.0E-02
5.0E-03
2.0E-02
3.9E-01
1. 41E-02
2.74E-01
3.63E-01
7.40E-03
6.58E-01
HAZARD INDEX:
4.61E-03
6.40E-03
3.39E-02
1. 04E-02
7.0E-02
5.0E-03
2.0E-02
3.0E-01
6.59E-02
1.28E+00
1. 69E+00
3.47E-02
HAZARD INDEX:
3.07E+00
-.
Final Baseline Risk Assessment for the Groundwater Pathway, Standard Auto Bumper
27
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.,-
No occurrences of Federally or State protected species or habitats
were identified for the site.
6.6
Remediation Goals
The risk assessment determined site-specific remediation goals for
the groundwater to initially establish levels suitable for
. drinking. Because all the COCs have MCLs, the MCL values were
utilized as remedial goals for this site. The remediation goals
for the COCs are included in Table 6. Site groundwater samples did
show aluminum and iron above State secondary DWS. Those standards
are included in Table 6 also.
7.0 DESCRIPTION OF ALTERNATrvES
Based on the results of the RI and Baseline Risk Assessment, EPA
concluded that former operations conducted at the Standard Auto
Bumper facility have resulted in the contamination of groundwater
in close proximity to the site. A feasibility study was conducted
to develop and evaluate remedial alternatives for contaminated
groundwater at the site. Preliminary remedial alternatives were
assembled from applicable remedial technology process options and
were initially evaluated for effectiveness, implementability, and
cost. Based on this evaluation, the following remedial
alternatives were selected for the site. The NCP requires that a
no action alternative be considered at every site to serve
primarily as a point of comparison for other alternatives.
7.1 Alternative 1 - No Action
This alternative does not provide any remedial activities to
address the source of contamination. Monitoring for at least 30
years would be included to evaluate trends in the contaminants'
concentrations in the groundwater. Existing monitoring wells would
be used for long-term groundwater monitoring.
Because this alternative would result in contaminants remaining on-
site, CERCLA requires that the site be reviewed every five years.
If indicated by the review, remedial actions would be implemented
at that time to address the contaminated groundwater.
As stated above, the No Action alternative was considered as a
baseline option for comparison to other remedial action
alternatives. The total present worth cost, due to the operation
and maintenance (O&M) costs for groundwater monitoring activities,
is $94,700. No construction is involved with this alternative.
7.2 Alternative 2 - Natural Attenuation and Institutional Controls
Institutional controls, or access controls, refer to obtaining
28
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TABLE
6
REMEDIATION GOALS FOR WATER
CONTAMINANT
MAXIMUM
CONTAMINANT LEVEL
(mg/l)
----
Bar i um
Manganese
Nickel
Zinc
21
0.05'
0.11
5'
1
2
MCL
SMCL
CONTAMINANT
SECO.t'lDARY STATE
DRINKING WATER
STANDARD
(mg/l)
----
Aluminum
Iron
0.2
0.3
Source: Final Baseline Risk Assessment for the Groundwater Pathway, Standard Auto Bumper
29
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easements or other instruments from property owners above
groundwater exceeding the cleanup level guaranteeing that they will
not use water from the surficial aquifer for drinking water
purposes. The agreements would remain in force until at least one
year beyond such time as the groundwater cleanup level is achieved.
The covenants run with the land and so once the agreement is
recorded, the prohibition on groundwater use would be enforced
against the current landowner and all subsequent purchasers of the
property.
This alternative would also provide for groundwater monitoring to
ensure that contaminant levels decrease during natural attenuation
of the groundwater or that contamination is not migrating.
Monitoring would continue for at least one year after the
concentrations in all monitored wells decrease below the cleanup
levels. Should any concentrations above cleanup goals be detected
within this post-remediation monitoring period, actions would be
taken to verify the contaminant levels, and, if verified,
additional control measures would be triggered. One of the two
extraction alternatives would be implemented as a contingency
remedy.
The cost of this alternative is dependent upon obtaining deed
restrictions. It is estimated that these could be put in place
within a few months. Capital costs for the institutional controls
or deed restrictions are estimated at $19,250. The O&M would
include the same activities and costs as those described for
Alternative 1 ($94,700). Total present worth costs for Alternative
2 are $113,950.
