Record of Decision Petroleum Products Corporation Superfund Site Pembroke Park Broward County Florida CERCLIS ID: FLD980798698


RECORD OF DECISION

PETROLEUM PRODUCTS CORPORATION
SUPERFUND SITE

Pembroke Park, Broward County, Florida

CERCLIS ID: FLD980798698

PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA, GEORGIA

July 2021

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Petroleum fVcxJocu Oxponrtioa SuperfUnd Site
ReconJ of Decision
July 2021

RECORD OF DECISION

TABLE OF CONTENTS

Acronyms and Abbreviations							v

PARTI: DECLARATION

FART 1; DECLARATION.	...A

1.0 Siil€s Nmiifi slid								•«»*!

2.# Statement of Basis and Purpose—	I

3.0	Assessment of tit Site	1

4.1	Description of Selected Remedy 		1

5.0 Statutory Determinatfcms

6.0 Oata Certification ChecldtsC..													.«««3

7.0 Authorizing Signature			—3

PARI 2: THE DECISION SUMMARY.......................							...............4

1.0 Site Name, Location and Brief Description

2.0	Site History and Enforcement Activities	

2.1	Site Operational History

2.2	Regulatory and Investigation History								.6

3J Community Participation		8

4.0 Scope and Role of the Response Action		9

5.0	Site Characteristics				9

5.1	Conceptual Site Model					............	.........9

5.2	Overview of the Site				10

5.2.1	Geologic. Hydxogcologic and Topographic Information					10

5.3	Sampling Strategy		.		12

5.4	Known or Suspected Soun.es of Contamination 				13

5.5	Nature and Extent of Contamination	 ... 		......... 	 ..13

5 5.1 Nature and Extent of Sludge Contamination					13

5.5.2	Nature and Extent of NAPt Contamination					16

5.5 3 Nature and Extent of Soil Contamination					18

5A4 Nature and Extent of Groundwater Contamination			20

6.0	Current and Potential Future Land and Water I ses		.2!

6.1	Laud Uses					21

6.2	Ground and Surface Water Uses									..............22

"7.0 SiimnnuA of Site* Risk-s.......................,.....2^>

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7. 1 Baseline Ecological Risk Assessment					.	. .23

7.2 Human Health Risk Assessment						23

7.2.1	1 kt/ard Identification									23

7.2.2	Exposure Assessment.....				.				24

7.2.3	toxicity Assessment.												25

7.2.4	Risk Characterization															25

7.2 5 Uncertainties	 				

8.0 Basis for Action ...30
*1.(1 Remedial Action Objectives				30

10.0	Description of Alternatives	..	..					31

10.1	Description of the Common Elements							 3!

10.1.1	Iiistiliitioual Controls			31

10.1.2	Unsaturated Zone	31

10.1.3	Common tiement ! Bamboo Mobile Home Park hxeavation and Relocation , ..32

I It J 4 C "ommon Plement 2 - Building Demolition and Relocation of Businesses and
Tenants Overlying the Main Source .Area									.33

10.1	5	Common Element 3 A -- Shallow Excavation Under Buildings - Retain Existing
Buildings	33

10,1.6	Common Element 3B - Shallow Excavation Under Buildings • Demolish Existing

Buildings	34

HI 2 Description of the Unsaturated /one Remedy Alternatives 			35

! 0 2 I	Unsaturated Zone Alternative U No Action 			..35

10.2	2	Unsaturated Zone Alternative 2 Fxeavution and OtV-hacilits Disposal in Landfill36

10,2.3 Unsaturated Zone Alternate .V Excavation, S*,\~S;tu Stabilization Solidification

and Disposal io

!0.2 4 Unsaturated Zone Alternative 4 In-Situ Stabilization-Solidification with Limited

Soil Txea\ation and OtT-Facility Disposal		 . 						37

It).2.5 Unsaturated Zone Alternative 5: £\eavaiio:i. Ex-Sstu Thermal Treatment and
Stabilisation- Solidification with Disposal				38

10,3 Description of the Main Source Area Remedy Alternatives			38

10.3.1 Main Souree Area Alternative l: No Action							39

10.3.2	Main Souree Area Alternative 2- F wioation and Off-Facility Disposal in Landfill

39

10.3.3	Mailt Souree Area Alternative 3: In-Situ Stabilization/Solidification with LDAs...40

10.3.4	Main Souree Area Alternative 4; Excavation, Ex-Sifu Thermal Treatment and
Stabilization/Solidification with On-Site Disposal	41

10.3.5	Main Souree Area Alternative 5: In-Situ Thermal Treatment (Conductive Heating)
with Chemieal Reduetion									41

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Petroleum Products Cotpontion Supcrfind Site
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0 4 Description of lie Extended Plume Remedy Alternatives	..............................	 . 42

st 4.1 Extended Plume Alternative i: No Action 				.		42

0.4.2	Extended Plume Alternative 2' Groundwater Recovery and Treatment		43

l) 4 x Extended Flume Alternative 3: In-Siiu Carbon Injection and In-Situ Reduction
Vnrcieuble Barriers 43

0	4,4 Extended Plume Alternative 4: Monitored Natural Attenuation					.44

1.0	Comparative Analysis of Alternatives					45

1.1	Unsaturated Zone							,.,..45

1.1.1	Overall Protection of Human Health and the Environment			45

t.1.2 Compliance with ARARs..										.................	45

1.J.J	Long-Term Effectiveness and Permanence				.................	46

1.1.4	Reduction of Toxicity, Mobility or Volume through Treatment				.4?

1	1.5 Short-Term effectiveness											47

1,1 .h Implementability				......48

I I 7 Cost........................................................................................	48

I 2 CMZ 2 - Main Source Area													 .4**

1 2.1 Overall Protection of Human Health and the Environment			49

1.2.2	Compliance with ARARs							49

1.2.3	Long-Term Effectiveness and Permanence								49

t 2 4 Reduction of Toxicity, Mobility or Volume through Treatment		..5U

1.2.5	Short-Term htketneness			................	,...„50

1.2.b Impiemenuibihry		 . .........51

1,2.7 Cost.............................................................................................51

I 3 CMZ 3 - Extended Plume			 	52

U.I Overall Protection of Human Health and the Environment	........................52

1.3.2 Compliance with ARARs			52

1,3.5 Long-Term Effectiveness and Permanence 	.................	52

1.3.4	Reduction of Toxicity. Mobility or Volume through Treatment. . , 		53

1 3.5 Short-Term Effectiveness		......						.53

I To Implementability												53

1.3.7 Cost....,,			...................................54

2.0 Principal Threat Waste < PTW)	54

3.0	Selected Remedy		S5

3.1	Summary of the Rationale for the Selected Remedy,,..						55

3.2	Description of the Selected Remedy						56

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13.2.1	OU-I: Unsaturated Zone Alternative 4 In-Situ Stabilization Solidification with
Limited Soil Excavation, and Off-Site Disposal				.56

13.2.2	OU2; Main Source Area Alternative 3, In-Silu Sfabilization/Sotidification with
I.DAs	57

112. ^ O10: Extended Plume Alternative 2, Groundwater Recovery and Treatment.,	57

! 3.2 4 Common Elements and Sitewide Costs	..					.	..		58

13.3	Cost Estimate for the Selected Remedy				—				...58

13.4	Estimated Outcomes of the Selected Remedy								58

14.0	Sta tutory Dctcrimiistion < ....5^

14	1 Protection of Human Health and the Environment		........................	59

14.2	Compliance with ARARs								60

14.3	Cost Effectiveness						60

14.4	Use of Permanent Solutions and Alternative Treatment Technologies to the Maximum
fcx tent Practicable 60

14.5	Preference for Treatment as a Principal Element		61

14.h Five-Year Review Requirements	................						62

15	J Documentation of Significant Changes		62

16.1) References	64

T AM.-IKS
Table 1

Table 2
Tabic 3
Table 4

Table 5
Table n

Table 7
Table 8

Table 9

Table 10

Table 11

Table 12
Table 13

Occurrence, Distribution and Selection of COCs in Surface Soil
Occurrence, Distribution and Selection oft OCX in Subsurface Soil
Occurrence, Distribution and Selection of COCs in Groundwater
Risk Characterization Summary - Non-Carcinogens (Future Resident)
Risk Characterization Summary - Carcinogens (future Resident)

Risk Characterization Summary - Non-Carcinogens (Future Outdoor

Worker)

Risk Characterization Summary - Carcinogens (future Outdoor Worker)

Risk Characterization Summary - Non-Carcinogens (Future Tenant,

Young Child)

Risk Characterization Summary - Carcinogens (Future Tenant, Young
Child)

Risk Characterization Summary Non-Carcinogens (Future Construction
Woiker)

Risk Characterization Summary - Carcinogens (future Construction
Worker)

Cleanup Levels for Groundwater

Cleanup Levels for Surface Soil

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Tabic 14
Tabic 15
Fable 16
Tabic 17

FIGURES

Figure 1

Figure 2
Figure 3
Figure 4
Figure 5
Figure 6
Figure 7
Figure S

APPENDICES

Appendix A
Appendix B

Appendix C
Appendix D

Petroleum Products Corpomtioa Superitittd Site
Rccorf of Decision
My 202 i

Cleanup Levels for Subsurface Soil
Chemical-Specific ARARs

Action-Specific ARARs

Selected Remedy Cost Estimate Summary

Site Location Map-

Site Layout Map

Historical Site Las out

General Conceptual Site Model

Haltandale, Florida Wellfield, 270-Day Travel

Conceptual Site Model

Building Demolition for Common Elements

Recommended SitewMe Remedial Alternative

Response to Comments

Transcript of January 2021, Public Meeting

Selected Remedy - Detailed Cost bstimate Sheets

State Correspondence

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Petroleum Products Conwratum Supcrfuad Site

fecord of 1 )eo»nm

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ACRONYMS AND ABBREVIATIONS

ALM	Adult Lead Methodology

ARAR	Applicable or Relevant and Appropriate Requirement

BC'HQCB	Broward County Environmental Quality Control Board

bis	Below Land Surface

BTEX	Benzene. Toluene, Ethylbenzene and Xylene

CT.RCLA	Comprehensive Environmental Response, Compensation, and Liability Act

CERCL1S	Comprehensive Environmental Response, Compensation, and Liability Information
System

CI R	Code of federal Regulations

CGC	Chemical of Concern

CO PC	Chemical of Potential Concern

CTL	Cleanup Target Level

CM/	Contaminated Media Zone

DBCP	1,2-Dibromo-3-Ch!oropropanc

DNAPL	Dense Non-Aqueous Phase Liquid

KDB	Ethylene Dibromide

EPA	U.S. Environmental Protection Agency

fcf'C	F.xposurc Point Concentration

ESD	Explanation of Significant Difference

FAC	Florida Administrative Code

FDFF	Florida Department of Fnvironmcntal Protection

FS	Feasibility Study

F.S.	Florida Statute

GAP	Gastrointestinal Absorption Factor

GCTL	Groundwater Cleanup Target Level

GR&T	Grotindwater Recovery and Treatment

HAP	Hazardous Air Pollutant

11FIRA	Human 1 lealth Risk Assessment

HI	Hazard Index

HQ	II a/ard 0 no tient

IAROD	Interim Action Record of Decision

IC	Institutional Control

ILCR	Incremental Lifetime Caneer Risk

LDA	Large Diameter Auger

LDR	Land Disposal Restriction

LNAPL	Light Non-Aqueous Phase Liquid

MCL	Maximum Contaminant Level

|jg/kg	Micrograms per Kilogram

jtg/dl.	Micrograms per Deciliter

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Petroleum Products Coiponuioa Supcrfuod Site
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|ig/L

Micregranis per Liter

mg/kg

Milligrams per Kilogram

mg/kg/day

Milligrams per Kilogram per Day

rog/L

Milligrams per Liter

NA

Not Applicable

NP

Not Determined

Hg^C

Nanograms per Kilogram

N 'VPL

Noil-Aqueous Phase liquid

NOAEL

No Observed Adverse Effect Level

WIT

National Contingency Plan

NPDES

National Pollutant Discharge Elimination System

NPL

National Priorities List

NPW

Net Present Worth

tkfcM

Operation and Maintenance

OSWfcR

Office of Solid Waste and Emergency Response

OU

Operable Unit

PAH

Polycyclic Aromatic Hydrocarbon

PCB

Polychlorinated Biphenyl

ITOS'PFOA

Perfhiorooctane Sulfonic Acid / Perfluorooctanoic Acid

PKCi

Preliminary Remedial Goal

PRP

Potentially Responsible Party

PI W

Principal Threat Waste

RAO

Remedial Action Objective

R( RA

Resource Conservation and lecevery Act

RID

Reference Dose

RI

Remedial Investigation

ROD

Record of Decision

SARA

Superfund Amendments and Reauthorization Act of 1986

SL

Slope Factor

SCTL

Soil Cleanup Target level

Site

Petroleum Products Corporation. Superfund Site

STARx

Ex Situ Smoldering

SVOC

Semi-Volatile Organic Compound

TIC

1 Be Considered

TCDD

Tetrachlorodibenzo-p-dioxin

TCE

Trichloroethene

TCLP

Toxicity Characteristic Leaching Procedure

TEQ

Toxicity Equivalent

TOO

Total Organic Compound

ft I

Upper Confidence Limit

IIS ACT

U.S. Army Corps of Engineers

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Petroleum Products Ccifpoeition SuperfUnd Sile
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I'Si5S	U.S. Geological Society

\ i K:	Volatile Organic Compound

VOf f -\P	Volatile Organic Hazardous Air Pollutant

\V<„)ATF	Water Quality Assurance Trust Fund

WWF	Wastewater Factor

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Petroleum Products Coiponttion Supetfund Site
Record of Decision

PART 1*. DECLARATION
1,0 Site Name ami Location

Petroleum Products Corporation Superiund Site OU1, ()U2, OU3
Pembroke Park, Broward County, Florida
CERCI IS ID: FI..D980798698

Lead Agency U.S. Environmental Protection Agency
Support Agency; Florida Department of Environmental Protection

2.0 Statement of lasts and Purpose

This decision document presents the final selected remedy for the Petroleum Products
Corporation Superfund site (Site), operable unit 1 (OU 1 > and OU2 and the interim remedy
selected tor UU3, which were chosen in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act (SARA.) of 1986,42 IJ.S.C, Section 9601 et scq., and, to
the extent practicable, the National Contingency Plan (NCP) 40 Code of Federal Regulations
(CFR) Part 300, This decision is based on the Administrative Record for the Site, which has been
developed in accordance with Section 113(k) of CERCLA, 42 IJ.S.C, § 9613(k). The
Administrative Record is available for review online at m%ny.fpi»g
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Petroleum Products Corporation Supcrfund Site
Record of Decision
July 2021

Solid Waste and Emergency Response [OSWER] 9380.3-06FS - 1991). PTW is source material
that is considered highly toxic or would present significant risk to human health should exposure
occur, or it acts as reservoir for mobile contaminants and there is an expectation in the NCP to
treat such wastes wherever practicable unless the EPA determines that such wastes can be
reliably contained. Sludge and highly contaminated soil are also PTW. The selected remedy for
OU1/OU2 will eliminate direct contact with source material considered PTW in the Unsaturated
Zone and Main Source Area and will reduce the leaching of contaminants of concern to the
Biscavne Aquifer. The interim selected remedy for GU3 (Extended Plume) will address residual
groundwater contamination following containment of source materials under the OU1/OU2
remedy.

The selected remedy for the Site is:

• OUI: In-Situ Stabilization/Solidification with Limited Soil Excavation and Off-Facility
Disposal,

• OU2: In-Situ Stabilization/Solidification with Large Diameter Augers (LDAs).

• OU3: Groundwater Recover.' and Treatment (GR&T).

Common elements of the selected remedy are:

• Bamboo Mobile Home Park excavation and temporary relocation.

• Building demolition and relocation of businesses arid tenants overlying the Main Source
Area.

• Shallow (0 - 5 ft bgs) excavation under buildings.

• Institutional controls (ICs) to prevent well installation and any use of contaminated
groundwater, to provide increased public awareness and restrict disturbance of the in situ
treated waste that remains at the Site as well as interference with other remedy
components such as existing or future remediation system and/or monitoring wells. Land
use at the Site (other than Bamboo Mobile Home Park which is currently residential) will
be restricted to remain industrial/commercial use.

• Long-term groundwater monitoring to assess remedy performance.

• Site reviews at a minimum of every five years to assess the protectivencss of the remedy
(Five-Year Reviews).

5,® Statutory Determinations

Based on the information currently available, the EPA believes the selected remedy meets the
threshold criteria and provides the best balance of tradeoffs among the other alternatives with
respect to the balancing and modifying criteria. In compliance with CLRC'L.A Section 121(b) and
Section 12 lid), the selected remedy is protective of human health and the environment, complies
with federal and state environmental requirements that are applicable or relevant and appropriate
to the remedial actioss, is cost effective, and utilizes permanent solutions and treatment
technologies to the maximum extent practicable.

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Petroleum Products Corporation Superfund Site
Record of Decision
July 202!

The selected in-situ stabilization/solidification remedy for NAPL and sludge-impacted soil in the
Main Source Area and Unsaturated Zone (OU1 and OU2) satisfies the statutory preference for
remedies that employ treatment to reduce toxicity or volume or mobility as a principal element.
Isolation/containment reduces mobility but will not reduce toxicity or volume of the
contaminated soil and NAPL. However, it does eliminate the risk exposure pathways of
ingestion or inhalation to humans.

Because this remedy will result in hazardous substances, pollutants or contaminants remaining
on site above levels that would allow for unlimited use and unrestricted exposure, a CERGLA
Section 121(c) statutory review will be conducted every five years after initiation of the remedial
action to ensure that the remedy remains protective of human health and the environment. If
results of the Five-Year Reviews reveal that remedy integrity is compromised and protection of
human health is insufficient, then more remedial actions will be considered and evaluated by the
EPA and the FDEP,

6 J Data Certification ChecWist

The following information is included in the Decision Summary Section of this ROD. More
information, can be found in the Site's Administrative Record file.

• Chemicals of concern (COCs) and their respective cleanup levels (Section 7 and Section
8, Table 1 and Table 3).

• Baseline risk represented by the COCs (Section 7, Tables 4 through 11).

• Cleanup levels established for COCs and the basis for these levels (Section 8, Table 12
and Table 14).

• How source materials constituting principal threats are addressed (Section 11).

• Current and reasonably anticipated future land use assumptions and current and potential
future beneficial uses of groundwater used in the baseline risk assessment and ROD
(Section 6),

• Potential land and groundwater use that will be available at the Site as a result of the
Selected Remedy (Section 6),

• Estimated capital, annual operation and maintenance, total present worth costs, discount
rate, and the number of years over which the remedy cost estimates are projected (Section
12, Table 17).

• Key factors that led to selecting the remedy (i.e., how the selected remedy provides the
best balance of tradeoffs with respect to the balancing and modifying criteria,
highlighting criteria key to the decision) (Section 12 and Section 13).

AUG 1 2 2021

Michael S. Regan
EPA Administrator

Date

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l-'etawuTi tT^tJuch i >rsw>i,i,"Kin SM.fKi i.t»sV.

Ha-ptv! ft t >^cskn,ri
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PART 2: THE DECISION SUMMARY

1.0 Site Name, Location and Brief Description

This ROD is for the Petroleum Products Corporation Superfund site (Site; EPA ID:
FLD98079869S) in Pembroke Park, Broward (. ounty, Florida The Site is about 8 acres in size
and is bounded by Pembroke Road to the north, SW 31st Avenue to the cast, Carolina Street to
the south and South Park Road to Ihe west (figure 1 h The facility it> a former processor and
broker of waste oil and other petroleum products in a moderately dense commercial, industrial,
and residential district (Figure 2). The Site includes several commercial properties containing
mini warehouses that are used for commercial and private storage and small businesses (e.g., a
shooting range, a restaurant, paint and repair shops, cabinet makers, woodworking facilities,
manufacturing facilities). The southeast comer of the property contains a fenced area where a
former bioslurper treatment system was located. The adjacent properties around the facility
include a public golf course to the. north, mobile home trailer parks to the south and west, and
light industrial''commercial businesses to the east and west. The Site has been heavily impacted
by development

Contamination within the pro pern boundary includes two waste oil sludge pits that partially
underlie some commercial warehouses and asphalt-covered access roads. The NAP1. and sludge-
impactcd soil extend beneath additional adjacent commercial and industrial warehouses A broad
range of chemicals of concern (COOs) are present within the properly boundary because of the
former petroleum operations, notably several volatile organic compounds (VOCY), some semi-
volatile organic compounds f SVOCs) and lead. Contamination outside the property boundary
includes petroleum contamination in shallow soil around a residential mobile home in the
Bamboo Mobile Home Park, located south of the southeast comer of the property.

The EPA anticipates that the cleanup of the Site will be funded by the Site's potentially
responsible parties (PR? Groups

2.1 Site History and Enforcement Activities
2.1 Site Operational History

The Petroleum Products Corporation was founded in Pembroke Park Florida, in 1958, The
facility also operated under the names International Petroleum Corporation and the National Oil
Service of Florida, Inc. The Petroleum Products C orporation facility operated from about 1958 to
1971 as a processor and broker of waste oil and other petroleum products, including the
reprocessing of used oil using a sulfuric acid-clay refining process. This process generated
sulfuric acid sludge and spent clay containing petroleum hydrocarbons and metals
contamination The sludge waste and spent clay was disposed of at the Petroleum Products
Corporation property* in excavated, unhned pits, about 2 acres m size. Excavation of the Primary
Sludge Pit included removal of limestone bedrock using a dragline. The Secondary Sludge Pit
may have been a pond that was filled in with sludge and. fill (and potentially some of the
excavated limestone) as opposed to a new excavation Petroleum Products Corporation operators
also received other types of hydrocarbon waste containing poiychlonnated biphen>ls (PCBs) and
chlorinated solvents that were also disposed of in the unlined pits.

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Pttrolet* Product* Cotpotttkm Supafuad Site

M,ee«rf of Decision
July 2021

Due to the shallow groundwater table and high amounts of precipitation, the sludge pits would
overflow and spread oil and sludge across the property. In addition, poor management practices
during Petroleum Products Coiporation operations resulted in oil and sludge being spread across
much of the property, Most of the sludge material is buried below the groundwater table, where
it is in constant contact with groundwater, subsequently promoting leaching of contaminants into
the Biscayne Aquifer, a federally designated sole-source aquifer used as a drinking water supply.

Historical records indicate that Petroleum Products Corporation oil reprocessing operations
occurred primarily from ! %6 to I %1 At that time, the facility had about 22 aboveground
storage tanks and the Primary Sludge Pit was in full operation (Figure 3). It was during this
period that residents in the Bamboo Mobile Home Park on the south side of the Site began
complaining to Petroleum. Products Corporation and local authorities about overflows of oil from
the disposal pits, In 1970, Petroleum Products Corporation modified its operation due to an
overflow of liquid in the disposal pits that spread contamination into the mobile home park to the
south.

Oils recycled at lie Site include petroleum feel oils, motor oils, boiler feel, gear oil and other
petroleum products from a variety of local sources, including federal entities, county tad city
fleet maintenance, car dealers, automotive shops and industrial/commercial facilities. Daily
refinery work sheets indicated the use of sulfuric acid, with typical usage between 350 to 500

gallons per day.

The actual treatment processes used at the Site are not well documented. The facility used an
acid-clay reining process. The sludge was characterized by the facility owner as a Fuller's earth.
Filler's earth typically consists of attapulgite or bentonite (montmorillonite, kaolinite) clays that
have an affinity for removing oily impurities. A typical clay-refining process generates skimmed
oil. wastewater, filter residues, taak bottoms, oily acid sludge and spent clay. Impurities in the oil
hang refined, such as metals, arc also typically found in the waste residues.

Between 1970 and 1971, Petroleum Products Corporation sold parts of the facility property. The
waste pits were covered with fill material, and there are indications contaminated sludge/soil was
spread across the surface of the property. Petroleum refining operations ended in 19? 1, By 1972,
the warehouse complex (cwreafly blown as the Pembroke Park Warehouses) was constructed on
the former Petroleum Products Corporation property.

Other petroleum-related operations at the facility continued from 1971 to 1985. They were
primarily restricted to the southeast comer of the Site, where a petroleum storage and distribution
facility operated. Petroleum storage and distribution operations ceased in 1985. Buildings were
constructed along the west side of southwest 31st Avenue, along the east side of the former
Primary Sludge Pit. in 1984 and 1985.

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2,2 Regulatory and Investigation History

aukui'i ?hx!lcI' n .>i.p«,t!U!U 1» t

Recwd »ii Oc;vis"»rt
hjly ?'Vt

This section summarizes pertinent federal, state and local site investigations and regulatory
activities from the 1970s through 2019, In 1979, the Broward C ounty Environmental Quality
Control Board iBCEiQCB) completed an inspection of the facility and subsequently issued
multiple warnings concerning oil and wastewater discharges from a bertned tank farm area and
seepage of oil from filled pits. These warnings were followed by letters from the BCEQCB
concerning complaints of oil seeping through warehouse foundations and asphalt throughout the
property la 1983, the Honda Department of bovironmeiifal Regulation (predecessor to the
FDEFl issued a notice of violation requiring Petroleum Products Corporation to remove waste
oil tanks from the property in preparation for further in\ estimations. In 1984, an initial
investigation by Petroleum Products Corporation confirmed the presence of groundwater
contamination and NAPL,

In the early 1980s, the BCEQCB received funding from the State of Fiends Water Quality
Assurance Trust Fund (WQATF) to investigate the extent of soil and groundwater contamination

at the property to determine the impact on nearby municipal well lie ids. The Hollywood
municipal well field is located 1.5 miles north of the property and the Italian dale municipal well
field is located about 0,5 miles to the east In June 1984, the State of Florida initiated a lawsuit
against Petroleum Products Corporation for violations of state statutes concerning the handling
and disposal of hazardous materials. This lawsuit included a cost-recovery contingency claim to
cover any allocated WQATP monies, la October 1984, the State of Florida retained
Environmental Science and Engineering, Inc. to investigate and determine the extent of NAPL
on the property. Ihese investigations found that NAPL covered an area of about 40,1100 square
feet 10.92 acres), with a maximum measured thickness in the wells of about 30 inches. The
investigation also concluded that the NAPL was slowly migrating to the east-southeast in the
direction of the Bamboo Mobile Home Park. Analytical results indicate that oil and grease were
the major contaminants, although significant levels of heavy metals and other organic
contaminants were present.

In 1985, the EPA collected samples that showed significant levels of hazardous compounds,
including chlorinated solvents and heavy metal*,. As a result, the PPA issued an Administrative
Order on Consent ( \0O under CERCLA authority for Petroleum Products Corporation to
conduct an emergency removal action at the property. Under EPA oversight. Petroleum Products
Corporation hired a contractor that removed, analyzed, and disposed of oil, water and sludge in
262 waste drums in accordance with regulations. The contractor disposed of or recycled all
wastes. Petroleum Products Corporation dismantled and removed all structures and tanks that
were stored on the property. The top 6 inches of contaminated soil was removed from the tank
area and the excavation was backfilled with clean sand fill from an off-site source

The EPA added the Site to the Supertiind program \ National Priorities List i N PL) in July 1987.
In 1989, the EPA assumed lead responsibility for the EJ/FS for 001 at the Site, The RI
con finned elevated concentrations of lead and chromium in soils. These contaminants were
identified as two primary inorganic "indicator" contaminants and focused on the nature and
extent of these metals. Composite soil samples from I) to It).5 feet below land surface (bis) bad

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luiy 2(C- f

lead concentrations as high as 22,4ni> milligrams per kilogram (tug,kg) and tola! chromium
concentrations as high as 38.5 mg/kg The Secondary Sludge Pit had nut vet been identified at
the lime of this im obligation. Sod analytical results from the central area of the property
indicated thai the depth of contamination had not been determined. Elevated concentrations of
lead and chromium in groundwater were confirmed and data indicated that the chromium plume
extended oil facility to the southeast.

The Ri connnued from August I'JXQ through June 1990 to further define the nature and extent of
groundwater contamination, and to collect data on the NAP! (NAPl ) plume, The investigation
concluded that areas of oil and oily-sludge contamination extended through the southeast
Primary Sludge Pit and west-central Secondare Sludge Pit. The RI Report also concluded that
some heavy metals bad become sorbed to the relatively immobile sludge matrix, whereas others
were migrating dovvrigradtem via adveetion, dcsorption-resorption and diffusion.

The EPA lotted im Interim Action ROD for OUl in 1990. The selected remedy was intended to
contain contamination sources until additional remedial alternatives could be assessed Remedial
components included abandonment of non-operating wells, closure of storm drain wells
discharging to the Biseayne Aquifer, a private well survey to identify groundwater users, and
modifications to the groundwater recovery system, originally installed by Petroleum Products
Corporation in 19X5, to improve efficiency of wa^te oil removal and contain future migration of
contamination. The EPA issued hxplannhons of Significant Differences (1'SDs) in March 1991
and 1998, The W1 ESD deferred the clogout of the surface drainage system until the
completion of OU2 remedy. The second ESD documented the significant differences between
recovery technologies m the original remedial design < groundwater extraction and treatment with
air .stripping and activated carbon) and the modified design implementation of a bioslurpcr
system). The PRP Group, implementing the remedy under a 1991 ( orient Decree, opted to try a
dliferent remedial technology to optimize free product recovery because the original remedial
design, which had been operating o( the Site since 1994, operated below the rale recommended
in the remedial design.

The PRP Ciroup installed a hioslurptmg system (vacuum enhanced reco\ cry of waste oiii at the
Sue in 1998, in 200S, the PRP Ciroup expanded this system to collect oil from most areas around
the Site. The collected oil accumulated m storage tanks that were shipped off site for treatment
and disposal, The bioslurpcr operated through October 2012, when the FDL P authorized
suspension of operation due to inefficiency in free product extraction and high operating costs.
At that time, the bioslurpcr system w.is reported to have recovered an estimated 30,t»95 gallons
of free product and 3,715 gallons of emulsified oil.

tn February 20 U, the PRP Group excavated 330 cubic yards of shallow, contaminated,

petroleum-impacted soil in the Bamboo Mobile Home Park, south of the former facility. This
excavation took place in the vicinity of Carolina Street and included excavation, off-site
dispos.il, backfilling and surface restoration work. The depth of the excavation was about 4 to 4,5
feet to the top of the groundwater table The area of (he excavation covered 2.53S square feet.

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Petroleum Product* Corpoottaa Supc»f ^ ,d i • t
Record of Decision

My 2021

The excavated soils were disposed of at a treatment facility. The excavated area was backfilled
with clean fill material The surface areas were restored by placement of sod and shrubs.

The 1TA completed an updated RI in 201 b to address data gaps and confirm the extent of soil
contamination.

Below are activities conducted at the Site from 1970 through 2019;

• ' 1970: Petroleum Products Corporation covered disposal pits with fill.

• 1985: PIP Group removed 262 drums of sludge,

• 1985: PRP Group installed a 30-inch diameter, 23-foot-deep free product recovery well
with an oil skimming unit along with a pump (about 7,(XX) gallons of oil was removed),

• 1995: PRP Group completed installation of OUJ NAPL removal system,

• 1999: The EPA documented the groundwater remedial technology inodiicalioii in the
!W(H1 USD.

• ?.00,V. PRP Group excavated and transported 2% Sens of soil off facility to allow for
installation of storm water main,

• 2009, PRP Group removed 400 gallons of NAPL from Warehouse flay 261.

• 2011: PHP Group performed a partial removal of soil to the water table (to a depth of 4,5
feet) on two residential mobile home properties, extending east into SW 31st Avenue.

• 201fv The 1'PA completed the RI and the Supplemental Human Health Risk Assessment
(HHRA)

• 2ul L> The hPA completed the FS.

3.0 Community Participation

Site documents, including the RJ/FS Reports and Proposed Plan, were made available to the
public on Januaiy 11,2021, in. the Administrative Record repositories. The Administrative
Record repositories are located at the EPA Region 4 Superfund Records Center (61 Forsyth
Street, Atlanta. liA 3 03 §3) and the local site repository, Broward County Public Library, located
at 100 South Andrews Avenue in Fort Lauderdale, Florida, A Notice of A\ailability was
published ia the Sun-Sentinel Newspaper on January 10, 202 L A public comment period on the
Proposed Plan was held from January 11,2021, to February 19.202 i.

On January N, 2021. the EPA hosted a virtual Proposed Flan meeting v in Zoom, due to the
COVlD-h) public health emergency During the meeting, the HV\ presented a description of the
Proposed Plan and schedule for remedy implementation and asked nearby residents and
interested parties to comment and ask questions of L PA officials. About 45 people attended the
meeting. Appendix B includes a transcript of the meeting

There were several comments and questions raised during the public meeting and EPA
representatives responded to them during the meeting. EPA responses to written comments

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Petroleum Products Corporation Superfund Site
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received during this comment period are included in the Responsiveness Summary, Part 3, of this
ROD.

4 J Scope and Role of tie Response Action

Tie Site is divided into three OUs:

1. OtII includes soil and groundwater impacted by NAPL or free product,

2. OU2 includes soil and groundwater impacted by oil/sludge.

3. OU3 includes contaminated groundwater and adsorbed phase contamination external to
OU1 and OU2,.

These OUs have been further divided into contaminated media zones (CMZs).

1. Unsaturated Zone - • CM/ !,

2. Main Source Area - CMZ 2,

3. Extended Plume - CMZ 1

The EPA issued an Interim Action ROD for OUI in 1990 to recover flee product NAPL in the
Unsaturated Zone. The EPA modified the OU1 interim remedy in 1991 and 1998, The selected
final remedy for the Unsaturated Zone and Main Source Area (OU1/OU2) documented in this
ROD will eliminate direct contact with source material constituting PTW (contaminated soil,
sludge and NAPL) and reduce the leaching of COCs torn this source material to the Biscaync
Aquifer, The selectee! interim remedy for the Extended Plume (OU3) documented in this ROD
will address residual groundwater contamination following containment of source materials,
under the OU1/OU2 remedy. The 0113 interim remedy is not expected to restore groundwater to
its beneficial use as a drinking water source. Consistent with the FPA's groundwater restoration
policy, remedial alternatives to restore groundwater at and beyond the boundary of the waste
management area (stabilized source material in the Unsaturated Zone and Main source Area)
will be developed after the effectiveness of the final OU1/OU2 remedy and interim OU3 remedy
has been evaluated.

5.0 Site Characteristics

5.1 Conceptual Site Model

figure 4 is a general simplified and idealized Conceptual Site Model developed for the Site. The
model depicts important site features, the subsurface lithology, known sources of contamination,
anil aspects of contaminant degradation and migration. The Conceptual Site Model is not drawn,
to either a vertical or horizontal scale, but instead represents important relationships in the
subsurface to the extent they are presently understood.

The Conceptual Site Model shows that several routes of potential contamination migration from
the Site are present. The primary source of COCs and NAPL is the sludge that extends across the
Site. The sludge is mostly a continuous layer with two distinct deep areas representing the former

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Petroleum Products Cofpontioa Superfcwl Site
Record erf Derision
July 2®2l

Primary Sludge Pit and Secondary Sludge Fit. The Primary Sludge Pit was located in the
southeast corner of the Site, near the main Petroleum Products Corporation operations. The

Primary Sludge Pit appears to have been an open unlined pit with an earthen berm that was
excavated to a deplh of about 20 feet bis to increase capacity for storage of liquid waste. The
horizontal extent of the Primary Sludge Pit appears to have been irregular in shape, with portions
extending to the north and south.

The Secondary Sludge Pit was in the central area of the Site, between the current location of
warehouses 3130 and 3140. The Secondary Sludge Pit appears to have been excavated as a long
narrow trench-oriented north-south and may have had a raised berm. A prior surface water pond
may have been used or expanded for this disposal pit. The purpose of the Secondary Sludge Pit is
unknown. It may have been excavated to receive oily waste and sludge at a time when the
Primary Sludge Pit was reaching capacity. However, the presence of a fairly consistent sludge
layer across much of the Site possibly indicates chronic overflow of oily sludge from both pit
areas. After site closure in the 1970s, it appears the pits were covered by fill material that may
have been partially mixed with residual oily sludge and spread across portions of the property.
No record of the date, duration or volume of specific releases of oil or sludge from process units
has been documented.

The sludge in the pits appears to be relatively stable and has not migrated significantly. Limited
migration of subsurface NAPL and ongoing dissolution of NAPL has been occurring since
deposition. The sludge consistency varies across the Site, However, many areas are saturated
with NAPL. Due to the nature and low permeability of the sludge, NAPL is slowly released
above and below the sludge layer, serving as a constant source of oil for the Unsaturated Zone
and Main Soiree Area (OU1). The sludge acts as a barrier to the horizontal and vertical
movement of groundwater due to its oily nature and very low permeability. As groundwater
interacts with the edges of the sludge, organic and inorganic constituents in the sludge slowly
dissolve and are transported along with the groundwater. 1 he suricial Biscayne Aquifer is
characterized by very high hydraulic conductivity albeit low groundwater flow velocities wMch
prevent extensive movement of contaminated groundwater. The sludge (0112) will continue to
serve as a source for NAPL tUUU and dissolvedCOCs in the groundwater (OU3)until this
selected remedy is implemented.

5.2 Overview of the Site

5.2.1 Oologic, Ilydrogeologic and Topographic Information

The Site is in an area of south Broward County characterized by low topographical relief, about
three miles west of the Atlantic Ocean. Land elevations at the Petroleum Products C orporation
facility arc generally flat, at about 6-to-8-feet above meats sea level. Ground surfaces in the area
of the Site are mostly covered by asphalt, concrete and commercial structures. A significant
portion of the land area has been reworked and filled by spoils excavated from borrow pits
throughout the area. The former borrow pit areas are now retention ponds south and west of the

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Pc(»i»'\nr 'Vrchict," .trpnr.r on ,m :

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Site Prior to excavation and filling, the area was largely tow-lying marsh with elevations a few
feet above sea level,

Hvdmgi 'oiugicat Setting

The Site is ra southeastern peninsular Florida underlain by ti scries of carbonate and clastic
sedimentary units, which overlie an igneous and metamorphic basemen! at great depth. The
surface and subsurface units in southeast Florida make up the highly productive Biscayne
Aquifer The Biscayne Aquifer is a federally designated sole-some e aquifer thai supplies
drinking water to the South Florida population The FDEP classifies shallow groundwater at the
Site as Class (J-1 and (j-0 iFlorida Administrative Code [FAC] 62-520 4IU) The aquifer consists
of a highly permeable sequence of carbonate and Mhcielastic sediment that is about 200 feet
thick in southeast Broward County- The Riscayne Aquifer is underlain by a 500-U>-6OO-foot-
thick section of Miocene-age marls and ciay separating it from the Flondan Aquifer The
Biscayne Aquifer exists under water fable conditions tunc on fined) and is recharged by the direct
infiltration of rainfall Water levels are generally within 5 feet of the land surface, Water table
isopleih maps developed by the United States Geological Survey (CSCiS) in 2004 for the
Biscayne Aquiter u southeast Broward County indicate a regional hydraulic gradient to the east
and northeast, with distinct cones of depression associated with the Hollywood and Ilallandale
well fields, Prior gradients in the early 1990s indicated a southeasterly How direction,

The City of Ilallandale, Florida, radicates that its well field is located about 1,800 feel from the
Site, and the wells are screened at about J 60 feet bgs, near the base of the Biscayne Aquifer. This
well field pumps about 6.2 million gallons per cias, according to the City of Ilallandale s 2013

Beach-Water Supply Strategy Regional hydraulic gradients are very low, rarely exceeding
0.0002 even where well pumping effects are most pronounced The Biscayne Aquifer is highly
productive, with iransmissivities generally exceeding I million gallons,'day*foot (Wedderbunm
11)R2}. Specific yield is usually estimated at 0.20 to O 25. and wells completed in the Biscayne

Aquifer can generally be expected to yield up to 7.O00 gallons per minute. Pumping at the
1 lailandale Well Field is on the order of 5 to ? million gallons per day and on the order of I'' to
2ft million gallons per day at the Hollywood Wei! I ield. Studies have shown that saltwater
intrusion is an increasing problem in tins area due to groundwater pumping volumes,

Groundwater modeling by (be Broward County Planning and Environmental Regulation Division
indicates that the Site is within the 2-foot drawdown contour and less than 1,000 feel from the
.ID-day travel time contour for the Hallandale Welt Field. Figure 5 show* the 270-day travel

time eonlotir for the Ilallandale Well Field.

The well fields appeal to have an effect on contaminant migration, Groundwater removal from
the well fields is the primary factor controlling deeper flow (below 40 feet i, whereas the other
factors interact to produce extremely variable and rapid changes in shallow flow conditions,
During the RI. it was noted that, across the Site, groundwater was often encountered perched on
the sludge layer whereas the underlying sludge may be moist, oily, or even dry. In roost areas,
groundwater saturated soils were encountered below the sludge layer and the groundwater

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Petroleum Products ("nrpofaticm Sitpcrfurtd Site
Record of Decision
July 2021

returned to static level in or above or within the sludge layer. This indicates that the sludge layer
acts as a partial hydraulic barrier to groundwater flow at the Site.

Site-Specific Geolo&v

The Site has been covered by a significant amount of fill material to bring the area to useable
grade. In addition, the surficial area underlying the Site has been significantly disturbed by
operations at the former oil reprocessing facility, including excavation of sludge disposal pits and
disposal of oil-contaminated soil across the Site. No areas of native surface soil arc essentially
present at the Site What is presumed to be native material, consisting mostly of sandy limestone
(organic peat in the shallow subsurface of the west part of the Site), is encountered at depths up
to about 20 feet. The boundary between disturbed/contaminated material and native soil is easily
discernible in drilled soil core sections. Portions of the north warehouse area were found lo
contain significant amounts of construction-related till material such as concrete nibble and
broken brick in the shallow subsurface. This material appeared to be mixed with hydrocarbon-
stained dark soil. Some limited areas of fill and small debris were also encountered in the south
portion of the Site.

Site-specific lithology (exclusive of sludge and oil) recorded from soil borings generally consist
of layers of fine sand, silty sand and peat (up to 7-feet thick) overlying greyish white limestone
with sand. Isolated layers of white silty clay and gravelly sand were also noted above the
limestone. Surficial fill with or without sludge may include isolated concrete fragments and
debris, gravel, wood debris, glass debris and rubber tire material.

5,3 Sampling Strategy

Multi-media sampling was guided by the Conceptual Site Model which was refined as
understanding of the Site increased over time. Samples were collected to fill data gaps in
knowledge identified by previous site investigations and to provide a current view of site
contamination. Samples of soil, sediment, sludge, surface water and groundwater were collected
and evaluated to determine the nature and extent in these media, support assessment of risks, and
improve the hydrogeologic understanding of the Site. Samples have also been collected to assist
in the evaluation of potential remedy alternatives and treatment options.

The following activities were completed during the 2016 Rl:

• Completion of 136 soil borings, including 34 borings to define the Secondary Sludge Pit,
24 borings to define the Primary Sludge Pit, 40 soil borings to delineate the horizontal
extent along the site boundary, 12 soil borings to delineate dioxin contamination. 5
borings to investigate 1,4-dioxane contamination and 21 borings during the installation of
groundwater monitoring wells.

• installation of 37 groundwater monitoring wells, including 21 shallow monitoring wells,
13 intermediate screened monitoring wells with 5-foot screened intervals ranging from 30
to 50 feet bis, and three deep groundwater monitoring wells screened 70 to 75 feet bis.

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s\!f u't fxvtixt*1 >> p^rs ,ivp \ >'t, nl x>t~

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3u^ ?ft? I

• Laboratory analysis, of 103 subsurface soil samples, nine surface soil samples and nine
background soil analyses.

• Sampling and analysis of ail groundwater monitoring wells, annually from 2009 to 2013.

• Gcotechnicai analysts of four undisturbed .sludge samples.

• laboratory analysis of oil seep samples.

5.4 Known or Suspected Sources of C ontamination

The observed contamination at the Site in attributable to one or more of the following known or
suspected sources m the Unsaturated Zone and Mam Source Area:

• NAPt in the subsurface as a result of the on-site waste disposal info the Primary Sludge
Pit and Secondary Sludge Pit on site.

• Discharges from process tanks lines from the former oil recycling operations at the Site.

Several contaminant migration pathways shown in Figure 4 have previously contributed and or
continue to result in contaminant migration"

• On-site sludge, mobile ISA PL and residual NAI'L represent an ongoing release of
contamination for sot! and groundwater.

• On-site v mI with adsorbed phase contamination is a source of leachatc for groundwater

• Historical water tabic fluctuations have contributed to oily waste overflows that have
migrated off-facility, including toward the Bamboo Mobile Home Park to the south.

• Prior stormwater runoff and airborne transport of contaminated fugitive dust from the

Site may have earned low-(eve! eontammation to adjacent properties.

• Stormwater transport of contamination off-facility has been minimi/ed via stormwater
engineering controls, S loxvever, the presence of ongoing seeps (day lighting sludge) and
the condition of the asphalt cover present an ongoing mechanism for off-laeility transport
and/or redistribution of eontammation.

• Direct contact of the local community or site workers with sludge, oil or contaminated
surftetal and subsurface sot! is also a receptor concern.

5.5 Nature and Extent of C ontamination

The nature and extent of contamination of the €OC> identified by the SRI and risk assessment
processes is summarized below for each environmental medium.

5.5,1 Nature and Fuent of Sludge ( ontamination

The physical characteristics and volumetric extent of the sludge pits are an integral factor for the
distribution and transport of COC s to different media. The sludge is principally wiihtn the
assumed perimeter for the Primary Sludge Pit and Secondary Sludge Pit, It is also present at
shallower depths across a large portion of the Site. The sludge is bound within a predominantly
sand-and-silt mixture 1 he sludge material consists of a black oily material that includes used oil
sludge, residua! waste from the clay-acid refining process formerly used at the property, and a

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f'«jx»!-Cuir Prodv-rfe 5usvrtund S.t<

Rvvori ol [>cc isioo

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mixture of native soils and fill. The Unsaturated Zone and Main Source Area include the sludge
found within the Primary Stodge Fit and the Secondary Sludge Pit; the main differentiator
between the two zones is depth. The Unsaturated Zone is (he 0-to-5-foot depth interval. The
Main Source Area is the 5-to-24-foot depth interval.

The texture of the sludge material is very heterogeneous throughout the Primary Sludge Pit. At
some locations, the sludge material exhibits a hard, dry, tacky, rubbery texture with a strong
petroleum odor. At other locations, the sludge had a much softer, muddy texture, and seemed 10
be saturated with NAPL. The nature of the sludge consistency varies across the Site, from a solid
and viscous liquid to areas saturated with NAPL. NAPL is present above and below the sludge
layer. The sludge acts as a barrier 10 the horizontal and vertical movement of groundwater due to
its oily nature and very low permeability .

The extent of sludge was evaluated through a large array of soil borings. Near the surface, at
intervals of 2-to-6-fect b!s, the sludge is more widespread than the original pit locations. As
depth increases, ihc sludge is more concentrated in the areai of die Primary Sludge Pii and the
Secondary Sludge Pit. Below a depth of 17 feet, the occurrence of sludge is significantly smaller
than Ihc footprint of the Primary Sludge Pit and Secondary Sludge Pit. After facility closure in
the 1970n, ihc Site was covered by fill material that may have been partially mixed with residual
oily sludge and spread across portions of the property. In addition, due to the shallow
groundwater table and frequent rain events, the sludge pits have overflowed and spread thin
layers of sludge materials outside of the pits, where it would accumulate in shallow depressions
across the Site. A summary of the area and volume of sludge and NAPL material for the
combined Primary Sludge Pit and Secondary Sludge Pit is shown below. Areas and volumes
down 10 6 feet bis are combined as they cannot be distinguished by the sludge pit source.

Sludge - Volumetric Summary
Depth

| CMZ1 - UiMtfaratMi Zeae (• is f feet lis)

Thickness

Soii

Impacted Swii Vftftsoic j

lf!fer%'at I>e!;tacacioii

0-1

very gooc

i -2

'.?6,.;57

5,050

very good

2-4

223,959

16,5%

veiy good

4 5

< ...

5-6

336,53?

12,464

very good

6-7

7-8

24#»M5

8,891

good

1 -9

9-10

176.885

6,551

good

10- 11

ND j

11 12

1 U.220

4,1 if

good

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Petroleum Products Corporation Superfund Site
Record of Decision
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Sludge - Volumetric Summary

Depth

Thieknesi

Impacted Soil

Impacted Soil Volume

Interval Delineation

(feet bis)

(feet)

Area (feet3)

(cubic yards)

Confidence

12-13

13-14

92,195

3,415

good

14-16

16-17

45,080

1,670

fair

17-18

18-19

18,242

676

fair

19-20

20-21

10,093

374

fair

21-23

16,950

628

Fair

Notes:

Areas are interpolated and represent an approximation. The areas and volumes represent the extent of sludge and
NAPL impacted soil, not the estimated area/volume of sludge itself. Areas denoted as "ND" were not contoured
and hence a specific area and volume is not identified. These areas are expected to be approximately equivalent to
the average extent of the immediately overlying and underlying areas.

ND = not determined

NA = not applicable

A subjective determination of the delineation data confidence for the interval is indicated. With
increasing depth, some data confidence is lost as not all borings reached the same depths. It
should be noted that there is a (relative) lack of sludge data in the central/northern interior of the
Primary Sludge Pit as depth increases. There is no indication of sludge material being present
within the limestone layers at any depth. NAPL oil associated with the sludge has been noted
within limestone at several borings.

Sample analysis of the sludge indicates that a variety of contaminants are present in the sludge
pits. SVOCs and polycyclic aromatic hydrocarbons (PAHs) are the most prevalent compounds,
as would be expected. Lead was found at concentrations as high as 19,000 mg/kg in the
unsaturated zone. The FDEP industrial soil cleanup target level (SCTL) for lead is 1,400 mg/kg.
Other metals (e.g., aluminum, chromium, zinc) are present, but at much lower concentrations.

PCBs are present at concentrations from 1.4 mg/kg to 21 mg/kg. Dichlorobenzenes, acetone,
l,l,2-trichloro-l,2,2-trifluoroethane (Freon 113), l,2-dibromo-3-chloropropane (DBCP), 1,2-
dibromoethane (EDB), ethyl benzene, toluene, xylenes and other VOC compounds were
detected. Low concentrations of perfluorooctane sulfonic acid/perfluorooctanoic acid
(PFOA/PFOS) (less than 27 micrograms per kilogram [|ig/kg]) and dioxins (less than 240
nanograms per kilogram [ng/kg] as toxicity equivalent) were also detected.

