Fifth Five-year Review Report for Miami Drum Services Superfund Site Miami-Dade County Florida


FIFTH FIVE-YEAR REVIEW REPORT FOR

MIAMI DRUM SERVICES SUPERFUND SITE
MIAMI-DADE COUNTY, FLORIDA

v>EPA

JULY 2023

Prepared by

U.S. Environmental Protection Agency
Region 4
Atlanta, Georgia

Digitally signed by WILLIAM
KEEFER

Date: 2023.07.28 12:44:31
-04'00'

Randall ChafFins, Acting Director
Superfund & Emergency Management Division

WILLIAM
KEEFER

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Table of Contents

LIST OF ABBREVIATIONS AND ACRONYMS	iv

I.	INTRODUCTION	1

Site Background	1

FIVE-YEAR REVIEW SUMMARY FORM	2

II.	RESPONSE ACTION SUMMARY	4

Basis for Taking Action	4

Response Actions	5

Status of Implementation	7

Systems Operations/Operation and Maintenance (O&M)	8

III.	PROGRESS SINCE THE PREVIOUS REVIEW	9

IV.	FIVE-YEAR REVIEW PROCESS	10

Community Notification, Community Involvement and Site Interviews	10

Data Review	10

Site Inspection	 12

V.	TECHNICAL ASSESSMENT	 12

QUESTION A: Is the remedy functioning as intended by the decision documents9	 12

QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the

time of the remedy selection still valid9	13

QUESTION C: Has any other information come to light that could call into question the
protectiveness of the remedy9	14

VI.	ISSUES/RECOMMENDATIONS	14

OTHER FINDINGS	14

VII.	PROTECTIVENESS STATEMENT	14

VIII.	NEXT REVIEW	15

APPENDIX A - REFERENCE LIST	A-1

APPENDIX B - CURRENT SITE STATUS	B-l

APPENDIX C - SITE CHRONOLOGY	C-l

APPENDIX D - SITE MAPS	D-l

APPENDIX E - PRESS NOTICE	E-l

APPENDIX F - INTERVIEW FORMS	F-l

APPENDIX G - SITE INSPECTION CHECKLIST	G-l

APPENDIX H - SITE INSPECTION PHOTOS	H-l

APPENDIX I - DETAILED DATA ANALYSIS	1-1

APPENDIX J - DETAILED ARARS REVIEW TABLES	J-l

APPENDIX K - HISTORICAL SOIL DATA REVIEW	K-l

Tables

Table 1: Constituents identified at the Miami Drum Site, by Media	4

Table 2: Groundwater Cleanup Goals for Priority Pollutant VOCs for all Biscayne Aquifer Sites	6

Table 3: Protectiveness Determinations/Statements from the 2018 FYR Report	9

Table 4: Status of Recommendations from the 2018 FYR Report	9

Table C-l: Site Chronology	C-l

Table 1-1: May 2023 Analytical Results, Influent Groundwater at Select Hialeah and Preston Wells	I-1

u

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Table J-l: Evaluation of 1985 Biscayne Aquifer Cleanup Goals	1-2

Figures

Figure 1: Site Vicinity Map	3

Figure 2: Detailed Site Map	11

Figure D-l: Excavation Depths and Soil Sample Locations, 1982 Soil Cleanup	D-1

Figure 1-1: Preston-Hialeah Production Well Map	1-2

in

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LIST OF ABBREVIATIONS AND ACRONYMS

ARAR

Applicable or Relevant and Appropriate Requirement

AWQC

Ambient Water Quality Criteria

CERCLA

Comprehensive Environmental Response, Compensation, and Liability Act

CFR

Code of Federal Regulations

COC

Contaminant of Concern

DERM

Mi ami-Dade County Department of Environmental Resource Management

EPA

United States Environmental Protection Agency

FDEP

Florida Department of Environmental Protection

FDER

Florida Department of Environmental Regulation

FYR

Five-Year Review

GAC

Granular Activated Carbon

IC

Institutional Control

IU

Industrial Use

MCL

Maximum Contaminant Level

|ig/L

Micrograms per Liter

N/A

Not Applicable

NCP

National Contingency Plan

NPL

National Priorities List

O&M

Operation and Maintenance

OU

Operable Unit

PCE

T etrachl oroethyl ene

PRP

Potentially Responsible Party

RAO

Remedial Action Objective

RI

Remedial Investigation

ROD

Record of Decision

RPM

Remedial Project Manager

svoc

Semi-volatile Organic Compound

SWRAU

Sitewide Ready for Anticipated Use

TCE

T ri chl oroethylene

TTHM

Total Trihalomethanes

UU/UE

Unlimited Use and Unrestricted Exposure

voc

Volatile Organic Compound

WASD

Miami-Dade Water and Sewer Department

WTP

Water Treatment Plant

iv

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I. INTRODUCTION

The purpose of a five-year review (FYR) is to evaluate the implementation and performance of a remedy
to determine if the remedy is and will continue to be protective of human health and the environment.
The methods, findings and conclusions of reviews are documented in FYR reports such as this one. In
addition, FYR reports identify issues found during the review, if any, and document recommendations to
address them.

The U.S. Environmental Protection Agency (EPA) is preparing this FYR pursuant to the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) Section 121, consistent with the
National Contingency Plan (NCP) (40 Code of Federal Regulations (CFR) Section 300.430(f)(4)(ii)) and
considering EPA policy. This is the fifth FYR for the Miami Drum Services Superfund site (the Site).
The triggering action for this policy review is the completion date of the previous FYR.

The Site consists of two operable units (OUs). OU-1 addresses the soil remedy. OU-2 addresses the
groundwater remedy for the Biscayne Aquifer Sites, which include the Miami Drum Services Superfund
site, the Varsol Spill Superfund site and the Northwest 58th Street Landfill Superfund site. This FYR
Report addresses both OUs.

The EPA remedial project manager (RPM) Marcia Nale led the FYR. Participants included the EPA
hydrologist Ben Bentkowski, EPA community involvement coordinator Ron Tol liver. Ginger Shi rah
with the Florida Department of Environmental Protection (FDEP), and Kirby Webster and
Kim Johnson Chase from EPA support contractor Skeo. The review began on 10/5/2022.

Site Background

The 1 2-acre Site is part of a larger 82-acre property owned by the Mi ami-Dade County Transit
Authority (Transit Authority). The Site is in an industrial and commercial area about 2 miles north of the
Miami International Airport in Miami, Florida (Figure 1). From 1966 to 1981, Miami Drum Services
operated a drum-recycling operation, washing drums containing various wastes with a caustic cleaning
solution. Miami Drum Services then disposed of the drums and drum residues on site. These operations
resulted in the contamination of soils and groundwater with metals, organic solvents, and other industrial
chemicals at the Site and in the Biscayne Aquifer beneath the Site. The EPA also identified two other
Superfund sites, the Varsol Spill site and the Northwest 58th Street Landfill site (both of which have
since been deleted from the National Priorities List (NPL)), that contributed to contamination in the
Biscayne Aquifer. Both sites are within about 2 miles of Miami Drum. The Transit Authority purchased
the site property in 1982 and has operated a train maintenance yard on site since then. Site features
include transit rail tracks, paved asphalt areas and gravel roads.

Site topography is flat, with overland flow controlled by a network of canals maintained by the South
Florida Water Management District. The Biscayne Aquifer provides drinking water to southeast Florida
from water treatment plants (WTPs) in the Medley, Miami Springs, Preston and Hialeah well fields. The
Preston well field is the closest to the Site, about a half-mile southeast (Figure 1). The variable pumping
rates at the well fields and the effects of seasonal operation of the canals (alternately operated to lower
groundwater levels during the rainy season and to recharge the aquifer during the dry season) influence
the aquifer's regional flow direction on a local scale.

There are no private drinking wells in the area and Miami-Dade County regulations restrict construction
and operation of new and existing groundwater wells. Additionally, there is no remaining site-related

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groundwater contamination detected at the Hialeah and Preston production wells (see the Data Review
section of this FYR).

Appendix A includes documents reviewed as part of this FYR. Appendix B includes the EPA's site
status information. Appendix C provides the Site's chronology of events.

FIVE-YEAR REVIEW SUMMARY FORM

SITE IDEYMI l( ATION

Site Name: Miami Drum Services

EPA ID: FLD076027820

Region: 4

State: Florida

City/County: Miami/Miami-Dade

NPL Status: Final

Multiple OUs?
Yes

Lead agency: EPA

Has the Site achieved construction completion?

Yes

REVIEW S I A I I S

Author name: Marcia Nale

Author affiliation: EPA with support provided by Skeo

Review period: 10/5/2022 - 8/1/2023

Date of site inspection: 1/25/2023

Type of rev iew: Policy

Review number: 5

Triggering action date: 9/18/2018

Due date (fiveyears after triggering action date): 9/18/2023

2

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Disclaimer: This map and any boundary lines within the map are approximate
and subject to change. The map is not a sun/ey. The map is for informational
purposes only regarding the EPA's response actions at the Site Map image
is the intellectual property ofEsri and is used herein under license. Copyright
© 2020 Esri and its licensors. All rights resen/ed. Sources: Esri, State of
Florida, Maxar, the 1981 Feasibility Study and the 2013 FYR Report

Miami Drum Services Superfund Site

City of Miami, Miami-Dade County, Florida

Last Modified: 3/20/2023

Figure 1: Site Vicinity Map

Hialeah Expressway

Preston WTP

Hialeah WTP

J Approximate OU-1 Boundary

i Miami-Dade County Transit
; Authority Property Boundary

3

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II. RESPONSE ACTION SUMMARY

Basis for Taking Action

Early in 1981, the Miami-Dade County Department of Environmental Resource Management (DERM)
and the Florida Department of Environmental Regulation (the FDER, now the FDEP) found
contaminants in site soils and groundwater, including volatile organic chemicals (VOCs), phenols,
metals and pesticides. A 1981 EPA site assessment study demonstrated that exposure pathways of
concern included direct contact with drums and contaminated soils, leaching of hazardous substances
into the drinking water supply aquifer, and ingestion of contaminated groundwater. The study found that
contaminants requiring remediation at the Site included several VOCs and semi-volatile organic
compounds (SVOCs) as well as metals and pesticides (Table 1).