7.3
Alternative 3 - Extraction and Discharge
This alternative would control the plume and recover contaminants
from the groundwater to actively reduce the contaminants'
concentrations. The contaminated groundwater would be collected
through a single recovery well or a series of recovery wells and
piped to a central location onsite. Extracted site groundwater
would then be pumped to the sewer system where it would flow to the
local publicly owned treatment works (POTW) after EPA receives
approval from DERM for disposal. Dilution of the contaminant
concentrations would occur upon mixing with the other wastewater in
the sewer system. Long-term periodic groundwater monitoring would
document that contaminated groundwater is being removed from the
groundwater.
Alternative 3 is projected to require four months. for
implementation. Assuming three recovery wells are utilized, the
estimated construction costs for this remedial action are $554,825
and the estimated annual O&M costs are $212,150. The total present
worth cost for this alternative is approximately $3,816,101.
30
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7.4 Alternative
4 - Extraction, Treatment, and Discharoe
Alternative 4 involves a similar type of groundwater recovery
system as Alternative 3. However, prior to discharge the metals
would be removed by a physical/chemical treatment process such as
ion exchange or precipitation. The treated water would be
transferred from the treatment tank to offsite surface waters, to
onsite soakage pits, or to a regulated underground injection well
system. The recovery, treatment and disposal system will be
characterized during remedial design.
Also during or prior to the remedial design, additional field
activities would be conducted to verify the levels and extent of
the inorganic plume. The field activities would include periodic
groundwater monitoring and, if necessary, installation of
additional monitoring wells. The initiation of the construction
activities may be deferred based on the results of the sampling
effort conducted during the remedial design. Failure to meet the
drinking water standards would require the initiation of the
construction phase for the remedial action. Exceedance of the MCLS
during a single sampling effort would be confirmed by EPA during
the subsequent sampling.
The last two components to this alternative are treatment effluent
monitoring and long-term groundwater monitoring to monitor the
progress of the cleanup.
The total present worth cost for this remedy, based on ion exchange
and reinjection, is estimated at $8,035,266. Implementation of
this remedy is estimated to require six months. The capital costs
are estimated at $1,191,045 and the annual O&M costs are estimated
at $445,225.
8.0
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 nine
criteria in CERCLA. A summary of the evaluation criteria are
provided in Table 7. The following is an evaluation and comparison
of the alternatives in light of these criteria.
Overall Protection of Human Health and the Environment
All alternatives except Alternative 1 would provide protection of
human health and the environment. Alternatives 2, 3, and 4 would
provide for the restoration of the aquifer. Alternative 4 would
rely on active restoration of the shallow groundwater contamination
through pumping and treating. Alternative 3 would rely on
containment and eventual removal of the contaminated groundwater in
the aquifer. Alternative 2 would provide for protectiveness
through the use of institutional controls to restrict human
exposure to contaminated groundwater and through the use of natural
31
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TABLE 7
EVALUATION CRITERIA FOR REMEDIAL ALTERNATIVES
Standard Auto Bumper Corp. Site
Hialeah, Florida
Threshold Requirements
Overall Protection of Homan Health and the Environment: Assesses degree to which alternative eliminates,
reduces, or controls health and environmental threats through treatment; engineering methods, or institutional
controls.
Compliance with ARARs: Assesses comp6ance with Federal and State requirements.
Prima" Balancin2: Criteria
Cost: Weighing of benefits of a remedy against the cost of implementation.
Implementability: Refers to the technical feasibility and administrative ease of a remedy.
Short-Term Effectiveness: Length of time for remedy to achieve protection and potential impact of
construction and implementation of remedy.
Long-Term Effectiveness and Permanence: Degree to which a remedy can maintain protection of health and
the environment once cleanup goals are meL
Reduction of Toxicity, Mobility, or Volume through Treatment: Refers to expected performance of the
treatment tecbnologies to lessen barmful nature, movement, or amount of contaminants.
Modifvine Criteria
State Acceptance: Consideration of State's opinion of the preferred alternative.
Community Acceptance: Consideration of public comments on the Proposed Plan.
Source: 40 CFR 3OO.43O(e)(9) (1990) or SS FR 8849.
