Five-Year Review ReportFive-Year Review Report

Third Five-Year Review ReportThird Five-Year Review Report forfor

B«&B Chemical Co., Inc.B&B Chemical Co., Inc. EPA to FLD004574190EPA ID FLD004574190

HialeahHialeah Miami-Dade County, FloridaMiami-Dade County, Florida

August 2012August 2012

Prepared By:Prepared By: Skeo SolutionsSkeo Solutions

921 Second Street SE921 Second Street SE Charlottesville, VirginiaCharlottesville, Virginia

2290222902

For:For: United States Environmental Protection AgencyUnited States Envirormiental Protection Agency

Region 44Region Atlanta, GeorgiaAtlanta, Georgia

Approved

ranklin E. Hill-•ranklin E. Hill irector, uperfund Division)irector, Superftind Division

Date:

#

11111111111111111111I11111111111111111111111111111 10903248

Third Five-Year Review ReportThird Five- Year Review Report forfor

B«&B Chemical Co., Inc.B&B Chemical Co.• Inc. 875 West 20th Street875 \Vest 20th Street

HialeahHialeah iVIiami-Dade County, FloridaMiami-Dade County. Florida

List of ,<\cronymsList of Acronyms 44

Executive Summary 55Executive Sunlnlary

Five-Year Review Summary Form 88Five-Year Revie\v Sunlmary Form

101.0 Introductiont.O Introduction 10

122.0 Site2.0 Site ChronologyChronology 12

133.0 Background3.0 Background 13

3 .1 PHYSICAL CHARACTERISTICS 133.1 PHYSICAL CHARACTERISTICS 13 LAND AND RESOURCE USE3.2 LAND AND 16163.2 RESOURCE USE

3.33.3 HISTORY OF CONTAMINATIONHISTORY OF CONTAMINATION 1616 3.4 INITIAL RESPONSE 173.4 INITIAL RESPONSE 17 3.5 BASIS FOR TAKING ACTION 183.5 BASIS FOR TAKING ACTION 18

4.0 Remedial Actions4.0 Remedial Actions 2020

204.14.1 REMEDYREI'vIEDY SELECTIONSELECTION 20 4.24.2 REMEDY IMPLEMENTATIONREMEDY IrvlPLEMENTATION 2121

224.34.3 OPERATIONOPERATION AND MAINTENANCE (O&M)AND MAINTENANCE (O&M) 22

5.0 Progress5.0 Progress Since the Last Five-Vear ReviewSince the Last Five-Year Review 2323

5.1 ESTABLISH 23235.1 DEED RESTRICTIONESTABLISH AA DEED RESTRICTION

5.25.2 VERIFY THAT THE SITE INFORMATION is PROPERLY MAINTAINED AND ACCESSIBLE IN THEVERIFY THAT THE SITE INFORMATION IS PROPERLY MAINTAINED AND ACCESSffiLE IN THE

INFORI'vIATIONINFORMATION REPOSITORYREPOSITORY 2424

256.0 Five-Year Revie\v Process6.0 Five-Year Review Process 25

256.16.1 ADMINISTRATIVEADMINISTRATIVE COMPONENTSCOMPONENTS 25 256.26.2 COMMUNITYCOMMUNITY INVOLVEMENTINVOLVEMENT 25 256.36.3 DOCUMENT REVIEWDOCUrvlENT REVIEW 25 276.46.4 DATA REVIEWDATA REVIEW 27 276.56.5 SITESITE INSPECTIONINSPECTION 27

6.66.6 INTERVIEWS : 30INTERVIEWS ; 30

7.07.0 Technical AssessmentTechnical ,<\ssessment 3131

7.1 Is THE REMEDY FUNCTIONING AS INTENDED BY THE DECISION

DOCUMENTS?DOCUI'vlENTS? 33 I1

7.1 QUESTIONQUESTION A:A: Is THE REMEDY FUNCTIONING AS INTENDED BY THE DECISION

7.27.2 QUESTION B: ARE THE EXPOSURE ASSUMPTIONS, TOXICITY DATA, CLEANUP LEVELS ANDQUESTION B: ARE THE EXPOSURE ASSUMPTIONS. TOXICITY DATA. CLEANUP LEVELS AND

REMEDIAL OBJECTIVES (RAOs) USED AT THE TIME OF REMEDY SELECTIONREMEDIAL ACTIONACTION OBJECTIVES (RAOs) USED AT THE TIME OF REMEDY SELECTION

STILLSTILL VALID?VALID? 33 I1 7.37.3 QUESTION C: HAS ANY OTHER INFORMATION COME TO LIGHT THAT COULD CALL INTOQUESTION C: HAS ANY OTHER INFORMATION COME TO LIGHT THAT COULD CALL INTO

QUESTIONQUESTION THETHE PROTECTIVENESSPROTECTIVENESS OFOF THETHE REMEDY?REMEDY'? 3232

2

327.47.4 TECHNICALTECHNICAL ASSESSMENT SUMMARYASSESSMENT SUMMARY 32

8.0 Issues8.0 Issues 3333

9.0 Recommendations and Follow-up Actions9.0 Recommendations and Follow-up Actions 3434

10.0 Protectiveness10.0 Protectiveness StatementStatement 3535

11.0 Next Revie\v11.0 Next Review 3636

Appendix A: List of Documents Reviewed ; A-1Appendix A: List of Documents Reviewed A-I

Appendix B: Press NoticesAppendix B: Press Notices B-1B-1

Appendix C: Interview Forms ~ C-1Appendix C: Interview Forms C-l

Appendix D: Site Inspection ChecklistAppendix D: Site Inspection Checklist D-1D-l

Appendix E: Photographs from Site Inspection VisitAppendix E: Photographs from Site Inspection Visit E-1E-l ,

Appendix F: Vapor Intrusion MemorandumsAppendix F: Vapor Intrusion Memorandums F-1F-l

TablesTables TableTable 1: Chronology of Site Events1: Chronology of Site Events 1212 TableTable 2: Site Property Parcels2: Site Property Parcels 1313 TableTable 3: Ground Water COC Cleanup Goals3: Ground Water cac Cleanup Goals 2121 TableTable 4: Progress on Recommendations from the 2007 FYR4: Progress on Recommendations from the 2007 FYR 2323 TableTable 5: Previous and Current ARARs for Ground Water COCs5: Previous and Current ARARs for Ground Water cacs 2727 TableTable 6: histitutional Controls (ICs)6: Institutional Controls (ICs) 2828 TableTable 7: Current Site Issues7: Current Site Issues 3333 TableTable 8: Recommendations to Address Current Site Issues8: Recommendations to Address Current Site Issues 3434

FiguresFigures FigureFigure 1: Site Location Map1: Site Location Map 1414 Figure 2: Detailed Site MapFigure 2: Detailed Site Map 1515 Figure 3: Institufional Control Base MapFigure 3: Institutional Control Base Map 2929

3

List of Acronyms List of Acronyms

ARARARAR B&BB&B CERCLACERCLA CFRCFR CICcrc COCCOC DERMDERM EPAEPA ESDESD FDEPFDEP FYRFYR HRSHRS LTMLTM MCLMCL MSLMSL NCPNCP NPLNPL O&MO&M OUOU' PPPP PRPPRP RAORAO RAPRAP RI/FSRIfFS RODROD RPMRPM TBCTBC UAOUAO VIVI VOCVOC WTPWTP

Applicable or Relevant and Appropriate Requirement Applicable or Relevant and Appropriate Requirement B&B Tritech Inc. (formerly B&B Chemical Co., Inc) B&B Tritech Inc. (fonnerIy B&B Chemical Co., Inc)

Comprehensive Environmental Response, Compensation, and Liability Act Comprehensive Environmental Response, Compensation, and Liability Act Code of Federal Regulations Code of Federal Regulations Community Involvement Coordinator Community Involvement Coordinator Contaminant of Concern Contaminant of Concern

Miami-Dade County Department of Environmental Resource Management Miami-Dade County Department of Environmental Resource Management United States Environmental Protection Agency United States Environmental Protection Agency Explanation of Significant Differences Explanation of Significant DitTerences

Florida Department of Environmental Protection Florida Department of Environmental Protection Five-Year Review Five-Year Review Hazard Ranking System Hazard Ranking System Long Term Monitoring Long Tenn Monitoring Maximum Contaminant Level Maximum Contaminant Level Mean Sea Level Mean Sea Level National Oil and Hazardous Substances Pollution Contingency Plan National Oil and Hazardous Substances Pollution Contingency Plan National Priorities List National Priorities List Operation and Maintenance Operation and Maintenance

Operable Unit Operable Unit Proposed Plan Proposed Plan

Potentially Responsible Party Potentially Responsible Party Remedial Action Objective Remedial Aedon Objective Remedial Action Plan Remedial Action Plan Remedial Investigation/Feasibility Study Remedial Investigation/Feasibility Study

Record of Decision Record of Decision Remedial Project Manager Remedial Project Manager To-Be-Considered To-Be-Considered Unilateral Administrative Order Unilateral Administrative Order

Vapor Intrusion Vapor Intrusion Volatile Organic Compound Volatile Organic Compound Water Treatment Plant Water Treatment Plant

4

Executive SummaryExecutive Summary

IntroductionIntroduction

The B&B Chemical Co., tnc. (the Site) occupies acres in Hialeah, Miami-Dade County,The B&B Chemical Co., Inc. sitesite (the Site) occupies 55 acres in Hialeah, Miami-Dade County, Florida. B&B Tritech, Inc. (formerly B&B Chemical Co., Inc.) (B&B) manufactured industrialFlorida. B&B Tritech, Inc. (formerly B&B Chemical Co., Inc.) (B&B) manufactured industrial cleaning compounds at the Site since 1958. Chemicals and products used by the facility includecleaning compounds at the Site since 1958. Chemicals and products used by the facility include aa variety of solvents, polishes, detergents, oxidizing agents, corrosive inhibitors and metalvariety of solvents, polishes, detergents, oxidizing agents, corrosive inhibitors and metal cleaners. In the mid-1970s, inspectors from the Miami-Dade County Department ofcleaners. In the mid-1970s, inspectors from the Miami-Dade County Department of Environmental Resource Management (DERM) documented wastewater residues in soakage pitsEnvironmental Resource Management (DERM) documented wastewater residues in soakage pits at the Site, and subsequently issued Cease and Desist Order related to wastewater discharge toat the Site, and subsequently issued aa Cease and Desist Order related to wastewater discharge to the soakage pits.the soakage pits.

In 1985, at the request of DERM, EPA conducted an investigation at the Site and found benzene,In 1985, at the request of DERM, EPA conducted an investigation at the Site and found benzene, chlorobenzene, vinyl chloride and chromium in the ground water. In 1987, B&B completedchlorobenzene, vinyl chloride and chromium in the ground water. In 1987, B&B completed aa Remedial Investigation/Feasibility Study (RI/FS) to determine the type and extent ofRemedial InvestigationlFeasibility Study (RI/FS) to determine the type and extent of contamination at the Site. EPA proposed the Site for inclusion on the National Priorities Listcontamination at the Site. EPA proposed the Site for inclusion on the National Priorities List (NPL) in 1988. The Site was finalized on the NPL in 1990. Starting in August 1988, B&B(NPL) in 1988. The Site was finalized on the NPL in 1990. Starting in August 1988, B&B operated ground water treatment system on site, in accordance with Order of Stipulatedoperated aa ground water treatment system on site, in accordance with aa CourtCourt Order of Stipulated

with DERM. The treatment system operated, with some periods of interruption, untilSettlementSettlement with DERM. The treatment system operated, with some periods of interruption, until 1993.1993.

The triggering action for this Five-Year Review (FYR) the signing of the previous FYR onThe triggering action for this Five-Year Review (FYR) waswas the signing of the previous FYR on April 26, 2007.April 26, 2007.

Remedy ComponentsRemedy Components

EPA issued the Site's Record of Decision (ROD) on September 12, 1994. The Site consists ofEPA issued the Site's Record of Decision (ROD) on September 12, 1994. The Site consists of one operable unit (OU). Although the 1994 ROD did not specify remedial action objectivesone operable unit (OU). Although the 1994 ROD did not specify remedial action objectives (RAOs), it did specify that the remedy was selected to mitigate the threat to human health and to(RAOs), it did specify that the remedy was selected to mitigate the threat to human health and to meet federal and Florida maximum contaminant levels (MCLs). In addition, the 1992 FSmeet federal and Florida maximum contaminant levels (MCLs). In addition, the 1992 FS identified RAOs based on existing or potential hazards identified in the 1992 Risk Assessment,identified RAOs based on existing or potential hazards identified in the 1992 Risk Assessment, including:including:

•• Prevent ingestion of water having carcinogen concentrations in excess of federal/statePrevent ingestion of water having carcinogen concentrations in excess of federal/state applicable or relevant and appropriate requirements (ARARs) and total excess cancerapplicable or relevant and appropriate requirements (ARARs) and aa total excess cancer risk of greater than 10" ..risk of greater than 10.6

•• Prevent ingestion of water having noncarcinogen(s) in excess of federal/state ARARs andPrevent ingestion of water having noncarcinogen(s) in excess of federal/state ARARs and risk assessment criteria.risk assessment criteria.

•• Restore the ground water system by cleanup to the health-based standards (stated above)Restore the ground water system by cleanup to the health-based standards (stated above) and prevent the migration of pollutants beyond the existing limits of the knownand prevent the migration of pollutants beyond the existing limits of the known contaminant plume.contaminant plume.

•• Prevent ingestion or direct contact with contaminated soil having greater than 10" excessexcessPrevent ingestion or direct contact with contaminated soil having greater than 10.6

cancer risk or exceeding public health assessment criteria for noncarcinogens.cancer risk or exceeding public health assessment criteria for noncarcinogens.

The remedy selected in the 1994 ROD consisted of the following remedial components:The remedy selected in the 1994 ROD consisted of the following remedial components:

5

Natural attenuation of ground water contaminants.•• Natural attenuation of ground water contaminants. •• Monitoring ground water to verify natural attenuation.Monitoring ground water to verify natural attenuation. •• Implementing institutional controls in the form of aa notification agreement between theImplementing institutional controls in the form of notification agreement between the

United States Environmental Protection Agency (EPA) and the landowner to ensure theUnited States Environmental Protection Agency (EPA) and the landowner to ensure the continued integrity of the asphalt cover.continued integrity of the asphalt cover.

The selected remedy waswas revised by the June 2009 Explanation of Significant Differences (ESD)The selected remedy revised by the June 2009 Explanation of Significant Differences (ESD) to require institutional controls to ensure the remedy remains protective of human health. Into require institutional controls to ensure the remedy remains protective of human health. In addition, the 2009 ESD removed the 1994 ROD requirement for aa tinal round of ground wateraddition, the 2009 ESD removed the 1994 ROD requirement for final round of ground water sampling. The 2009 ESD removed this requirement because all monitoring wells had metsampling. The 2009 ESD removed this requirement because all monitoring wells had met performance standards during two consecutive rounds of sampling.performance standards during two consecutive rounds of sampling.

The 2009 ESD required that restrictive covenants be placed on the site properties to:The 2009 ESD required that restrictive covenants be placed on the site properties to:

Ensure that the integrity of existing impermeable surfaces is maintained.•• Ensure that the integrity of existing impermeable surfaces is maintained. Ensure that future use of the property remains commercial or industrial.•• Ensure that future use of the property remains commercial or industrial. Ensure that the potentialpotential for vapor intrusion (VI)(VI) into any newly constructed buildings is•• Ensure that the for vapor intrusion into any newly constructed buildings is evaluated and properly addressed.evaluated and properly addressed.

Technical AssessmentTechnical Assessment

The review of documents, ARARs, risk assumptions and the sitesite inspection indicate that theThe review of documents, ARARs, risk assumptions and the inspection indicate that the Site's remedy is functioning as intended. The ROD's ground water performance goals were metSite's remedy is functioning as intended. The ROD's ground water performance goals were met in 2007. The pavement cover controls source material at the Site. Until all institutional controlsin 2007. The pavement cover controls source material at the Site. Until all institutional controls are implemented at the Site, the 1995 Unilateral Administrative Order (UAO) establishesare implemented at the Site, the 1995 Unilateral Administrative Order (UAO) establishes aa notification agreement requiring B&B or the owners of the property to provide 60 daysnotification agreement requiring B&B or the owners of the sitesite property to provide 60 days written notice prior to disturbing the asphalt/pavement cover or prior to the sale of the property.written notice prior to disturbing the asphalt/pavement cover or prior to the sale of the property.

In January 2007, EPA conducted visit to evaluate each on-site building for VIIn January 2007, EPA conducted aa sitesite visit to evaluate each on-site building for potentialpotential VI issues. An EPA memorandum dated, February 20, 2007, concluded that there is no VI forissues. An EPA memorandum dated, February 20,2007, concluded that there is no VI riskrisk for existing buildings on the Site. However, any ftiture construction at the Site should consider theexisting buildings on the Site. However, any future construction at the Site should consider the

for VI.potentialpotential for VI.

In order to ensure long-term protectiveness at the Site, the 2009 ESD required that restrictiveIn order to ensure long-term protectiveness at the Site, the 2009 ESD required that restrictive covenants be placed on the site properties to:covenants be placed on the site properties to:

• Ensure that the integrity of existing impermeable surfaces is maintained.Ensure that the integrity of existing impermeable surfaces is maintained. • Ensure that future use of the property remains commercial or industrial.Ensure that future use of the property remains commercial or industrial.

Ensure that the for VI into any newly constructed buildings is evaluated and• Ensure that the potentialpotential for VI into any newly constructed buildings is evaluated and properly addressed.properly addressed.

EPA, Florida Department of Environmental Protection (FDEP) and the property owner areEPA, Florida Department of Environmental Protection (FDEP) and the property owner are working together to ensure that the restrictive covenants are implemented as required.working together to ensure that the restrictive covenants are implemented as required.

6

ConclusionConclusion

The remedy at the Site is protective of human health and the environment in the short-term,The remedy at the Site is protective of human health and the environment in the short-term, because ground water at the Site met performance standards and structures at the Site preventbecause ground water at the Site met performance standards and structures at the Site prevent exposure to remaining source material. However, in order for the remedy to be protective in theexposure to remaining source material. However, in order for the remedy to be protective in the long term, institutionalinstitutional controls called for in the Site's decision documents should belong term, controls called for in the Site's decision documents should be implemented to:implemented to:

Ensure that the integrity of existing impermeable surfaces is maintained.•• Ensure that the integrity of existing impermeable surfaces is maintained. Ensure that future use of the property remains commercial or industrial.•• Ensure that future use of the property remains commercial or industrial.

•• Ensure that the potentialpotential for VI into any newly constructed buildings is evaluated andEnsure that the for VI into any newly constructed buildings is evaluated and properly addressed.properly addressed.

7

I

Five-Year Review Summary FormFive-Year Review Summary Form

SITE IDENTIFICATIONSITE IDENTIFICATION

SiteSite Name:Name: B&B Chemical Co., Inc.B&B Chemical Co., Inc.