A 1983 remedial investigation (RI) into groundwater at and near the Site identified VOCs above the
cancer risk criteria, as well as low levels of metals and several pesticides, herbicides and extractable
organic compounds below state and federal criteria at the time. The RI found no evidence that the
groundwater at the Site was more contaminated than other areas in northwest Mi ami-Dade County. The
EPA and FDER therefore addressed groundwater contamination with contamination from other sites in
the area.

Table 1: Constituents identified at the Miami Drum Site, by Media

coc

Soil

Groundwater

VOCs

1,1 -Dichloroethane

—

Cis- 1.2-dichlorocthvlene

—

Chloroform

—

Trichloroethylene (TCE)

—

SVOCs

Phenols

Oil & Grease

Inorganic Compounds

Arsenic

Cadmium

Chromium

Cvanide

—

Lead

Mercury

Nickel

Pesticides

Dieldrin

—

Lindane

—

Notes:

Source: Table 2-1 of Evaluation of the Clean-Up Activities Already

Undertaken at the Miami Drum Services Hazardous Waste Site.

Miami-Dade County. Florida. Prepared by CH2MHill. September
1982.

COC = contaminant of concern

X = contaminant is a COC for the given medium.

— = contaminant is not a COC for the given medium.

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Response Actions

OH-1: Soil

Between December 1981 and January 1982, DERM conducted removal actions at OU-1. The
actions included:

• Removal and appropriate disposal of all surface structures and debris at an approved hazardous
waste facility off site.

• Excavation of all visibly contaminated soils and transportation of the soils to an approved
hazardous waste disposal facility off site (see Figure D-1).

• Sampling and removal of subsurface soil and waste exceeding FDER minimum criteria based on
extraction procedure toxicity testing, disposal of the material off site at an approved hazardous
waste facility, and backfilling of excavated areas with clean fill.

• On-site treatment of about 550,000 gallons of groundwater encountered during the excavations
and discharged treated groundwater back into the Biscayne Aquifer.

Following removal actions, the EPA proposed listing the Site on the NPL in December 1982. The EPA
finalized the Site's listing on the NPL in September 1983.

The EPA issued the Record of Decision (ROD) for OlJ-1 in September 1982 to address soil
contamination at the Site.

The OU-1 ROD did not identify remedial action objectives (RAOs), but the purpose of the actions was
to control source contamination and remove contaminated soil that could leach hazardous substances
into the Biscayne Aquifer. The EPA determined in the OlJ-1 ROD that DERM's removal actions
provided an adequate level of cleanup to mitigate and minimize damage to the aquifer effectively and
provided adequate protection of public health, welfare and the environment. The ROD further states that
the action was completed in accordance with CERCLA program requirements and met the conditions
outlined by the state of Florida for authorization of retroactive funding. DERM's removal actions left
3,900 cubic yards of soil with mercury levels slightly above state extraction procedure criteria because
alkaline soils at the Site cause mercury to be less susceptible to leaching.

OU-2: Groundwater

The EPA signed the Biscayne Aquifer Sites ROD (the OlJ-2 ROD) in September 1985 to address
groundwater contamination from the Site as well as at two other Superfund sites (the Varsol Spill site
and the Northwest 58th Street Landfill site), all located within an approximately 82-acre study area.
All three Superfund sites have contributed contamination to the Biscayne Aquifer. The RAO for the
groundwater remedy was to provide uncontaminated drinking water to the public. The selected
remedy included:

• Use of existing wells in the Miami Springs and Preston well fields as recovery wells.

• Installation of air stripping towers, treatment of VOC-contaminated groundwater and monitoring
of priority VOCs in groundwater at both the Hialeah and Preston WTPs.

The RAO of providing uncontaminated drinking water had the secondary benefit of cleaning up the
aquifer. Pumping from the Miami Springs and Preston wells fields would create a cone of influence
which would cause contaminants in the groundwater to migrate toward the well field. Air stripping
would then remove the contaminants prior to release of the treated water to the distribution system.

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The OU-2 ROD recommended a preventative action program, the Biscayne Aquifer Protection Plan,
which would be administered at the county level to address pollution caused by small quantity
generators and industrial facilities not connected to the sanitary sewer system. However, the
implementation of these practices was largely beyond the EPA's CERCLA authority. Therefore, their
implementation was not considered part of the remedy.

The OlJ-2 ROD considered existing Miami-Dade County regulations regulating construction and
operation of wells to be an 'existing institutional control." This is discussed further in the Institutional
Controls section of this FYR Report.

Table 2 provides a summary of the cleanup goals listed for priority pollutants/contaminants of concern
(COC) in the OlJ-2 ROD for all of the Biscayne Aquifer Sites, including addressing priority pollutant
VOCs from all three Superfund sites. Only a subset of these VOCs has been detected at the Site, as
previously noted.1 Further, the EPA determined that the VOCs were the predominant organic
compounds present in the groundwater of the well fields. VOCs are effectively removed by the
groundwater remedy (air stripping) for all three Superfund sites.

Table 2: Groundwater Cleanup Goals for Priority Pollutant VOCs for all Biscayne Aquifer Sites

Priority Pollutant VOCs"

Biscayne Aquifer Sites ROD
Cleanup Goal (us/L)

Constituent Detected at
Miami Drum Siteh

Acrylonitrilc

0.34

Benzene

0.7

—

Broinodichloroinethane

100

—

Chloroben/cne

488

—

Chloroethane

N/A

—

Chloroform

100

Chloroinethane

N/A

—

1,1 -Dichloroethane

0.9

1,1 -Dichlorocthvlene

0.04

—

1.2-Dichlorocthvlenc (cis and trans)

270

Ethvlben/cne

1,400

—

Methylene chloride (or dichloroinethane)

0.2

—

1.1.2.2-Tctrachloroethane

0.2

—

Tctrachlorocthvlcne (PCE)

—

Toluene

340

—

1,1,1-T richlorocthane

—

Trichlorocthvlcne (TCE)

Vinvl chloride

—

Xylenes (total)

620

—

Notes:

Source: Table 11 on pages 12-14 of the 1985 Biscayne Aquifer Sites ROD.

a. This list applies to contaminants from all three OU-2 Superfund sites. Not all of these COCs were

identified at the Site.

b. Constituents detected in groundwater at the Site were reported in Table 3-1 of the 1981 Feasibility
of Abating the Source of Groundwater pollution at Miami Drum Services Report.

1 According to the OU-2 ROD. the EPA confirmed the presence of SVOCs at very low concentrations or below detection in
the well fields. In addition, the EPA identified metals in groundwater primarily below primary drinking water standards in the
well fields. Further, the EPA determined that the standard water treatment softening process would reduce metal
concentrations at each WTP to include lead below the primary drinking water standards. Granular activated carbon (GAC)
treatment was not necessary since it was determined that there was no need to treat the low or non-existent concentrations of
SVOCs. However, the OU-2 ROD indicated that GAC treatment could be added to the WTPs. if necessary.

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c. Only cis-l,2-dichloroethylene detected at the Site. However, the cleanup goal is for cis and trans-1.2-

dichlorocthvlcne combined.

N/A = cleanup goal not specified in the 1985 OU-2 ROD.

Hg/L = micrograms per liter
X = given constituent detected at the Site.

- = constituent was not detected at the Site.

Status of Implementation

()(/-!: Soil

The EPA OU-1 ROD did not require any additional actions beyond DERM's removal actions. The EPA
reimbursed Miami-Dade County for 90% of DERM's expenses with funds that the Agency recovered
from Miami Drum Services and more than 60 other potentially responsible parties (PRPs) that
contributed to contamination. The EP A completed a removal assessment of the OU-1 remedial actions
in August 1992. The Site achieved the EPA's Construction Completion milestone in April 1993.

The OU-1 soil remedy did not require any further cleanup beyond the removal action to remove soil to
meet leachability criteria. However, post-removal sampling for extraction procedure toxicity confirmed
that the removal provided an adequate level of cleanup, with the exception of 3,900 cubic yards of soil
with mercury leachability values slightly above the criteria. Based on soil alkalinity, it was determined
the mercury would be unlikely to leach.

In 2021, in response to an issue in the 2018 FYR and to determine if the Site qualifies for deletion from
the NPL, the EPA's Scientific Support Section reviewed post-removal soil sampling data from the
1980s. The Scientific Support Section determined that no soils on site would pose an unacceptable risk
to human health and that there is no evidence of contamination emanating from the Site (see Appendix K).
The Site is in an area zoned exclusively for industrial uses. Fencing and a secured gate control access to
the Site.

OU-2: Groundwater

In 1987, the EPA conducted the remedial design for the remedy selected in the OlJ-2 ROD. It also
concluded that aeration treatment of contaminated groundwater using air stripping towers at the Preston
and Hialeah WTPs as centralized locations was preferable to treatment of groundwater at each
individual supply well. In 1988, the EPA signed a Cooperative Agreement for the Biscayne Aquifer
Sites remedy with the Miami-Dade Water and Sewer Department (WASD), and remedial action began.
Construction began in mid-1989 under the oversight of WASD's Engineering Division. WASD
constructed the air stripping towers at the Hialeah and Preston WTPs and began operating them.
Operation of the 64 air stripping towers and initiation of the long-term response action for OlJ-2 began
in September 1992.

The Hialeah WTP operates 20 air stripping towers. The Preston WTP operates 43 air stripping towers
and one original prototype air stripping tower. The air stripping towers have been in continuous
operation since 1992; individual units have shut down periodically for maintenance. The EPA conducted
the pre-final inspection at the Site in October 1992. Following the inspection, the EPA and the FDEP
determined that a final inspection was not necessary because the basic construction activity was
complete at the time of the pre-final inspection.

The Biscayne Aquifer Sites ROD required that WASD conduct water quality monitoring activities at the
supply wells and WTPs at its own expense. WASD initiated monitoring activities in 1986. Annual
monitoring has been ongoing since 1988. In 2012, a Phase II investigation in the vicinity of and

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downgradient of the Site collected shallow groundwater samples to support a development project at the
train maintenance yard. The analytical results for all four groundwater samples were non-detect for all
VOC compounds.