The analytes detected are found in both the Unsaturated Zone and the Saturated Zone. However,
the concentrations are more elevated in the Unsaturated Zone. Concentrations of the detected

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analytes in many cases are greater than the risk-based levels calculated in the HHRA and I DLP
SCTL& This information is documented in the 2016 RI Report and the 2019 FS Report,

Due to elevated levels of Resource Conservation. and Recover)- Act (RCRA) hazardous
constituents, including lead, some of the .sludge and NAPI may be considered a RCRA
characteristic waste cine to toxicity [40 CFR 261.24], Any extracted multi-phase NAPL fluids
could also be considered a characteristic hazardous waste. The toxicity characteristic is meant to
identify those hazardous wastes which, if disposed of in the environment, have the potential of
leaching specific hazardous constituents in levels at or above regulatory thresholds. These
constituents include eight heavy metals, four insecticides, two herbicides and 25 other organic
compounds. The required laboratory test for evaluating wastes under the toxicity characteristic is
the toxicity characteristic leaching procedure MC LP). Hie maximum concentration of
contaminants for the toxicity characteristic are provided in Table 1 of 40 CFR 261,24, For
example, the maximum concentration for lead IDOOS waste code) is 5 milligrams per liter < mg/L)
TCLP, TCLP analysis of 10 subsurface samples from the Primary Sludge Pit ranged from <1
ing/L to 20 mg/'L TCLP (SB020), indicating some of the waste to be removed from the Site may
exceed the maximum concentration ol eontammaiiis for the toxicity characteristic and be
classified as a RCRA toxicity characteristic waste,

5.5.2 Nature and Extent of NAPI. Contamination

NAPL is present on site as a pore space adherent to the sludge matrix and as a mobile and
residual phase product within the native sand matrices outside the Primary Sludge Pit and
Secondary Sludge Pit The NAPI, is colored dark brown to black, similar to the sludge "MAPI, is
present within, above and below the sludge layers. Oil was noted m the Unsaturated Zone in
several borings. Oil and or NAPL noted in the Unsaturated Zone is considered waste source
material for the Unsaturated Zone. As a primary source contaminant, the transport characteristics
of this NAPI , within the high-permeability hthology for the Site, are an integral factor for the
distribution ot'COCs. Due to elevated levels of RCRA hazardous constituents, including lead,
some of the sludge and NAPL may be considered a RCRA characteristic waste due to toxicity
[40 CFR 261,24], Any extracted multi-phase NAPL fluids could also be considered a
characteristic hazardous waste

Mobile NAPI. will tend to move laterally in coarser, more-permeable portions of heterogeneous
media, avoiding the tincr-granted zones which provide greater capillary resistance to entry . As a
result, mobile NAPL is present as globules connected along fractures, macropores and the larger
pore openings. Water occupies the smaller pores and tends to be retained as a film between the
nonwetting NAPL globules and media solids, At residual saturation, NAPL occurs as
disconnected singlet and multi-pure globules within the larger pore spaces, NAPI, can also be
present below the water table due to its origin t i.e., buried oily sludge) or due to water-table
fluctuations that trap NAPI, restdually in pores. NAPL below the water tabic is considered
source material for the Main Source \xa

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Petroleum Products Corporation Super fund Site
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July 2021

The relatively high viscosity of the NAPL, ongoing sludge/source leaching of oil and persistence
of the NAPL in the subsurface has allowed a long period of time for NAPL movement in the
subsurface following the sludge placement in the Primary Sludge Pit and Secondary Sludge Pit
or past disposal practices of oil spills and surface disposal. Many of the compounds in the oil
mixture are typically hydrophobic; they tend to sorb strongly to the subsurface soils and are
retained as residual NAPL. Residual saturation conditions reflect a stable equilibrium (no new
hydrostatic forces), with complete drainage of mobile NAPL along preferential pathways. Any
applied forces, such as a hydrostatic change induced by hurricane flooding, could cause
movement of NAPL. Ultimately, the NAPL in the soil matrix will undergo dissolution into
groundwater and represents an ongoing, long-term source of dissolved phase contamination.

Five waste oil samples were submitted for laboratory analysis from wells and seeps on the Site.
The waste oil samples were analyzed for VOCs, SVOCs, metals and PCBs. Analytical results
identified several compounds present. One analyte (PCBs) exceeded the Florida soil
commercial/industrial cleanup target levels (CTLs) for direct exposure. The compounds with
high concentrations include 1,2,4-trimethylbenzene, 1,3,5-trimethylbenzene, trichloroethene, 1,1-
biphenyl, 2-methylnaphthalene, benzo(a)anthracene, bis(2-ethy!hexyl) phthalate, chrysene,
naphthalene, phenol, PCB-1242, PCB-1260 and lead. Contaminants detected in the five NAPL
samples are summarized below.

NAPL Analytical Testing - Select Results

Chemical

Unit

Minimum

Value
Detected

Maximum

Value
Detected

Average
Value

FDEP Commercial/
Industrial Sofl CTL1

1,2-Dichlorobenzenc

mg/kg

1.0

20.98

5,000

1,2,4-Trimethylbenzene

mg/kg

0.240

190

77.0

1,3,5-Trtmethyibenzene

mg/kg

1.4

100

38.85

Trichloroethene

mg/kg

1.4

6.87

9.3

Xylenes, Total

mg/kg

0.180

32.26

700

Total VOCs

mg/kg

206.4

l,l'-Biphenyl

mg/kg

9.5

13.17

34,000

1 -Methylnaphthalene

mg/kg

100

1,800

2-Methylnaphthalene

mg/kg

8.0

100

2,100

3 & 4 Methylphenol

mg/kg

3,400

Benzo [a] anthracene

mg/kg

2.0

Bis(2-ethylhexyl) phthalate

mg/kg

390

Chrysene

mg/kg

2.5

5.95

Fluoranthene

mg/kg

3.4

5.1

4.25

59,000

Naphthalene

mg/kg

4.0

40.75

300

Phenanthrene

mg/kg

3.5

20.12

36,000

Pyrene

mg'kg

2.7

8.4

4.82

45,000

Phenol

mg/kg

110

220,000

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Petroleum Products Corporation Supcrfuod Site
Record of Decision

My 2021

NAPL Analytical Testing - Select Results

Chemical

Unit

Minimum

Value
Detected

Maximum

Value
Detected

Average
Value

FDEP Commercial/
Industrial Soil CTL'

Total SVOCs

mg/kg

184.0

1,2-Dibromoethane (EDB)

mg/kg

1.4

200

PCB (Aroclors 1242)

mg/kg

2.6

PCB (Aroclors 1260)

mg/kg

3.9

10.28

Chromium (total)

mg/kg

470

Lead

mg/kg

110

440

258

1400

Titanium

mg/kg

Zinc

mg/kg

630,000

Notes:

1 Based on FDEP soil CTLs for commercial/industrial direct exposure, FAC Chapter 62-77, Table II. February
2005.

Hg/kg = micrograms per kilogram

Near the surface, at intervals of 2-to-6-feet bis, the NAPL is more widespread than the original
pit locations. As depth increases, the NAPL is more concentrated in the areas of the Primary
Sludge Pit and the Secondary Sludge Pit. Below a depth of 17 feet, the occurrence of NAPL is
significantly less than the footprint of the Primary Sludge Pit and the Secondary Sludge Pit. The
covering of the pits in the early 1970s assumes the relocation and transport of oily sludge and
NAPL across portions of the Petroleum Products Corporation property. NAPL has most likely
spread through pond overflows from high water tables and storm events, stormwater flows and
past surface seeps. The deepest observed NAPL impact in limestone is 22 feet bis. Several
borings between 23 and 26.5 feet bis (such as PSP-1 and PSP-4) indicated a slight petroleum
odor, although no residual or mobile NAPL or significant staining was noted,

5.53 Nature and Extent of Soil Contamination

Soil analyses were performed from most borings, including intervals above or below isolated
occurrences of NAPL and/or sludge. Following a 2011 removal action, a small inaccessible area
of contaminated, petroleum-impacted soil remains under a residential mobile home and will be
addressed by this action.

5.5.3.1 Surface Soil - CMZ1 (Unsaturated Zone) i

The Unsaturated Zone encompasses the significantly contaminated soil in the Unsaturated Zone
from 0-to-5-feet bis. This zone includes the former Primary Sludge Pit and Secondary Sludge Pit,
and several areas believed to be impacted by overflows from the pits and relocation of sludge
and NAPL as fill on site. This CMZ was configured to represent the largest mass of significantly
contaminated soil containing both potentially mobile and residual NAPL and sludge that could
be easily excavated due to unsaturated conditions. Remediation of this zone is principally

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'.-ti.li \ i'lvaai' w ¦ w *>iv

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focused on protection of human receptors from direct couluct with seeps and soil, treatment of
PTW, and prev ention of leaching of COCs into groundwater

Analytical results from sampling between 2009 and 2012 con 11 in ted ihe presence of elevated
COt" concentrations in site surface soil from 0 to 2 feet b'k. Analytical, results identified several
com,pounds exceeding PDPP SCTl.s for direct contact and teachability, including SVi K s.

VOL's, PCBs. dioxms, lead and arsenic. SBO S 8 (; to 2 fee! bis I and Sl'P-i I 11 to 3 feet bis) hud
the highest COC concentrations, SB018 and SSP-11 are located in Ihe Primary Sludge Pit and
the Secondary Sludge Pit, respectively.

The predominant surface soil contaminant is lead, with sample SSS-? (22,000 mg kg, 0 to 0.5
feet bis), exceeding ihe FDEP industrial,'commercial direct contact SCTL of 1,400 mg/kg. SSS-?
is located within the footprint of the former tank farm.

Soil sample SSS-3 (20 mg'"kg} exceeded the direct contact SCTt for arsenic of 12 mg/kg.

Sample SS'S-3 is located within the footprint of the former tank farm

Dioxin toxicity equivalent and benzo(a)pyrcne toxicity equivalent exceedances were also present
in multiple samples. SB0W exceeded the 30 nanograms per kilogram (rig'kg) dioxin toxicttv
equivalent FDHP direct contact SC'TL with the highest detection of 240 ng kg. collected from 4
to 5 feet bis. SHOI o is located within the boundary of" Ihe Primary Sludge Pit.

SSP-l i exceeded the bcti/o(a>pyrene toxicity eqimatem FDHP teachability SCTL of 8,000
fig/kg. with the highest detection of 20,530 ug'kg, collected from I to 3 feet bis. SSP-11 is
located along tie western boundary of the Secondary Sludge Pit.

5. 5.3.2 Subsurface Soil - OfZ 2 (Main Source Area)

I'he Main Source Area encompasses the significantly contaminated soii in the Saturated Zone
from 5 to about 21 feet bis iwtth
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Petroleum Products Corporation Super:und Site
Record of Decision
July 2021

The distribution of lead in subsurface soils is extensive. The average lead concentration for
samples exceeding the industrial FDEP teachability SCTL is 8,350 mg/kg, Several samples were
elevated for lead concentrations: SSP-9 (22,000 mg/kg. 15 to 17 feet bis) and SSP-2G (23,000
mg/kg, 10 to 12 feet bis). Samples SSP-9 and SSP-2Q arc both located within the boundary of the
Secondary Sludge Pit,

Three samples exceed the chromium FDEP teachability goal of 38 mg/kg. Two subsurface soil
results, COEMW-1 and SBB-22 exceeded the 12 mg/kg arsenic industrial FDEP leachability
SCTL. One sample has a chromium detection of 100 mg/kg (SSP-13). This sample was collected
at the water tabic interface from 4 to 6 feet bis. Sample SSP-13 is located just north of the
boundary of the Secondary Sludge Pit. Among the VOCs detected axe benzene, toluene,
ethylbcn/ene and xylene (BTT.X). VOC exccedances include chlorinated ethenes, chlorinated
ethanes, BTEX, 1,4-dioxane, chlorobcnzencs arid others. Elevated total VOC values were
recorded at PSP-9 and SB019 (within and adjacent to the Primary Sludge Pit).

Several soil samples exceeded FDEP leachability SCTLs for VOCs, SVOCs, PCBs, dioxin and
metals. Dioxin toxicity equivalent and ben/o(a)pyrene toxicity equivalent exccedances were
present in multiple samples. The sample with the highest dioxin detection, SSP-3 J (610 ng'kg)
from the 19-to-20-foot bis interval, exceeded the 30 ng/kg dioxin toxicity equivalent FDEP
leachability SCTL. Boring COEMW-1 recorded the highest benzo(a)pyrenc toxicity equivalent
detection of 9,434 micrograms per kilogram (ug/kgi, exceeding the FDEP leachability SCTL of
8,000 p.g/kg,

5.5.4 Nature and Extent of Groundwater Contamination

The groundwater data allows an evaluation of the interaction with various media at the Site. The
groundwater contaminant plumes are centered across the Site and extend out to the northwest
and southeast near the vicinity of Park Road, with the highest contaminant concentrations in the
areas of the Primary Sludge Pit and the Secondary Sludge Pit. High concentrations often
correlate to the Primary Sludge Pit and Secondary Sludge Pit OU2 (Main Source Area) and OU3
(Extended Plume CMZ 2 (Main Source Area) and CMZ 3 (Extended Plume) include the
groundwater contamination. The main difference between the two zones is the concentrations of
COCs detected. Groundwater in the Main Source Area is contaminated with COCs very similar
to the COCs in the source material. Sludge and NAPL arc in contact with the groundwater. Some
observations of highly variable groundwater concentration results, such as lead for example, may
be a result of small droplets of NAPL or microparticles of sludge or sludge-sediment composites
in the sample.

The highest concentration of lead detected during the 2018 sampling event (47 micrograms per
liter [jig/L]) was recorded at COEMW-14A, three times the FDEP MCL of 15 j.ig/1. (FAC
Chapter 62-550,310, Table 1). During the 2013 sampling event, lead was recorded at a
concentration of 190 j.ig/1, at COEMW-14A. COEMW-14 A is located within !he boundary of the
former tank farm and is screened from 4,5 to 19.5 feet bis. Samples collected in 2013 and 2018
at the deeper paired wells COEMW-14B and COEMW-14C were below the FDEP MCL, The

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'Vjffl't'!!1 !'<• s'lkts' I N inftVVj ""lit*

Record ai :Kvr, on
}»il. ?i;:;

highest lead detection during the 2013 sampling e\enl was 8,400 jig-'L at well ( < 15A

L"0tM\V-!5A is1 located within the boundary of"the Seeondary Sludge Pit CORVIW- I2C, also
located within the boundary of the Secondary Sludge Pit, exceeded the target le\el\ for both
manganese and 1,4-dioxane.

Arsenic exceeds the FDEP M( L HO ug'lt at monitoring well PMVVlsiA. near Park Road at the
western boundary i>f ihe Site. COUMW -I4A contained the highest detection of arsenic (65 fig/t)
in the 2013 sampling event. C Ol MW-I4A is located within the boundary of the former tank
farm and is screened from 4.5 to 19.5 feet bis.

The 2018 groundwater results indicate that both ben/otb)fliioran(hene and wdenot 1.2,3-cd)
pyrcnc exceed or are equal to the FDFP CitTl. (it 05 ug. L) at monitoring well 1MW-B, Iocaied
near Pembroke Road at the northern boundurs of the Site (CM23). Monitoring well 1MW-B ss
51,5 feel in depth, The 2013 groundwater data defines the southern boundary of the dissolved
plume within the Bamboo Mobile Home Park, located south of the facility. Arsenic and lead
were both detected in monitoring well MW-A, both at levels above the MCL values of 10 (.tgT
and 15 pg;L, respectively. Monitoring well MW-A has a depth of 10,9 feet. Monitoring well
PMW-U3A, located south of MW-A, exceeded the FDEP GCIL {3.2 fig 1 ) for f ,4-dioxdiic
Monitoring wdi PMW-03A has a depth of 18.9 feci. Both MW-A and PMW-03A are located
south of the facility, in the Bamboo Mobile Home Park (Extended Plume I

A shallow well, BBLPMW-1A, was sampled in 2018, with a total depth of 6,7 feet bis.
BBLPMW-f A ss located in the northwest corner of the Site. BBLPMW-i A tetorded several
detections with exceedancc levels for SVOC analytes ben/ota (anthracene. ben70(a)pyrenc.

benzo(b)fluorantlieue,
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I • tHnj-.i, t<-< umro'ii'i- \ jji. <¦; i,- \ \ ¦

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Most of the property is occupied bv a sell-storage facility I Figure 2i The Site also includes
several commercial properties containing mini h at chouses used for commercial and private
storage and small business (c.g , a shooiing range, a restaurant, paint and repair shops, cabinet
makers, woodworking facilities, manufacturing facilities}, The adjacent properties include a
public golf course to the north, mobile home trailer parks to the south and west, and lighi
industrial commercial businesses to the east and west Several large marimade retention ponds
arc located north, south and west of the Site, Figure ! Tno Hollywood, Florida municipal
\s ell field is located 1,5 miles north of the Site and the Hullandale. Florida municipal wo II fie Id is
located about 0,5 miles ro the east

The reasonably anticipated future land use for most of the Sue is industrial commercial use, A
portion at the S;k. the Bamboo Mobile Home Park, is currently zoned for residential use, It is
anticipated that it wilt remain zoned for residential use in the future

6,2 Ground and Surface Water Uses

The groundwater beneath the Site and the surrounding area in the Biscaytie Aquifer, which is
fedeniih designated sole-source aquifer that supplies drinking water to the South Honda
population In particular, the Btscayne Aquifer ts the pnmar> supply of all fresh groundwater in
Btov\ard 1 ountv. Honda. The FDEP classifies groundwater at the Site as Class G-1 and G-1I
i* At1 oJ>-5?0.4*111),

Surface water drainage paths*.ays have been paved and sealed la prevent inadvertent infiltration
of surface contamination into the shallow aquifer and there arc no permanent Mirface water
features at the Site, 1 lowever, the paved surface of the Site is hummocks and cracked, with
numerous laige depletion:* that hold wafer resulting from precipitation. Obstipations made
during lieldwork ai the Site suggest that standing water drains through cracks and unsealed
openings into the subsurface. Permanent surface water features m the area adjacent to the Site
include a retention pond about 30 acres ir. size located due wot of the Site across South Park
Road Several small retention ponds t 1 -2 acres in. si/ei are located directly south of the Site, in
the Bamboo Mobile Home Park.

7.0 Nummary of Site Risks

As part of the KIT'S, a baseline risk assessment was conducted to estimate the current and future
effect* of contaminants on human health and the environment \ baseline tusk assessment is an
analysis of the potential adverse human health and ecological effects of releases of hazardous
substances from a site in the absence of any actions or controls lo mitigate such releases, under
current and future land uses. The baseline risk assessment include^ a tinman health risk assessment
and an ecological risk assessment ft provides the basis for taking a ('FRC1 A response action and
identifies the contaminants and exposure pathways that need lo be addressed by the remedial
action. This section of the ROD summarizes the results of the baseline risk assessment for the Site,

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Pcmtimr' FSvAccrs ( Ni-wrjiiidii hujx-riurtt.i 5j(te
Record ni f5,Y)<*i*ft
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7.1 Baseline Ecological Risk Assessment

The Baseline Ideological Rs Risk OmnicH'tiztiiitm ami Unceruufiry Analysis integrates the three earlier steps to
summarize the potential and actual risks posed by hazardous substances at the Site,
including carcinogenic and non-carcinogenic risks and a discussion of the uncertainty in
the risk estimates

7.2.1 Hazard Identification

flie chemicals of potential concern (COPCs) were selected based on toxicity, concentration,

frequency of detection, and mobility and persistence in the cm uonruent They can be found m
the baseline 20! 6 Supplemental HHRA Front this, a subset of the chemicals was identified as
presenting; current or future unacceptable risk arnt'or were identified at the Site in excess of the
chemical-specific AR \R value. This ROD refers to these chemicals as the Site's t Ot\ Tables \
through 3 its! the site t.'OCs identified in surface soil (Unsaturated Zone). subsurface soil (Main
Source Areal arid groundwater (Dilute Plume}.

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Petroleum Products Corporation Superfund Site
Record of Decision
July 2021

A subset of COCs, classified as "risk drivers", is listed by media below.

Site COCs, by Media

Surfteial Soil1

Subsurface Soil

Groundwater2

SVOCs

VOCs

Metais

Benz(a)anthracene

1,2 - Dibromocthanc/ethy lene
dibromide (EDB)

Benzene

Antimony

Benzo(a)pyrenc

SVOCs

cis-1,2-Dichloroethenc

Arsenic

Benzo(b)fluoranthene

Benz(a)anthracene

Trichlorosincne (TCE)

Lead

Dibenz(a,h)anthracene

Other

Vinyl chloride

Vanadium

lndeno( 1,2,3-cd)pyrcne

PCB (Arochlor 1016)

SVOCs

Other

PCB (Arochlor 1248)

Naphthalene

PCB (Arochlor 1016)

PCB (Arochlor 1260)

1,4-Dioxane

PCB (Arochlor 1248)

PCB (Arochlor 1254)

Other

PCB (Arochlor 1260)

Dioxin TEQ

PCB (Arochlor 1242)

Dioxin toxicity equivalent (TEQ)

Metals

PCB (Arochlor 1260)

Metals

Arsenic

Dioxin TEQ

Arsenic

Lead

Notes:

1 Surficial soils considered to be those soils l-to-2-feet bis.

2 COCs from all groundwater sources (i.e., groundwater with sludge and groundwater without sludge.

7.2.2 Exposure Assessment

Exposures to COPCs were estimated quantitatively or qualitatively through the development of
several different exposure scenarios. Exposure scenarios were developed based on the nature and
extent of contamination, the location of the Site, current and future potential use of the Site, and
identification of potential receptors and exposure pathways. Potentially complete exposure
pathways and populations included:

• Incidental ingestion, dermal contact with surface soil (tenants, residents, indoor/outdoor
workers, construction workers).

• Incidental ingestion and dermal contact with subsurface soil (residents, outdoor workers,
construction workers).

• Incidental ingestion of groundwater, dermal contact with groundwater (tenant, residents,
indoor/outdoor workers, construction workers).

• Incidental ingestion of sludge/seepage (older child tenant).

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\tn u '< < wM'ion Sv o S,v

SvC.>fU .>1 ?)d)M Supplemental HHRA were:

• Chronic reference dose iRfDl for non-carcinogenic effects. Chronic RfDs were derived
from the no-obser\ ed-adverse»effec{-level (NOAELt for the critical toxic effect and were
developed to be protective over an exposure period of seven years to a lifetime.

• Oral cancer slope factors (SFs) for carcinogenic effects.

In the derivation of a dermal K iD. the oral RfD was multiplied by the gastrointestinal absorption
factor (GAh j. The dermal SF was derived by dividing lite oral SF by the GAh llic oral toxicity
factors were only adjusted if the GAf for ihe specific chemical was less than 50% or 0.50

Since lead toxicity values are not available, the iif'AT Integrated exposure Uptake Biokmctic
tilT'BKi Model was used to evaluate lead uptake in children t«,g., a resident child and tenant)
The Adult Lead Methodology I AIM) was used to evaluate lead uptake in odulis (c g.„ adult
tenants, indoor workers, outdoor workers, adult residents and construction workers?.

7.2.4 Risk Characterization

Risk characterization integrates the results of the exposure assessment and toxicity assessment to
estimate the probability or potential that adverse health effects may occur if no action were to be
taken at a site. Noncancer health effects were evaluated for all OOPCs (i.e., including
carcinogen- i for which noncancer toxicity values arc available Carcinogenic risks were

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Petroleum Products Corporation Supcrfund Site
Record of Decision
July 2021

calculated for those COPCs with evidence of carcinogenicity and for which cancer toxicity
values are available.

7.2.4.1 Noncancer Health Effects

Noncarcinogenic effects were quantified by comparing the estimated dose (i.e., ingested or
dermally absorbed) of the COPCs with the RfDs (i.e., the chemical-specific toxicity value used
for expressing noncarcinogenic effects). The hazard quotient (HQ) associated with the incidental
ingestion of affected media (i.e., surface/subsurface soil or groundwater) was calculated using
the following equation:

HQ = ^r

RfDo

where:

HQ = hazard quotient (unitless)

Id = ingested or dermally absorbed dose of COPC in media (mg/kg-day)
RfDo =» oral reference dose (mg/kg-day)

To characterize the overall potential for non-carcinogenic effects associated with exposure to
multiple chemicals, the EPA uses a hazard index (HI) approach. Since a potential receptor is
likely to be exposed to more than one chemical by more than one exposure route, an estimate of
total noncarcinogenic hazard was performed by summing the HQ values across different
chemicals and across different exposure pathways. The sum of the HQs is termed the HI. It is
calculated as follows:

HI = HQ1 + HQ2 + ... + HQith toxicant
Calculation of an HI in excess of 1 indicates the potential for adverse health effects.

Summary of the Reasonable Maximum Exposure Noncancer Hazard for All Receptors

Receptor

Total
Noncancer
HI

Organ

Noncancer HI

Notes

Young
Child

Current

Incidental ingestion of surface soil;
respiratory

Future

640

447

Incidental ingestion of
groundwater; renal, hepatic,
neurological

Tenant

Current

Older
Child

Future

345

244

Incidental ingestion of
groundwater; renal, hepatic,
neurological

Adult

Current

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Petroleum Products Corporation Superfund Site
Record of Decision
July 2021

Summary of the Reasonable Maximum Exposure Noncancer Hazard for All Receptors

Receptor

Total
Noncancer
HI

Organ
Noncancer HI

Notes

Future

240

168

Incidental ingestion of
groundwater; hepatic, neurological

Occupational

Indoor
Worker

Current

0.5

Occupational

Indoor
Worker

Future

114

Incidental ingestion of
groundwater; renal, hepatic,
neurological

Outdoor
Worker

Current

< 1

NA: Total HI > 1, but all target
organ His < 1

Future

105

Incidental ingestion of
groundwater; hepatic, neurological

Resident

Child and Adult
(age adjusted)

Future

491

326

Incidental ingestion of
groundwater; hepatic, neurological

Commercial/
Industrial

Construction
Worker

Future

Incidental ingestion of
groundwater; renal, hepatic

Notes:

For each receptor, the current exposure scenario includes exposure to surface soil. The future exposure scenario
includes exposure to surface soil as well as exposure to groundwater (assuming that site groundwater is used as
the source of drinking water).

NA = not applicable

The cumulative HI exceeds 1 for the current and future young child tenant and future outdoor
worker, the future older child and future adult tenant, future indoor worker, and future resident
and future construction worker scenarios. No unacceptable noncancer hazards were identified for
the other receptor scenarios.

Tables 4 through 11 show noncancer hazards to surface soil were unacceptable only for residents
and tenant child (His ranging from 1 to 3). Noncancer hazards to subsurface soil were
unacceptable only to residents (HI = 3). Noncancer hazards to groundwater without sludge pits
were unacceptable for residents, outdoor workers, tenant children and construction workers (His
ranging from 5 to 41), with construction workers having with the lowest hazard and tenant
children having the highest hazard.

7.2.4.2 Cancer Health Effects

Carcinogenic risk is expressed as a probability of developing cancer as a result of lifetime
exposure and is expressed as the incremental lifetime cancer risk (ILCR) to an individual or

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Petroleum Products Corporation Saperfiiiid Site
Record of Decision
My 2021

population exposed to contaminants at a site and were quantified as the product of the estimated
dose (i.e., ingested or dermally absorbed) of the COPCs multiplied by the SFs, For a given
chemical and route of exposure, excess lifetime cancer risk was calculated as follows;

II.CR Id • SK>

where:

ILCR = incremental lifetime cancer risk (unitless)

Id = ingested or dermally absorbed dose of CQPC in media (mg/kg-day)

SFo = oral slope factor (mg/kg-day V1

These risks are probabilities that are generally expressed in scientific notation (e.g., lE-tlo or
1x10"6). For exposures to multiple carcinogens, the HP A assumes that tie risk associated with
multiple exposures is equivalent to the sum of their individual risks. Increased cancer risks less
than IxlO"6 indicate no action is required, Cancer risks between IxlO4 and 1x10"' generally do
not warrant cleanup unless dictated by site-specific circumstances or other considerations.
Increased cancer risks greater than IxlU-4 indicate some type of action needs to be considered.

Young Child

lili1

Tenant

Older Child

•J v in'

2 i if)"'

Adult

1 x 10*

3 119*

Worker

Indoor

? x 10-5

1 x If1

1 11,hi',l'f

1 x 10"*

1 I 10'"

Resident

Child and Adult
fsgc adjusted)

71 irf

CommerciaUIndustrial

Construction Worker

5 t 111 '

Notes:

I ' »!icabic

Total ILCR exceeds the target risk range of lxtirfe to IxlO"4 for the current and fiiture young
child tenant, the fiiture older child and future adult tenant, the future indoor and outdoor worker,
and tlie future resident and fiiture construction worker scenarios. The calculated cancer risks for
other receptors are in the acceptable risk range.

At the time, the 2016 Supplemental Hi-IMA was finalized, the EPA was using a blood-lead target
of 10 micrograms per deciliter Oig/dL) in the IEUBK model and ALM. An assessment of a
surface soil lead EPC of 7.t>21 nig/kg results in an unacceptable risk (greater than 5% probability
of exceeding the blood-lead target) to an on-site worker and a hypothetical future resident. Since

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iVaml-um -N« Drw'.vii® Vv

KccoM •¦ i i)cc» -.ft
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that time, the EPA has considered lowering the blood-lead target when assessing lead
contamination. Using any lower blood-lead target would still equate to an unacceptable risk for
both an on-site worker and a hypothetical future resident. The groundwater lead concentration is
above the I IM P MOl of 15 nig L that is a ( hcmical-speejfic ARAR

The cumulative cancer risk for exposure to surface soil was unacceptable only for resident
(incremental lifetime cancer risk of 31>04) and tenant child scenarios (incremental lifetime
cancer risk of 2I--04I while exposure to subsurface soil posed unacceptable risk onh to the
residents {incremental lifetime cancer risk of 2F.-'-04>. Risk from exposure to groundwater without
the sludge pits was unacceptable for the resident, tenant child and outdoor worker scenarios, with
residents exposed to the highest risks (incremental lifetime cancer risk of 4L*'-03).

The cumulative His and cancer risks for all other current and current and future receptor
scenarios are in the 201ft Supplemental HHK-\

",2.5 Uncertainties

The uncertainty analysis describes the uncertainty associated with each step of the risk
assessment process. Since it is impossible to eliminate all uncertainty, it is critical to identity the
level of uncertainties in the risk assessment to understand and use the Jesuits for risk
management purposes. Such uncertainties include, but axe not limited to, the variations in sample
analytical results, the values of variables used as input parameter the development of the
exposure scenario;;, and the hfgh-to~low dose and interspecies extrapolations for dose-response
relationships in toxicity data, In addition, the use of chronic toxicity data instead of,sub-chrome
toxicity data for the construction worker added a level of uncertainty to the risk assessment. In
general the.se uncertainties in risk assessment are largely overcome by conservative estimates of
chemical concentrations and exposure parameters to ensure that potential exposure and risk are
not underestimated.

The estimate of noncarcinogenic hazards and carcinogenic risks in the supplemental ilHRA was
based on many assumptions and therefore, involved a significant degree of uncertainly. This
uncertainty is inherent m the risk assessment process within the current constraints of scientific
knowledge regarding human health nsk factors. The HI approach assumes that ail noneanccr
adverse effects to the same or^an or systems are addith c Therefore, the Hi approach is
appropriate for assessing chemicals that have similar modes of action and act on the name target
organ. However, it may not be appropriate when there are di tie rem modes of action. It is
important for risk managers to consider these uncertainties when interpreting the site risk
assessment results to determine appropriate remedial alternatives based on the risk assessment
conclusions

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Petroleum ftsxjacts Corporation Sopcrfund Site
Recon} of Decision
Inly 2021

8.0 Bmtis for Action

The remedial action selected in this ROD is necessary to protect public health and the
environment from actual or threatened releases of hazardous substances, contamination and
pollutants into the environment.

9.0 Memeiial Action Objectives

Remedial action objectives (RAOs) consist of media-specific goals for protecting human health
and the environment that are developed during the RI/FS process to guide evaluation of remedial

alternatives and must be met by the selected remedy. The RAOs were developed for COCs in the
media of concern, the exposure routes and receptors, and the acceptable contaminant levels or
range of levels for each exposure route. The RAOs developed to
posed by the contamination at the Site are presented below;

Source Material NAPL and Sludge (CMZs J and 2}

• Prevent leaching from CO< * source material from the subsurface to groundwater above
levels that are protective for beneficial use (i.e., drinking water use).

• Prevent human exposure to COCs in site soils through direct contact above levels
protective of residential and industrial use,

G round water f CMZ J)

• Prevent human exposure to COCs in groundwater through ingestion, and dermal contact
above levels that are protective for beneficial use (i.e., drinking water use).

• Prevent migration of COCs in groundwater above levels that are protective for beneficial
use (i.e., drinking water use).

Soil (CMZs 1 and 2)

• Pommer Facility Property;

o Prevent leaching of COCs from soil to groundwater above levels that are protective
for beneficial use (i.e., drinking water use),

o Prevent human exposure to COCs in surface and subsurface soil through ingestion
and dermal contact above levels protective of commerciaVindustrial use,

• Bamboo Mobile Home Park:

o Prevent human exposure to COCs in subsurface soil through ingestion and dermal
contact above levels protective of residential use.

Tables 12 and !4 list the COCs for soil and groundwater, respectively, and their associated
cleanup level Cleanup levels were mainly based on chemical-specific ARARs. including FDEP
SCTLs and GCTLs (that include MCLs), as indicated in the tables referenced above.
Groundwater cleanup levels are used to measure performance of the interim remedy for the
Extended Plume,

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10 J Description of Alternatives

To develop and focus the remedial alternative process in the FS. soil and groundwater
contamination at the Site were classified into three CMZs A (AMZ represents a portion of the
site contamination that has a particular characteristic thai defines the optimal remediation
approach. Defining characteristics can include one or more parameters such as lithology, COCs,
depth, area! extent, ami or presence of sludge or NAPL Classification of the Site into CMZ&
allowed remedial alternatives to be tailored to these conditions, resulting in a more economical
and focused remedy

10,1 Description of the ( ommon Elements
li.1,1 institutional Controls

Institutional control * IC>) will be required as part of the selected remedy. ICs are
nonengincered instruments, such as administrative and legal controls, that help to minimize the

potential tat v\posure to contamination and/or protect the integrity of a response action ICs are
typically divided into four categories: proprietary eontroK te.g.. recorded restrictive covenant),
governmental controls (e.g., zoning or local ordinances); enforcement and permit tools with IC
components (e.g., construction permit requirements: use restrictions in lease between landowner
and lessees i: and informational devices ie.g., recorded Notice} The objectives of the 1C& for
implementation at the Site are:

• Prohibit disturbance of the in-situ treated waste that remains at the Site and interference
with the integrity of any existing or future remediation system and'or monitoring wells
without prior EPA and FDKP approval. This objective can he achieved by using a
recorded Notice and restrictive covenant executed by the property owner(s) and approved
by the FPA and the FDEP and construction permit requirements and leases between
landowner and lessees.

• Prohibit groundwater well installation and all uses of groundwater use at the Site
including but not limited to human consumption, dewatering, irrigation, heating/cooling

purposes and industrial processes (unless prior approval is obtained from EPA and
FDLl'i, This objective can he achieved by using local zoning/ordinances. construction
permit requirements, and leases between landowner and lessees.

• Prohibit residential, and recreational future use of the property t other than Bamboo
Mobile Home Park which is currently residential). This objective can be achieved by
using a recorded restrictive covenant executed by the property owner(s) and approved by
the fc'PA and the HIM5

ttl. 1 .2 Unsaturated /.one

Two remedial components are included in the overall remedial effort for the 1 'nsaturated Zone,
These elements are considered common, as each alternative will include these components. A
comparative analysis of the common elements was not completed because these alternatives
were deemed to he She most beneficial with no practical alternatives

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Ah pari of excavation and demolition components, tenants, residents, and businesses currenth
located w ithtit the boundaries of the affected areas (defined as the extent of CM/ • f And CMZ-2 i
*111 need to be temporarily or permanently relocated to off-site locations. Relocation of
businesses, tenants and residents will be performed pursuant to or consistent with the Uniform
Relocation Assistance and Real Property Acquisition Act, 42 U.S. Code §§ 4601 el seq , and
regulations promulgated pursuant thereto at 49 CI R Part 24, depending on whether the BPA or
the PRP Group is the lead to perform the relocation activities

10.1.3 Common Element I - Bamboo Mobile Home Park Excavation and Relocation
Estimated Capital Costs $1-1 i,5W)

Estimated Annual Operation and XfuiMemtnvr n)&\f) C<>sis $0

h'$ti mated Present Worth I 'o\f\ H)()

Estimated Construction Timeframe less than 1 month

Estimated Time to Aehk've 8. iO*-Cleanup Ivxeh lest than I year

This common element consists of the excavation of contaminated soil from one residential area
at the Bamboo Mobile Home Park. The mobile home and its tenants would be temporarily
relocated so that area could be excavated dow n to the top of the water table < between 4 5 and 5
feet bls|. The sides of the excavation would be sloped as necessary to permit safe excavation.
The base of the excavation is estimated to he about 2.2X5 square feet The FDI-P residential
SCTLs are relevant and appropriate chemical-specific requirements that are the basis for the soil
cleanup levels for the Bamboo Mobile Home Park property, Clean soil would he placed into the
excavation area; compacted and include a vegetation or gravel cover to match previous site
conditions.

As part of excavation and demolition components of the common remedies, tenant* and
businesses currently located within the boundaries of the affected areas will need to be
temporarily or permanenttv moved lo off-site locations Relocation of businesses, tenants arid
residents will be performed pursuant to or consistent with the Uniform Relocation A>MStunce
and Real Properly Acquisition Act, 42 1 ,S. Code 460J et and regulations promulgated
pursuant thereto ai 49 CFR, Part 24, depending on whether the FPA or the PRP Group is the lead
to perform the relocation activities,

Batches of the excavated sot! will be sampled and TCLP analysed to determine if the excavated
soil is a RCRA toxicity characteristic hazardous waate. Soil batches that are not characteristic
hazardous waste will be disponed of m an oil-site permuted RCR\ Subtitle I) landfill approved
by the EPA, Soil batches that are found to be characteristic hazardous waste will require
treatment off-site to meet RCRA alternative land disposal restriction tl OR) requirements for
contaminated soil prior to disposal m an off-site permuted RCRA Subtitle € landfill approved by
the EPA..

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111,1,4 Common Element 2 - Building Demolition and Relocation of Businesses aid
Tenants Overlying the Main Source Art a

Es timated Capital' Cus t % S / 691.000

Estimated Annual (Mhtf Costs $0

E.siimak'ii iWseni Worth C>\t\ $1,691,000

Estimated Construction Timeframe- I month

Estimated Time m Achieve ILiOs-Cleanup Levels': less than I year

This common element consists of the demolition of five buildings (Figure 7) in the center of the
Site thai overlie the former Primary Sludge Pit and the Secoinkr\ Sludge Wl where extensive
sludge and fsAPL contamination extends to ?4 feet bis Debus from the warehouses, their
underlying concrete slabs and the adjacent asphalt overlying the Main, Source Area will be

sampled so that the materials can be characterized. The characterized debris will be cleaned as
necessarv and sent to the local RCRA. Subtitle D landfill as construction debris, If debris is
designated as a RCRA hazardous debris, it will be sent to an off-site Rt'RA Subtitle 0 landfill
for treatment and disposal. As part of excavation and demolition components of the common
remedies, tenants and businesses current!) located within the boundaries of the affected areas
wilt need to be temporarily or permanently moved to off-site locations. Relocation of
businesses,"tenants will be performed pursuant to the Uniform Relocation Act, 42 U S. Code §§
460; el seq,and regulations promulgated pursuant thereto at 49 C.F R part 24,

A fair market value appraisal of the five buildings completed in mid-2019 determined that the
estimated value of the buildings was S9.5M,

10,1,5 Common Element 3A - Shallow Excavation I'nder Buildings - Retain Existing
Buildings

Estimated Capital Costs. $4,S^2jW0

Estimated Annual (MM (V>.\7.v $0

Estimated Present Worth Costs ¦ $4J~"2,00li

Estimated Qmsimcihm Timeframe. fi months

Estimated Time to Aehteiv ll4t )s/'Cletwnp Lewis less than 1 year

Shallow {») to 5 feet bis) sludgc>'NAPL contamination exists under more buildings on the Sue, as
shown on Figure t\
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Petroleum Products Corporation Superfund Site
Record of Decision
July 2021

of 2 feet around the perimeter of the building will be conducted and may be backfilled with soil
or flowable concrete fill. Temporary shoring (such as I-beams, timber, jacks and/or pneumatic
pillows) will be used to support the footer during excavation. Once the shoring is in place, the
soil beneath the building(s) can be excavated, possibly pneumatically. Excavation beneath the
buildings will be excavated in sections to ensure building stability. After the contaminated soil
has been excavated clean compacted soil fill will be used to backfill the excavation.

Batches of the excavated soil will be sampled and TCLP analyzed to determine if the excavated
soil is a RCRA toxicity characteristic hazardous waste. Soil batches that are not characteristic
hazardous waste will be disposed of in an off-site permitted RCRA Subtitle D landfill approved
by the EPA. Soil batches that are found to be characteristic hazardous waste will require
treatment off site to meet alternative LDR requirements for soil prior to disposal in an off-site
permitted RCRA Subtitle C landfill approved by the EPA.

10.1.6 Common Element 3B - Shallow Excavation Under Buildings - Demolish Existing
Buildings

Estimated Capital Costs: $5,635,000

Estimated Annual O&M Costs: $0

Estimated Present Worth Costs: $5,635,000

Estimated Construction Timeframe: 2 months

Estimated Time to Achieve RAOs/Cleanup Levels: less than 1 year

Shallow (0 to 5 feet bis) sludge/'NAPL contamination exists under six more buildings on the Site,
as shown on Figure 6. (These six buildings for Common Element 3 are in addition to the five
buildings identified for Common Element 2.) There are an estimated 7,200 bank cubic yards of
COC-contaminated soil beneath these six buildings. During the remedial design, an investigation
will need to be completed to determine the full extent of the contamination under the buildings.
This alternative assumes that the contamination under the buildings will be extensive or it will be
found to be unfeasible to perform shallow excavation below the buildings while maintaining the
buildings intact, so these six buildings will have to be demolished. As part of excavation and
demolition components of the common remedies, tenants and businesses currently located within
the boundaries of the affected areas will need to be temporarily or permanently moved to off-site
locations. Relocation of businesses, tenants and residents will be performed pursuant to or
consistent with the Uniform Relocation Assistance and Real Property Acquisition Act, 42 U.S.
Code §§ 4601 et seq., and regulations promulgated pursuant thereto at 49 CFR. Part 24,
depending on whether the EPA or the PRP Group is the lead to perform the relocation activities.

The buildings will be demolished first. Debris from the demolished warehouses, their underlying
concrete slabs and the adjacent asphalt will be managed like the demolished warehouses in
Common Element 2.

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After the building? have been demolished, the excavation will proceed The initial excavations
will be around the perimeters of the demolished buildings After the contaminated soil has been
excavated, clean compacted soil fill will be used to backHSI the excavation

Batches of the excavated soil will be sampled and TCI P analyzed to determine ii the excavated
soil is a k( K \ uuictry characteristic ha/;irdous waste. Soil batches that are not characteristic
hazardous waste wilt be disposed of m .in off-site permitted Rl RA Subtitle D landfill approved
by the l;PA. Soil batches that are found to be characteristic hazardous waste wifi tequue
treatment off-site to meet alternativ e LOR requirements tor soil prior to disposal in an oil-site
permitted RCRA Subtitle € landfill approved by the EPA.

10.2 Description of the I'nsaturated Zone Remedy Alternatives

Unsaturated sludge, NAJPl. source material in the I (maturated Zone is a PTW. Currently, the

shallow sludge and \AP1. are a long-term source of leaehate for underlying groundwater, The
Unsaturated Zone represents the largest meal extent of sludge and NAPL on-facility and includes
the Conner shallow extent of the sludge pits and significant areas impacted from overflow of the
ponds or sludge-'KAFL redistribution from site till ''grading activities, The entire surface of the
Unsaturated Zone is overlain by the warehouse buildings with active tenants, asphalt, utilities
and vehicles, love remedial alternatives mere developed and evaluated for the Unsaturated Zone

111.2.1 Unsaturated Zone Alternative 1: No Action

Fsnmated Capital Coats: $0
Estimated Annual O&M i osls, $S6, f(H)

Estimated Present H'orth Co$i>: $86,'00
Estimated Construction Timeframe not npftivuhle

f,„v«UfhtHvti FiffW "o 4t hwvc RMh Cleanup hu Is greater than 30 vain

NCP Section 3(H»,43tHe)(0) directs that a "No Action Alternative" be evaluated to provide a
baseline seen,mo to i ompure all other alternatives against, Under the No Action Alternative, no

funds would be expended to address the risks posed by the contamination in this area. Funds are
required for the statutory Five-Year Reviews of the Site, site visits, review of regulatory changes*
and ieport preparation.

Under the No Action Alternative, the Unsaturated Zone would remain in its present condituxi
Minimal periodic sampling and analysts of C'OCs in soil would be used to track contaminant
concentrations over the course of a 30-year monitoring period. The collected sample data will
fanlitate evaluation of lie conditions in the Unsaturated Zone for the Five-Yea: Reviews

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Peliokjrr. Products Coipoatioc, SipirtwJ S.w

Record of Decision
July 2021

10.2.2 Unsaturated Zone Alternative 2: Excavation and Off-Facility Disposal in Landfill

list i ma I i'd Capital Costs: $14,372,100
Estimated Annual O&M Costs: $0
Estimated Present Worth Costs, $ J 4,372, J 00

Estimated Construction Timeframe: 6 months

Estimated time to Achieve R.4()sC leanup Levels: less than 1 year

This alternative consists of excavation of the contaminated soil within the Unsaturated Zone,
along with the necessary sidewail slope volumes to allow the excavation. A shallow (10 fee! bis)
sheet pile wall will be installed around the area of the five demolished buildings (Common

Element 2) to protect the buildings on the periphery of the Unsaturated Zone excavation, and will
minimize the side slope soil removal. About 49,300 cubic yards of soil would be excavated to
About 5 feet bis to remove COC-conianiinalci soil, PTW is represented by the sludge and NA.FL
and is expected to be encountered during this action. Clean compacted soil fill will be ttsei to
backfill the excavation areas.

Batches of the excavated soil (including any NAPL or sludge) will be sampled and TCLP
analyzed to determine if the excavated soil is a RCRA toxicity characteristic hazardous waste.
Soil batches that are not characteristic hazardous waste will he disposed of in an off-Site
permitted RCRA Subtitle D landfill approved by the EPA. Soil batches that are found to be
chaiacterislic hazardous waste will require treatment off site to meet alternative LDR
requirements for soil and LDR treatment standards for waste (i.e , N APl./sludge) prior to
disposal in an off -site permitted RCRA Subtitle C landfill approved by the EPA.

10.2.3 Unsaturated Zone Alternative 3: Excavation, Ex-Situ Stabilization/Solidification
and Disposal

Estimated Capital Costs Si2, "$5,000
Estimated Annual O&M Costs: SO
Estimated Present Worth Costs: H2,7S5,0§0
Estimated Construction Timeframe: 6 months

Estimated Time to Achieve RAOs/Cleanwp Levels: less than I year

This alternative consists of excavation of contaminated soil within the Unsaturated Zone, along
with the necessary sidewail slope volumes lo permit excavation. As in Unsaturated Zone
Alternative 3, a 2 shallow (10 feet bis) sheet pile wall will be installed around the area where the
five demolished buildings (Common iiiement 21 to protect the buildings on the periphery of the
Unsaturated Zone excavation and will minimize the side slope removal. About 49,300 cubic
yards of soil would be excavated to a depth of about 5 feet bin to remove COC-contaminaied
soil. PTW is represented by the sludge and NAPL and is expected to be encountered during this
action.

Batches of the excavated soil will be sampled and TCLP analyzed to determine if the excavated
soil is a RCRA toxicity characteristic hazardous waste. Soil batches that are not characteristic

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Petroleum Products Corpomon Super-find Sire
Record of Decision
JlIv 202!

permitted RCRA Subtitle D landfill. Treated soil that is still considered toxicity characteristic
waste must be disposed in an off-site permitted RCRA Subtitle C landfill approved by the EPA.

10.2.5 Unsaturated Zone Alternative 5: Excavation, Ex-Situ Thermal Treatment aid
Stabilization/Solidification with Disposal

Estimated Capital Costs: $15,610,100

Estimated Annual OAM Costs: $0

Estimated Present Worth Costs: $15,610.100

Estimated Construction Timeframe: 6 months

Estimated Time to Achieve KAOs/Cleanup Levels: Less than 1 year

This alternative consists of excavation of contaminated soil within the Unsaturated Zone, along
with the necessary sidewall slope volumes to permit excavation. As m Unsaturated Zone
Alternatives 2 and 3, a shallow (10 feet bis) sheet pile wall will be installed around the area
where the five buildings are demolished (Common Element 2) to protect the buildings on the
periphery of the Unsaturated Zone excavation and will minimize the volume of side slope
removal. About 49,300 bank cubic yards of soil would be excavated to a depth of about 5 feet
bis.

The excavated soils would be treated ex situ with a STARx batch smoldering process enclosed
within a new fabricated steel building. The STARx process will remove more than 99% of the
organic contamination in the excavated soils. The STARx-treated soils are expected to need
further off-site ex-situ treatment to manage the metals contamination thai will remain after
STARx treatment. To treat the residue of metals contamination, following the STARx process,
the treated soil would be stabilized^solidified above grade to meet alternative LDR treatment
standards. Following ex-situ stabilization/solidification treatment, the soil will be placed in an
on-site engineered disposal unit that complies with RCRA ARARs The treated soil will then be
disposed of in the on-site engineered unit and covered with a multi-layered cap that complies
with identified RCRA Subtitle C landfill final cover requirements. The capped area would need
to be specifically designed and constructed with adequate strength to support the anticipated use
of the property including constructed buildings while ensuring the performance of the remedy.

10.3 Description of the Main Source Area Remedy Alternatives

Unsaturated sludgc/MAPL source in the Main Source Area is deemed an extensive area of PTW
within the aquifer. Currently, the deeper sludge and NAPL arc a significant long-term source of
leachate for contiguous groundwater. The main source area represents the largest volume of
sludge and NAPL cm-facility and includes the full depth of the former sludge pits, and
sludge/NAPL redistribution from site fill/grading activities. In addition to sludge and mobile
NAPL, the Main Source Area includes soil impacted with residual NAPL levels and adsorbed
phase contamination of a variety of COCs. The entire surface of the main source area is overlain
by the warehouse buildings with active tenants, asphalt, utilities and vehicles.

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• ""Vn'!',» >rj> n>tnin \t ;t.nv Site
R'CCC'fti c;ir monitoring period The collected sample data will
facilitate evaluation of the conditions in the Unsaturated Zone for the Five-Year Reviews.

10.3.2 Main Source Area Alternative 2; Excavation and Off-Facility Disposal in Landfill

Estimated Capital Costs $28,43 T 700

Estimated Annual OS.M Costs $0

Estimated Present tt'tmk Cost*. $*$,4$?, 700

Estimated C cmstrnetion Timeframe: 7 months

Estimated Time to . khkve RAOsiClcanup Levels, less than 1 war

"Tins alternative coji.mms of excavation of contaminated soil within the Mam Source Area, along
with the necessary sidewall slope volume* to permit excavation. Use of a traditional sheet pile
wall installation to protect adjacent buildings would be untenable due to the presence of
limestone. Therefore, excavation would be accomplished using an engineered system such as a
slide rail shoring box system or interlocking steel sheet pile and hydraulic waters to isolate
segments of soil ami to minimize devaterttsg, About 116,300 bank cubic yards of soil would be
excavated to a depth oI about 21 feet bis {varying as deep as 24 feet bis) to the Main Source Area
limits to remove the COC-contaminated soil. Clean compacted soil fill would he used to back 111!
the excavation.

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Petro ; j~. t orccrattoo Supcrfund Site

te«®n!«f Decision
July 202!