EPAEPA ID:ID: FLD004574190FLD004574190

Region: 44 State: FL City/County: Hialeah/Miami-DadeHialeah/Miami-Dade

Final

MultipleMultiple OUs?OUs? Has the site achieved construction completion?

NPLNPL Status:Status: Final

Has the site achieved construction completion?

NoNo YesYes

REVIEW STATUS

Lead agency: EPALead agency: EPA If "Other Federal Agency" was selected above, enter Agency name: N/A

Author name:Author name: Treat Suomi (Reviewed by EPA)

If "Other Federal Agency" was selected above, enter Agency name: N/A

Treat Suomi (Reviewed by EPA)

Author affiliation: Skeo Solutions

Review period: 10/18/2011 -~ 4/26/20124/26/2012

Author affiliation: Skeo Solutions

Review period: 10/18/2011

Date of site inspection: 1/27/2012Dateof site inspection: 1/27/2012

Type of review: StatutoryType of review: Statutory

Review number:Review number: 33 -

Triggering action date: 4/26/2007Triggering action date: 4/26/2007

Due date (fivB years after triggering action date): 4/26/2012Due date (five years after triggering action date): 4/26/2012

8

Five-Year Review Summary Form (continued)Five-Year Review Summary Form (continued)

Issues/RecommendationsIssues/Recommendations

^Issjues and Recommendations Identifilcil in the Five-Year Review: |Jssues and Recommendations Identifi~ctin the Five-Year Review': :-:::>. ... ' .~ ,. ". .,., :

OU(s): 11 Issue Category: Institutional Controls

Issue: Institutional controls called for in the 2009 ESD are not yet

OU(s): Issue Category: Institutional Controls

Issue: Institutional controls called for in the 2009 ESD are not yet implemented.implemented.

Recommendation: Implement required institutional controls.Recommendation: Implement required institutional controls.

Affect CurrentAffect Current Affect FutureAffect Future· ImplementingImplementing OversightOversight Milestone DateMilestone Date ProtectivenessProtectiveness ProtectivenessProtectiveness PartyParty PartyParty

NoNo YesYes EPAEPA EPAEPA 5/1/20135/1/2013

Site Wide Protectiveness StatementSite Wide Protectiveness Statement

Protectiveness Determination:Protectiveness Determination: Addendum Due Date (if applicable):Addendum Due Date (if applicable): Short-term ProtectiveShort-term Protective N/AN/A

Protectiveness Statement:Protectiveness Statement: The remedy at the Site is protective of human health and the environment in the short-teon, becauseThe remedy at the Site is protective of human health and the environment in the short-tenn, because ground water at the Site met perfomiance standards and stmctures at the Site prevent exposure toground water at the Site met perfomlance standards and structures at the Site prevent exposure to remaining sourcesource material.material. However, in order for tlie remedy to be protective in the long term,remaining However, in order for the remedy to be protective in the long tenn, institutional controls called for in the Site's decision documents should be implemented to ensure tliatinstitutional controls called for in the Site's decision documents should be implemented to ensure that the integrity of existing impermeable surfaces is maintained; ensure that future useuse of theof the propertypropertythe integrity of existing impemleable surfaces is maintained; ensure that future remains commercial or industrial; ensure that the potential for VI into any newly constructed buildingsremains conmlercial or industrial; ensure that the potential for VI into any newly constructed buildings is evaluated and properly addressed.is evaluated and properly addressed.

Environmental IndicatorsEnvironmental Indicators

Current human exposures at the Site are under control.-- Current human exposures at the Site are under control. Current ground water migration is under control.-- Current ground water migration is under control.

Are Necessary Institutional Controls in Place?

I D All ^ Some D None

Has the Site Been Designated as Site Wide Ready for Anticipated Use'i

I D Yes No

Has site been put into reuse?

I ^ Yes D ~

9

Third Five-Year Review ReportThird Five-Year Revnew Report forfor

B&B Chemical Co., Inc. Superfund SiteB&B Chemical Co., Inc. Superfund Site

1.0 Introduction1.0 Introduction

The purpose of Five-Year Review (FYR) is to evaluate the implementation and performance ofThe purpose of aa Five-Year Review (FYR) is to evaluate the implementation and performance of remedy in order to determine ifthe remedy will continue to be protective of human health andaa remedy in order to determine if the remedy will continue to be protective of human health and

the environment. The methods, and conclusions of FYRs are documented in FYRthe environment. The methods, findingsfindings and conclusions of FYRs are documented in FYR reports. In addition, FYR reports identify issues found during the review, if any, and documentreports. In addition, FYR reports identify issues found during the review, if any, and document recommendations to address them.recommendations to address them.

The United States Environmental Protection Agency (EPA) prepares FYRs pursuant to theThe United States Environmental Protection Agency (EPA) prepares FYRs pursuant to the Comprehensive Environmental Response, Compensation, and Act (CERCLA) SectionComprehensive Environmental Response, Compensation, and LiabilityLiability Act (CERCLA) Section 121 and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).121 and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). CERCLA Section 121 states:CERCLA Section 121 states:

"Ifthe President selects remedial action that results in any hazardous substances,"If the President selects aa remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedialpollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each years after the initiation of such remedial action toaction no less often than each fivefive years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial actionassure that human health and the environment are being protected by the remedial action being implemented. In addition, if upon such review it is the judgment of the Presidentbeing implemented. In addition, if upon such review it is the judgment of the President that action is appropriate at such in accordance with section [104] or [106], thethat action is appropriate at such sitesite in accordance with section [104] or [106], the President shall take or require such action. The President shall report to the CongressPresident shall take or require such action. The President shall report to the Congress aa list of facilities for which such review is required, the results of all such reviews, and anylist of facilities for which such review is required, the results of all such reviews, and any actions taken as result of such reviews."actions taken as aa result of such reviews."

EPA interpreted this requirement further in the NCP; 40 Code of Federal Regulations (CFR)EPA interpreted this requirement further in the NCP; 40 Code of Federal Regulations (CFR) Section 300.430(f)(4)(ii), which states:Section 300.430(f)(4)(ii), which states:

"If remedial action isselected that results in hazardous substances, pollutants, or"If aa remedial action is 'selected that results in hazardous substances, pollutants, or contaminants remaining at the above levels that allow for unlimited use andcontaminants remaining at the sitesite above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such actions no less often than everyunrestricted exposure, the lead agency shall review such actions no less often than every five years after the initiation of the selected remedial action."five years after the initiation of the selected remedial action."

Skeo Solutions, an EPA Region contractor, conducted the FYR and prepared this reportSkeo Solutions, an EPA Region 44 contractor, conducted the FYR and prepared this report regarding the remedy implemented at the B&B Chemical Co., Inc. (the Site) in Hialeah,regarding the remedy implemented at the B&B Chemical Co., Inc. sitesite (the Site) in Hialeah, Miami-Dade County, Florida. This FYR conducted from October 2011 to April 2012. EPAMiami-Dade County, Florida. This FYR waswas conducted from October 2011 to Apri12012. EPA is the lead agency for developing and implementing the remedy for the Potentially Responsibleis the lead agency for developing and implementing the remedy for the Potentially Responsible Party (PRP)-financed cleanup at the Site. Florida Department of Environmental ProtectionParty (PRP)-financed cleanup at the Site. Florida Department of Environmental Protection (FDEP), as the support agency representing the Florida, has reviewed all supporting(FDEP), as the support agency representing the Florida, has reviewed all supporting documentation and provided input to EPA during the FYR process.documentation and provided input to EPA during the FYR process.

This is the third FYR for the Site. The triggering action for this statutory review is the previousThis is the third FYR for the Site. The triggering action for this statutory review is the previous FYR. The FYR is required because hazardous substances, pollutants or contaminants remain atFYR. The FYR is required because hazardous substances, pollutants or contaminants remain at

10

the Site above levels that allow for unlimited use and unrestricted exposure. The Site consists ofthe Site above levels that allow for unlimited use and unrestricted exposure. The Site consists of one operable unit (OU), which is addressed in this FYR. one operable unit (OU), which is addressed in this FYR.

II11

2.0 Site Chronology2.0 Site Chronology

Table I lists the dates of important events for the Site.Table 1 lists the dates of important events for the Site.

Table 1: Chronology of Site EventsTable 1: Chronology of Site Events

.. ' •• ;0.-/

• • •• • •• ' : " • • EventE v e n t ; ,. . : DateDate •.;.~W .·,·:~f<:\>:• ••- :Jlfe;.> Miami-Dade County Department of Environmental ResourceMiami-Dade County Department of Environmental Resource Mid-1970sMid-1970s Management (DERM) issued Cease and Desist Order for wastewaterManagement (DERM) issued Cease and Desist Order for wastewater soakage pits B&B Chemical Co., Inc. began operation of wastewater pretreatment May 1976 soakage pits B&B Chemical Co., Inc. began operation of aa wastewater pretreatment May 1976 systemsystem DERM Administrative Order directed B&B Chemical Co., Inc. to planDERM Administrative Order directed B&B Chemical Co., Inc. to plan October 1983October 1983 ground water monitoring DERM filed civil suit alleging substantial delay in submitting groundDERM filed civil suit alleging substantial delay in submitting ground November 1984 ground water monitoring

November 1984 water monitoring plan DERM requested that EPA investigate the SiteDERM requested that EPA investigate the Site August 1985 water monitoring plan

August 1985 Initial discoveryInitial discovery October 10, 1985October 10, 1985 FDEP conducted site inspectionFDEP conducted site inspection July 21, 1986July21,1986

completed preliminary assessment November 19, 1987EPEPAA completed preliminary assessment November 19, 1987 EPA proposed the Site for listing on the National Priorities List (NPL)EPA proposed the Site for listing on the National Priorities List (NPL) June 24,1988June 24, 1988 EPA began remedial investigation/feasibility study (RI/FS)EPA began remedial investigation/feasibility study (RIIFS) September 13, 1989September 13, 1989 EPEPAA finalized the Sitefinalized the Site on the NPLon the NPL August 30, 1990August 30, 1990 EPEPAA completed removal assessmentcompleted removal assessment August 25, 1992August 25,1992 EPEPAA conducted ecological risk assessmentconducted ecological risk assessment Octobers, 1992October 5, 1992 EPEPAA conducted risk/health assessment EPEPAA completed RIfFScompleted RI/FS September 12, 1994

conducted risk/health assessment September 12, 1994

EPEPAA signed Record of Decision (ROD) EPA issued Unilateral Administrative Order (UAO)EPA issued Unilateral Administrative Order (UAO) Septembers, 1995

signed Record of Decision (ROD) September 5, 1995

PRP began remedial design September 20, 1995PRP began remedial design September 20, 1995 PRP completed remedial designPRP completed remedial design October 18, 1995October 18, 1995 PRP began remedial actionPRP began remedial action December 7, 1995December 7, 1995 PRP completed remedial action September I, 1999PRP completed remedial action September 1, 1999 PRP began long-term response actionPRP began long-term response action First FYR signed October 24, 200200October 24, IFirst FYR signed 1

conducted vapor intrusion study February 20, 2007EPEPAA conducted aa vapor intrusion study February 20, 2007 Second FYR signed April 26, 2007Second FYR signed April 26, 2007 EPA issued ExplanationEPA issued Explanation of Significant DifferencesofSigniticant Differences (ESD)(ESD) June 12,2009June 12,2009

12

" 3.0 Background3.0 Background

Physical Characteristics3.13.1 Physical Characteristics

The Site is located in an industrial area of Hialeah, Miami-Dade County, Florida (FigureThe Site is located in an industrial area of Hialeah, Miami-Dade County, Florida (Figure 1). The 5-acre Site is located at 875 West 20th Street and is bounded by Metrorail tracksI). The 5-acre Site is located at 875 West 20th Street and is bounded by Metrorail tracks to the south, Florida East Coast Railroad tracks to the north, West 8th Avenue to the east,to the south, Florida East Coast Railroad tracks to the north, West 8th Avenue to the east, and the Dade County Metrorail Okeechobee Station and parking garage to the westand the Dade County Metrorail Okeechobee Station and parking garage to the west (Figure 2). Prior to development, the natural topography of the Site was generally flat.(Figure 2). Prior to development, the natural topography of the Site was generally flat. The maximum elevation of 7.5 feet above mean sea level (MSL) is along the easternThe maximum sitesite elevation of 7.5 feet above mean sea level (MSL) is along the eastern boundary of the Site, and the ground surface slopes to minimum of five feet above MSLboundary of the Site, and the ground surface slopes to aa minimum offive feet above MSL near the northwestern of the Site. The south-central area is higher thannear the northwestern cornercorner of the Site. The south-central area is higher than immediately surrounding areas.immediately surrounding areas.

AA gate at the southwest comer of the facility provides access to the walled compound thatgate at the southwest comer of the facility provides access to the walled compound that up the Site. The western portion of the Site is used for employee parking. guardmakesmakes up the Site. The western portion of the Site is used for employee parking. AA guard

station is located in the parking area to control access to the facility. Administrative andstation is located in the parking area to control access to the facility. Administrative and manufacturing operations are housed in buildings located in the southwest and south­manufacturing operations are housed in buildings located in the southwest and south­central portions of the Site. Warehouse and storage areas for raw materials and finishedcentral portions of the Site. Warehouse and storage areas for raw materials and finished goods are located in the eastern and northern portions of the Site. tank farms, eachgoods are located in the eastern and northern portions of the Site. TwoTwo tank farms, each with approximately seven tanks ranging in size from 5,000 to 10,000 gallons, are locatedwith approximately seven tanks ranging in size from 5,000 to 10,000 gallons, are located in the northeast comer and south-central portion of the Site. However, only one tank inin the northeast comer and south-central portion of the Site. However, only one tank in the south-central area is currently in use; this tank stores potable water. Use of thethe south-central area is currently in use; this tank stores potable water. Use of the permanently-installed tanks for storage of feedstock chemicals used in the manufacture ofpermanently-installed tanks for storage of feedstock chemicals used in the manufacture of B&B Tritech, Inc. (formerly B&B Chemical Co., Inc.) (B&B) products has beenB&B Tritech, Inc. (formerly B&B Chemical Co., Inc.) (B&B) products has been discontinued. The areas surrounding the buildings and tank farms, as well as the parkingdiscontinued. The areas surrounding the buildings and tank farms, as well as the parking area, are covered by either asphalt or concrete pavement. The southeast comer of the Sitearea, are covered by either asphalt or concrete pavement. The southeast comer of the Site is unpaved and covered with grass and gravel. storm drain system, consisting ofis unpaved and covered with grass and gravel. AA storm drain system, consisting of infiltration trench drains, allows percolation of stormwater runoff to the water table. Theinfiltration trench drains, allows percolation of stormwater runoff to the water table. The existing storm drainage system is not connected to the drainage system. Theexisting storm drainage system is not connected to the municipalmunicipal drainage system. The Site is located on three property parcels (Table 2).Site is located on three property parcels (Table 2).

Table 2: Site Property ParcelsTable 2: Site Property Parcels

OwnerOwner Parcel !dentification NumberParcel Identification Number Total Parcel AcresTotal Parcel Acres William B. Brock Jr. Isabel K. 04-3013-001-0170 1.61.6William B. Brock Jr. && WW Isabel K. 04-3013-001-0170

William B. Brock Jr. Isabel K. 04-30 I3-00 1-0 171 2.32.3William B. Brock Jr. && WW Isabel K. 04-3013-001-0171

William B. Brock Jr. Isabel K. 04-3013-001-01 T2 1.11.1William B. Brock Jr. && WW Isabel K. 04-3013-001-0172

The major surface drainage features in the area are manmade. The Miami Canal, theThe major surface drainage features in the area are manmade. The Miami Canal, the area's primary drainage feature, traverses the area in northwest to southeast corridorarea's primary drainage feature, traverses the area in aa northwest to southeast corridor and passes within 800 feet of the southwestern comer of the Site. The effects of seasonaland passes within 800 feet of the southwestern corner of the Site. The effects of seasonal operation of the canals (altemately operated to lower ground water levels during the rainyoperation of the canals (alternately operated to lower ground water levels during the rainy season, then to recharge the aquifer during the dry season) and the variable pumping ratesseason, then to recharge the aquifer during the dry season) and the variable pumping rates at the three wellfields influence the aquifer's regional direction on local scale.at the three well fields influence the aquifer's regional flowflow direction on aa local scale. Annual rainfall averages 60 inches and occurs primarily from July through November.Annual rainfall averages 60 inches and occurs primarily from July through November.

1313

- y • • . , ! , ia*- ' . ; / ; ! ! .*! ; -

Figure 1: Site Location MapFigure 1: Site Location Map

o 55 110 220 330 440.-E:l--==-__':::==:J Feet

B & Chemical Co., Inc. Superfund SiteB & BB Chemical Co., Inc. Superfund Site0 skeo oo NORTH Hialeah, Miami-Dade County, FloridaHialeah, Miami-Dade County, FloridaNORTH

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not survey. The map is forDisclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not aa survey. The map is for informational purposes only regarding EPA's response actions at the Site, and is not intended for any other purpose.informational purposes only regarding EPA's response actions at the Site, and is not intended for any other purpose.

1414

MJiMfcii i i , L Jl--

Figure 2: Detailed Site MapFigure 2: Detailed Site Map

Legend Q Perimeter V\feilJPenmeterwa

D~~r~

^skeo7 .:,, . ^ ^ .V * i

O NORTH

o· NORtH

B&B Chemical Co., Inc. Superfund Site Hialeah, Mtami-Dade County, Ftorida

B &B Chemical C,o•• loe. Superfund Site Hialeah, Mianli.oQade County, FloJiqa.

Disclaimer: This map and any boundary lines within the inap are approximate and subject to change. The map is not survey. The map is for informational purposes only regarding EPA's responseDisclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not aa survey. The map is for informational purposes only regarding EPA's response actions at the Site, and is not intended for any other purpose.actions at the Site, and is not intended for any other purpose.

15is

3.23.2

3.33.3

Land and Resource UseLand and Resource Use

Land use in the area is predominately industrial and commercial. There is no residentialLand use in the area is predominately industrial and commercial. There is no residential development in the immediate vicinity of the Site. The Site has remained in continueddevelopment in the immediate vicinity of the Site. The Site has remained in continued commercial/industrial use throughout remedial activities. B&B waswas incorporated in thecommercial/industrial use throughout remedial activities. B&B incorporated in the State of Florida in 1953 and constmction of its Hialeah facilities took place in 1959 andState of Florida in 1953 and construction of its Hialeah facilities took place in 1959 and 1960. Since initial constmction, the Site expanded to its current size (five buildings,1960. Since initial construction, the Site expanded to its current size (five buildings, which total about 50,000 square feet) through series of additions. Prior to 1963, B&B'swhich total about 50,000 square feet) through aa series of additions. Prior to 1963, B&B's products were mixed by company in Atlanta, Georgia. Products were delivered to theproducts were mixed by aa company in Atlanta, Georgia. Products were delivered to the B&B facility in Hialeah, or directly to B&B's customers in dmms. B&B began mixingB&B facility in Hialeah, or directly to B&B's customers in drums. B&B began mixing products at the Site in early 1963 and gradually increased its product line over time. Inproducts at the Site in early 1963 and gradually increased its product line over time. In 1989, B&B changed to its current name, B&B Tritech, Inc., but ownership of the1989, B&B changed to its current name, B&B Tritech, Inc., but ownership of the company did not change.company did not change.