32
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attenuation and dispersion of contaminated groundwater. Although
each of these three alternatives would eventually provide
protection of human health and the environment, Alternatives 3 and
4 would achieve protectiveness more quickly than Alternative 2.
Alternative 1 would not provide any active cleanup to reduce the
risk levels nor would provide access controls to restrict human
exposure to contaminated groundwater and would, therefore, not
provide protection.
COmDliance with ARARs
Alternatives 3 and 4 would include active remediation of the
groundwater and would be designed to comply with relevant Federal
and State ARARs and local regulations. Alternative 2 would allow
for attainment of the MCLs through natural attenuation of the
groundwater contaminants. Potential compliance with ARARs would be
monitored during groundwater monitoring. Alternative 2 would not
attain ARARs as quickly as Alternatives 3 or 4. Alternative 1
would not comply with Federal and State drinking water standards.
Because the No Action alternative would not comply with the two
primary criteria (Table 7), it will not be considered further in
the analysis of alternatives.
Long-Term Effectiveness and. Permanence
Alternative 4 would provide for the recovery of the plume and
reduction in risks on a long-term basis through treatment.
Alternative 3 would be designed to remove the groundwater
contamination to achieve long-term effectiveness and permanence.
Alternative 2 would not provide for active remediation and would
attain a long-term and permanent reduction in risk more slowly than
active restoration (Alternatives 3 and 4). Alternatives 3 and 4
would restore groundwater to cleanup goals more expeditiously than
Alternative 2. There would also be a potential of exposure from
residual contamination in Alternative 2. However, the removal of
the source of contamination for OU one will promote quicker natural
attenuation of the groundwater. One of the objectives of in
determining the soil cleanup goals was to eliminate the migration
of contaminants from the soil to the groundwater.
Reduction of Toxicity, Mobility, or Volume
Alternative 4 would satisfy this criterion more thoroughly than the
other 3 alternatives. Only Alternative 4 would employ treatment to
reduce the toxicity, mobility and volume of all groundwater
contaminants posing a hazard index for noncarcinogens greater than
one for ingestion. Alternative 3 would remove contaminants from
the aquifer thereby reducing the mobility and volume of the plume.
Dilution would reduce the toxicity of the contamination. In both
of these al ternati ves, pumping would create a zone of capture
preventing or reducing contaminant migration.
33
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Alternative 2 allows the contaminated groundwater to continue
migrating and does not satisfy this criteria in the short term.
However, implementation of the au one remedy would facilitate
natural dispersion/attenuation of the plume to below cleanup goals.
Short-Term Effectiveness
Alternative 2 would involve the least amount of short-term risk,
because it does not involve construction. This alternative would
be the quickest to administer, but slowest to achieve
protectiveness. Active restoration would achieve protectiveness
more rapidly than natural attenuation, but EPA' s conclusion derived
from the graph of previous sampling events (Figure 10) shows that
Alternative 2 may be effective in eighteen to twenty four months.
Quarterly groundwater monitoring would be used to assess the
adequacy of Alternative 2. Alternatives 3 and 4 would involve some
potential for short-term risk to workers during the installation of
the recovery wells and disposal system. Alternative 4 also would
involve risks during the construction of the treatment system. Any
risks to workers involved during construction of Alternatives 3 or
4 would be reduced through implementation of a health and safety
plan. Although Alternative 4 would take the longest to implement,
it would be the quickest to achieve protection of human health.
Implementability
Alternative 2 would be the simplest to accomplish. Institutional
controls and natural attenuation do not require construction
equipment as in the other alternatives. While, Alternatives 3 and
4 would both involve straightforward construction and maintenance
of equivalent recovery systems, Alternative 4 would also require
construction and maintenance of a treatment system. As
Alternative 3 would involve the disposal of groundwater to the
POTW, it may be administratively difficult to send groundwater for-
a long period of time to the treatment plant.
Cost
Table 8 shows that Alternative 2 has the lowest present worth,
capital and O&M cost than Alternative 3 or 4, because it does not
require construction. Alternative 4 has the highest capital, O&M,
and present worth cost of the other two alternatives, due to the
treatment component.
State AcceDtance
The State of Florida, as represented by the Department of
Environmental Protection, has been the support agency during the
Remedial Investigation and Feasibility Study process for the
Standard Auto Bumper site. In accordance with 40 CFR 300.430, as
the support agency FDER has provided input during this process.