Institutional Control Review

OU-1 is within Miami-Dade County's "industrial districts, unlimited manufacturing" (IU-3) zoning
area.2 There are no restrictions in place for OU-1 to ensure that the land use remains industrial.

However, the 1 2-acre Site is now indistinguishable from and part of a larger 84-acre parcel belonging to
Miami-Dade County that is central to the county's infrastructure investments and has been in use for 40
years as a train maintenance yard. Miami-Dade County has authority to restrict property landuse through
zoning by virtue of its ownership.

The OU-2 ROD indicated that, at the time of its issuance, the Mi ami-Dade County Code of Ordinances
served as an existing institutional control to control the installation of wells across the county. Code
Section 24-45 regulated construction and operation of wells in Miami-Dade County. Construction and/or
operation of a new or existing well required a permit from DERM. The county codes were updated on
July 6, 2017, and Section 24-45 is now Section 24-43. Code Section 24-43 lists the county's drinking
water well field protection regulations.' This code section requires that DERM maintain maps of the
areas influenced by Miami-Dade County's potable water production wells (i.e., cones of influence). The
cones of influence are the basis for defining the county's well field protection areas. The code provides
land use restrictions for properties within well field protection areas to ensure the safety of Mi ami-Dade
County's drinking water supply.

Currently, Section 24-43 .2 and Section 24-43 .3 of the Miami-Dade County Code of Ordinances regulate
well permitting and use of wells in Mi ami-Dade County and require written approval in the form of a
permit from DERM to construct, maintain or operate a new or existing well. To obtain a permit, several
qualifications must be met, including a requirement that the groundwater does not need treatment to
meet drinking water standards. The ordinance also prohibits the installation of a groundwater well if a site
is within a feasible distance of an existing water main, which is the case for the Site. Section 24- 43 .2
and Section 24-43 .3 of the Miami-Dade County Code of Ordinances serve as institutional controls
for OU-2.

Since the county owns the site property and it is overlain with land and groundwater use restrictions
promulgated and enforced by the county, no more institutional controls for groundwater are necessary.

Systems Operations/Operation and Maintenance (O&M)

The OU-1 ROD did not include O&M requirements for the soil remedy. However, the Transit Authority
maintains access controls to the Metrorail William Lehman Operation and Maintenance Center, which
includes OU-1.

The selected remedy for OlJ-2 included O&M activities related to the air stripping towers at the Preston
and Hialeah WTPs. The OlJ-2 ROD projected annual O&M costs of $334,400 for the life of the project
(until untreated water attains groundwater cleanup goals). O&M requirements therefore include
monitoring of water quality at both WTPs. Mi ami-Dade County is responsible for funding O&M

2 Located at: http://www.miamidade.gov/zoning/district-iu-3-industrial-unlimited-manufacturing.asp.

3 Located at: http://miainidade.elaws.us/code/coor ch24 artiii div2 sec24-43.

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activities for the air stripping towers at the Preston and Hialeah WTPs. The air stripping towers have
been in continuous operation since 1992; individual units have shut down periodically for maintenance.

The air stripping towers at the Preston and Hialeah WTPs are subject to a federally enforceable limit on
total and individual hazardous air pollutant emissions as well as the limits imposed by the state of
Florida through its Title V Air Operations permit. Based on the amount of emissions approved in the air
permit, the permit describes the WTPs as a major source of hazardous air pollutants. Emissions data are
collected from the towers monthly and summed for the 12-month period from January to December of
each calendar year. These 12-month totals are reported to demonstrate compliance with the terms of the
air emission permit. WASD operates the 40 air strippers at the Preston WTP and the 24 air strippers at
the Hialeah WTP under a Title V Air Operation Permit 0250281-015-AV. This permit is valid from
June 11, 2020, to June 10, 2025.4

III. PROGRESS SINCE THE PREVIOUS REVIEW

Table 3 includes the protectiveness determinations and statements from the last FYR Report. Table 4
includes the recommendations from the last FYR Report and the status of those recommendations.

Table 3: Protectiveness Determinations/Statements from the 2018 FYR Report

OIJ #

Protectiveness
Determination

Protectiveness Statement

Protective

The remedy at OU-1 currently protects human health and
the environment because Miami-Dade County's removal
actions eliminated the immediate threat of direct exposure
with contaminated drums and soils and mitigated leaching
of contamination into the drinking water supply aquifer.

Current zoning district is IU-3 - Industrial Districts.

Unlimited Manufacturing.

Protective

The remedy at OU-2 currently protects human health and the
environment because groundwater treatment has effectively

removed COCs from drinking water at the Preston and
Hialeah WTPs prior to being supplied to the public, and there
is no complete vapor intrusion pathway for groundwater.

Sitewide

Protective

The remedy at the Site currently protects human health and
the environment.

Table 4: Status of Recommendations from the 2018 FYR Report

OIJ #

Issue

Recommendations

Cu rrent
Status

Current Implementation Status
Description

Completion

Date (if
applicable)

OU-1

A conservative
screening-level risk
evaluation demonstrates
that the prc-reinoval

concentrations fall

within the EPA's
cancer risk management
range or arc below the
noncancer threshold of

Institutional control
already in place
through current
zoning as IU-3 -
Industrial Districts.

Unlimited
Manufacturing.

Completed

The EPA Region 4 Scientific Support

Section reviewed post-removal
sampling data and determined that no
soils on site would pose an
unacceptable risk to human health.

7/27/2021

4 Air permit information is available at https://fldep.dep.sfate.fl.iis/air/eiiiissioii/apds/lisfpemiifs.asp (accessed 2/22/2023).

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OIJ #

Issue

Recommendations

Cu rrent
Status

Current Implementation Status
Description

Completion

Date (if
applicable)

1.0 for industrial
exposure.

OU-2

County regulations

governing well
permitting and use arc
in place but not
required by the
Biscaync Aquifer
Sites ROD.

Institutional control
is already in place
through existing
county regulations
that govern well
permitting and use.

Completed

Section 24-43.2 and Section 24-43.3
of the Miami-Dade County Code of
Ordinances continue to regulate well
permitting and use of wells in
Miami-Dade County and serve as
groundwater institutional controls.

9/18/2018

IV. FIVE-YEAR REVIEW PROCESS

Community Notification. Community Involvement and Site Interviews

The EPA issued an online news release on October 19, 2022, to announce that the FYR was underway.
A copy of the news release is available online at https ://www. epa. gov/newsrel eases/epa-revi ew-
cleanups-45-southeast-superfund-sites and is included in Appendix E. The results of the review and the
completed FYR Report will be made available on the EPA's site profile page,

https://www.epa.gov/superfliiid/miami-dinm-services. People can also access the FYR Report online
from the Site's information repository, Miami-Dade County Public Library, located at
101 West Flagler Street in Miami, Florida 33128.

During the FYR process, interviews were conducted to document any perceived problems or successes
with the remedy that has been implemented to date. The interviews included in Appendix F and are
summarized below.

Ginger Shi rah from the FDEP stated that the performance of the remedy remains protective in the short
term due to the County Ordinance and current property ownership, but in order for the remedy to remain
protective in the long-term, FDEP recommends implementing institutional controls/deed restrictions. A
Miami-Dade County Department of Transportation and Public Works representative felt well informed
of site activities and hoped that the Site would be deleted from the NPL.

Data Review

The OU-2 ROD stated that groundwater monitoring for all VOCs would be done annually by WASD
and DERM at the Preston and Hialeah WTPs. The OlJ-2 ROD stated that this monitoring was sufficient
and that it should continue until it is determined that groundwater cleanup goals listed in the OlJ-2 ROD
had been met. Groundwater monitoring has taken place at the 23 Hialeah production wells and the seven
Preston production wells since the installation of the air stripping towers in 1992. The data included in
this review are for influent groundwater sampling results prior to treatment from these production wells
from 2023, which was the only sampling event during this FYR period. Analytical results and a map of
sampled wells are included in Appendix I.

The analytical results for the Hialeah and Preston production wells demonstrate that VOCs were
below detection in 2023 (Table I-1), with a detection limit of 0.5 |ig/L. This is below the cleanup goal
for all of the constituents detected at the Miami Drum Site (Table 2). No VOCs were detected during
this FYR period.

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Figure 2: Detailed Site Map

N Miami Drum Services Superfund Site

A City of Miami, Miami-Dade County, Florida

Disclaimer: This map and any boundary lines within the map are
approximate and subject to change. The map is not a survey. The map
is for informational purposes only regarding the EPA's response actions
at the Site. Map image is the intellectual property of Esri and is used
herein under license. Copyright © 2020 Esri and its licensors. All rights
reserved. Sources: Esri, State of Florida, Maxar, the 1981 Feasibility
Study and the 2013 FYR Report.

11

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Site Inspection

The site inspection took place on 1 /24/2023. Participants included Marcia Nale (EPA RPM),

Satyen Thakar and Adien Toledo (Department of Transportation and Public Works, Mi ami-Dade
County), and Kirby Webster (EPA FYR contractor Skeo). The purpose of the inspection was to assess
the protectiveness of the remedy. A completed site inspection checklist is included in Appendix G.
Appendix H includes site inspection photos.

Participants met at the Miami-Dade Transit Authority property entrance at 6601 NW 72nd Avenue.
Participants observed OlJ-1, where DERM completed soil and waste removals in the early 1980s. An
active rail line and train cars cover the area. There was ongoing activity at a staging area, with new track
being laid down. Monitoring wells were not required for OlJ-1 and would be difficult to install given the
proximity to the road, utility corridor and the underground utility workings around the train tracks.

The EPA and Skeo also visited OlJ-2, Mi ami-Dade County's Water and Sewer Department's John E.
Preston Water Treatment Plant, located at 1100 West 2nd Avenue. The entire plant is enclosed by a high
fence and the entrance to the facility is monitored by security.