The nature of the B&B business at the Site changed over time and currently aa smallThe nature of the B&B business at the Site changed over time and currently small portion of the buildings and property at the Site are used for business operations. Locatedportion of the buildings and property at the Site are used for business operations. Located immediately west of the Site is the County's Okeechobee Metrorail Station and parkingimmediately west of the Site is the County's Okeechobee Metrorail Station and parking garage. The property, formerly the location of the Crown Paint Company, Inc. andgarage. The property, formerly the location of the Crown Paint Company, Inc. and Fullerton Metals, Inc., was acquired by the County through eminent domain in 1981,Fullerton Metals, Inc., was acquired by the County through eminent domain in 1981, when approximately 120 dmms of paint waste were found. Most of the dmms were inwhen approximately 120 drums of paint waste were found. Most of the drums were in good condition. However, some of the dmms had either msted or expanded, breaking thegood condition. However, some of the drums had either rusted or expanded, breaking the containers, and others had been tipped over, spilling their contents onto the ground.containers, and others had been tipped over, spilling their contents onto the ground. AA removal action for the paint-related waste was completed in January 1984. To the southremoval action for the paint-related waste was completed in January 1984. To the south of the Site are several and commercial businesses. To the north of the Site isof the Site are several industrialindustrial and commercial businesses. To the north of the Site is aa highway.highway.

The Biscayne Aquifer, the sole-source drinking water aquifer for the metropolitan area,The Biscayne Aquifer, the sole-source drinking water aquifer for the metropolitan area, lies partly below the Site. The aquifer exists in geologic formations of limestone and sandlies partly below the Site. The aquifer exists in geologic formations of limestone and sand to depth of about 80 feet, at which point it is confined by layer of relativelyto aa depth of about 80 feet, at which point it is contined by aa layer of relatively impermeable silts and clays. Seasonal fluctuations raise the ground water table to withinimpermeable silts and clays. Seasonal tluctuations raise the ground water table to within

feet of the surface. Regional flow of the Biscayne Aquifer is from west to east at an33 feet of the surface. Regional tlow of the Biscayne Aquifer is from west to east at an average velocity of 1.5 feet/day. Major wellfields that draw water from the Biscayneaverage velocity of 1.5 feet/day. Major welltields that draw water from the Biscayne Aquifer within mile radius of the Site are the Hialeah/Miami Springs welltleldAquifer within aa fivefive mile radius of the Site are the Hialeah/Miami Springs welltield (located approximately 6,000 feet southeast), the John E. Preston wellfield (about miles(located approximately 6,000 feet southeast), the John E. Preston welltield (about 33 miles southeast), and the Northwest wellfield (located less than miles west of the Site).southeast), and the Northwest wellfield (located less than 55 miles west of the Site).

The source water for the Hialeah Water Treatment Plant (WTP) is from theThe source water for the Hialeah Water Treatment Plant (WTP) is from the Hialeah/Miami Springs wellfield, supplemented by the Northwest wellfield. As of 2008,Hialeah/Miami Springs wellfield, supplemented by the Northwest well field. As of 2008, the Hialeah WTP had rated capacity of 60 million gallons per day. The treatmentthe Hialeah WTP had aa rated capacity of 60 million gallons per day. The treatment process at the plant includes lime softening with sodium silicate activated chlorine,process at the plant includes lime softening with sodium silicate activated chlorine, recarbonation, chlorination, fluoridation, filtration and air stripping.recarbonation, chlorination, tluoridation, tiltration and air stripping.

History of ContaminationHistory of Contamination

Chemicals and other products manufactured by B&B include variety of solvents.Chemicals and other products manufactured by B&B include aa variety of solvents,

16

polishes. detergents, oxidizing agents, corrosive inhibitors and metal cleaners. In the mid­polishes, detergents, oxidizing agents, corrosive inliibitors and metal cleaners. In the mid­1970s, inspectorsinspectors fromfrom Miami-Dade County Department of Environmental Resource1970s, Miami-Dade County Department of Environmental Resource Management (DERM) documented wastewater residues in soakage pits at the Site.Management (DERM) documented wastewater residues in soakage pits at the Site. Subsequent to this, DERM issued aa Cease and Desist Order for wastewater discharge toSubsequent to this, DERM issued Cease and Desist Order for wastewater discharge to the soakage pits. In May 1976, B&B put wastewater pre-treatment system intothe soakage pits. In May 1976, B&B put aa wastewater pre-treatment system into operation. During 1979 area-wide ground water study conducted for DERM, twooperation. During aa 1919 area-wide ground water study conducted for DERM, two samples were collected from irrigation wells located on the B&B site. Analytical datasamples were collected from irrigation wells located on the B&B site. Analytical data

these samples indicated the presence of trans-1,2-dichloroethlyene,fromfrom these samples indicated the presence of trans-l ,2-dichloroethlyene, tetrachloroethylene, chlorobenzene, 1,1-dichloroethane, vinylidene chloride andtetrachloroethylene, chlorobenzene, 1, I-dichloroethane, vinylidene chloride and trichloroethylene. In September 1981, constmction workers installing potable water linetrichloroethylene. In September 1981, construction workers installing aa potable water line immediately south of the B&B experienced skin irritation. Analytical data fromimmediately south of the B&B sitesite experienced skin irritation. Analytical data from aa ground water sample collected in the ditch indicated the presence of phenol,ground water sample collected in the ditch indicated t~e presence of phenol, trichoroethylene, tetrachloroethlyene, vinylidene chloride, trans-1,2 dichloroethlyene andtrichoroethylene, tetrachloroethlyene, vinylidene chloride, trans-l ,2 dichloroethlyene and cis-1,2 dichloroethylene. In June 1982, during the constmction of the Metrorail trackcis-l,2 dichloroethylene. In June 1982, during the construction of the Metrorail track immediately south of the Site, workers also complained of skin bums while working inimmediately south of the Site, workers also complained of skin bums while working in the trenches, hi October 1983, DERM issued an Administrative Order direcdng B&B tothe trenches. In October 1983, DERM issued an Administrative Order directing B&B to develop plans for a ground water monitoring system. DERM filed a civil suit againstdevelop plans for a ground water monitoring system. DERM filed a civil suit against B&B in November 1984 for the substantial delay in submitting the requested groundB&B in November 1984 for the substantial delay in submitting the requested ground water monitoring plan.water monitoring plan.

3.43.4 Initial ResponseInitial Response

In August 1985, DERM requested that EPA investigate conditions at the Site. EPAIn August 1985, DERM requested that EPA investigate conditions at the Site. EPA obtained warrant from the Federal District Court in Miami to install monitoring wellsobtained aa warrant from the Federal DistriCt Court in Miami to install monitoring wells and to sample ground water and soils. Results of the 1986 EPA-funded investigation wereand to sample ground water and soils. Results of the 1986 EPA-funded investigation were used to compute Hazard Ranking System (HRS) score for ground water at the Site. Theused to compute aa Hazard Ranking System (HRS) score for ground water at the Site. The HRS score exceeded the threshold at which sites would normally be placed on theHRS score exceeded the threshold at which sites would normally be placed on the National Priorities List (NPL).National Priorities List (NPL).

B&B completed the Remedial Investigation/Feasibility Study (RI/FS) and RemedialB&B completed the Remedial Investigation/Feasibility Study (RIfFS) and aa Remedial Action Plan (RAP) with the use of an environmental consulting in 1987. EPA andAction Plan (RAP) with the use of an environmental consulting firmfirm in 1987. EPA and FDEP found the RI inadequate based on the NCP requirements. Nevertheless, in lateFDEP found the RI inadequate based on the NCP requirements. Nevertheless, in late 1987, an Order of Dismissal and Court Order Stipulation of Settlement were signed by1987, an Order of Dismissal and aa Court Order Stipulation of Settlement were signed by DERM and B&B in Dade County Court. This agreement required theDERM and B&B in Dade County CircuitCircuit Court. This agreement required the constmction and operation of ground water recovery and treatment system. Operationconstruction and operation of aa ground water recovery and treatment system. Operation of the system started in late August 1988 and continued with some intermptions untilof the system started in late August 1988 and continued with some interruptions until May 1993. The system treated more than 37 million gallons of contaminated groundMay 1993. The system treated more than 37 million gallons of contaminated ground water.water.

The proposed for the NPL in June 1988. In April 1989, EPA sent notice letters toThe sitesite waswas proposed for the NPL in June 1988. In April 1989, EPA sent notice letters to B&B, offering the company the opportunity to conduct new RI/FS and informing themB&B. offering the company the opportunity to conduct aa new RI/FS and informing them of their potential liability for all costs associated with the Site. B&B declined to performof their potential liability for all costs associated with the Site. B&B declined to perform an EPA-approved RI/FS. The Site listed on the NPL in August 1990. In Novemberan EPA-approved RI/FS. The Site waswas listed on the NPL in August 1990. In November 1990, the United States District Court for the Southem District of Florida granted EPA1990, the United States District Court for the Southern District of Florida granted EPA access to the Site, permitting to obtain environmental samples for the RI/FS. The RIaccess to the Site, permitting EPEPAA to obtain environmental samples for the RI/FS. The RI

conducted in 1991. The ground water sampling for the 1991 RI occurred 32 monthswaswas conducted in 1991. The ground water sampling for the 1991 RI occurred 32 months

17

after start-up of the ground water recovery and treatment system.after start-up of the ground water recovery and treatment system.

3.53.5 Basis for Taking ActionBasis for Taking Action

The 1991 RI detected the highest concentrations of volatile organic compounds (YOCs)The 1991 RI detected the highest concentrations of volatile organic compounds (VOCs) in the shallow (7 to 20 feet bis) wells, located in the south-central portion of the Site.in the shal10w (7 to 20 feet bls) wel1s, located in the south-central portion of the Site. Tentatively identified compounds were present at this location at significantly higherTentatively identified compounds were present at this location at significaritly higher concentrations than compounds on the target compound list. Organic compounds withconcentrations than compounds on the target compound list. Organic compounds with concentrations marginally above Florida or federal maximum contaminant levels (MCLs)concentrations marginal1y above Florida or federal maximum contaminant levels (MCLs) included vinyl chloride and benzene. Inorganic contaminants detected above MCLsincluded vinyl chloride and benzene. Inorganic contaminants detected above MCLs included cadmium and chromium.included cadmium and chromium.

In August 1992, EPA issued Proposed Plan (PP) for the Site. The PP, based in part onIn August 1992, EPA issued aa Proposed Plan (PP) for the Site. The PP, based in part on the 1991 ground water data, proposed contingent remedy of quarterly ground waterthe 1991 ground water data, proposed aa contingent remedy of quarterly ground water monitoring. If MCLs were exceeded for two consecutive quarters, then ground watermonito~ing. If MCLs were exceeded for two consecutive quarters, then aa ground water remediation system was to be designed and built.remediation system was to be designed and built.

On August 24, 1992, Hurricane Andrew affected South Florida. During the hurricane,On August 24, 1992, Hurricane Andrew affected South Florida. During the hurricane, rainfall swelled surface water features and had major impact on ground water rechargerainfal1 swelled surface water features and had aa major impact on ground water recharge and Four weeks after the hurricane, EPA conducted the next scheduled round ofand flow.flow. Four weeks after the hurricane, EPA conducted the next scheduled round of sampling at the Site. The sampling showed considerably higher concentrations of groundsampling at the Site. The sampling showed considerably higher concentrations of ground water contaminants in number of source area and down-gradient well clusters. Threewater contaminants in aa number of source area and down-gradient well clusters. Three additional rounds of sampling took place, beginning in Febmary 1993 and ending inadditional rounds of sampling took place, beginning in February 1993 and ending in January 1994. Prior to the final round of sampling, EPA issued UnilateralJanuary 1994. Prior to the tinal round of sampling, EPA issued aa Unilateral Administrative Order (UAO) requiring removal of the pump the ground waterAdministrative Order (UAO) requiring removal of the pump fromfrom the ground water recovery well. This done to ensure that contaminant concentrations detected inrecovery well. This waswas done to ensure that contaminant concentrations detected in monitoring wells were not influenced by cyclical operation of the ground water recoverymonitoring wells were not influenced by cyclical operation of the ground water recovery and treatment system. In June 1993, EPA locked the single recovery well located on site,and treatment system. In June 1993, EPA locked the single recovery well located on site, effectively terminating operation of the ground water treatment system.effectively terminating operation of the ground water treatment system.

In May 1994, EPA issued second PP for the Site. The new PP considered ground waterIn May 1994, EPA issued aa second PP for the Site. The new PP considered ground water data collected since the initial P and Hurricane Andrew. The results of the samplingdata col1ected since the initial PPP and Hurricane Andrew. The results of the sampling reflected favorable, downward trend in ground water contamination. The new PPreflected aa favorable, downward trend in ground water contamination. The new PP differed the initial PP in that contingent remedy of ground water treatment was notdiffered fromfrom the initial PP in that aa contingent remedy of ground water treatment was not pre-established if ground water contamination trends increased rapidly.pre-established if ground water contamination trends increased rapidly.

Contaminants of concern (COCs) identified at the Site were constituents commonlyContaminants of concern (COCs) identified at the Site were constituents commonly associated with chemical manufacturing operations that posed aa threat to human healthassociated with chemical manufacturing operations that posed threat to human health and the environment. The primary COCs identified in the 1994 RIfFS included benzene,and the environment. The primary COCs identified in the 1994 RI/FS included benzene, chlorobenzene, chromium and vinyl chloride in ground water.chlorobenzene, chromium and vinyl chloride in ground water.

In the 1992 Baseline Risk Assessment, EPA evaluated all potential exposure pathwaysIn the 1992 Baseline Risk Assessment, EPA evaluatedal1 potential exposure pathways that could expose human receptors to the various contaminant sources. The followingthat could expose human receptors to the various contaminant sources. The following pathways were evaluated under current land use conditions:pathways were evaluated under current land use conditions:

Exposure of on-site workers to contaminants in surface soil through incidental•• Exposure of on-site workers to contaminants in surface soil through incidental

18

ingestion and dennal contact.ingestion and dennal contact.

The following pathways were evaluated under future land use conditions:The following pathways were evaluated under future land use conditions:

•• Exposure of on-site constmction workers to contaminants in surface andExposure of on-site construction workers to contaminants in surface and subsurface soil through incidental ingestion, dennal contact and inhalation ofsubsurface soil through incidental ingestion, dermal contact and inhalation of contaminants in air (dust vapor).contaminants in air (dust vapor).

•• Exposure of trespassers to contaminants in surface soil through incidentalExposure of trespassers to contaminants in surface soil through incidental ingestion and dennal contact.ingestion and dermal contact.

•• Exposure of on-site residents to contaminants in ground water throughExposure of on-site residents to contaminants in ground water through ingestion, dennal contact and inhalation.ingestion, dermal contact and inhalation.

The 1992 Baseline Risk Assessment found that sitesite ground water containedThe 1992 Baseline Risk Assessment found that ground water contained concentrations of site-related contaminants that may pose risk to human health iftheconcentrations of site-related contaminants that may pose aa risk to human health if the ground water were used for human consumption. Exceedances of MCLs were observedground water were used for human consumption. Exceedances of MCLs were observed for several analytes. Locally, the Biscayne Aquifer not used for potable water.for several analytes. Locally, the Biscayne Aquifer waswas not used for potable water. However, the Miami-Dade Water and Sewer Authority currently uses water from theHowever, the Miami-Dade Water and Sewer Authority currently uses water from the Hialeah/Miami Springs and Northwest wellfields at the Hialeah WTP, located less thanHialeah/Miami Springs and Northwest wellfields at the Hialeah WTP, located less than

miles from the Site. The Site is within the cone of depression caused by groundfivefive miles from the Site. The Site is within the cone of depression caused by ground water pumpage for the Hialeah WTP. Due to the area-wide ground water contamination,water pumpage for the Hialeah WTP. Due to the area-wide ground water contamination, ground water is treated at the Hialeah WTP by air stripping of VOCs prior to distribution.ground water is treated at the Hialeah WTP by air stripping of VOCs prior to distribution. Semivolatile organic and inorganic compounds are not treated.Semivolatile organic and inorganic compounds are not treated.

The 1992 Baseline Risk Assessment concluded that based on risk calculations, the'The 1992 Baseline Risk Assessment concluded that based on risk calculations, the noncarcinogenic and carcinogenic risksrisks related to soil were below the EPA level ofnoncarcinogenic and carcinogenic related to soil were below the EPA level of concem or benchmark values for risk. Therefore, no remedial goals on risk wereconcern or benchmark values for risk. Therefore, no remedial goals basedbased on risk were established for soils at the Site. It was concluded in the 1992 Baseline Risk Assessmentestablished for soils at the Site. It was concluded in the 1992 Baseline Risk Assessment that leaching of contaminants contaminated soil was negligible because the vastthat leaching of contaminants fromfrom contaminated soil was negligible because the vast majority of the Site is covered by impervious material (asphalt and buildings). Because itmajority of the Site is covered by impervious material (asphalt and buildings). Because it was assumed that the Site would continue to be covered by impervious material in thewas assumed that the Site would continue to be covered by impervious material in the foreseeable future, soil remedial goals based on contaminant leaching were notforeseeable future, soil remedial goals based on contaminant leaching were not considered. Therefore, no remedial goals were developed for soils on potentialconsidered. Therefore, no remedial goals were developed for soils basedbased on potential ground water contamination.ground water contamination.

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4.0 Remedial Actions4.0 Remedial Actions

In accordance with CERCLA and the NCP, the overriding goals for any remedial action areIn accordance with CERCLA and the NCP, the overriding goals for any remedial action are protection of human health and the environment and compliance with Applicable or Relevantprotection of human health and the environment and compliance with Applicable or Relevant and Appropriate Requirements (ARARs). number of remedial altematives were considered forand Appropriate Requirements (ARARs). AA number of remedial alternatives were considered for the Site, and selection made on an evaluation of each alternative against ninethe Site, and finalfinal selection waswas made basedbased on an evaluation of each alternative against nine evaluation criteria that are specified in Section 300.430(e)(9)(iii) of the NCP. The nine criteriaevaluation criteria that are specified in Section 300.430(e)(9)(iii) of the NCP. The nine criteria include:include:

1.1. OverallOverall ProtectivenessProtectiveness of Human Health and the Environmentof Human Health and the Environment 2.2. ComplianceCompliance with ARARswith ARARs 3.3. Long-TermLong-Term Effectiveness and PermanenceEffectiveness and Permanence

Reduction of Toxicity, Mobility or Volume of Contaminants through Treatment4.4. Reduction of Toxicity, Mobility or Volume of Contaminants through Treatment 5.5. Short-termShort-term EfIectivenessEffectiveness 6.6. ImplementabilityImplementability 7.7. CostCost 8.8. StateState AcceptanceAcceptance 9.9. CommunityCommunity AcceptanceAcceptance

4.4. I1 Remedy SelectionRemedy Selection

EPA issued the Site's ROD on September 12, 1994. Although the 1994 ROD did notEPA issued the Site's ROD on September 12,1994. Although the 1994 ROD did not specify Remedial Action Objectives (RAOs), it did state that the remedy was selected tospecify Remedial Action Objectives (RAOs), it did state that the remedy was selected to mitigate the threat to human health and meet federal and Florida MCLs. In addition, themitigate the threat to human health and meet federal and Florida MCLs. In addition, the 1992 Feasibility Study identified RAOs on existing or potential hazards identified1992 Feasibility Study identified RAOs basedbased on existing or potential hazards identified in the 1992 Baseline Risk Assessment, including:in the 1992 Baseline Risk Assessment, including:

•• Prevent ingestion of water having carcinogen concentrations in excess ofPrevent ingestion of water having carcinogen concentrations in excess of federal/state ARARs and aa total excess cancer risk of greater than 10-6

.federal/state ARARs and total excess cancer risk of greater than 10' . •• Prevent ingestion of water having noncarcinogen(s) in excess of federal/statePrevent ingestion of water having noncarcinogen(s) in excess of federal/state

ARARs and risk assessment criteria.ARARs and risk assessment criteria. •• Restore the ground water system by cleanup to the health-based standards (asRestore the ground water system by cleanup to the health-based standards (as

stated above) and by preventing the migration of pollutants beyond the existingstated above) and by preventing the migration of pollutants beyond the existing . limits of the known contaminant plume.limits of the known contaminant plume.