Based upon comments received from FDER, it is expected that
34
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TABLE 8
REMEDIAL ALTERNATIVE COST ESTIMATES
Standard Auto Bumper Site
Alternative
Capital Cost
O&:M Annual Cost
Present Worth
30 Year O&:M
Total Co.t
U No Action $0 NA $94,700 $94,700
112 Natural Attenuation &: $19,250 NA $94,700 $113,950
Institutional Controls
113 Extraction &: POTW Discharge $554,825 $212,150 $3,261.276 $3,816,101
114 Extraction. Ion Exchange &:
Injection Well Discharge $1.191,045 $445,225 $6.844,221 $8,035,266
NA:
Not Available
35
-------
-I -
concurrence will be forthcoming; however,
concurrence has not yet been received.
a
formal
let ter of
Community AcceDtance
EPA solicited public conunent on the remedial alternatives discussed
in Section 7.0 of this document during the period of August 24
through September 23, 1993. The public meeting at which EPA
presented the proposed plan was not attended by any local citizens.
One staff member from DERM attended the meeting and provided the
only written comment that EPA received during the comment period
(see Appendix B). OVerall, there has been very little community
interest at this site throughout the Superfund process, even though
over 400 proposed plans were sent to the community, media, and
government officials. There is no indication the public would not
support the selected remedy.
9.0 SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the NCP,
the detailed analysis of alternatives and public and state
comments, EPA has selected Alternative 2 as the groundwater remedy
for this site. This remedy was selected since it will be
protective of human health, comply with ARARs, and provide the best
balance among the alternatives with regard to effectiveness,
implementability, and cost.
9.1
Groundwater Remediation
Implementation of this alternative will include the natural
attenuation of the metals in the shallow groundwater and measures
to restrict human consumption of contaminated groundwater. These
measures include groundwater use controls such as deed notices and
prevention of new potable wells under FAC Chapter 17-524.
Groundwater monitoring activities would be conducted to verify the
levels and extent of the inorganic contamination in the
groundwater. The major components of this remedy include the
following:
a)
Natural attenuation of groundwater contaminants above MCLs to
concentrations below MCLs
b)
Groundwater use controls on properties containing contaminated
groundwater
c)
Groundwater monitoring for a minimum of 18 months
In addition to these components of the OU2 remedy, the remedy for
the source control, selected in the Record of Decision - Operable
Unit One, September 1992 will be fully implemented. OUl
remediation goals or performance standards were developed for
36
-------
chromium and nickel which were two QU2 COCs.
components of the QUI remedy include the following:
The
general
a)
Excavation of contaminated soils
b)
Groundwater monitoring for up to 5 years
The purpose of the QU1 and QU2 groundwater monitoring will be, in
part, to verify that removal of the source and that natural
attenuation are reducing the concentrations of the indicator
chemicals to below MCLs. The remedy for QU1 did not contemplate
installation of additional monitoring wells; however, the QU2
remedy contains the following modification to the original QU2
Alternative 2 stated in the FS:
a)
Installation of additional monitoring well
9.2
Performance Standards
The restoration of the aquifer will be monitored quarterly for
indicator chemicals. The indicator chemicals for this site include
contaminants that are currently exceeding MCLs and contaminants
whose concentrations may be questionable. Performance standards
are determined for these chemicals and are as follows:
Nickel
Chromium
Thallium
100 ug/l
100 ug/l
2 ug/l
Performance standards are based on Federal MCL values. The major
ARARs for this remedy include but are not limited to the Federal
Safe Drinking Water Act MCLs (40 CRF Part 141) and the Florida
Primary DWS, FAC 17-550, which are relevant and appropriate.
9.3
Compliance Testing
A groundwater compliance program will monitor the progress of the
natural aquifer restoration. Groundwater samples will be collected
from existing monitoring wells and from an additional monitoring
well to be installed downgradient of MW-02S on the Gilda Bakery
property. The new monitoring well will provide further
confirmation that nickel levels are continuing to decline and that
contamination has not migrated to the Red Road Canal.