Batches of the excavated soil wilt be sampled and I'C 'LP analyzed to determine if the excavated
soil is considered RCRA toxicity characteristic hazardous waste. Soil batches that are not
characteristic hazardous waste will be disposed of in an otf-site permitted RCRA Subtitle D
landfill approved by the EPA. Soil batches that arc found to be characteristic hazardous waste
will require treatment to meet alternative LDR treatment standards. Treated soil that meets LDRs
and is no longer toxicity characteristic waste (using IC LP) may be disposed of in an off-site
permuted RCRA Subtitle D landfill approved by the EPA. Treated soil that is still considered
toxicity characteristic waste must be disposed in an off-site permitted RCRA Subtitle € landfill
approved by the EPA.

1#J J Mail Scarce Area Alternative 3: In-Situ Stafcilliatl«ii/SttlMlficatiflB with LDAs

Estimated Capital Costs Sit,6'000

Estimated Annual O&M Costs: $0

Estimated Present Worth Costs $< I,hi i oOO

Estimated Construction Timeframe: 8 months

Estimated Time to Achieve RAOs/Ommtp Levels: less than I year

This remedy is analogous lo Unsaturated Zone Alternative 4, In-Situ Stabilization. Solidification

and Limited Soil Excavation and Off-Site Disposal. 1 his alternative consists of the use of in-situ
stabilization, solidification to isolate and stabilize the sludge and NAPL and contiguous soil
contamination within the Main Source Area down to about 21 feet bis (as deep as 24 feet bis).
The in-situ stabili/ation/solidification tooling can cut through limestone rock and can remediate
NAPL at locations where it is bound in the limestone- The estimated target volume for in-situ
stabil i/ation'solidi fication is about i! 6.300 bank cubic yards over an area of 4.5 acres. This
alternative would not require a surrounding .sheet pile to protect adjacent buildings as no soil
excavation is required.

Samples will be collected from the soils treated with in-situ stabilization/solidification. These
samples will be XCLP analyzed to confirm that the in-situ treated soils meet the cleanup
requirements. Volumes that do not meet cleanup requirements will be retreated.

Stabilization/solidification treatment usually causes an increase in the final treated soil volume
from being mixed and ton the addition of the stabilization/solidification treatment chemicals.

To keep the post-remediation land surface as close as possible to existing grade, my excess soil
volume will be excavated. Clean compacted soil fill would be used to backfill the excavation
areas. The in-situ stabilization/solidification areas would need to be specifically designed and
constructed with adequate strength to support the anticipated use of the property including
constructed buildings while ensuring the perfonnaa.ee of the remedy.

Batches of the treated excavated soil will be sampled and TCLP analyzed to determine if the
excavated soil is a RCRA toxicity characteristic hazardous waste. Soil batches that arc not
characteristic hazardous waste will be disposed of in an off-site permitted RCRA Subtitle D
landfill approved by the IT*A Soil batches found to be characteristic hazardous waste will
require treatment to meet alternative LDR treatment standards. Treated soil thai meets TDRs and

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is no longer toxicity characteristic waste (using Tt'LP) may be disposed of in an off-site
permitted RCRA Subtitle D landfill approved by the EPA Treated soil that is still considered
toxicity character)she waste must, be disposed in an off-site permitted RCRA Subtitle C landfill
approved by me EPA.

10 J.4 Main Source Area Alternative 4: Excavation, fcx-Situ Thermal Treatment and
Stabilization/Solidification with On-Siie Disposal

This alternative, as developed in the PS, is not considered for leniedy selection.

10.3.5 Main Source Area Alternative 5: In-Situ Thermal Treatment (Conductive Heating)
with Chemical Reduction

Estimated Capital Cmrs S»ylh4i,00(l
Estimated Annua! CM',1/ Costs ,1 182HJ00
Estimated Present li'orth Costs: $23,699,100
Estimated GimtruciiiM Timeframe, 24 months
Estimated Time to Achieve RAOs'Cleanup l.ewis, 10 years

Common Element ,N the demolition of the five buildings, would riot need be completed he I cue
the Maiis Source Area \iternat:\e 5's in-situ treatment begins, although implementation would
be enhanced if they were demo I'.shed. This alternative assumes that the buildings would remain
in place. However, tenants would need to be relocated for up to a year due to the hazards from
volatilization of COO created by the iiv-situ heating below the buildings.

This alternative entails the m-situ thermal conductive heating of the sludge and N API,-impacted
soils followed by !he injection (via mufti-phase extraction wells) of either reducing or
sequestering amendments to fix the lead ami other metal $ to the .soil aid prevent leaching, Mam
Source Area Alternative 5 is an entirely tn-stru remedy and does not involve any excavation,

A traditional sheet ptle wail would be installed surrounding the Main Source Area to prevent
groundwater flow from quenching heat within treatment areas and minimize excursions of
von tattit na t ed ground w ^ te r at id vapors.

Thermal conductive heating is capable of remediating 95% to 99°'o of organic VOCs and lighter
carbon SVOCs, rendering die soil essentially free of petroleum leaehate. Healed groundwater
and vapor from the thermally treated area would be captured and routed to a treatment plant. The
plant would be constructed inside a steel building to house the separation and treatment
equipment. Due to the various types oft OCs that would be in captured groundwater and vapor,
the process train for the extracted total fluids could be complex, and involve several steps. The
treated effluent \umld be discharged, either to infiltration galleries constructed west of the
facility or to a series of injection wells and; or surface water in compliance with identified
.\RARs.

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Petroleum Products Corporation Supcrftind Site
Record of Decision
July 2021

While thermal conductive healing will remove essentially all the organic contamination in the
Main Source Area it docs not address the metal COCs. Therefore, after the in-situ thermal
conductive heating treatment of the sludge and NAPL impacted soils is completed, in-situ
reduction or stabilization using injected amendments would be needed to stabilize lead and other
metals in the soil matrix,

I§,4 Descripti«Ji of tie Extended Plume Remedy Alternatives

The Extended Plume consists of groundwater on the periphery of the source areas that arc
impacted above cleanup levels (MCLs or FDEP GC.TLs identified as chemical-specific ARARs)
with generally low concentrations of VOCs, select SVOCs, 1,4-dioxanc, lead, chromium and
other COCs. The diverse mixture of COCs limit the options for remediation, as different
physicochemical processes are needed for the unique COCs. The RAO for this zone is focused
on preventing the further vertical and horizontal migration of contaminated groundwater above
these levels. This approach is consistent with the EPA expectation in the XCP lo prevent further
migration of the plume, prevent exposure to the contaminated groundwater and evaluate further
risk reduction (40 CFR Section 300,430 (a)( 1)(IH)(,F).

Remedial alternatives for the Extended Plume are interim and the EPA expects to select a final
remedial action for groundwater in a separate ROD that includes art RAO to restore groundwater
to its beneficial use as a drinking water consistent with the FDEP classification of G-I and G-1I.
Therefore, attainment of MCLs or more stringent FDEP GCTLs is not required for this interim
remedy. The remedial alternatives for the Extended Plume are predicated on the assumption that
remediation of contaminant sources in the Unsaturated Zone and Main Source Area CMZs is
undertaken.

Four remedial alternatives were developed and evaluated for the Extended Plume.

10.4.1 Extended Plume Alternative I: No Action

Extended Plume Alternative J: No Action

Estimated Capital Costs: SO

Estimated Annual O&Kt Costs: $86,100

Estimated Present Worth Costs: $0

Estimated Construction Timeframe: Mot Applicable

Estimated Time to Achieve RAOs/Cleamtp Levels: greater than 30years

The Extended Plume No Action Alternative is equivalent to the Unsaturated Zone and Main
Source Area No Action alternatives.

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10.4.2 Extended Plume Alternative 2: Groundwater Recovery and I reatnunt

Fsti mated Capita! Cmts $919,250

Estimated Annual O&M Costv 53J72JMH)

t iimcicd P>\ -vt*nt flor (h < \jsL\ ^ I, 090, WM)

Estimated L 'onstrvction Timt'tmrnv, 5 months

Estimated Time to Achic\e RAOs>Cieumip I * xvars

This alternative includes installing about six groundwater recosery welis across the dissolved
plume and perpendicular to groundwater flow to hydrauhcall) contain and prevent the lateral
migration of contaminants. The recovery wells will also provide limited COt" mass removal, The
actual number of well?;, their location and the extraction flow rates would he determined by
groundwater modeling during the remedial design.

The recovered vvaier would be treated with a complex treatment train consisting of oif water
separation, air stripping, metal sequestration/adsorption. filtration. pH adjustment ex-situ
oxidation and carbon filtration. Preferentially, the treated effluent would be discharged to
infiltration galleries constructed west of the facility, Conversely, a \enes of injection wells
and/or direct discharge to the surface water retention pond located west of the Site eouid be used
for effluent disposal, In the event of discharge into surface water is necessary, then it wilt meet
the substantive requirements of a National Pollutant Discharge Flimination System iNPOESl
permit, deluding effluent limits that arc identified as ARARs

Groundwater samples would be collected and analyzed for COC levels against MC la or mote
stringent t-DFP OCT I s to gauge the effectiveness of hydraulic containment in reducing the
migration of the Extended flume i 'OCs downgradient. The samples would be collected from
monitoring wells located throughout the lx tended Plume. Groundwater levels would also be
collected and used to determine the degree of the hydraulie containment of the f xtended Plume.
Process samples would be collected after each of the treatment trains steps to ensure that each
step was operating correctly and reducing the contaminants in the extracted water Samples
would also be collected before the treated water is discharged to confirm that it meets discharge
effluent limits or injection standards meluding meeting MCLs and more stringent CtiTLs.

1(1.4.3 Extended Plume Alternative 3: lii-Situ Carbon Injection anil In-Situ Reduction
Permeable Barriers

Estimated Capital Costs. S2,S5,\4
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Petroleum Pftxfacts < nrporatton Suprrtitrd Site
Rccord ofDctiaor,
luiv ma

would be used to apply in-situ carbon adsorption and metal/ fixation amendments to create
passive treatment zones,

initially, an injectable colloidal carbon composed of imcroscaie particles of activated carbon
suspended in water through the use of organic polymer chemistry would be injected The
injected carbon should also function as a colloidal biomatrix binding to the aquifer matrix,
providing both direct carbon adsorption and enhancing hiodegradatton of dissolved COCs. The
same injection wells will be used to inject a reducing agent or sequestering agent such as calcium
polysulfide or a soluble phosphate-based mattoa'sequestenng agent such as monopotassium
phosphate. For both the colloidal carbon and the metal reducing sequestering chemical, tie
injection flows and pressures would be devised to achieve an approximately 15-foot distribution
of these suspensions,

Groundwater samples would be collected and analyzed for COC levels to gauge the effectiveness
of carbon capture and metal sequestering mechanisms, The samples would be collected from
monitoring wells located throughout the Extended Plume If necessary, direct push soil sampling
may be conducted to confirm thai in-situ chemical distribution is being achieved

111,4.4 Extended Plume Alternative 4: Monitored Natural Alt en nation

Estimated Capital Costs $0

Estimated Annual ()& M Cm a, $330,000

Estimated Present Worth Costs' 5329MOO

Estimated Construction Timeframe. Not Applicable

Estimated Time to Achieve R.H)s'Cleanup Levels: 30years

This alternative, monitored natural attenuation, uses the natural biotie degradation or natural
abiotic degradation (e.g., due to reduced iron species, soil attenuation, advectiori, dispersion,
dilution) for contaminant reduction. The dtveise array of COC s. within the Extended Plume will
limit the effectiveness of monitored natural attenuation as an interim remedy. The different
COCs require different physical conditions to support either biottc or abiotic decay. For example,
the largely aerobic groundwater conditions on site may limit natural biodegradation for some
€ DCs (such as chlorinated ethenes) that preferentially degrade in anaerobic geochemistry. Some
COCs in the Extended Plume (such as 1,4-dioxaneJ are recalcitrant to biotie degradation. The
current geochemistry is not sufficiently reduced to transform dissolved metals into less soluble
sulfides. Natural abiotic degradation ts assumed to also be a limited but active degradation
mechanism.

The difference between monitored natural attenuation and an active btorcmediarion or redox
remedy is that no effort is made to enhance the existing biotie or abiotic mechanisms. Monitored
natural attenuation may be a viable supplemental alternative for the Extended Plume when used
in conjunction with treatment of the source areas/higher COC concentration areas. The
effectiveness of monitored natural attenuation for the Extended Plume will be largely dependent

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n< rv': " i " i»j. n Ski1. r« i j s >.

K'fsi'ttl '?f Dc^'w iir3
My ?-,0 I

on the aggressiveness of the treatment options selected tor the Unsaturated Zone and the Mam
Source Area, Monitored natural attenuation will be ineffective without source area treatment and

will require an extended time to achieve restoration (estimated at 10 to 30 years) throughout (he
plume, even if source area remedies are conducted.

IIJ Comparative Analysis of Xltcrnativcs

The NCP establishes a framework at*nine criteria for evaluating remedial alternatives. These
nine criteria were used to evaluate the remedial alternatives individually and against each other
to identify the selected remedy. If an alternative does not meet the first two threshold criteria,
Overall Protection of Human fleailh and the tnvtronroeni, and Compliance with ARARs. the
EPA does not consider the alternative for further evaluation. The PS used a comparative analyM:>
to assess the relative performance of each alternative in relation to the nine criteria
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1 -Ti U „t i"H li^cc t ji, i„'vn irnj V ft

H-'t .nj >f i">.\ Hi'j30o ^ 15(d),

Chemical-specific ARARs include the I IM i' SCI Ls m "I able li of hAC Chapter 62-770 for

contaminated soil as well as ITM:!' Mi'Ls or PPKP GCILs for contaminated groundwater m
f At' Chapter 62-770, Table i. The f-OI P CUT! Table I incorporates the \1( I > front Florida
primary drinking water standards at FAt' 62-550 310 lor some of the listed chemicals. The more-
stringent level is identified as the cleanup level for a particular COC. consistent with the NCP
and EPA guidance. These levels are used to evaluate the effectiveness of the interim remedy for
the Extended Plume that includes hydraulic containment of gioundwater migration above the
Ml'Ls and'or Gi'Tf s

The primary action-specific ARARs include RCRA requirements for characterizing, staging,
treating and disposing of hazardous waste. Other net ion-specific ARARs include requirements
for construction and operation and closure of monitoring and injection wells

All CMZ alternatives, except the No Action alternatives, are expected to meet the chemical*
specific and action-specific ARARs through treatment, containment, or removal and proper
disposal of the contaminants, engineering controls and/or ICs, The ARARs tables for all
remedial alternatives are mailable in the appendix of the Site's 2019 FS Report, starting with
Table 5-1,

11.1.3 Long-Term Effectiveness and Permanence

Long-term effectiveness and permanence assess the magnitude of residual risk and the ability of
a remedy to maintain reliable ptoteetion of human health and the environment ovei time, ouce
cleanup levels have been met. This criterion includes the consideration of residual risk that will
remain on site following remediation and Ihe adequacy and reliability of containment controls
and institutional controls.

Alternatives that physically remove contaminants from the site media (especially Alternative 2)
provide tlie most protection for the longest period and preclude COC rebound or residuals.
Alternative 5, the thermaRstabili/ation combined remedy, would provide a uniform treatment

and eliminate Ihe sludge and NAPL components from the Main Source Area while leaving a
stabilized metal residual in an on-site engineered disposal unit that complies with identified
RCRA ARARs,. With the highest mass destruction potential, it would also have a low occurrence

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m %\n "Vuti « > iT'i i,ti« i rf,r.1 >

PUcorc vrDcc; i">n
jui> 2i»:i

tor contaminant lebound Stabilization, solidification alternatives. Alternatives 3 and T will
indefinitely contain COCs and will require only minor long- term groundwater performance
monitoring The e.v-sttu process for Alternative 3 will allow a very uniform treatment with high
assurance of meeting leachate limits. The iu-situ isolation based remedial alternative, Alternative
4 will meet this criterion if the engineered remedy is stable and construe ted with no defects. The
Mabili/atioiv solidification alternatives also have a lower ranking due to potential concerns wills
performance monitoring indicating the need for expanded treatment and the need for long-term
monitoring. The likelihood of ai! alternatives to meet performance standards in the near term is
high.

In-situ alternatives are preferred as they add an ex'ra component of eiimate resilience As

htuncancs frequently pass through this area, in-situ Alternative 4{stabilisation,'solidification) is
more effective in the long term with no on site above ground components Complete removal of
the contaminated media via Alternatives T 1 and 5 would also achieve long-term eiimate
resilience.

Alternative*, ? through 5 provide some degree of long-term protection Rtuevvs at least every
five years, as required, would be necessary to evaluate the effectiveness oi' all of the alternatives

11.1.4 Reduction of Toxicity, Mobility or Volume through Treatment

This criterion assesses the degree to which alternatives employ recycling or treatment that
reduces toxicity, mobility, or volume, including how treatment h used to address the principle
threats posed by the site.

Alternative 5 f ex situ) and Alternative 4 (in situ) treat the contaminated soil through
stahili/at ton/sol iditleatiori and are expected to reduce the mobility of the contaminants through
treatment "loxieitv and volume would not he reduced as contaminants are not destroyed.
Alternative 5 incorporates thermal treatment thai would reduce the toxicity and volume of die
contaminants in the soil prior to stabilization''solidification to reduce their mobility. Alternative 2
(off-site disposal,? is expected to provide fot j»ome treatment of the contaminated media thai
contain RCRA Hazardous waste to meet the RCRA 1 l)Rs prior to disposal.

11.1.5 Short-Term Effectiveness

Short-term effectiveness assesses the period of time needed to implement a remedy and any
adverse impacts that may be posed to workers, the community and the environment during
construction and operation of the remedy until cleanup ieveb are achieved

The No Action alternative for all three CM/s is expected to prov ide the highest level of relative
overall short-term effectiveness as these alternatives do not require any remediation of the Site
and so pose no short-term threats to workers, the community, or the environment The
comparative analysis results for this criterion were similar as ail the active alternatives are fairly
disruptive to the tenants and community fof up to a yeai. Alternative 4 was ranked high because

¦i

•4 /

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Petwteum Products Cmporatioo Supcrfttnd Site
Record of Decitfcra

July 2021

it should hive the smallest impact on the local community and construction workers. The
excavation components of lie other active alternatives increase the potential for impacts to the
community and workers, although these issues can be effectively managed.

11.1.1 Implementability

Implementability assesses the technical and administrative feasibility of a remedy from design
through construction and operation. Factors such as availability of services and. materials,
administrative feasibility, and coordination with oilier governmental entities are also considered.

Alternatives 2 through 5 are considered to have good implementability. Due to the shallow depth
of the Unsaturated Zone and technology reliability, alternatives that included excavation.
Alternative 2, Alternative 3, and Alternative 4, scored highest; it will be easier to monitor these
remedies for remedial effectiveness and make remedial modifications with minor site disruption.
In comparison, the use of LDAs at shallow depths will be more complex (Alternately, the in-situ
mixing could be accomplished with or in conjunction with excavators or shallow soil mixing
tools such as a Lang or AIlu tool). Tlte thermal and stabilization alternative (Alternative 5) is less
implementable due to a more complex treatment train for operation.

11.1.7 Cost

The cost criterion involves an evaluation of the capital costs, the annual operations and
maintenance (O&M) costs, and a present worth analysis. The cost estimates are order-of-
magnitude level estimates, which are defined by the American Association of Cost Engineers as
approximate estimates made without detailed engineering data. It is normally expected that an
estimate of this type would be accurate to +50 percent to -30 percent. The actual costs of the
project would depend on the final scope of the remedial action, the schedule of implementation,
actual labor, material costs at the time of implementation, competitive market conditions, and
other variable factors that may impact the project costs. The net present worth (NPW) for each
alternative was developed using the modified uniform present value method. In accordance with
current EPA guidance (OSWER Directive 9355,0-75, July 2000), a discount rate of 7 percent
before taxes and after inflation (for a non-Federal facility) was used to account for the time value
of money.

Costs for the implementation of statutory Five-Year Reviews and groundwater monitoring are

included as the sitewide costs. These costs were estimated separately as they apply to all remedy
alternatives since waste will remain in place at the Site with every alternative.

There are no capital costs associated with the No Action Alternatives; present worth costs for
this alternative include the costs to conduct long term monitoring of field parameters. COCs. and
natural attenuation parameters every live years for 30 years (six events). The total NPW costs aie

estimated at $86,00©.

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'«(-vHi,-. i if \,»\r -•> "* .

Rev ore Of D^v-cifir.
Jul) 202!

Costs for the Altematnes 2 through 5 varied widely,, reflecting the differential between disposal,
containment, and treatment options. Alternative 5 has the highest projected cost at SloM. owing
partially to the need to treat the soil thermally followed by a stabilization phase Alternative 2

I Excavation and Off-Facility Disposal in Landfill} has an equivalent cost of SUM to Alternative
5 with the high cos) associated. The stabiI i/ation solidt fieation alternatives have comparable
costs with the ex-situ stabiiizatkm/solidifieatton alternative (Alternative 3) being marginally
higher at $13M and the in-siiu alternative (Alternative 4) being M ?M.

11.2 OIZ 2 - .Main Source Area

11.2.1 CHtfrail Protection of Human Health aid the Environment

Overall Protection of human health arid the env ironmem assess uhethei an alternative adequately
protects human health and the environment. in the short- and long-term by eliminating. reducing,
or controlling exposures to levels established during development of cleanup levels This
criterion draws on long-term effectiveness and permeance, short-term effectiveness, and
compliance with ARAKs

Alternative I, the No Action alternative is not protective of human health and the environment
and will not be carried forward. Alternatives 2 through 5 will be protective of human health and
the environment Each alternative would reduce the threat of sludge and NAPL mobility either
though stabilization'isolation, partial treatment, or direct removal. Alternative 2 {Excavation and
OA-Facility Landfill Disposal I removes all source area contamination from the Mam Source
Area in about 7 months, Alternative 3 doe* not provide a treatment reduction in concentration as
the other active remedies can provide Alternative 5 i lo-Sito Thermal Treatment with Chemical
Reduction) has the highest risk arid uncertainty; it lacks adequate treatability testing arid is highly
contingent on sub surface heterogeneity and conditions.

11.2.2 Compliance with ARAJRs

This criterion assesses whether an alternative attains ARAR.s or provides grounds for invoking

one of the AKAR waivers. Alternatives ?. * ami ^ meet the chemical-specific and action-specific
ARARs. The ARAlis tables for all alternatives can been found in the appendix of the 2019 FS
Report, starting with Table M

11.2 J Long-Term Effectiveness and Permanence

Long-term effectiveness and permanence assess the magnitude of residual risk and the ability of
a remedy to maintain reliable protection of human health and the environment over time, once
cleanup levels have been met. This criterion includes the consideration of residua! risk that will
remain on site following remediation and the adequacy and reliability of containment controls
and institutional controls.

Alternative 2 (Excavation and Off-Facility Disposal in an appropriate permitted landfill) is
expected to offer the best long-term effectiveness as all site contamination is removed, ln-suu
.stabilization will combine a proven soil mixing approach along with a bench-scale proven

4\>

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Petrol' uts P-rducts Cotpontkm Supt i f„!,d J» it
Record of Dccutoc
July 202!

stabilization solidification mixture; long-term expectations for this remedy arc also high.
Alternative 5 (In-Situ Thermal Treatment with Chemical Reduction) for the Main Source Area
was ranked lower as the in-situ thermal and injected stabilization approach has a higher chance
of inefficiencies and may leave residual areas not thoroughly treated with either thermal
conductive heating or stabilization. Alternatives 3 and 5 require long-term stabilization ofOK'v
However, all stabilization/solidifieation approaches should be irreversible.

In-situ alternatives are preferred as they add an extra component of climate resilience. As
hurricanes frequently pass through this area. Alternative 3 t In-Situ Stabilization/Solidification) is

more effective in the long term, with no above-ground components on site. Thermal treatment
Alternative 4 (Ex Situ with Stabiliiation/Solidiicatloit) and Alternative 5 (In-Situ) would have
an above-ground component for a short period; this would not affect their long-term climate
resilience, Complete removal of tie contaminated media via Alternative 2 would also achieve
long-term climate resilience.

11.2*4 Redaction of Toxicity, Mobility or Volume through Treatment

This criterion assesses the degree to which alternatives employ recycling or treatment that
reduces toxicity, mobility or volume, including how treatment is used to address the principal
threats posed by the Site.

The alternatives have considerable differences in their reductions of contaminant toxicity,
mobility, and volume Alternative 2 provides complete removal but does represent a transference
of waste to another location without treatment for toxicity if required. Alternative 3 is expected
to provide strong assurance of mobility reduction to prevent leachate that would exceed
groundwater cleanup levels off Mie, Alternative 3 requires long-term stabilization of COC's on
site. However, ail stabilization Solidification approaches should be irreversible.

11.2.5 Short-Term fclfectiveness

Short-tern effectiveness assesses the period of time needed to implement a remedy and any
adverse impacts that may be posed for workers, the community and the environment during
construction and operation of the remedy until cleanup levels are achieved.

All Main Source A era alternatives have similar expectations for short-term effectiveness The tn-

situ options. Alternative 5 and Alternative 3. have less potential for site and neighborhood
disruption as they do not involve excavation or trucking. The large-diameter auger soil mixing
alternative. Alternative 3, should have minimal dust and odor issues as vapors can be collected in
a shroud. Alternative 5 has a longer period before RAOs are completed and requires air-phase
treatment controls. While tmwt of the MSA alternatives require less than a year to reach RAOs,
Alternative 5 is estimated to take up to 10 years to reach RAOs. Alternative 2 will provide a
substantial disruption to the Site and local traffic, due to the number of trucks necessary to haul
the contaminated soil to a landfill.

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5\l»>*L'crt"' fjiHiivK ( s,i[h rtunj Nit!1

Record of IJeciiioii
i'ily Sit

11,2,6 Implemcntability

Iniplementabiliiy assesses the technical and administrate feasibility of a remedy from design
through construction and operation. Factors such as auii lability of services and materials,
administrative feasibility, and coordination with other governmental entities are also considered,

Alternative?* 2, 3 arid 5 evaluated for the Mam Source Area are implementable with only minor
issues and there is little differentiation. Alternatee 3 (I IJA Stabilization Solidification) should
be a straightforward application in shallow soils with the buildings removed. The excavation and
dewatering scenarios can be executed but are expected to be arduous, due to the shallow water
table. Alternative 5 (In-Situ Thermal Treatment fConductive Heating) with Chemical Reduction!
has no implementation concerns for drilling and construe lion. Operation of the system is less
siicc, largely due to the potential impact of non-u.mform distribution of the
reduction,''sequestration mjectute and increased reliance on less defined performance monitoring
data.

11.2,? Cost

This criterion assesses capital costs, the annual O&M costs, and a present value of capital and
(kV V! costs (present worth analysts}, The cos! estimates are
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Petroleum Pnkiuctf < .inwiraUnn Sispetlurtd Silt
Record N" lUv ision

M* iv:;

11.3 CMZ 3 - Extended Plume

i 1.3,1 Overall Protection of Human Health and the Environment

The Overall Protection of Human Health and the Environment criterion assesses whether an
alternative adequately protects human health and the environment in the short term and long term
by eliminating, reducing or controlling exposures to levels established during development of
cleanup levels. This criterion draws on long-term effectiveness and permeance, short-term
effectiveness and compliance with ARARs

Alternative J (No Action) is not protective of human health and the environment and will not be
carried forward. Alternatives 2 through 3, along with lCs, will be protective of human health and
the environment in the short term. Alternative 2 (GR&T) provides hydraulic containment and
long-term mass reduction. Alternative 3 (In-Situ C arbon Injection and ln-Situ Reduction

Permeable Barriers) creates a passive treatment wall that will treat groundwater as it continues to
How downgrudient Alternative 3 will effectively limit any significant tltssoived-pha.se
contamination from migrating past the barrier but will not accelerate the mass recovery and
subsequent treatment equivalent to the GR&T alternative

11.3.2 Compliance with ARARs

This criterion assesses whether an alternative attains ARARs or provides grounds for invoking
one of the ARAR waivers Alternatives 2 through J will meet the chemical-specific and aettoii-
specitic ARARs, Given that the remedy for contaminated groundwater is interim and that a final
remedy will be selected in a separate ROD that includes objective for restoration lo beneficial
me "A Class 1 or Class II groundwater, attainment of chemical-specific ARARs, including MCI.s
or FDKP GCTI s, is not required at this time. These levels are being used to evaluate the
effectiveness of remedial alternatives in preventing further migration of contaminated
groundwater All other action-specific ARARs, including those for installation, operation and
closure of monitoring and injection wells, will be complied with during remedy implementation.

11.3.3 Long-Term Effectiveness and Permanence

The Long-Term Effectiveness and Permanence criterion assesses the magnitude of residual risk
and the ability of a remedy fo maintain reliable protection of human health and the environment
over time, once cleanup levels have been met. This criterion includes the consideration of
residual risk that will remain on site following remediation and the adequacy and reliability of
containment controls and institutional controls.

Alternative 2 (GR&T) will have better long-term effectiveness by providing a mixture of mass
reduction and containment. The groundwater treatment system will be more complex but will use
proven and reliable technology with adequate and reliable controls. Alternative 3 involves a
fixation mechanism that needs site-specific pilot-scale testing to validate the expected
effectiveness. CiR&T will he more effective as a containment remedy than the Alternative J
treatment barrier, even if the barrier performs at optimal effectiveness. All alternatives will
require long-term monitoring. Alternative 3 docs offer a low complexity long-term operation

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iri, r, ' I" Si j, V't
Rcfcri i'>i IXvi^tofi
,'viiV

relative to GR&T and can be designed coaservmively to function as a contaminant flux barrier.
Alternative 2 ami Alternative 3 arc not expected to have significant issues with residual risks or
treatment irreversibility Both remedies are susceptible to long-term O&M costs events if Main
Source Area remediation does not adequately limit the incoming rtux of COl's - Alternative 2
through conoriued operating costs and Alternative 3 through reinjcctions of substrate Alternative
3 is dependent on direct hydraulic contact that could be limited in the heterogeneous lithologv,
Alternative 2 relies on long-term back diffusion of COCs from soil,

11,3.4 Reduction of Toxicity, Mobility or Volatile through Treatment

This criterion assesses the degree to which alternatives employ recycling or treatment that
reduces toxicity, mobilitv or volume, including how treatment is used to address the principal
threats posed by the Site,

Alternative 3 s UR&l I will have the highest tale of mass reduction and will shrink and contain
the plume. Alternative 3 (treatment barrier) will reduce toxicity in the long term and will contain
the plume on silt* at startup. Alternative 3 does not reduce the volume of the ptume.

113,5 Short-Term Kffcctiveness

The Short-Term Effectiveness criterion assesses the time needed to implement a remedy and any
adverse impacts that may be posed to workers, the community and the environment during
construction and operation of the remedy until cleanup levels are achieved

Neithej Alternative 2 or Alternative 3 will have a distinguishable difference m community
impacts or worker protection, Al! options are general!) protective of the community, The two
active alternatives t Alternative 2 and Alternative 3) provide good short-term effectiveness and
are protective of workers and the community during remedial action. Alternative 2 (CiR&T)
should be more effective at meeting RAOs in a shorter timeframe

TlJ.i Implementafoilitv

The Implememabditv criterion assesses the technical and administrative feasibility of a reroed)
from design through construction and operation, f actors such as availability of services and
materials, administrative feasibility, and coordination with other governmental entities are also
considered

All of the alternatives evaluated !br the Extended Plume are implementable with only minor
issues. Alternative J itiKAiT! ts more > omplev due to the reliance on establishing and
maintaining reduced conditions and achieving a uniform distribution of soluble carbon.
Alternative Z lOR&T) is an easily implemented approach, although the long piping runs will
prov ide some disruption at the Site. The number of trucks needed (about, 4,100) to transport the
large soil volume for Alternative 2 would be a burden to the community, as well Operation of
the GR&T system ;s expected to be labor intensive and require extensive remote monitoring.

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>V»t i r i* t

EecoiioflJiciiiiii

Alternatives 2 and 3 offer reliable and pun en technology that is eo»y to implement, though the
CJR&T s\ stem is more easily modified.

113.7 Cost

This criterion assesses capital casts, annual O&M costs, and a present value of capital and O&M
costs (present worth analysis), The cost estimates are order-of-magnitilde level estimates, which
are defined by the American Association of Cost Mngmecrs as approximate estimates made
without detailed engineering data. It is normally expected that an estimate of this type would be
accurate to *50% to -3o°u The actual costs of the remedy would depend on the final scope of the
remedial action, the schedule of implementation, actual labor, material costs at the time of
implementation, competitive market conditions and other variable factors thai may impact the
project costs. The NPW for each alternative was developed using the modified uniform present
value method. In accordance with current EPA, guidance (OSWER Directive 9355,0-75, July
2000), a diicount rate of 7% before taxes and after inflation (for a non-federal facility) was used
to account for the time \alue of money

Costs for (he implementation of statutoty \< ive-Year Reviews and groundwater monitoring are

included as the si tew ide costs. These costs were estimated separately as they apply to ail remedy
alternatives .since waste v.ill remain in place at the Site.

Costs for the active remedial alternatives for the I-\tended Plume zone ranged from $4.1 M to
$5,9M Projected costs for Alternative 2 {CtR&Tl are high due to high capital and operation and
maintenance costs. Projected costs for Alternative 3 ^treatment barrier) are high due to the
drilling and chemical costs and potential re-injection of amendments

12.0 Principal Threat Waste (PTW »

The NCP establishes an expectation that the ItPA will address the principal threats posed by a
Site through treatment wherever practicable (NC P $ 500.4301 a}( i )tiii)(A)), The EPA guidance
"A Guide to Principal Threat and Low Level Threat Wastes" (Office of Solid Waste arid
Emergency Response |OSWF:R| 9380.3-OoFS - 1991) defines principal threat waste (PTW) as
source maierial considered to be highly toxic or highly mobile that generally cannot be reliably
contained or that would present significant risk to human health or the environment should
exposure occur PTW is defined on a site-specific basis for source maierial that acts as a
resersoir for migration oi comannnanis or acts as a source for direct exposure. In general, the
priority for treatment for PTW is placed on source materials considered to be liquid, highly toxae
or highly mobile, which generally cannot be contained m a reliable manner or would present a
significant risk to human health oi the environment should exposure occur.

The soil containing \ isuat evidence of N APL is considered PTW at the Site. Currently, the
sludue and MAPI, is also PTW and is a long-term source of leaching of contaminants for
surrounding groundwater. The former sludge pits (primary and secondary pits) represent the
largest extent of sludge and NAPL on-facility and the extent also include* significant areas
impacted from ovetlknv of She ponds or sludge NAPL redistribution from site fill and grading

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H iD'a.in-' SUI Ofl.t- I rxfifiifi-" v j.uti.tn* ^ H
Hccort of Macwnt.
u; :w.;

activities There are nn estimated I (>5.570 cubic yards of sludge- and MAPL-tiupaeted soil in the
Main Source Atca

13 J Selected Remedy

13,1 Summan" of the Rationale for the Selected Remedy
The selected remedy for the Site is:

• OU1 (I "rtsaturated Zone); In-Situ Stabilization Solidification with Limited Soil
Excavation and CHT-Facility Disposal

• OU2 i Main Source Areaf In-Siiu Stabilisation Solidification with LDAs.

• OU3 I Lxtended Plume': CiR&T.

Common Elements are;

• Bamboo Mobile Home Park excavation and relocation

• Relocation ofbusiiie&ses, tenants and residents prior to building demolition in the Main
Source Area.

• Shallow excavation under buildings

• ICs to prohibit well installation and any use of contaminated groundwater, to provide
increased public awareness and lestriet disturbance of the in -situ treated waste that
remains at the Site as veil as interference with other rented) components such as existing
or future remediation system and/or monitoring wells. Land use al the Site (other than
Bamboo Mobile Home Park which is currently residential) will be restricted to remain
imiustrial/commercnil use.

• Monitoring, including long-term groundwater monitoring, to assess remedy performance

• Site reviews at a minimum of even, five years to assess the protect i veriest of the remedy
( f ive-Year Review.sK

Any businesses still operating on the Sile within the boundaries of the affected areas (defined as
the extent of CMZ and CMZ 2) at the commencement of the remedial action shall be
permanently relocated and the structuies used by them vacated and demolished as they
physically bloek and will interfere with the .selected remedy. Relocation of businesses, tenants
and residents will be performed pursuant to or consistent with the Uniform Relocation
Assistance and Real Property Acquisition Act, 42 t1 5. Code 4r>0i et icq,, ami regulations
promulgated pursuant thereto at 49 CFR. Part 24, depending on whether the EPA or the PRP
Group ts the lead to perform the relocation activities.

These alternatives were chosen based on the comparative analysis of all the alternatives. The
Selected Remedy meets the threshold criteria and provides, the best balance of tradeoffs among
the other alternatives, with respect to balancing and modifying criteria. The EPA and the FDEP
determined that the Pre fen ed Alternative prevented in the Proposed Plan best satisfies the nine
criteria oi the NCR as compared to the other alternatives. Figure 8 summarizes the selected
remedy.

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Hi'tiuieuw Frwtajs buccnWui Site

Record ul Decision

fob- zni

Based on the information available at this time, the EPA and the FDBP have determined that the
selected remedy combination satisfies the following statutory requirements of CERCi A Section
121(b) and Section 121(d): 1) protects human health and the environment; 2) complies with
ARARs (and does not require a waiver): ?>) is cost effective; 4) tiiilbes permanent solutions and
alternative treatment technologies or resource recovery technologies to the maximum extent
practicable: and 5) satisfies the preference for treatment as a principal element. In combination.
Unsaturated Zone Alternative 4, Main Source Area Alternative 3 and Extended Plume
Alternative 2. will achieve substantial risk reduction to all potential exposure routes in a
reasonable timeframe,

The modifying criteria of State Acceptance and Community Acceptance have been incorporated
into the selected remedy. The State of Florida, as represented by the FDEP. has been the support
agency during the RJ FS process. The FDEP provided input during the process in accordance
with 40 CFR §300.430 and concurs with the selected remedy (Appendix D). The community has
participated in the review of the Proposed Plan and, based on comments received, supports the
selected remedy (Appendix B).

13,2 Description of the Selected Remedy

13,2.1 Ol'-i: Unsaturated Zone Alternative 4 - lo-Situ Stabilization/Solidification with
Limited Sol Excavation, and Off-Site Disposal

The shallow, unsaturated soil depth makes stabilization solidification soil treatment relatively
easy and allows the true extent of sludge and NAPL contamination to be visually observed. The
shallow soil excavation under buildings will complement the stabilization/solidifieaiion
treatment of the Unsaturated Zone soils above the Main Source Area. Alternative 4 is expected to
cost about S2M less than if the Unsaturated Zone soils were excavated and then transported and
disposed of iti a landfill (Alternative 2), The number of trucks needed < about 4,100) to transport
the large soil volume for Alternative 2 would be a burden to lite community
Stabilization/solidification results from bench-scale testing were very positive, even for
conservatively (higher than anticipated in the field) rich in sludge'NAPL treatability test
samples.

This remedy will have some oil-sue landfill disposal for the soils under the shallow buildings
and for the top 2- foot layer of treated soil over the Main Source Area, (.'lean compacted soil till
(at least 2 ft, thick) will be placed into the excavated areas, including the residential property in
the Bamboo Mobile Home Park, to provide complete assurance of meeting the direct contact soil
cleanup levels based on chemical-specific ARARs. The m-situ .stabili/ation sohdificauon areas
would need to be specifically designed and constructed with adequate strength to support the
anticipated use of the property including constructed buildings while ensuring the performance
of the remedy.

This alternative provides the highest potential for discovery and treatment of all contaminated
soil in the Unsaturated Zone via stabilization/solidification and will prevent direct contact with

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any seeps or with 1Ot '-laden soil. This alternative will be readilv implementabte. uses proven
technologies (in-situ mixing with IDAs, in-situ stabilization'solidification, excavation, and off-

si te treatment and disposal ia a permitted landfill), and can be implemented in a short timeframe
Mess than one unirs with minimal disruption to the community Alternative 4 also has the
shortest expected construction lime, five months, of all the Unsaturated Zone alternatives.

13.2.2 QU2: Main Source Area Alternative 3. In-Sltu StabilizatumSididification with

LDAs

Altername 3 v\ill provide complete isolation and containment ot tne sludge and MAPI., It has the
lowest NPW cost of the three active Main Source Area alternatives Alternatives 2, 3 and 5 were
very close in their likely remedial outcomes, indicating that any of {he alternatives would be a
good choice for protection of human health and the environment. The overall cost for Alternative
\ Si! 6VI, compared to about S28.4M for Alternative 2 (Fxeavation and OfT-Site Disposal in
Landfill) was a differentiating factor. Both Alternative 2 and Alternative 3 are protective.
Alternath e 3 eost> about $1?M !e^> than if the soil was taken off site for disposal, Alternative 5.
In-Situ Thermal Treatment (Conductive Heating) with Chemical Reduction, had the same
relative likelihood of successfully remediating the Site arid would ho an equally acceptable
approach, but was about 70% more costly ($19 8M) than Alternative 3,

Bench-scale stabilization "solidification testing results were ver> positive, even lot the highly
contaminated treatability lest samples (higher than anticipated in the field).

Demolition of the Main Source; Area buildings will allow enough space for the i D \ rjjrs
Another advantage to in-situ stabilization/solidification with the LDAs is the abilin ot the LM-\>

to penetrate, mix and treat the uppei layers of limestone where residual MAPI is trapped.
Alternative 3 also does not require expensive deep shoring or sheet pile walls and can he used in
relatively proximity to existing buildings. Alternative J will be moderately easy to implement,
uses proven technology li D \ mixing and stabilizaiioivsolidificatwn) that have been bench
tested using site materials, and can he implemented in a short timeframe (less than one ycari with
minimal disruption to the community.

Stabilization/solidification treatment usually causes an increase in the final treated soil volume
from being mixed and from the addition of the stahiiimion/soltdiCtcauori treatment chemicals.
To keep the post-remcdiation laud surface as close as possible to existing grade, any excess soil
volume will be excavated, t. lean compacted soil ftl! would he used lo backfill the excavation
areas The in-situ stabilization/solidification areas would need to be specifically designed and
constructed with adequate .strength to support the anticipated use of the property including
constructed buildings while ensuring the performance of die remedy.

13.2.3 Ol 3: Extended Plume Alternative 2. Groundwater Recovery and Treatment

As discussed in the comparative analysis of the alternatives. Alternative 2 had a higher expected
icmedia! performance jnd lower costs than Alternative 3, In-Sitti Carbon Injection and In-Situ

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Petroleum Products Corporation Supeifuod Site
Record of Decision
July 2021

Reduction Permeable Barriers, The overall costs for Alternative 2 are about 44% less and
Alternative 2 can provide ongoing containment and mass removal throughout the Extended
Plume. The annual O&M costs were derived for a 10-year period with an additional five years of
performance monitoring. These annual costs arc high if extrapolated for a longer (i.e., 30-year)
timeframe, but are realistic for an interim action dissolved-plume remedy coupled with
aggressive source isolation, which is planned for the Site. Of the Extended Plume alternatives.
Alternative 2 will combine the best with the selected Main Source Area alternative, because the
locations and depths of Alternative 2*s well screens could be adjusted to be clear of the Mali
Source Area ui-situ stabilization/solidification matrix. This alternative will be easy to construct
(i.e., installation of groundwater extraction wells), uses proven technologies (hydraulic
containment and water treatment), and can be implemented in a short timeframe with minimal
disruption to the community.

13,2.4 Common Element! and Sitewide Costs

Three Common Elements will be implemented before the Unsaturated Zone and Main Source
Area remedies are conducted. These elements - Bamboo Mobile Home Park excavation and
relocation {Common Element 1), building demolition and relocation of businesses, tenants and
residents overlying the Main Source Area (Common Element 2), and shallow excavation under
buildings - retain existing buildings I Common Element 3A), arc recommended for protection of
human health and the environment. In addition to the Common Elements, the selected remedy
also includes implementation of ICs to prevent unacceptable exposure to treated waste or
residual contamination (including contaminated groundwater), to provide increased public
awareness of residual contamination that remains at the site and restrict disturbance of the in-situ
treatment areas and groundwater recovery and treatment system. It also includes conducting Five
Year Reviews to ensure that the remedy remains protective and long-term groundwater
monitoring to ensure that contaminant levels in groundwater are decreasing.

133 Cost Estimate for the Selected Remedy

The estimated total NPW cost for the Selected Remedy is $57.1M for all three OvfZs, including
the Common Elements. The cost estimate for the Selected Remedy is included in Table 17.
Detailed cost breakdown, sheets of'the components for each alternative are included in Appendix

C, The cost estimate is based on the available information regarding the anticipated scope of the
remedial action. Changes in the cost elements are likely to occur as a result of new information
and data collected during the remedial design phase. Major changes may be dTCumeiited in the
form of a memorandum to the Administrative Record file, an ESD or a ROD Amendment. The

projected cost is based on an order-of-magnitnde engineering cost estimate that is expected to be
within +50% or -30% of the actual project cost. Costs are based on the conservative estimate of a
30-year timeframe until all cleanup leveJs are met.

13.4 Estimated Outcomes of the Selected Remedy

The Selected Remedy will provide protection of human health, and the environment by
eliminating, reducing or controlling risks at the Site through in-situ stabilization/solidification
treatment of PTW (sludge, NAPL and high-concentration contaminated soils); excavation and

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oil-facility treatment and disposal of soils as neeessan, '• off-faeslity disposal of excess soils: the
installation of at least 2-U clean compacted soil fill in all iSie excavated portions of the pioperty;
hydraulic containment and treatment of the Is tended Plume, long-terra monitoring of the
remediated Site; and implementation of the ICs, tf's will prevent unacceptable exposure to
residual waste and contamination (including contaminated groundwater), provide increased
public awareness of residual contamination thai remains at the site and re,strict disturbance of in-
situ treatment areas and the groundwater recovery and treatment system, future land use of the
Site property is anticipated to continue to be industrial/commercial and residential for the
Bamboo Mobile Home Park

Implementation o; the ¦selected remedy and achievement of the cleanup levels for source
materials, soils, and groundwater will achieve the R AOs identified for the Site. The cleanup
levels determined for this remedy are shown m Tables 12 through 14, The selected interim
remedy for groundwater uses FDf:P \i('l s GC TI s for monitoring purposes to assess
effectiveness of the remedy in presenting further migration of groundwater above these levels

14,® Statutory Determination

Based on the information currently available, the EPA believes the selected remedy for each of
the t'MZs meets the threshold cmeiia and provides the best balance of tradeoffs between the
selected alternative 4tid the other alternatives with respect to the balancing and modifying
criteria, The CPA expects the selected remedv will satisfy the follow tug statutory requirements
ofCliRCLA Section 121(b).

• Be protective of hitman health and the environment.

¦ Comply with AKARs I unless a waiver is justified under Section I2hd)(4ll.

• Be cost effective,

• Use permanent solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable.

14,1 Protection of Human Health and the Environment

Protection of human health and the environment will be achieved by the m-situ
stabilization/solidification of the studge-'NAFl in the Unsaturated Zone and the Main Source
Area: excavation and off-facility disposal of excess contaminated Unsaturated Zone soils;
installation of at least 2-fbot-thick. clean compacted soil fill over the treated Unsaturated Zone
and Mai a Source Area soils and materials: and hydraulic containment and groundwater treatment
of the Extended Plume. In addition, implementation of ICs will prevent unacceptable exposure to
residual waste and contamination (including contaminated ground water), provide increased
public awareness of residua! contamination that remains at the Site and restrict disturbance of sn~
situ treatment areas and the groundwater recover}' and treatment system These remedial actions
should prevent any exposure to site contaminants and so should reduce the risks from the
contamination at the Site to protective levels.

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Petroleum Products Corporation bupertur.d Site
Record of Decision

My 2021

14.2 Compliance with ARARs

Section 121(d) of CERCLA and NCP §300.43Q(f)(l )(ii)(B) require that remedial actions at
CERCLA sites attain legally applicable or relevant and appropriate federal and more stringent
state requirements, standards, criteria and limitations that are collectively referred to as
"ARARs," unless such ARARs arc waived under CERCLA section 121(d)(4). The selected
remedy will comply with all identified ARARs and To Be Considered (TBO guidance presented
in Tables 14 and 15,

The in-situ stabilization/solidification of the sludge/NAPL and other COCs in the contaminated
Unsaturated Zone and the Main Source Area, along with the excavation and off-site disposal of
contaminated Unsaturated Zone soils will aUain the identified ARARs, including, but not limited
to, RCRA requirements for characterization and management of hazardous waste. Hydraulic
containment of the Extended Plume includes treatment of the recovered groundwater to levels
that allow the treated water to be discharged or injected in compliance with chemical-specific
ARARs and comply with Clean Air Act requirements for emissions of VOCs identified as
action-specific ARARs.

The scope of the selected interim action for Extended Plume groundwater does not include
restoration to beneficial use as a drinking water resource. The MCLs and GCTLs (identified as
Chemical-specific ARARs) are being used to assess remedy effectiveness of the interim remedy.
Also, the GR&T system shall attain MCLs or more stringent FDEP GCTLs prior to re-injection
of treated groundwater to comply with underground injection requirements. All other action-
specific requirements for remedy for the Extended Plume will be met, including requirements for
construction, operation, and closure of groundwater monitoring and injection wells,

14.3 Cost Effectiveness

The EPA has determined that the selected remedy is cost effective, and that the overall
protectiveness of the remedy is proportional to the overall cost. As specified 40 CFR
§300.430(f)( 1 )(ii)(D), the cost-effectiveness of the selected remedy was assessed by comparing
the protectiveness of human-health and the environment in relation to three balancing criteria;
long-term effectiveness and permanence, reduction in toxicity, mobility and volume, and short-
term effectiveness, with the other alternatives considered.

Wile more than one remedial alternative can be considered cost effective, CERCLA does not
mandate the selection of the most cost- effective or least-expensive remedy. The estimated total
cost (i.e., capital plus present worth of O&M costs) of the selected remedy is $57. IM at a 7%
discount rate.

14.4 Use of Permanent Solutions and Alternative Treatment Technologies t# tie
Maximum Extent Practicable

The EPA has determined that the Selected Remedy represents the maximum extent to which
permanent solutions and treatment technologies can be used in a practicable manner ai the Site.

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Of fhiue alternatives lhai arc protective of human health and the environment and comply with
ARARs, the hi'A has determined that the Selected Remedy provides the best balance of
tradeoffs in terms of the five balancing criteria, while also considering the statutory preference
for treatment as a principal element, bias agaiti-4 off-site ireatment and disposal, ano considering
state and community acceptance.

EPA recommends development of at least one alternative that would eliminate the need for long-
term O&M at the Site, The selected remedy should eliminate the need for long-term management
at the Site. The stabilization solidification treatment proposed for the source area PTW is
irreversible. After the treatment, the treated materials (M A PI./sludge) and contaminated soils will
be contained in a very low permeability matrix that will limit CQC migration to the groundwater
that \\ ould exceed cleanup levels for groundwater The groundwater recovery and treatment of
the Hxtended Plume .should contain further migration of contaminated groundwater. The
stabilization-solidification treatment of the Unsaturated Zone and the placement of the clean
cover over the treated wastes and soils, along with the ICs, should allow normal use of the Site
for Us current and reasomtbl} anticipated future use i commercial'industrial use).