V. TECHNICAL ASSESSMENT

QUESTION A: Is the remedy functioning as intended by the decision documents9
Question A Summary:

Yes. The remedy components are functioning as intended by the decision documents. The OU-1 soil
remedy required by the 1982 ROD was the excavation and off-site disposal of all soil and waste
exceeding extraction procedure toxicity test criteria. DERM eliminated the immediate threat of
contaminated soil and waste and mitigated leaching to groundwater by excavating and disposing of
contaminated soil and waste at a permitted hazardous waste facility off site. The 1982 ROD determined
that no additional remedial actions were warranted. The property has been in use for 40 years as a train
maintenance yard that is central to the county's infrastructure investments. Miami-Dade County has
authority to control this property through zoning and by virtue of its ownership. The Transit Authority
enforces access controls at the site property, which is zoned for industrial uses. The EPA reviewed
historical soil data and confirmatory excavation data in 2021 and concluded that there are no soils
remaining on-site that would pose an unacceptable risk to human health. Soils at depth were sampled
and confirmed to be below Florida's DEP leach ability values (Appendix K).

Review of site documents, regulatory criteria and the site inspection indicate that the OlJ-2 remedy is
functioning as intended by site decision documents. The recovery wells and air stripping towers have
operated continuously since 1992 to remove VOCs and meet federal and state drinking water standards
for the public drinking water supply. Levels of VOC contaminants in the Biscayne Aquifer have
decreased over time and the air stripping towers removed remaining VOCs. The OlJ-2 ROD states that
existing county regulations governing well permitting and use were in place at the time of the issuance
of the ROD. Thus, through existing institutional controls, Dade County can control the installation of
wells throughout the County.

The NCP establishes the criteria that the EPA uses to delete sites from the NPL. In accordance with
40 CFR 300.425(e), sites may be deleted from the NPL where no further response is appropriate. In
making such a determination, the EPA considers, in consultation with the state, whether all appropriate

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Fund-financed responses under CERCLA have been implemented, and no further response action by
PRPs is appropriate.

The soil removal was completed and met state standards. Confirmatory sampling shows that soils at
depth were cleaned up to a leachability standard, a more stringent standard than dermal contact. The
excavation was backfilled with clean fill. A 2021 EPA review of post-removal sampling determined that
no soils remain on site that would pose an unacceptable risk to human health and also stated that there is
no evidence of groundwater contamination emanating from the Site.

In 1983, the state dismissed the need for a site-specific groundwater remedy due to the ubiquitous
presence of contaminants in the Biscayne Aquifer and lack of evidence that the Site was contributing to
the groundwater contamination. Treatment of the groundwater at the Preston and Hialeah wellfields via
air stripping was determined by the state and the EPA to be the best way to address aquifer-wide
contamination due to the rapid movement of contamination in the Biscay ne Aquifer along with the
widespread groundwater contamination in northwest Mi ami-Dade County due to multiple potential
sources. EPA intends to propose this Site for deletion from the NPL upon approval of the Final Close
Out Report.

QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time
of the remedy selection still valid9

Question 6 Summary:

Yes. The OU-1 soil and waste removal action cleanup goals were based on extraction procedure
leaching criteria to ensure that contaminated soil left in place would not leach to the groundwater. At
the time of the removal action, soils exceeding the leachability criteria (extraction procedure toxicity
concentrations at or below 10 times the state "minimum criteria" for groundwater) were removed,
except for an area of with mercury concentrations slightly exceeding criteria. However, the mercury
concentrations in these soils were of the same order of magnitude as the leachability criterion and
because the groundwater was alkaline, it was determined that the pH of the groundwater would prevent
any further leaching. A map showing soil excavation areas at the Site is located in Appendix D.

The OU-2 ROD assumed exposure to groundwater through ingestion of drinking water and established
cleanup goals that were protective for consumption of groundwater. These exposure assumptions remain
valid. Appendix J provides an evaluation of the groundwater cleanup goals identified in the OlJ-2 ROD.
The RAO for the groundwater remedy was to provide uncontaminated drinking water to the public. The
WTPs monitor the water to ensure that the treated drinking water from the Preston and Hialeah wells
meets all current state and federal drinking water standards prior to being supplied as drinking water to
the public.

The vapor intrusion exposure pathway was not evaluated as part of the groundwater remedy selection
for the Site. However, vapor intrusion is not currently a completed exposure pathway as there are no
occupiable structures or buildings in the railyard where contaminated soils and wastes have been
removed. In addition, because there were no detections of VOCs at the Preston and Hialeah productions
wells during the FYR period, there is no evidence that site-related contamination could contribute to
unacceptable risk from vapor intrusion.

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QUESTION C : Has any other information come to light that could call into question the protectiveness
of the remedy9

No other information has come to light that could call into question the protectiveness of the remedy.
VI. ISSUES/RECOMMENDATIONS

Issues/Recommendations

OU(s) without Issues/Recommendations Identified in the FYR:

OU-1 and OU-2

OTHFR FINDINGS

Several additional recommendations were identified during the FYR. This recommendation does not
affect current and/or future protectiveness.

• EPA intends to propose this Site for deletion from the NPL upon approval of the Final
Close Out Report.

VII. PROTECTIVENESS STATEMENT

IVolcctncncss Statement

Operable Unit: OU-1 Protectiveness Determination:



Protective



Protectiveness Statement:



The remedy at OU-1 is protective of human health and the environment because there are no

completed

exposure pathways to contamination.





IVotcclhcncss Slsilcmcnl

Operable Unit: OU-2 Protectiveness Determination:



Protective



Protectiveness Statement:



The remedy at OU-2 is protective of human health and the environment because there are no

completed

exposure pathways to contamination.





Silcwidc IVolcctncncss Statement

Protectiveness Determination:



Protective



Protectiveness Statement:



The remedy at the Site is protective ofhuman health and the environment because there are no

completed

exposure pathways to contamination.



14

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VIII. NEXT REVIEW

The EPA intends to propose this Site for deletion from the NPL upon approval of the Final
Close Out Report.

15

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APPENDIX A - REFERENCE LIST

EPA Superfund Record of Deci si on, Miami Drum Services, OU-1, Miami, FL. EPA Region 4.
September 13, 1982

Evaluation of Clean-up Activities Already Undertaken at the Miami Drum Services Hazardous Waste
Site, Dade County, Florida. Prepared by CH2M Hill. September 1, 1982.

The Feasibility of Abating the Source of Ground-Water Pollution at Miami Drum Services, Dade
County Florida. Prepared by Ecology and Environment. Inc. December 8, 1981.

Fourth Five-Year Review Report for Miami Drum Services Superfund Site, Miami-Dade County,
Florida. EPA Region 4. August 2018.

Miami Drum Remedial Action Report. Air Stripping Facilities at the Hialeah and John E. Preston Water
Treatment Plants. EPA Region 4. Approved June 15, 1993.

Phase II—Sampling, Analytical, and Investigative Program for the Protection of the Biscay ne Aquifer
and Environment in North Dade County, Florida. Final Report. Volume I. Prepared by CH2M Hill.
February 1984.

Phase II—Sampling, Analytical, and Investigative Program for the Protection of the Biscay ne Aquifer
and Environment in North Dade County, Florida. Final Report. Volume II Appendix. Prepared by
CH2M Hill. February 1984.

Phase III—Feasibility of Remedial Actions for the Protection of the Biscay ne Aquifer in Dade County,
Florida. Final Report. Prepared by CH2M Hill. May 1985.

Record of Decision: Summary of Remedial Alternative Selection, Biscay ne Aquifer Sites - Study Area
Ground Water, Dade County, Florida. EPA Region 4. September 16, 1985.

Record of Decision: Miami Drum Services. Miami, Florida. September 13, 1982.

Remedial Investigation for Miami Drum Services Site, Florida. Prepared by Vernon B. Myers, Ph.D.,
Florida Department of Environmental Regulation. November 1983.

Superfund Preliminary Close-Out Report. Miami Drum/Biscayne Aquifer Remedial Action. Dade
County, Florida. April 28, 1993.

Fourth Five-Year Review Report for Miami Drum Services Superfund Site, Miami-Dade County,
Florida. EPA Region 4. August 2018.

A-l

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APPENDIX B - CURRENT SITE STATUS

K11 v i roil in en 1211 I ml iesi 1 ors

Current human exposures at the Site are under control.
Current groundwater migration is under control.

Arc Necessary Inslitnlion;il Controls in Place

All O Some Q None

I his (lie KIW Designated (lie Silo sis Silcwidc Ready lor Anticipated I so?

^ Yes O No

I his (lie Silo Keen Put into Uense.

1X1 Yes O No

The Transit Authority has operated a train maintenance yard on site since 1982.

B-l

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APPENDIX C - SITE CHRONOLOGY

Table C-l: Site Chronology

Li csrs

Date

Miami Dram Services operated a drum-recycling operation on the Site,
washing dnuns containing various wastes with a caustic cleaning
solution.

1966 to 1981

Contamination discovered at the Site

November 1979

Miami-Dade County (formerly Dade County) required Miami Dram

Services to cease operations through a court order

June 1981

Miami Dram Services ended operations and abandoned the property
The EPA and DERM conducted a feasibility studv at the Site

1981

DERM began removal actions at OU-1

December 1981

The FDEP conducted a remedial investigation of the Biscavne Aquifer

1982-1983

Miami-Dade County Transit Authority purchased the Site property and
has operated a rail yard since then.