Compliance testing will be performed in conjunction with the soils
remediation in QU1. Quarterly groundwater samples will be
collected from the monitoring wells and analyzed for the indicator
chemicals for 18 months after soil cleanup is complete. At the end
of this 18 month period, if groundwater is no longer in violation
of the performance standards for the indicator chemicals set forth
in Section 9.2, no active groundwater remediation will be
necessary. If levels are exceeded, EPA and FDEP will evaluate the
37
-------
need for further action. Irregardless, monitoring will continue
until the performance standards are met. Post remediation
monitoring will be conducted for a minimum of one year to confirm
that the performance standards have been attained.
10.0 STATUTORY DBTElUUNATIONS
EPA's primary responsibility at Superfund Sites is to select
remedial actions that are protective of human health and the
environment. CERCLA also requires that the selected remedial
action for the site comply with ARARs, be cost-effective and
utilize permanent solutions or alternative treatment technologies
to the maximum extent practicable. The statute contains a
preference for remedies that include treatment as a principal
element. The following sections discuss how the selected remedy
for contaminated groundwater meets all the statutory requirements
with the exception of the preference for treatment.
10.1
Protection of Human Health and Environment
The selected remedy protects human health and the environment by
reducing levels of contaminants in the groundwater to levels within
Federal and State MCLs. Natural attenuation of the groundwater
contaminants will reduce the .risk to human health to a hazard index
of below one for noncarcinogens. Groundwater use controls for
properties that are above the contaminated groundwater will reduce
the risk of human exposure to contaminants. No unacceptable short-
term risks or cross-media impacts will be caused by implementation
of the remedy.
10.2
Comoliance with ARARs
Implementation of this remedy will comply with all Federal and
State ARARS and will not require a waiver.
Chemical-Specific ARMs. The performance standards for the
indicator chemicals specified in Section 9.2 are based on Federal
and State MCLs. Federal and State MCLs are considered relevant and
appropriate when determining acceptable exposure to groundwater.
During the most recent round of sampling, nickel was the only
chemical detected at a concentration above its MCL. Aluminum and
iron exceeded State secondary DWS in a number of monitoring wells.
As a result, the State identified the secondary DWS for aluminum
and iron as a potential ARAR, pursuant to FAC Chapters 17-550.320
and 17-520.420. However, the elevated levels of aluminum and iron
appear to reflect the general groundwater quality in the area.
Properties surrounding the site are industrial or commercial' and
include a junk yard. These two chemicals are not considered to be
site related; therefore, such compounds will not be used as
indicator chemicals and their secondary standards are not
applicable or relevant and appropriate. Similarly, one groundwater
sample contained manganese at a level equivalent to its Federal
38
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secondary MCL of 50 ug/l. EPA also does not consider this to be
representative of groundwater conditions at the site; however, EPA
expects that remediation of groundwater will result in reduction of
manganese to below the secondary MCL.
Action-Specific ARARs. ARARs for groundwater use controls include
FAC Chapter 17-524, -New Potable Water Well Permitting in
Delineated Areas -. This Florida rule restricts installation of new
wells in delineated areas of known contamination.
Location-Specific ARARs. No location specific ARARs are applicable
or relevant and appropriate for the site.
10.3
Cost-Effectiveness
After evaluating all of the alternatives which satisfy the two
threshold criteria above, EPA has concluded the selected remedy
affords the highest level of overall effectiveness proportional to
its cost. Section 300.430(f) (1) (ii) (D) of the NCP also requires
EPA to evaluate three out of the five balancing criteria: long-
term effectiveness and permanence; reduction of toxicity, mobility
or volume through treatment; and short-term effectiveness, to
determine overall effectiveness. Cost-effectiveness is determined
by evaluating these balancing criteria to determine overall
effectiveness. Overall effectiveness is then compared to cost to
ensure that the remedy' is cost-effective. The selected remedy
provides for overall effectiveness in proportion to its cost.
This remedy has a relative low present worth, capital and O&M cost
compared to more exotic remedies, while satisfying the criteria for
long-term effectiveness and permanence and short term
effectiveness. This alternative would not reduce toxicity,
mobility, or volume through treatment; however, the reduction of
toxicity, mobility, or volume through this action would be
monitored until cleanup is attained.
The estimated total present worth cost for the selected remedy is
$113,950.