Long-term effectiveness and permanence will be attained by long-term containment isolation and
treannent of the N APL/sludge PTWs and the contaminated soil The in-situ
stabilization1 solidification technologies are proven remedial treatment methods for tins type of
waste, have been verified by successful bench-scale treatability testing, and have long hfe c)eies

14.5 Preference for Treatment as a Principal Element

The NCP at 40 CFR §300.430
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S'cm c im *» 4^ -lU'W S'.

Rcciira "I !Kh • tur.

IUl¥i!02l

source materials, sludge and NAPL in the Cnsaturaied Zone and the Main Source Area will treat
some of the metals contamination, making these COCs less toxic The stab11 i/a t ion- >o) id i ftc a 11on
treatment will also bind the organic and nici.il Ct K s and the kludges and NAPL into a very law
permeability matrix that will reduce the t'OCs mobility to groundwater The recovery and
treatment of the groundwater will reduce the toxicity and volume of contaminated groundwater.
The recover}- system will also contain the contaminated groundwater, preventing further
migration oi'COCs.

14 J Five-Year Review Requirements

Because this remedy will result in bawtdous substances, pollutants or contaminants remaining
on the Site above levels that would ailow for unlimited use and unrestricted exposure, a
Ci'Rt'LA Section 121(c) statutory review will he conducted every five years after initiation of
tiie remedial action to ensure thai the temedy remain* protective of human health and the
environment The statutory Flve-Year Reviews will he conducted in accordance with EPA policy
and guidance

15.0 Documentation of Significant Changes

Pursuant to ChRCL A 117(b) and NCP §300.430(0!3Kit), the ROD must document any
significant changes made to the Preferred Alternative discussed in the Proposed Plan. The
Proposed Plan, which was released for public comment in January 20? I, identified the remedial
alternatives described in this document and identified the preferred alternatives.

The HPA reviewed all written and verbal comments submitted during the public comment
period. It was determined that no significant changes to the remedy, as originally identified in the
Proposed Plan. were necess.it> or appropriate as a result of public comments.

The Pioposed Plan identified several preliminary remedial goals i PRCs) for groundwater
me hiding, EPA Ml 1 s, PIMP GC11 s and risk-based levels, hut tt was not entirely clear in the
document which of these applied to the particular CtXT and how they would be met for an
interim rented) This ROD identifies HHP MCi s i winch are the same or for certain chemicals
more stringent than HPA MCLs in the Safe Water Drinking Act regulationsi and the PDFP
GCTL- sn b'A(' Chapter h2-7^'! 1 able L as chemical-specific ARARs for contaminated
groundwater 1 DI P tiCTf Tabic I incorporates the MCLs from Florida primary drinking water
standards at FA(" < 'hapter f>2-5^0.310 for some of the listed chemicals The more-stringent level
ts identified as the cleanup level foe a particular CDC consistent with the NCP1 and EPA
guidance Since restoration of the groundwater throughout the plume was not part of the
objective of this interim remedy, attainment of identified MCI s ami (iC i"L> is not required
uisder this Kt >D. Instead, the MCLs CiCTls are used for monitoring purposes to assess
effectiveness of (he remedy in preventing further migration of groundwater above these levels, A
final remedial action for the Extended Plume will be documented in a separate ROD that
includes the objective to restore the groundwater throughout the plume to attain MCLr, and
GC f Ls within a reasonable timeframe.

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Petroleum Products Coiponrtion Superfund Site
Record of Decision;
My 2021

The use of the term "Common Alternative" was switched to "Common Element" to clarify thai
these elements will be implemented regardless of which alternatives are chosen,

EPA is currently evaluating its existing policy on human health risks from lead contamination in

soil. Should 1PA change its lead policy, EPA will determine if changes to the cleanup levels for
lead in soil are needed at tits Site. Changes to the lead cleanup levels are not likely to affect the
remedial footprint as the lead contamination is co-located with other COCs,

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Petroleum Products Corporation Superfund Site
Record of Decision
Jily 2021

16,0 References

BBL, 1993. Blasland, Bouck & Lee. Contamination Assessment Report for the Petroleum
Products Corporation Site, Pembroke Park, Florida, June 1993.

Black & Veatch, 2018a, Black & Vcatch Special Projects Corp., Technical Memorandum for the
Petroleum Products Corporation Site, Pembroke Park, Florida, Revision 1. November 2018.

Black & Veatch, 2018b. Black & Veatch Special Projects Corp., Technical Memorandum
Addendum for the Petroleum Products Corporation Site, Pembroke Park, Florida, Revision 0.
December 2018.

Black & Veatch, 2018c. Black & Veatch Special Projects Corp., Treatability Study Variance
Memorandum for the Petroleum Products Corporation Site, Pembroke Park, Florida, Revision 0.
May 2018.

Black & Veatch, 2019. Black & Veatch Special Projects Corp., Feasibility Study Report' for the
Petroleum Products Corporation Site, Pembroke Park, Florida, Rev 3. June 2019.

Bechtel, 1992. Bechtel Environmental, Inc. Supplemental Remedial Investigation Report for the
Petroleum Products Corp Site. Consultant's Report for U.S. EPA, Region IV.

ECT, 2011. Source Removal - Event I, Petroleum Products Corporation Bamboo Mobile Home
Park, January 2011.

EPA, 1987. U.S. Environmental Protection Agency, Interim Guidance on Compliance with
Applicable of Relevant and Appropriate Requirements. July 9, 1987.

EPA. 198Rb. U.S. Environmental Protection Agency, Guidelines for Ground-Water
Classification Under the EPA Ground-Water Protection Strategy. Office of Ground-Water
Protection. June 1988.

EPA, 1990a. U.S. Environmental Protection Agency, Guide to Selecting Superfund Remedial
Actions. Office of Solid Waste and Emergency Response (OSWER) Directive 9355.0-27FS.

April 1988,

EPA. 1990b. U.S. Environmental Protection Agency, A Guide to Delisting ofRCKA Wastes for
Superfund Remedial Responses. Office of Emergency and Remedial Response Hazardous Site
Control Division (9347 3-091-S). September 1990.

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O i'w; ui " >1 t> i iiima'Mn M «,H r is
Hworfi of IVriC

Jiiif iu

EP*\ 19Q2. U> Environmental Protection Agency, Selecting a Combined Response Action
Approach for Noncontiguous CBRCLA Facilities to Expedite Cleanups Fact Sheet t Hike of
Solid Waste and Emergency Response. OSWER Directive No. 9355 J-14FS, April i992.

EPA, il^2s, Cr S. Environmental Protection Agency. Region 4, Baseline Risk Assessment for
the Petroleum Products Corporation Superfund bite, Pembroke Park. Florida. Prepared by
Clement International Corporation, Fairfax. Virginia, Prepared for Bechtel I nvirotmienUiJ, Oak
Ridge, Tennessee June 1 J, 1992,

EPA, W21?. U.S. Environmental Protection Agency, National Oil arid Hazardous Substances
foliation Contingency Plan tNCPK EPA 540-Z-00-001 January 1992

EPA, N93a. U.S. Environmental Protection Agency, Presumptive Remedies: Technology

Selection Guide for Wood 1 renter Sues, OSWER Directive 9?60.0-4hFS PPA 540'l;-9Vo2<>.
April 1993,

EPA, H03b. U.S. Environmental Protect.on Agencj, Presumptive Remedies. Policy and
Procedures, <. )S\\ I R Directive 9355.G-47FS, EPA 54CFF-93/047 (PB 93-9633451 September
1993.

EPA, 1995. V S. Environmental Protection Agenc>, (Page 5-4) Presumptive Remedies for Soil,
Sediments, and Sludges at Wood Trcatcr Sties, OSWER Directive ^209.5- IfO Decernner

PPA H%. V S, Environmental Protection Agency, Promotion of Innovative Technologies in
Waste Management Programs OSWER Policy Directive 93 ! 3 Office of Research and Development, Washington, D C
2003.

EPA, 2009. U.K. Knvironmema! Protection Agencv, Update of the Adult Lead Methodology's
Default Baseline Blood Lead Concentration and Geometric Standaul Deviation Parameters.
OSWER 9200.2**2, Prepared by the Lead Committee of the I ethnical Review Workgroup for

Metals and Asbestos. June 2009.

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Petroleum Products Corporation Superfund Site
Record ofDeeistoti
July 2021

1 PA. 2011. U.S. Environmental Protection Agency, Region 4, final Report for Petroleum
Products Air Study, Pembroke Park, Broward County, Florida, Science and Ecosystem Support
Division Project No. i 1 -0230. April 2011.

il'A, 2015, U.S. Environmental Protection Agency, Region 4, Memorandum, Petroleum
Products Site, Pembroke Park, Florida, From William N. O'Stecn, Environmental Scientist,
Technical Services Section, Superfund Division, Through Glenn Adams. Chief, Technical
Services Section, Superfund Division, To Michael Taylor, Remedial Project Manager, Superfiiiid
Remedial Section P, February 12, 2015.

EPA, 20 P. I' S Environmental Protection Agency, Statement of Work for Remedial
Investigation/Feasibility Study, Petroleum Products Corporation Site (Petroleum Products

Corpora!ion) August 11.2017.

Florida (ieu'logfcal Survey. 1958.

IEUBK, 2010. Integrated Exposure Uptake Biokinetic Model for Lead in Children, Windows®
version (lEUBKwinvi .1 build 11). February 2010, 32-bit version,

Kucper, et at., 2003. Kuepcr, B. H., Wealthall, G. P., Smith, J. W. N.. Lehamc, S. A., and Loner,
D. N. An Illustrated Handbook of DNAPL Transport and Fate in the Subsurface, 2003.

Sikdar and Irvine, 1998, Subhas K. Sikdar and Robert L. Irvine, Bioremediation Principles and

Practice, Volume II, Technomic Publishing, Lancaster, Pennsylvania. 1998; 2:113-219, 1998.

Tetra Tech, 2011 leira Ted FM, Inc., Final Comprehensive Environmental Response,
Compensation, and Liability Act (C ERC'LA) Removal Action Report, Revision 0.0. March 2011

USAGE, 2001. U.S. Army Corps of Engineers, Groundwater flow and Contaminant Transport
Modeling Near the Peeie Dixie Well Field Including Florida Petroleum Eeprocessors Superfund
Site, Ft. Lauderdale and Davie, Broward County, Florida. August 2001,

USACF., 2016a. U.S. Army Corps ofEnginecrs, Final Remedial Investigation Report, Former
Petroleum Products Superfund Site, Pembroke Park, Florida. Januar> 2016.

USACF. 201 Oh U.S. Army Corps of Engineers, Final Supplemental Human Health Risk
Assessment. Former Petroleum Products Superfund Site, Pembroke Park, Horida. January 2016.

i'6

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Petroleum Products Corporation Superfund Site
Record of Decision
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USAGE, 2016c. U.S. Army Corps of Engineers, Draft Final Remedial Alternatives Technical
Screening Memorandum, Former Petroleum Products Superfund Site, Pembroke Park, Florida.
March 2016.

USAGE, 2016d. U.S. Army Corps of Engineers, Draft Feasibility Study, Former Petroleum
Products Superfund Site, Pembroke Park, Florida. June 2016.

USGS, 2004. U.S. Geological Survey, Hydrogeology, Water Quality, and Distribution and
Sources of Salinity in the Floridan Aquifer System, Martin and St. Lucie Counties, Florida.
Water-Resources Investigations Report 03-4242.

Wedderburn, Leslie A., 1982. Hydrogeology of the South Florida Water Management District,
in: Ground Water in Florida, Proceedings of the First Annual Symposium on Florida
Hydrogeology, Northwest Florida Water Management District Public Information Bulletin 82-2.

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Petroleum Products Corporation Superfund Site
Record of Decision
Inly 2021

PART 3: RESPONSIVENESS SUMMARY

The Responsiveness Summary for the Site has been prepared in accordance with the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA),
as amended by the Superfund Amendments and Reauthorization Act (SARA), and the NCP, 40
CFR §300.430(f)(3)(i)(F) and CFR §300.430(f)(5)(iii)(B), The EPA's responses to comments
received on the Proposed Plan during the public comment period are included in Appendix A,

The Proposed Plan for the Site was issued on January 11,2021, On January 19,2021, the EPA
hosted a virtual Proposed Plan meeting via Zoom due to the COVID-19 public health
emergency. Site documents, including the RI Report, FS Report and Proposed Plan for the Site
were made available to the public on January 11,2021, in the Administrative Record
repositories. The Administrative Record repositories are located at the EPA Region 4 Superfund
Records Center (61 Forsyth Street, Atlanta, GA 30303) and the EPA local repository, located at
Broward County Public Library (100 South Andrews Avenue, Fort Lauderdale, Florida). A
Notice of Availability was published in the Sun-Sentinel Newspaper on January 10, 2021. A
public comment period on the Proposed Plan was held from January 11, 2021, to February 19,
2021. The comment period ended on February 19,2021. The EPA's responses to comments are
included in Appendix A. Several questions were asked during the public meeting by the
attendees after the presentation. The EPA's responses to these questions are documented in the
meeting transcript, which is included in Appendix B.

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hUvnrj u( Hc» ision
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Petroleum Products Corporation Supcrfjuti Site
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July 2021

Table 1. Occurrence, Distribution and Selection of COCs in Surface Soil

Expoture

Chemical

Concentration Detected

Units

Frequency

i'xpoiure

Exposure
Point

Statistical

Point

Miniiuutn

Maximum

Point

Concentration

Measure

Concern

Cofteetiteittoii

Concentration

Detection

Concentration

Units

Berafatonthraccnc

0,42 J

21.0

IT.g'kg

2'16

21 ft

mg/kg

Maximum

Btwofaipytrnt*

11.0

rrf \i

I/t2

11 0

mg/kg

Maximum

Surface Soil

Ben/o! sWluoranihcnc

0,46 J

13.0

mglg

3/16

130

mg/kg

Maximum

Otbrwia.lilamtacene

5 li >

5 Ji J

n-gVi

116

5.0

mg/kg

Maximum

lndcnof 1.' cJipyrcnc

<¦) 5

9 5

nig'kg

I/O

9.5

mg/kg

Maximum

PCB
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Petroleum Products Cotporetion Superftrad Site

Hcimi'i' 1 'rciMnn
!n|-, .**»,'1

Table 2. Occurrence, Distribution and Selection of COCs in Subsurface Soil

Ctrnmut

CanceaaitiOfj Detected

Units

FpKpttsf

Exposure

Point

MMmwra

Matin*®

Feu*

Ctm«o6r»lsafk

C*M«»

Concentration

( onccnkjEior.

Detection

Corerritratiort

linils

IHi*I

2 'fi

Subturfitcc Sosl

2,1 J

*11

IT Mi

mgfcg.

Mssifissffi

rCBtAtwHa 1UI41

8.48 j

nigAi

3.J

msfks.

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Petroleum Products Stpoettion Superfinid Site
Record of Decision
July 2021

Table 3. Occurrence, Distribution and Selection ef COC's in Ground water

¦ ¦ • -

&p«»rc

Ch*mx*l

Mtmrnum

OfPt#.

£*po#ute Pomf

Swatietf

PotRl

OKxcntrsJioa

Cufciaa®

¥emi

Cmms&mm
U*te

kte.ee

0.14 J

•I

14 ¦:

*% Aifwtrf CSMM* UCt

d#-1 J-Dk ft iowwtteftc

mS2i

C! J

!««¦, Mi

TrkJilof«}i»f CTCE>

0.21 I

i ^ ¦

mim.

W/, OMbyitev fife* Si) UCL

Groundwater

ViftylChlarul*

tvm

414

Hg*.

«% €!»%»!» (Mm .«> UCL

Without

NaphtfwHene

1,141

150 J

JiflL

J164

s^t.

»S% Owbyttev Weill, Mi UCL

Sludge

4.21

i :m> r

1200

Mtnnwn

KB lAmlm 1242)

on i

27)

|l»'l

mfc

9Wk U wM' !.mr. : i !

r> » ^toelor U«ft

a ii 1

1«'L

nm*

JO 7

m> M» 1.. ;

y^wn > r.u

<: 0 irtvm i

0060} 4 1

Mt'l.

mmmi

fig-'L

Antimony

150

«C

7,1 9

p.grt

95% Id tiumria 1 ¦1 t

Avmnxt

II#

»1-

¦} %

MB*

WH (U|*i iMw. Mi UCL

P#t«

W% CteUj Jiw (Mem, SO UCL

1 _ ..

Vteuhdtwrn

nf j

54#

86.5

S®1-

4J%Cl.e%Ae*fM«BS,,«j

Statistics; Maximum Detected Value (Maximum) or 95% UCL (PrelJCL Vmioa S.i).

Source: Supplemental UHRA (U5ACE. 2016V

(1) Used dtu for cii-iite groundwater monitoring welt

UCL = upper eon Hence limit

jig-1 - enktograms per liter

-------
Petroleum Products Corporation Super-fund Site

Record of Decision
July 2021

-------
Table 4. Risk Characterization Summary - Noii-Carcinogezts (Future Resident)

Petroleum Products Corporation Superfund Site
Rceord of Decision

July 2021

====«

Hi!.!*#!!

point

Cfemieri «f Ctwitr s

loh»t»tkw

Expftiurt Route* T
-------
1 Groundwater not including sludge pies.
HI - hazard index
NE = not evaluated

Petroleum Products Corporation Super-fund Site
Record of Decision
July 2021

-------
Petroleum Products Corporation Superfimd Site
Record of Decision
July ?n?>

Table 5. Risk Characterization Summary - Carcinogens (Future Resident)

Srenario TmuTrsmr Vuiurt
Kffeplor Population: Rraide»T
Receptor A.tJult/t htld (i.ilftimr)

Carcinogenic (Uiks

Medium

Kxpokure Me4lum

ti|H»«urr Point

Chemical of Concern

it?gr&Utiri

tahaUOMi

Dermal

Exposure Routes Total

B®p3(a)srafe#c««

2L -<)5

H' ns

Icn.'i^aipyacnt

[F-A4

Nli

4L-0S

[KIM

h){!uet Athene

I k~»l%

Nf\

:b m

OjIxmhr hJairthraccnc.

55-"IS

Ni-;

'b 05

Surface Sml

Surface Swi

lht>xn ! 3')

r-,-05

NI-

ifc-m

Indent*, t ,pyrct.c

IE-05

PL'B

1L as

is- m

IF-^i

u--m

Surface S»tt Wi^k Total

If'-fM

Soil

Bcruu* O-fitfuactne
U-DihTiiinoetriftr.e 1 F.DB)

i; -n«

NE
NI-

2H-06
Ni'

"MM.

>h m

Thomn . It)

RF-H5

Subsurface Soil Risk Total »

2&CM

Pcnzrno

I ESS

IE-06

11,05

l„4*Diox*nc

imi

5E-oe

2h-0.>

Gmmawmi

CirouniJwsicT

Groundwater1

tr-04

tfc-W

rcn

:r-n4

2 L£- CM

PCB 12M<

«L-U

Rti-fc

rntVtUimrihviL-nj.'

n -04

2K-05

!MH

V -tnl f hronut

4' -*14

2H-05

41>04

Arsenk:

5f-04

2F-0*>

Jt -fH

Groundwater Risk Total«

4L-W

Touii Risk w

5f.-»dudi'i>* sludge pita.
M rut cvo.uaUj

-------
Petroleum Ptwlscts Corporation Supcriund Site
Record of Dec»#»a
July 2021

Table 6. Risk Characterization Summary - N®«-Carcliogens (Future Outdoor Wtrker)

xcBino < )ffltiriD«. ruiort

Ci}mart fowl

Cit«te«S *f €i»«f®

lahtltma

IWtintt

Sutbt* Vxl

Surface Soil

No. | }

&U.1M W III f,.W

Subnofee Sell

Si Sal dvX Ss> i j ' v v

S> j-u r M.I'iM,«i

M J

u J

(t 0304

ttKlkmrnhflam

Groundwstcr

Graunrfwftter

VlwiOM*

BiswnTBQ

Artnxmy

0.02

1 J

A.mnJ<

0 (»ft2

Viimltuiu

0 1

Groundwrt«rHi 1 xal

T«ftl Rftccfttor ill
luunuacfogid! H?

111 80

Ifemtifttagteal III«

Mfte-

ft}

111«

Bcpttic HI •

C VdKHUCullI I'll

ihnmimmml Hi«

».!. - l»- .

For tilt oooupvhoiwi recepter iccuro. mtk »iiw ouhkeor worlir n pnacntcd.»t>K tf cmrnKc to the intoor wcxtM icerwvo

«omwdwW Ml tacMis stiu%e f>tB.

HI - ton! t»i«

NE - no" tmiwtei

-------
Pettolcum Products Corporation Superfund Site
Re«j«J of Deeisktti
My 2021

Table 7 (#10). Risk Characterization Summary - Carcinogens (Future Outdoor Worker)

fepvtete: Ou.rtw u,

!«>!» Afe: Mwli

£*jM#art ISotni 1 Cltimkai *f Cswctft

mfmmmrnmmtlmM

Soil

Sirf»«S»»l

SorfiK* Sell

Norte

! 1

Stirtec Soil Wsl 1'ettlsa-

ttriMttoeSail

Suburb* 5*1

Nooe

Skill Risk T«W»i -

Eksnzcoe

ill,-m

2Mi

1,4-UMtune

m-m

Jfc-M

Grewj4wa6«r

(•roundwatcr

Groundwater1

Dtoxi* TBQ

!(• cl\

JE-M

K*8-1142

! - ti<

1®

IMS

PCB-IHO

:mw

THditomthyleiK

iliH*

21-05

Vinyl OMi

«4»J

Awns

ii :i ¦...{ki:

MMIT

{'jfQuittiwBtcf Misfe 7 Ot*l "

SG-M

TetaifcA- 8E-&4

Nvte*

Gioimdwste"'idi iiociadilii skk^e pis*

MB » set

-------
Petroleum Products Coipanittoti Superftmd Site

i;e> ..rd ,if 11> OMwn

i»;% ?ifi

Tabic 8 (#11), Risk Characterization Summary Non-C arcinogens (Future Tenant, Young Child)

Scenario Timeframe: Ftitare
gKt^isr Afe: Yo»«f CbUtf

Um»t4

Mnthn*

fcqmart Mrfisis

Eapawre Point

Cktfltktl *f Concern

Imffcrti-m

i,Ni»ii.« r fcfn.il

EtpmumU&mtM'Urnl

i*™~——I5:f -tou

OS "*

KI-

(17

Surtax Soil

Surface Soil

MiwiiiTe©

Sutfcci Sail HI

Bczjwvc

i.«

««»-!,i-DkMmertiyJwe

t,«.«#»*

nm:

TiuMaoMlvkM

«•

UrwrfnM

{Mmmitmm

ii-5T ""iK r

on*

S.4

DwuftTEO

Aae.lt

«.(I»T

Vmmitum

§.»

BBS

Groundwater HI Total

I«t«»l ItlMfiftlf HI »

B ^c*»roti«ntv*»in *¦

ImflWMhwalK)*

ifeifh*tfiS4itor III ®

Dtniafmaml Ml •

¦M

itwutapwrw »

OmlsftR -

QritowwHiW

HI =

Ptf®it HI fc

Risk k> young child icntnt presented, n the fr-fc Mina ana ihcrcEGttjroteciivt 0f,ihc other ten**? wetnrau.
s Groundwater not mekriLiagitaite pit#

III *! hazard asfs
Nfi » not cv^ubimj

-------
Petroleum Products Corporation Supcrfuml Silc
Record of Decision
JiiK 202)

-------
Pettoteum Products Corporate m S ipi-riciui \u.-
Rccotd nt 1 K'CImxu
Mt ,'it?)

Table 9 (#12). Risk Ciiracteriziti®! Summary - Cardnogens (future Tenant, Young Child)

Stimrto Tifiitlrtiie tlit w*
lenfbt ft»f Tcsuc

iKfpltf Aft: ¥»1B| €111.1

....

1 Medium

E*|»s»« MmU»«

Hapmrnm Mm

Ctmrital ef Cmmm

*«&**» 1

CtiHnMSwiaiTMttl j

S«ra(*)ud»»iK

"MR ' "

4»

I&«

n, n

2MB

fE-iS I

tv.N '. 'il-U -t

8E-06

K: >»

21-116

lints j

Diie«l»,!»>»»ilil«ae.

N>:

~E-*

Suite Sail

Swl«« $ml

MwudTBQ

Nr:

Ss-<:»v

2£,t5

Sail

feiiowjl,

PCB. t2«
rTBlJM

Nr.'.
Nf

li-W

V-m

I
3
i

:r-'w

* " ~iw ~ ~1

Ki-.

IE4T?

3h-i!b

l,<-S«J«£

5E-04

N£

4I4IT

>J4

(xrcMftdtt'iier

UraadwMtt

Madura?

KB- !2«
PCB-1260

6E4I5

Nr
NB

NE
Nl-

Nf-

4k1-0%

i-»r

1F~>M

i ncnMJroeiityiestc

IE-06

Viny l Chloride

Nih

it-)-*

Arsenic

2R-04

5E-a?

11 'N

ONMMtWMIf MAIM-

TttUlRuk- IB-M

ttiak to yming iMM usumi pnwnted, «i ita n«i U tagtor than, k,™

mi ,^1,1 ta>, i.ua^f.ii.

-------
Petroleum Products Coiporattin SupcrturHi S.ir

Rcctird 01 IX*ums»a
July JMl*

Table 10 (#13), Risk Char ../...ization Summary- Non-Carcinogens (future i instruction Worker)

%c«»r;» limrfnme >ac»r»

fppoliflon: C«ni»tH«#M Wwrktr
RWif»f«r Age A*bH

Medium

E*pow»r« Mttfium

iUpotwr* Point

Cktmfc*! of C»M*ni

J fc«l

I.UI

Surface Soil

fkutfrnx: Sml

Seme

^t*s:

® GwiiB^wwIcf pils

HI-
KE .

¦82

-------
;lioo Superfciitj Site
Record of Decision

July 2021

Table 11 (#14), Risk Characterization Summary - Carcii#gens (Future Construction Worker)

1 —

r-pm i vt«iL..'

CttfMkd afCoKira

« feuiilstfirtf HltKi

Omimt

EtjMMti HgiNn T*M

Sw&cc *iit

SurfiKe S«r.i

Mow J

Swfcw left 111 T«»l

r tl I 1 1

Sut».af»t«S6fliirfoi*i-

1 ,4-1

1MV

1E4W

| CJfOBltlWttt

C««o»iitfw»tsr

(frouftdwattr'

DionijiTBQ

IB*

k:b-i2«

:p (u«

JE«

PCTMHO

h} w,

»:

IE-«t> '

VtaylCiitoMfc

ig-«»

38* |

Anesk

4L- £«*

»e-»

41,*

JE-iS

Total tii =

MMB

Main.

KE*#ole»lii«tat

• n-
-------
Petroleum Products Corporation Superfund Site
Record of Decision
July 2021

Table 12. Cleanup Levels1 for Groundwater

COCs

Units

Cleanup Level
Concentrations

Basis

Benzene

Hg/L

GCTL2

cis-l,2-Dichloroethene

pg/L

GCTL

1,4-Dioxane

pg/L

GCTL

Trichloroetbene

|ig/L

GCTL

Vinyl Chloride

pg/L

GCTL

Naphthalene

pg/L

GCTL

PCB-1242 (Aroclor 1242)

Hg/L

0.5

GCTL

PCB-1260 (Aroclor 1260)

0.5

GCTL

Dioxin TEQ

pg/L

3.00E-05

GCTL

Antimony

Mg/L

GCTL

Arsenic

Pg/L

GCTL

Lead

pg/L

MCL

Vanadium

pg/L

GCTL

Notes: mg/kg = milligrams per kilogram

'Cleanup levels for groundwater used only to measure performance of the interim remedy in preventing further migration of contaminated groundwater.
JTable I of FAC Chapter 62-777, Groundwater and Surface Water CTLs.

-------
Petroleum Products Corporation Superfund Site
Record of Decision
July 2021

Table 13. Cleanup Levels for Surface Soil

roc*

I'nits

Cleanup Level
(Facility Properly)

Basis

Cleanup Level
(Bamboo Mobile Home Park)

Basis

Kenz|a)anthraeene

mg/kg

7.0E+00

SCTLs (Industrial)

1.0E+00

SCTL1
(Residential)

Benzo(a)pyrene

mgykg

7.0E-01

SCTLs (Industrial)

l.OE-01

SCTL
(Residential)

Benzo(b)fluoranthene

mg/kg

1.0E+00

SCTLs (Industrial)

1.0E+00

SCTL
(Residential)

Dlbenz(a,h)anthracene

mg/kg

7.0E-01

SCTLs (Industrial)

1.0E-01

SCTL
(Residential)

Indeno(l J3-cd)
pyrene

mg/kg

7.0E+00

SCTL (Industrial)

l.OE+OO

SCTL
(Residential)

PCB-1016

mg/kg

2.6E+00

SCTL (Industrial)

5.0E-01

SCTL
(Residential)

PCB-1248

mg/kg

2.6E+00

SCTL (Industrial)

5.0E-01

SCTL
(Residential)

PCB-1260

mg/kg

2.6E+00

SCTL (Industrial)

5.0E-01

SCTL
(Residential)

Dioxin TEQ

mg/kg

3.0E-05

SCTL (Industrial)

7.40E-06

Site
Background
Level

Arsenic

mg/kg

1.2E+0I

SCTL (Industrial)

2.1E+00

SCTL
(Residential)

Lead1

mg/kg

1,400

SCTL (Industrial)

400

SCTL
(Residential)

Notes; mg/kg = milligram per kilogram
!FAC Chapter 62-777, Table 2, Soil CTLa.

1 EPA is currently evaluating its existing policy on human health risks fiom lead contamination in soil. Should the lead policy change. EPA will determine if changes to the cleanup levels for lead in soil
are needed at this Site.

-------
Petroleum Products Corporation Supcrfund Site
Record of Decision
My 2021

Table 14. Cleanup Levels for Subsurface Soil

COCs

Units

Cleanup Levels
(Facility Property)

Basis

Cleanup Levels
(Kuinhoo Mobile Home
Park)

Bums

Dribromoetliane

mg/kg

1.2E-01

SCTLs1
(Industrial)

1.0E-01

SCTLs
(Residential)

Benz(a)anthracene

mg/kg

7.00E+00

SCTLs
(Industrial)

1.0E+00

SCTLs
(Residential)

PCB-1016

mg/kg

2.6E+00

SCTLs
(Industrial)

5.0E-01

SCTLs
(Residential)

PCB-1248

mg/kg

2.6E+O0

SCTLs
(industrial)

5.0E-01

SCTLs
(Residential)

PCB-1254

mg/kg

2.6E+00

SCTLs
(Industrial)

5.0E-01

SCTLs
(Residential)

PCB-1260

mg/kg

2.6E+00

SCTLs
(Industrial)

5.0E-01

SCTLs
(Residential)

Dioxin TEQ

mg/kg

3.0E-05

SCTLs
(Industrial)

7.40E-06

Site Background Levels

Lead2

mg/kg

1400

SCTLs
(Industrial)

400

SCTLs
(Residential)

Notes: mg/kg - milligrams per kilogram

'FAC Chapter Reference Table II of62-777, Table 2, Soil CTLs

2 EPA is currently evaluating iu existing policy on human health risks from lead contamination in soil. Should the lead policy change, EPA will determine if changes to the cleanup levels for lead in soil
are needed at this Site.

-------
tV.n an P * .ii.vrv 0*1 l-\

July :((" t

Table 15, Chemical-Specific ARARv

• i:

f lasoJkotMii >~f gUHimlw.tter

* !l s'it< r%i\>ai< t ot iKc su'c u s L:wth\l » Hie rikMiinuicd

\i >0 4JW

> liy >i 1 |>uU)(ni ,v ,ii k> - u 1,1 <)' .v'l'nl -'uluK c >nuiii < t (r\? Knit it-M1. ,n>> »

ti-ll jxn.iHr a.j :i (>,v , ^niUiniu iiur b \»i|-le-un»iLC .ii|ui!iT;«
th« H'i<. ii-Ui! d.sMiUed eet.U'nt t>i kk>i than 1
,\h--(-AiKc okv.itu'd I'v ! Ionia l,n\ irenmeitial Regulation

i kn.nnitt ui r wiiiiw tlx itc

Puiicvium e.f giuuiid* jicr .is »t

P • \\>ihall meet thi minimum
r.l-TU (<>r i'luatiiiw.iik" spe« ificd in F.1C ^2-52»l*MWf 1 H*V(i)

iiMHHiiJViaici wslhirs Stjic «<
Florida wrth dCMcnmed tvnclkiil
. oft l.>\<»| tj» ('tAv*. U-H •
Kflfisnt »I«i \|>|tr«ptUir

fAC 62-S20.400

Miwimm CfiU
ttnuindwalcr

< 1hi> 1 tuul lla.s* ll }(,(\niinJwii!rt '.biii! meet »h«s putsian water
•iiaiuliiuK listed in 1 <\l (..MSO.MO *"m rmHir water tsstcin- e\«n>» ,i\
mherw^prtifiri!

i r \c 4:c>< 11

1 Suudrttds i«r v"liu.s 1 4jn iv .>i-o j (ijujIisY ¦JUindaatv as.
»ci. tciH e»l *! I At i 1>«ptor 'P •"?((>

Sni-;'itt«.\ i»<1! 1 v tot S'te fv-hat'ii.idtion hAC 1 1 ibL 1 im.v

! the dcfjuH nr< . rurc.i

M pp\>i 1 >{ f.ni |i i»Hu

n,i <, h ill »,ne i is ' *u'
*¦5'! »t '» Krtrviiot »ad

Vppmprittf

F SiVC-SNO.jl'i

i'nm.ir, Dnnkmg Wak-i
SJ.piAiWn

l'«-i>t«thiTi i>t ptivondv* ii.i as .1
potential drir.Unj' v>.i>ei so .i«

R»*hahiiit;u!on 'i > «i tiicdi »tn>iii ^

.s'ff |?t',>t«sw!fp%aicf
Hflc* «ni «rti) .%pprn(M«a(i>

t \i>,N"!S0JX!|,'iS
1 lTOi)«ai

I'rMtanon <»: a^awwiti fw>
! sx Iwi gr ih contaminated

A.I sulfite a,»uv's i f «l'f i.aie sJul' at a.l p'an^ and at al! UTivN "x* Ihv

(a > IXnstcstn', iitiliismiil, iti-'ncisllsifftj or other mtitHixiwett ticn-
ilwiiiwl ofdisvl'iMpt v, v,N(h. .ij.'iw tii ii>
i>iwhiiw!tnn vu-'.!-w !(>.< '!" \ Rtltiant and
Xpp/«pri*ir

IV MW( 1 )(a 11 -

»-

Mimnjuin Cnt<*»w Km
Surface Waters

" I'he waft* of the irtenm ,in-«ots ux y,rMMtlv*iiti.'i <)wn not incUulc rvsmuitian io beneficial use » a \lt> iking »ator reswivc llvwcwt, " ¦(

Ny itrnt *Uail attain MCI s !nry.ciii TDEI* Arokmg vtutnt , )itwf in ic mjcct'ois of trcati si (."tiDihlwt.kT |**r iV t Jtuk'fwnmt Intention t 'ont»oi iWhIjuwi-. iJeruts -»i

ns Table 16 as Action Sprcitk ARARs

-------
Pettti.ams ftoducts \ 'orpnraHfm Svpcriuttri Site
Rocottl of fv< isittn
July 2021

nuisance or

2. Float as debris, scum, oil. or other ituUet m such amounts
as to form oi

Product; color, odor t»5>k, tuiWdii), or other axuiiiioii* in

>.tich a degree as to create it ntiisanci*, or

4. Are acutely tow: or

5. Are present us oMketuratiom wnieh are wrciiKH.'.cnk:,
mulngcmr, oi lcraliigcmc to human beings of to

fiymitkant, locally iKVuning, wildlife \>r aquatic j-pectcs
unices sjkxifK' -,t4ndardi *rc established lor such
c«ni|»iiefits »p suhtacction f At" ft2-,Wr.5W>t2) a? Rule S2-
302,5.10. or

^ Pww a -serial ft ih," ;n li'te ik t"H m.;}«
welfare.

Shall not exceed the surface water quality criteria fox the pollutants
!f4tot -it 1 able viittted Surface Water Quality Standard*.

Premier of polluunt in waters of'the
State i-f Kondu as defined in F.S.
Section 40 J 031! n i Relevant and

Appropriate

F'\(" 62-302.5 tct

Surface Water Qua!it\
Cnlerta

Removal of contaminated
>ur:'as-r sutl tV>i
cotmnerml. industrial urn

ScR\«lIe^ default ,St"Tl > for sire rciMhtliuiicn. FAt' 62-,* Tabk II
lists the cleanup l^veb for coin!ticri ial/;rnla,stna) direct exposure,

Rehabilitation 'i c,, i«medt«i\ior>( of

tonum untied site soil and sediment
- Relevant and Appropriate

FAC t>2.-> :~K Table II

sc:i s s

Removal of eortlirmiuieci
iurtace .-tnl for i.-Mdcimal use

Specifies SCO i *oi ;ite rehabilitation. FAC t>2 77*?. Tabk H list* the

cImbujj lew's tor jLihtentuI Jam „>|tohiire.

Rehnhilitatwn , remediation! of
woiiUnuiuted Mis iS.nl and set'iineni

Relevant and Appropriate

FAC fr:-777, Table 11
SCTLs

Prr.ii-ainn itf Mirtiicr water trow
discharge of ireatwl

eoiilninmaieii £ioimdwt|>n.itt'4«\ i\\ HI f tmi!c < HI except for any site spectfk alternative cntera thai httve been evwhltsluid for the watrrbotfy under
Rule fi2-?02.K00, I' A a' Class ill-limited waters are restricted to waters, with luiMm-ittduced phvMcal or habitat cauditnuts that pi event attornment of Clas.s III uses and do not
include wdttibodics itoi weic created for mitigation purposes. "Limited ixvrcJtion" •wjiisi optH>tlunni&> (or jeerealiasi m Hie watei ate reduced due to ph>>ki] conditiopN "I

in or 1Hi and wildlife'' means th«. aquarie biological aimnnmhy does not fully rci» mhU- that t>t a natural y t-nn n the !yj cs, toknnct' and diversity <»l species present.

-------
Petroleum Products Corporation Supcrfund Site
Record of Decision
July 2021

Aclion'Mcdia

Requirement

Prerequisite

Citation

Pollution which causes or contributes to new violations of water
quality standards or to continuation of existing violations is hamiful to
the waters of this State and shall not be allowed. Waters having water
quality below the criteria established for them shall be protected and
enhanced, HoweveT, the Department shall not strive to abate natural
conditions.

FAC 62-302 300(15)

If the Department finds that a new or existing discharge will reduce the
quality of the receiving waters below the classification established for
them or violate any Department rule or standard, it shall refuse to
permit the discharge

NOTE: Per CERCLA § 121 (eX 1). permits are not required for on-
site response action; however, compliance with identified ARARs
(including substantive requirements that otherwise would be
included in a permit) is required.

•

FAC 62-302.300(16)

Protection of surface water from
discharge of treated
contaminated groundwater

All surface waters of the state shall at all places and at all times be free
from:

(b) Domestic, industrial, agricultural or other man-induced non-
thermal components of discharges, which, alone or in
combination with other substances or in combination with other
components of discharges (whether thermal or non-thermal):

7. Settle to form putrescent deposits or otherwise create a
nuisance; or

8. Float as debris, scum, oil, or other matter in such amounts
as to form nuisances; or

9. Produce color, odor, taste, turbidity, or other conditions in
such a degree as to create a nuisance; or

10. Are acutely toxic; or

11. Are present in concentrations which are carcinogenic,
mutagenic, or teratogenic to human beings or to
significant, locally occurring, wildlife or aquatic species,
unless specific standards are established for such
components in subsection FAC 62-302.500(2) or Rule 62-
302.530; or

12. Pose a serious danger to the public health, safety or
welfare.

Presence of pollutant in Waters of
the State of Florida as defined in F.S.
Section 403.031(13)- Relevant and
Appropriate

FAC 62-302.500(1 )(a) 1-
6

Minimum Criteria for
Surface Waters

Shall not exceed the surface water quality criteria for the pollutants
listed in Table entitled Surface Water Quality Criteria for Class Ill-
Limited.2

Presence of pollutant in waters of the
State of Florida as defined in F.S.
Section 403.031(13) - Relevant and

FAC 62-302.530
Surface Water Quality

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Action Mc
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Petroleum Products Corporation Superfund Site
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Table 16. Action-Specific ARARs and To Be Considered Guidance

Action

Requirement

Prerequisite

Citation

General Construction Standard! — All Land-disturbing Activities i

e.g., excavation, clearing, grading)

Control of stomiwater runoff
from soil disturbing
activities

Must comply with the substantive provisions in the "Generic Permit for
Stormwater Discharge from Large and Small Construction Activities,"
document number 62-62 l .300{4)(a), issued by the FDEP and effective
February 17,2009. Requires development of a stomiwater pollution
prevention plan and implementation of best management practices and
erosion and sedimentation controls for stonnwaicr runoff to ensure
protection of the surface waters of the state.

NOTE: Plan would be part of CERCLA document such as Remedial
Design or Remedial Action Work Plan.

Stomiwater discharges from large
and small construction activities to
surface waters of the State as
defined in F.S. Section 403.031 -
Applicable

FAC 62-621.300(4)(a)

Generic Permit for
Stomiwater Discharge from
Large and Small Construction
Activities

Control of stomiwater runoff
from soil disturbing
activities

No discharge from a storm water discharge facility shall cause or
contribute to a violation of water quality standards in waters of the
State.

Construction activity (e.g.,
alteration of land contours or land
clearing) that results in creation of
stoimwater management system as
defined in FAC 62-25.020( 15) -
Applicable

FAC 62-25.025

Regulation of Stormwater
Discharge

Erosion and sediment control best management practices shall be used
as necessary during construction activity to retain sediment on site.
These practices shall be designed by an engineer or other competent
professional experienced in the fields of soil conservation or sediment
control according to specific site conditions and shall be shown or
noted on the plans of the stomiwater management system.

Note: Plan would be part of CERCLA document such as Remedial
Design or Remedial Action Work Plan.

FAC 62-25.025 (7)

Control of Fugitive Dust

No person shall cause, let, permit, suffer or allow the emissions of
unconfined particulate matter from any activity, including vehicular
movement; transportation of materials; construction, alteration,
demolition or wrecking; or industrially related activities such as
loading, unloading, storing or handling; without taking reasonable
precautions to prevent such emissions.

Land disturbing activity that has
potential for unconfined emissions
of particulate matter - Applicable

FAC 62-296.320<4Xc)

General Pollutant Emission
Limiting Standards

-------
'V»i tr'ii,'"ii-d-uU i (ir) itt iiion Si j frtiih.i \i,
Keconl of Deu-uon
IjK *f>2l

ClwuiAateMoLteil^

W! *11 fMntntln* V -n tt»*i ontamc Mill tie substantive

requifetswiits sj>.rii«I 1ft PAC62-532.500(l)(a)*»«§!*()'•'»
appropriate.

i^>S»lUl'in >1 v.,»k-f ho!1 ,i J.lW "
FAC l»2-5J2,2l>»i - RAwnt and
Appraprlalt

FAC 62-512,5C

\Ui! Tifmg, un.'r i'^,

i oup! «^itd ^ Scre^i

%ts «"hul 1» «^»«Ukw«it.»'tuvtthe tuiltiwiiigcriteria;
>lK\>'u\l \k\"h ,» urt|vc-f»*<,.\!,3,it c.^%pr %«.h,*i* hi"f <•> >r>
snlt'ifiijMHm .Vs t\i?i ,iiui tne<"> i;*h? . r(\cHi« itvulttd i" " \C 62-
532.S00(4Xtt>«Mt(^) appiopnau

! 12.500(4)

T^eflicWea

of fptmiMlwstis'' wells

/J. itbJttiluiicU vi ii.b JLtil tv piuiiiieJ, L» filimp ikiac feuia butttm U

?>f -Mt^ nt ,»i ^w.ii j'i -«.i v K*n,«-u;r ,md .Mpjvu wnh i n'ttmi'ini nH

one f- w W «•.« < vrwm «>i» h Aa «Iieiii»ie iiietlioi pfowiiig
L'tj.jiiitli-n; pmwiii.m hiwl< !<« approved by the FP1P «ui the EPA,

62-532.500(5)

la tin* jlumkmmcm .>1 .t w.isc wt-'!, aiumn iJwll be wkcu io ni'nmii*
\ht ptitniiial ctUroiv o <>) cmLmmmu into tie bore hole «nd
groundwater resource.

S2-SJ2.5IMK3)®

Only from a potable water source sh#i •* usrt *n the

fac §2-532smmg)

leiajeetiMi of treeted

ter

x tr

lii|«th»i5 tt! tiejteu
u'tuntn'niui ino
j'Hidr>tUv Jter

K»m>»iu'» or 1 \t«^ print ir\ thinking w .-t^r rctail.tu.in ¦ mdr ~
«. rR Psrt 1!,' si' >i! ft iithc"* m- jtiw»*n\ a»fe,> :!u* health *7 pr*vv

An uiRvitoti ijcii* u\ v.trrru Jiov. tV nunci'wit >t ftui.J u«iSa«n;n'
wy oontamitunt .nit-i aiuk'U'tiiSind vtaic;4vI >i:iitk)ii| *¦ -tn-r, n 'ivf
ffi "-e-'ce N.fth it cunl.tmnwiil "'.»v „ ¦, ',*'uf thf pm\<,r*

1 tit)fif«i<>iiiu1 »i<\ iidti \-»Jo nn

uihlcisv^utul so.uvc of iSrmkmj:
MUi Rfttvanl »n

40 (TR 144 i.'idi

¦tCiCFR (44 "O.iKl'

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Petroleum Products Corporation Supcrfund Site
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Action

Requirement

Prerequisite

Citation

drinking water standards under 40 CFR part 141, other health based
standards, or may otherwise adversely affect the health of persons.

This prohibition applies to well construction, operation, maintenance,
conversion, plugging, closure or any other injection activity.

Abandonment for Class V
wells

Wells must be closed in a manner that complies with the above
prohibition of fluid movement. Also, any soil, gravel, sludge, liquids or
other materials removed from or adjacent to the well must be disposed
or otherwise managed in accordance with substantive applicable
federal, state and local regulations and requirements.

Class V wells [as defined in 40 CFR §
144.6(e)] - Relevant and
Appropriate

40 CFR 144.82(h)

General Criteria for Class V
well used for underground
injection (e.g., re-injection of
treated groundwater)

A well shall be designed and constructed for its intended use, in
accordance with good engineering practices.

Operation of Class V well Group 4
(wells associated with aquifer
remediation projects) - Relevant and
Appropriate

FAC 62-528.605(1)

May not cause or allow fluids to migrate into underground source of
drinking water which may cause a violation of a primary or secondary
drinking water standard contained in FAC Chapter 62-550, or
minimum criteria contained in FAC Rule 62-520.400, or may cause
fluids of significantly differing water quality to migrate between
underground sources of drinking water.

FAC 62-528.605(2)

Construction of Class V well
used for underground
injection (e.g„ re-injection of
treated groundwater)

Shall be constructed so that their intended use does not violate the
water quality standards of FAC Chapter 62-520 at the point of
discharge, except where specifically allowed in subsection 65-
522.300(2), FAC

Operation of Class V well Group 4
(wells associated with aquifer
remediation projects) - Relevant and
Appropriate

FAC 62-528.605(3)

All drilled wells shall, at a minimum, meet the casing and cementing
requirements for water well construction set forth in Chapter 62-532,
FAC

FAC 62-528.605(7)

Operation of Class V well
used for underground
injection (e.g., re-injection of
treated groundwater)

Shall be used or operated in a manner that it does not present a hazard
to an underground source of water.

Operation of Class V well Group 4
(wells associated with aquifer
remediation projects) - Relevant and
Appropriate

FAC 62-528.610(1)

Pretreatment for fluids injected through existing wells shall be
performed if necessary, to ensure the injected fluid does not violate
applicable water quality standards in FAC Chapter 52-520.

FAC 62-528.610(3)

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(Vtruictmi Products t WyK*atirm SupcrtniK! Sif

lit IsUHion

<«b« :i>2\

Monintnap or C" ass V well
used for underground
injection

Plugging and atauidmunetil

of Class V well used for
underground injection

The need lot iij.wiitrtmg shall t*. dcu-imuicd by the type of well, suture
of" miitcrs

NOTE: The monitoring parameters and frequency wiU be -vpecified

in a CfcRCi A document such as a Remedial Work Plan or
Removal Action Work Plant.

Prioi m ahiMittoiung Cia.th V wclk, the well shall be plugged with
cement in a manner that will not allow movement of fluids hei^ccii
underground sources, of water, i'l.iccnwrit of the cement shall be
accomplished by any r«rugnt?eW|? 4
uve'tls .i.s«,<>c uuxi with utjuifei
rmtolMtionpmiLVbl - Reievant iim)
Apprnpriite.

f AC <2- 52H 25(31

expedition ^ntl M()flitofin^ of*

system (e~g.. pimping and
treatment)

A vrmnite air **fwiif wilt not he reooind if the total air etBMStom* froitt

.a ®r ,% wv sz.&w w Stasiw' ^sjfesa.eiR8«pjs.^f8ais^ mm %srt& sU"ih( -.ido not exceed 5.5 pounds

per day for anv single; tM/jriknis au polluted (HAPJ ot ! 3 7 pound* per
iUv for KHa! HAPs

MOTE. Although p«?ao>S not required under C I HO A 12 !(e)t I i for
cm-sue response aeik a*, the specified thresholds arc -c levant to
ipptication ,it oilier >i i vmism ail deviated wells, puvonieiers
and staff gauge iocanonv each time monttonre and rrrnvery wells
arc simipiol (watd-Jcwl nwartuiemcnlt shall he maae within i M-
how period).

• Tout volume t/ tiny free produn rc -oven d m\i tlu tins bt< vs irtd
hort?onla) cucrt of free product

• Total voltim; <»f groundwater rewvered from each recovery well

• Cmtccnlnii tim* of applicable t onUmmant. based on Mulyjei.
performed on the affluent from (lie groundwater treatment system.

• C t«»€ciii»ti(»iw of applicable couiaminants based op un.ilyiies
performed on the untreated groundwater from select recovery
we);s

t At 62-180 mm; s;i)
thsough

f AC «•

^80,700(11 }li)( 1.1(2 Ur.dO>

Operation and Monrtonng of
H«mndwrtlei treatment
system

LVittLTittiauoiis ttf lecovered vdpws fivm a vacuum e.\!iaciu>» syMetn
and po.st tieaioisnt at? emissions if air emissions tre«tmcnt is prwiikd,
must be conducted weekly for the first month, nwnthly for die next two
ftv-nihs and qtiartriis iliercalitr

Op« Jhon (if an attivc leuicdiauoii
system iiitliOTfj ,ic!i>'atoj ovboo
ufF-g*c treatment Rebvwf sad
i Appropritlf

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Petroleum Products Corporation Supcrfund Site
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Action

Requirement

Prerequisite

Citation

Additional sampling may be performed based upon the estimated time
of breakthrough, as follows:

1. Concentrations of recovered vapors from individual wells shall be
determined using an organic vapor analyzer with a flame ionization
detector, or other applicable field detection device to optimize airflow
rate and contaminant recovery.