•• Prevent ingestion or direct contact with contaminated soil having greater than 10'Prevent ingestion or direct contact with contaminated soil having greater than 10-6

excess cancer risk or exceeding public health assessment criteria forexcess cancer risk or exceeding public health assessment criteria for noncarcmogens.noncarcinogens.

The remedy selected in the 1994 ROD waswas consistent with the May 1994 PPP andThe remedy selected in the 1994 ROD consistent with the May 1994 P and consisted of the following remedial components:consisted of the following remedial components:

•• Natural attenuation of ground water contaminants.Natural attenuation of grqund water contaminants. •• Monitoring ground water to verify natural attenuation.Monitoring ground water to verify natural attenuation.

Implementing institutional controls in the form of notification agreement•• Implementing institutional controls in the form of aa notification agreement between EPA and the landowner to ensure the continued integrity of the asphaltbetween EPA and the landowner to ensure the continued integrity of the asphalt cover.cover.

2020

The 1994 ROD selected cleanup goals for four ground water COCs (Table 3).The 1994 ROD selected cleanup goals for four ground water COCs (Table 3).

TTablblee 33 :: GGrounroundd Wat er cac CIeanup Ga Water COC Cleanup Goaloa ss

Ground;water COC . .:...::.Groundwater COC ROD Cleanup Goal (^g/L)ROD Cleanup Goal (JJ.2:/L) I1

Vinyl chloride BenzeneBenzene I1 ChlorobenzeneChlorobenzene 100

Vinyl chloride

100 ChromiumChromium 100100

In January 2007, EPA conducted aa sitesite visit to evaluate potential vapor intrusion (VI)(VI)In January 2007, EPA conducted visit to evaluate potential vapor intmsion issues for each on-site building. An EPA memorandum, dated Febmary 20, 2007issues for each on-site building. An EPA memorandum, dated February 20, 2007 (Appendix F), concluded that VI is not risk for existing buildings on the Site. However,(Appendix F), concluded that VI is not aa risk for existing buildings on the Site. However, any future constmction at the Site should consider the for VI.any future construction at the Site should consider the potentialpotential for VI.

The selected remedy revised by the June 2009 Explanation of Significant DifferencesThe selected remedy waswas revised by the June 2009 Explanation of Significant Differences (ESD). The 2009 ESD required institutional controls to ensure the remedy remains(ESD). The 2009 ESD required institutional controls to ensure the remedy remains protective of human health, fri addition, the 2009 ESD removed the 1994 RODprotective of human health. In addition, the 2009 ESD removed the 1994 ROD requirement for round of ground water sampling. This requirement removedrequirement for aa finalfinal round of ground water sampling. This requirement waswas removed because performance standards were met for all monitoring wells in two consecutivebecause performance standards were met for all monitoring wells in two consecutive rounds of sampling.rounds of sampling.

The 2009 ESD required restrictive covenants be placed on the properties to:The 2009 ESD required restrictive covenants be placed on the sitesite properties to:

Ensure that the integrity of existing impermeable surfaces is maintained.•• Ensure that the integrity of existing impermeable surfaces is maintained. Ensure that future use of the property remains commercial or industrial.•• Ensure that ftiture use of the property remains commercial or industrial.

Q Ensure that the potential for VI into any newly constructed buildings is evaluated and« Ensure that the potential for VI into any newly constmcted buildings is evaluated and properly addressed.properly addressed.

4.24.2 Remedy ImplementationRemedy Implementation

On September 5, 1995, EPA issued UAO that directed B&B to perform the workOn September 5, 1995, EPA issued aa UAO that directed B&B to perform the work described in the 1994 ROD. The UAO clarified that the notification agreement requiresdescribed in the 1994 ROD. The UAO claritied that the notification agreement requires B&B or the owners of the property.to provide 60 days written notice prior toB&B or the owners of the sitesite property. to provide 60 days written notice prior to disturbing the asphalt/pavement cover or prior to the sale of the property. Remedialdisturbing the asphalt/pavement cover or prior to the sale of the property. Remedial design began on September 20, 1995, and was completed on October 18, 1995. Thedesign began on September 20, 1995, and was completed on October 18, 1995. The

institutional controls established in the 2009 ESD have not been implemented.additionaladditional institutional controls established in the 2009 ESD have not been implemented. EPA, FDEP and the property owner are working together to ensure that the restrictiveEPA, FDEP and the property owner are working together to ensure that the restrictive covenants are implemented as required.covenants are implemented as required.

For the post-ROD ground water monitoring program, eight wells ranging in depth fromfromFor the post-ROD ground water monitoring program, eight wells ranging in depth 8.56 to 87 feet were selected. The three on-site wells were in the south-central part of the8.56 to 87 feet were selected. The three on-site wells were in the south-central part of the property (the area of historical contamination). The remaining wells in the Longproperty (the area of historical contamination). The remaining fivefive wells in the Long Term Monitoring (LTM) program were offsite, south and south-east of the contaminatedTerm Monitoring (LTM) program were off site, south and south-east of the contaminated area, which is consistent with the expected ground water flow direction and observationsarea, which is consistent with the expected ground water flow direction and observations of contamination during previous monitoring events. On December 7, 1995, B&Bof contamination during previous monitoring events. On December 7, 1995, B&B

2121

initiated ground water monitoring in accordance with the ROD.initiated ground water monitoring in accordance with the ROD.

Semi-annual sampling of the ground water waswas conducted in accordance with the RODSemi-annual sampling of the ground water conducted in accordance with the ROD beginning in December 1995. The 1994 ROD allowed sampling of any well to be stoppedbeginning in December 1995. The 1994 ROD allowed sampling of any well to be stopped when the well attained the required MCLs for two consecutive rounds of sampling. Bywhen the well attained the required MCLs for two consecutive rounds of sampling. By January 1999, monitoring had stopped for six of the eight wells. Upon completion of theJanuary 1999, monitoring had stopped for six of the eight wells. Upon complefion of the January 2007 sampling event, the finalfinal two wells qualitied for stopping semiannualJanuary 2007 sampling event, the two wells qualified for stopping semiannual monitoring.monitoring.

After reviewing the results of the 2007 ground water sampling, FDEP and EPAAfter reviewing the results of the 2007 ground water sampling, FDEP and EPA determined that the cleanup goals specified in the 1994 ROD had been met and there wasdetermined that the cleanup goals specitied in the 1994 ROD had been met and there was no need to continue with regular, semiannual sampling of the monitoring wells. Further,no need to continue with regular, semiannual sampling of the monitoring wells. Further, upon consultation with FDEP, EPA issued an ESD in 2009 removing the 1994 RODupon consultation with FDEP, EPA issued an ESD in 2009 removing the 1994 ROD requirement of final round of sampling for all monitoring wells associated with the Site.requirement of aa tinal round of sampling for all monitoring wells associated with the Site.

4.34.3 Operation and Maintenance (Oi&M)Operation and Maintenance (O&M)

With completion of the monitoring program, long-term O&M is limited to needed repairsWith completion of the monitoring program, long-term O&M is limited to needed repairs and maintenance of the asphalt areas of the Site. There have not been any needed repairsand maintenance of the asphalt areas of the Site. There have not been any needed repairs or maintenance to these areas during the last years. During the five years since theor maintenance to these areas during the last fivefive years. During the tive years since the 2007 FYR and the completion of the monitoring program, no O&M costs have been2007 FYR and the completion of the monitoring program, no O&M costs have been incurred.incurred.

2222

5.0 Progress Since the Last Five-Year Review5.0 Progress Since the Last Five-Year Review

The protectiveness statement from the 2007 FYR for the Site stated the following:The protectiveness statement from the 2007 FYR for the Site stated the following:

"Human Health Present: The remedies established in the ROD are present~y protective ofhuman health. This has "Human Health

Present: The remedies established in the ROD are presently protective of human health. This has been demonstrated by results ofthe Long-Terrn Monitoring (LTM) lvhich show that the arealbeen demonstrated by results of the Long-Term Monitoring (LTM) which show that the areal extent and level ofcontamination has continued to decrease. and do not impact the nearbyextent and level of contamination has continued to decrease, and do not impact the nearby municipal1vellfield.municipal wellfield. Future: It is e.\pected that natllral attenuation and source control (contaminant isolation) willFuture: It is expected that natural attenuation and source control (contaminant isolation) will continue to be protective oflmman health. Implementation of a deed restriction will assure thatcontinue to be protective o/human health. Implementation ofa deed restriction will assure that future owners maintain adequate source control.future owners maintain adequate source control.

Protection ofthe EnvironmentProtection of the Environment The ROD aclalOwledged that the site and its vicinity is an area oflight industrial and limitedThe ROD acknowledged that the site and its vicinity is an area of light industrial and limited residential use, with most of the area covered by buildings, pavement, or other man-maderesidential use. with most ofthe area covered by buildings. pavement. or other man-made features such as rail lines. As such, this area provides little habitat for wildlife and very littlefeatllres such as rail lines. As such, this area provides little habitatfor wildl({e and ve,y little opportunity for exposure of flora andfauna to contamination. However, the remedy of sourceopportunity for e.\posure offlora andfawla to contamination. However. the remedy o.{source control through the use of the asphalt/pavement cover assures that the remedy is now and willcontrol through the use o.lthe asphalt/pavement cover assures that the remedy is now and will continue to be protective o.fthe environmentenvironment.continue to be protective of the . .."

The 2007 FYR included two issues and two recommendations (Table 4). Each recommendationThe 2007 FYR included two issues and two recommendations (Table 4). Each recommendation and its current status is discussed below.and its current status is discussed below.

Table 4: Progress on Recommendations from the 2007 FYRTable 4: Progress on Recommendations from the 2007 FYR

Party Milestone' Acidbn-Taicen^and^;- • Dateof 4. Section· ... Acti0onu>:Itc'~o:'~m~e,~.~d.:· > Date of, <Section Recommendations D a t e ' * ^ ' Action'

Establish deed EPA issued an ESD .. ~.:.: :-:::~::>j.:.:.:<).<. "::; Responsible ; • Action

Establish aa deed EPA issued an ESD restrictionrestriction clarifying the need forclarifying the need tor

institutional controls 09/30/2008 OngoingOngoing

institutional controls 5.15.1 B&BB&B 09/30/2008 andand is working withis working with

B&B to implement theB&B to implement the required deedrequired deed restrictions.

Verify that the SiteVerify that the Site EPA provided restrictions. EPA provided

informationinformation is properlyis properly documents to thedocuments to the 5.25.2 maintained and EPA 10/31/2007 information repository. 10/31/2007maintained and EPA 10/31/2007 information repository. 10/31/2007

accessible in theaccessible in the information repositoryinformation repository

5.1 Establish aa Deed RestrictionEstablish5.1 Deed Restriction

EPA issued an ESD on June 12, 2009. The 2009 ESD required restrictive covenants beEPA issued an ESD on June 12,2009. The 2009 ESD required restrictive covenants be placed on the site properties to:placed on the site properties to:

Ensure that the integrity of existing impermeable surfaces is maintained.•• Ensure that the integrity of existing impermeable surfaces is maintained.

•• Ensure that future use of the property remains commercial or industrial.Ensure that future use of the property remains commercial or industrial. •• Ensure that the potentialpotential for VI into any newly constructed buildings is evaluated andEnsure that the for VI into any newly constmcted buildings is evaluated and

properly addressed.properly addressed.

EPA is currently working with B&B to implement the required restrictive covenants onEPA is currently working with B&B to implement the required restrictive covenants on the necessary property parcels.the necessary property parcels.

Verify that the site information is properly maintained and accessible in the5.25.2 Verify that the site information is properly maintained and accessible in the information repository.information repository.

EPEPAA provided documents to the information repository in 2007. During the sitesite visit forprovided documents to the information repository in 2007. During the visit for the current FYR, contractor staff from Skeo Solutions verified that the records availablethe current FYR, contractor staff from Skeo Solutions verified that the records available at the information repository are up-to-date.at the information repository are up-to-date.

24

6.0 Five-Year Review Process6.0 Five-Year Review Process

Administrative Components6.16.1 Administrative Components

EPA Region 44 initiated the FYR in October 2011 and scheduled its completion for AprilEPA Region initiated the FYR in October 2011 and scheduled its completion for April 2012. The EPA sitesite review team waswas led by EPA Remedial Project ManagerManager (RPM)2012. The EPA review team led by EPA Remedial Project (RPM) Shelby Johnston and also included EPA RPM Bill Denman, EPA CommunityShelby Johnston and also included EPA RPM Bill Denman, EPA Community Involvement Coordinator (CrC) L'Tonya Spencer, FDEP representative Theresa PepeInvolvement Coordinator (CIC) L'Tonya Spencer, FDEP representative Theresa Pepe and contractor support provided to EPA by Skeo Solufions. In October 2011, EPA heldand contractor support provided to EPA by Skeo Solutions. In October 2011, EPA held aa scoping call with the review team to discuss the Site and items of interest as they relatedscoping call with the review team to discuss the Site and items of interest as they related to the protectiveness of the remedy currently in place. review schedule establishedto the protectiveness of the remedy currently in place. AA review schedule waswas established that consisted of the following activities:that consisted of the following activities:

•• Community notification.Community notification. •• Document review.Document review.

Data collection and review.•• Data collection and review. •• Site inspection.Site inspection. •• Local interviews.Local interviews. •• FYR Report development and review.FYR Report development and review.

Community Involvement6.26.2 Community Involvement

Ll March 2012, public notice published in the Miami Today newspaper announcingIn March 2012, aa public notice waswas published in the Miami Today newspaper announcing the commencement of the FYR process for the Site, providing contact infonnation forthe commencement of the FYR process for the Site, providing contact information for EPA, and inviting community participation. The notice is available in Appendix B.EPA, and inviting community participation. The presspress notice is available in Appendix B. No one contacted EPA as result of this advertisement.No one contacted EPA as aa result of this advertisement.

The FYR Report will be made available to the public once it has been CopiesThe FYR Report will be made available to the public once it has been finalized.finalized. Copies of this document will be placed in the designated repository: John F. Kennedyof this document will be placed in the designated sitesite repository: John F. Kennedy Library, located at 190 West 49"" Street, Hialeah, Florida 33012.Library, located at 190 West 49th Street, Hialeah, Florida 33012.

6.36.3 Document ReviewDocument Review

This FYR included review of relevant, site-related documents including the ROD,This FYR included aa review of relevant, site-related documents including the ROD, remedial action reports, and recent monitoring data. complete list of the documentsremedial action reports, and recent monitoring data. AA complete list of the documents reviewed can be found in Appendix A.reviewed can be found in Appendix A.

ARARs ReviewARARs Review

CERCLA Section 121(d)(1) requires that Superfund remedial actions attain "a degree ofCERCLA Section 121 (d)(l) requires that Superfund remedial actions attain "a degree of cleanup of hazardous substance, pollutants, and contaminants released into thecleanup of hazardous substance, pollutants, and contaminants released into the environment and of control of further release at minimum which assures protection ofenvironment and of control 'of further release at aa minimum which assures protection of human health and the environment." The remedial action must achieve level of cleanuphuman health and the environment." The remedial action must achieve aa level of cleanup that at least attains those requirements that are legally applicable or relevant andthat at least attains those requirements that are legally applicable or relevant and appropriate. Applicable requirements are those cleanup standards, standards of control,appropriate. Applicable requirements are those cleanup standards, standards of control, and other substantive requirements, criteria, or limitations promulgated under federaland other substantive requirements, criteria, or limitations promulgated under federal

2525

environmental or state environmental or facility siting laws that specifically address aaenvironmental or state environmental or facility siting laws that specifically address hazardous substance, remedial action, location, or other circumstance found athazardous substance, remedial action, location, or other circumstance found at aa CERCLA site. Relevant and appropriate requirements are those standards that, while notCERCLA site. Relevant and appropriate requirements are those standards that, while not "applicable," address problems or situations sufficiently similar to those encountered at"applicable," address problems or situations sut1iciently similar to those encountered at the CERCLA site that their use is well suited to the particular site. Only those statethe CERCLA site that their use is well suited to the particular site. Only those state standards that are more stringent than federal requirements may be applicable or relevantstandards that are more stringent than federal requirements may be applicable or relevant and appropriate. To-Be-Considered (TBC) criteria are non-promulgated advisories andand appropriate. To-Be-Considered (TBC) criteria are non-promulgated advisories and guidance that are not legally binding, but should be considered in determining theguidance that are not legally binding, but should be considered in determining the necessary remedial action. For example, TBC criteria may be particularly usefial innecessary remedial action. For example, TBC criteria may be particularly useful in determining health-based levels where no ARARs exist or in developing the appropriatedetermining health-based levels where no ARARs exist or in developing the appropriate method for conducting remedial action.method for conducting aa remedial action.

Chemical-specific ARARs are health- or risk-based numerical values or methodologiesChemical-specific ARARs are health- or risk-based numerical values or methodologies which, when applied to site-specific conditions, result in the establishment of numericalwhi~h, when applied to site-specific conditions, result in the establishment of numerical values. These values establish an acceptable amount or concentration of chemical thatvalues. These values establish an acceptable amount or concentration of aa chemical that may remain in, or be discharged to, the ambient environment. Examples of chemical­may remain in, or be discharged to, the ambient environment. Examples of chemical­specific ARARs include MCLs under the Federal Safe Drinking Water Act and ambientspecific ARARs include MCLs under th~ Federal Safe Drinking Water Act and ambient water quality criteria enumerated under the Federal Clean Water Act.water quality criteria enumerated under the Federal Clean Water Act.