10.4 Utilization of Pe~ent Solutions and Alternative Treatment
Technologies or Resource Recoverv Technologies to the Maximum
Extent Practicable (-MEP-)
EPA believes the selected remedy represents the maximum extent to
which permanent solutions can be utilized in a cost-effective
manner for the site. After evaluating the alternatives that are
protective of human health and the environment and comply with
ARARs, EPA has determined that the selected remedy provides the
best balance in terms of the remaining criteria.
The NCP Preamble, 55 FR 8734, states that natural attenuation is
generally recommended only when active restoration is not
39
-------
practicable, cost effective or warranted because of site specific
conditions. The following factors were considered in determining
that groundwater contaminants should decrease to levels below
Federal or State MCLs through natural attenuation and dispersion:
a) soil cleanup and removal of the source of contamination; b) low
levels of concentration of contaminants; and, c) observed decline
in contaminants concentrations during the RI. Given that the soil
remediation will eliminate the pr"imary source of contamination
aquifer restoration would be extremely likely to occur naturally at
this site. Based on the observed drop in concentrations of
contaminants during the successive sampling rounds in the RI, EPA
anticipates that concentration of contaminants in groundwater will
be reduced to below the performance standards within a reasonable
timeframe.
10.5
Preference for Treatment as a princioal Element
The statutory preference for treatment is not satisfied by the
selected remedy; however, natural attenuation utilizes a cost-
effective method to address the residual threat to the groundwater
posed by the source following aU! cleanup. Based on the limited
area of the groundwater plume; the apparent low mObility of
groundwater contaminants due to site-specific hydrogeologic
factors; the groundwater" contaminants present and their
concentrations, relative to drinking water quality standards; and
the fact that the source of the contamination, the soil, will be
removed this year, EPA concluded that it was impracticable to treat
the groundwater effectively. The remedial objectives of the
selected remedy address the health and environmental threats at the
site: ingestion of contaminated groundwater.
40
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APPENDIX A
Fourth Round Groundwater Analytical Data
-.
-------
TABLE 4-15
FOURTH ROUND GRO\JNt) WATER ANALYTICAL DATA FRCM SIJA1.Im WELLS
STANnARD AIITO BUHPER CORPORATION
OIALEAO. FLORIDA
Novnmm. 1992
01S-GW 02S-GW 03S-GW 4SR-GW 6SR-GW l1S-GW 12S-GW 13S-GW
11/18/92 11/18/92 11/18/92 11/11/92 11/11/92 11/17/92 11/18/92 11/17/92.
0935 0955 1055 1140 1505 1310 1420 1520
INORGANIC ELEMENTS UG/L UG/L UG/L UG/L UG/L UG/L UG/L UG/L
SILVER IOU IOU IOU IOU IOU IOU IOU IOU
ARSENIC 30U 30U 30U 30U . 30U 30U 30U 30U
BARIUM 33 16 21 22 22 14 36 11
BERYLLIUM S.OU 5.0U 5.0U 5.0U 5.0U 5.0U 5.0U S.OU
CADMIUM 5.0U 5.0U 5.0U 5.0U 5.0U 5.0U S.OU S.OU
COBALT IOU IOU IOU IOU IOU IOU IOU IOU
CIIROMI UM IOU IOU IOU IOU IOU IOU IOU IOU
COPPER IOU IOU IOU IOU IOU IOU IOU IOU
MOLYBDENUM IOU IOU IOU IOU IOU IOU IOU IOU
NICKEL 20U 210 26 120 20U 120 20U 20U
LEAD 5.0U S.OU 5.0U S.OU 5.0U S.OU 5.0U 5.0U
ANTIMONY 30U 30U 30U 30U 30U 30U 30U 30U
SELENIUM 40U 40U 40U 40U 40U 40U 40U 40U
TIN 25U 2SU 25U 2SU 2SU 25U 25U 25U
STRONTIUM 860 100 810 800 750 360 600 830
TELLURIUM 50U SOU 50U SOU SOU 50U 50U SOU
TITANIUM IOU IOU IOU IOU IOU IOU IS IOU
THALLIUM 100U 100U 100U 100U 100U 100U 100U 100U
VANADIUM IOU IOU IOU 10U IOU IOU IOU IOU
YTTRIUM IOU IOU IOU IOU IOU IOU IOU IOU
ZINC 18 18 11 IOU 12 12 22 11
MERCURY 0.2U 0.2U 0.2U 0.2U 0.2U 0.2U 0.2U 0.2U
ALUMINUM 240 120 100U 100U 100U 100U 460 100U
MANGANESE 12 38 50 18 38 18 29 23
MG/L MG/L MG/L MG/L MG/L MG/L MG/L MG/L
CALCIUM 18 84 89 82 84 S1 61 94
MAGNESIUM 9.6 4.0 8.3 6.8 1.3 2.7 1.2 1.2
IRON 0.46 1.2 1.8 1.6 2.1 0.18 0.32 2.3
SODIUM 41 25 35 36 31 11 40 37
POTASSIUM 2.4 2.8 3.2 2.1 2:2 2.0U 2.1 2.8
~*~~*A**A*A.**.**.~...........**..****.**.*.*********...........