2. The influent and effluent samples shall be collected using
appropriate air sampling protocols and shall be analyzed using an
analytical method.

3. The samples shall be collected using appropriate air sampling
protocols as specified in FAC 62-160.

NOTE: Monitoring frequency, sampling and analysis methods will
be specified in a CERCLA Remedial Action Work Plan.

Corrective action for leaks
during operation of
groundwater treatment
system (e.g., pumping and
treatment)

If effluent concentrations or air concentrations exceed specified or
prescribed levels or plume migration occurs during remediation system
startup or during operation of the treatment systems, then corrective
actions shall be taken.

Operation of an active remediation
system - Relevant and Appropriate

FAC 62-780.700(13)

Post-active remediation
monitoring for groundwater
treatment system

Unless otherwise provided in a CERCLA Remedial Action Work Plan,

the following shall be performed as follows:

• A minimum of two monitoring wells is required, with at least one
located at the downgradienl edge of the plume; and at least one
located in the areas of highest groundwater contamination or
directly adjacent.

• Designated monitoring wells shall be sampled quarterly for
contaminants that were present.

• Water-level measurements in all designated wells and piezometers
shall be made within 24-hour of initiating each sampling event.

Operation of an active remediation
system - Relevant and Appropriate

FAC 62-780.750(4Ka)
through (c)

General standards for
process vents used in
treatment of VOC-
conlaminated groundwater

Select and meet the requirements under one of the options specified
below:

• Control HAP emissions from the affected process vents according
to the applicable standards specified in §§ 63.7890 through
63.7893.

• Determine for the remediation material treated or managed by the
process vented through the affected process vents that the average
total volatile organic hazardous air pollutant (VOHAP)
concentration, as defined in § 63.7957, of this material is less than
10 parts per million by volume. Determination of VOHAP

Process vents as defined in 40 CFR
63.7957 used in site remediation of
media (e.g„ soil and groundwater)
that could emit HAPs listed in
Table 1 of Subpart GGGGG of Part
63 and vent stream flow exceeds
the rate in 40 CFR 63.7885(cH 1) -
Relevant and Appropriate

40 CFR 63.7885(b)
FAC 62-204.800( 11 )(b)(59)

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Action

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Prerequisite

Citation

concentration will be made using procedures specified in §
63.7943.

• Control HAP emissions from affected process vents subject to
another subpart undo' 40 CFR pert 61 or 40 CFR part 63 in
compliance with the standards specified in the applicable subpart.

Emission limitations for
process vents used in
treatment of VOC-
contaminated groundwater

Meet the requirements under one of the options specified below:

• Reduce from all affected process vents the total emissions of the
HAP to a level less than 1.4 kilograms per hour and 2.8 mg/year
(3.0 pounds per hour and 3.1 tons per year).

• Reduce from all affected process vents the emissions of total
organic compounds (TOCs) (minus methane and ethane) to a level
below 1.4 kilograms per hour and 2.8 mg/year (3.0 pounds per
hour and 3.1 tons per year).

• Reduce from all affected process vents the total emissions of the
HAP by 95% by weight or more; or

• Reduce from all affected process vents the TQC emissions (minus
methane and ethane) by 95% by weight or more.

Process vents as defined in 40 CFR
63.7957 used in site remediation of
media (e.g., soil and groundwater)
that could emit HAPs listed in
Table 1 of Subpart GGGGG of Part
63 and vent stream flow exceeds
the rate in 40 CFR § 63.7885(c)(1)
- Relevant and Appropriate

40 CFR 63.7890(bMlK4)
FAC 62-204.800(1 l)(bK59)

Standards for closed vent
systems and control devices
used in treatment of VOC-
contaminatcd groundwater

For each closed vent system and control device you use to comply with
the requirements above, you must meet the operating limit
requirements and work practice standards in Sec. 63.7925(d) through
(j) that apply to the closed vent system and control device.

NOTE: EPA approval to use alternate work practices under
paragraph (j) in 40 CFR § 63.7925 will be obtained in a CERCLA
document.

Closed vent system and control
devices as defined in 40 CFR
63.7957 that are used to comply
with § 63.7890(b) - Relevant and
Appropriate

40 CFR 63.7890(c)
FAC 62-204.800(1 l)(bX59)

Monitoring of closed vent
systems and control devices
used in treatment of VOC-
contaminated groundwater

Must monitor and inspect the closed vent system and control device
according to the requirements in 40 CFR § 63.7927 that apply to the
affected source.

NOTE: Monitoring program will be developed as part of the
CERCLA process and included in an appropriate CERCLA
document.

Closed vent system and control
devices as defined in 40 CFR
63.7957 that arc used to comply
with § 63.7890(b) - Relevant and
Appropriate

40 CFR 63.7892
FAC62-204.800(ll)(bX59)

Treatment in miscellaneous
treatment units (with air
emissions)

Unit must be located, designed, constructed, operated and maintained,
and closed in a manner that will ensure protection of human health and
the environment.

Treatment of RCRA hazardous
waste in miscellaneous units,
except as provided in 40 CFR
264.1 - Relevant and
Appropriate

40 CFR 264.601

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Action

Requirement

Prerequisite

Citation

Protection of human health and the environment includes, but is not
limited to, prevention of any release that may have adverse effects due
to migration of waste constituents in the air considering the factors
listed in 40 CFR 264.60I(CK 1H?).

40 CFR 264.601(c)

The requirements of RCRA Subpart A, Air Emission Standards for
Process Vents do not apply to process vents that would otherwise be
subject to this subpart when equipped with emission controls and
operated in accordance with an applicable Clean Air Act regulation
codified under 40 CFR Part 60, Part 61 or Part 63.

Process vents associated with the
air or steam stripping operations
that manage hazardous wastes with
organic concentrations of at least
10 parts per million - Relevant
and Appropriate

40 CFR 264.1030(e)

The requirements of RCRA Subpart CC, Air Emission Standards for
Tanks, Surface Impoundments and Containers do not apply to a waste
management unit that is solely used for on-site treatment or storage of
hazardous waste that is placed in the unit as a result of implementing
remedial activities required under RCRA 3004(u) and (v) or 3008(h), or
CERCLA authorities.

Air pollutant emissions with
volatile organics from a hazardous
waste tank, surface impoundment
or container - Relevant and
Appropriate

40 CFR 264.1080(a)(5)

Wastewater Treatment and Discharge— Contaminated Groundwater

Discharge of treated
groundwater to a
Wastewater Facility

An industrial user shall not introduce into a wastewater facility (WWF)
any pollutant which causes pass through or interference.

Discharge pollutants into a
"Wastewater Facility" as defined in
FAC 62-625.200(29) by an
industrial user (i.e., source of
discharge) Applicable

FAC 62-625.400( 1 X»)
Genera] Prohibitions

Discharge of treated
groundwater to a WWF

The following pollutants shall not be introduced into a WWF:

• Pollutants which create a fire or explosion hazard in the WWF.

• Pollutants which will cause corrosive structural damage to the
WWF, but in no case discharges with pH lower than 5.0, unless
the WWF is specifically designed to accommodate such
discharges.

• Solid or viscous pollutants in amounts which will cause
obstruction to the flow in the WWF resulting in interference.

• Any pollutant, including oxygen demanding pollutants, released in
a discharge at a flow rate or pollutant concentration which will
cause interference with the WWF.

• Heat in amounts which will inhibit biological activity in the WWF
resulting in interference, but in no case heat in such quantities that
result in the discharge from the treatment plant having a
temperature that exceeds 40° C (104° F) unless the FDEP, upon

Discharge pollutants into a
"Wastewater Facility" as defined in
FAC 62-625.200(29) by an
industrial user (i.e., source of
discharge) - Applicable

FAC 62-625.400(2KaMh)
Specific Prohibitions

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Action

Require in Mil

Prerequisite

Citation

request of the control authority, approves alternate temperature
limits in accordance with FAC Rule 62-302.520.

• Petroleum oil, nonbiodegradable cutting oil or products of mineral
oil origin in amounts that wil! cause interference or pass through.

• Pollutants which result in the presence of toxic gases, vapors, or
ftimes within the WWF in a quantity that will cause acute worker
health and safety problems.

• Any trucked or hauled pollutants, except at discharge points
designated by the control authority.

Local limits: Where specific prohibitions or limits on pollutants or
pollutant parameters are developed by a public utility in accordance with
FAC 62-625.400(3), such limits shall be deemed to be pre-treatment
standards.

Discharge pollutants into a
"Wastewater Facility" as defined in
FAC 62-625.200(29) by an
industrial user (i.e., source of
discharge) - Applicable

FAC 62-625.400(4)

General duty to mitigate for
discharge

Take all reasonable steps to minimize or prevent any discharge or
sludge use or disposal in violation of effluent standards which has a
reasonable likelihood of adversely affecting human health or the
environment.

Discharge of pollutants to surface
waters of the State - Applicable

40 CFR 122.41(d)

No wastewater facility or activity which discharges wastes into waters
or which will reasonably be expected to be a source of water pollution
shall be operated, constructed, or modified without an appropriate and
valid permit issued by the Department, unless exempted by Department
rule.

FAC 62-620.300(2)
General Prohibitions

NOTE: Per CERCLA § 121 (e)( 1), permits are not required for on-
site response action; however, compliance with identified ARARs
(including substantive requirements that otherwise would be
included in a permit) is required.

No person shall discharge into waters any waste which, by itself or in
combination with the wastes of other sources, reduces the quality of the
receiving waters below the classification established for them.

FAC 62-620.300(4)

Operation and maintenance
of treatment system

Properly operate and maintain all facilities and systems of treatment
and control (and related appurtenances) which are installed or used to
achieve compliance with the effluent standards. Proper operation and
maintenance also includes adequate laboratory controls and appropriate
quality assurance procedures.

Discbarge of pollutants to surface
waters of the State - Applicable

40 CFR 122.41(e)

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Action

Requirement

Prerequisite

Citation

A permitted wastewater facility or activity shall not be operated,
maintained, constructed, expanded, or modified in a manner that is
Inconsistent with the terms of the permit.

NOTE: PerCERCLA § l21(eXl), permits are not required for on-
site response action; however, compliance with identified ARARs
(including substantive requirements that otherwise would be
included in a permit) is required.

FAC 62-620.300(5)

The permittee shall at all times properly operate and maintain the
facility and systems of treatment and control, and related
appurtenances, that are installed and used by the permittee to achieve
compliance with the conditions of this permit. This provision includes
the operation of backup or auxiliary facilities or similar systems when
necessary to maintain or achieve compliance with the conditions of the
permit

FAC 62-620.610(7)
General Conditions for All
Permits

Technology-based treatment
requirements for wastewater
discharge

To the extent that EPA promulgated effluent limitations are
inapplicable, develop on a case-by-case Best Professional Judgment
(BPJ) basis under Section 402(a)(1)(B) of the CWA, technology based
effluent limitations by applying the factors listed in section 125.3(d)
and shall consider:

• The appropriate technology for this category or class of point
sources, based upon all available information; and

• Any unique factors relating to the discharger.

Discharge of pollutants to surface
waters from other than a POTW -
Applicable

40 CFR 125.3(c)(2)
Effluent Limitations

Except for collection system permits under Chapter 62-604, F.A.C.,
each permit shall contain the following permit conditions as applicable:

(a) Technology-based effluent limitations and standards set forth
in Chapters 62-600,62-610,62-611, 62-660,62-670, or 62-
671, F.A.C., or developed under 40 CFR Part 125, subpart A;
(h) Technology-based controls for toxic pollutants which are or
may be discharged at a level greater than the level which can
be achieved by technology-based treatment requirements
appropriate to the permittee or, in the alternative, limitations to
control those or other pollutants that will provide treatment of
the toxic pollutants to the required levels for discharge;

NOTE: Per CERCLA § 12l(eXi), permits are not required for on-
site response action; however, compliance with identified ARARs
(including substantive requirements that otherwise would be
included in a permit) is required

FAC 62-620.620(1 )(a) and (h)

Guidelines for Establishing
Specific Permit Conditions

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Record of Decision
My 2021

Action

Requirement

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Citation

Water quality-based effluent
limits for wastewater
discharge

Must develop water quality based effluent limits that ensure that:

• The level of water quality to be achieved by limits on point
source(s) established under 40 CFR. 122.44(d)( 1 )(vii) is
derived from, and complies with alt applicable water quality
standards; and

• Effluent limits developed to protect narrative or numeric
water quality criteria are consistent with the assumptions and
any available waste load allocation for the discharge prepared
by the State and approved by EPA pursuant to 40 CFR 130.7.

Discharge of pollutants to surface
waters that causes, or has
reasonable potential to cause, or
contributes to an instream
excursion above a narrative or
numeric criteria within a State
water quality standard
Applicable

40 CFR 122.44
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Petroleum Products Corporation Super fund Site
Record of Decision
July 2021

Action

Kequirctncnt

Prerequisite

Citation

Monitoring requirements for
discharges

In addition to 40 CFR 122.48 (a) and (b) and to assure compliance with
effluent limitations requirements to monitor, one must monitor, as
appropriate, according to the substantive requirements provided in 40
CFR 122.44(i)(l)(i) through (iv).

NOTE: Monitoring location and frequency will be conducted in
accordance with CERCLA Remedial Action Work Plan.

Discharge of pollutants to surface
waters Applicable

40 CFR 122.44{iKl)
Monitoring Requirement.'!

40 CFR 122.44(i)(2)

Sampling and monitoring data shall be collected and analyzed in
accordance with Rule 62-4.246, Chapters 62-160 and 62-601, F.A.C.,
and 40 CFR 136, as appropriate.

FAC 62-620.610(18)

General Conditions for All
Permits

Outfalls and discbarge points

All effluent limitations, standards and prohibitions shall be established
for each outfall or discharge point, except as provided under 40 CFR
122.44(k).

40 CFR 122.45(a)

All permit effluent limitations, standards and prohibitions shall be
established for each outfall or discharge point of the permitted facility
or activity, except as otherwise provided under paragraphs (1 Xm),
(l)(p) and (2)(i) of this section and activities permitted under Chapter
62-624, F.A.C.

FAC 62-620.620(2)(a)
Guidelines for Establishing
Specific Permit Conditions

Continuous discharges

Unless impracticable or not applicable under Department rules, all
permit effluent limitations, standards, and prohibitions, other than
permitted capacity, pH, and fecal coliform, shall be stated as:

I. Maximum daily and average monthly discharge limitations
for all industrial wastewater treatment facilities;

Continuous discharge of pollutants
to surface waters - Applicable

FAC 62-620.620(2)(dX 1)

Watte Characterization - Primary Watte (e.g., excavated watte and contaminated toil, purged groundwater) and Secondary Wastes

(e.g., contaminated equipment or treatment rctiduals)

Characterization of solid
waste (all primary and
secondary wastes)

Must determine if solid waste is a hazardous waste using the following
method:

• Should first determine if waste is excluded from regulation under
40 CFR 261.4.

• Must then de termine if waste is listed as a hazardous waste under
subpart D 40 CFR Part 261.

Generation of solid waste as
defined in 40 CFR 261.2 —
Applicable

40 CFR 262.11(») and (b)
FAC 62-730.160

Musi determine whether the waste is (characteristic waste) identified in
subpart C of 40 CFR part 261 by either:

Generation of solid waste which is
not excluded under 40 CFR
261.4(a) - Applicable

40 CFR 262.11(c)
FAC 62-730.160

101

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Action

KiHiuircmciii

Prerequisite

Citation

(1) Testing the waste according to the methods set forth in subpart C
of 40 CFR part 261, or according to an equivalent method approved by
the Administrator under 40 CFR 260.21; or

(2) Applying knowledge of the hazard characteristic of the waste in
light of the materials or the processes used.

Must refer to Parts 261, 262,264,265,266,268, and 273 of Chapter 40
for possible exclusions or restrictions pertaining to management of the
specific waste.

Generation of solid waste which is
determined to be hazardous waste
Applicable

40 CFR 262.11(d)
FAC 62-730.160

Characterization of
hazardous waste (all primary
and secondary wastes)

Must obtain a detailed chemical and physical analysis on a
representative sample of the waste(s), which at a minimum contains all
the information that must be known to treat, store or dispose of the
waste in accordance with pertinent sections of 40 CFR 264 and 268.

Generation of RCRA hazardous
waste for storage, treatment or
disposal - Applicable

40CFR264.13(bXD
FAC 62-730.180(1)

Determinations for
management of hazardous
waste

Must determine each EPA Hazardous Waste Number (waste code)
applicable to the waste in order to determine the applicable treatment
standards under 40 CFR 268 et seq.

NOTE: This determination may be made concurrently with the
hazardous waste determination required in Sec. 262.11 of this
chapter.

Generation of hazardous waste for
storage, treatment or disposal -
Applicable

40 CFR 268.9(a)
FAC 62-730.183

Must determine the underlying hazardous constituents [as defined in 40
CFR 268,2(i)] in the characteristic waste.

Generation of RCRA characteristic
hazardous waste (and is not D001
non -wastewaters treated by
CMBST, RORGS, or POLYM of
Section 268.42 Table 1) for
storage, treatment or disposal -
Applicable

40 CFR 268.9(a)
FAC 62-730.183

Determinations for
management of hazardous
waste

Must determine if the hazardous waste meets the treatment standards in
40 CFR 268,40,268,45, or 268.49 by testing in accordance with
prescribed methods or use of generator knowledge of waste.

Note: This determination can be made concurrently with the hazardous
waste determination required in 40 CFR 262.11.

Generation of hazardous waste for
storage, treatment or disposal -
Applicable

40 CFR 268.7(a)
FAC 62-730.183

Must comply with the special requirements of 40 CFR 268.9 in addition
to any applicable requirements in CFR 268.7.

Generation of waste or soil that
displays a hazardous characteristic
of ignitability, corrosivity,
reactivity, or toxicity for storage,
treatment or disposal Applicable

40 CFR 268.7(a)
FAC 62-730.183

102

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T ,ii n *VJ<\ !«< )ffir it'f\ mp. •turw S 1'

Rcooft! £if Decision

July 2021

Characterization of
remediation wastes

Obtiv.it a detailed chemical and physical analysis of a representative
«&(''|)ic «f the lu/jolmw ict'iciWiiufi mastic to be manatteil *»l liw site
At j mnnmun. the anoiyxis nas! contain all «f the infutnutio/i which
must be known «> treat M-.irr or dispose ot the waste sceotritng to this

Management of remediation wastes
at fatLiiv that does. not have a

RCRA permit Applicable

40 OR « 2MJlj)f2)

Waste Stor age - Prunan- Wmk {e.g., WMvstft? *vxg!« ant! tonUnimsted iofi) sad S«*#uiiary Wastes

(e.g.-, tonuralnitted iqulpmcni or trestBieot rtiidnalxi

femp>trart ri; sit*- storage
vi twfliaojs wa«c w
containers

A generator may nccumuluiti r melons y,«if at the htrt'ity provided
that:

• Waste is placed in cwiiamm fiwt c«riip,y with 40 OK 265,17i
in

Accumulation of RCRA hazardous
waste on site as defined in 40 O R
260,10 Applicable

4ft CFR lulMim:
40 CFR 26? MiaM'l MiK

j • Tht di.t upon which .H-tumiiktion begins is clearly marked and
; wsib»e fm itispcviicm on c&ch container,

1 lie conui'twr is- nin'ked with the vvor«is "te/ttHlmis Mod cundttum

Storage of RCRA hazardous waste
ip containers Applicable

40 CFR 265,171
r yV-Mtt !

Must usf container taaJe or lined with nina-nab compatible with waste
v> He stun J so that thf aMity of flit ;untam« to imtain return' to
lflui 'remove waste,

40 CFR 265,1 ?3(a"i and (b)

Contamrr must n«f lie nixmcd, handled ard stored in a manner that ma\
rupture tfv.» wirtritiii r«; ca.w a to

li .'-2- on l*fl(2i

Storage of hazardous waste
in container area

Area mua have a containment de>

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Petroleum Products Corporation Supcrfund Site
Record of Decision

July 2021

Action

Requirement

Prm-qiiisiit-

Citation

Area must be sloped or otherwise designed and operated to drain liqujd
resulting from precipitation; or

Containers must be elevated or otherwise protected from contact with
accumulated liquid.

Storage of RCRA-hazardous waste
in containers thai do not contain
free liquids (other than F020, F021,
F022, F023, F026 and F027)-
Applicable

40 CFR 264.175(cM 1) and (2)
FAC 62-730.180(1)

Closure of RCRA container
storage unit

At closure, all hazardous waste and hazardous waste residues must be
removed from the containment system. Remaining containers, liners,
bases, and soils containing or contaminated with hazardous waste and
hazardous waste residues must be decontaminated or removed
[Comment: At closure, as throughout the operating period, unless the
owner or operator can demonstrate in accordance with 40 CFR 261.3(d)
of this chapter that the solid waste removed from the containment
system is not a hazardous waste, the owner or operator becomes a
generator of hazardous waste and must manage it in accordance with all
applicable requirements of parts 262 through 266 of this chapter].

Storage of RCRA hazardous waste
in containers in a unit with a
containment system - Applicable

40 CFR 264.178
FAC 62-730.180(1)

Storage and processing of
non-hazardous waste

No person shall store, process or dispose of solid waste except as
authorized at a permitted solid waste management facility or a facility
exempt from permitting under this chapter.

No person shall store, process or dispose of solid waste in a manner or
location that causes air quality standards to be violated or water quality
standards or criteria of receiving waters to be violated.

Management and storage of solid
waste - Applicable

FAC 62 701.300(1 )(a) and (b)

Temporary on-site storage of
remediation waste in staging
pile (e.g.. excavated soils)

Must be located within the contiguous property under the control of the
owner/operator where the wastes are to be managed in the staging pile
originated.

For purposes of this section, storage includes mixing, sizing, blending
or other similar physical operations so long as intended to prepare the
wastes for subsequent management or treatment.

Accumulation of solid non-
flowing hazardous remediation
waste (or remediation waste
otherwise subject to LDRs) as
defined in 40 CFR 260.10 -
Applicable

40 CFR 264.554(a)(1)
FAC 62-730.180(1)

Performance criteria for
staging pile

Staging pile must:

• Facilitate a reliable, effective and protective remedy

• Be designed to prevent or minimize releases of hazardous wastes
and constituents into the environment.

• Minimize or adequately control cross-media transfer as necessary
to protect human health and the environment (e.g., use of liners,
covers, runoff/run-on controls).

Storage of remediation waste in a
staging pile - Applicable

40 CFR 264.554(d)( 1 )(i) and

(ii)

FAC 62- 730.180(1)

104

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Petroleum Products Corporation Superfimd Site
Record of Decision
July 2021

Action

Requirement

Prerequisite

Citation

Operation of a staging pile

Must not operate for more than two years, except when an operating
term extension under 40 CFR 264.554(i) is granted.

Note: Must measure the two-year limit (or other operating term
specified) from first time remediation waste placed in staging pile

Storage of remediation waste in a
staging pile - Applicable

40 CFR 264.554(d)(l)(iii)
FAC 62-730.180(1)

Must not use staging pile longer than the length of time designated by
the GPA in the appropriate decision document.

40 CFR 264.554(h)
FAC 62- 730.180(1)

Extension of up to an additional 180 days beyond the operating- term
limit may be granted provided the continued operation of the staging
pile will not pose a threat to human health and the environment; and is
necessary to ensure timely and efficient implementation of remedial
actions at the facility.

40 CFR 264.554(iKl Hi) and
(»)

FAC 62- 730.180(1)

Management of staging pile

Must not place ignitable or reactive remediation waste in a staging pile
unless the remediation waste has been treated, rendered, or mixed
before placed in the staging pile so that:

• The remediation waste no longer meets the definition of ignitable
or reactive under 40 CFR 261.21 or 40 CFR 261.23; and

• You have complied with 40 CFR §264.17(b); or

• Must manage the remediation waste to protect it from exposure to
any material or condition that may cause it to ignite or react

Storage of ignitable or reactive
remediation waste in staging pile -
Applicable

40 CFR 264.554(e)
FAC 62-730.180(1)

40 CFR 264.554
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Petroleum Products Corporation Supcrtund Site
Record of Decision
July 2021

Action

Requirement

Prmqoitiic

Citation

• Volumes of waste you intend to store in the pile.

• Physical and chemical characteristics of the wastes to be stored in
the unit.

• Potential for releases from the unit.

• Hydrogeoiogical and other relevant environmental conditions at
the facility that may influence the migration of any potential
releases.

• Potential for human and environmental exposure to potential
releases from the unit.

FAC 62-730.180(1)

Closure of staging pile of
remediation waste

Must be closed within 180 days after the operating term by removing or
decontaminating all remediation waste, contaminated containment
system components, and structures and equipment contaminated with
waste and leachate.

Must decontaminate contaminated sub-soils in a manner that the EPA
determines wilt protect human and the environment

Storage of remediation waste in
staging pile in previously
contaminated area - Applicable

40 CFR § 264.554(jXl)and

(2)

FAC 62-730.180(1)

Must be closed within 180 days after the operating term, according to
40 CFR 264.258(a) and 264.111 or 265.258(a) and 265.111.

Storage of remediation waste in
staging pile in uncontaminated area
- Applicable

40 CFR § 264.554(k)
FAC 62-730.180(1)

Waste Treatment and Disposal - Primary Wastes (e.g., excavated sludge, NAPL, contaminated soil) and Secondary Wastes (e.g., contaminated equipment or

treatment residuals)

Disposal of RCRA
hazardous waste in a land-
based unit (e.g., sludge asd
NAPL)

May be land disposed if it meets the requirements in the table
"Treatment Standards for Hazardous Waste" at 40 CFR 268.40 before
land disposal.

Land disposal, as defined in 40
CFR 268.2, of restricted RCRA
waste - Applicable

40 CFR 268.40(a)
FAC 62-730.183

All underlying hazardous constituents (as defined in 40 CFR 268.2(i)]
must meet the UTS, found in 40 CFR 268.48 Table UTS prior to land
disposal.

Land disposal of restricted RCRA
characteristic wastes (D001 -
D043) that are not managed in a
wastewater treatment system that is
regulated under the Clean Water
Act, that is Clean Water Act
equivalent or that is injected into a
Class I nonhazardous injection well
- Applicable

40 CFR 268.40(e)
FAC 62-730.183

Disposal of RCRA
hazardous waste in a Land-
based unit

To determine whether a hazardous waste identified in this section
exceeds the applicable treatment standards of 40 CFR 268,40, the
initial generator must test a sample of the waste extract or the entire
waste, depending on whether the treatment standards are expressed as

Land disposal of RCRA toxicity
characteristic wastes (D004 -
D011) that are newly identified
(i.e., wastes, soil or debris

40 CFR 268.34(1)
FAC 62-730.183

106

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Petroleum Products Corporation Supcrfund Site
Record of Decision
July 2021

Action

Requirement

Prerequisite

Citation

concentration in the waste extract or waste, or the generator may use
knowledge of the waste.

If the waste contains constituents (including underlying hazardous
constituents [UHCs] in the characteristic wastes) in excess of the
applicable UTS levels in 40 CFR 268.48, the waste is prohibited from
land disposal, and all requirements of part 268 are applicable, except as
otherwise specified.

identified by the TCLP but not the
extraction procedure) Applicable

Disposal of RCRA
hazardous waste soil in a
land-based unit

Must be treated according to the alternative treatment standards of 40
CFR 268.49(c) or according to the UTSs specified in 40 CFR 268.48
applicable to the listed and/or characteristic waste contaminating the
soil prior to land disposal.

Land disposal, as defined in 40
CFR 268.2, of restricted hazardous
soils - Applicable

40 CFR | 268.49(b)
FAC 62-730.183

Disposal of RCRA
hazardous waste debris in a
land-based unit (i.e.,
landfill)

Must be treated prior to land disposal as provided in 40 CFR
268.45(a)(l)-(5) unless the EPA determines under 40 CFR 261.3(f)(2)
that the debris no longer contaminated with hazardous waste or the
debris is treated to the waste-specific treatment standard provided in 40
CFR 268.40 for the waste contaminating the debris.

Land disposal, as defined in 40
CFR 268.2, of restricted RCRA
hazardous debris - Applicable

40 CFR § 268.45(a)
FAC 62-730.183

Disposal of treated
hazardous debris

Debris treated by one of the specified extraction or destruction
technologies on Table 1 of 40 CFR 268.45 and which no longer
exhibits a characteristic is not a hazardous waste and need not be
managed in RCRA Subtitle C facility.

Hazardous debris contaminated with listed waste that is treated by
immobilization technology must be managed in a RCRA Subtitle C
facility.

Treated debris contaminated with
RCRA listed or characteristic
waste - Applicable

40 CFR § 268.45(c)
FAC 62-730.183

Disposal of hazardous debris
treatment residues

Except as provided in 268.45(d)(2) and (d)(4), must be separated from
debris by simple physical or mechanical means, and such residues are
subject to the waste-specific treatment standards for the waste
contaminating the debris.

Residue from treatment of
hazardous debris - Applicable

40 CFR § 268.45(d)0)
FAC 62-730.183

Disposal of RCRA
characteristic wastewaters in
a publicly owned treatment
works

Are not prohibited, if wastes are treated for purposes of the
prctreatment requirements of Section 307 of the Clean Water Act,
unless the wastes are subject to a specified method of treatment other
than DEACT in 40 CFR 268.40, or are D003 reactive cyanide.

Land disposal of hazardous
wastewaters that are hazardous
only because they exhibit a
characteristic and are not otherwise
prohibited under 40 CFR 268 -
Applicable

40 CFR 268.49(b)
FAC 62-730.183

107

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Petroleum Products Corporation Superfund Site
Record of Decision
July 2021

Action

Requirement

Prerequisite

Citation

Treated Waste In Place - Cover and Post-Cloiure Care

Florida solid waste landfill
cover design and
construction

For unlined Class I landfills (i.e., unlined landfills containing "Class I
waste"), the barrier layer shall have a permeability of 1 x 10"7
centimeters per second or less. "Class I waste" means solid waste that
is not hazardous waste, and that is not prohibited from disposal in a
lined landfill under FAC Rule 62-701.300. See FAC 62-701.200(13).

Closure of a Class I solid waste
landfill as defined in F.A.C 62-
7O1.340(2)(a) - Relevant and
Appropriate

FAC 62-701,600(3)(g)( 1)

Florida solid waste landfill
deed notice for areas with in-
situ stabilization

Once closure construction has been completed, the landfill owner or
operator shall file a declaration to the public in the deed records in the
office of the county clerk of the county in which the landfill is located.
The declaration shall include a legal description of the property on
which the landfill is located and a site plan specifying the area actually
filled with solid waste. The declaration shall also include a notice that
any future owner or user of the site should consult with the FDEP prior
to planning or initiating any activity involving the disturbance of the
landfill cover, monitoring system or other control structures. A certified
copy of the declaration shall be filed with the FDEP.

Closure of a Class I solid waste
landfill as defined in FAC 62-
701,340(2Xa) - Relevant and
Appropriate

FAC 62-701.600(7)

Florida solid waste landfill
(Vegetation and Grading) for
areas with in-situ
stabilization

The final cover shall be vegetated to control erosion and provide a
moisture infiltration seal, with species that are drought resistant and
have roots that will not penetrate the final cover-

Closure of a Class I solid waste
landfill as defined in FAC 62-
701.340(2)(a) - Relevant and
Appropriate

FAC62-70l.600(3)(f)(2)

Top gradients of final cover on landfill areas shall be graded to
maximize runoff and minimize erosion, considering total fill height and
expected subsidence caused by decomposing waste, and shall be
designed to prevent ponding or low spots.

FAC 62-701.600(3)(f)(3)

Warning signs at hazardous
waste sites

Shall place warning signs pursuant to FAC Chapter 62-730.

Site located in Florida where risk
of exposure to the public exists due
to contaminated soil and sediment
- Relevant and Appropriate

FAC 62-780.220(5)

Waste Transportation -Primary and Secondary Wastes

Transportation of hazardous
waste on site

The generator manifesting requirements of 40 CFR 262.20-262.32(b)
do not apply. Generator or transporter must comply with the
requirements set forth in 40 CFR 263.30 and 263,31 in the event of a
discharge of hazardous waste on a private or public right-of-way.

Transportation of hazardous wastes
on a public or private right-of-way
within or along the border of
contiguous property under the
control of the same person, even if
such contiguous property is divided
by a public or private right-of-way
- Applicable

40 CFR 262.20(f)
FAC 62-730.160

108

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Petroleum Products Corporation Supcrfund Site
Record of Decision
July 2021

Action Requirement Prerequisite Citation

Transportation of hazardous
waste off site

Must comply with the generator standards of Part 262, including 40
CFR 262.20-23 for manifesting. Sect 262.30 for packaging. Sect.
262.31 for labeling. Sect. 262.32 for marking and Sect. 262.33 for
placarding.

Preparation and initiation of
shipment of hazardous waste off
site - Applicable

40 CFR 262.10(h);
FAC 62-730.160

Transportation of hazardous
materials

Shall be subject to and must comply with all applicable provisions of
the Hazardous Materials Transportation Act and Hazardous Materials
Regulations at 49 CFR 171-180 related to marking, labeling,
placarding, packaging and emergency response-

Any person who, under contract
with a department or agency of the
federal government, transports "ill
commerce," or causes to be
transported or shipped, a hazardous
material - Applicable

49 CFR 171.1(c)

Transportation of samples
(i.e., contaminated soils,
sludge and wastewaters)

Are not subject to any requirements of 40 CFR Parts 261 through 268

or 270 when:

• The sample is being transported to a laboratory for the purpose of
testing.

• The sample is being transported back to the sample collector after
testing.

• The sample is being stored by sample collector before transport to
a lab for testing.

Samples of solid waste or a sample
of water, soil for purpose of
conducting testing to determine its
characteristics or composition -
Applicable

40CFR261.4(dXlXiH»i)

FAC 62-730.030

In order to qualify for the exemption in 40 CFR 261.4 (dX 1 X>) and
(ii), a sample collector shipping samples to a laboratory must:

• Comply with U.S. Department of Transportation, U.S. Postal
Service or any other applicable shipping requirements.

• Assure that the information provided in (1) thru (5) of this section
accompanies the sample.

• Package the sample so that it does not leak, spill or vaporize from
its packaging.

40 CFR § 261.4(dX2)

40 CFR §261.4(d)(2) (i«KA)
and (B)

FAC 62-730.030

Notes:

ARAR = applicable or relevant and appropriate requirement

CFR = Code of Federal Regulations

FAC = Florida Administrative Code, chapters as specified

FDEP = Florida Department of Environmental Protection

F.S. = Florida statute

HAP = hazardous ait pollutant

RCRA - Resource Conservation and Recovery Act
TCLP = toxicity characteristic leaching procedure
UHC - underlying hazardous constituent
UTS = universal treatment standard
VOC = volatile organic compound

109

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Petroleum Products Corporation Supcrfund Site
Record of Decision
July 2021

Table 17. Selected Remedy Cost Estimate Summary

Zone

Alternative #

Alternative Name

Cost

Common

COM #1

Bamboo Mobile Home Park Excavation and Relocation

S141K

COM #2

MSA Building Demolition and Relocation of Businesses, Tenants and
Residents

S1.69M

COM #3A

Shallow Soil Excavation Under Buildings

S4.57M

UZ #4 .

In-Situ Stabilization/Solidification with Limited Soil Excavation, and Off-
Facility Disposal

S12.3M

MSA

MSA #3

In-Situ Stabilization/Solidification with LDAs

$11.6M

EP #2

GR&T

S4.1M

Sitewide Costs

(e.g., five-year sampling and reviews, ICs)

S102K

Potential Ancillary Costs

Fair Market Appraisal of Buildings Proposed for Demolition (preliminary estimate)

S9.5M

Tenant Relocation Costs (To be submitted under separate cover)

$13.1M

Estimated Total

$57.1M

110

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FIGURES

11!

-------
Figure 1. Site Location Map

Ortando

Tampa

Pwmbrok# Paifc, FL

. £

iwuu

? fl* >u-

Hmmm

D 100

200

T
Cor* Sprtn

PompMO tVcacH

Fort
Laudntdilf

All

i r )

Pambrofca

Plmt MWI)r«ro»<»

T u

P«roi«um Profloctt
Corporation

0 5 10

1 ' ultl '

• »*»••«> t

\ T1

Boundary j

~U4fe«r- «

025
Miin

Site Location Map
Petroleum Products Corp. Superfund Site
Pembroke Park, Broward County, Florida

Figure
1

112

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Figure 2. Site Layout

Legend

x — xF«nca

Former Tank Farm
I I Surface Extent of PSP
I * 'l Presumed Location of SSP
f/A Formal Lake/Pond (1S69)
™ Site Boundary
I 1 Bamboo Paradise Trailer Park

^ Assigned Building 10

Pvflbrek* Rd

Site Layout Map
Petroleum Products Corp. Superfund Site
Pembroke Park, Broward County, Florida

113

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Figure 3. Historical Site Layout - November 1969

Carolina St

Lagand

I I Sludge Disposal Pit ..

*•—~ Facility demoltshed in 1970

L J Former Lako/Pond (1969) Warehouses constructed 1970 to 1973.
Site Boundary

Historic Site Layout - November 1969
Petroleum Products Corp. Superfund Site
Pembroke Park, Broward County. Florida

N o

80
-f-

160

—I

Fee!

NAOB3 Statu Plan* Ftortds Ea«. Feat

Figure
3

114

-------
Figure 4. General Conceptual Site Model

Pembroke Parte
Warehouses ~TN

Bamboo Paradise
Trailer Park

Main Potential Exposure Routes

® Dermal contact - soils, future groundwater (?)
(D Inhalation

(D Ingestion - soils, product, future groundwater (?)

| Diffused/Dispersed Contamination in Groundwater

Cneb to foundwor rikar
topon to enter fcuMri|

115

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Figure 5. Hallandale, Florida Wellfield, 270-Day Travel

LEGEND
170 Day Travel Time
— -2-foot drawdown contour
Appro#. Scale 1" -1,500"

Hallandale, FL Wellfield, 270 Day Travel
Petroleum Products Corp. Superfund Sfte
Pembroke Park, Broward County, Florida

Figure
5

116

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Figure 6. Conceptual Site Model

Route

Twwi

Indoor Workar

Outdoor ttwfcw

fW-tam

CorafeuoSoftWortoar

CAJTT«ra 1 Futui*

Currant | fumm

Currant J fiAuni

Currwr* I ft*#*

Curnmt I Fukn

Curat* J FiAjt*

fen*

•

Dam* Contact

•

o O

i » i"

iPcttHqr -

°lel°

I O I O I o"T^

| o|o|cj|o|o|o]o|o|o|a|

—M—

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Figure 7. Building Demolition for Common Elements

lUrbpertieSTfKl'J

Legend

Extant of Shidge/NAPt CMZ-1 -
Unsaturated Zone fUZ) 0 to S-ft bt%

Extant or ShJdg»NAPL n CUZ-2 - Mam
Source Zone (MSA) el Ml bit: saturated

Common Aftemabve 2
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HtghKghted to the Extents Shown

Common Attamatrves 3A and 3B
Excavate beta* the aoc buddings
hightfyhted to the extents shown (3A)

Carolina St

Building Demolition for Common Alternatives 2, 3A, and 38

Petroleum Products Corp. Superfund Site
Pembroke Parte. Broward County, Florida

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Figure 8. Recommended Sitewide Remedial Alternative

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> EWM of SiudgmmAPl m CMZ-f -
1 UnMMuraM Zoom {UZ) 0 to Wt bfe

h-rtent a* S]o*y*-HAPL n CMZ-2 -
• U»r Sow re# ?oo» (MSA) m S4I bit.

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APPENDIX A

RESPONSE TO COMMENTS

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PETROLEUM PRODUCTS CORP. SUPERFUND SITE
RESPONSIVENESS SI'MMARY

PREFACE

This Responsiveness Summary addresses comments and questions related to the Proposed Plan

for the Petroleum Products Corp. Superfund site received by EPA during the public comment
period from Jamurs I? to febiuary 19, 2021. EPA received comments and questions on the
Proposed Plan \u email and tetter and during the January 19. 2021 Zoom public meeting. This
document summarizes these questions and comments as well as EPA's responses,

A chronological list of additional EPA interactions with stakeholders regarding the Proponed Plan
follows the comments/questions and EPA responses below. Attachment A provides extended
comments submitted by the 01' t Cooperating Parties Group Attachment B is a copy of the
transcript from the January 20,1' /«*»m public meeting. The transcript includes all of the comments
and questions submitted during the meeting.

SUMMARY OF EMAIL, I.F ITER AND PUBLIC MEETING COMMENTS MADE ON
THE PROPOSE!) PLAN FOR THE PETROLEUM PRODUCTS CORP, SITE3

1, Question: li'lun will you know which buildings will he demolished and whu h timiiup plan
will he twrt/:1

EPA Response: Once we receive all of the comments on the Proposed Plan, we will
compile them aid include them in the Record of Decision, which is the final decision
document. At that point, it will be decided whether the Proposed Plan should be
modified based on the comments that we receive from tie public and the state of Florida,
The Record of Decision will show the structures flat will ultimately be demolished. All
of the evaluation of technologies and treatments includes the five buildings that we
identified. Our approach was to minimize the number of buildings that will lie affected,
and this plan includes the minimal number of buildings affected to accomplish the goals
for the site.

2. Question: How wilt the gun range in the building affect the project'.'

EPA Response: The gun range building is the center of the site, on top of the primary pit
and portions of the secondary sludge pit. ft is the most centrally located budding and has io

3 When known, the names of the pi-.-pte ,u>.| orgamsumum providing cowmen's adunjj qavstsor^ Jttc .n.luded to the
document f.Hieyions asked , sot the chat nmcron Jurmg die JaniMrs -MUI /com public meering a-e not attributed to a

person or ;i!!ilt I P>t M>i iht pub'i: meeting virtually axing Zoom due to t OV!D-l^ concerns

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be removed to access the soil and the sludge pits, which includes the majority of the depth
of soil down to 24 feet underneath the gun range building.

3. Question: Are only buildings south of 19th Street presumed to be removed, and nothing
north of 19th Street?

EPA Response: All of the buildings
that we are looking at for proposed
demolition are south of 19th Street.

There are four buildings on the
Pembroke Park warehouse property and
one building on the Kelsey property at
31st Avenue and Carolina Street, on the
far-right corner. These five buildings
are the ones that fall into the demolition
category. We are proposing that the
yellow buildings (referring to a slide
from the video presentation, shown to
the right) remain and that we excavate
underneath them, since there is much-
shallower contamination there. If it is
found later, even during the design
phase, that there's more extensive or
deeper contamination than what we are
aware of, there will be an evaluation to
determine whether to demolish one of
those buildings or to try and save it. We do not want to demolish any buildings
unnecessarily. Based on where contamination is located and the depth of the contamination,
these five buildings have to be removed to reach the contaminated soil and accomplish all of
the goals for this site.

4. Question: Will the presence of PCBs exclude a Class D landfill as a
disposal option?

EPA Response: PCBs are present and are at very low levels. Once the soil is excavated,
a sample analysis will be performed on the batch soiL Then it will be determined
whether the disposal method will be off site at a Subtitle C or Subtitle D landfill.

5. Question: Do the groundwater impacts extend to the Florida Department of
Transportation (FDOT) right of way on Pembroke Road?

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EPA Response: It extends to Pembroke Road, a
we have identified to the north. The red dashed
line (referring to a slide from the video
presentation, shown to the right) is CMZ 3,
which is the groundwater. This red dashed line
shows what we have identified through our
investigation of groundwater contamination and
the dissolved phase to a depth of 40 feet below
surface. This is located within the yellow
boundary and Pembroke Road is to the north of
the yellow line. After soil treatment and sludge
treatment, there will be more groundwater
investigations or sampling necessary to monitor
if any contaminants migrate at all. Once the soil
and the sludges are disturbed, there may be a
release of contaminants and the groundwater
could carry that contamination toward the well
fields to the east and to the north.

6. Question from Maria Salgado, FDOT: We
have projects working along DOT right of way. As per guidelines from the Florida
Department of Environmental Protection (DEP), we are supposed to look for any
Superfund or other contaminated sites that show up on our GIS layers with a potential
impact on our projects within 500feet if it is a contaminated site or 1,000feet if it is a
Superfund site, and so on. How soon is this activity going to take place so we can keep it
on our radar for our surrounding projects?

EPA Response: The schedule for this project will be updated at the end of the comment
period in February 2021. We will compile all the information from the comments we
receive and prepare a Record of Decision around June or July of this year. After the Record
of Decision is completed, we will conduct negotiations with responsible parties and prepare
a Consent Decree. The design will start after the Consent Decree is lodged. A typical design
will take about 18 months. We estimate that it will take two years from the time the Record
of Decision is signed to starting physical activity. The summer of 2023 is an approximate
date for on-site activities to begin.

7. Question from Evan Goldenberg, White & Case, on behalf of The Kelsey Group: My
client, The Kelsey Group and its affiliates, requests an in-person meeting (or a virtual one
if necessary) to discuss issues unique or specific to it, including traffic, access and
ingress/egress issues. We believe an in-person meeting would be best so the participants
can walk the area in order to best understand the traffic and access concerns. We would
like to have the meeting sufficiently in advance of the February 12, 2021 public comment
deadline so that what we learn from the meeting can inform our comments. Please let us
know if and when the relevant EPA personnel are available for such a meeting.

Soil/Groundwater from 5 to 40-ft his

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EPA Response The details for all remedial actions will be included in the upcoming
renictii.il design once a decision document is approved. The traffic details will depend on
the approved contractor and how they propose addressing site objectives. The remedial
design will lay oat the order of progression for site plans and schedule of events that will be
followed for the selected contractor, All planned act axis will allow adequate lime for
surrounding businesses, local officials, and residents to be familiar with the scheduled
events, Typically, all efforts to present road closures or cause inaccessible roadways are a
lop priority for any site remediated. There may he intermittent periods of the operation that
affect traffic during movement of dump trucks or heavy equipment onto the site. This may
slow traffic or temporarily stop the flow until the equipment is off the road. At this time, 1
do not envision road closures for three of the snrruundine roads, Pembroke Road, Park
Ro.kI and ^ f %t Avenue Carolina Street may experience the most disruption over the course
of the remediation, but I do not anticipate a complete closure If there ti> a need for this
action, it veil! be for a relatively short duration. There can be prov isions for one lane closure
al a time that still allows traffic to flow through the area,

The initial remedial action that involves the removal of buildings through demolition will
cxpei sencc the most active road traffic, The majority of the soil/sludge activity will be
conducted on the property and not affect the surrounding roadways, with the exception of
delivering flic stabilizing agent to be added to the soil. This material is delivered via tractor
mobile home and offloaded into containers as needed, 1 would anticipate that personnel will
be directing traffic on occasion, strictly for safety concerns and this will allow traffic flow
to continue along with the remediation of the sue.

As ,1 lin-sl note, I expect that there will he a website, phone number or location provided for
locals to cheek on site progress and upcoming events in order to keep the public informed,
There will always be a point of contact available to address public concerns and provide site
updates

Comments from Evan Goldenberg, White & Case, on behalf of The Kelsey Group; As
you know this [hm wptVKemt The keisex Group and its affiliated < ompimia, imimimg
/fen ils* IIP <*on I and Park 11st L orp t Pari U " with respect to environmental

issues associated with 'Ac Petn^cum Products Corporation Supvtiuttd Site f "/V'C Site " \
The Kelscv Group Aon and Park 31 herein submit these comments to the Superfnrui
Program Ptopused Plan/or the PPC Sue. dated Jtmujir 2tl2t (the * Proposed Plan "f Am
is the #m tier of the property located at JffUft-JOSO S if. e is! A venue, Pembroke Park,
Florida, u hi eh i.v identified as "Keixei> Propt'rtkw (K2t' on Figure 6 **f tkt Propami Plan
f "AT > Pad M V Park Road, Pembroke
Park, Florida, winch is identified as "Kelset Proper! ie\ (Kt,» on Figure 6 of the Proposed
Plan ("47 Keisei (Pvup affiliates aho own other properties in the immediate vicinity
tru Iudtto* property on the east side of 31st A\enue which are teferred to herein as the
i Wiit Keixey Pmperties

These comments to the Proposed Plan focus on two issues, iji compensation fjr the taking
of Aon and Park Jj property under (he Fifth Amendment < >/" the I ntted States C 'institution

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and'ot Article X, Section b(a' ;? the Fbnda Constitution, and fj; traffic and access issues
associated with She remedial activities discussed in the Proposed Plan.

Takings Under (he f 'mied States and Florida Constitutions

The Fifth Amendment of the £ 'nitcd States Constitution requires jusi compensation whenever
the federal go eminent takes private property far publie me. Article X Section 6{a) similarly
requires lust compensation whenever (he State of Florida takes private property for publu
use There is no exception fat response activities under Comprehensive flnvironmental
Response. Compensation and Liability Act i "CERCL-t "> and nothing in CERCl.A itself
purports to limit the government \ takings liability (nor could id.

While Kcisei Group and EPA representatives have discussed CFRClA liability tissoeiated
with anticipated response actions at the PPC Site for many years, the Proposed Pirn is
largely silent on ike issue, The Proposed Plan proposes to demolish structures on the K2
property, which dearie constitutes a ph\sicai taking for which compensation is requited.
The Proposed Plan also proposes soil removal beneath the A / property thai will eltminait
any economically viable use of that property for an extended period of time, which also
constitutes a compensable temporary taking, Thi ex tens oe remediation activities proposed
for the K2property will aim constitute an ewnded physical invasion oj (he K2 proper!} thai
Mill a (so deprive Aon of any economically viable me of its property jo? a significant periinl
of time

In (he discussion of Common Alternative' ft 2 on page 24, the Proposed Plan notes thai 'jaj
Fair Market Value iFMf) appraisal <>f the five buildings was completed in mid-20J9 and
determined the value of the buildings to be estimated at ,W M/ " hut this $9,5 million figure
is not included in the "Estimated i"mas foe Common Alternatives " on page 25, mhich hus a
"AW I'usetif Value for Alternative #2 ofjust $1 ,W0.90(1,00 The S9J million figure far
"Fair Market Appraisal of building* proposed for demolition f "Preluntnan Estimate"} is
included in the estimated costs of Recommended Alternatives on page J of the Proposed
Plan, which is an appropriate acknowledgment of the need to provide just compensation to
Aim for the taking of the buildings themseh es.

While we are pleased to see recognition if the need to provide t tmpematumfor the physical
destruction of the buildings, the estimated costs for Common Alternative #2 also appear to
ignore the government's obligation to provide compensation, ir: addition to ine i usts of the
buildings themselves, for the physical occupation if the K2 property >hr what *i!l elaoiv he

an extended period of time, A physical taking doe^ not require a showing thai a deprives the
owner ef all, or substantially ail, i< .momically viable use at the property during the
temporary taking, but it is clear thai (he proposed sue activities on the K2 property will leave
Aon with no economically viable use of the proper!} while siie ai tivities are ongoing. The
costs associated with compensotton /<;» such temporary faking should have been included in
the Proposed Plan and must he included w the ROD, This also true of Common
Alternatives tiJA, which will nor only cause a physical in\avion of the Ki pntpem but also
seems hkelv to eliminate any economically viable use of the property for an extended period

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of time. Relocation of tenants under the Uniform Relocation Act, 42 U.S.C. $$460] et seq.,
may not be sufficient.