Action-specific ARARs are technology- or activity-based requirements or limits onAction-specific ARARs are technology- or activity-based requirements or limits on actions taken with respect to particular hazardous substance. These requirements areactions taken with respect to aa particular hazardous substance. These requirements are triggered by particular remedial activity, such as discharge of contaminatedtriggered by aa particular remedial activity, such as discharge of contaminated groundwater or in-situ remediation.groundwater or in-situ remediation.

Location-specific ARARs are restrictions on hazardous substances or the conduct of theLocation-specific ARARs are restrictions on hazardous substances or the conduct of the response activities solely based on their location in special geographic area. Examplesresponse activities solely based on their location in aa special geographic area. Examples include restrictions on activities in wetlands, sensitive habitats and historic places.include restrictions on activities in wetlands, sensitive habitats and historic places.

Remedial actions are required to comply with the chemical-specific ARARs identified inRemedial actions are required to comply with the chemical-specific ARARs identified in the ROD. In performing the FYR for compliance with ARARs, only those ARARs thatthe ROD. In performing the FYR for compliance with ARARs, only those ARARs that address the protectiveness of the remedy are reviewed.address the protectiveness of the remedy are reviewed.

Ground Water ARARsGround Water ARARs According to the 1994 ROD, cleanup goals for ground water COCs were basedbased on theAccording to the 1994 ROD, cleanup goals for ground water COCs were on the federal National Primary Drinking Water Standards and Florida MCL values. ARARsfederal National Primary Drinking Water Standards and Florida MCL values. ARARs from the 1994 ROD were compared to the current National Primary Drinking Waterfrom the 1994 ROD were compared to the current National Primary Drinking Water Standards and Florida MCL values (Table 5). There have been no changes in the federalStandards and Florida MCL values (Table 5). There have been no changes in the federal or state MCLs for the COCs.or state MCLs for the COCs.

2626

6.46.4

6.56.5

Table 5: Previous and Current ARARs for Ground Water COCsTable 5: Previous and Current ARARs for Ground Water COCs

,",Grollnd'Water Current;• Groundwater 19941994 RODROD/~ 'Yit' CUrrent .-

A R A R S ChangeARARs CI1'~~geCOCs ARARs (p.lglLf:;'; f*,A'Rj\Rs (p.lg/L)

Benzene I1 None

COCs AJRARs (^g/L) ARARs (Hg/L)

Benzene I" Noner Chlorobenzene 100 100b NoneNoneChlorobenzene 100 100"

ChromiumCliromium 100 100" None100 100" None

Vinyl chlorideVinyl chloride I1 pI" NoneNone

a.a. Based on Florida Ground Water and Surface Water Contaminant Cleanup TargetBased on Florida Ground Water and Surface Water Contaminant Cleanup Target Levels, available at: http://\v\vw.dep.state.tl.us/water/drinkincwater/standard.htmLevels, available at: http://www.dep.state.ll. us!water/drinkinl!water!standard.htm (accessed 2/2/12).(accessed 2/2/12).

b. Based on National Primary Drinking Water Regulations, available at:b. Based on National Primary Drinking Water Regulations, available at: http:.'/waier.epa.u,ov/drinky'coiitaminants/index.cfm (accessed 2/2/12).http://w<iter.epa.gov/drink/contaminants/index.c lin (accessed 2/2!12).

Data ReviewData Review

Post-ROD ground water sampling waswas initiated in December 1995. Sampling continuedPost-ROD ground water sampling inifiated in December 1995. Sampling continued on semiannual basis until 2007. After reviewing the results of the 2007 ground wateron aa semiannual basis until 2007. After reviewing the results of the 2007 ground water sampling, FDEP and EPA determined that the cleanup goals specified in the 1994 RODsampling, FDEP and EPA determined that the cleanup goals specitled in the 1994 ROD had been met and that there no need to continue with regular, semi-annual samplinghad been met and that there waswas no need to continue with regular, semi-annual sampling of the monitoring wells. Further, upon consultation with FDEP, EPA issued the 2009of the monitoring wells. Further, upon consultation with FDEP, EPA issued the 2009 ESD that removed the requirement for final round of ground water sampling. Therefore,ESD that removed the requirement for aa tlnal round of ground water sampling. Therefore, no data have been collected since the previous FYR and there are no data to review forno data have been collected since the previous FYR and there are no data to review for the current FYR.the current FYR.

Site InspectionSite Inspection

On January 27,2012, Treat Suomi and Lynette Wysocki (Skeo(Skeo Solutions), ShelbyOn January 27, 2012, Treat Suomi and Lynette Wysocki Solutions), Shelby Johnston, Bill Denman, and La'Tonya Spencer (EPA), Bryan Brock (the site owner) andJohnston, Bill Denman, and La'Tonya Spencer (EPA), Bryan Brock (the site owner) and Theresa Pepe (FDEP) met at the entrance, located at 875 West 20'' Street, Hialeah,Theresa Pepe (FDEP) met at the sitesite entrance, located at 875 West 20lh Street, Hialeah, Florida 33010, to participate in the site inspection. The visit participants met inFlorida 33010, to participate in the site inspection. The sitesite visit participants met in aa conference room at the facility and discussed the history, regulatory documents, pastconference room at the facility and discussed the sitesite history, regulatory documents, past studies and property parcels. Participants also discussed the necessary requirements forstudies and property parcels. Participants also discussed the necessary requirements for the implementation of institutional controls on the property. Following the meeting,the implementation of institutional controls on the sitesite property. Following the meeting, Bryan Brock gave tour of the Site. The group toured the Site to observe the condition ofBryan Brock gave aa tour of the Site. The group toured the Site to observe the condition of all remedial components:all remedial components:

•• Asphalt/concrete pavement cover.Asphalt/concrete pavement cover. •• Inactive monitoring wells.Inactive monitoring wells. •• Institutional controls.Institutional controls.

Other observations and discussions included current activities, possibleOther observations and discussions included current sitesite activities, possible decommissioning of the inactive monitoring wells, and surrounding light landdecommissioning of the inactive monitoring wells, and surrounding light industrialindustrial land uses. The group found the Site well maintained and the remedy functioning as intended.uses. The group found the Site well maintained and the remedy functioning as intended. Skeo Solutions staff took photographs of conditions at the Site (Appendix E) andSkeo Solutions staff took photographs of conditions at the Site (Appendix E) and completed the Site Inspection (Appendix D).completed the Site Inspection ChecklistChecklist (Appendix D).

2727

On January 26, 2012, Skeo Solutions staff visited the designated site informationOn January 26, 2012, Skeo Solutions staff visited the designated site infonnation repository, John F. Kennedy Library, located at 190 West 491h Street, Hialeah, Floridarepository, John F. Kennedy Library, located at 190 West 49''' Street, Hialeah, Florida 33012, as part of the site inspection. The infonnation at the library included the33012, as part of the site inspection. The informafion at the library included the Administrative Record as of 1995, the 2007 FYR, and the 2009 ESD.Administrative Record as of 1995, the 2007 FYR, and the 2009 ESD.

EPA is currently working with FDEP and B&B to the required restrictiveEPA is currently working with FDEP and B&B to implementimplement the required restnctIve covenants. Table 66 and Figure 33 summarize the institutional controls associated withcovenants. Table and Figure summarize the institutional controls associated with areas of interest at the Site.areas of interest at the Site.

Table 6: Institutional Controls (ICs)Table 6: Institutional Controls (ICs)

• • - " ; • • • • • - • . " : • • . n ' ' ­ '" "h>~'>ICsCaUed^^ ~~~ ~a~::~~ j,:l':~~~ted Iefor in the; >» ^,,-impacted. IC Instrument inInstrumeiit'in

Media Decision?:\/> Parcel(s) Objective Documents >"

Neieded Decision*'*'' ParceKs) Objective sii PIaee>Place::-Documents,

Ensure integrity ofEnsure integrity of existing impermeableexisting impermeable surfaces aresurfaces are

04-3013-001- maintained, future use04-3013-001­ maintained, fliture use 0170,04­0170,04- of the propertyof the property 3013-001­3013-001- remains commercial orremains commercial or

SoilSoil Yes Yes NoneYes Yes None0171 and 04­ industrial, and the 3013-001- potentialpotential for VI into 0171 and 04- industrial, and the 3013-001­ for VI into 01720172 any newly constructedany newly constructed

buildings is evaluatedbuildings is evaluated and properlyand properly addressed.addressed.

GroundGround NotNotNoNo No Not Applicable NoneNo Not Applicable None

ApplicableWaterWater Applicable

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•dmm

Figure 3: Institutional Control Base MapFigure 3: Institutional Control Base Map

r n,.' r-.

^ "I Highway 934 - Hialeah Expressway

vVesnMWBI^PP*"*'*

LeQ&ndLegend

o____1ST!;;-======- 350350 l~~l Parcels175 Feet o Parcelsars m, • i f ee l t ' / .y Area requiring deed restrictionf.2ZJ Area requiring deed restriction

n B &BB Chemical Co., Inc. Superfund SiteB& Chemical Co., Inc. Superfund Site Hialeah, Miami-Dade County, FloridaHialeah, Miami-Dade County, Florida

• : . - /NORTH

Disclaimer; This inap and any boundary lines within the map are approximate and subject to change. The map is not survey. The map is for informational puiposes only regarding EPA's responseDisclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not aa survey. The map is for informational pwposes only regarding EPA's response actions at the Site, and is not intended for any other purpose.actions at the Site, and is not intended for any other purpose.

2929

6.66.6

(_

InterviewsInterviews

During the FYR process, interviews were conducted with parties impacted by the Site,During the FYR process, interviews were conducted with parties impacted by the Site, including the current landowners and regulatory agencies that are involved in siteincluding the current landowners and regulatory agencies that are involved in site activities or are aware of the Site. The purpose of the interviews to document theactivities or are aware of the Site. The purpose of the interviews waswas to document the perceived status of the Site and any perceived problems or successes with the phases ofperceived status of the Site and any perceived problems or successes with the phases of the remedy that have been implemented to date. All of the interviews were conductedthe remedy that have been implemented to date. All of the interviews were conducted during the inspection on January 27, 2012. Interviews are summarized below andduring the sitesite inspection on January 27,2012. Interviews are summarized below and complete interviews are included in Appendix C.complete interviews are included in Appendix C.

Bryan Brock: Mr. Brock is the site owner and president of B&B. Mr. Brock believes thatBryan Brock: Mr. Brock is the site owner and president of B&B. Mr. Brock believes that the remedial activities were completed smoothly. Mr. Brock believes that the Site has notthe remedial activities were completed smoothly. Mr. Brock believes that the Site has not impacted the surrounding community because the surrounding area is industrial and heimpacted the surrounding community because the surrounding area is industrial and he has not received any complaints or inquiries about the Site. Mr. Brock stated that hehas not received any complaints or inquiries about the Site. Mr. Brock stated that he would like to review the institutional controls that are going to be put in place before hewould like to review the institutional controls that are going to be put in place before he comments about the current performance of the remedy. Mr. Brock feels that EPA iscomments about the current performance of the remedy. Mr. Brock feels that EPA is keeping him informed, but that nothing has been done at the Site in recent years.keeping him informed, but that nothing has been done at the Site in recent years.

Theresa Pepe: Ms. Pepe from FDEP believes that the Site has met the ROD cleanup goalsTheresa Pepe: Ms. Pepe from FDEP believes that the Site has met the ROD cleanup goals and the remedy is complete. Ms. Pepe stated that the Site is ready for deletion from theand the remedy is complete. Ms. Pepe stated that the Site is ready for deletion from the NPL after final implementation of the controls. She has not received anyNPL after final implementation of the institutionalinstitutional controls. She has not received any complaints or inquiries about the Site. Ms. Pepe stated that FDEP coordinated with EPAcomplaints or inquiries about the Site. Ms. Pepe stated that FDEP coordinated with EPA to issue the ESD and implement the institutional controls. Ms. Pepe is not aware of anyto issue the ESD and implement the institutional controls. Ms. Pepe is not aware of any changes to state laws that affect the protectiveness of the Site's remedy. Ms. Pepe statedchanges to state laws that afIect the protectiveness of the Site's remedy. Ms. Pepe stated that the institutional confrols are in progress, but that the institutional control research isthat the institutional controls are in progress, but that the institutional control research is taking while. Ms. Pepe recommends that the institutional controls be put into place astaking aa while. Ms. Pepe recommends that the institutional controls be put into place as soon as possible.soon as possible.

Bill Denman: Bill Denman is the EPA RPM for the Site. Mr. Denman believes that theBill Denman: Bill Denman is the EPA RPM for the Site. Mr. Denman believes that the project team has been very cooperative, especially the owner, making things easier.project team has been very cooperative, especially the sitesite owner, making things easier. Mr. Denman is not aware of any effects of the Site on the surrounding community andMr. Denman is not aware of any effects of the Site on the surrounding community and has not received any calls or community concems regarding the Site. Mr. Denman statedhas not received any calls or community concerns regarding the Site. Mr. Denman stated that the Site is ready for deletion after the institutional controls are implemented. Mr.that the Site is ready for deletion after the institutional controls are implemented. Mr. Denman is comfortable with requirements for the institutional controls.Denman is comfortable with requirements for the institutional controls.

3030

7.0 Technical AssessmenAssessmen tt7.0 Teciinicai

Question A: Is the remedy functioning as intended by the decision documents?7.17.1 Question A: Is the remedy functioning as intended by the decision documents?

The review of documents, ARARs, risk assumptions and the sitesite inspection indicate thatThe review of documents, ARARs, risk assumptions and the inspection indicate that the site's remedy is functioning as intended. Ground water performance goals specified inthe site's remedy is functioning as intended. Ground water performance goals specified in the 1994 ROD were met in 2007. Semiannual ground water sampling waswas conducted inthe 1994 ROD were met in 2007. Semiannual ground water sampliiig conducted in accordance with the ROD beginning in December 1995. The monitoring program beganaccordance with the ROD beginning in December 1995. The monitoring program began with eight wells. The 1994 ROD, as amended by the 2009 ESD, allowed that sampling ofwith eight wells. The 1994 ROD, as amended by the 2009 ESD, allowed that sampling of any well could be stopped when the well contained concentrations below MCLs for twoany well could be stopped when the well contained concentrations below MCLs for two consecutive sampling rounds. By January 1999, monitoring had stopped for six of theconsecutive sampling rounds. By January 1999, monitoring had stopped for six of the eight wells. Upon completion of the January 2007 sampling event, the two wells hadeight wells. Upon completion of the January 2007 sampling event, the finalfinal two wells had qualified for no fijrther semiannual monitoring.qualified for no further semiannual monitoring.

The pavement cover accomplished containment of source material at the Site. The 1995The pavement cover accomplished containment of source material at the Site. The 1995 UAO directed B&B to establish aa notification agreement requiring B&B or the owners ofUAO directed B&B to establish notification agreement requiring B&B or the owners of the property to provide 60 days written notice prior to disturbing thethe sitesite property to provide 60 days written notice prior to dis~rbing the asphalt/pavement cover or prior to the sale of the property.asphalt/pavement cover or prior to the sale of the property.

In order to ensure long-term protectiveness at the Site, 2009 ESD required restrictiveIn order to ensure long-term protectiveness at the Site, 2009 ESD required restrictive covenants be placed on the site properties to:covenants be placed on the site properties to:

• Ensure that the integrity of existing impenneable surfaces is maintained.Ensure that the integrity of existing impenneable surfaces is maintained. • Ensure that fiature use of the property remains commercial or industrial.Ensure that future use of the property remains commercial or industrial. • Ensure that the potential for VI into any newly constmcted buildings is evaluated andEnsure that the potential for VI into any newly constructed buildings is evaluated and

properly addressed.properly addressed.

EPA, FDEP and the property owner are working together to ensure that the restrictiveEPA, FDEP and the property owner are working together to ensure that the restrictive covenants are implemented as required.covenants are implemented as required.

7.27.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels andQuestion B: Are the exposure assumptions, toxicity data, cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid?remedial action objectives (RAOs) used at the time of remedy selection still valid?

The exposure assumptions, toxicity data, cleanup levels and RAOs used at the time ofThe exposure assumptions, toxicity data. cleanup levels and RAOs used at the time of remedy selection are still valid. Ground water cleanup levels were on federalremedy selection are still valid. Ground water cleanup levels were basedbased on federal National Primary Drinking Water Regulations and Florida MCL values, and there haveNational Primary Drinking Water Regulations and Florida MCL values, and there have been no changes in these ARARs since the remedy was selected. Any changes in toxicitybeen no changes in these ARARs since the remedy was selected. Any changes in toxicity factors would not call into question the protectiveness of the remedy because the cleanupfactors would not call into question the protectiveness of the remedy because the cleanup levels for ground water were based on the MCLs. Therefore, the cleanup levels remainlevels for ground water were based on the MCLs. Therefore, the cleanup levels remain valid.valid.

In January 2007, EPA conducted visit to evaluate each on-site building for potentialIn January 2007, EPA conducted aa sitesite visit to evaluate each on-site building for potential VI issues. The results indicated that it was extremely unlikely that VI could occur in anyVI issues. The results indicated that it was extremely unlikely that VI could occur in any of the on-site buildings, with the possible exception of the climate-controlled area ofof the on-site buildings, with the possible exception of the climate-controlled area of Building Number 1. The potential for VI in the climate-controlled area of BuildingBuilding Number 1. The potential for VI in the climate-controlled area of Building Number evaluated with a screening level model using the highest contaminantNumber 11 waswas evaluated with a screening level model using the highest contaminant

313\

7.37.3

7.47.4

concentrations from the shallowest well as aa worst-case scenario. The modelmodel showed thatconcentrations from the shallowest well as worst-case scenario. The showed that the risk from VI into the building for all site-related VOCs was well within EPA'sthe risk from VI into the building for all site-related VOCs was well within EPA's acceptable risk range. Therefore, even if the pathways were present, contaminantacceptable risk range. Therefore, even ifthe pathways were present, contaminant concentrations are low enough that any VI would be within the acceptable risk range. Anconcentrations are low enough that any VI would be within the acceptable risk range. An EPA memorandum, dated February 20,2007, concluded that existing buildings on theEPA memorandum, dated Febmary 20, 2007, concluded that existing buildings on the Site do not pose aa VI risk (Appendix F). However, any future construction at the SiteSite do not pose VI risk (Appendix F). However, any future constmction at the Site should consider the potential for VI.should consider the potential for VI.

Question C: Has any other information come to light that could call into questionQuestion C: Has any other information come to light that could call into question the protectiveness of the remedy?the protectiveness of the remedy?

No other intormation has come to light that could call into question the protectiveness ofNo other information has come to light that could call into question the protecdveness of the remedy.the remedy.

Technical Assessment SummaryTechnical Assessment Summary

The review of documents, ARARs, risk assumptions and the inspection indicate thatThe review of documents, ARARs, risk assumptions and the sitesite inspection indicate that the Site's remedy is functioning as intended. Ground water performance goals specifiedthe Site's remedy is functioning as intended. Ground water performance goals specified in the 1994 ROD were met in 2007. The pavement cover controls source material at thein the 1994 ROD were met in 2007. The pavement cover controls source material at the

all controls implemented the the UAOSite.Site. UntilUntil all institutionalinstitutional controls areare implemented atat the Site,Site, the 19951995 UAO establishes notification agreement requiring B&B or the owners of the site property toestablishes aa notification agreement requiring B&B or the owners of the site property to provide 60 days written notice prior to disturbing the asphalt/pavement cover or prior toprovide 60 days written notice prior to disturbing the asphalt/pavement cover or prior to the sale of the property.the sale of the property.