""~FOOTNOTES'HH'
NA - NOT ANALYZED
U - MATERIAL WAS ANALYZED FOR BUT NOT DETECTED. TIIŁ NUMBER IS THE MINIMUM QUANTITATION LIMIT
4-32
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TABLE *-16
FOURTH ROUND GROUND HATER ANALYTICAL DATA FROM DEEPER HELLS
STANDARD AUTO BUMPER CORPORATION
niALEAB. FLORIDA
NOVHffiER, 1992
INORGANIC ELEMENTS
SILVER
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
COBALT
CHROMIUM
COPPER
MOLYBDENUM
NICKEL
LEAD
ANTIMONY
SELENIUM
TIN
STRONTIUM
TELLURIUM
TITANIUM
THALLIUM
VANADIUM
YTTRIUM
ZINC
MERCURY
ALUMINUM
MANGANESE
CALCIUM
MAGNESIUM
IRON
SODIUM
POTASSIUM
IW7-IW
11/17/92
1205
UG/L
10U
30U
12
5.0U
5.0U
10U
10U
10U
10U
20U
5.0U
30U
40U
25U
720
SOU
10U
100U
10U
10U
27
0.2U
100U
11
MG/L
77
7.6
1.0
38
2.0U
01D-GW
11/18/92
1000
UG/L
10U
30U
12
5.0U
5.0U
10U
10U
10U
10U
20U
5.0U
30U
40U
25U
760
50U
10U
100U
10U
10U
17
0.2U
100U
12
MG/L
78
9.8
0.93
44
2.0U
4DR-GW
11/17/92
1220
UG/L
10U
SOU
13
5.0U
5.0U
10U
10U
10U
10U
20U
5.0U
30U
40U
25U
820
SOU
10U
100U
10U
10U
10U
0.2U
100U
10U
MG/L
77
10
0.68
45
2.2
06D-GW
11/17/92
1305
UG/L
10U
30U
18
5.0U
5.0U
10U
10U
10U
10U
20U
5.0U
30U
40U
25U
780
SOU
10U
100U
10U
'10U
18
0.2U
100U
10U
MG/L
78
7.2
0.79
38
2.0U
14D-GW
11/17/92
1245
UG/L
10U
30U
18
5.0U
5.0U
10U
10U
10U
10U
20U
5.0U
30U
40U
25U
690
SOU
11
100U
10U
10U
81
0.2U
290
17
MG/L
73
7.4
0.72
35
2'.OU
• ***•***.•******•**************.•*******•*••*•**•*•*••***
•••FOOTNOTES***
NA - HOT ANALYZED
U - MATERIAL WAS ANALYZED FOR BUT NOT DETECTED.
THE NUMBER IS THE MINIMUM QUANTITATION LIMIT
4-33
-------
'tABLE 4-17
FOURTH ROURD QUALITY ASSURARCE/QUALITY CONIROL AHALYTICAL DATA
SI:AliDARD AUTO B~
-------
APPENDIX B
RESPONSIVENESS SUMMARY
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RESPONSIVENESS SUMMARY
This summary presents the Agency's responses to any comments that
were received from the community, local officials, or potentially
responsible parties (PRPs) for the Standard Auto Bumper Corporation
site operable unit two, groundwater. EPA received only one
comment, submitted by the Pollution Prevention Division of the Dade
. County Department .of Environmental Resources Management (DERM).
A.
OVERVIEW
At the start of the public comment period, EPA issued its selection
for the preferred alternative via the media and the Proposed Plan.