Traffic and Access

The Proposed Plan does not meaningfully address potential access and traffic issues. It
seems highly likely that the proposed remedial activities will affect ingress and egress in and
around the PPC Site. Access restrictions associated with activities in the Main Source Area
f "MSA ") may affect access by The Kelsey Group, its tenants and their clients/customers at
the Kl property, and vice-versa. In addition, all activities may affect access and traffic with
respect to the Other Kelsey Properties, which include the properties located at 1798-2101
SJV. 31st Avenue. Pembroke Park, Florida, on the east side of 31st Avenue. Approximately
58 tenants run their businesses in approximately 275,000 square feet of warehouses. Their
ingress and egress are from SW 31st Avenue and Carolina Street. Any activity that
diminishes access to those roads will disrupt and negatively impact these businesses, which
bear no blame for the contamination at the PPC Site. Closure and demolition of all or most
of Carolina Street would similarly create transportation problems, as well as potential noise
and air quality impacts thai could make the neighboring residential community
uninhabitable. Traffic and transportation impacts on Pembroke Road, South Park Road and
Hallandale Beach Boulevard and could create hazards at railroad crossings and with
respect to first respondcrs' ability to respond to emergencies in the area. There is a risk that
site activities could constructively shut down businesses that are outside the site boundaries
due to inability to receive materials, ship/deliver products or get customers in and out of the
area safely.

While the Proposed Plan does not address these issues, you responded to our inquiry on
these issues in the email from you dated February 2, 2021, which is attached hereto as
Exhibit A and which should he included in the Administrative Record. We reiterate our
request for an in -person meeting in the vicinity of the PPC Site to discuss these issues to
ensure that they are properly accounted for and addressed in the remedial design.

EPA Response: EPA is aware that the preferred remedial alternative for the Kcisey southeast
property, K2, involves demolition of the warehouse structure arid that an appraisal which
attempts to address the fair market value (FMV) of that structure, which includes its revenue
generating capacity, has been developed. CERCLA remedial response (i.e., cleanup) work is
also needed on the Kelsey southwest property, Kl, due to both historical PPC Site activities
and business activities conducted by Kelsey or its tenants during Kelsey's ownership.
However, business interruptions for cleanup work on property owned by a CERCLA PRP
absent a defense to liability typically do not involve compensation from EPA.

During remedial design and settlement discussions with the other Site PRPs, the FMV of the
K2 property will be discussed further. Updating the 2019 appraisal or conducting a new
appraisal for the K2 property with input from EPA, FDEP and the other PRPs is likely.
Further discussions on damages, costs or other financial impacts to the Kcisey properties and
tenants will also need to occur. Some of those issues are directly addressed by EPA's
CERCLA authorities, while others are potentially the responsibility of the Kelsey entities
and the other businesses as site PRPs for both the Kl arid K2 properties.

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( omnjents from Franklin Zcniel, Saul Ewing Arnstein & Lehr LLP on behalf of
Pembroke Park Warehouses; ihe Trustees Owner i *
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been discussed, some of the expected financial impacts from the upcoming site work, such as
demolition, relocation and the fair market value of the warehouses, can be addressed by
CERCLA legal authorities. Other economic losses cannot but would be the collective
responsibility of the site PIPs to compensate the Trustees/Owners where appropriate and
legally required based on individual PRJP-allocaled shares.

10. Question: What was the outcome of the air sparging system that was on
site and is now demolished?

EPA Response: That system was in operation from the cmrty-to-inid 1990s. This system
was later replaced by the bioslorping system in the late 1990s. The initial system
collected about 3,000 gallons of oil. It was replaced will a more efficient system, the
biostorper system that was put into use after Iff?, The bioslurpiag system collected
about 40,000 gallons of oil by late 2012. The State of Florida removed the bioslurper
system in 2(119, and it is no longer on the properly. All of the old equipment has been
removed.

11. Question fr#m Josh Buchheit, Envirocon: What type of water system., or what do you
think the water treatment would be for the discharge criteria and overall treatment of it?

EPA Response: The groundwater treatment is an interim action that we are proposing. Once
the soil and sludge work are complete there will be about 18 months before the interim
groundwater action will begin. The groundwater treatment will involve a multi-treatment

system, Since we have different types of contaminants of concent with metals, chlorinated
compounds and PCBs, one single treatment type will not address all of these contaminants.
The interim action is proposing approximately six wells across the property. It will include
an oil/water separator, a filtration system, a pH adjustment and an infiltration gallery. Once
we treat the groundwater, the plan will be to reinject it on the west side of the property,
which is the preferred method. If we are not able to install an infiltration system, then the
alternative will be to consider the local publicly owned treatment works or the nearby
surface water retention area to the west.

Question: /.* the n\i-lined area preferring to a slide from the video presentation that is
included below) mst being monitored after the excavation? Afy building is in the top left of
iInn area.

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EPA Response: Once the soil and sludge are
addressed, several monitoring wells that we
currently have in position will be removed or
destroyed, because of the soil remediation and
the depth that we must reach in some areas.

New wells will be installed in affected areas.

We will be monitoring the existing wells in
addition to installing new wells to get a
baseline on conditions after the treatment of the
soil and sludge. Everyone in the vicinity of the
site receives groundwater through city sources
or county water, and EPA is not aware of wells
that are pumping groundwater currently. We
have conducted well surveys in the area, and no
one is pumping groundwater for any potable
source. This site has been designated as a
delineated area, so it requires permits from the
State to install any type of wells.

12. Comment from Genifer Tarkowski, U.S.

Department of the Navy: The plan to stabilize soils in-situ is a good solution to achieving
RAOs. One concern is related to stabilized soil that is in contact with groundwater that
contains chemicals that could act as a solvent for contaminants in the stabilized material.
Nonpolar compounds could mobilize dioxins and other COCs after long-term contact.
Recommend running TCLP analysis on in-situ stabilized material using a modified
procedure that more closely approximates groundwater conditions to evaluate that
potential before moving to full scale treatment.

EPA Response: Page 4-13 of the Feasibility Study Revision 3 includes the following
language: "At this time, based on the preliminary results of the treatability study, and
following confirmation from SPLP testing, Black and Veatch recommends mixtures 12 and
13 for use in the CMZ-2 zones." The CMZ-2 zones are the sludge pit materials and associated
soil below the water table that would be left in place as solidified/stabilized material. The
various SPLP mixtures evaluated in treatability testing for compressive strength and
hydraulic conductivity will be tested for SPLP during the remedial design and remedial
action to make a final mix selection for application to CMZ-2 soils and sludges.

13. Question: Will the schedule be coming out through this PowerPoint (referring to the
video presentation)? Will it have the schedule you are talking about so that we can
download it and keep it in our files for later?

Soil/Groundwater from 5 to 40-ft

EPA Response: The best way to keep up with site information is through our site web page.
You can also contact remedial project manager (RPM) Marcia Nale for site scheduling.
Information will be posted with periodic updates on our web page. We also post the

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initiation of site activities in the local newspapers and through the mail list we have on file.
The site presentation is available on YouTube.

14. Question from Robert Stover, Action Environmental; Thank you for all of your work
on this site» Has the EPA selected am engineer/designer for this site?

EPA Response: The contractor for the remedial design and remedial action will be selected
later in the Superfund process. EPA is currently in the comment period for the Proposed
Plan, The next phase of the process will be for a final decision document, which is the
Record of Decision. Once a Record of Decision is signed, fcPA will negotiate a Consent
Decree with the responsible parties at the site. After the Consent Decree is finalized, the
contractor for the remedial design will be selected. I anticipate this will occur in late 2021.
Feel free to check with HPA's Petroleum Products Corp. web page or RPM Mareia Nale on
future developments.

15, Question from Scheril Murray Powell, Douitiar, AHsworth, Laystrom, Voigt, Wachs,
Adair & Dishowitz, LLC/Green Sustainable Strong, LLC: Thank you so much for the
presentation earlier today. / appreciate your team taking the time to review the plan. I
was hoping that I could speak with you about potentially planting hemp on the site post-
excavation so thai we cam use the hemp to remediate the soil Hemp was used after
Chernobyl in the Soviet Union to remediate the soiL I am an Agricultural Attorney, but I
am also a Florida-licensed hemp farmer doing research cultivation with the University of
Florida. I would love to have a discussion about using hemp for soil remediation as a
final phase of the cleanup project If you are open to this possibility, I will engage the
University team of researchers to assist with the planning. J am attaching my bio for your
review. 1 am a Broward County resident and 1 am a close drive to the restoration site. I
am copying my business partner William Rennalls on this email, he is a soil and water
management expert.

EPA Response: Thank you for your response in reference to the Proposed Plan for the
Petroleum Products Corporation site. EPA has evaluated numerous treatment technologies
during the remedial investigation and feasibility study. Multiple factors are considered in
narrowing the proposed treatment options.

Primary and supplemental remedial treatment technologies were eliminated if they did not
satisfy the RAOs for the evaluated media, were inappropriate for the site-specific
contaminants of concern, were untenable for the given lithology, presented an unacceptable
Impact on the community or were cost prohibitive.

In-situ bioremediation can be effective for treating many of the petroleum contaminants in
the dissolved phase, but would not be effective for specific VOCs, some SVOCs, some
metals and many other COCs, such as PCBs and 1,4 dioxane.

The process you are referring to is phytoremediation. Phvtoremediation is a bioremediation
process that employs a variety of plants to eliminate, extract or degrade contaminants in the
soil and groundwater. Bioremediation was considered and eliminated during the screening

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process. This approach may address some of tie contaminants identified from low level
concentrations for some metals but may not be effective for all contaminants.

In addition, there are several factors that las rendered this type of treatment unacceptable.
The depths of contamination extend into the aquifer to depths of 24 feet below surface, The
root system for hemp typically extends to 1.5 to 3 feet deep. Even if effective, most of the
contaminated media would not be addressed. In addition, there are some areas of soil
contamination that may be considered a RCRA characteristic faazardotis waste due to
toxicity, If there is a RCRA waste, this material will require off-site disposal at a Subtitle C
landfill. Also, there are soil and sludge pockets of low pH levels that may greatly hamper
any biotreatment remediation.

The RAOs are to reduce and prevent exposures to soil and groundwater contamination. A
biotreatment remedy would not accomplish the RAOs identified for this site, further
migration of contaminants would continue to migrate into the Biscayrie Aquifer and further
degrade a federally designated drinking water source.

The timeframe to conduct a biotreatment action is another consideration that does not meet
the site objectives. A biotreatiiieit process would typically take a much longer period to
remediate the site than better alternatives. "His Superfine! site is zoned as a
commercial/industrial area by the Town of Pembroke Park and Broward Comity. The
current property owners have expressed a desire to quickly redevelop their property upon
completion of any final remediation. An extended biotreatment process would delay the
property owners using their property for their livelihoods.

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USE T "RITE YOUR COMMENTS

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EPA Response: Thank you for reaching out to us about your concerns about relocation
related to the Petroleum Products Corporation Supertund xtle in Halfandaie. Florida. This
letter is written in response to let you know that relocation will not be necessary for you,

The Frequently Asked Question Fact Sheet and Proposed Plan Fact Sheet provided an
outreach opportunity to inform the surrounding community about the activities that will he
taking place at the site. Residents in the community who will he affected by relocation have

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already been informed and are aware that these activities will not take place for 18 months
or more.

We upologi/e for the miscommunication of information provided and assure you ihai we
only wanted to inform you of activities at the Site near your home More information will
be provided in the future. If yon have any questions or concerns, please call RPM Mara a
Male at 404-^1-8442 or public affairs f»pecialisi LTonya Spencct-Harvey at 404-56--

S463.

17, C omnwits from the OL'l Cooperating Parties Group imeiudcd as Attachment A)
EPA Response: For Comment I from Attachment A.

During F.PA's development of the PPC Proposed Plan, EPA has had discussions with FDRP
about its past and future financial obligations to pay for the cleanup of releases from petroleum
storage systems that are covered by the terms of the FDKP Early Detection Initiative (HDD
and inland Protection Trust Fund program. The PPC Site applied to and was accepted into
this stale petroleum cleanup program back, in the late 1980s. For planning purposes. 1 DhP's
ongoing funding responsibilities and how it plans to identify .and select environmental
remediation contractors for the PPC remedy, along v*.ith 1 PA oversight, have been discussed
on several occasions in the past two years. EPA understands thai state law governs '.lie
administration of the EDI program and its source of funding Further. PDEP acknowledges
the importance of its funding lo the negotiations of 4 settlement for the implementation of the
PPC Site remedial design and remedial action response activities, EPA believes that FIH P
will use its flexibility and discretion to accommodate HP A\ basic CERCLA requirements for
the selection and approval of contractors and. the effective oversight of the implementation of
the required Site response work.

EPA Response: l or Comment 2 from Attachment A.

In order to effectively evaluate the proposed remedial alternatives, the CERCLA response
activities and their associated response costs must be identified and quantified to determine
the total estimated cost of each remedy option, CERCLA response costs can be incurred hy
both EPA and the site PRPs. EPA believes that the cost components outlined is the Proposed
Plan for all the remedial alternatives under consideration identify and quantify the main
CPKCL A response costs for each remedy proposal. EPA understands that the characterization
and appraisal of the FMV of the warehouses proposed lo he demolished is an issue that is
significant to the Site PRPs and EPA will work with the panics during settlement discussion
to resolve any outstanding concerns on this topic.

EPA Response: For Comment 3 from Attachment A.

The comment specifically points to the assessment of chromium and of acetone in the 2016
Human Health Risk Assessment (IIIIRA). This 2016 HHRA was setwaJly written as a
Supplement to the 1992 site-specific Baseline Risk Assessment The HHRA Supplement used
all data available at the time and closely followed relevant EPA guidance and policy for site
IDlRAs (EPA 1^0, 2010>. As stated m the comment, "Hexmalent chromium was never
analyzed tn connection with the HHRA." When data are available only fcr total chromium.

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EPA region 4 policy has long been to assume that all of the detected chromium is in the
hcxavalent (more toxic i form. The intent is mil to make any final remedial decisions based on
unacceptable health nsks estimated from this approach, tail rather to follow up the UHRA
with chromium speciation analysis. Following the 20161II IRA, chromium specianon analysis
was indeed performed, and based on ihe reported hexavalcnt chromium concentrations, the
risks were re-calculated. Based on the re-calculated risks, chromium was determined to no
longer be a COC in soil based on direct human contact, Chromium is still a COi m
groundwater as the health-ba>cd drinksng water MCI. 1100 ug Li is for total chromium, the
site groundwater concentrations of total chromium, as of -Olo, ranged from 0 I ? to 1 10,000
jig'I, and the exposure point concentration f KPC) derived for site groundwater was ^24
fig'1. (calculated statistical Upper Confidence Limit on the mean fiCL ji

Regarding acetone tn groundwater, I PA used the data availubte at the time of the 20 lo
HHKA I he maximum acetone detection of 17.000,000 jigl was determined to be a valid
concentration based on 'validated laboratory data. Bused, on the entire Uataset for acetone in
aroundwaiet, an UPC |l»CL> of M-7 S jug/t was calculated for estimating risks in the
IIIIR V This I PC tesulted in high hazard quotient tilOt \ uluc.> for all relevant receptor?,
hollowing the 2tit6 IliiR V however, I PA gathered additional groundwater data and
detenntued that the extremely high acetone level was not seen prior to or since the July 2011
sample result. Therefore, EPA has tetitaii\t*!> removed acetone as a COC in groundwater.

liven after the HHRA risk characterization is revised regarding acetone and chromium, there
are other C< it's that pose unacceptable risks (carcinogenic and iionearemogenic). When
chromium is removed from the risk characterization table, the carcinogenic risk to a future
resident assumed to be drinking the groundwater is 4 t 10 \ exceeding the FFA target risk
range of 10* to 10 4 The COCs contributing significantly to this carcinogenic risk include
trichloroethylene, dioxin, arsenic, benzene, ! ,4-dioxane, vinyl chloride and PCBs Likewise,
even without chromium or acetone, the noncareinogenic ha/ard index (HI) for this receptor is
above L even when appropriately segregated by target organ. The C< )C> contributing
significant!) to the noncarcmogeme HI include tnehloroethylene, dioxm, arsenic, antimony
The gtoundwater levels. of lead are also significant relative to heaith risks. The maximum
level of 4,SOft jig'l and the as erage concentration of 270 jig't are well abov e the drinking
water action level of I * »ig I. |EPA 20 IK).

HPA rveogni/es that the siw-.-tpecific health risks from direct contact with soil are lower than
the risks from assumed use oi the groundwater as a drink trig water source. Once unacceptable
risks are determined fbi a given receptor, however, 1 PA policy is to include as COCs all
contaminants (In all exposure media) that contribute a carcinogenic risk of at least 10 *\ or a
HQ of at least 0 1. The COCs can he fun her refined \ ts discussed in the site's Proposed Plan)
based on factors such u,s the frequency of detections exceeding selected risk-based level.-, or
cxccedances of ARARs s,c.g.. Honda CT1.A

The comment also slates that " .institutional controls, an asphalt parking lot, and the current
?oittng regulations are more than sufficient to prevent the hypothetical tenant-young child

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from exposure to any Chemical of Concern at the site in the future." EPA sr. strictly forbidden
by the NCP (Super fund regulations) to assume m a baseline risk assessment thai any
institutional controls, including current zoning regulations, will he in place in the future (KPA-
FR H
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the Proposed Plan to Mr, Velsx and answered any concerns 1- PA provided the public Zoom
meeting invite to Mr. Veliz.

On January 19, 2021, 1-PA received an email from Seheril Murray Powell inquiring about a
potential remediation approach for hemp plants, a biorcmediation treatment. KPM Taylor
prepared a response,

On January 20, 2021. Mike Miller of do maximis, inc. requested that the public meeting
presentation be sent to him.

On January 20, 2021, Robert Stover submitted an email inquiry soliciting business for
Action Environmental of Tampa, Florida, The inquiry was regarding the selection of a
contractor for the site remediation.

On February 2, 2021, EPA 1PM Taylor responded to Kelsey Group representative Evan
Goldenberg regarding the concern for road closures and traffic issues that might impede
surrounding businesses during a remedial action. RPM Taylor responded via an email.

On February 2, 2021, EPA and FDEP held a conference call with de maximis, inc. to
discuss technical issues regarding the site remediation.

On February 2, 2021, EPA and the Pembroke Park Warehouse owner's representative.
Franklin Zand ct. al. held a conference call to provide a site status and next steps
discussion for the site.

On February 3,2021» EPA and de maximis, inc. held a second call that included an EPA
hydrogeologist to discuss the proposed groundwater interim action.

On February 10, 2021, U.S. Department of Justice attorney Debra Carfora, who represents
the I! S Department of Defense, provided an email to EPA Attorney Rudy Tandsijevich

slating that the U.S. Navy will submit comments on the Proposed Plan before the closing
date.

On February 11,2021, EPA RPM Taylor received an email from Cooperating Parly Group
representative John Barkett, who is representing a group of OUl selling PRPs with
comments/questions on the Proposed Plan, A follow-up email from John Barkett requested a
"recall" of the email and requested the deletion of the email A revised set of comments will
be provided on February 12, 2021, per Mr, Barkett,

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ATTACHMENT A: COMMENTS SUBMITTED BY THE OU1 COOPERATING
PARTIES GROUP

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BARNES ÞBURGar

E t-bnijirv S1, 2021

Via E Mail

Mn hjct T»\lor, Msirtu NstJe
I'S EPA

MipcttiUHl & hnicrgi*T)L\ MarutJcwait l^-vwk.n
61 Kwr*>\U) S'.tB ftunrrfafri *ttf »»' I>n

I .tear V>' I nvi't .and N.\te

On behalf <.»( a poup of (HXcimaih resfonMbu1 gcBcip»»> i! Plat iti.-v,
ctwmrwnls are m.ulc }•,) protect these parwes' interests in the event thai tPV* ncgiiUdttoiv; wrth the
liUgt si jc.mut >i pttciuialh resfwiMbk $tart\. 'h« I'lSteJ Stales |tk" K«,;n ¦». A\i i*on\\ Cuast
inurd. ind iVtcruf ftcittik»nti«tn & KfaAn'iinjj rcpics^i'tinr, of the gcik-ut»tr

«mw »i fails to prmtu.-c a Consent Ooetre i>> *hrh these {whrn iart (>nn

Comment Nik 1

We ffce Florida I tepartmsnf n I mwiipKfrtal Protect it m * O'HKF) umtuntttij*,

ttwoK uncut arid eiTorts k' execute ;i» under Sue iaw *,»» Jv\ut-up the Nit'. "Itie

pcti"l\'(»MUi|Mi.k*4l svils. and peit» u.- Jk- Mibhiif),w\ jl. (he R>t«. msullwg frcw refcaii 'rooi
jv'roloiiun i«ior4<« h.i ll*e bhvslurjvr remedy 'Mat wm port ot t Jpersbb I ins! N * I at the Nile *.Vv-u pic#!
dalciHitaalMi w >to tfcsnr to iiiiwii the >"*!•

I tat «ii Oicrv reuuuiM dw tif.«S t.i integrate the Si*.x s jdminislraii^v urn ess and retortion ol 8
ijujlifii'd etnironmcnij reiiiedratwii Finn with the mpiJicmeiits vftlic NatMial Ci)i>ling«K">. Pkia.
KPA made appropriate ?efer«iee in the IVofHWi,-*! Plan to funding tf«ii ihe Slate W rk.ciilale how n p!;«mr«i t>» ci>iirfi)r»«te with inc. Slate ft e «i« vwiidert that fiMftMMHon can
be .wtHnnplisht-'d !>irei"t«,sfuih bai n« *>iiliow i-areRil plwitim^ Wv;uc kn«w ihu>< pic >«as Ikoi
ih^tnivul in 'T-\ and tl>F? aikl ait* opthuMv thai mfcgiiitlOfi the *«•> will he

sutcv^fuL pteaise pf'>wde int^miation oi Misi«n«"s that FP4 will be coordinating rw»di«!
design and rtmetlwl with the FDtP to «suw flidi tl» rDl'F \u!I Iv abi< > nkntiH a

-------
Febrimn i I. 20It

?*§#!

k •>rur< lh*t nineAlton

nnrnaji or sMuy tuvomic 'wifi, -«iJ <;M t« fuih' tmpvmcnt rcr.ievlia! dfMjjji -tmi trnied*,».)

Kit-?",

C innn»«nl N.», 2

ihc i'top^e*! W in ,-ttvrp In ji "tM \< .«|)pi4iwil •>f'lk- Fise buiWinf^ " plait not
for tlesnoliimn tsisdet tl« IVijwui 1'i m "w^xnittw !«i the Pn^xwd Plan, the ' wl* the
hHi.Jinsp >«• 1 • rtimMed at 5N > million "

thr.v jc i>» I .-.vn til mc, >>ni ?vjua' .»i -ire ki;tt in n.sutr.'

->po»cd I'iJu Um ii>w trie ?\H w*- ilen iA;ik it

tw^d >r> r>nn4 imw 1 " , . fkiw {ttmiJc ihe kisis He the I M V calaiutfion !) it was
not ha.se d on *ioal rettai iritMiik\ on »h;«i wi< tl We J ' It" il warn not based on on-uuU rental
nicome ami sx.'ua Icam.* him lw« I f* \ vcritk*! tltat fJk- fit! *ik* >s-*d mt»;ch

\>p 10 .wtiu! L'am' tenn,^ iiiij actaat itTil.il muwr *

,\eft- t*c a) 'fuM lf,-*hk'nts »li!tsn

cNpUtiu'J ,fc Unit'' 11 Kt'l V Nvctiim !U4^f* numoi applv h- tiw ut ibf

SiSe. i,I") VM\ ,ur not il RCi \ "K'fiio\ nl" or * ronudiuT • <*ms, mx! (V) over three

ikc.vWi \M s,u.i' i«a pn»i c<{cnt confirm 'h.it I H\ v-conunn..* ;m* nftt rvcovoriHi' under
tT.IU'l A, Whether "r'MV" wa» hi cd on toi rpuI or j,*tv olhi i nvU'h , >1^ v »\u i»t>l
v I'liiptJiis.tbk*" fi'spoij.w ' umi« Ct:RCt A

(t > C 'EMCl A i-aniKHt apply t« Ihr SHr

«,"! St'L V iksniH-s >1 A u'qmtt ui ,nlcv!< hi k-aj ic i.» conduct

i nmc Jul ii-iion S? \ Si Hui FTA v'miwi i--|> «.n the, p:o\tsu>n us thf

inolutrm r»f "f'AtX1" ?r llw i1.uv liw Iwo tywwu I n\«, .imir (¦",(*A

\Mnortt tw its .u'ljiiKiiiwi ,Hith«rnt\' the state <>t HoiKk « craffM or

ii^vXincni ¦>« t'llkwiw, aprecs lc» ! ft,? pn>|Hts>)\g!o demuMi hti;l»iing^ > '~ai'c fiemna^lk'J thcre >» ioilhui\:
'is uu-rtv Bid ih»is [unhr^; tic ti:i" S1«e ,u .-r;K 't>r ihf S?.«e has i-weii > a
Kcnirm1* or n>>>[%,hi>n 'irtcetrnftii ^ rnjiiifci i. 1 RC 1 \ iUh! Jieti- < m rt-kTttK i H

il.h. U! *J;r ij Pliii,

a b«il <> v*x not ut m k**1 [wofvin under I toncta law .V»jV„; i»

v >,¦"«'«», 44 Ho ii) 41? (Us, 1950) .'HiV.t htilds tiial a huiiilu^' lh«t is vtW Mcpasaieh tnmi tiw
Sunt) to which it is iitlKcd bev\i!tc» (K'tsiina! (trx^nty up>»r' vtiwpvtfitti ,>f tht ,v>i4 >*wniK
(t> it 0 pn'fK-rtx where ibc }j»la-ts«3 c>i il* va!¦> ih.it the biiiidnif. :v n, bff
r^rn.wed truis the tn" the ki>« in , i"- ih,' p!*mnll^u\i I wc • with the tk h n-lisd-

scSIc m rwrchdic wirf mnon' n sircli^ (»itu>nm»cnf HniMmjt th« .uIskcJ la triv ^

'»«*!<•, kegjfUtfiH ihi. ttatiue of liw (hi "Jajicnit Onuri of 5 lifuli o\(>l juwJ H.sc 1 l s\ »>-s

Lrtili-'mpktcd t:s fhii > ^nlrj*.hrtR jvutics skat (he clf anv slie bui!iltn;> v>t*iU Iv
fciiHivctl fwm the prv^iHtscs that thi' sai^* stx*ul«l mi inclihit1 wi}1 Mtorwt n the rt\4r\ ,"J, «

BARNES ÞBURG;lf

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Februiirv 11,2021
Page 3

421, The Florida Supreme Court held that "fwjhen the plaintiff in good faith paid the price asked
for the building and Gordon Land Company gave its invoice and credited the amount of the
proceeds to its account, the building became severed from the really, as a matter of law, and
thereafter, as between the parties, became subject to the rules applicable to personal property." Id
tt 422-23, "lie Supreme Court reasoned fttt ""whereas the parties have expressed the intention by
their contract to buy and sell a. building separate from lie really and moved from its foundations,
not an intention to buy mi sell tie building coupled with the real property interest, the courts wilt
give effect to 1h.1t intention." Id. at 420. As * result of the sale, "the plaintiff ha{d] a complete
property Interest m the building. eouplei with the right to remove it from lie premises..,Id at
423'. Therefore, where parties comae! for the .sale «»;* a lnin ihe -aim.* constitute

an iaterert in real property because the completion of the sale operates to sever the building from
the rea)t\ .i> a matter of law, Deinolislnny a bu, Iding is an even easier em ftan Oat presented in
Stiles. Demolishing a building does not leave EPA with an interest in real or personal property.

In addition, if lost raatol income or persona! property loss was covered by CERCLA. Section 104(j)
woalil have been the place for Congress to say that Yet Congress did aot do so. Tien; is no
statutory authority for compensating an owner for lost rental income or any other economic loss
where liPA has determined thai demolition of a building Is necessary,

(2) F.VtV is wrf a CERCLA Cost of Removal or Remedial Action

t'FRC'LA KcUion l07(aX4)(B) wily pernuls El'A lo iccitver f<* all ! .•( icmma! or remedial

atliiHi." 1,ost rental income is not a "cost " It is an economic |i»ss.

It is also not a cosl of a "removal" or a "remedial" action. Belli "removal" and "remedial"* ave
defined terms in CERCLA. 42 U, S. C. §9601(24) and (25). They do not include lost rental

income or "fair market value. A "removal action" means:

jTJhe cleanup or removal of released hazardous substances from the
environment, sack actions as
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PdhiMtrv ||,»21
Page 4

MnnUrh mjrKtl \ tin- t» nH ,1 iym «jrv tU-iimthtn n>' rmiciln>'
fvtfvin"

Dw -I 'icincditil actn»n" means

k *rth jHimaiK'iit icmc;h t\kcn HMtcft.*! *r» • ir >o

rt'itKivn1 4ciu>ns m tt>e c*-a;i *,*! .1 akaw ar tlire.:««M! <\ ,<

fkv;irU^a- > uMam t- m(o \h< ciivihr.mcni. to prevail miwhi-i-c
Ac Kk« t>t' ha. anioav >ubvuncei *e that t!w> c!n tvt n-.ijjrak to
cause Huhswniml d.tngv-t to }i)hu*i)I Ihr Irrw irnJuikv hut *«< f\\ xih'h

m ilk >' ilw »«lease xs <.u;' fdewed ha/.uJ^i-. \uhsu»t'i" ;vvi
*wviiknl cvntAiniinuii truHetw a as vt|mf! or rv-usv, ,iiwr->u<«,
iie-ltuction, ^ceiv'SMjoti jt waste. 014'w>v«tn..t,>.

t pjur 01 itfUkrttM.t \<> ..o!ie,.itji ot rvJmU-

iir>d nmiftf, oa*n?<- ireatmens v* maiwntiira. pr-nuiii ahem .tine
wner MMi ,»in niiifiitotirij,' tcinonAhiv K-nuih*'cn ,u.ti v s « ilsc |»uH'iv he;. 1th *11' w.'!tmnumtv tWihtki. when- the
President JkJenmiKs >)wl, jiIosk* i»r in irunribmatien with rtticf
iiWAMircs, bU»'h •dw.ttHW more coM-ciYeetiu iiu#» mf
cmimftnicnt.ilH fmfeuMc t>i (lie ti jh^utLiImil iun*>•,», ttaitnxm.

or secure .ii»pcf-;ti-in oiTwU' of ha/ur\)>>iis > jiKiaiKts, at
trtts othemwi. h« ikw»w !o fr *.- i ftx* puhh^ h^nllh i*i! WiAi^K
the 1C1TO l/Kkkdrt oitsik' ltiiiwp»n as suhstAivc- wii

4.it..vi i!o>! civtfimi'uu it

ini^ tkiltnlitm i>«jns iclv-a-'ht* i« 1 ,fc,,nni.' Acji \>iiahi\ if aH'iic4 :>*- ilvs

hui U'cic !s uo to iusl icnu! v>f ,uis fKr.«vt

if i» «hc- u.Vs ajt|Hn*nl hm\ I"4 » plum (,> tbts» rMv " I'ifiic K 1; plummy so he an

iintaitcdkirv l'«r ilie UMi^fur ui mwwv »pvMwil>k fnrtK-s k! *'> cjr,rv« uJinimiL uitV^ 1 i iV 1 \ Ff

k annul wln;^' !<>r 1 PRP wta! the t'lO' v i-nki I'i'i -h hicv^ icf itsflS utukr < I Ki I, \,

!lu Ci*u:t in r1'.!.'.1! *v\iV 1 -1 ' VI ?v* 1V 1 T>i i,v)2', J^t-uvu^d RC) • L ty-Lrtnc
•'HhWT. ,attl ik .«k|»kiinsii sjsii Cmij'fv'.NS '.{KLilii.'iiilv MjtiUed fee recs>\.n .4 iliinwa-?.'

.MHiwiHK- ("«« K'hij: unong'firm ibkI"! CI KCf A:

BARMES&TNORNBURGuf

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IVhntan U. 2%)21
Page 5

itO' ti^nt n|«. 1 l« I ,\ !\ \ .-.is-. Aal U>th few

* H.R. 7080,

\ s * w II, ws^m

t f\ y l) % '} -sk < H u 1 . ., ,'o _ i, | ;tei

I1W^¥©irjr» jl-lt. ¦ W«V, j^-UPtoJi W4*4tkMb»ft- m*0 •*$> WsAssWiV-w uMnofe** •?*>«•* 1 *ovt

- . • m s.-.. i v1* 1 ji f * 9 [ \M& f'if t 1 ^ i 9 fe k ««*« If \ ^

* *>Jr* w ¦»» .« <1 Ijrtc/fjk* *Oi. 11% ©y. ii*

S.'Mte Hill she <,<.•« mined a pr»wM,ni k* pn*»tv fvu^cry .'fall

* lut-ttf-j-wkd nwJirtl vMixr.s^. iii.«ulii,t' u'lioMfUitdii CiMis or

C , jvi" , , L , # ' , ^ f . " , ,

^ V-wI. I FJt&fj f*j J*\ VV 11 § *3t^/rV */f« J$

?ii2(i w*» ukmistetv

Tewaee

• J & IJ.kv-i"3 ituiu'tl t Vrtd i i RC I * \.^ Kmi juiviviod »,",, «i

•stn,..t, n-n.-f jvjg' imi ths' l •rij.-ti,^--has n^t mm ht (i> f(tult-i.i>f nunc n )<• v

!<> 17 v-» . ."...fii, -VS *• ,> i1'?, 3'S i !''<<_.> ho i >iik.1 ^w>iv > Vujnknu C\«yt intii^i' *i,\t tHti
vnoiMw i I Ril \ -n ihM !!sc Ncs\ ,V^ >j»dl 'n1',

'vhrch dix' pc-niHt r»vv\otv It iwm.irwi' low*. pa*-cmpt»nl m run tf\ O-Rt 1 V

I utikv (hi' Scili ( CRt I A J\«5s »«l mtliitk i"id spills wiiiitn lis
vStlitnliofi s>i h.vuuJwxn subvteicf a'lca.M.-5>, nor is Suprrfunil
ia1 H^M»ifcnth v.ti^Sr
Jiviut^s apo |ni ^flm-nc tufv

« £ ietnpli.iM« ,ii.kl«.'d i

(. r KCl A !9 ,i cu-.l-(i;if»|iy)M'!»knl > {f.sun , i.4>t a n-i",!1mw, uheh.ivi tii.'iluM
cuinnnni Icv^^es h,i%i» niisisionth i *4 tK-c !,tr c\»t ihro,' nJc-vadc1;. IVit c,(sev are

ifldMrulivc

BARNES & THORNBURG»j#

-------
fdmtajrv IL 2021
b

# ,>Stt «¦>« .'l, - i" ¦ i '(Vifftt)" >i . -v' C>:tik < ni>xn. t>**# ( Suftp t2v'>, (28*7 (O.
Dei 19S7) »-*t SUU'W n, U.kus t»,v ikti n»; pi hs |f\ an J

cqyifnient tcciuKj-n| pttmpmj, nsHliitU\rti< w»< r«j.<.trJ I FPi I A fncvulvs ro>

p, ivm'j c^use u-iis, this ». ,\ wt scape ol' 'iu Mittuu /,

* ,viv'Vu •' 5(i»i «i > ! Hi v'rti;, t>>vh I" Hupp, lOMtMu i's I^SS) tptuUirifc. .nsiH d * 'Hj j;c•>> .*f

land 1 }*hintiH» re^v-vi lv» itaug^ uh,«ct< can ?*• nfii\!r»)««»! i, ilimnpys I'm-

ilmnnsj!t.}x«'. \i.ixt I *4 mcsxw >«"*¦ n»« wwverahk* under t'F.RCl.A"";!

• littmpfim v„ A tfinUo* Ci*p, Civil No, 4-88- 22l>, l«HW U, S. t&t LLXJS (t?J,
* 13-! 5 (D. Minn. Jan, i 7, 1 »W) < iiialnlity to fulfill long-u tin lontiACfe. tor « ant> Uk>jvm1
i«nJ (l.niimshtd proj«i1\ vidtx k)c<,!ci1 as the Kwis fr-r a datm " If <>'» h\tr ih.it !c«' ukcxtw
h ru>t a Kmus iiieumni iti ort(v to Iwyarctetis v,uc»!e cleanup " *(( 1 i*^" rm
nut be nwncrcd * litis ivmIi <*> untsMout *it)t «CFRl 1 A - j»f>msrv (>unx>Sv U> prtHidt
rttinihuf^kiiiiriii «o titosv Cni.,«J i>* nkits U«: iitn.c-i.SM'> t.> ii"«i»e cofb not
neuvcriiik uiiJer t b N' t«0\e f«MHnran 5 .-,v ,•.) , n ,! \Ui:ijkvv

;t p?n a.v |<,vr\ iuv sx^k ,tn part i f.« u^\h tmt iKtsiin"".

• I>'ra-~tikI, ttjs ri. ¦ t\ Ji. i' "i 2fMI?31, S.il'i* f-4® Ct: U''' i ~ 'AwnajCv*
for \UfTiiniilion prryK-rt-, value .w W CI'Rt I .A

• (t'litun v J.'.'-vtii hin' ((' i i U11 Nupp kl i if I ^ i \ 11 lid if1'"1,1 | ;v i'oart finds
thjt, -fe a mailer t»f km, Pljinlitt'.' espciwe* lor trni[>«rr.ir\ Ihhkhi^ .ind ?«l. hnui tfieit tunc »1 ihi '^«t t',\lunKt Iloiwing i umpkx,
h iti) !,>«< iW vihuh i'I Kt'l \ not mtmimi ti» ptuviik «teinvds"l

l,i" \ m>v Tii\ 1 pat ^ the Frif^scJ fian iv :!« »>! iXc.^im ui n nut he .i -.liiibii

• )! C Mil! V ^u}«rcnit: C>»a1 pave.kiti u*! ovt-t >c(i;n i'f . tec !i» ib«« tvKit;:d the
fo, >\tr. >1 %.c >i(«uui» vSa.M« umStf«, 1 KC ' \ 1

C iimtiifnt Ntx J

»rW Ploit rvhtf* on a flawed Hunan Health Rijik .'IwtiMneni tillIM V) UP4 prin iwukIv

fk-. t Irttcr Jofrsn M iK.. tmfvr ? \ cxpljmtfiQ (htv ! vt wilti the

,ivs«l;inii* ot i hnslophcr M. Icaj, fttsiJenl and Ihrector Iokic^I<»s> at llai.ardwis

Ni^sl4«cc A Wasic M«iav,cniwii Rc^caith. luc R.iUw-t ! the c^uk-iiih «f lh»i kuier,
»!«>!» he.ii rt^w.-Uin^ Viitu-iih ,»ll n) the uLs cslculalci m tlic tiltMA .w 4um

i if ! !• 1 • .an%r> un lj» U > «. '5 H fc .".Iji#.-. » ,.! >n. I'. • 11

,.1 ; v-f p,- '(•" • ' V - (I t» V ' V, H (!¦.'» il ». ;> . ! Il OI iw I'l-X 'i. 30

vniif j ,¦) ntii » . •>V" It '* * si\ t\ 'Ursoh ,i ! . cti

¦n iw > Hi, i> t'Kl 1 , "<%¦ "unrk* *>•' k Vf i>< '!»w in if "if I >

BARNES ÞBURG u,

-------
i"v%r <• ihv fliiK'A \tuc asMmvd K* irpiY t ui the vfcto.toj »hrtmntan rtmilrt Hi

ran* ur rs citcam-iuuuo l!u> >>fv\u • chfvotiuri s> t\pic>UI\ tmnA n«\v
ch*<*!se ;ng >>» melai piuv<.s>> twilitir*, (u»i in the Biujvih.' V]ui!er U'ijJi m

.ttubtkal \fnlk»*{n»n the lha: t,f (mi diMnitur. {fcivted uus tk'vn»!wrt

viw(Un.tiii iKK >t.l> .irbivart, it ***> m iUf_ Ik vn>»k(ti whrointum >> |hit! i!>c Siu
as ( I" \ hj-i iimftrmctl mi Huhscqucnt uMini; F>» Hl.wk & \eat;h ,t«tKtuex«i atti' Me Itaii.ett -n
letter.

And the actios*- tuntpk* n-miSt that the HHRA wa> [hiihim-i! upon hhuulii haw never tw.'vA
KXisidcTtJ Hu; ich»H v.inic tkdn me WMjnc fi«m Mi>nihrinf»( Wt ll C'< >! \tW- ? lli«* rcviSl br«
relationship K> ftvtn that saint* wc»1 Ki<«c ravl .«lkr liw an^tnalim*- ?cwilt m« reported

Here are the data Ihwn >1 MW-7 \iibict? is ivHtrotiiiiw: the mk 4 the Site

1OI M\\

SetMplt Daft

7/13/2010

7/8/2011

8/2/2012

7/1S/20J3

...js:1..

Uf/I.

ng'L

ii it

(iX

17 l|Uu,l»tH

t-ltrwHlllftl

3000

-KilX)

1 hi.'HX/

4««

5400

Neutral ofisetvvn, wu,«kl Iwl uriiiwau*f sisinf.k >*n ,U>i\ j, 2')! n1ic V\ > ?'"l I testi'i hrt b- (<• rvbt.-J idmuiimg >^»r»,
j LiKif.mon 4iiwhtic;tl i, * ?' grrti>nth,h»* »ii Iscf aM ciKrfami'ii fm nmlnet
'»L or M-dtnu in the,s,imf>h lit tui-ini*! w\ r.Mjil has*. UverK,iin«n4i«d ii\1n;n.ui»K
>hvwki twi tusc '*•«.•!< \t>«i 4k ilk* !um\ (V- * ivtuf.klth J«iium,4Ht mfliwKtc «n ihe r.iks kiku'.iKd
* t SHt »& a

While the HHR a «,ih «i Lutic ,»afl prcun-vJ mi tr.c.st tw(> oo1 S' \ iWcl! hus

inn1 tixuytt/cd licit ncuKi wvinor hsviMktH vhiniiitwt) "CttetiiKaK ,*kv*iii 1

j.1 ila' Srt 1 »ti p,i41 21 '•! l(«, Ftup«»»*J P'div !¦ f \ I tils, tnv * i'telirmiiars R«;mcdiaiion Crisis' fW
% iK'iiiaab tn i.nj md subMirtaiv «>iii < hi pxjee 21 the IV^piHcd i f.\

it^ts iht Fkfk fir 'tlwrnical ut t in ^ro»un,lw>ikf and hexavslea! flirr-imiim tii>

>»« appear \Si eniwi ui ttw M'.ts \ ti ' FA ^i»|! j«ii«, w boib ut (u.-ti»iv ih:

III IRA Hut sh b\>C'i m4 w»;<» ttnt iK^avaltni vh:»>mium

wt unw.vJ r'totn » /!¦»}• ..iLuljltuii, t^r ij^pn !h^ I?jet? yumi.tit

nyntfuantK , to 0* ^ u>r Iht tauBl auuh^ chiM" iuidhst<^^clic.(l fuutrt re«>i
-------
i- vfcnwr. 11, 2021

P»f*8

lh« ntn rcckkvd IK^s «*•>' tS.wfi>r\MC«l O 4> not evei> h*t«J tw ! t* \ >ts,«Oicmk\tl t>f <\>rH«rn us ^.sK IH.ip,«<.•».) Plan p ; I Aid
the v?u*Ktn rrt hiM'J on Una •--'ifiuiwj f" " viluej: t'-om mh' -.intpK"-, ^itli (lie maximum
vkicctCvl \ a.uo CKVWftnij, wiUmi „* iMitii mii' *r,v hvpothiiK tl j 4 ',¦» a taiuu" tvfAM «ron Jk-wu" ;t«v f<«m,' iV HQ w.ttn i«>wn
to I.

i*i*H | K ltl.JXHh»,Ui-\»! filUtU* (VMik'nl, ItK- HQ f» J. i vtluf thai n U'lrtsii tllcti K v.'fipcf, vthjfK, JiUl
,n>t> \ ft none of tiv *. ion>titiK'i\L». i> even identified »« « Ctsciniv.il .»< C unccm in the Proposed
S'I.'mi IVjwvted Wsn, p 11,22, Hie rtmaminf, iw«-i.'arci»rtp»*nn n<»k wish a ISy i cutis i.^ly
tw,» InpetiwtH.tl hiUnniifiiui \-Mtnf thild ouul i.i »lsf imaftm ¦*• a jxitt w csjmsutc to u^xfr,
k'i>l«ilt, atiJ moo, none of which h a CJk-mu'&l or C oncem in lljt Pio^sed P) hi Plan p

21, 22 \ discussion of actual Sit amihicn < m the KHRA uoulo !mi\ v tnghh£lrte>t the iimcoliftiv
<. «,f >>uu -i>Mimptiorx \ih»vh t\vn this mk *<«'»-- v .iluU lUsi Ut mv v mstrttittixul

,-i>ntr>iK, .Ht ,i>f»tnti paiiine, i >i, and to. am*n yorirp t^'ukuiun- aio m»r»* than hiIIVkM u»
iwtrt* U.o !H|H>iht*ii«.aS UtKJV. - unnis; vfnld !f\m> (i|«.nuk tr ji'v CI'cuvi iboi lh.v Profv^d
Plan n not known vondidmn st Ihe , i i that •( if> .trhstr-an amJ , ipn. >¦ »»

F«>r n-4, U> s-xLmj .niJ he\uvlicin ctimmiui,! tsi >v'fwci-«n

5Mi"«< 4i ihv fUvumiv. jut ioulithuitun la twk *ot (Jw 'er.Air >^ung ihiW, uaairt vh\l<),

wici iuvlv\uw!»alcr ^onttiHiKip K> nhk '•« toe .riiJivt worker,
!«nw»< ,uh»l! nnd rtntdfxv '-Mtrkct Hrn^u-i. fvniy\t'tf, !J« nxk
F.uiei' !«• it*'. I i.» U-06.

Wnh trt ihe soil Mitnrihunm» in mi,, P \S-K \!it if H\ iv tllniiw

dihr.ttuide «FS)l u» rak, FD3 i1- tm ^\cn h >>t t H(u«n at

liu' SiW PIjjt., p. 21 22. flji ?.\il ri*i

!u'n«'i'ia(fnri,*Tic */.a> A"tix.1cd m ->nt out >.•! I 2 x-unwie*" PCB \u-r; rcj»>trle%i m *,ar- ^ut

cl j- sjrnp'v-s, vvfi' ihe nuMiniiin wisltin iJie .«a at ih- S:V \ • tb- dnn>' ihc^e
wi>n*»!!iiiwT>tj- and ct>m>pomtiw i»>.k .uc casih *tfdresM>l will) « -tw!i«>w, iWttscd i«\K-.i\aitm
ihcfti f4act\-, tkc v-ii/xuhm^iMl «4» in t» nry.e of II-, t-*\ *iin a

si.ri.Hv ('.(p hi.c an asphaM parking !r»f > fUMtn ftt pi<>p»^cij amcd> » imI !vihi«v%v Pian

< iimmcnt N«> 4

IK* I'rMpi'.Nfc'd Pijai uw the Public \!ccfn tJsc micnm «n«iti,tlwiit>s tcm«kh In a
f<«lwcv]uciii ntnlcKocc call K^ecti do iiiAxiran viJ EF\» it w.l< ¦. U/(fuvi itu; >h« ntcnw
rotnedv, •{ rcqu>rc>l, would result After the soiis an»1 *u v\ mib1- of

aiWitiofui! p'HitMfwawr vmplinf, pcr:*>J were tttiiplcte M iiial |*» rH, "S c ivcil tin iSv, ma*nm
Ktaais woulJ he ijv^lujfid Ptca»< cvnflrm th»

BARNES & THORNBURG ^

-------
iL?021

Piigc

< onmirnt Ho. 5

I am attaching, as Attachment 2, a. separate letter elated September 26,2016 to Rudolph C,
Tanasijevich and Michael Taylor from John M, Barkett regarding the HHRA and the Remedial
Investigation. That letter also contains comments from Dr. Tcsfand Mike Miller, some similar
to the ones set forth above There was a request ia that letter that it be made pari of the
administrative record. It was not. Please make it 8 part of the administrative record I
incorporate its contents herein rather than repeat them.

€>«hib#hI fto, i

Here may be technical or other reasons thaiare determined dating Remedial Design that would
eliminate the need f© demolish what is relented to as the "Kdsey EmT building. This kind of
flexible decision-making by EPA and FDEP is nomiiil during Remedial Design, tot, for
thoroughness we wmt to record the comment

C omrncnt No. ?

i'hcic have been a number of comment > submitted tu Lit1 A (eluding llic Fil l'S If]fRA. and the
hoposcd 1'lan sine* 2WJ from John BaiU'ft or Jc maxims In particular. ihoc comments
cnttct/«i the work ut'the Arm Corps of Engineers. m attempting t«> complete the Ri 1>N_ which
tlu-\ tailed to do despite taking more than seven xents ami spending birge sums i>t inonrv I he*
comments are ic flee ted in letters Irons John M liaikctt hi f.l'A's tiles I'tease acknowledge that
tin.";*: comments arc pail ttf the Administrative Rccoid

Yours 'truly,.

Bruce White

Attachments

BARNES ftTXORNBURfiuf

-------
ATTACHMENT 1

-------
tfY RMA!L AND V S MAI!.

I.I

*w* »tmnn Ak*mky
Krjfloti 4

. ,ytb S?n:e:, .v»V
MUnu, GA .U'.'iO'-i

KuMii: iU«a»till£V> JUiUliili'tuJ kW*. U> Ivil .miCfcH'ltttfepO^V

RR Perrolvuin 1'nHtuls Corpnnfito ?4}M>fHut» .old thfN tar's

>« house law ikp.irtiwtti, < havp that .iinmcai^ tfut

we i e. >.¦»•'~•d 4n»,i .i* maximts uh») M t\if m Sn Mencdi.i!

(r>«stigamon Ri'jmrt uul HuruJit li>.d;r BkI-' '\ss>t'sMnt tit • M In \], *£!«,• >«ji u-iif ,%>
von to hf inchuieJ u> the ;>rin".nv^ '<,i >r I hy *¦»».$ U-nt» ] 3tcpht i M IVsr bvjiU mu'Um hv the Atvuinnv <»?