In January 2007, EPA conducted site visit to evaluate each on-site building for potenfialIn January 2007, EPA conducted aa site visit to evaluate each on-site building for potential VI issues. An EPA memorandum, dated Febmary 20, 2007, concluded that there is no VIVI issues. An EPA memorandum, dated February 20,2007, concluded that there is no VI risk for existing buildings on the Site. However, any future constmction at the Site shouldrisk for existing buildings on the Site. However, any future construction at the Site should consider the potential for VI.consider the potential tor VI.

In order to ensure long-term protectiveness at the Site, the 2009 ESD required restrictiveIn order to ensure long-term protectiveness at the Site, the 2009 ESD required restrictive covenants be placed on the sitesite properties to:covenants be placed on the properties to:

•• Ensure that the integrity of existing impermeable surfaces is maintained.Ensure that the integrity of existing impermeable surfaces is maintained. •• Ensure that ftiture use of the property remains commercial or industrial.Ensure that future use of the property remains commercial or industrial. •• Ensure that the potentialpotential for VI into any newly constructed buildings is evaluatedEnsure that the for VI into any newly constmcted buildings is evaluated

and properly addressed.and properly addressed.

EPA, FDEP and the property owner are working together to ensure that the restrictiveEPA, FDEP and the property owner are working together to ensure that the restrictive covenants are implemented as required.covenants are implemented as required.

3232

8.0 Issues8.0 Issues

Table 77 summarizes the current sitesite issues.Table summarizes the current issues.

Table 7: Current Site IssuesTable 7: Current Site Issues

• - V K - ' ' ' - i « - ^ ' » s « * ^ ; ; ^ j . « i « 5 . ; , . - , . , ^ . . •• • • '• •

.W'Affect~' Current^"^.^ffects Current AffectSsFuture , .. y~)~, ~:/~<.<". '":. '•-*';'' •• '•'••'• i s s u e . '^' "-<A'Protectiveness Protectiveniess/jpi Pi-btectiven ess

. (Yes or No) (Yes or No); '". (Yes or No) Institutional controls called for in the 2009 ESD areInstitutional controls called for in the 2009 ESD are

NoNo YesYes not yet implemented.not yet implemented.

3333

9.0 Recommendations and Follow-up Actions9.0 Recommendations and Follow-up Actions

Table 88 provides recommendations to address the current site issues.Table provides recommendations to address the current site issues.

Table 8: Recommendations to Address Current Site IssuesTable 8: Recommendations to Address Current Site Issues

Affects: ™."- •:-;;; .. Affects""·:~"j0;':f i „ Recomniendations^A; Party Oversight Milestone Protectiveness?Pi6t~ctiveness?' Milestone

Issue-- ^ ^Issue (Yes or No) Curre'iltCurrent Future

FoUow-Lp Actions- Responsible .4gency DateDatec' ('Yes or No) Future

Institutional controlsInstitutional controls Implement requiredImplement required called for in the 2009called for in the 2009 institutional controls.institutional controls.

EPAEPA EPAEPA 05/01/2013 NoNo YesYes05/0112013ESD are not yetESD are not yet implemented.implemented.

3434

10.0 Protectiveness Statement10.0 Protectiveness Statement

The remedy at the Site is protective of human health and the environment in the short-term,The remedy at the Site is protective of human health and the environment in the short-tenn, because ground water at the Site met perfomiance standards and stmctures at the Site preventbecause ground water at the Site met perfomlance standards and structures at the Site prevent exposure to remaining source material. However, in order for the remedy to be protective in theexposure to remaining source material. However, in order for the remedy to be protective in the long term, institutional controls called for in the Site's decision documents should belong tenn, institutional controls called for in the Site's decision documents should be implemented to:implemented to:

•• Ensure that the integrity of existing impermeable surfaces is maintained.Ensure that the integrity of existing impenneable surfaces is maintained. •• Ensure that future use of the property remains commercial or industrial.Ensure that future use of the property remains commercial or industrial. •• Ensure that the potential for VI into any newly constmcted buildings is evaluated andEnsure that the potential for VI into any newly constructed buildings is evaluated and

properly addressed.properly addressed.

3535

11.0 Next Review11.0 Next Review

The Site is statutory site that requires ongoing FYRs as long as waste is left on that doesThe Site is aa statutory site that requires ongoing FYRs as long as waste is left on sitesite that does not allow for unrestricted use and unlimited exposure. The next FYR will be due within fivenot allow for unrestricted use and unlimited exposure. The next FYR will be due within tiye years of the signature/approval date of this FYR.years of the signature/approval date of this FYR.

3636

Appendix A: List of Documents ReviewedAppendix A: List of Documents Reviewed

Addendum to October 1992 Feasibility Study Report: B&B Chemical National Priorities ListAddendum to October 1992 Feasibility Study Report: B&B Chemical National Priorities List Site. Prepared by Galo Jackson, Remedial Project Manager, South Superfund Remedial Branch.Site. Prepared by Galo Jackson, Remedial Project Manager, South Superfund Remedial Branch. May 9, 1994.May 9, 1994.

Baseline Risk Assessment Report: B&B Chemical Site, Hialeah, Florida. Prepared by B&VBaseline Risk Assessment Report: B&B ChemicalSite, Hialeah, Florida. Prepared by B&V Waste Science and Technology Corp. for EPA Region 4. July 22, 1992.Waste Science and Technology Corp. for EPA Region 4. July 22,1992.

CERCLA Information System Site Information accessed from websiteCERCLA Information System Site Information accessed from website http://cuinulis.epa.gov/supercpad/cursites.^c$itinfo.cfin?id=0400566. Accessed November 15,http://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0400566. Accessed November 15, 2011.2011.

EPA Record of Decision: B&B Chemical Co., fric. EPA ID: FLD004574190. Prepared by EPAEPA Record of Decision: B&B Chemical Co., Inc. EPA ill: FLD004574190. Prepared by EPA Region 4. September 12, 1994.Region 4. September 12, 1994.

Region Reuse Fact Sheets: Sites in Continued Use Hialeah Industrial Property. OctoberEPEPAA Region 44 Reuse Fact Sheets: Sites in Continued Use Hialeah Industrial Property. October 2009.2009.

EPA Explanation of Significant Differences: B&B Chemical Co., hic. EPA ID: FLD004574190.EPA Explanation of Significant Differences: B&B Chemical Co., Inc. EPA ill: FLD004574190. Prepared by EPA. June 12, 2009.Prepared by EPA. June 12,2009.

Environmental Resources Management. Letter to Jim McGuire, EPA Region 4, August 18, 1994.Environmental Resources Management. Letter to Jim McGuire, EPA Region 4, August 18, 1994. RE: Draft Proposed Remedial Action Plan (RAP)-Natural Attenuation for the B&B ChemicalRE: Draft Proposed Remedial Action Plan (RAP)-Natural Attenuation for the B&B Chemical Company facility located at 875 West 29 Street, Hialeah, Dade County, Florida.Company facility located at 875 West 29 Street, Hialeah, Dade County, Florida.

Final Remedial Investigation Report: B&B Chemical Site, Hialeah, Florida. Prepared by B&VFinal Remedial Investigation Report: B&B Chemical Site, Hialeah, Florida. Prepared by B&V Waste Science and Technology Corp. for EPA Region 4. June 11, 1992. .Waste Science and Technology Corp. for EPA Region 4. June 11, 1992.

Five-Year Review Final Report: B&B Chemical Co., Inc. Superfund Site, Hialeah, Miami-DadeFive-Year Review Final Report: B&B Chemical Co., Inc. Superfund Site, Hialeah, Miami-Dade County, Florida. Prepared by U.S. Anny Corps of Engineers Jacksonville District, SeptemberCounty, Florida. Prepared by U.S. Anny Corps of Engineet;s Jacksonville District, September 2001.2001.

Five-Year Review Final Report: B&B Chemical Co., Inc. Superfund Site, Hialeah, Miami-DadeFive-Year Review Final Report: B&B Chemical Co., Inc. Superfund Site, Hialeah, Miami-Dade County, Florida. Prepared by U.S. Army Corps of Engineers Jacksonville District. April 2007.County, Florida. Prepared by U.S. Army Corps of Engineers Jacksonville District. April 2007.

Ground Water Sample Collection Report for B&B Chemical Superfund Site, Hialeah, Florida.Ground Water Sample Collection Report for B&B Chemical Superfund Site, Hialeah, Florida. Prepared by EPA Region 4, Environmental Services Division, Hazardous Waste Section. June 2,Prepared by EPA Region 4, Environmental Services Division, Hazardous Waste Section. June 2, 1994.1994.

Interim Remedial Action Report for B&B Chemical Co., Inc. NPL Site, Florida,Interim Remedial Action Report for B&B Chemical Co., Inc.NPL Site, Florida, NaturalNatural Attenuation. Prepared by EPA Region 4. September 1, 1999.Attenuation. Prepared by EPA Region 4. September 1, 1999.

Memorandum Jan B. Rogers, RPM. B&B Chemical Company, Hialeah, FL VaporMemorandum fromfrom Jan B. Rogers, RPM. B&B Chemical Company, Hialeah, FL Vapor Intmsion Considerations. December 19, 2006.Intrusion Considerations. December 19,2006.

A-I.\-\

Memorandum from William C. Denman, PE. B&B Chemical Five-Year Review Site Visit­Memorandum from William C. Denman, PE. B&B Chemical Five-Year Review Site Visit-January 2007. February 20,2007.January 2007. Febmary 20, 2007.

EPA. 2007. Letter to Bryan Brock, May 11, 2007. EPA. 2007. Letter to Bryan Brock, May 11, 2007.

Unilateral Administrative Order for Remedial Action: B&B Chemical Superfund Site. Unilateral Administrative Order for Remedial Action: B&B Chemical Superfund Site. September 5, 1995. September 5, 1995.

A-2A-2

Appendix B: Press Notices Appendix B: Press Notices

!vfake7ileading sinizilar:'o',';plural as appropriate.]Make heading singuldror plural as appropriate}

B-1B-1

Appendix C: Interview FormsAppendix C: Interview Forms

Five-Year Review Interview Form Site Name:Site Name: B&B Chemical Co., Inc. EPA ID No.: FLD004574190 B&B Chemical Co., Inc. Superfund SiteB&B Chemical Co., Inc. Superfund Site Five-Year Review Interview Form

B&B Chemical Co., Inc. EPA ID No.: FLD004574190 InterviewerInterviewer Name:Name: Treat Suomi Affiliation: Skeo SoltitionsTreat Suomi Affiliation: Skeo Solutions SUbject Name:Subject Name: Bryan Brock Affiliation:Bryan Brock B&B Chemical Co., Inc.Affiliation: B&B Chemical Co., Inc.

Owner and PresidentOwner and President Subject Contact N/ASubject Contact Information:Information: Time: 10:50 A.M. Date: 01127/2012Time: 10:50 A.M. Date: 01/27/2012 InterviewInterview B&B Chemical Co., Inc. SiteB&B Chemical Co., Inc. Site Location:Location:

Phone Mail Other:InterviewInterview Format (circle one):'^In Person^Format (circle one):(~ Phone Mail Other:

InterviewInterview Category:Category: Site OwnerSite Owner

1.1. What is your overall impression of the remedial/activities at the Site?What is your overall impression of the remedial/activities at the Site? The remedial activities have been done and have gone smoothly.The remedial activities have been done and have gone smoothly.

2.2. WTiat have been the effects of this Site on the surrounding community, if any?What have been the effects of this Site on the surrounding community, if any? There have been no effects on the surrounding community. The surrounding area isThere have been no effects on the surrounding community. The surrounding area is industrial.industrial.

3.3. What is your assessment of the current performance of the remedy in place at the Site?What is your assessment of the current performance of the remedy in place at the Site? would have to see what ICs are put into place before could comment.II would have to see what Ies are put into place before II could comment.

4.4. Are you aware of any complaints or inquiries regarding environmental issues or theAre you aware of any complaints or inquiries regarding environmental issues or the remedial action from residents since implementation of the cleanup?remedial action from residents since implementation of the cleanup? No.No.

5. Do you feel well-informed regarding the Site's activities and remedial progress?Do you feel well-informed regarding the Site's activities and remedial progress? If not,5. If not, how might EPA convey site-related information in the future?how might EPA convey site-related information in the future? It has been so long since any remedial activities have happened at the site. EPA is keepingIt has been so long since any remedial activities have happened at the site. EPA is keeping me informed but nothing has been done in the last 10 years.me informed but nothing has been done in the last 10 years.

6.6. Do you have any comments, suggestions or recommendations regarding the managementDo you have any comments, suggestions or recommendations regarding the management or operation of the Site's remedy?or operation of the Site's remedy? No.No.

C-lC-1

Five-Year Review Interview Form SiteSite Name:Name: B&B Chemical Co., Inc. FLD004574190 B&BB&B Chemical Co., Inc. Superfund SiteChemical Co., Inc. Superfund Site Five-Year Review Interview Form

B&B Chemical Co., Inc. EPA ID No.: Interviewer Name: TreatTreat SuomiSuomi Affiliation:Affilia tion: Skeo Solutions

EPA I DNo.: FLD004574190 Interviewer Name: Skeo Solutions Subject Name: TheresaTheresa PepePepe Affiliation:tion:Subject Name: Affilia FDEPFDEP Subject ContactSubject Contact Information: Time: 10:5710:57 AMAM Date: 01/27/2012 Information: Time: , Date: 01127/2012 Interview B&B Chemical Co., Inc. Superfund SiteInterview B&B Chemical Co., Inc. Superfund Site Location:Location:

~

Phone Mail Other:InterviewInterview Format (circle one)f^^^nFormat (circle one):-:ln PersoyPerso j^ Phone Mail Other:

State AgencyInterviewInterview Category:Category: State Agency

1. What is your overall impression of the project; including cleanup, maintenance, and reuse1. What is your overall impression of the project; including cleanup, maintenance, and reuse activities (as appropriate)?activities (as appropriate)? The Site has met ROD cleanup goals and FDEP is satistied. The Site is ready for deletionThe Site has met ROD cleanup goals and FDEP is satisfied. The Site is ready for deletion after tinal implementation of ICs.after final implementation of ICs.

2.2. WhatWhat is your assessment of the current performance of the remedy in place at the Site?is your assessment of the current performance of the remedy in place at the Site? The remedy is complete.The remedy is complete.

3.3. AreAre you aware of any complaints or inquiries regarding site-related environmental issuesyou aware of any complaints or inquiries regarding site-related environmental issues or remedial activities residents in the past five years?or remedial activities fromfrom residents in the past tive years? None at all.None at all.

4.4. HasHas youryour oftlce conducted any site-related activities or communications in the past fiveoftice conducted any site-related activities or communications in the past five years? If so, please describe the purpose and results of these activities.years? If so, please describe the purpose and results of these activities. FDEP coordinated with EPA about the ESD and Institutional Controls.FDEP coordinated with EPA about the ESD and Institutional Controls.

5.5. AreAre you aware of any changes to state laws that might affect the protectiveness of theyou aware of any changes to state laws that might atlect the protectiveness of the Site's remedy?Site's remedy? No.No.

6.6. Are you comfortable with the status of the institutional controls at the Site? If not, whatAre you comfortable with the status of the institutional controls at the Site? If not, what are the associated outstanding issues?are the associated outstanding issues? The controls are in progress.. The institutionalinstitutional controls are in progress.

7.7. AreAre you aware of any changes in projected land use(s) at the Site?you aware of any changes in projected land use(s) at the Site? No.No.

8.8. DoDo you have any comments, suggestions or recommendations regarding the managementyou have any comments, suggestions or recommendations regarding the management or operation of the Site's remedy?or operation of the Site's remedy? No. ICs need to be started sooner rather than later. The IC research is taking while andNo. ICs need to be started sooner rather than later. The IC research is taking aa while and ICs need to be put in place as soon as possible.ICs need to be put in place as soon as possible.

C-2C-2

Five-Year Review Interview Form Site Name:Site Name: B&B Chemical Co., Tnc. EPA ID No.: FLD004574190 B&B Chemical Co., Inc. Superfund SiteB&B Chemical Co., Inc. Superfund Site Five-Year Review Interview Form

B&B Chemical Co., Inc. EPA ID No.: FLD004574190 Interviewer Name:Interviewer Name: Treat Suomi Affiliation: Skeo SolutionsTreat Suomi Affiliation: Skeo Solutions Subject Name:Subject Name: Bill Denman Affiliation: EPABill Denman Affiliation: EPA Subject ContactSubject Contact Information:Information: Time:Time: 11:00 A.M. Date: 01/27/201211:00 A.M. Date: 01127/2012 InterviewInterview B&B Chemical Co., Inc. Superfund SiteB&B Chemical Co., Inc. Superfund Site Location:Location:

Phone Mail Other:Interview Format (circle one):CjnInterview Format (circle one):~Person^^ Phone Mail Other:

Interview Category:Interview Category: EPA Remedial Project ManagerEPA Remedial Project Manager

1.1. What is your overall impression of the project; including cleanup, maintenance, and reuseWhat is your overall impression of the project; including cleanup, maintenance, and reuse activities (as appropriate)?activities (as appropriate)? There has been good project team. Everyone has been cooperative especially the propertyThere has been aa good project team. Everyone has been cooperative especially the property owner which has made things easier.owner which has made things easier.

2.2. What have been the effects of this Site on the surrounding community, if any?What have been the effects of this Site on the surrounding community, if any? None that am aware ofNone that II am aware of.

3.3. Are you aware of any complaints or inquiries regarding site-related environmental issuesAre you aware of any complaints or inquiries regarding site-related environmental issues or remedial activities since the implementation of the cleanup?or remedial activities since the implementation of the cleanup? No. have not received any calls about it.No. II have not received any calls about it.

4.4. What is your assessment of the current performance of the remedy in place at the Site?What is your assessment of the current performance of the remedy in place at the Site? The remedy has been effective. The Site is ready for deletion after the ICs areThe remedy has been effective. The Site is ready for deletion after the ICs are implemented.implemented.

5.5. Are you comfortable with the status of the controls at the Site? If not, whatAre you comfortable with the status of the institutionalinstitutional controls at the Site? If not, what are the associated outstanding issues?are the associated outstanding issues?

am comfortable with what is required for the ICs.II am comfortable with what is required for the ICs.

6.6. Are you aware of any community concems regarding the Site or the operation andAre you aware of any community concerns regarding the Site or the operation and management of its remedy? If so, please provide details.management of its remedy? If so, please provide details. No.No.

7.7. Do you have any comments, suggestions or recommendations regarding the managementDo you have any comments, suggestions or recommendations regarding the management or operation of the Site's remedy?or operation of the Site's remedy? No.No.