1982

DERM completed removal actions at OU-1

Januarv 1982

Action Memorandum approved CERCLA funds

June 1982

EPA Region 4 concurred with OU-1 removal actions

August 1982

The FDEP concurred with OU-1 removal actions
The EPA signed the OU-1 ROD

September 13, 1982

Phase 1 Report - Protection of Biscavne Aquifer issued

October 1982

The EPA proposed the Site for listing on the NPL

December 30, 1982

Dade Countv Well Field Protection Ordinance adopted

September 1983

The EPA final i/cd the Site's listing on the NPL

September 8, 1983

Phase 11 Report - Protection of Biscavne Aquifer issued

Februarv 1984

Phase 111 Report - Protection of Biscavne Aquifer issued (feasibility
studv completed)

May 1985

Remedial Investigation/Feasibility Study Report for Biscavne Aquifer
Sites (OU-2 at the Site) completed

The EPA signed Biscavne Aquifer Sites (the Site's OU-2) ROD

September 16, 1985

The EPA created the Biscavne Aquifer Protection Plan

1985

Consent Decree final i/cd

Februarv 25, 1987

The EPA began the remedial design for Biscavne Aquifer Sites (OU-2 at
the Site)

September 1, 1987

The EPA completed the OU-2 remedial design

September 30, 1987

The EPA executed Cooperative Agreement with WASD for OU-2

September 30, 1988

WASD began construction of air stripping towers at the Preston and
Hialeah WTPs

1989

The EPA completed the removal assessment

August 25, 1992

The EPA conducted the pre-final inspection at the Site

October 29, 1992

WASD completed construction of air stripping towers at the Preston and
Hialeah WTPs and operation of the towers began

1992

The EPA determined the Site achieved Construction Completion and
signed the Site's Preliminary Close-Out Report

April 28, 1993

The EPA final i/cd the Final Close-Out Report for the Site

June 21, 1993

The FDEP issued the Initial Title V Air Operation Permit

June 29, 2000

The EPA concluded funding of long-term response actions at the Site

September 30, 2002

The EPA issued the Site's first FYR Report

Mav 2, 2003

The FDEP issued Final Title V Air Operation Permit 0250281-010-AV

Januarv 30, 2006

The EPA issued the Site's second FYR Report

May 1, 2008

The FDEP issued Final Title V Air Operation Permit 0250281-013-AV

September 26, 2010

The EPA issued the Site's third FYR Report

July 31,2013

The FDEP issued Final Title V Air Operation Permit 0250281-014-AV

July 23, 2015

The EPA issued the Sites fourth FYR Report

September 18, 2018

C-l

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Li csrs

Date

The EPA designated the Site as Sitewide Ready for Anticipated Use
(SVVRAU)

July 16, 2019

The FDEP issued Final Title V Air Operation Permit 0250281-015-AV

June 11,2020

The EPA's Scientific Support Section reviewed post-removal soil data
and determined that no soils remaining on site pose an unacceptable risk
to human health and there is no evidence of groundwater contamination

emanating from the Site

July 27, 2021

C-2

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APPENDIX D - SITE MAPS
Figure D-l: Excavation Depths and Soil Sample Locations, 1982 Soil Cleanup3

MO-29#

Ofl Figure

MO-100

MO-1 thru MO-34 • 10 Fool Coring*
MD-100 thru MO-700 . - Surface Samples
SS-1 thru SS-4	- Surf*

LEGEND)

\ / / / \ Excavation to 1 Foot Beiow Grade
1	—I Excavation to 10 Feet Below Grade

Excavation to 3 Feet Betow Grade

I I I Excavation to 2.5 Feet Below Grade

KWWWM Excavation to 5 Feet Betow Grade
Excavation to 8 Feet Betow Grade

1- = 333'

Bms map iNm Envwop*ci O H	Co FtQu/t

FIGURE 5-4J

Depth of Soils Excavated at Miami Drum Site (Alternative E.).l

s Figure 5-4 of Evaluation of the Cleanup Activities Already Undertaken at the Miami Drum Services Hazardous Waste Site. September 1982.

D-l

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APPENDIX E - PRESS NOTICE

VIRONMENTAL PROTECTION AGENCY

NEWS RELEASE

EPA.GOV/NEWSROOM

EPA to Review Cleanups at 45 Southeast Superfund Sites

Contact Information: reqion4press@epa.gov. 404-562-8400

ATLANTA (Oct. 19, 2022)-Today, the U.S. Environmental Protection Agency (EPA) announced that
comprehensive reviews will be conducted of completed cleanup work at 45 National Priority List (NPL)
Superfund sites in the Southeast.

The sites, located in Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina,
and Tennessee, will undergo a legally required Five-Year Review to ensure that previous remediation
efforts at the sites continue to protect public health and the environment.

"The Southeast Region will benefit tremendously from the full restoration of Superfund sites, which can
become valuable parts of the community landscape," said EPA Region 4 Administrator Daniel
Blackmon. "The Five-Year Review evaluations ensure that remedies put in place to protect public health
remain effective overtime."

The Superfund Sites where EPA will conduct Five-Year Reviews in 2022 are listed below. The web links
provide detailed information on site status as well as past assessment and cleanup activity. Once the Five-
Year Review is complete, its findings will be posted in a final report at

https://www.epa.aov/superfund/search-superfund-five-vear-reviews.

Alabama

Alabama Army Ammunition Plant https://www.epa.aov/superfund/alabama-armv-ammunition-plant
Alabama Plating Company, Inc. https://www.epa.aov/superfund/alabama-plating-co
Mowbray Engineering Co. https://www.epa.gov/superfund/mowbrav-engineering
US NASA Marshall Space Flight Center

US Army/NASA Redstone Arsenal https://www.epa.gov/superfund/redstone-aresenal
Florida

ALARIC Area GW Plume https://www.epa.gov/superfund/alaric-area-groundwater-plume
Beulah Landfill https://www.epa.gov/superfund/beulah-landfill

Chevron Chemical Co. (Ortho Division) https://www.epa.gov/superfund/chevron-chemical-companv

Florida Petroleum Reprocessors https://www.epa.gov/superfund/florida-petroleum-reprocessors

Miami Drum Services https://www.epa.gov/superfund/miami-drum-services

Pensacola Naval Air Station https://www.epa.gov/superfund/naval-air-station-pensacola

Raleigh Street Dump https://www.epa.gov/superfund/raleigh-street-dump

Taylor Road Landfill https://www.epa.gov/superfund/tavlor-road-landfiil

Tower Chemical Co. https://www.epa.gov/superfund/tower-chemical-companv

Georgia

Alternate Energy Resources Inc. https://www.epa.gov/superfund/alternate-energy-resources

Peach Orchard & Nutrition Co. Rd PCE Groundwater Plume Site https://www.epa.gov/superfund/peach-

orchard-road-pce-plume

Powersville Site https://www.epa.gov/superfund/powersville-site

T.H. Agriculture & Nutrition Co (Albany Plant) https://www.epa.gov/superfund/t-h-agriculture
Kentucky

A.L. Taylor (Valley of the Drums) https://www.epa.gov/superfund/al-tavlor-vallev-of-drums
Brantley Landfill https://www.epa.gov/superfund/brantlev-landfill

E-l

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Distler Brickyard https://www.epa.qov/superfund/distler-brickvard

Distler Farm https://www.epa.gov/superfun https://www.epa.gov/superfund/lee-lane-landfilld/distler-farm
Lee's Lane Landfill https://www.epa.gov/superfund/lee-lane-landfill

National Electric Coil Co./Cooper Industries https://www.epa.gov/superfund/national-electric-coil-cooper-
industries

Tri City Disposal Co. https://www.epa.gov/superfund/tri-citv-disposal
North Carolina

ABC One Hour Cleaners https://www.epa.gov/superfund/abc-one-hour-cleaners

Aberdeen Pesticide Dumps https://www.epa.gov/superfund/aberdeen-contaminated-groundwater

Benfield Industries, Inc. https://www.epa.gov/superfund/benfield-industries

Cherry Point Marine Corps Air Station https://www.epa.gov/superfund/cherrv-point-marine-corps

CTS of Ashville, Inc. https://www.epa.gov/superfund/cts-millsgap

GEIGY Chemical Corp (Aberdeen Plant) https://www.epa.gov/superfund/ciba-geigy-corporation
Gurley Pesticide Burial https://www.epa.gov/superfund/gurlev-pesticide-burial

North Carolina State University (Lot 86, Farm Unit #1) https://www.epa.gov/superfund/north-carolina-state-
universitv

Sigmon's Septic Tank Service https://www.epa.gov/superfund/sigmon-septic-tank
South Carolina

Admiral Home Appliances https://www.epa.gov/superfund/admiral-home-appliances

Beaunit Corp (Circular Knit & Dyeing Plant) https://www.epa.gov/superfund/beaunit

Carolawn Inc. https://www.epa.gov/superfund/carolawn

Elmore Waste Disposal https://www.epa.gov/superfund/elmore-waste-disposal

International Minerals and Chemicals (IMC) https://www.epa.gov/superfund/imc

Kalama Specialty Chemicals https://www.epa.gov/superfund/kalama-specialtv-chemicals

Koppers Company, Inc. (Charleston Plant) https://www.epa.gov/superfund/koppers-charleston-plant

Savannah River Site (USDOE) https://www.epa.gov/superfund/savannah-river-site

SCRDI Bluff Road https://www.epa.gov/superfund/scrdi-dixiana

Tennessee

Mallory Capacitor Co. https://www.epa.gov/superfund/mallorv-capacitor

Memphis Defense Depot (DLA) https://www.epa.gov/superfund/memphis-defense-depot

Background

Throughout the process of designing and constructing a cleanup at a hazardous waste site, EPA's primary
goal is to make sure the remedy will be protective of public health and the environment. At many sites,
where the remedy has been constructed, EPA continues to ensure it remains protective by requiring
reviews of cleanups every five years. It is important for EPA to regularly check on these sites to ensure the
remedy is working properly. These reviews identify issues (if any) that may affect the protectiveness of the
completed remedy and, if necessary, recommend action(s) necessary to address them.

There are many phases of the Superfund cleanup process including considering future use and
redevelopment at sites and conducting post cleanup monitoring of sites. EPA must ensure the remedy is
protective of public health and the environment and any redevelopment will uphold the protectiveness of
the remedy into the future.

The Superfund program, a federal program established by Congress in 1980, investigates and cleans up
the most complex, uncontrolled or abandoned hazardous waste sites in the country and endeavors to
facilitate activities to return them to productive use. In total, there are more than 280 Superfund sites
across the Southeast.