EPA's recommended alternative was natural attenuation, groundwater
use controls and groundwater monitoring. This alternative,
Alternative 2, was specified in the final ROD.
Since no comments were received from the residents in the community
during the public comment period, EPA can conclude that the
community would not be adverse to natural.attenuation, groundwater
use controls and groundwater monitoring. DERM's comment is
addressed below. The local citizens did not voice objections to
any of the alternatives. .
B.
BACKGROUND ON COMMUNITY INVOLVEMENT
Community interest in the Standard Auto Bumper Corporation site has
been very limited dating back to the start of the' Remedial
Investigation when EPA held a public availability session at the
Henry M. Filer Middle/Community School. The meeting, held on
January 10, 1991, was announced in the local newspaper and an EPA
fact sheet. The only person from the community who attended the
meeting, was an employee of the Standard Auto Bumper Corporation.
EPA has made information on the site available at the local library
and the Regional office in Atlanta, Georgia. These files are
updated as new material is generated concerning the site.
During the Remedial Investigation/Feasibility Study (RI/FS), public
interest remained at the same low level.
At the completion of the groundwater FS, the Proposed Plan for the
groundwater was sent to approximately 500 people in the community,
government, and media. A public comment period was held from
August 24 to September 23, 1993. A public meeting, announced in
public notices and in the Proposed Plan, was held in the John F.
Kennedy Memorial Library in Hialeah on September 2, 1993. The
purpose of the meeting was to present the Proposed Plan and answer
questions. No local citizens attended the public meeting; however,
one staff member from DERM was present.
c.
SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
AND AGENCY RESPONSES
Only one comment was received regarding the Standard Auto Bumper
-------
site during the comment period. No comments were received from the
community or from the PRP. A summary of the written comment and
EPA's response to that comment is set out below.
SUmmary and Response to Dade County DBRK'g Concerns
1.
Staff at the Hazardous Waste Section. of DERM support
Alternative 4, extraction, treatment and discharge as the
treatment methodology best suited for the site.
BPA Response: EPA sent out a draft ROD to a peer review
committee for comments. The recommended remedy in the draft
ROD was Alternative 4 in part due to the Superfund statutory
preference to employ treatment to reduce toxicity, mobility,
or volume as a principal element. The Florida Department of
Environmental Protection (FDEP) commented on the draft ROD and
recommended that groundwater monitoring be performed for 18
months. At the end of the monitoring period, if groundwater
was no longer in violation of drinking water standards for
site related.contaminants, no active groundwater remediation
would be necessary. If levels were still exceeded, EPA and
FDEP would re-evaluate the need for a more pro-active
approach. EPA concluded that it was impracticable to treat
the groundwater effectiv~ly based on the limited area of the
groundwater plume; the apparent low mobility of groundwater
contaminants due to site-specific hydrogeologic factors; the
groundwater contaminants present and their concentrations,
relative to drinking water quality standards; and the fact
that the source of the contamination, the soil, will be
removed this year. In addition, groundwater use controls will
address the health and environmental threat posed by the site,
ingestion of contaminated groundwater. EPA agreed with FDEP
and determined that the cost of pumping and treating the
groundwater relative to other alternatives that provide
overall effectiveness was excessive. Therefore, Alternative
2 was recommended in the Proposed Plan and selected in the
final ROD as the remedy for the contaminated groundwater. The
final ROD contains further details of the process for
selecting the remedial alternative.
D.
REMA:INING CONCERNS
EPA is mainly concerned with determining whether groundwater
contamination is abated by cleaning up the soils, the source of the
contamination. EPA is confident that the soil cleanup will
minimize the need for groundwater pumping and treatment.
Groundwater will be monitored to determine the impact of. soil
remediation.
In the event an active groundwater recovery is necessary at the
site, the public will be notified.
2
-------
!h
RE~PENING OF THE PUBLIC COMMENT PERIOD
Due to the addition of several documents to the administrative
record after the issuance of the proposed plan, the decision was
made to re-open the public comment period for the receipt of
comments on the added documents. The documents that were added to
the record analyzed remediation time frames under the different
alternatives.
The public comment period was held from October 28, 1993 to
November 27, 1993. No comments were received during the re-opened
or second public comment period.
3
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