C-3C-3

--

Appendix D: Site Inspection ChecklistAppendix D: Site Inspection Checklist

FIVE-YEAR REVIEW SITE INSPECTION CHECKLISTFIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

I. SITE INFORMATION1. SITE INFORMATION

Site Name: B&B Chemical Co., Inc.Site Name: B&B Chemical Co., Inc.

Location and Region: Hialeah, FL Region 44Location and Region: Hialeah, FL Region

Agency, Office or Company Leading the Five-YearAgency, Office or Company Leading the Five-Year Review: Skeo SolutionsReview: Skeo Solutions

Remedy Includes: (Check all that apply)Remedy Includes: (Check all that apply) o Landfill cover/containmentI I Landfill cover/containment o Access controlsI I Access controls r8J Institutional controls^ Institutional controls o Ground water pump and treatmentI I Ground water pump and treatment o Surface water collection and treatmentI I Surface water collection and treatment

Date of Inspection: 01127/2012Date of Inspection: 01/27/2012

EPA ID: FLD004574190EPA ID: FLD004574190

Weather/Temperature: Sunny, 82 degrees FFWeather/Temperature: Sunny, 82 degrees

r8J Monitored natural attenuation^ Monitored namral attenuation o Ground water containmentI I Ground water contaimtient I I Vertical barrier wallso Vertical barrier walls

r8J Other: asphalt/concrete pavement cover over historically contaminated areaOther: asphalt/concrete pavement cover over historically contaminated area

Attachments: o Inspection team roster attached o Site map attachedAttachments: HH Inspection teain roster attached I I Site map attached

II. INTERVIEWS (check all that apply)II. INTERVIEWS (check all that apply)

1. Owner of FacilityOwner of Facility Bryan BrockBryan Brock NameName

Interviewed ^ at site Q at office QJ by phoneInterviewed r8J at site 0 at oftice 0 by phone Problems, suggestions 0 Report attached: YesProblems, suggestions Q Report attached: Yes

2. O&M Staff N/A2. O&M Staff N/A Name

InterviewedInterviewed 0Q at site 0 at officeat office 0 by phone Name

at site Q Q by phoneProblems/suggestions Q Report attached:Problems/suggestions 0 Report attached:

B&B Chemcial Co., Inc. OwnerB&B Chemcial Co.. Inc. Owner and Presidentand President TitleTitle

Phone:Phone: --

TitleTitle Phone: --Phone:

01/27/201201/27/2012 DateDate

mm/dd/yyyymin/dd/yyw DateDate

D-1D-l

__

__

--

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

3.3.

4.4.

1.1.

2.2.

3.3.

Agency EPAAcencv EPA ContactContact Bill DenmanBill Denman RemedialRemedial

NameName ProiectProject ManagerManager TitleTitle

Problems/suggestions D Report attached: YesProblems/suggestions • Report attached: Yes

Agency Florida Department of Environmental ProtectionAgency Florida Department of Enviroimiental Protection Theresa PepeContactContact Theresa PepeNameName

Problems/suggestions D Report attached:Problems/suggestions 1 1 Report attached:

Agency __Agency ContactContact

NameNameProblems/suggestions D Report attached:Problems/suggestions 1 1 Report attached:

Agency __Agency ContactContact

NameNameProblems/suggestions 1 1 Report attached:Problems/suggestions D Report attached:

O&M DocumentsO&M Documents

Q O&M manualo O&M manual

• As-built drawingso As-built drawings

• Maintenanceo Maintenance logslogs

Remarks:Remarks: --

ProjectProiect ManagerManager Title

_ Title

Title _

Title

TitleTitle

Agency __ .Agenev Contact

NameName Title Contact

Title Problems/suggestions f l Report attached:Problems/suggestions D Report attached:

Other Interviews (opfional) ^ Report attached:Other Interyiews (optional) N/N/AA [gJ Report attached:

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

[gJ N/AS N/A

IE! N/A[gJ N/A

lEl N/A[gJ N/A

Q Readily availableD Readily available

• Readily availableD Readily available

• Readily availableD Readily available

Site-Specific Health and Safety PlanSite-Specific Health and Safety Plan

Q Contingency plan/emergency response plano Contingency plan/emergency response plan

Remarks:Remarks:

O&M and OSHA Training RecordsO&M and OSHA Training Records

Remarks:Remarks: -­

1/27/20121/27/2012 DateDate

1f?7/20121/27/2012 DateDate

DateDate

DateDate

DateDate

404-562-8939404-562-8939 Phone No.Phone No.

850-245-8927850-245-8927 Phone No.Phone No.

Phone No.Phone No.

Phone No.Phone No.

Phone No.Phone No.

• Up to dateD Up to date

• Up to dateD Up to date

• Up to dateD Up to date

[ J Readily availableD Readily available

Q Readily availableD Readily available

Q Readily availableD Readily available

KlN/A[gJ N/A

IEIN/A[gJ N/A

^ N / A[gJ N/A

n Up to dateD Up to date

n Up to dateD Up to date

D Up to dateD Up to date

D-2D-2

--

--

--

--

Permits and Service Agreements4.4. Permits and Service Agreements

D Readily available n Up to date lElN/A

1 1Effluent dischargeEffiuent discharge 1D 1 Readily available D Up to date [gI N/A

1 1Air discharge permitAir discharge permit 1D 1 Readily available D Up to date [gI N/A

D Readily available • Up to date 13 N/A

nD |E|N/ADD Waste disposal, POTWWaste disposal, POTW D1 1Readily availableReadily available Up to dateUp to date [gI N/A

nD Other permits: __ • Readily availableReadily available • UpUp to dateto date N/AD [gI N/AOther permits: D 3

Remarks:Remarks:

5. [gI N/A5. Gas Generation RecordsGas Generation Records •D Readily availableReadily available nD Up to dateUp to date 3 N/A

Remarks:Remarks: - ­

6. Settlement Monument RecordsSettlement Monument Records Readily available • Up to date lElN/A6. 1D 1 Readily available D Up to date [gI N/A

Remarks: --Remarks:

7. Ground Water Monitoring RecordsGround Water Monitoring Records Readily available • Up to date IEIN/A7. 1 1 Readily availableD D Up to date [gI N/A

Remarks:Remarks:

8. Leachate ExtractionLeachate Extraction RecordsRecords Readily available n Up to date ^ N / A8. 1D 1 Readily available D Up to date [gI N/A

Remarks:Remarks:

9.9. Discharge CompHance RecordsDischarge Compliance Records

n Air n Readily available Q Up to date mDAir D Readily available D Up to date [gI N/AN/A

Readily Up to date m N/AnD Water (effluent)Water (effluent) DD Readily availableavailable D• Up to date [gI N/A

Remarks:Remarks:

Daily Access/Security Logs 1 1 Readily available UpUp to dateto date10. Daily Access/Security Logs D nD [gIlElN/AN/A10. Readily available

Remarks: The site has an existing business operating on the property and is secure and limits access atRemarks: The site has an existing business operating on the proDertv and is secure and limits access at all times.all times.

IV. O&M COSTSIV O&M COSTS

I.1. O&MO&M OrganizationOrganization

1 1State in-houseState in-house 1 1Contractor for stateContractor for stateD D

PRP in-house nD Contractor for PRPD Contractor for PRP

1 1Federal facility in-houseFederal facility in-house 1 1Contractor for Federal facilityContractor for Federalfacility

n PRP in-house

D D

D_"n

0-3D-3

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2.9 O&M Cost RecordsO&M Cost Records

1 1 Readily available on Up to date o Readily available Up to date

1 1 Funding mechanisr n/agreement in place o Unavailableo Funding mechanism/agreement in place 1 1 Unavailable

Original O&M cost estimate: Original O&M cost est imate: __ 01 1 Bre akdown attached Breakdown attached

Total annual cost by year for review period if available

From:From: inm/dd/ww mm/dd/yyyy To: mm/dd/yyyy To: trun/ddywYV o Breakdown attached

Total aimual cost by year for review period if available

1 1 Breakdown attached

Date Date Total cost Total cost Date Date

From: mm/dd/yyyy From: mm/dd/ww To:To: mm/dd/yyyy mm/dd/ww o Breakdown attached 1 1 Breakdown attached

DateDate DateDate Total cost Total cost

From: mm/dd/yyyy To: mm/dd/yyyy o Breakdown attached

DateDate DateDate Total cost

From: mm/dd/ww To: mm/dd/ww 1 1 Breakdown attached

Total cost

From: mm/dd/ywv To: mm/dd/ww o Breakdown attached Breakdown attached From: mm/dd/yyyy To: mm/dd/yyyy n

Date DateDate Total cost Date Total cost

From: mm/dd/yyyy To: mm/dd/yyyy 1o1Breakdown attached Breakdown attached

DateDate DateDate Total cost

Froin: mm/dd/ww To: mm/dd/ww

Total cost

3.3. UnanticipatedUnanticipated or Unusually High O&M Costs during Review Period or Unusually High O&M Costs during Review Period

Describe costs and reasons: N/A Describe costs and reasons: N/A

ACCESS AND INSTITUTIONAL CONTROLS N/A V.V. ACCESS AND INSTITUTIONAL CONTROLS lSI ApplicableApplicable DDN/A

A. Fencing A. Fencing

I.1. Fencing Damaged o Location shown on site map Location shown on site map ^ Gates secured DN/AFencing Damaged O lSI Gates secured Q N/A

Remarks: Perimeter wall and gates function as necessary. Remarks: Perimeter wall and gates function as necessary.

B. Other Access Restrictions B. Other Access Restrictions

I. 1 1 Location shown on site map1. SignsSigns and Other Security Measures and Other Security Measures o Location shown on site map DN/A Q N/A

Remarks: Remarks:

C. Institutional Controls (ICs) C. Institutional Controls (lCs)

D-4 D-4

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I.1. Implementation and EnforcementImplementation and Enforcement

Site conditions imply ICs not properly implemented DYes• Yes • No r8J N/ASite conditions imply ICs not properly implemented D No N/A

Site conditions implyimply ICs not being fully enforcedSite conditions ICs not being fijlly enforced Q Yes D No ^ N/ADYes dl No r8J N/A

Type of monitoring (e.g., self-reporting, drive by): N/AType of monitoring (e.g., self-reporting, drive by): N/A

Frequency: __Frequency:

Responsible party/agency: __Responsible parry/agency:

ContactContact mm/dd/wwmm/ddlyyyy

NameName Title Date Phone no.Title Date Phone no.

Reporting is up to date • DNo• r8JReponing is up to date DYesYes NoN/AN/A

Reports are verified by the lead agency DYes• Yes • No r8J N/AReports are verified by the lead agency DNo N/A

Specific requirements in deed or decision documents have been met DYesO Yes ^ No DN/AQ N/ASpecitic requirements in deed or decision documents have been met r8J No

Violations have been reported DYesCH Yes CH No r8J N/AViolations have been reported DNo N/A

Other problems or suggestions: CH Report attachedD Repon attachedOther problems or suggestions:

.., ICs are adequate N/A

Remarks: ICs in the form of deed restrictions are planned so that future owners (1) maintain the integrity

2. AdequacyAdequacy •D ICs are adequate r8J ICs are inadequateICs are inadequate DN/A•

Remarks: ICs in the form of deed restrictions are planned so that future owners (I) maintain the integrity of the pavement cover, (2) take appropriate precautions during contruction to prevent vapor intrusion andof the pavement cover, (2) take appropriate precautions during contruction to prevent vapor intrusion and (3) use site property for industrial or commertiaUianctllsd.(3) use site property for industrial or commerciallland use.

D. GeneralD. General

Vandalism/Trespassing Location shown on site map No vandalism evidentI.1. Vandalism/Trespassing DCH Location shown on site map r8J No vandalism evident

Remarks: --Remarks:

2.2. Land Use Changes On SiteLand Use Changes On Site |E1 N/Ar8J N/A

Remarks:Remarks:

Land Use Changes Off Site |E1 N/A

Remarks:

3.3. Land Use Changes Off Site r8J N/A

Remarks:

VI. GENERAL SITE CONDITIONSVL GENERAL SITE CONDITIONS

(El Applicable N/AA.A. RoadsRoads r8J Applicable DDN/A

1. Roads DamagedRoads Damaged D Location shown on site map ^ Roads adequate DN/ACH N/AI. CH Location shown on site map r8J Roads adequate

Remarks: - ­. Remarks:

B. Other Site ConditionsB. Other Site Conditions

Remarks: --Remarks:

VII. LANDFILL COVERS ApplicableVII. LANDFILL COVERS DD Applicable g ] N/Ar8J N/A

A. Landfill SurfaceA. Landfill Surface

D-5D-5

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1.1. SettlementSettlement (low spots)(low spots)

Arial e.xtent:Arial extent: --

Remarks:Remarks: --

Cracks2.2. Cracks

Lengths:Lengths: __

Remarks:Remarks:

3.3. ErosionErosion

Arial extent:Arial extent:

Remarks: --Remarks:

Holes4.4. Holes

Arial extent:Arial extent:

Remarks:Remarks:

5.5. Vegetative CoverVegetative Cover

1 1 No signs of stresso No signs of stress

Remarks:Remarks:

1 1 Location shown on site mapo Location shown on site map

1 1 Location shown on site mapo Location shown on site map

Widths:Widths:

1 1 Location shown on site mapo Location shown on site map

1 1 Location shown on site mapo Location shown on site map

1 1 Grasso Grass

o Settlement not evident

Depth: __

1 1 Settlement not evident

Oepth:

1 1 Cracking not evidento Cracking not evident

Depths: __Oepths:

o Erosion not evident

Depth: __

1 1 Erosion not evident

Oepth:

1 1 Holes not evidento Holes not evident

Depth: __Oepth:

1 1 Cover properly establishedo Cover properly established

1 1 Trees/shrubs (indicate size and locations on a diagram)o Trees/shrubs (indicate size and locations on a diagram)

Alternative Cover (e.g., armored rock, concrete)6.6. .\lternative Cover (e.g. armored rock, concrete)

Remarks:Remarks:

7.7. BulgesBulges

Arial extent:Arial extent: --

Remarks:Remarks:

8.8. Wet Areas/Water DamageWet Areas/Water Damage

CH Wet areaso Wet areas

• Pondingo Ponding

o SeepsCH Seeps

• Soft subgradeo Soft subgrade

Remarks:Remarks: -­

9.9. Slope InstabilitySlope Instability

1 1 Location shown on site mapo Location shown on site map

o Wet areas/water damage not evidentCH Wet areas/water damage not evident

1 1 Location shown on site mapo Location shown on site map

1 1 Location shown on site mapo Location shown on site map

1 1 Location shown on site mapo Location shown on site map

1 1 Location shown on site mapo Location shown on site map

n Slideso Slides

D N / AON/A

o Bulges not evident

Height: __

1 1 Bulges not evident

Height:

Arial extent:Arial extent:

Arial extent:Arial extent:

Arial extent:Arial extent:

Arial extent:Arial extent:

1 1 Location shown on site mapo Location shown on site map

o No evidence of slope instabilityCH No evidence of slope instability

Arial extent:Arial extent:

Remarks:Remarks:

B. Benches Q ApplicableB. Benches o Applicable ^ N/A~N/A

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

1.1. Flows Bypass BenchFlows Bypass Bench 1 1 Location shown on site map • N/A or okayo Location shown on site map o N/A or okay

Remarks:Remarks:

0-6D-6

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2 ') Bench Breached Bench Breached

Remarks:Remarks:

Bench Overtopped 3.3. Bench Overtopped

Remarks:Remarks:

o Location shown on site map 1 1 Location shown on site map

o Location shown on site map 1 1 Location shown on site map

o N/A or okay 1 1 N/A or okay

o N/A or okayCH N/A or okay

C. Letdown Channels D Applicable IZI N/AC. Letdown Channels n Apphcable ^ N/A

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

Settlement (Low spots) I.1. Settlement (Low spots)

Arial extent: Arial extent:

Remarks:Remarks:

2.2. Material Degradation Material Degradation

Material type: ___Material type:

Remarks:Remarks: -­

3.3. ErosionErosion

Arial extent: Arial extent:

Remarks: Remarks:

4.4. UndercuttingUndercutting

Arial extent: Arial extent:

Remarks: Remarks:

5.5. ObstructionsObstructions

o Location shown on site map 1 1 Location shown on site map

o Location shown on site map 1 1 Location shown on site map

o Location shown on site map CH Locafion shown on site map

1 1 Location shown on site map o Location shown on site map

Type:Type: __

D No eviden~e of settlement

Depth: __

CH No evidence of settlement

Oepth:

No evidence of degradation1D 1 No evidence of degradation

Arial extent: Arial extent:

No evidence of erosion

Depth: __

1D 1 No evidence of erosion

Oepth:

1D 1 No evidence of undercutting No evidence of undercutting

Depth: __Oepth:

1D 1 No obstructions No obstructions

1 1 Location shown on site map Arial extent: Arial extent: D Location shown on site map

Size: --Size:

Remarks: Remarks:

6.6. Excessive Vegetative G rowth Type: __Excessive Vegetative Growth Type:

• No evidence of excessive growth D No evidence of excessive growth

1 1 Vegetation in channel s does not obstruct flow o Vegetation in channels does not obstruct flow

1 1 Location shown on site map Arial extent: _ o Location shown on site map Arial extent: --

Remarks: Remarks:

D. Cover Penetrations D. Cover Penetrations

I.1. Gas Vents Gas Vents

13 Applicable Q N/A IZI Applicable DN/A

n Active 1 1 Passive o Active o Passive

• Properiy secured/lockedo Properly secured/locked • Functioningo Functioning CH Routinely sampledo Routinely sampled CH Good condition o Good condition

1 1 Evidence of leakage at penetrationo Evidence of leakage at penetration CH Needs maintenanceo Needs maintenance ^ N/A IZI N/A

Remarks: Remarks: -­

D-7 0-7

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Gas Monitoring Probes

.• oI IProperly secured/locked Properly secured/locked oI IFunctioning Functioning oI IRoutinely sampled Routinely sampled o Good condition

2.2. Gas Monitoring Probes

CH Good condition

[8J N/A .

, Remarks:

oI IEvidence Evidence of leakage at penetration of leakage at penetration oI INeeds maintenance Needs maintenance ^ N/A V;

Remarks: - ­3.3. Monitoring Wells (within surface area of landfill) Monitoring WeDs (within surface area of landfill)

,: [8J Properly secured/locked CH Fimctioning o CH Routinely sampledRoutinely sampled ^ Properly secured/locked o Functioning [8J Good condition Good condition ,.