More information:

EPA's Superfund program: https://www.epa.gov/superfund

EPA.GOV

O0©G

E-2

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APPENDIX F - INTERVIEW FORMS

MIAMI DRUM SERVICES SIPERFUND SITE
FIVE-YEAR REVIEW INTERVIEW FORM

Site Name: Miami Drum Serv ices

EPA ID: FLD076027820

Interviewer name:

Interviewer affiliation:

Subject name: Ginger Shi rah

Subject affiliation: FDEP

Subject contact information: gin ger ,k. shirah@,floridadep.gov

Interview date:

Interview time:

Interview location:

Interview format (circle one): In Person Phone Mail Email Other:

Interview category: State Agency

1. What is your overall impression of the project, including cleanup, maintenance and reuse activities
(as appropriate)9

In January 1982, soil and debris source removal actions were completed at the Miami Drum site. The
criteria usedfor identifying contaminated soil was based on a combination of visual contamination,
grossly contaminated soils with high metals concentrations and soils with extraction procedure toxicity
concentrations exceeding 10 times the DEP "minimum criteria" for groundwater. No numeric remedial
criteria for soils were established in the 1982 Miami Drum ROD to address direct contact for
commercial industrial scenarios. A complete comparison of the contaminant levels remaining in the
vadose zone, particularly the top 2 ft,, to the current Chapter 62-777 SCTLs for industrial direct
exposure is necessary to determine the long term protectiveness of the remedy. EPA's Scientific Support
Section issued a memo in July 2021 stating that the confirmatory excavation data had been reviewed, but
this data was not presented for DEP technical review.

Groundwater sampling as part of the 1983 Remedial Investigation performed by DEP at the Miami
Drum site confirmed concentrations of volatile organics that would now be considered as exceedances of
the GCTLS established in Chapter 62-777. However, there was a reduction in concentrations as
compared to those observed prior to and during excavation, which could be indicative of the
effectiveness of the 1982 removal in reducing groundwater contaminant levels at the Miami Drum site.
Results from the more recent 2013 groundwater sampling of shallow temporary monitoring wells at the
Ml XT Lehman Center Test Track in the area east of the former Miami Drum facility property suggest that
at least in the shallow portion of the aquifer, GCTLs are met off site for IRPH. PAHs, PCBs, RCRA
metals including mercury and VOCs. It is not known if groundwater currently meets MCLs/GCTLs at the
Miami Drum site. If GCTLs are not met onsite, groundwater use restrictions would be required to close
the site pursuant to Chapter 62-780, /•'. A. C.

2. What is your assessment of the current performance of the remedy in place at the Site9

The performance of the remedy remains protective in the short term due to the County Ordinance
and current property ownership, but in order for the remedy to remain protective in the long term,
DEP recommends implementing institutional controls deed restrictions.

F-l

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3. Are you aware of any complaints or inquiries regarding site-related environmental issues or remedial
activities from residents in the past five years9

4. Has your office conducted any site-related activities or communications in the past five years9 If so,
please describe the purpose and results of these activities.

DEP has participated in several meetings with EPA and DERM regarding the Deletion of the site
from the NPL.

5. Are you aware of any changes to state laws that might affect the protectiveness of the Site's remedy9

Chapter 62-780 and Chapter 62-777. /•'. A. C. have been promulgated since selection of the Miami Drum
(OU1) andBiscayne Aquifer (OU2) remedies, establishing SCTLs and health based GCTLs as ARARs.

6. Are you comfortable with the status of the institutional controls at the Site9 If not, what are the
associated outstanding issues9

The Miami-Dade County Department of Regulatory and Economic Resources (DERM) has designated
this property as a contaminated site and requires that any land disturbing activity on or adjacent to the
site obtain prior review and approval by DERM. However, DEP maintains that in order for the remedy
to be protective in the long term, institutional controls and or land use restrictions through a restrictive
covenant with Miami-Dade County are needed to ensure human health and the environment are
protected in perpetuity.

7. Are you aware of any changes in projected land use(s) at the Site9
No

8. Do you have any comments, suggestions or recommendations regarding the management or
operation of the Site's remedy9

See above comments regarding the needfor institutional controls deed restrictions. In addition, DEP
would like for the post-excavation soil data that EPA references within the FYR to be included
for review.

9. Do you consent to have your name included along with your responses to this questionnaire in the
FYR report9

Yes

F-2

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MIAMI DRUM SERVICES SIPERFUND SITE
FIVE-YEAR REVIEW INTERVIEW FORM

Site Name: Miami Drum Serv ices

EPA ID: FLD076027820

Interviewer name: Kir by Webster

Interviewer affiliation: EPA Support Contractor Skeo

Subject name:

Subject affiliation: Miami-Dade County Department of
Transportation and Public Works	

Interview format (circle one): In Person

Phone

Mail

Email

Other:

Interview category: Local Government

1.	Are you aware of the former environmental issues at the Site and the cleanup activities that have
taken place to date9

Response: Yes, based on EPA's reports (Fourth Five-Year review report dated August 2018 and
EPA's community involvement Plan, dated November 2021), I am aware of former environmental
issues at the site.

2.	Do you feel well-informed regarding the Site's activities and remedial progress9 If not, how might
EPA convey site-related information in the future9

Response: Yes, Ifeel well informed regarding site activities and remedial progress.

3.	Have there been any problems with unusual or unexpected activities at the Site, such as emergency
response, vandalism or trespassing9

Response: Not that I am aware of

4.	Are you aware of any changes to state laws or local regulations that might affect the protectiveness
of the Site's remedy9

Response: No, I am not aware of any changes to state laws or local regulations that might affect the
protectiveness of the Site's remedy.

5.	Are you aware of any changes in projected land use(s) at the Site9

Response: I am not aware of any changes for land use at the site.

6.	Has EPA kept involved parties and surrounding neighbors informed of activities at the Site9 How
can EPA best provide site-related information in the future9

Response: Per EPA's Community Involvement Plan dated November 2021, it seems EPA have kept
involved parties informed of activities at site.

7.	Do you have any comments, suggestions or recommendations regarding the project9

Response: Based on current future land use and remediation so far, we hope that this site is
removedfrom NPL list.

8.	Do you consent to have your name included along with your responses to this questionnaire in the
FYR report9

Response: No.

F-3

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APPENDIX G - SITE INSPECTION CHECKLIST

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

I. SITE INFORMATION

Site Name: Miami Drum Services

Date of Inspection: 01/24/2023

Location and Region: Miami, Florida 4

EPA ID: FLD076027820

Agency, Office or Company Leading the Five-Year
Review: EPA

Weather/Temperature: Sunnv/80 degrees Fahrenheit

Remedy Includes: (check all that apply)

~	Landfill cover/containment

~	Access controls

~	Institutional controls
[3 Groundwater pump and treatment

~	Surface water collection and treatment

E3 Other: Removal actions excavated contaminated soil for off-site disposal at a permitted facility;
excavated areas were backfilled with clean soil.

~	Monitored natural attenuation

~	Groundwater containment

~	Vertical barrier walls

Attachments: Q Inspection team roster attached

~ Site map attached

II. INTERVIEWS (check all that apply)

1. O&M Site Manager

Name Title
Interviewed ~ at site ~ at office ~ by phone Phone: _
Problems, suggestions ~ Report attached: 	

Date

2. O&M Staff

Name	Title

Interviewed ~ at site ~ at office ~ by phone Phone: _

Problems/suggestions ~ Report attached: 	

Date

3. Local Regulatory Authorities and Response Agencies (i.e., state and tribal offices, emergency
response office, police department, office of public health or environmental health, zoning office,
recorder of deeds, or other city and county offices). Fill in all that apply.

Agency Miami-Dade County Department of Transportation and Public Works
Contact

Name

Problems/suggestions ~ Report attached:

Title

Date

Phone

Agency.
Contact

Name

Problems/suggestions ~ Report attached:.

Title

Date

Phone

Agency.

Contact

Name

Problems/suggestions ~ Report attached:

Title

Date

Phoi

Agency.

Contact

Name

Problems/suggestions ~ Report attached:

Title

Date

Phone

G-l

-------


Agencv
Contact

Name Title
Problems/suggestions [~~| Report attached:

Date

Phone





4.

Other Interviews (optional) d Report attached:













III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)

1.

O&M Documents











~ O&M manual ~ Readily available

~ Up to date

IKIn/a





~ As-built drawings ~ Readily available

~ Up to date

IKIn/a





~ Maintenance logs ~ Readily available

~ Up to date

M N/A





Remarks:









2.

Site-Specific Health and Safety Plan

~ Readily available

~ Up to date

IE

|n/a



~ Contingency plan/emergency response plan

~ Readily available

~ Up to date

IE

|n/a



Remarks:









3.

O&M and OSHA Training Records

~ Readily available

~ Up to date

0N/A



Remarks:









4.

Permits and Service Agreements











~ Air discharge permit

~ Readily available

~ Up to date

IE

]n/a



~ Effluent discharge

~ Readily available

~ Up to date

IE

]n/a



~ Waste disposal. POTW

~ Readily available

~ Up to date

E

]n/a



n Other Dcrmits:

~ Readily available

~ Up to date

IE

]n/a



Remarks:









5.

Gas Generation Records
Remarks:

~ Readily available

~ Up to date

IE

|n/a

6.

Settlement Monument Records
Remarks:

~ Readily available

~ Up to date

IE

|n/a

7.

Groundwater Monitoring Records

13 Readily available

~ Up to date

~ n/a



Remarks:









8.

Leachate Extraction Records

~ Readily available

~ Up to date

IE

|n/a



Remarks:









9.

Discharge Compliance Records











1^ Air ~ Readily available

~ Up to date

~ N/A





~ Water (effluent) ~ Readily available

~ Up to date

13 n/a





Remarks:









G-2

-------
10. Daily Access/Security Logs	^ Readily available ^ Up to date O N/A
Remarks: A security gate and fencing control access to the Site.

IV. O&M COSTS

1. O&M Organization

[~l State in-housc	~ Contractor for state

[~l PRP in-housc	O Contractor for PRP

~ Federal facility in-house	~ Contractor for Federal facility

m Miami-Dade County funds the O&M of the air strippers that treat groundwater as part of the OU-2
remedy.

2.