Svknu <> am; *\ Dtrvt i*w \>t l\>\it uln^y anil hoMdent tor HSWMR Di

Tc.^t submitted on tt.e R \k h <•,»/;.%!nuiit vr {!«• PPl Mtv

prepare.) 'sv 1 ,}V; K' it IrttYmr,irsii.il tor^(W;.l»nri I(><" 8>vhtei ('oqwTHl'-.n vn
i.-». ,u 'i,v*.cJ rn fif cci^nofiu" v*i".t tint* OHi Sue rui h-s

\it n-iiv'^>«sh> * i iln.* n>, » nr.'.

behdif i)f" EPA
c vtHJti.se, th

• Thf HIIKA ^autaiiis uwiMfi'<\ trw.t, aa ..nTra-nniblt «uu iw!
cansl<:ii'n: wuh >cnown Asjt'raptioii. .U-<>u* i umnt tfnant

psipoHin". ro M«?a«w sufisurtn,.odsand .i^iti'npuAiis-ahrut tirtiin
reii.k'iifuil iKi'upancy nit tsctrrdiisUt1 and do nm "import With thf
%r.. wn n'»' S;Swiv .itilu.pj'tiS •; Sin.J u^r mh'
forth r tl'»> Ha.'fruMiitn ' nuIiJIRA"

Wt* U\Vv a- A»" h,w<» :•» itn? ^,)n! > v-%i u;.i July 1 c>, 2^1 "< lcturf fir ,>U' s ;kiv»j,; jini t itvi'i <"\i Hy w.treh>nis( s The &irwl] urip.iv ...i

Gtnwft

Xa~« ttU

0. rnn
y.»

fv*'Av
»S\*t ^

-------
Shook,

-WW.jfcfc CK'H

• AcetotiP dttil ohttirnium continue c« f?«ent over Whi >A the

calculated noncancer hazard index in groundwater with exposure to T

aircont* making op over 70% t)l the hazard index. Chromium >s

the overwhelming driver for rh»» uilrulated rancor risk in

gn>umiwr:f«>r Vho^p risk cal dilations ai»» dn«ftr by i v»\rtpw

ft-'Ull thai :? anomalous in relatlim u» all odier darj cullMtnt oi She

Site.2

• lac av.uniption that chromium is 11M§\« ht'X.Wiilral ek milium is
continued ip ibe fttwl HUM. As Or Tuif notes, it« 'highly unteiUl^

's>-< j'suno !) *br highly elevated tapiwtirr jiotur coitccnhati«m 2) alt
i huxultitn 15. hexavatew dromRtm, and 3} hexavalcnt chromium is

Va the »i ,>l i uutk ''

• V> we tuve tu*»:n suuii^ -,iBCi4 2013, tticrt leti ali» double counting in
the s«"'{! Higtstbn idkuiations lor the ninent and future ouidtxx
worker, future resident, and future construction worker h«a!ise nir
HHRA asst^tis sod i;sgi*«tii)n rdtow* both sunauP ,md subsurface sol!, A
d.v>s>- mgtstmn Mtt jsMirr.pthm should tvo iwedwl, .4 Uu>
soui« of tlie ingestion, "it ye> «we a ..olai t-f 100 rng/day for a
worker you cannot assume 100 mg/aay for surfao* sell and 130
mg/da.Y for subsipfaci soli * at. Or. l>?t csylaiTi \ et rtv Jt w.-y 4i»*^ t»
the HHRft fbert*fw doubling noncancer h.u^nls wri cancer nskf

de mmtmts ond Mike MiHei, in particu'w hav*: bthrii involved with the Site for about
25 >c*rs and ere fanwiar with past and current sue comi'Mim"} t? W! as de-inup

ix4 i»fenced m «nd locked Fch* a hiturv^xpusuiv u.-toil inwiu, all
(•Msting fen, uig, all pvsting p lyraten, onri mi pwstmg building iti the areas
of soil impacts would need to be removed Fuitiwrimofe, for ,i future
resld».»iitiat exposure scoiiarm, current wning ant! land u« dc'^nanons
dictating indnstflal us*.' only wuukl hav« ui be changed at both the CUy jiwI
County level For a ftitare groundwater exposure s«®aiio. when.' no
gruundwatf* <\ currently used for potable water, a groundwater withdrawal
and delivery system would n«d to be InstGiwn fh^ nahire o! r,le
i wndltiont. ,^nd th<> his! ai tc of the property, Shese lliecretical swaanos
are not likely to ever occur.

I be ^roaty»a«t »teta t«e€ (i '.UOil H*1 ii^'t I *>.1 chr.msiiim ; • Hl.lXKi ug/'l.l CC'jRMW-?
» rc»-n\ d irs iht* ntulto* «ea of Mutijc as noted m ihr *eN Appcn.icv P.
'I'bts we!; was also used f«rcoiieLirii»| wi\tc <>d ^nipiec and s% m the ptim«f^ p>i
sledgt m'i >k\urdipj; Ic fiiturc.s and hiMorscd! serial r»lmjtogiAfte ui itw PI. It t%
inappropriate io I* using this data to evaluate risk.

' The HHRA ccmtairte a U<»s» ntnng how prntecilve its af-sur«t)tk'tit> wen1, Kai

that is another way ot" saying I'PA cannot rely on the rhronmco-tMsed risks
for jriv reinoiy deten»ntian«« I« uthp: c:rtiim«.Uoce«?, Ettgion 4 lias
acknowledged that 16% hexjvajeni Cr is i rpawn.ible default" .tssuistptnm, <>"
no data are available.

Houston
K»m» c»v

v'jrrif*;

Wan)
Oranijs Coa«/
'• ««K+a
Sm f '**jocc
Turipa
* C

7^^'>4

-------
Shook,

hSS&jc

vw>,Sc, ,m"r ir„i\trt,t* \ mm; eriCv address,

,m-,u«n^ uuw? th«* lo.h-wnmi'-sti'^'

i •#» >

• il etv !«*n »iii .,i»estiont ih\,l .m in j> y »>• tbf M.e msVi y

• Ttefx ivw.'io aa'.i t,lei« how "Asms wUh twi in
tbem.

» Th<.' i»e w itit »>< skWtw sni® i'h tnnum Jjta eulkftwi f»«rj COKMW-
"? is nnpfi>[HT

• 'Vf«P e«iw itfi. t'.ftg i
liii'jVffiif >t> *.v f( r »s

Wi: v« «« to vsktivvt I'j;'* |'> oijUj; a r> \nl j i e>tiv u* i > a

rfHideml.il scotMrlu

The r»mh i k<* • u< x .svf! Jet irwted |o. in'Jus'-a! -.sjiii h«,h i.v Biowim Cduntv
On* !«U' lh ?i!sl (Htltr wiiait>.> ki>.^»a from iht Bi\n%an i unnU Properiv
iSppralrrr1-. w« bs;»«- shmvidf ;h< ,w,>;\(S and urns! »•;< »ni rt,iv .Torn thf ,1 u-
Mfi p< tnO-»i • n{>;«s «>f rhf /wain; >•«!«: t»rd ki>p ,it-st:c th? patxeK
U®t e «(>•

2, Urowjiil i'mttiiv i-wm tfw ptittsou v»i ?}«> PPC SKe sli.K a NrwevJ m ami \*ih
«'u* (ti.iinwtit u wunenliv '-n^n-ii

A prrjpein ywrier wa^um: to null*! reiul'tu'ec on ;lu" pi otWV wtwisi u»
cnrmno ih»> mrrW. prirafp who warehousing i,p.«cf\ a«;

^Hla^DHHsjiiUvigni'v u- v ijh h* (^c'tume, trsr tjvih.thw.ral owae! wouhs
h,iv«,* r« rutiviin e Browrml Luuniv u> i ^.jrsje ihf Unti a%t- iit*7,, k« !hi> s'i>y o! Pmtnfikr

Pa.k 101 liangr th»* lurintg
6 The thwirrlna! iiwntT wuutC, ihwi lo sih-hihu* to auiid «*i

pc'prr.y »aa tustall drink.m, %\tUM wtlfs alt*-! permits ti mi*

igciiro" ttut wauk1 to «ier.d^ te »!s^vv iSnuking vvr,u>r w»iK
C'l thrSiie • Si»fu'(h(ml
And tin' tt'«ire«cil cwi»pf woaul snen it.nr t -> t unsiutT hawrs t t tenusn;¦. »n
i>,t,>u(»>lw;-itri.

:t ciofti i rthwn'ii«• to aiSi'iLifp , oo tlifn t ill u* proptnlv f*ptat!i flaw i" pLsiis 1*1^ iht»
i\ Ara'l«'nm I'MiMwire K)i i.!jv ru<>n> !uvl>,iih'i;¥

"h*» AftM h,iv tiken vt>^pv n> M that mil h»: the sti nfoct n>ture »ii%i iw.m h« nust; ir, frx>, ^ not an

<>«**¦#

^ */*«»'. *y
landan

. >1 V* •-> f,

'"#*¦ f '»-.«• •
Wsnl'infllnn n '"

-------
Bacon,"

**.*» b cO«'

MCP-consistent document. EPA is a fiduciary with respect to the funds in the Special
Account We wauid iike to know tow mart money has been paid to the ACOE from the
Special Account, ant} thus would appreciate you sending us an accounting of ail such
payments from 2909 to the present

Please confirm thai these comments are in the administrative retort for the Site,

. Barkett

Enclosures

cc: Michael Miller

Christopher leaf, Ph.!)

PPC Cooperating Parties Group

6om»w
¦(oust®

Harms "tv
Lwdwt

WiOJVu

Orange Count)!

Phite-Btpfra
Sar f trevx,

WiiHimjlwi, 0 C

796934

-------
ATTACHMENT 2

-------
de maximis, inc.

Wiseman

February 24. 2016

IMImmm: Cemmmrti on EPA's Pti and HHRA dated January 2018
Ptlrokuin Producte Corpofilion NPL Sit#

We have rwiewd ths ravtaadl Rl and HHRA sobmitei by EPA on January 26,2016.

Our continents address whether bHA considered da mawrais' previous comment* from the
Group's July 16, 2014 setter to the EPA. The previous comments were about four broad subjects
listed below.

Then we have soma new comments about Hi® revised Rl and HHRA.

Site hstorv

The EPA report dwcnptisn of site history mm not revised despite our previous commentoi. and air
comments were not nddfMMd in subsequent w#8lin§s This sectewt of the Rl. thus. conifiu#8 to
haw ques&on marks associated with i.

After sutaitting our comments end subsequent conference cells and a meeting. EPA agreed to
analyze the groundwater data and calculate risks for two groundwater exposure scenarios. The

two exposure path® would include daft sets for;

• groundwater ¦including sludge p* data"

« groundwater 'not indudiog sludge pi data"

AUctiiown. PA »Cltatan, NJ ¦ 6A * KnoxvM*. TN • San Diego, CA • irvtn*. CA

Sanuot*. H - Mmwtao, 'FX - WIwImw, CT • W*lfWv MA • GuMvImkI, NY

-------
dm maximis

The final Rl text on page 55 stated ¦* fn mivnlams with this momommiim the Qmuorfnater date

was mfiamM into two drfonHit data sets; one mailing the mitige pas awl am not inditctmg me

siudgs ofts '

Tf» revised HHRA dom fyeaem groundwater risks for the* tm exposure patrw

EPA RyarogeoiOQ*3t EMS O'Sfeen, alao rmwed when wells m>ght toa suitable of not suitable for

groundwater sampling

Tht« review was inducted tn Appendix K and a %«* key paragraph® foflow:

• Page 1 Appends k *f\r this mofyas n^y 5M as an #«rc*se to dsmaisimle
that a significant Site risk omfs basso inrgoty on the Groups Iftswy of wh&i
gmm^vmtw data can t» irtcioded m the Rl amt ffm HHRA, lh>$ immorsndum mII
»valiiBte use rV data oitjutrnd /nm writs focatm out?*** of tfw* bmt"d»w of
the two nimiti§«! mudge disfmml pis, The Stlf-specfm cmMmn md tm imaiton of
H/ch iw#s am lifastraifxi 6v F-igu-ie 4-t o front im Rt kepuMt fugum 4-10 stsom an
arm *MiWy.-'V tho locafw of ffw tm former a(«dpt» <»fe tm1 eftufuimg isw) wifi
?w :»5,«; worn, KtentiYmd m tht sioJgv eiimit and the #»¦*!««
SmiiO'ty Figum 4-2i nfOm Ri Report also depicts tho a ma of sludge extent and ihm
mm tit o9 extent.*

• Page 8 - Appendix K: *Wherp<«s « w»# u< nn^Mfnl through mmml imt rJ sfoogw or
wmVatty rSmmfml nmtmmi is pmhatty vmthm a wssf# tfaposaf »r»a In ff» /after
j»a» the wmS mn-ti imh £># if? a loc&im thai is mrt of a waste m atsm mm6tl,al
scenario md thus shmU imt be> umd in tlm HHRA *

However, the gnaundwiwr data for 'not incwding sluoge pta* still irvciuctes data from *ils in tne

slwJgt pt area.

• Weils in fhe ares of tte siudoe pits were inckided In tfw groundwatef data f»' m$k
analysis far groundwater "not rchiding slu^e prts* Tlvs included COKMW-/,
COEMW-8, COEMW-SA COEMW-KA etc

• Groundwater data fron COEMW-' was still used in risk calculation!, COEMW-7
had if* t-ifh values of acetone f1?,OOQ,QOO u®/L) and chromium (110.000 ug/l)

• COEMW-? is screened in tfw shallow area of sludge as noted in 0* weil Jogs,
Appendix B This well was alio wed for cotlaciing waste oil samples and is m the
primary pi *tjogo area aocoafcng to COE figures and historical aerial photogrspds

Appendm K avotoed trw svafuarion of welb msicte Ihe oil and sludge areas.

• COEMW-7, and otha! watls Ike COEWW-14A sn sludge 0 areas, were not
evaluated in Appendix K

Append!* K also stated that the risk asses&ar sIkiuM decide wbier» we# data is aseo.

-------
dm maxlmi*

• *HcA» llmt fr»- oafs frrvn fipf cm tm usrxi >'r /no HHRA Hm memorandum
oms no# sp&city which walls sfioukt tm in&iideo stt th*> rtsk m-nluaitw Instead,
OSWfc>? OtrMr.s M8S 142 iOctemmnr.g GtoutnUaim £#x*04>we
Concertfratons, i-.PA, 2Q14I should tw umo among mto k»«H.irtifig "w LPA Region
4, Tn-Jmntl Smvmw S»ctkM nufltfm ImaSh nm ossessor 6> *«» wMrVi we# cfate
sAoufcf 6o included in tho HHRA "

• 'AStrruj!} front a «r»pfe owterfK/ij oH *s rax otooctGd to to
iBprwsonM/ve .V ffts p;«»y tbsjaufved-ptese $n>tif>{r cw'v •# >,? be
pirfted «to a fty|*ottslicsl ***/ and pefsnm ccukf o#» mpmea In (ha* e,o^tfnmmat,f»i
there m otearty a potential rtsk fmm moimm to the om HHRA of mg w©#s j»Mim| ymnrfiJiwtf## wtf? tos poimtim

of «? «wW iikeiy imttonaslimattt ifte potential rtsk frwri iwposws to
contaminated groundwater. *

In response to these observaton-cancer| and1 ILCRt fcancefj rale calculations

Risks are much higher becai»» need another calculation for the Exposure
Point Concentration (EPC or Cw in tbeTabtes),

Much of the groundwater n#ks are sill driven by acetone and chromium Th«
exposure car cent rstior for acetone went from 1,380,"96 to 8,427,12? utfl-

« Tbu revised HHRA represents the rtviti calculation of risks using naw mtthods of
calwlaliof tie exposure concentrator

The EPA uaetl the abeotute highett value for all anafyiss in thair firit risk
ca!at.afions. Their second risk calculation used the "mean * This is acreplablo when
the data is mote noonatsy distributed tat often not when 1he data & »k-w<€<1
as it is at PPG. 1 he output from tfie»r 8«cond calculations used the «r« soft*am
oiogram Pro UCt, «hich does not recx3.Twr.end wing tie mtsaa

-------
tie max/mis

Their third risk calculation* used §5%/97.5% Chebyshev mean. 1: is troubling that
the risk assessor has done two revisions in calculating trie exposure concentration

and calculating risks.

• I is difficult to evaluate the exposure concentration when Hew are such extremely
skewed va'ues to a data set, l! or oil <.«.i>mant was inducted In the groundwater sanpl© cotected
on July 8.

COEMW-7

Sample
Date

711312010

21112011

7/8/2011

812/2012

7/15/2013

Anayte

ug/L.

ug/L

ugflL

ug/L

Acetone

17,000.000

180

Chromium

300Q

4600

HO.OOO

4900

5400

At a s u» wtfti free product ONAPL or LNAPl, we would avoid groundwater sampling from a welt
with standing free product just, as FDEP has done at tfw PPC site since we have been inwhiwt
in# data is not representative of groundwater quality.

if you have any questions concaminB this matter, please contact me at (085) 691-5052.

Best regards.

<*• mmitniB, inc.

-------
APPENDIX B

TRANSCRIPT OF JANUARY 2021 PUBLIC MEETING

-------
Environmental Protection Yj>wu-v PropiM*] Plan Public Meeting

Pitblic rt!#lSS®21

TRANSCRIPT OP

EPA PETROLEUM PRODUCTS CORPORATIOH SITE
PROPOSED FLAM PUBLIC MEETING

VIA SOOW WEI CONFERSMCB
January 19, *i V
S:C. 0 p.m. - 5:51 p.m. EST

Kf?r; >iMpn..Mliv rxpm-ted r«r » vi\ r-y

K<= I i y : ^ r ->mr l >* Id , FPR
i „¦ kepoi ter

Huf.it'V G i .jba 1 Lit iga f ;,on

1 - R 0 11 - 4 i 1-2 0P?

www.hBsrty.com Huteliy, Inc. Regional Center* W.iiMIMfi

Charlotte-- Atlanta - Washington, PC - New York - ltouxton - San Francisco

-------
Envfronm«ntd Protection Agency Proposed Hai» IVMic Meeting

Public Meeting on 01/19/1021 Page 2

EPA COMT^f.'Tf,

2 I nTon/a irmcer
'"'intimity involvement. CY.

3 r,l€ EFA Region 4

i pence: irsc iny»#e; s >.* ~v

f-ty 1 •'r /.na M i- ";a N„k

h sr.sdlAl f . .» 1 < K.uufjtsrii
!>' EPA He^inn 4
T sylor , mi ""hat- i >.-i if.jv
? c^nt'dl, max v |.'c( < ji ,y •.•»£ n -|ov

1.1 {4 04) 562-957?

12 n" n 7 =* 1 I•-y
P t. j , hc i Ma uanf.' t
.13 FDEt

k i I 1 i an . r ^ 11 "V *d'r

14 (*50)245-8SJ«

«•- Atlanta - Wistitogtiwi, DC - Nn* York - Houston - 8m Francisco

WW S33-2m

-------
Environment*! Prot«li«n Agttu-y IIan I'ublk Meiting

Public Meeting <»> 01/198021 P»r 3

1 . . .

2 ("he presentation commenced at 5:02 p.m., EST via Zoom
h'elr* • •Tiierer.ee , ¦

€ MS. SPEMCSH: My name is LaTonya Spencer. I'm

5 the Coronunity Involvement Coordinator for the

6 Rnv; r^nr.ental Protection Agency for the Petrc-if urj

7 Ftjducts Corporation Sice, and we would like to

8 welcome you to our Proposed Plan Meeting on this
evening.

As ju^? anrr nr.'-fl, 1 ,-t• s<' n<->t* b,i<" Dy

par •: icipat inq in thin i o>-o» d i rn i you ate •*nn-~rmt trig [

12 to be lecoideil. W«: wj.ll u:I Ml. ll>jt ,1 inq lot

13 future reterenee. ir lease note t ha> tni being t ranecri rc. w* J-> >nv.* a

15 transci ipLioro st f itroLt ,

16 On this evenincf our agenda will consist of

17 introductions. We will also have the video, the
virtual presentation will run, then we will also j

r> have a question and answer session. The question

, u and answer session will tirst answer questions that

::i are put i» the chat room. If you have questions

during the video presentation, please type it into
„• ? the chat room, and also, if there's a particular

'M slitle that rieecws to ee addressed, pleaae put, the

slide number in your question so that we'll know to

www,huMby.com Hoseby, Inc. Regional Center* 8§®-333-2Mfi

Charlotte ~ Altai* ~ Wwhington, DC - New York ~ Hftueton - S*n Franciwso

-------
EnvironracnUi Pri.tmiinu V^n-no PropowU It an Public Meeting

Public Merthtg on M/liMlt p»gf 4

| 1 go back to that particular slide, Josie will xvid

\ 2 th ^estions and have us to go back to the slide

3 that's needed to be summarized or explained.

4 Also, at this point in time, if there's anycrv

5 that needs Spanish translation, please type your

6 name and your need for Spanish in the chat room so

• 7 that we can address you and so that you will have an

8 opportunity to have the Spanish translation.

9 After we finish with the questions arid answer

10 that have been put into the chat, we will open up

11 the lines for additional questions. If everyone

12 *¦ ul i please ensure that your phones are on mute so

13 that we can cut dowr. on background noise. And,

14 again, we will ^nrj up the lines when we go into

If> question and answer after we answer the questions m

i'.< the chat, list, It you have a VPN, it would help i:

;7 you turn it off so that you won't havt* -,•*(•.» H'-.it r„v t i.i- »t , i «?:.*• h K'-'A |

AI «!¦ > ; r t h i p c?.' , Ren*1.!,.*. Prr,]p':: Manaj'. r j

| 22 Ficha*.'! Taylor. Wc aln»* have Rc.r»*4,.t. P:roject j

| 23 Manager Harcia Nale, Also from EPA ve. levin j

( 24 Koporek ar i fciil -j-uteen, as well as our EPA

[ 25 attorney, Rudy Tanasijevich. From the Florida

wwwJiuMby.com Hos%4>\, Inc. ItpoMiI Centers 800 J3J-M82

Chijrlrttr - VUnta - Washington. i»f - Vw York - Hotstcm ~ San Fraacitco

-------
Environmental Protection Agency Proposed Plan Public Meeting
Public Meeting «n 01/190021

1 Department of Environmental Protection we have |

2 fiilian. Talley. From the Army Corf cf <•¦».*< vm

3 have Michael Grove, t

4 And also, now that I've done those

5 introductions,, if we end up having anyone rrom

6 media, if you would please let us know in the chat

7 that you are part of the media. If you have any

8 ail.t ; ,„al questions that «e can address, «, »m.

I 9 Also if we have any CongressionaIs or Congressional
• 10 Aides, if you will put your information in this chat

11 as weii so that we can acknowledge you and address

12 any questions you may have.

13 At. this time we are going to run the virtual

14 presentation. And, i,, af < • ; tk*; virtual

1 : s presentation is completed. we will answer t he
ques* > -iv :v * h- and then open it vr

1" add:: i -nai iens,

1 ^ (v i | 11 s-*::tati<_n starts,)

Ml>\ FAYIiO»< ; W<=>] -'-ni*-1 rvrryrr.i , my name is
,!D Michael I'.vylor, T am a PeruMia 1 I'tciect for

t;ic Envi„otmv r.t .»! Fr<_ tt_cl i oi A.,•_ r... y u Rr'.jior. 4
,• j I'mneiH r.-i i-*y " - vr" *'13* >"«• \.-V r. <. t n.e EPA" s j

. prop">s<-1 -1' in ,f r- r r-v I*rr. •» : u-f s )

M \~ri >r t: lv.n Sucwif aid £itu, vot:i^i: I *» ill ivfor i : as j

2*. Che PK! HxLt:, I

www.luieby.C0Bi Hmeby.lnc Regional Centers St0333-2082

Charlotte - Atlanta - Wuhington, DC - New York - Houston - W Francisco

-------
PywtiwrtWB ,\g«i« t"r«»|iw«il Han ftiMtc Mining
Public MrriingOn «!/M/2i2! l'*g* ft

I 1 The 1 ¦ i' ¦ .I""1 i) \r Kt it - rk< P'-ik, B,-nwird |

J "vnxnty, , I'll ttxplniu th« !•". story oi t.he |

< '?Lf«a!f t h«^ Suj>, r i'.rA pi-,-", ;ind hew y. >u can torment ;

4 .: u t.hi»* s;u-, y.vj

wi I l find tiiti- names and ;iumb»' ; -r -"'A and ;

'•sit- Fici i i.i "*« i" it M< <>i:i of Sr.vi * f iv« I

> >: ha! are M»ar,v j wi t\h the sit.1. Tr ynu need :

'¦¦i further infcriRar u~r. after this pr«#tw-iitat ion, we can i

:> i« !.at * h< >--tku i sice t*ror..- nutter pii-vi-ied ,

::: As r r. fn.c i o n, v.bv i t V > 1 -jtv! in

? li

» lemur ;itk Fc-rc Laudcrda-uvl M:nm:

1 i Tho ioiir.«r ia.'ili:.y i,% Ic-caffC .* cpnr'er i a rule
!, ; west or 1-95 off ij«tni>i:oke Road. The* yt > < >* ! \<

14 t his* f'.-.jure i n«'i i ,;at, a*, t h« ^pproxipu* - N.>ir.1a;y and
Jt h«. area irt'pa."u„-;i :"/> ? th-v .cvf.>*i fund s*

<»• itpptvvxiiuat-.I') , .-'over, a n-; j: ire, th ,

. ' mulr.ip'.f* warehr-r.a^H as ^ sf •>?age unity ¦¦>ur»jr,tiy ,.n

iH Ct," rt.^pPT"1/ T, fe.iStfi Oil rtiuuli^ ¦» ,

1") that have been filled in oxitft h •: -n>< of

2 0 K «txuct uctcs, The C'^tanuztated vi 1 dm I .; d*raily i«?si jr. r.iKfi th,« teii.i Supc?i fur.d

WhAt if Sup^t i undi1 p. - "i«j >t. ;h ir . >"¦' ;i

.'.S SPA tor s.h** r"B5>r«ti«xiw Envirot>re»r«tsi K»'Ap->ris4

>»»« tiswfn.mm llu»t>fw, luc Kfgnmal <'««crs (#0 Sii 2WC

rh»ri«(fn> ~ All«n!» •• WMtiWfjta. W' • York ¦ HnuMftn Nan

-------
Environmental Protection Agency Proposed Plan Public Meeting

Public Meeting on ®1/19C«2J Ptgt 7

1 Compensation and Liability Act or CERCLA. This is a

2 law that mandates cleanup of hazardous waste sites, j

3 EPA Super!und program oversees carrying out this 1

4 responsibility. Superfund includes both removal and

5 remedial actions, The PPC is under a Remedial

6 Action,

7 This slideshow is the Superfund process. Once I

B a site is discovered, the site is evaluated, which l
.

9 consists of a preliminary assessment and site j

10 investigation. The site is then scored for listing |

11 on the National Priority List. The PPC site was j

12 listed on the NPL in 1987, the next step is to j

13 conduct a Remedia. Investigation. We have concluded j
M the Remedial Feasibility Study for the site.

15 Currently, we are at the Proposed Plan stage. At

16 the conclusion of the Proposed Plan and comment

17 period, we will make a remedy selection which will

1.8 be documented in a Record of Decision. A design j

19 will follow the Record of Decision, and then we

20 begin implementation of the Remedial Act ion, which

21 is the physical site activities of treating the soil

22 and groundwater. Once the site actions are

23 completed, the site will move into the maintenance

24 phase. After all site remedial actions and goals

25 ait; achieved, the sit« will bt deleted from the NPL,

www.buseb) .com lluseby. Inc. Regional C'enterm t#M> 3J3-2UH2

Cbwlotte ~ AtUnt* - Washington, IK' - New York - Houston - San Frtndtoo

-------
kii«ironm«i< • . " t >><:< • »¦ vi r4. >n kurjJto ! * : ;
l l • v i ~. IV w,s;t( v i.m j aun ' i p;t?, wh i --h :
s incTunte the primary aim t .<.con&ry ctua * I

t? i •:• iiasjc;;- »-f npt.-ut wast« ir-si t»i ;•*; &tt*r !

[ 1

l |

' tival 'lonts. ?h*» t s, i > -iuc. ih-(s"> i v i* »>si s. ' u«' >

3 i loat ing van to v 1'' ..n r t rl the<> grotsr.riw-if-•>r >

, 9 •.locumrtnts and testimony iihow that men * fh:» < *. 1 I

IV "iri! lion gallonp oi w«.ir !<.••* :J wajs f«j- >,.• j h> 1

?hnS ' >. i 1 s > y i->r .

1'; j x f * w t • till photc ; 'I rf. ¦ ' > ul

Is a how what Lhfe? ciissa looked like i n 3 and >' l.<,

14 T»w • * •>« tial :sh< wcs U\e f't vt**ry kludge pit ;

l(3C.i»' i>:t- j.s cv-t 1 ir.«-d 5'"/ tho ot^r: hex A.1

it" |?i :t uiV'.l is cr.o w»rtf.,..n.r«! building aiii scvorjO

,? above*-sji "Jn.l st oraut- tanks, M j 1 < '.1 \*i«-* i dioa

1 it-jitcat a water body msch *n -<¦ • nr nolf or

1 i wetlachi, There w#h*. ••• iv i.«sw .v or

£0 bus! i fii-t;,'; r,i ai'I.a.i Ur , i -t i*t yv.".. \*:i "-X

^: The .suvr; *< >1;h Phnw u\ ^xpemcied t'.. l;»>^ry

22 si jci.jt* ,-.t cwtltn «.» ^ ' «?.*»• v Th*> 3^cr.?viaiy i

2"! b i L' ¦ , t o4 t-,. fhe noith • u vKv tviSH;y

24 p i r.. r 'y^s iv! the tl'.e i;c , vV«'j:' a-* <- •
£h 9ir.Ati>~»i'--r>. wanlanis, and pjraa Invoir iyat ioaa

I !

liu«i'b\ Ai»«> Htou-iiv. Ur Kcsiiwil Center* WKl JlLi 2D®

< h«rl>H(r Atlxnt* WaUiin^on, IX" - "Sum Vorb --llouslwi S*n f r«nciv:>

-------
Environmental Protection Agcnrv Proposed Plan Public Meeting

Public Meeting on il/19/2021 Page 9

. 1 ^ i

1 indicate that all these areas were eventually filled |

2 in and graded to allow for construction of storage

3 warehouses that were built in the 1970a and 1980s,

4 Multiple oil spills contributed to oily

5 contaminants negatively impacting the soil and

6 Biscayne aquifer. These photo,*? show some of the

7 above ground storage tanks that were on the property

8 during the facility operation and the conditions

9 that existed, There are obvious spills and releases

10 that occurred as shown by these photographs.

11 These are photos of Bay 261 at the Pembroke

12 Park warehouse. Inside this bay the floor is

13 purposely cut away in order to collect oil and |

14 sludge. Bay 261 is cleaned periodically from the I

15 lateral and vertical movement of oil, The viscosity (

16 of the material ranges from a light machine oil to a j

17 heavy crude, often a solid mass that is not readily

18 pumpable. The oil and sludge pits are located

19 underneath some of the warehouses that are located

20 primarily on the south end of the warehouse

21 property. These sludge pits extend to,

2 2 approximately, 20 to 24 feet below land surface,
2 3 This is well into the groundwater and Biscayne
24 aquifer, tfhich begins at, approximately, 5 feet
2 5 below surface. There is periodic day-lighting of

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-------
En»nunn.en«*l Pm.i.vIi. n \g«tcvProptiwl Han CuhlicMcrttng

labile Meeting on 01/19/2021 P»r»»

1 which is above ground The seepage of oil and

2 sludge i.njt seep through "he- cracks and around

3 foundations of coticr*-«, and aSBlialt, The structures

4 are more than 40 yeass eld with notable settling and

5 uneven foundations . The bui Idi r u>v-sk t-egan

I 8 in 1989» In l?1"'1, «n In^rirr A^Mor i-^D ro>r

| 9 Opei ii: i'' Unit 1, which is product n cvvery, was

10 signed. An oil ion system was ^f-tabliistied in

11 th* \ 3 ?*'. xiF latn t- ' ved by the

12 Inst -„i: <» vr. r£ a ir ir c.lurper unit in late 1**^3. ?

13 biot.Uu pft unit h> a vai'iu-enhanced oi 1 coilt-v-rion
If system rh-ir I ichr . non-aqueei.s pha*r

15 liquids, Thf- i: ic s *%.*;£•»-r ur.n operated • nt l i late

j 16 2012, DiirintLxs. ^ r,- i, approximate!y, 43,000

= 1? jai ion," ct waste .-'11 »hh collected. !'m i ent 1 y ,

18 prola^f ! ef.ivfry crr.t with oil ml looted

| 13 marr...il ly trci £xictu,_: v^'llc and i ::p :>s>~d off

20 .. f- Is, j i i %* ^ r, i~r,cC. t~ c ' 1.rit - - . . s.t 1' ; j ^ , "J 2 <--!¦>.* > ~ t

ot .npe-nt fra"€rial !>• Jrrpact :r:j qtomiaw.i; k; j

[ 22 Th^ s i r« i.i loc.it r-n in fh^ en?if. of mf liwnco, j

. 23 for gro-r4w.«tt, x aruwdewn i •>.•*, pt j nt for the |

j 24 r.ea rr y H-*. i-i: ual>* s I ' . «-i»i, Ti.*- *'»„•*. j; e, a . s i
| 25 *ppr*oc W.ir> iy, fjo i r .> ti: .» <»ast ct r••.tg ml

ww*.huM-tj\ i-orn ilim-hy, ln«\ kociorul Oncers 8Wt AM 2^82

Charlotte - Atlanta - W»htngt«i> IX' - Vw York - Hhumiki - Sun Pr»nriw>

-------
K»vironmniU) Proiet-tiim Aguic> Pr upward Plan Public Meeting

Public MfCling'on i|/l«B21 Page 11

1 supplies water to Broward County residents. The oil |

2 and sludge has not impacted the well fields that j

3 supply the local drinking water. The buried sludge J

4 volume in this area is estimated to be around 50,000 |

5 cubic yards, I

6 The primary contaminants of concern 3denti fied

7 on site are listed here on this slide. Additional
6 constituents are present at lower concentrations

9 that did not. add to site risk. For example, we have

10 polycyclic aromatic hydrocarbons, or PAHs, heavy

11 metals, PCBs, dioxina, and chlorinated compounds in

12 the waste, oil, sludges, and soil. The groundwater

13 contains, for example, Benzene, multiple chlorinated

14 compounds, PCBs, 1-4 Bioxane, and multiple heavy

15 metals, such as lead and arsenic,

16 This photo shows some examples of day-lighting

17 I mentioned. This is oil around the warehouse

18 structures and roadways. There's occasional oil

19 seepage at the parking lot and building foundations,

20 as well as around one of our monitoring wells. As

21 you can see tire tracks where vehicles have driven

22 through a seepage area and tracked it along the

23 roadway. We have been addressing these seepages as

24 they occur. These seeps are intermittent and do not

25 daylight at the same location every time.

www.liuseby.com Hutcby, Inc. Regional Outers 8U0~333-20W

Charlotte ~ Atlanta - Washington, IX' - New York ~ Houston - San Francisco

-------
K fitirj»'*-d I1«n KNk

I'd Mir Mvrting'oii il/W.HKI Pug*? 12

1 ti. rv f\n . t this • ,i < and sludge ivy®

/. > * . v,,Tif i»; u iv,1- i,< J <• in' 1fr phrt;i> dhowj

I $ ;ij»3 Jtrracu cor.di i ions at cu£f.er»?nf deptho , Tlit*

4 s i,t >* «• n*»i -at*e v-ety oiiy manes iai fro** gr.M.rvi

5 si."*. Ut *¦-i % '»«t and * t • rtt intst:- Iron B t>«t i.c *,0 '
I |

^ s 'u -;111 >. c I i-nt 1 - r '

; w.ietv it in-Sica^H a mere rat 1 .p ~ * i i .

H Inn phc 1 or. the tjuhc i„3 irr anofner i ' • fj-ilns wry low pf Ifve!:-; the sulfui .

•uri.1. .Sulfuric av> < *"•»« i ?* * * t (¦! »»>«•».. • n,:t, {

It,' pr -,<•>'<&* Our invest, ioat ion ;sK>v> t 1 .it sludge

, 13 4-|*.•«Hf« t ^aclird 'itpi |i,r> vt x4 r- !*¦» low ^rounsi

I aurt i n. ar« itr . This phot re shows how \ hu

„'5 si fvif' ; • bound tc the sar.d at r, , \ t -• > «

l;> The u- it.-iriai will -vj.} ir.ualJy loach !>om t.w.«

.7 ^tvunJwdtet o£ tfa* &iaym aqu.i>i . Because

; IB .-vint .iwiSti.irt h arf beneath t*he- site in lh<-»

i'> Biycayih i i j if •; i , r^;. to a j,..! vnt . .>! too

21 iU/it J, U'l', T.iqtHf irt' till .'Jlkj'h CJ"! OUTiJOdt

n«.arhy wn!. i tieicR, Th«r r.'-ni-amiriarii - i.,sr- a

22 por*-ntJ-*1 risk to local inimioipai we] s fields whioh
2} draw wator rliom tho yi!.»cayne aqui!oi and rorvi >¦
14 *- i i vm.(- ; *¦>',, ?CC ttsid-ut •- ,

"h s •] showu 1 tw (El r < a ;• i» o < • .

I ___ ______

wwn.buwfc) com fliiM'by, Inc. Hegtonal Center* (MMI-.1W-21W2

Chariot*' \!lin<« >Va*htniJl«^). !*' • V» Vttrk ¦ >I.iu«8i*i S*n I

-------
KnviroMtenttl Protection Agency Proposed Han Public Meeting

Public Meeting on 01/19/2021 Pap 13

1 the nearby Ballamdale we 11 fie 1.d, which is, j

2 approximately, half a mile east and along 1-95, The

3 site is within the cone of influence and the

4 two-foot drawdown, of this well field system.

5 There's another wellfield located directly north of j

I i

| 6 the site, which is the Hollywood wellfield. The

? Hollywood wellfield is, approximately, two miles

8 north, A third wellfield, Miramar, is more than two

9 miles away and is located southwest of the site near
10 the Broward and Miami-Dade County line.

II This slide will give you a conceptual site

12 model of what exists at the sit'1. As you can see,

13 th<=»re are two distinct sludge pits whien have been

14 filled in and graded over with the construction of

15 warehouses on top of the waste material„ The

16 contaminated soil and sludge continually impact

1? their surroundings and the groundwater for migration

IB of this waste. The PPC site is underlaying by a

IS series of carbonate and clastic sedimentary unit

20 typical of marine deposits. The depth to the

21 limestone varies across the site. Groundwater is

22 often perched or the sludge. The surrounding area

23 is highly developed with commercial and light

24 industrial operations. There is also a significant

25 residential ai^a located to the south and west of

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EnvironmentalPratcrtion Accnrv Prupuwd ilitn f'tiMic Meeting

Public Meeting on •l/lt»2I f#fe 14

1 tliis facility.

2 Our Remedial Action objectives for this site

3 are identified in this slide. Our objective is to

4 minimize the migration of contaminants to protect

5 the Biscayne aquifer and the drinking water, We

6 want to prevent leaching of contaminants from the

7 subsurface soil and sludge pits to the groundwater.
9 Our objective is to prevent any human exposure to

9 contaminants in the groundwater. These objectives

10 also include tn* p»>y«:tirr t« t n>an .ir :on ->T

11 contaminate ir rh«; .K>i;Ur. Ir. ~.,-i

12 objectives iud«. y-tcvcnt ir.g Lun.-.u» cxuosur. t.»

13 contaminant's it; th* Mirtact a\d ; «m*t; soi , uu

14 the former facility ,CBs#

21 v^LrtU, semi-volar 11 p compounds. PAHs, as I

22 ment. Urusj earlier. The site is within the cone of

23 :n - for the tiearbj Hallanda..- «- . t t«-l 3 Fh«

24 Biscayne aquifer begins at around 5 feet below
surface and is, approximately, 200 feet deep. Soil

ww.laisftij loin Huseby, Inc. Mcginna! {'enters HUO JM.i 2U82

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Environmental Protection Aj'inrv ITopti>«l Plan Public Mating

Ptifclic Meeting 1*1 Ol/lffflttl ' Ftps 15

1 contamination in the former sludge pits are

2 impacting this Biscayne aquifer,

3 EPA conducts baseline risk assessments as part

4 of the remedial process, A Superfund human health

5 risk assessment estimates the baseline risk:, this

6 is an estimate of the likelihood of health p» W-ms

7 occurring if no cleanup action were taken at thr

8 site. To estimate the baseline risk at « iup.-i :and

9 site, EPA undertakes a four-step process. Step one

10 is analyze contamination. Step two is estimate

11 exposure. Step three is assess potential health

12 dangers. And step four characterize site risk.

13 To address the diff.>f«>nf font-nmina ted Media,

14 EPA broke out the various J-M «.* Contaminated

15 Me.ii t '-r CMZs. CN/ : It £ * t th* Unsaturated

: , wi-ii "i is? i-h<* T.-rn -a , r»-!-[ t > ma. law soil from

1" 3art i."" ! >¦ ^ keK-w ix.ui.c This area

: :j. iaciuJey, uif piv.-xn.at«sly, 11 > ,*'p; ujI Ic yards of

t) soi1 .

.'Mi' J Li! comprised >->f t hf Mn i n it >urce At ra.

*1 Which J---", »-is,-u>f,t tally, tin LWk covered sludge

„ <1 pit wi.cli ''Xtfiid iron. i; r, | t-H, teiw qjroji.d

? "* surt a vp. :?me -t . *r t :ik '„\MU „ if,,

.M ippi'v'.xir-] y, n.003 .'ubii, yitaa. CK7, 1 is

1 * ^ i Lin* \A' tho slide.

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Viiviromtuni-d Agtwev Frflptwtl I1»b l\ibik Meting

»MM«- Mrt* in put OK'NCMll ' Pi.ft» 16

1 ; w>.i11 •!«;« u, «<•(•> Main Source hrn^, pits. ,is

2 shewn with thf tej ,:Mshtd 1 ir;<~ .

i i

* T*»t • 1 i v »;•«,- r'-iv * \1 : i • nr ami .iv-iti=-d Media

4 Zona, whi'"t > - ?! o fx funded j-lumc- * r>r cir ouridwat, «r
•i cDn.ami nat. ioi'i The arc,iir.dwaf.*f has d-ster't ions :-jr

! i

>i OOntMtfiWff Ot «,•(?!IC«k ti 'k «i UtpCi .»f !•> >\ > I l.«w* !

*"' «ui: t-v. Mi"> I'tenr - tying the art*as and !

t» contaminated fiv-r t»«r« i:i" r invest iqar l-.m„ EPA will
~.-i select a tr««tnier»t teredy for tbe, corit^Timants E?<\ !

»-v-i! the i i ? f wtvf.r r i j , ^i:ase:i

is upon nine crit,te» , h tiit^d-dd

12 - i «* u is- ^ eift'.inc if th« remedy i;? pr>,.t active oi
I '¦ * !tc }\l\ and eftv i L'OlWMht, ** w« *. '« as iirtkifig

"> 4 -rare it is crimp I j ,sr-t- wjth Applicable >,n kr-tovanf a«d
1 Appropriate fteqi; 11 f>mei;r. s , or A&Mta, A balanring

:'cir<.>ria fellows wicl I;.*w i-iift ivs > j. *• j«, . ai >y
<" '. c no -1 • t T .i!d £"h*" 11. - f f-.TTp , Ko» w- u I i'»i if be

i imp ifrr,flntt--d? Whot t [o* ot Tie r*ri«Mv? The

If.' I 4.'* : .¦s,' , i, ' thf: Mc-diiy liv.i i>t > »¦ s i \ wwch

i« thttre at at* accept «*ncv ->¦ - lit. i »~{»,~»> I y ¦ uid
>: i rhi^Tf -r.nmunir y ar.re- V This *m> »i,iy .-on Rtr.it

j>'-r i "-d <-ill r.elf* pi.-vidt? the r^raniuni' y a:i
J;.s 'uniry f c r ^ 1 .;af j;.i t !tf ^ j-cst'd s vim'fly

..M Tne », i *-x n.-it {k were .>i»- ; - i

.d. w vera I areas or, f»it> Tht Ratabro Sob .«•* ''•¦n- >,ir«

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Environmental Prott\ (hju Agi-nn IVtitwu-d flan )*utilic Mwsting

Public Merti.ig .m 111 /lf/SJ.21 Pap 17

1 i r, an area south of the former process area that

2 includes a small area of subsurface soil under one

3 iao.0i.ie home. The area that is impacted, is from 2 to

4 •> feet below surface. The contamination is a result

5 of the oily material migrating from the former j

1 6 process area. Cleanup alternatives considered fcr

i 1

f ? tne Contaminated Media Zone, CMZ 1., Unsaturate':

a Zone, which is the sh.i. are shown in this

s!:J«. A no AJti^n l.' /.-a u-u,

10 k» ib: »r i«**n. nit«1 t i^rrr* i treatments

11 wt-T-" conni-lere 1. Thin alr^rn;»tivo a'11rrpr»;S the
1.2 doil Ju*.Ti t3( approximately, !> *>:><-t l.el'-w lan*i

surface,

14 Cleanup alternatives considered for the CMZ 2, J

15 which is t.ie Main Source Area, are shown in this

16 sli-1-. A no action to excavation,

11 s' .ifv ; • :Mtion/solidif ication, and thermal treatments

,18 were also considered. The Main Source Area is

19 predominantly the buriea siuage pits that extend,

.20 approximately, 20 to 24 feet below surface. The

21 cleanup alternatives considered for CMZ 3, the

j 22 Extended Plume and the Groundwater, are shown here,

J 23 A lie--i * i »»i, h receive I y ami t ovist „*;y>st -to» «

4 carbon in; , *f i<~n with r^rri^rr. r momrci

[ 25 natural it Umadt ion alternatives ver>* com? idiH»«ii.

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Knwr JYopnwti Plan I'uWk Me«thiK

Puhltc M«>fing"«ti» #1/1*1/2(121 t'ngv iH

1 < rr > s vttH .-ont .wunanr on this sit*-,

2 i.' ,:>n : r, t < it u>;nr r,«-!tnc) agy will nt;i *-sa ¦?, the

i ;i;r« ccnr.sminantd, :• ha. »' > w* trust- >; \,ViuAte so
A many te-.-hr.i logics t.h.v a: i*fss ,sll ror." arnir.'int s , I

•" ai: conai'it.n^j. :

: 3

r. i. >tt ». it: ves ttitjaa th-.i';

. ' ! >¦ KUv'h a? ' <'.r « l«- ¦ r> H *t>' ,, i\ h f !

rt In thv v '» Ware FarH 'his -notion will

'' * i \ L A~ a V* * V ^ ^ i \ vl'Ul' & t. ,1C Ti t.v X ^TU».'Oi 1 .-it ^ , S-^TiCS

' > ' !>>:* •> 1 m >; i n t .1, i. * !,..;] ' »> i.>rv>\-j and

i 1 ,ua.i;k? i 11 . i'r. will i,r>Y' i\ e .r-rif ">r.u y ['"i^Mfiun

;? I

1,1 *" si > „ zupants „r- i ?••*»») * .> nova zh*t t r«i ler At)d !

1« »% -ct- <>» ih ' . ..I'Jt-i iit',41, h. Ti'-r -XL:iivar»;?d ». .j,; will !

14 \> > -.hipped off s» j f«» t-c a lanfif .1 , 'she noi I m'.il be
1:.- ,-:*.'.d ar.d the pi :>p< tty t%c:or*<3

1 ^ .C'tv-i foiwrcn ivc -invc<.

i >* -, j "i •• • !¦ t\\<- wa r~r)Ut-, Pi L> i i • loim i it i-n) aiv.i
.'1 -j i ;spof-tai of f '1 rti-"ra; .-Jlr.-ja <"vn«i

urs^sil l.asiricMjs. *•. 1 ' * >«• ! -»nd

24 : tr i, • ratfrd , ar;.; > «¦'. )u; r»?ni^r.*, t;>; '.he-

,}S xv?nr^i .>-« and ]*af,u. ? . »| „t .t r,h«s«? war•>h-;.us«fj

L _ _ J

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Environmental Protection Agency Proponed nan Puliic Meeting

Pu blic Mwting tw 111 /t 9/1021 1 9

| I will l.f ,-tiid; eaael wi-fti Ht-A, t he property ownes.«>, !

2 r (it- J? on as; : nhi v\iua I basis. Keep in

3 niai ' tu* no 3iv>' will take pla ur'i.

4 .-sit- * ^ le.si^n is :;mcL-.i ^ i, wh". „-h is aKur l w;.
y».>a: m : i :cu Lli«s Record ->f iJtviiur; -Approval . lh»' ,

1 & thir-l '-ornm-tn a 1 ternat i vp itiV'-.l v.-*k h shallow s< < i 1 !

7 eivM'/ai ion 1 rom undertKarh nix buiMinor;. 'Hk-cc ar* j

8 hiqh: sM'.i! n>l in yell w ajhI t tu» i->I«n i« for the a-? 1

9 s( u> * • rf-^ain in place.

1 10 \ , r z-.tumazit t.< rref«tred

| II al~t*.-;u< • I v. • i, Due r.ctil" sr. t h<-» Saraboo Mobile

I 12 Koru- p-i? < is proposed t a tf .w w«i nnd the pc*i 1

*. j uiiderrit-.r, h will he excavated down fo s fe^f .

14 BackLill ami .grading will '•-of-ur afterwords. r: .he

15 iei!ia.n;;H w.nk will be on property that it< zoned

I 1* c^ntik" .'i <1 .';n1 atrial . iewiy w.l«. ircl.^e a

:7 v«- :>r relo^at •, r-n t o « r»c- impacted

[ IS terian* ¦; in t;w five warehouseldcutif i«_?c Zci |

U' denial 11 ion, whivh are pic! uie>i in f.ianue. |

Demoi it i ,->n r>t f hp five sh ru.-t ih'ps r^quir^ri

8 ir'i'o

waste cinrv-f b»j addressed

C'i t a fci'.k the

,.G i

L ,llji.,i.s in t* 1 r^cc;. The t

- 1- two feet of sell

which

is r . -• <;( p i in ; h<= tan col

¦r, will be exeste*<

arf

foil i iy sr .it ; 1 , zaticn

ai»• i .5 i i '11 f »catiCr.

:: 4-lie

remaining yub.iu; fact' aoil is

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Environmental Prut «ii«m Awnitv Proposed Plan PiiMk Meeting

Public Meeting mi 01/19/2021 P»ee 20

1 Under the buildings, which are pictured in

2 ytel 1 jw, 5 feet of soil will be excavated £oi

3 o: £-site disposal ar, i backfilled with a i..wabie

4 cement-based material. The six yellow highlighted

5 buildings will remain in place and not be

6 demolished.

7 The final action will include ar. interim

8 short-term multi-treatment groundwater system to

9 prevent further degradation of the Biscayne aquifer j

10 from the oily soil and sludge contaminants. This

11 interim step will help determine if the remedy has a

12 positive impact on groundwater contamination.

13 Here is a suiiniary of the costs for the

14 alternatives evaluated and recommended. This table

15 includes the conraon elements, estimated la; t lair, j

16 v.-* I .u;. and estimated relocation cost Th« - r i t ctc-d

17 t -r cost for the Proposed Plan * £ . . n.

18 NV.w that the Proposed Plan has beer. mo< -in.'.-iblt

19 r hot o io a 30-day comment foiled. After , }i«* .•orament

20 pot jo-n in

22 i h> se.rcrd of Decision, A "t-ccrd ri r-t"" <•,

23 explains the cleanup, and it also targeted to be

24 completed in mid-2021, and will be a\.*i. .j-it u.ixi*

25 and at the Broward County Public Library.

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Environmental Prelection Agency Propwed Plan Public Meeting

Public Meeting on •WHM2I Page 21

1 Afterwards, a remedial design will be prepared,

2 which ip typically completed in 18 to 24 months,

3 Then the renr-riiil action . , ; > 1PA will let

4 the puKir rice the Record of Decim is

5 signed and oerore the cleanup begins. j

6 MARC 1A MfihE: Community participation is ~
; 7 important part of the Superfund process, it a. 1

8 the dublie and EPA to communicate concerns and

3 issues, as well as r-r.-.v kit- a ar- it. la ;ilitate

10 t.v- pr:tprsed a: 1 deci s , or,.<- t h it i-r Made for

11 ih( that irpaetj rru <.*< ipotu 11 r i -»n you

13 mail, s^nd art I, cm r,i I I uk Out com

14 int.-x-ni.ition is on the next el id.-*, Thic IT'* Proposed j

15 PLh, j j uoblisheJ jnJ you can send comments to us

16 mi' -' /< r»raAry kth, As part of the process in
1? pi'iv.'iinj tne public an opportunity to review

f 18 kcurr.-ntj a.*ii intimation, the Administrative
If i. ,\x has t&ci. established. The M. can be

20 v. >-*Wf 1 *: Pr-,wa-1 ,\-„nty Public Lii • -t , * d on

21 ETA There is also a significant awount

22 of inform*•? Ei'k

24 in Atlanta is currently unavailable for the pubiic
to visit due to the COVID ]idiklemi> •.