O&M Cost Records

~ Readily available	O Up to date

IXI Funding nicclianisni/agrccnicnt in place ~ Unavailable

Original O&M cost estimate:	 ~ Breakdown attached

Total annual cost by year for review period if available

From:		To:			

Date

Date

Total cost

From:

To:

Date

Date

Total cost

From:

To:

Date

Date

Total cost

From:

To:

Date

Date

Total cost

From:

To:

O Breakdown attached
O Breakdown attached
O Breakdown attached
O Breakdown attached
O Breakdown attached

Date

Date

Total cost

3. Unanticipated or Unusually High O&M Costs during Review Period
Describe costs and reasons:	

V. ACCESS AND INSTITUTIONAL CONTROLS ~ Applicable [X] N/A

A. Fencing

1. Fencing Damaged ~ Location shown on site map ~ Gates secured ~ N/A
Remarks:	

B. Other Access Restrictions

1. Signs and Other Security Measures
Remarks:	

~ Location shown on site map ^ N/A

C. Institutional Controls (ICs)

G-3

-------
1. Implementation and Enforcement

Site conditions imply ICs not properly implemented
Site conditions imply ICs not being fully enforced
Type of monitoring (e.g., self-reporting, drive by): __

Frequency:	

Responsible party/agency:	

Contact 	

~	Yes M No ~ N/A

~	Yes [X] No ~ N/A

Name Title

Date



Phone

Reporting is up to date

l~l Yes

~

No

IXlN/A

Reports arc verified by the lead agency

l~l Yes

~

No

[x]n/a

Specific requirements in deed or decision documents have been met

[~l Yes

~

No

|N/A

Violations have been reported

[~l Yes

~

No

IXIn/a

Other problems or suggestions: ~ Report attached









2.

Adequacy

Remarks:

~ ICs arc adequate

~ ICs arc inadequate

^ N/A

D. General

1. Vandalism/Trespassing ~ Location shown on site map ^ No vandalism evident
Remarks:	

2. Land Use Changes On Site
Remarks:	

13 N/A

3. Land Use Changes Off Site
Remarks:	

13 N/A

VI. GENERAL SITE CONDITIONS

A. Roads ~ Applicable ^ N/A

1. Roads Damaged
Remarks:	

~ Location shown on site map ~ Roads adequate

~ N/A

B. Other Site Conditions

Remarks:

VII. LANDFILL COVERS	~ Applicable ^ N/A

A. Landfill Surface

Settlement (low spots)

Area extent:	

Remarks:	

~ Location shown on site map

~ Settlement not evident
Depth:	

2.

Cracks

Lengths: _
Remarks:

~ Location shown on site map
Widths:	

O Cracking not evident
Depths:	

G-4

-------
3.

Erosion
Area extent:
Remarks:

[~l Location shown on site map

~ Erosion not evident

Depth:

4.

Holes

Area extent:
Remarks:

~ Location shown on site map

~ Holes not evident

Depth:

5.

Vegetative Cover
l~l No signs of stress
Remarks:

[~l Grass

l~l Trees/shrubs (indicate si/c and

~ Cover properly established
locations on a diagram)

6.

Alternative Cover (e.£
Remarks:

armored rock, concrete)

~ N/A

7.

Bulges
Area extent:
Remarks:

~ Location shown on site map

~ Bulges not evident

Height:

Wet Areas/Water Damage O Wet areas/water damage not evident

l~l Wet areas

l~l Ponding
[~l Seeps
~ Soft subgrade
Remarks:	

[~l Location shown on site map	Area extent:

[~l Location shown on site map	Area extent:

~	Location shown on site map	Area extent:

~	Location shown on site map	Area extent:

Slope Instability	O Slides

~ No evidence of slope instability

Area extent:	

Remarks:	

~ Location shown on site map

B. Benches

~ Applicable

N/A

(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in
order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)

1. Flows Bypass Bench
Remarks:	

I I Location shown on site map Q N/A or okay

2. Bench Breached
Remarks:	

~ Location shown on site map ~ N/Aor okay

3. Bench Overtopped
Remarks:

~ Location shown on site map ~ N/Aor okay

C. Letdown Channels

~ Applicable ~ N/A

(Channel lined with erosion control mats, riprap, grout bags or gabions that descend down the steep side
slope of the cover and will allow the runoff water collected by the benches to move off of the landfill
cover without creating erosion gullies.)

G-5

-------
1.

Settlement (Low spots) ~ Location shown on site map

Area extent:

Remarks:

~ No evidence of settlement

Depth:

2.

Material Degradation ~ Location shown on site map
Material tvpc:

Remarks:

~ No evidence of degradation

Area extent:

3.

Erosion ~ Location shown on site map

Area extent:

Remarks:

~ No evidence of erosion
Depth:

4.

Undercutting ~ Location shown on site map

Area extent:

Remarks:

~ No evidence of undercutting

Depth:

5.

Obstructions Tvdc:

n Location shown on site man Area extent:

Size:

Remarks:

~ No obstructions

6.

Excessive Vegetative Growth Tvdc:

~	No evidence of excessive growth

~	Vegetation in channels does not obstruct flow

n Location shown on site man Area extent:
Remarks:





D.

Cover Penetrations ~ Applicable ~ N/A





1.

Gas Vents Q Active Q Passive

l~l Properly secured/locked Q Functioning O Routinely sampled O Good condition

l~l Evidence of leakage at penetration O Needs maintenance O N/A

Remarks:

2.

Gas Monitoring Probes

l~l Properly secured/locked Q Functioning O Routinely sampled
l~l Evidence of leakage at penetration O Needs maintenance
Remarks:

O Good condition
~ N/A

3.

Monitoring Wells (within surface area of landfill)
l~l Properly secured/locked Q Functioning O Routinely sampled
l~l Evidence of leakage at penetration O Needs maintenance
Remarks:

O Good condition
~ N/A

4.

Extraction Wells Leachate

l~l Properly secured/locked [U Functioning O Routinely sampled

O Good condition

G-6

-------
[~l Evidence of leakage at penetration O Needs maintenance ~ N/A
Remarks:

5.

Settlement Monuments Q Located O Routinely surveyed O N/A
Remarks:

E.

Gas Collection and Treatment ~ Applicable ~ N/A

1.

Gas Treatment Facilities

l~l Flaring O Thermal destruction O Collection for reuse
l~l Good condition ~ Needs maintenance

Remarks:

2.

Gas Collection Wells, Manifolds and Piping
l~l Good condition ~ Needs niaintenance

Remarks:

3.

Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)
l~l Good condition O Needs maintenance O N/A
Remarks:

F.

Cover Drainage Layer ~ Applicable ~ N/A

1.

Outlet Pipes Inspected O Functioning ~ N/A
Remarks:

2.

Outlet Rock Inspected Q Functioning O N/A

Remarks:

G.

Detention/Sedinientation Ponds ~ Applicable ~ N/A

1.

Siltation Area extent: Depth: [~~l N/A
O Siltation not evident

Remarks:

2.

Erosion Area extent: Depth:

~ Erosion not evident

Remarks:

3.

Outlet Works Q Functioning ~ N/A

Remarks:

4.

Dam Functioning O N/A

Remarks:

EL Retaining Walls ~ Applicable ~ N/A

1.

Deformations O Location shown on site map Q Deformation not evident

Hori/ontal displacement: Vertical displacement:

Rotational displacement:

Remarks:

G-7

-------
2.

Degradation ~ Location shown on site map
Remarks:

[~l Degradation not evident

I. Perimeter Ditehes/Off-Site Discharge ~ Applicable

~ N/A

1.

Siltation O Location shown on site map

l~l Siltation not evident



Area extent:

Depth:



Remarks:



2.

Vegetative Growth O Location shown on site map
O Vegetation does not impede flow

~ n/a



Area extent:

Tvpe:



Remarks:



3.

Erosion ~ Location shown on site map

l~l Erosion not evident



Area extent:

Depth:



Remarks:



4.

Discharge Structure O Functioning
Remarks:

~ n/a

VIII. VERTICAL BARRIER WALLS ~ Applicable

^ N/A

1.

Settlement ~ Location shown on site map

[~l Settlement not evident



Area extent:

Depth:



Remarks:



2.

Performance Monitoring Tvpe of monitoring:
~ Performance not monitored





Frcauencv:

l~l Evidence of breaching



Head differential:





Remarks:



IX.

GROUNDWATER/SURFACE WATER REMEDIES Applicable ~ N/A

A. Groundwater Extraction Wells, Pumps and Pipelines

~ Applicable ^ N/A

1.

Pumps, Wellhead Plumbing and Electrical





~ Good condition ~ All required wells properly operating ~ Needs maintenance E3 N/A



Remarks: The Miami-Dade Water and Sewer Department operates and maintains the eauioment as Dart



of the water treatment process. No additional extraction wells were installed as part of the remedy.

2.

Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances



~ Good condition ~ Needs maintenance





Remarks:



3.

Spare Parts and Equipment





O Readily available Q Good condition ~ Requires upgrade Q Needs to be provided



Remarks:



G-8

-------
B. Surface Water Collection Structures, Pumps and Pipelines ~ Applicable X N/A

1.

Collection Structures, Pumps and Electrical

O Good condition ~ Needs maintenance
Remarks:

2.

Surface Water Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances

~ Good condition ~ Needs maintenance

Remarks:

3.

Spare Parts and Equipment

O Readily available Q Good condition ~ Requires upgrade Q Needs to be provided
Remarks:

C.

Treatment System ^ Applicable ~ N/A

1.

Treatment Train (check components that apply)

O Metals removal ~ Oil/water separation O Biore mediation
^ Air stripping O Carbon adsorbers
n Filters:

n Additive (e.g.. chelation agent, flocculent):
n Others:

O Good condition Q Needs maintenance
O Sampling ports properly marked and functional
O Sampling/maintenance log displayed and up to date
O Equipment properly identified
n Ouantitv of groundwater treated annuallv:
n Ouantitv of surface water treated annuallv:

Remarks:

2.

Electrical Enclosures and Panels (properly rated and functional)

N/A O Good condition O Needs maintenance

Remarks:

3.

Tanks, Vaults, Storage Vessels

K1 N/A ~ Good condition ~ Proper secondary containment O Needs maintenance

Remarks:

4.

Discharge Structure and Appurtenances

E3 N/A O Good condition O Needs maintenance

Remarks:

5.

Treatment Building)*)

E3 N/A ~ Good condition (esp. roof and doorways) O Needs repair
~ Chemicals and equipment properly stored

G-9

-------
Remarks:

6. Monitoring Wells (pump and treatment remedy)

~ Properly secured/locked ~ Functioning ~ Routinely sampled O Good condition

~ All required wells located ~ Needs maintenance N/A
Remarks: DERM oversees the operation of the public water supply.

D. Monitoring Data

1. Monitoring Data

No monitoring data is collected for this Site - water
treatment influent data is reviewed periodically.

O Is routinely submitted on time ~ Is of acceptable quality

2. Monitoring Data Suggests:

O Groundwater plume is effectively contained ~ Contaminant concentrations arc declining

E. Monitored Natural Attenuation

1. Monitoring Wells (natural attenuation remedy)

~ Properly secured/locked ~ Functioning ~ Routinely sampled ~ Good condition

~ All required wells located ~ Needs maintenance K1 N/A

Remarks:

X. OTHER REMEDIES

If there are remedies applied at the site and not covered above, attach an inspection sheet describing the physical
nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.
XI. OVERALL OBSERVATIONS

A. Implementation of the Remedy

Describe issues and observations relating to whether the remedy is effective and functioning as designed.
Begin with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant
plume, minimize infiltration and gas emissions).

The removal action removed contaminated soil and the groundwater remedy was put in place to ensure

there was no completed exposure pathway to groundwater contamination. The remedy is effective and

B. Adequacy of O&M

Describe issues and observations related to the implementation and scope of O&M procedures. In
particular, discuss their relationship to the current and long-term protcctivcness of the remedy.
No ongoing O&M activities are required for the Site. Groundwater treatment is addressed as part of the

C. Early Indicators of Potential Remedy Problems

Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
frequency of unscheduled repairs that suggest that the protcctivcness of the remedy may be compromised
in the future.

Nojssues.

D. Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.

No opportunities for optimization.

G-10

-------
APPENDIX H - SITE INSPECTION PHOTOS

MIAMI-DADETT1ANSIT

Sign at the entrance to the Site

Utility corridor between the Site and 72nd Avenue

H-l

-------
The Site from outside the fence line

The general location of OU-1 (under the trains and tracks)

H-2

-------
APPENDIX I -DATA TABLES AND FIGURES

Table I-1: May 2023 Analytical Results, Influent Groundwater at Select Hialeah and
Preston Wells

coc

Hialeah Well #

Preston Well #

11

13

Of

02

04

' 05

06

07

Benzene

ND

ND

ND

ND

ND

ND

ND

ND

Bromodichloro methane

ND

ND

ND

ND

ND

ND

ND

ND

Chloroform

ND

ND

ND

ND

ND

ND

ND

ND

1.1.1 -Trichloroethane

ND

ND

ND

ND

ND

ND

ND

ND

1,1,2,2,-Tetrachloroethane

ND

ND

ND

ND

ND

ND

ND

ND

1,1 -Dichloroethane

ND

ND

ND

ND

ND

ND

ND

ND

1.1-Dichlorocthvlene

ND

ND

ND

ND

ND

ND

ND

ND

Cis-1,2-Dichloroethylene

ND

ND

ND

ND

ND

ND

ND

ND

Ethvlbcn/cne

ND

ND

ND

ND

ND

ND

ND

ND

Tetrachlorocthvlcne

ND

ND

ND

ND

ND

ND

ND

ND

Toluene

ND

ND

ND

ND

ND

ND

ND

ND

Trans- 1.2-Dichloroethvlene

ND

ND

ND

ND

ND

ND

ND

ND

Trichlorocthvlcne

ND

ND

ND

ND

ND

ND

ND

ND

Vinvl Chloride

ND

ND

ND

ND

ND

ND

ND

ND

Total Xylenes

ND

ND

ND

ND

ND

ND

ND

ND

Notes:

















Source: Data received from the Miami-Dade Water and Sewer Department







ND = Not detected with a method detection limit of 0.50 ng/L









1-1

-------
Figure 1-1: Preston-Hialeah Production Well Map6

6 Received from the Miami-Dade Water and Sewer Department

1-2

-------
APPENDIX J - DETAILED ARARS REVIEW TABLES

CERCLA Section 12 l(d)( 1) requires that Superfund remedial actions attain "a degree of cleanup of
hazardous substance, pollutants, and contaminants released into the environment and control of further
release at a minimum which assures protection of human health and the environment." The remedial
action must achieve a level of cleanup that at least attains those requirements that are legally applicable
or relevant and appropriate. In performing the FYR for compliance with applicable or relevant and
appropriate requirements (ARARs), only those ARARs that address the protectiveness of the remedy are
reviewed.

According to the OU-2 ROD, cleanup goals the EPA selected for groundwater VOC priority pollutants
were based on federal and state drinking water standards. In the absence of drinking water standards, the
EPA selected promulgated ambient water quality criteria (AWQC). In the absence of chemical-specific
ARARs, the EPA developed health-based cleanup goals. ARARs from the OlJ-2 ROD were compared
to current federal and state promulgated standards to identify any changes (Table J-l).

New standards have been promulgated for nine VOC priority pollutants since the OlJ-2 ROD. In
addition, standards are now less stringent for four priority pollutants (benzene, methylene chloride, 1,1-
dichloroethylene and 1,1,1-trichloroethane), while one standard became more stringent (chloroform).
Although some of the values have changed, this does not impact the protectiveness of the remedy
because the WTPs monitor the water to ensure that drinking water from the Preston and Hialeah wells
meets all current state and federal drinking water standards prior to being supplied as drinking water to
the public.

J-l

-------
Table J-l: Evaluation of 1985 Biscayne Aquifer Cleanup Goals

Groundwater COC

ARARs Listed in OU-2
ROD (n«/L);1

Current Standards
OiR/L )b

Change

Acrvlonitrilc

0.34

	

	

	

None

Benzene

0.7

EPA AWQC

1

FL MCL

Less stringent

Bromodichloro methane

	

	

80°

EPA MCL

New standard

Chlorobcn/ene

	

	

100

EPA MCL

New standard

Chloroethanc

	

	

	

	

None

Chloroform

100

EPA MCL

80°

EPA MCL

More stringent

Chloromethane

	

	

	

	

None

1,1 -Dichloroethane

0.9

EPA AWQC

	

	

Withdrawn

1,1 -Dichloroethy lene

0.04

EPA AWQC

7

EPA MCL

Less stringent

Cis-l,2-Dichloroethylene

__

__

70d

EPA MCL

New standard

Trans-l,2-Dichloroethylene

__

__

100d

EPA MCL

New standard

Ethvlben/cne

__

__

700

EPA MCL

New standard

Methylene chloride

0.2

EPA AWQC

5

EPA MCL

Less stringent

PCE

	

	

3

FL MCL

New standard

1,1,2,2-Tetrachloroethane

0.2

EPA AWQC

0.2

EPA AWQC

None

Toluene

	

	

1,000

EPA MCL

New standard

1,1,1-T richlorocthane

22

EPA AWQC

200

EPA MCL

Less stringent

TCE

	

	

3

FL MCL

New standard

Vinyl chloride

1

FL MCL

1

FL MCL

None

Xylenes (total)

__

__

10,000

EPA MCL

New standard

Notes:

a.	Values listed in Table 11 of the Site's OU-2 ROD for priority pollutant VOCs with promulgated standards
which included the following:

EPA MCL = EPA maximum contaminant level
FL MCL = Florida maximum contaminant level

EPA AWQC = EPA 1980 Ambient Water Quality Criteria for Human Health

b.	Based on the lower of the national drinking water MCLs (40 CFR 141), available at

htlDs://www.eDa.gov/eroiiiid-wafer-aiid-driiikiiig-wafer/iiafioiial-Driiiian'-driiikiiig-wafer-reeiilafioii-fable
(accessed on 10/21/2022), and the Florida 62-550.310 Primary Drinking Water Standards, available at
Mtos://www.finiles.ore/eafewav/CtoDferHoiiie.asD?CltaDfer=62-S50 (accessed on 10/21/2022). The
EPA's recommended water aualitv criteria, available at httDs://www.eDa.eov/wac/national-recommended-
water-aualitv-criteria-human-health-criteria-table (accessed on 10/27/2022) arc used if no MCL is
available.

c.	The EPA MCL for Total Trihaloinethanes (TTHM) which includes broinodichloroinethanc. broinoforin.
dibroinochloroinethane and chloroform.

d.	OU-2 ROD cleanup goal was combined for cis-l,2-dichloroethylene and trans-l,2-dichloroethylene.
Hg/L = micrograms per liter

- = standard not available; OU-2 ROD cleanup goal was health based.

J-2

-------
APPENDIX K- HISTORICAL SOIL DATA REVIEW

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 4
61 FORSYTH STREET
ATLANTA. GEORGLA. 30303-8960

¦ \
m)

% JF

July 27, 2021

MEMORANDUM

SUBJECT:

FROM:

Historical Data Review
Miami Drum Sendees,
Miami-Dade County, Florida

Sydney Chan, Life Scientist
Scientific Support Section

SYDNEY
CHAN

TO:

THRU:

Marcia O'Neal. Remedial Project Manager
Restoration and Construction Section

Tim Frederick. Chief Ti IT)

Scientific Support Section Frederick

Dkjltaty s-grec try
SYDNEY CHAN
Ds:e: 2021.D7J7
1Q:25:2C -04'D0'

Digitally signed by
Tim Frederick
Dale: 2Q21.07.27
10:32:14 -04'OT

Per your request, Scientific Support Section (SSS) has reviewed the historical soil data and
confirmatory excavation data provided for the Miami Drum Services Superfund Site, Miami-
Dade County, Florida (the Site).

Review of the pre- and post-excavation of soils on the Site concluded that there are no soils
remaining on-site that would pose an unacceptable risk to human health. Furthermore, soils at
depth were sampled and confirmed to be below Florida's Department of Environmental
Protection teachability values.

Groundwater contamination at the Site lias been historically investigated and determuied that
there is no evidence that the contamination is emanating from the Miami Drum Site (CH2M Hill.
1983).

The data reviewed addresses the issues raised in my August 7, 2018 Memorandum titled Fourth
Five-Year Review. If you have any questions regarding this review, you can contact me at 404-
562-8907 or chan.sydnev@epa.gov.

K-l

-------