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Environmental Protection Ageoej PropimJ Han VuMfc

futile Meeting (« 01/19/2021 1'»!«»22

1 MR. TAYLOR; I want to thank you fox ycu< : im^

2 in allowing roe to present tine proposed plan to you,

3 i Ji.i"'.' r: ' it ;r,

4 Ms. siF'ENCER. .it thiss t im» wo are n.-'iiKt t.o

5 open it up for cjut^it i > >nr-, dr.r>i<-, >ud wo t any

6 iJUCiT i >' & 1 T< Lht k ll.it

7 M.v TORRE:-; • i'i T~r>v-i. ; i »>r>- v, i ~ -e ;i -n

8 in t he ."hat It w i r. twe -far;, qu» Tt;on, it wai

9 Wh«>u will you km .w wbilh l)Ui3d iria^ are going

10 and wh*'* will *v t in-i c..t fc-i *b; *h plan you

11 are going to use?

12 US, SPENCER.: I think that's for you, Michael.

13 MR. TAYLOR: Yes, I'll answer that. Once we
1.4 receive all the comments from the proposed plan

15 we'11 compile those and include those in the Record

16 of Decision, and the Record of Decision will be a j

17 final decision document. At that point, it will be

18 decided, if this proposed plan, as you've just heard t

19 the presentation., or if it's been noaitied based J
.•'1 upon, the comments that we receive from the pwciic or

21 ,-.f Fl.-*idr. ar.1 it nay be menu '* -i so n

22 Recoi.l *.f Pceision will be the final ito:: sion

23 document, shows what structures will ultimately be

21 demolished, but just keep in itinel, all of the j

evaluation of technology, the treatments, do include |

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Knviro*m«ot«i Projection Agency Han Public Meeting

Public Meeting tin •t»M2i Pip 23

1 the five buildings that we identified. And our

2 approach was to minimize the number of buildings

3 that will be affected, and these are the end

4 results, these are the minimal, amount ot buildings

5 that would affected to accomplish the .jv dl t; that we
S have for this site.

7 IS, TOtRES; Thanks, Michael, We actually have

8 another question that's been submitted, The

9 question is:

1 f> Will piv-r.i-ncr ,-t !»*H excii;ne a Class D

lanuf.ll .i Al.--.- hew will the gun range

1,' in tn? i.>m I atttvr. r li— p i .• - * rr ?
I < MR. TAYLOR. i*>n the POJ qnostiex l-'CHS htp

14 present. they ajv vt>r\ l.->w l».-vr>ls hT-t w» '11 do is
,once 5-.1 '.v/ar^d, y<*n: ] >. atalytls will be

1 pert -r\ * h,v rh h -; . ar-' i r w. i 1 be

1? u>i you

2 '< repe the f.a:t i'm:t rru -v:.r ' nr .r"
21 MS, TORRES. ..lute. It" i,.j i i:;

2/: Also, how will the gun tanue in the building

I .• affect trh«= rr\i' t'5

24 MR. TAYLOR . the qui. r-inae luildiny is,

; 21 if you see o;i ~h<• ; ^sentatiui,, if actually the

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Environmental Protection AgencyPYopoird I1<»« labile Meeting

PnWie MMii| on t»VI«2#2t I'age 24

1 center of tb*. r.itr-. It's on t c-p rho primary and I

2 potions of r h* secondary sluu> -» pit i:- of all th >i
.< t»u ti 1j , » r»*« i;« the jih st .vt.' ~ t ! ani

;t wouii r-• rv q.-t arr^ss ' " "

5 -.oil ani r ht„ n . uo'n> • pife-, which * ht rwn^r; * y ot th^

6 dHpth of sail dwwr It 24 feet It. ui. tit-; at-di h the yuri

7 ratvje buiMin.j.

8 MR. TvRRF;-- • AT. t laht . Gr*M Michael.

9 MR. TAYI'.P . The!*- a: e twe lal photos of the

10 f-1:^ that «nc* **hai* ti» .-rtc. lie in 1963 and

1360 —

12 MS. TORRES: Great, Thai* you rr.i that

13 response, I tit l.riw another quest km h> ic It

14 says:

15 Do r.he ^touiftatfr impacrr extend to the

right-c £-•*«>: !

17 MR. TAYI, k; i *rt the groundwater I

18 impact #.x"-*nn* -r rr.* i ighf ^"-way. Could you I

19 explain what' c yvut ion?

20 MS, TORRES . U>t u«- see if the fin t t, : c i pant
l-i h.-iB moi p to aun ?<

¦3o rhe nr. r:» of Ti Asportation

i ujh- • "A - ^ay Pembroke load — j

^4 Mx . TAYICR: It »- x i - ¦ i ¦ < 11; to ?er,d>r oke Road, as we

::s'. i .1prir i t i »-d to r|-< north . It yo'i recall the

t'tiarlotlr Atlanta - Washing.>n. IK" - \p» York - Houston -Sim Frandaco

-------
Environmental Protection Agency Propmed Plan Public Meeting

Public Meeting on 01/190021 25

1 yellow outline of the property, and there's a red

j 2 line that shows on one of the slides the identified

j 3 groundwater contamination --

4 MR. TORIES: like, if you will give me a moment

5 I will pull that slide up. Just give me a moment.

6 MR. TAYLOR: Okay, I don't recall what sLuie

7 number it is, but it's near the end, j

8 MS, TORRES: Just one moment folks, just bear

I 9 with me. All right, I think this could be it,

j 10 Trying to get the most complete picture here. A;i

11 right. Michael, can you see my screen now, is "hi.--

12 t "tup you wiru thinkLnq of-

1"? MR, TAYlop: No, i f ' r« ciii > with the

14 i iiV'-T.r i jat ion, it shows a hvavy t < d line, it may bt->

15 -j t hl.H >, i.t-,

o Mi'. 1 Jk'KL'c : One T.nn- r.f . : up •. i~> A;- j

tiyirn r - ravtqar.fi tc tn<= e I i.> T -.r K y.vj Mr your j

13 pat i-:-uo<-.

19 MR. TAYLOR: The one you ; u.st wi-te showi tiM<

20 with i"M'/' 1 .md "A, t he 1 iovt- it 'the rest one fWow
„n that, tn«i next. one. That * e it". The* i^d d^f-h^d

tZ line, : til;- i;\ the CMZ t» vd.i.h 1:-. the ^ivur.iwdrKf.

«' ^ Ar,d rhls r>o1 dar.r.ej lire sr>"-w5 vhu( wu have

,.'4 irierit i r ><,*¦! thr«-io:r, our ir. hje,' of groundwater

.;!? centum; u.«t 10.11 ana dissclvt fhu u.:t deep as 40 feet

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K«w«bmmh»1 PrutMCtiwt I'rupuw-d I1«n Public Meeting

Public Meetingm #1/1M«I I «*e *

^ SOX triCf;- , !

i; AncJ 11 i « * j Lhli, i h,- yt « bouKiai v * l.-> j

i-'-irt * ,sc i'.u Rr.ac if- to the nori'h ?'>>• \« > 1 ^ :

4 .irk- K >•*, Keep in itiftd, sC cor ft" Itxciatnwur an>!
.-l.''1 it- * x' T";i>,-nr t , »¦> % i 1 to ;t<;ai t > wn-s,

C iji -ttri'dwiii-.ii invest .-cnu. I •s u- y ):.•

7 k r,e in'fr.c • •- oCit.' nu -it r ion, ot v-rntrffunarirs

i) bc-r'S4;i«- , :x ycc start srnrina up th*s b>-' , »h; r ;•

5 sluJcjes iHer« uw> if it lea*.* of oont-a:r.iriant.5 and the •

.*i Vlri uv„"ui I'aivy :.lw. <'h^ reason for ixv/iiiO

11 an jriVovirr. metier, qtc-»:ri4 water cowponen*. to nun:m js*

12 furihtii .spread o! cotX Ami nation v ; I s

1 ¦' t'!«!>•»» i. »ii,' c *t- * iui the north. So at this

14 ¦ »"k i' nnr "•InioBi" tr< Pembroke Road, as w#>

i:> ideiit s r . * •< , t.i t additional inveatiaat ion » { I .,»-
: c 1 «lt,« i Ut« -¦•c: t. work.

1 1 MtJ, "K»Kf.Ei-1 A1 ; right", Great:. Thank you.
., 8 Mich^f! drr.'r think ¦*<:¦ have any ad » *" ia!

15 qu.-';tr 1 or.:>,, .r.l'.-** that participant 'ut

20 aV!fclt:J !. < :-\t * J i-.-K ,ft tX-flSHeRt Wfrt I. . > I • 1 isui

.V: "ur. r •• Av-r-ry^nr1: > nir.k, yo.-i we arc 3. *,,-,5

22 v.o qo tv ; 1 .•nyvrx- huu an/ ether quest 1^ • o>\.

23 ,"<• 1 t . t cut Ic-i.t-, f. s.ub»-~. t h«*r.

24 vh« >rha;, , OtfiC-rvrisc , T'iry.!, site Kcjv^x /cu

2 3 would 1 , \ -m • i 11 v folk ^ 1 Lir.mi.t"«¦? r.h^r.is#-1 wf ;

x«*.hiiwh mm lluwt»j» lee Ontcn WW-Ul 2tW2

rhmrlellr • VtUnta \V**hinfU««. iH' <\rw>'«rk I (ou%tiHi Sin Vrmrvmt

-------
Kn virus meat •! Protection Agency Propwied Plan Public Meeting
Public VJerting'tm

1 MS. SPENCER; Yes, please go ahead and unmute

2 the lines, if anybody has any additional questions

3 we will open it right now for those people to ask

4 their questions. Don't be shy.

5 MR. TAYLOR: Does chat tell me 1 explained

6 things very well or totally confused?

7 MS. TORRES; Me are still accepting questions

8 via chat if you don't feel comfortable corning off of

9 mute, feel free to submit your question via chat.
10' Or if you are having issues coming off of chat I'm

11 happy to help you.

12 So we actually do have another question

13 submitted by chat. It's;

14 What was the outcome of the air sparging system

15 that was onsite that is now demolished?

16 MR. TAYLOR; That was a system that was in

17 operation ill the early 90s, mid-90s. That was

18 replaced by the bioslurping system later on in the

19 late-90s. That system did collect, approximately,

20 3,000 gallons or so of oil, and it was replaced

| 21 because of a much more efficient system, bioslurper

I 22 system was put in use after 1997. So their system

| 23 that was removed, the state of Florida removed that

24 two years ago, and that's no lonyer on the property.

25 All the old equipment has been removed now.

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Environmental Prolfv:iun \j>cne> l¥i>p««wf I1»n ltohlir Meeting

ft.hltr \ta-itng on 01.19/2*21 Page 28

1 M;-. TORKt.S j Ml light. Thank you, Hi -na.*. .

2 Still h atim for additional ou<«,:f ; .-•!*. s in, the chat,

3 Folks, i r >v..„ vtcuM like to to In. •ur.r.'ute yrut : *.;i ,

4 '-"i v»>u can vrit.tr .i tw ssage int.* i hp ^ikI > w> i "

5 ask ( hat

8 ad-lit it n&l quest j . It 1c »>>.<» like a an* >nc is j

? i'lavm ; is?m- urni.t • n^, lp"t w 55.-»-> it I car nelp \

8 them out. All t . jl.r Let ne *»v , o-m y-vi ri-* * r

9 now?

Ml. BUCHHE1T: li. I can talk now. Quick

11 question en the what type of water system, or what

12 dr y< 1, on the water treatment uui r.n thi>:

13 i»»>uld be for the disch«u\ie cr.teria and,

14 k 7 r\«i v.*, tup*" ii 4 r^atrnen: o{ < f

i i- V': . cPEN'.'EI- . A'i : 00 /.a y . -* >* <- y hit name,

please?

!1 MR. BUCHHEIT: Josh Euchheit, Env;rucou,

1 ft MR. TAYLOR; Okay. Now, the groundwater

19 treatment, that's going to be an intena act i r,;t t h r

20 we're proposing. What will happen, "tire ~K-- -

21 and sludge work is completed there w;.l r<-. <1 .1.1. ¦*

22 time period of, approximately, a year to /***• ,uvl a

23 half to assess the groundwater and see what the

24 conditions are. We hope they are greatly reduced

25 once we remove the source material or treat the

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Environ meat*) Proliftbn Agency Proposed Han Public Meeting

!*ublir %feettmg on 01/(9/202 i Page 29

1 source material. It will be a multi-treatment

2 system since we have different types of contaminants

3 of concerns with the metals and. the chlorinated
; 4 compounds and the PCBs, et cetera, that one

5 treatment will not address it. So we'll have a

6 multi-treatment set up. And in the proposed plan it

7 goes into more detail, but what it will consist of
IB is, approximately, six wells across the property

j 9 within the yellow outlined areas that you see. And

I 10 it will be an oil/water separator system, a

11 filtration system, a pH adjustment, an infiltration

12 gallery. Once we treated the groundwater to try re

13 inject it on the west side of the property, and

14 that's the preferred method. It we are not able to

15 install an infiltration system, then the alternative

16 will be either a PoTW or the open lake to the west

17 for an NPDES permit. So there are some options for

18 post-treatment of groundwater, but first we are

19 going to determine if the actual need for

20 groundwater is necessary after that, roughly,

21 18-month period of soil and sludge treatment.
2 2 MR, BUCHHEITs Okay. Thank you.

23 MS, TORRES: This is Josie Torres here, taking

24 a look in the question queue in the- chat and I don't

25 have any questions to add. Folks, remember, you Cdji

WWW.huseby.com Huwby, !itr Regional Center*. f*KM33-20W

Charlotte ~ Atlanta - Washington, DC ~ >'»» York - Houston - San Francisco

-------
Environmental Praterin«n \r(t,o !Vi.|*.vi-«I Han PuWif Mwting

Ptiblu Mii'itne f"> Uli 19/2021 " JO

unmute yourself and go ahead and ask a question.
Let. me know if you are having issues unmuting your
phone» happy to help you cut,

| 5 any questions after this is cv. i y--u r*.« email

: 6 your comments or questi.-.i.s r~" M: or

; ? Marcia Hale. The comment period doesn ' t *«nd until

8 February 12th, so if you don't thirs ,->r *»nyt h:R*

s 9 today or this evening, please feel free »»:naLl to

10 M,ireia i i Nike Ait.l «>verythiim that's been recorded

11 -..jay ; - U> a jv rt • >! - r.e !- • ;ponsi veness Summary

12 rn.it „• ; r.t - thr h>:, -rd of 'j. ".s: m. ii -

i 13 qivf a ft w niL-ie ffiir.uti.:;, "'ust" in 'Mso anft> «iy has
1 14 'u,'5fior;?.

N'S . Kkf*K,?; W>-' a rt i;p>. ky h i?i *pi» ,~r i ,r>

16 in the ci at,, t quwt i »t ub^uc 11 •» m,»p sp«>.'.f .illy

17 that we .itr i.Htkin.) .*» »>n t.h» «j*. t Jc Ir • «

1- To . - >t I---", i i>\= ?t;i;se ar-'.js • .is:

19 beir..: mcr.i" r* i afrt » t excAv ,i' : t

20 This p»»rr»oii comment a t hat I* ho ir buiidint) ia in
1 di the *."•? .i-ft ,»t thn'

22 MT. . T h\ '„uk \ fP " r > ¦ =»; <1 ym: Wl>, v wi i. I

23 be involved, keep in mind, once the soil and sludge
2% is addressed, a lot of the r.or.i f .:>r ing wells that we

currently have in position, those will be removed or

MS, SPENCER Also tnit ^ if y< ai think of

Huseby, Inc. Megioital Center*
~ Atteirt* - Washington, DC ~ New York - Houston

~ San Frsocisco

W# BJ-S®

-------
Environmental Protection Agency Propmed Plan Public Meeting

Public Meeting on IJI/1V2821 P»ge3l

1 destroyed, because of the soil and the depth that we

2 have to reach in some areas. So there will be new

3 wells that have to be installed in some areas that

4 have been affected.

5 Now. the upper left corner that you are

6 referring ro, that* would not include soil

7 excavation, so there will still be some wells there,

8 le would be monitoring the existing wells in

9 addition to installing new wells to get a baseline, '

10 if you will, on what the conditions are after the

11 treatment of the soil and sludge is completed.

12 Also, I i Jtsr want to add, you know, I want to

13 add to everyone, "
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. Environmental Protection \flvni-y Pr.tjw^xl llwi Public Mealing

Pafciic Meeting on «MW»2t P*feS

1 question in the chat .

2 So is it only tu;dings south of Ninth 3trt-<;\

3 fhan. an: i j> n t.cj t.- I Lerncvei, : fining :i<:a th of Ninth

4 Si*reft -- '>r l°th Kl i« «>t , ~x-'u-u- m<--. are only j

5 I utidings" fex;fn >"t l«rr. .5*vv»et to be j

6 i„ Ouw i- UK ,i l:h<-*k" rhe t i\> cr*rn* '•->< »r»-l bu* . 1* *n§m. Tnat
i wyjld -Afliir., te a .?i- -o, viuu.. i .

10 MS. TORRES: Is it later in the presentation?

11 MR. lA'tlf-R :t w; >' "owe; 4om in rh* slide

12 y< - There yr „ c," ;

13 Mi-. Il-PkES- if wm3 back Hvt*. that last |
I fk. 'iMl/.tR- I *t now w- can »«»• t h < s. |

15 thi pre Lot i •= i uth .-If , b<-"* ¦ »• • r ' >4

15 small, t ut it's pout.-d . th: '• *1 , As you can

17 see, a]l I !;<* UiiUfKnati that Soaking at for

13 f r,~ I * f ion u. r. ci and they do fall

19 i,th ol 1 ' t :>ur ~n "n»-¦

20 Pembroke Purk. warthi'U:!" pt op»_«j t y mil one en Kolsey
.'I { t J'fHHty it '»st AWliUt »r.4 •"*.« *C>; I.'! St.r-f' j ~ - h«S
12 fir righf ^ ¦tn^r, Th.-ct. ,-rf t«,- : • v- 14"1.4a -..'..i*
2 3 IjII irif • t tu. demolition category,

24 The yellow buildings, again, we're proposing

.,i:s those remain and excavate underneath, since there's

'liarliille- Atlanta - Waskhtgloo, DC ~ New Yiirk - - %»< Francisco

-------
Environmental Protectmn Agmcj Propwcl Han Public Mvstfatg

Public Mwttog OK •«

1 much shallower contamination there. If it is fvm.sl

2 later, even during the design phase, that >¦ i>:i .-

3 more extensive contamination or deeper contamination

4 than what we are aware of, there will be an
J S evalw ; a whether to ir.fa one of those

6 bui Ml igs or try tn save it-

7 Our approach overall was try to save as many

8 t igs as possible, because we don't want to

9 d^-v. „ . -;'t »*iy -irre than we had to, but it actually

10 caor : t " r fi%re# bac> ; r !

11 cj,.'.n^uti ~'i the depth >.f t. :.rarainati-n, t .»

Ii a-- ¦, iRRti!; 3ryd * th.-iiik, y\ »> Ki ^ host*.» . L t. o k... j > < !

1 f\ at rs ."h it- i -1 r.'f any acaif i-mr.i

I"7 cnirs , F l tc , fc-el free t< or.r ;; •'<,

15 ;ai ; that chat, ci yvu L »v<* an option fo
19 unmut " in.! ask Michael ycur qinif:i. icr, direct 1 y ,

?0 MS. SAL-IADO: Hey, Mi chat 1, this is Maria

i: 1 Salci-iJc, PIDT. J nave a jut=stHi. V.V have pro t
, i 2 *1 c»\-j Ia>I right -rf - at per

j'1 g\;: 1- l t<-.'n tV D~K wo ar£ .-'.rpr s* 'i to look tor

. 1 any Supe-if u:u < -r any cciit.ar inar.ei sit? t-hat shuwu ij'

I on oar TK", Id'/v'-s tnat have * i > t ct.f ial impact £m

www.hUMby.nim Inc. Kcponsl < tmrr\ StMWJJ- 2
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Eitviroameatri Prr* eel Ion Agency PItqjkmwiI Han fiiblk Meeting

Pullic Mwfing'on 0I/W/M21 Page 34

1 our projects within, either, *">00 -1 if th^y are

2 just cor.tsurisutl tlJ ;utts that die >u axe

3 there Suf^i t .nl1*, yi*u kn:w, a . itr . e ,ntu»*r tad:us,
I av have 1, 0 ! e-c >~r . Hew will tuu" -- and

1 CST-? a lirr'.e : ,^r < r.~ rhe net-1 i r\:, > ^ ¦ I warn ' t
sure if ycu'Vf aiO'ddy discussed . How soon is

f this activity qnix-.i] to take plac* «r> #«• c.m k«ep it

a into our raruo sti with nur proi«vti* w< know what's
9 bapper.iiiu i:. n L-uii'.-u.cir.a pr„ - * c * s.
10 M«<. T^!1' k • Kd} od cii^W -ui,. |

'II schedule tct nr.,- {.r- i«cr , Li J"* 2/ f^nya sa;i, will j

• 12 be closed in th»- o. (iisrcr.t period FcL'J mi y 1 he I2tn, j

13 and we'll compile; a!! i r. toisiiat ion ti.>m cu'wu^n*' s ww [

14 received, prtpai> * [<*cr>rcl of Decision, which we I

j 15 expect tc iiajrp* r nuyt-e by June :>r July ,M til's year. J

I . t

i 16 After the R«c«-i 3 IVciaion is completed, there's a f

. 17 period that have t c pmpure consent decrees and

18 deal with t-h* :>*o't idt ions, responsible parties,

| 19 And the deai«ji» w..»ulJ start after that, about

20 18 months, so r.lu- t iim- i in- ROD is s inm-d f m eH'f ually

21 starting physic* I *•>*!¦ ivlfy, it could N* i*w. years,

22 So if we fir*-1 : of '21, so r »f " 2*

= 23 w , ur.at I would a- t .../lpate, onsite activities
to begin,

«: MS. SALG1DO; That was very helpful. Thank

www.huMby.CAtn Iluscby, Inc. McftmnaJ ('culm NiKI Wi 2082

Charlotte~ Atlanta ~ Washington, in' - ><•* York - H»u»ion ~San Franri»co

-------
Environmental Protection Agancv Proposed Piu Public Meeting

Public- %frr1r»R mm 01/19/2021 P*«e 15

1 you. S<,j the sehedul* will l>t* coming out through

2 this PowerPoint, it will have the schedule you are

3 talking about so that w«- •.•an download and keep in
I 4 Gil t J for ; «!l ft 1

I 5 MR. TAYLOR; i think the best way to keep up

; 6 with the site information is through our web page.

7 Obviously, you can always call the numbers we have

; 8 listed there for the 1PM. Marcia would be probably j

9 thp It st contact for scheduling. If things change,

10 she'll be able to provide information or we" 11 have

; 11 :t pv\st:ed as p®t ivniic updates on our web p^>i,

12 We do also list, you know, our beg inning of

13 site activities in the .local newspapers and mn i 1

14 list we have on file, so we can share that

15 information several ways.

j 16 MS. TORRES:- Thanks, Michael, Maria, also the

| 1? presentation is av^ilAblcs cn You Tube So : ,:ai«

® 16 include a link to th«- pi esentutior. in th-i chat .
j 19 MS- SALGMIO; Th«» w.Mild be qr-at , Hiarm y-m.

20 MS. TORRES; Ax\ '-th^r ^^Mr.ns : r-n r~ As'1

21 IS. SPENCER: If we don't have any tid . *t.-i |

?4 F> liiu-ry :2th, s.-^ y>.n» have t ii.v *¦•*> if.-t- yc-iu c«»bxh«h;8 I

J .• iiiiJ questions in if you didn't -jet them in t h i«

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-------
Environmental Protection lYt^wit Hum Public NU'ciihr

Public Mwtiagon mnmmi ______ i.if»

. I evening, and they will stiii be a part of the

. 2 Responsiveness Summary Uu' ' - « part of the Record

j 3 of Decision., which will be the final decision

I 4 document,

I 5 i v».ir.t to t:..»rr veryl ty f~t yr.;r - ime, fci

i 6 at t^r. Ill > l t-'.-iiimj air i <«<• i | *j: re c i s t- ^ y. u, ai'yi

j 7 k> Lop** tit h(jar : rom 1 commar ity arid the public
wirh ar.y .'nr.cemr : *'i? t-r q'lrp1* r^s rh^f

1 9 l. :i,_y a.ive, £?v, -Mr.}. y:.i £ r jts uis

10 Proposed Plan Zoom meeting for the Petroleum

i 11 Products Corporation site. And Josie has put the

j 12 link clown at the bottom for the access to the

' 1-1 presentation. And if you received the fact sheets,

14 you have the email address for the EPA website. We

If also have all the documents downloaded that relate

lo to the decision for this particular site, and the

I 17 Administrative Record on th* *. U , Wt ,»ihw I «ve

J 18 documents in French and Spanish, just in case

1 19 someone needs them.

LV So if there's anything -ri?w y»-u rf»h!, please

_ ] feel free to contact me, LaT<-r.ya fj-e-r.cwr, mrna

Hale or Michael Taylor or Su-v, r *tt.nr\:evi-rdiiig, He j

£.'4 appreciate you.

| 25 MR TAYLOR: Thank you. |

www.buaeby.cnm Hiiselj, toe. Regional Centers •**> .\331IW2

Charlotte ~ Atlanta" Washington, DC - New York - HouMon - Sm lunow

-------
Environmental Protection Agency Proposed Plan Public Meeting

I-uNk- Mwttafi on 01/M/IMl Pips37

1 (Pi eseritar, ion was concluded at 5; 51 p.m. EST^ .

2 . . -

M
I 1
1*1

16
1?

wwi».hu»eby.com Huseby, Inc. Regional C'cnltr. NIKi AW-20R2

Charlotte'-Atlanta - Washington, IK' - Vw Ywk - llc>u\tnn San ~'tantmtt

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APPENDIX C

SELECTED REMEDY - DETAILED COST ESTIMATE SHEETS

-------
Feasibility Study Cost Estimate Summary

piomct

ReorwT'

1WI

loc.ition P

Project n

umb«r

Hevimin

Proii'

Ohk

DPI

Oimobie ijnit QBH

tstlirjlrd St

Checkni By

535

Alternative

Description

Construction Cost

OAM Cost

IMPW Total

Un .,i, rj {om, Alternatives

UZ tfl

No Action

S86.04S

$86 100

UZKZ

Exavation and Off-Facility Disposal in Subtitle D Landfill

S14472,128

$14,372,100

UZ S3

Excavation, Ex Situ Stabilization/ Solidification (S/S>. ar

>d Oii-Facility Disposal

SU.7SS.005

$12,785,000

UZS4

In Situ S/S and Limited Soil Excavation with Ex Situ S/S and Off-Facility Disposal

S12J39.&29

$12,339,800

UZH5

Excavation, Ex Situ Thermal Treatment and S/S with On-Site Disposal

sis.eio.ios

$15,610,100

•

Main Source Area ANemathra*

MSA #2

Excavation and Off-Facility Disposal in Subtitle D Landfill

S2B.4 37.671

$28,437,700

MSA S3

In Situ Stablluatian/Salldlfkation (S/S) with Uige Diameter Augers (LDA)

$11.610,974

$11,611,000

MSA #4

Excavation, Ex Situ Thermal Treatment and S/S with On-Site Disposal

S2S.0U.ttl

$25,015,600

MSA #5

In Situ Thermal Treatment with Chemical Reduction

$19.840 676

sajuajae

$23,669,100

Eirtpndfd Www AKemjrt VP-.

EP *2

Groundwater Recovery and Treatment (GR6T)

5812.131

SJ.ni.6S4

$3,983.&00

E PIS

In Situ Carbon ln|ection and In Situ Reduction Permeable Barriers

S2.8SS.400

53,017387

S5.87I.400

EP#4

Monitored Natural Attenuation

S323.802

S329.800

SttewirJc Ccwti Appiir.ibir to each Alternative

Sitewide Costs

S1D1.8H2

1 B0 1

| $101,900 |

1 1 1

Common Scope to UZ ARemaflves (Con shown included In UZ Alternatives, except Bamboo Trailer Parii)

COM 91

Sam boo Tranter Park Excavation

$141,500

COM W 2

Building Demolition Overling MSA

$1.690300

$1,690,900

COM *3A

Shallow excavation under Buildings A - Retain Building

$4,572,400

COM #38

Shallow Excavation Under Building* B - Demolish Biddings

$5,635,100

$5,615,100

MPW Cost Summary - Remedial AHomativet

NPW = Nat Prmmtt Worth

U2#l
UZ#2
U2«
UZ #4

UZiS

MS* #2
MW«)

•

riCofi

¦ Constructloi
¦O&MCost

1 1 1

Total I smiu,soo

$5,000,000 Si0.000.000 $15,000,000 $20,000,000 $25,000,000 $30,000,000

Page lof 1

-------
r*u

Projwl NurnW:

l«N'V«fln

2U8

t* tnapecww* in&uda 1710 mm far nM"« OCX*
s (NAPs) t<*ry !» mart tar 30 yua

MM M Ma i

Unit Com Not*

Lefel Fmi, Licenses & Nmfti'
Enginwing* Admiidiliitjwe'

1 Applied xo capital ujbtotaf and contk^ancy
1 Applied to capital subtotal conUnfancy, im, and EM

03%

of Capital Coat

of Capital Cost

Total Capital Coat:

0AM Parted

7.00%

Discount Rate

0-00% Constant Escalation Factor

U> Sfee-WUe Casts awl MoWtorfeif (Yaar 1 ta Yaar 30)

Geu#e 12 welts far field parameter* COCs and natural attenuation parameters (NAPs) mry 5 )*ari fbr 10 years (2
rwnts); 8 hew day -2 day tffao. 2 personnel, * hr tra^—l. 4 hr pt*p Sfta melmenence Complete Wr Review*
and general support. to EPA.

Labor

¥T *

total 5

20.948

$ 20,348

Travel

f 1

total $

705

t 70S

Ma»rtaiV^gJpment/Sjbcantractors

V x

total S

3380

S 3,580

Anetydcal Sort

V 1

total $

•

Analytical - Water

IF *

beta; S

9327

I S Iftwuarey of Periodic Annual Coat (yrt)

94,540

1244300
$244)00

1 l

$18,000

$8,000

¦ _

* ¦ —

¦ ¦ ¦ m

Year

2 a

IS 28 21 M

04M Contingency
EWwttWi

Nat Praeent Worth (NPW)

»% | erf NPW Coat

Subtotal: $

74,373

$ IX. Ifl6

S 6 861
$ 9,262

1 Applied toOltM subtotal and contingancy
3 Applied to Q4M subtotal, contir^ency, and E&A

Mat Present Worth dertoed from summation of Modified Uniform Present Value

Subtotal. CUM Ca«n:| } 101,P2

Hi Pieaei* Worth feowii

L ProtesslanalratBe are averaged to rafted typical labor
2. Cost beds derived from professional judgment and
3 Cons are derived to be (-30*% to *S0%)

t P » Present Value (5)
Ao ¦ Annual Amount (S)

d • dteount rate
a • escalation factor
n - time parted (ytt)

Total t*W Coat

for personnel required for project,
unseat speeded cfrect)y.

b»»M»:[T 101, W0

"•mlali

*/tpDl9

-------
Volume of Impacted Soli ind SidrwiHita be Ejmv«t«l/StjbHtjm | 6J.633 |bqr Unit Con |S/ytU)^S_

10 iemedal Ootgn/Smch VuU«/no» Terti

ID Mobilo*lkin/DrrpobUli«flon of Equipment aid Personnel

Deagn/Bendt/Ptot TMh| Subtotal: 5

Utility protection, frubrnnd. clip lug, pre anoivation meeting. material* (3 day%>

Labor 1 Ij

Trmi 1 I*

Mjttflili/t ouiprwnty iitaiUmwn t ti

Building Demolition 1 b

32.146

Me Preparation Subtotal: $

4J Mia^-llt

In irtu sod mirtng with installation of ~ 3,330 IDA tocrtcnt krSfiai mhji% btumn -2 tc S ft bfa. 10-Aaoger
auuRMdwithoverlap. yiof -JLaXJbc*. StaMliation chemical agents added »laa<««i during downward
movement. Estimated 90 days InjectlooAO* 2 rigs.

1ST

Ramedral Oevgn Prolewonal Labor

1 I*

44,696

44.696

Remetfal Oet^n TrMl

1 It

1,310

U10

Ma teriaU/Equipment/Subcontr actors

1 k

16.000

&eneh ScH# Tailing

1 Is

Pilot Scale Testing

1 1*

17,Mt

Labor
Travel

Materials/Equipment/ Subcontractors

1
1
1

It
It
l>

$ 39,951
S 5,066
S 194,156

$
i
}

19,951
5,066

miss

She Preparation

Mobilization SuDtty

¦1: i

219472

32.146

Labor

1 ¦

65.966

Travel

1 It

28,356

24356

LDA Rig Mo!>lt3at
-------
Fusibility Study Cost Estimate

Alternative #: |

TiUe I

U Soil limitation and Staflng - fjtertor to BvlWlngt

Ejceoitton of appnnirnaMly 27 500 bey of to* ndud« 16.440 bty contaminated 10 »ofl to - 2-ft bh: S3S0 bc»
contaminated sod between U2 and MSA Iwn 2-SA bb. 2,210 hey contaminated *><1 In unallcr MSA area m - Ml
biv nfaa LOCO bey udevnll siope Top I-lk of ami C 14.440 bey) excavated fir a liam 100* icquke* tfabitaiion)
and off-Hi* dbptual it Subtitle D landfill. followed by erraticn of remaining KUll |~"9,06C bcyj, ctebibzation
(•aunw 100K), end placement In egsvatian. Placement of 2-ft dean IB. Staging of loto. bedcfVI. me reBoratlon
Aisumc 2.S weeks of effort

labor

1 Is

19.430

19,436

Travsl

1 II

2345

2.945

Eiicsv«rk>n/$he«t Pile Subcontractor Costs

1 It

2.092.420

2.092,420

Transport and Disx&al

1 Is

2,265,471

2.265/71

Backfill Subcontractor Costs

1 Is

405,162

SH» Restoration

1 Is

552JS54

Jr..

S"-854

Soil Eacavat

Ion ant

Stating Stibn

tal: f

533*Jt7

tlie UZ and MSA from 2 - 5 ft Hs (nd t he smj If e» MSA area trwn 0 -6 ft bb en iftu ni tfi Portland cement and fmiwd
bUatfi»neceiiag.£mnloyjabatoiptem tomb nockpHetfsol eedtu, Ajiunej 27,500 bey of tsmM Mi

Labor
1M

Excavation Subcontractor

S 27.914
i 4374
S 1.530,003

$ 27.916
$ 4374

5 1,530,083

En SHu Soil Stab libation Subtotal:

,-h

legal Fee*. License* 16 Permits'
Engineering A Administrative1

15%

0.5%

of Capful Con

of Capital Colt

1.562,373

1 Applied to capital subtotal and contingency
1 Applied 1o capital subtotal, contingency, fee*, and E tA

134*591

51.696

617,136

1.121303

12.339329

Page 2 of 3

4/6/3019

-------
Feasibility Study Cott frtifratf

H59

7-0 04M Cost)

Liter

Trevel

Ma T e n a 1 i/t qi j I p ment/Su bean tract o rs

Alternative *
tiKr

UoitOm Nut** CouS.

OfcM Period

0.00%

frscrsurit Rat*

Constant Escalation Factor

Annua) Cm*

V
W
W

1 total $
1 total $
1 total $

O&M Contingency

15*

Nrt Present Worth (NPW) Subtotal: $

ofNPWGoct $

8ft

10*

1 Applied to O&M subtotal and contmfency
1 Applied to O&M subtotal. contingency, and E&A

Net Present Worth Formula

'-«-63-MB5n

Subtotal - OAM Com IT*

where: P • Present Value ($)

Ao s Annual Amount ($)
d = discount rate
e ¦ escalation fade
n*tfme period (vrc)

Mote: fm Present Worth derived from summation of Modified Uniform Present Value (UPV*).

Tata* N»W Out | $ U 039,800

| 0 7*

Capital Coct
Summary

Uofrianiofl/Oernobfltjatior) d Equipment and PaiMMmal

| 2 «*

Ml Preparation

Of*

SeiMMig'ifiA

¦ 13 ®*

Son CacavattM? a»4 5ta0ng - E«cr lor to 6ut»dirtf&
SoH Stattfoation Ex S0u

| 17.4*

General toaunmtiore

1_ professional rate are averaged la irfleit typical labor rates for personnel required tor prefect.

2. Cut bus derived from professional Judgment Jnd mrpe-imcr jri«i specified directly.

3. Costs are derived to be (-30* to *50*)

Page 3 of 3

4/V»19

-------

COM H-tA [iiullow Iwawtwr, *

Prajrct tohiwg:
Tiv* Dwcrtpf'on:

l^roffd Nh«mt»*.

(Me

tuHdlnti Outaidc MSA; fait-fcHlMlftf
In k*ta*a 0 Umtm

BmT«r

wwa

ILxcavstion of 7J0D dc* of w«fc»/MA*L cantsnivtid x» beneatr **¦* (7) bw. «*np to -1ft ttt BuiMtae
r^Utnrd OHeou! d IdGft «f*apu»v4t«l *Mi « ¦ Sal*4>» D UndflU SoilrfKlcatfoa/StBbHfMtion u< apprMbnat»fti
d>% «rf »i to meet TO# 6*H» and Land Ban raautwiafib. >wnW ni

iwdlk

Voiivne of Impacted Soil and Sidewalk to be Exavated;f 7,100 |bcy Unit Cm* (S/ydi)JT

U> Remedial Design/tench Scaie/Pikrt Te

1J0

AJO SoU Eacavatton and Staging - Below Buildings

Pneumatk eaovaoon at approbate* 7JOD bey cf CVQC-laden sod to a depth of S-ft bt* (pius stdewall stop*).
SLagtng of Mfc, transport Jnd

$ 19,951
$ 5,066
$ 167378

s
s

19,951
5.086

167578

Ste Preparation

MoblftzatJon Suto

otal: $

192,594

Utility protection. grubfcsnf, cSearint, ore ei«av*tion meeti

nfc materials |3 days);

later

$ " •

•

Travel

Material VCqwfKnent/ Subcontractors
Building Demolition

1
1

S 30,475
S

30,47$

Site Preparation Subb

mat; S

30,475

Later

1 t>

38.628

Travai

1 Is

6,038

6.038

Eacavatioi^Sheat Pile Subcontractor Costs

1 Is

1.506,498

L506.498

Transport and CKgmst

1 Is

631,3 b 2

631352

Backfill Subcontractor Costs

1 Is

756,981

Ste Restoration

1 Is

2.939.496

Pa(* 1 of 3

4/8/2019

-------
^e-n^rrEZEEll

CRi Unit UnnCnvt No

SX Salt Stabilization ta Sftu

Stabiit* 40* of »aca«al*d tab torokteftd hazardous fTCV W) nstuvMi Portland cement and freund Mast
furnace dag. Em^cysabatfJiplant to mix MockpiM sal a* illu, Auumet 3.U7 Icy of km] stabilized.

Travel

Excavation Subcontractor

Engineering A MndnMbettva1

* Applied to capital subtotal and contingency
1 Applied to capital subtotal, contingency, fees, and ERA

S 3577

$ 112.698

ISM

0.5*

10ft

$ 3577

$ 112,598

Subtotal - Capital Cnb:
of Capital Cost

of Capital Cost

HOTS

499.702
19,155
106.4JM
415.469

Total Capital Cacti

Page 2of 3

4/1/2019

-------
Feasibility Study Cost fMimatt

NtonMa** [ ¦ '.II

6.0 O&MCottS

7.00*

Discount Rate
Constant Escalation Factor

Labor
Travel

Ma tenali/tquipmeni/Subcontractors

Q&M Contingency
Engineering & Admlntrtnrtlw1

15*

Met Resent Worth (WW) Subtotal: $

ofMPWCo* $

IP*

1 Appited to OftM subtotal and contingency

2 AppJ*d to 0AM subtotal, contingency, end E&A

Met Pieaent Worth Formula

'-<.«G3)«["g3)1

Subtotal -OAM

Cortr^T

when: P » Present Velue (S|

As « Annul Amount (5)
d « discount rite
e = escalation factor
ii ss time period (yre)

Nat*: fcgt Pfw#fit Worth dwwd from summation of Modtfttd Untform Prevent Valtw (UPV*)

Tom WPW Can tainme: | $ 4,572, MO

MmrtM Mga/banch ScaWWet Tests
Malaiiatkvt/OcrnnliiilTat Hvi of Equipment and <^*n«nn«il

K 1 ®H
¦1 VH

Capital Cost
Summary

Sna Preparation

1 0.9%

Bulking DrrooWkwi

00%

SiMlDtca

wtJon and Stagmc - Bataw Binding

feUEKMfc

n and Staging-t*er»or to Suildlnp
SoM StatwIlutJon Et Situ

OH*
J,S*

General Asurtiotiore

3. Professional rates are averaged to reflect typical labor rates for personnel required for project
Z Cost bus denved from professional Judgment and experience unless specified (treaty.
3. Costs are darived to be (-90* to *S0*)

Page 3 of3

4/8/2019

-------
1.0 Ramedlal Design/Bench Scale/Pilot T«ts

Remedial Design Professional Labor

$ 57,270

57,270

Remedial Design Travel

S U10

1310

Mater(al*fEqulpment/Subconiracior*

$ 16,000

16,000

Bench Scale Testing

S 120.000

120,000

Pflot Scale Testing

Dnign/Bench/Pttat Testing Subtotal: S

195.M0

2JO N%»bilaation/DernobiMxatiori of Equipment and Personnel

General mabHIzatlon/dernobitlzationof equipment and personnel

Labor 1 Is

Travd 1 Is

MiTerials/Equlpment/ Siixonrractors 1 Is

JLD MuhipwHw

Utility protection, grubbing. clearing, pre excavation meeting, materials (3 days);

labor 1 Is

Travei 1 Is

Materia iVEqui'pmem/ Stiscontractors 1 Is

Building Demolition 1 Is

$ 19,951
$ 5jQ66
$ 170387
M obi fixation Subtotal

*-§-

s
$
s
$

33,691

Srt# Preparation Subtotal: %

4X1 Soil Mkldnf IDA

In situ soil mixing with Installation of "3430 LDA locations ft* S/S "® mining between "5 to II ft bit 10-N auger
assumed with weriap. Stabilization chemical agents added via augers during downward movement. Estimated 14S

19.951
5,066
170387

BQH

33,691

11,691

days inJecticn/LOA using 2 rigs.

Labor

i 748,208

748.208

Travel

$ 132,293

132.293

IDA Rig Mobilization/Demobilization

$ 330,000

330X100

Tracked Ei«vator/U>A Rig

S 1,744,000

1,744.000

ISM Subcontractor

S 1,309,438

1.309.43*

Soli Mblng - IDA Subtotal:

4,J 6 3.9 33

SJO Soil Stab! illation In Situ

Stabittie mixture and chemcial cosu using Portland cement and ground blast furnace slag. Employs a batch plant to
mh stockpiled soil o situ Assumes 118,270 bey of soil stabilised.

labor

64.390

64390

Trawl

12,596

12395

Excavation Subcontractor

3,693,974

3,693374

In Situ Soli Stablflution Subtotal: S i,770,J5S

Page 1 of 3

4/8/2019

-------
Capital Contingency
Legal Ffn, Lkcnsa A Permits1
Engineer* ng 1 Adminbtretive1
Contractor fmz

1 A^ied to capital subtotal and eofttingmcy

2 Applied to capful subtotal, contingency, fees, and E&A

15K
0-SH
IK

iuamal - Capnai com: I $ «,«S9,S72

of Capital Cost $ 1,261,936

$ H.M3

S TTtjm.

or Capita) Cat $ 10S5&B
Total CjpMil Coat:

fM^r 3 of 3

4/4/2019

-------

O&M Period

7.00%

Discount Rate

0.00%

Constant Escalation Factor

O&M Costs

1 o

Annual Cost

None

Labor

total

travel

total

Materials/Equipment/Subcomractors

total

OAM Contingency
Engineering A Administrative*

15%

Net Present Worth (WW) Subtotal: $

of WPWCost S

10%

1 Applied to O&M subtotal and contingency
1 Applied to O&M subtotal, contingency, and E&A

Subtotal -O&M Corts^$_

Net Preterit Worth Formula

P = Present Value IS)
Ao * Annual Amount ($)
d = discount rate
e = escalation factor
n ® time period (yrs)

Note: Net Present Worth derived from summation of Modified Uniform Prevint Value (UPV*)

Total NPW Cost Estimate-.

Capital Coat

| 2.3*

Summary

Motxhzaltofl/Demotxtixatkm o* Equipment and Personnel | 2.3%

Sit* Preparation

0.4H

Soli Mixing - IDA

SoU Stabdrtation In Slot

Qepyi>i

t Professional rates are averaged to reflect typical labor rates for personnel required for project.

2. Cost basts derived from professional Judgment and experience unless specified directly.

3. Costs are derived to be {-30* to +50%)

Page 3 of 3

4/8/2019

-------
NjHtHwir.
Tasli OescnpAon

Alternatjvr »

Piutect fiwMm-
Djtir

Tout NPW C«wJ

tP»2 |IF Ateragtot «
Groundwater ItcovtfY end Treatment

mm ^^___ _

<*•08* 2011

WJ0S9 0

en (C| rounM rtcoMiy Mfli «p «{Ml b* to aeon and r*dra«*c

cc«t»

Const rud/lrattfll Groundwater Treatment System

Instil GW Treatment system. Trailer enclosed equ

prnmL Aniim ifHtnwit trwt fwmiln of O/W ttptmon.

fTKretion, air stripping, metals sequestration, and GAC Ten day installation assumed Includes const ruction of

labor

5 36,035

36,035

Travel

i 9,922

9,922

Extraction Writs Main Header

$ 4,364

4,364

Water Treatment System

S 232JOO

232,800

Effluent Manifold

$ 19.195

19195

Mtw? Spitm Subtotal:

NUU

PagelofB

-------
Construct Infiltration Galleries

Install (S) Infiltration galleries assume 14 days; assume two (2) 150-ft by 6-ft by 2Sfwt deep infiltration gall arte*
*k#bH recfacement.

Labor 1 li $ 52,707 $ 52,707

Travel 1 It $ 5,385 $ 5.385

General Subcontractor Costs 1 it $ 32,024 $ 32,024

Gallery Construction Subtotal: $ 90,116

Capital Contingency
Legal Feet, licenses A Perm**1
Engineering A Administrative1
Contractor Fee1

1 Applied to capital subtotal and contingency
1 Applied to capital subtotal, contingency, fees, and E&A

05%
8%
10%

Subtotal - Capita! Com: I $ 591,7S1

of Capital Cost $ 8S.763

$ 3,403

$ 54,441

of Capital Coct $ 73.836

Total Capital Cost: |$ 813,183

PageZo»3

4/8/3019

-------
OfcM Period

7.00%

D-jcount Rat*

74) GJUkT Operation [

Sysu-m ooeratkm tor 10 years, airbon dwigeoen r

0,00% IConstant Escalation Factor

i ft—ifcgi unit* chanfeouts; refiabiihmefiu; 2 *Wt» per

Travel

Mi «i*' *lv'Equ pment

10
10
10

w
w
w

total
total

$ 93399
S 2M&
5 1414)00

Annual Coat

S 93.J99
S 2M2S

s mo

BJ3 Performance Sampling Cots

Manftor synem performance for CVDCs (Influent and affluent, psot AS, port 6AC. eacfi RW [13 samples]) weekly first
month, quarterly for Tear 1(8 events), quarterly through year 15 (64 eventsJ; 16 br effort (2 hr travel. 2 hr prep) per

Later

17.757

37.757

Trawi

«JN

4.299

Mauriaii/Eqdfinwn/StiKaitrxton

2.1«4

2.144

An»Mc# • Water

24.930

26.930

04M Contingency

Contractor fa**

1 Applied to 04M subtotal and contingency
1 Applied to O&M subtotal, contingency. and E&A

Nat Prevent Worth Formula

Sampling Subtotal: $ 51,130
Mat Present Worth (MPW) Subtotal; $ 2,321*515

% lot NPW Cort

J25_

Subtotal OAM Costs:

¦hoc; P = Pnwnt Vilu»(Sl

Ao ¦ Mnud Amew* {$)

4>4

i MM. 2 77
S 21B.579
S 2M.3J2

e = e

n * time period (yn)

Not» Net Present Worth derived from summation of Modified Uniform Present Value |UPV*)

Total WW Cost estimate: I S 3,943,800

Remedial Oastn/Banch Scaie/PikxTests 81%

5*e Preparation ¦ 14%
Install GR4T Extraction Walls
Iretai Extraction System Pljrinii/Welheacts
Canter uctftastaK Groundwater Treatment. j^HH
trvtal injaction WW 00%
Construct mftferaOon Galarlci

Summary

Sll%

152%

fira rrt touTTBttoro

1. Prcte-tstona1 rates are averaged to reflect typical labor rates for personnel required for prafrect.
X Coat basis derived from professional Judgment and wperteoce ur#a*s specified directly
3. Costs are derived to be (-30% to *50%)

Page 3 of 3

4/8/2C19

-------
APPENDIX D
STATE CQWtlSPONDlMCE

-------
FLORIDA DEPARTMENT OF

Environmental Protection

Bob Martinez Center

Rao D«Santis

Governor

jMiwtts Nuftu

Lt Governor

Secretary

Memorandum

TO: Killian Talley, Environmental Specialist 111

Waste Cleanup Program

THROUGH: Brian Dougherty, Program Manager

District & Business Support Program, DWM

FROM: Jeff Wagner, PG II

District & Business Support Program, DWM

SUBJECT: Petroleum Products CERCLASite

3150 W Pembroke Road, Pembroke Park, Broward County
Draft Record of Decision, April 2021
Site ID: ERIC_3796

Digitally s>gn«d byuach J.
SrnWi

Dots 2021.0528
06:27:57 -04W

DATE:

May 27.2021

The District and Business Support Program (DBSP) has reviewed the EPA Draft
Record of Decision dated April 2021. The following review comments are provided to
assist the Waste Cleanup Program staff with their review. DBSP's review comments
should not be inferred to be an approval of the subject document.

The Draft Record of Decision (ROD) dated April 2021 prepared by the EPA does not
differ technically from the approach previously agreed to by the Department

The Applicable or Relevant and Appropriate Requirements (ARARs) deleted from the
ARAR Table appear to be duplications in some cases. ARARs relevant to landfill
vegetative cover and grade appear to be cited sufficiently. However, all ARARs
relevant to RCRA have been removed even though they are cited in the Feasibility
Study. NPDES ARARs are not cited in the table.

DBSP has no further comments for this draft ROD.

Please contact me at

lif you have any questions.

-------