CH Evidence of leakage at penetrationo Evidence oflea)<age at penetration oI INeeds maintenance Needs maintenance DN/AI I N/A

.-. . •. :i. nn .Remarks:Remarks: Ground water cleanup goals have been reached and monitoring is no longer required^

4. Extraction WeDs Leachate

I I Properly secured/locked o Functioning I o CH Good condition Good condition

Extraction Wells Leachate

o Properly secured/locked CH Functioning oIRoutinely sampled Routinely sampled

on Evidence Evidence of leakage at penetration of leakage at penetration I I Needs maintenance [8J N/A N/Ao Needs maintenance ^ *

Remarks: Remarks:

5. Settlement Settlement MonumentsMonuments CH Located o[~1 Routinely surveyedRoutinely surveyed N/A 5. o Located [8J N/A

Remarks: . > . . . , Remarks:

[8J N/AE.E. Gas Gas Collection and TreatmentCoDection and Treatment o Q ApplicableApplicable | 3 N/A

Gas Treatment FacilitiesI. Gas Treatment Facilities

I Thermal destruction I Collection for reuse oCH Flaring Flaring oI Thermal destruction oI Collection for reuse

CH Good condition oI Needs maintenance o Good condition I Needs maintenance

Remarks: Remarks:

Gas CoDection WeDs, Manifolds and Piping

CH Good conditiono Good condition CH Needs maintenance

2.2. Gas Collection Wells, Manifolds and Piping

o Needs maintenance

Remarks: --Remarks:

Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)3.3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)

oCH Good conditionGood condition o CH Needs maintenance Needs maintenance DN/A CH N/A

Remarks: Remarks:

[gJ N/A Applicable N/A F.F. Cover Cover Drainage Layer Drainage Layer on Applicable ^

Outlet Pipes Inspected1.1. Outlet Pipes Inspected oI IFunctioning Functioning DN/A DN/A

Remarks: --Remarks:

2.2. Outlet Outlet Rock Inspected Rock Inspected I I Fimctioning nDN/A N/Ao Functioning i

Remarks: Remarks: --G. Detention/Sedimentation Ponds o Applicable 3

1. Siltation Siltation , Area extent: Depth: DN/A DN/A

G. Detention/Sedimentation Ponds CH Applicable [gJ N/A N/A

I. Area extent: Depth: __

I I Siltation not evident o Siltation not evident

Remarks: --Remarks: ,

D-8D-8

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2') __Area extent: Depth:ErosionErosion Area extent: Depth: -1 1 Erosion not evidentD Erosion not evident

Remarks:Remarks:

3.3. Outlet WorksOutlet Works DCH FunctioningFunctioning D N / ADN/A

Remarks:Remarks: - ­

4. Dam CH FuncfioningFunctioning

Remarks:

4. Dam D DN/AD N / A

Remarks:

H.H. Retaining WallsRetaining Walls D Applicable [^ N/AQ Applicable lZl N/A

1. CH Location shown on site map D

Horizontal displacement: Vertical dVertical displacement: .

1. DeformationsDeformations D Location shown on site map 1 1Deformation not evidentDeformation not evident

Horizontal displacement: __ splacement: __

Rotafional displacement: __Rotational displacement:

Remarks:Remarks:

2') DegradationDegradation CH Location shown on site mapD Location shown on site map 1D 1 Degradation not evidentDegradation not evident

Remarks:Remarks:

I. Perimeter Ditches/Off-Site Discharge • Applicable 3I. Perimeter Ditches/Off-Site Discharge D Applicable lZl N/AN/A

1. CH Location shown on site map D

Area extent: Depth: __

1. SiltationSiltation D Location shown on site map 1 1Siltation not evidentSiltation not evident

Area extent: Depth:

Remarks:

2

Remarks:

') Vegetative Growth D Location shown on site map N/AVegetative Growth CH Location shown on site map DN/AD

1 1 Vegetation does not impedeD Vegetation does not impede flowflow

Area extent:Area extent: Type: __Type:

Remarks:Remarks:

3. CH Location shown on site map

Area extent: Depth: __

3. ErosionErosion D Location shown on site map CH Erosion not evidentD Erosion not evident

Area extent: -- Depth:

Remarks:

CH Functioning DN/AN/A

Remarks:

4.4. Discharge StructureDischarge Structure D Functioning n

Remarks:Remarks: --

VIII. VERTICAL BARRIER WALLS Applicable N/AVIII. VERTICAL BARRIER WALLS QD Applicable lZl3 N/A

Settlement Location shown on site map CH Senlement not evidentSenlement not evident

Area extent: Depth: __

1.1. Settlement D• Location shown on site map D

Area extent: Depth:

Remarks:Remarks:

0-9D-9

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2. Performance Monitoring Type of monitoring: __2. Performance Monitoring Type of monitoring:

o Perfonnance not monitored

Frequency:Frequency: __ CH Evidence of breaching

I I Perfonnance not monitored

o Evidence of breaching

Head differential: --Head differential:

Remarks:Remarks:

IX. GROUND WATER/SURFACE WATER REMEDIES r8J Applicable D N/AIX. GROUND WATER/SURFACE WATER REMEDIES 3 Applicable Q N / A

A. Ground Water Extraction Wells. Pumps and Pipelines o Applicable 3A. Ground Water E.xtraction Wells, Pumps and Pipelines CH Applicable r8J N/A N/A

Pumps. Wellhead Plumbing and Electrical I.1. Pumps, Wellhead Plumbing and Electrical

o Good condition o All required wells properly operating o Needs maintenance DN/A• Good condition CH All required wells properly operating CH Needs maintenance CH N/A

Remarks:Remarks:

2.2. Extraction Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances System Pipelines, Valves, Valve Boxes and Other Appurtenances

oI IGood condition Good condition o Needs maintenance CH Needs maintenance

Remarks: Remarks:

3.3. Spare Spare Parts and Equipment Parts and Equipment

I I Readily available CH Good condifion I I Requires upgrade I I Needs to be provided o Readily available o Good condition o Requires upgrade o Needs to be provided

Remarks:Remarks:

B. Surface Water Collection Structures. Pumps and Pipelines o Applicable 3B. Surface Water Collection Structures, Pumps and Pipelines CH Applicable r8J N/A N/A

I.1. COllection Structures, Pumps and Electrical Collection Structures, Pumps and Electrical

oI IGood condition Good condition D Needs maintenance CH Needs maintenance

Remarks: Remarks:

2.2. Surface Water Collection System Pipelines. Valves, Valve Boxes and Other Appurtenances Surface Water Collection System Pipelines, Valves, Valve Bo.xes and Other Appurtenances

Good condition CH Needs maintenance DI I Good condition D Needs maintenance

Remarks: Remarks:

3.3. Spare Parts and Equipment Spare Parts and Equipment

o Good condition CH Needs to be provided oI I Readily availableReadily available CH Good condition o CH Requires upgradeRequires upgrade o Needs to be provided

Remarks: --Remarks:

C. Treatment System CH Applicable r8J N/A N/AC. Treatment System o Applicable 3

D-10 0-10

1. Treatment Train (check coinponents that apply)Treatment Train (check components that apply)

I IMetals removalMetals removal DCH Oil/water separationOil/water separation ID D I BioremediationBioremediation

CH Air strippingAir stripping CH Carbon adsorbersCarbon adsorbersD D

n Filters: __D Filters:

I I Additive (e.g., chelation agent, flocculent):__D Additive (e.g., chelation agent, tlocculent):

DOthers: __

I IGood conditionGood condition Needs maintenance

n Others:

D DCH Needs maintenance

ID I Sampling ports properly marked and fijnctionalSampling ports properly marked and functional

I I Sampling/maintenance log displayed and up to dateD Sampling/maintenance log displayed and up to date

ID I Equipment properly identifiedEquipment properly identified

I I Quantity of ground water treated annually:__D Quantity of ground water treated annually:

I I Quantity of surface water treated annually:__D Quantity of surface water treated annually:

Remarks:Remarks:

2. Electrical Enclosures and Panels (properly rated and functional)Electrical Enclosures and Panel.s (properly rated and functional)

ID I N/A D Good condition CH Needs maintenanceN/A CH Good condition D Needs maintenance

Remarks:Remarks:

3.3. Tanks, Vaults, Storage VesselsTanks, Vaults, Storage Vessels

ID I N/A D ID I Proper secondary contaiimient DCH Needs maintenanceN/A CH Good condition Proper secondary containmentGood condition Needs maintenance

Remarks:Remarks:

Discharge Structure and Appurtenances

D D I Needs maintenance

4. Discharge Structure and Appurtenances

I I N/AN/A DCH Good conditionGood condition I Needs maintenance

Remarks: __Remarks:

Treatment Building(s)

I I N/A CH Good condition (esp. roof and doorways) ID I Needs repair

5. Treatment Building(s)

D N/A D Good condition (esp. roof and doorways) Needs repair

ID I Chemicals and equipment properly storedChemicals and equipment properly stored

Remarks: __Remarks:

6. Monitoring Wells (pump and treatment remedy)Monitoring Wells (pump and treatment remedy)

ID I Properly secured/locked D DCH Routinely D I Good condifionProperly secured/locked CH FunctioningFunctioning Routinely sampledsampled I Good condition

I I All required wells located D Needs maintenance D N / AD All required wells located CH Needs maintenance DN/A

Remarks:Remarks:

D.D. Monitoring DataMonitoring Data N/AN/A

1.1. Monitoring DataMonitoring Data

ID I Is routinely submitted on time D I Is of acceptable qualityIs routinely submitted on time I Is of acceptable quality

2. Monitoring Data Suggests:2. Monitoring Data Suggests:

ID I Ground water plume is effectively contained ID I Contaminant concentrations are decliningGround water plume is effectively contained Contaminant concentrations are declining

D-11D-11

E. Monitored Natural AttenuationE. Monitored Natural Attenuation 1.1. Monitoring Wells (natural attenuation remedy)Monitoring Wells (natural attenuation remedy)

DI Properly secured/locked CH Fimctioning D Routinely sampled CH Good conditionI Properly secured/locked D Functioning CH Routinely sampled D Good condition

D All required wells located CH Needs maintenanceI I All required wells located D Needs maintenance l 3 N / A / > ' r[8] N/A

Remarks: Ground water monitoring has been completed.Remarks: Ground water monitoring has been completed. . >- < X. OTHER REMEDIESX. OTHER REMEDIES

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

XL OVERALL OBSERVATIONSXI. OVERALL OBSERVATIONS A. Implementation of the RemedyImplementation of the Remedy

Describe issues and observations relating to whether the remedy is effective and functioning as designed.Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with aa brief statement of what the remedy is designed to accomplish (e.g., to contain contaminantBegin with brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant plume, minimize infiltration and gas emissions).plume, minimize infiltration and gas emissions). . . 1 - -n..The remedy fimctions effectively as intended. The asphalt/concrete pavement cover functions as designej. ~ . .... . . . . . .....

·lIftI!RlUtoto divert water fi'om penetrating the historical area of contamination. Concentration of contamination in . . .. . . ... . . ..the monitoring wells decreased to levels which satisfy the required performance standards. Ground watet""'the . . . .• . .!i......Lmonitorigg is no longer required or conducted at the Site. Adequacy of O&MB.B. Adequacy of O&M Describe issues and observations related to the implementation and scope of O&M procedures. InDescribe issues and observations related to the implementation and scope of O&M procedures. In particular, discuss their relationship to the current and long-term protectiveness of the remedy.particular, discuss their relationship to the current and long-term protectiveness of the remedy. There is no required O&M except ensuring the integrity ofthe asphalt/concrete pavement. This area doesThere is no required O&M except ensuring the integrity of the asphalt/concrete pavement. This area does not currentlv reQuire anv maintenance.not currentiv require any maintenance. Early Indicators of Potential Remedy ProblemsC. Early Indicators of Potential Remedy Problems Describe issues and observations such as unexpected changes in the cost or scope of O&M or aa highDescribe issues and observations such as unexpected changes in the cost or scope of O&M or high frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromisedfrequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised in the future.in the future. Placement of institutional controls will ensure that current and future owners of the Site considerPlacement of institutional controls will ensure that current and fiiture owners of the Site consider maintainence of the asphalt/concrete pavement cover, land use restrictions and vapor intrusion during anymaintainence of the asphalt/concrete pavement cover, land use restrictions and vapor intrusion during any new construction on site.new construction on site. Opportunities for OptimizationD.D. Opportunities for Optimization Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy. N/AN/A

, - l .•"i f- ' .

• f ^ • •

• \ • . • : • < ? ' • . - • • * '

•• ' V , . •

• - . J . •

• , 1 1 • «

D-12D-12

' * "•^ •HW 1 '>iiW

Appendix E: Photographs from Site Inspection VisitAppendix E: Photographs from Site Inspection Visit

" I r T •*!> T"*?)^ # J i f f r -« « 'an •- -^^^

Entrance to the Site property from West 20th Street. The property is privately owned.Entrance to the Site property from West 20th Street. The property is privately owned.

Fenced and gated entrance to the site property. View from inside the fenced site toward the employee parking lot. AAFenced and gated entrance to the site property. View fi'om inside the fenced site toward the employee parking lot. station controls access to the walled property. Parking garage for Metrorail seen in background. ,guardguard station controls access to the walled property. Parking garage for Metrorail seen in background.

E-lWrl

" '

I

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' ' • ! » • • ' '

'•f • y ' ' '

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Building 22 located on site, currently in use.Building located on site, currently in use.

Asphalt/concrete pavement cover. Facing east toward gated entrance to the Site.Asphalt/concrete pavement cover. Facing east toward gated entrance to the Site.

"'N ©"2.E-2

. '•• ...•.;(ji»).'.»,n - " • •! •".-«'y»W»«—,fi*r W.* ' * i * . l t ( i - l « ^ 'A'

' •. *y

Grass-covered area in the southeast comer of the Site. Grass-covered area in the southeast comer of the Site.

• • % . •

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• • • V o , ' * ; ' " '

n / " • • E-37, . ' J S ^ ' .

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- ••*iiA-, '^i;jj^' . . '^r:

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Three of the inactive monitoring wells located on site along the southern wall.

E-4

' / ;

;'- ''^•i£'^-^^:.f-.:^:,.^.i;:2,i:^j,

/

Three of the inactive monitoring wells located on site along the southem wall.

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Appendix F: Vapor Intrusion MemorandumsAppendix F: Vapor Intrusion Memora~dums

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYUNITEDSTATESEN~RONMENTALPROTECnONAGENCY

REGIONREGION 44 ATLANTA FEDERAL CENTERATLANTA FEDERAL CENTER

V / V 61 FORSYTH STREET,-«P 61 FORSYTH STREET ^ ^ i " ' PfO^ ATLANTA.ATLANTA. GEORGIA 30303-8960GEORGIA 30303-8960

February 20, 2007February 20, 2007

MEMORANDUMMEMORANDUM

SUBJECT:SUBJECT: B&B ChemicalB&B Chemical Five-Year Review Site Visit January 2007Five-Year Review Sire Visir -- January 2007

FROM: , Remedial Project Manager '

FROM: William C. Denman, P.E.William C. Denman, P.E. ^Uiy/o. . .^ Y Remedial Project Manager

TO:TO: Project FileProject File

On January 25, 2007,1 conducted follow-up site visit at the B&B Chemical site in orderOn January 25, i007, i conducted aa follow-up site visit at the B&B Chemical site in order to inspect each on-site building for the purpose of evaluating the potential for vapor intrusionto inspect each on-site building for the purpose of evaluating the potential for vapor intrusion issues. To follow is summary of my observations. See attached Figure Site Layout forissues. To follow is aa summary of my observations. See attached Figure 11 -- Site Layout for identification of buildings by number.. identification of buildings by number.

1. climate controlled area. The building is constructed on concrete slab that is elevated Vi to

1. Building No. 1; This building is the only building on-site that containsBuilding No.1: This building is the only building on-site that contains aa climate controlled area. The building is constructed on aa concrete slab that is elevated 33 Y2 to 44 feet and contains climate controlled office area, dry manufacturing area and wetfeet and contains aa climate controlled office area, aa dry manufacturing area and aa wet manufacturing area. The dry manufacturing and wet manufacturing areas cannot bemanufacturing area. The dry manufacturing and wet manufacturing areas cannot be accessed from the climate controlled area. The only access points are through overheadaccessed from the climate controlled area. The only access points are through overhead doors. Because there are no other doors for entrance or exit, fire code requires thesedoors. Because there are no other doors for entrance or exit, fire code requires these doors to remain open when anyone is inside to provide for emergency fire exit (seedoors to remain open when anyone is inside to provide for emergency fire exit (see pictures #1 and #3). Additionally, overhead vent fans are turned on when manufacturingpictures #1 and #3). Additionally, overhead vent fans are turned on when manufacturing occurs (see picture #2).occurs (see picture #2).

2. Buildings No. 2Buildings No.2 && 3: These buildings are used for warehousing raw materials. The only2. 3: These buildings are used for warehousing raw materials. The only entrance and exit to these buildings are through overhead doors which must be open ifentrance and exit to these buildings are through overhead doors which must be open if anyone is inside due to firefire code. People are only in these buildings to unload or retrieveanyone is inside due to code. People are only in these buildings to unload or retrieve raw materials. See pictures #4 and #5.raw materials. See pictures #4 and #5.

3. Building No. 4: These buildings are cunrently used only for raw material storage (4-S),3. Building No.4: These buildings are currently used only for raw material storage (4-5), equipment storage (4), and carpenter shop (4-E). Building 4-S is only accessibleequipment storage (4), and aa carpenter shop (4-E). Building 4-5 is only accessible through gates (see picture #6). Buildings #4 and #4E have overhead doors which arerhrough gates (see picture #6). Buildings #4 and #4E have overhead doors which are opened during use because the stmcture is cooled (see picture #7).opened during use because the structure is notnot cooled (see picture #7).

4. Building No. 7: This building is used for shipping and receiving. People are only4. Building No.7: This building is used for shipping and receiving. People are only present in this building when bringing in or taking finished products. There arepresent in this building when bringing in or taking outout finished products; There are multiple overhead doors which are the only ways to enter or exit the building (see picturemultiple overhead doors which are rhe only ways to enter or exit the building (see picture #8). On the south side of this building is an open air eating area (see picture #9).#8). On rhe south side of this building is an open air eating area (see picture #9).

Internet A~dress (URL) •• htlp:/lwww.epa.govInternet Address (URL) http://www.epa.gov RecycledJRecyclable •• Pflnled .....ilfl vegelable 01' Based Inks on Recycled Paper (Minimum 30% Postccnsumef)Recycled/Recyclable Printed wiin vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postccnsumer)

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As aa result of this site inspection, it appears extremely unlikely that vapor intrusion couldAs result of this site inspection, it appears extremely unlikely that vapor intrusion could occur in any of the onsite buildings with the possible exception of the climate controlled areaoccur in any of the onsite buildings with the possible exception of the climate controlled area of BUilding Number I. Most buildings are accessible only through overhead doors whichof Building Number 1. Most buildings are accessible only through overhead doors which must be left open lo provide for emergency exit. When open, these doors provide adequatemust be left open to provide for emergency exit. When open, these doors provide adequate ventilation.ventilation. In order to evaluate the potential for vapor intrusion into the climate controlledIn order to evaluate the potential for vapor intrusion into the climate controlled area of Building Number 1, screening level model was run (see attachment). This modelarea of Building Number I, aa screening level model was run (see attachment). This model took highest concentratioiis from the shallowest well as worst case scenario. The modeltook hi'ghest concentrations from the shallowest well as aa worst case scenario. The m'odel showed that the from vapor intrusion into the building for all site related VOCs was wellshowed that the riskrisk from vapor intrusion into the building for all site related VOCs was well within EPA's acceptable range. Therefore, even if the pathways were present,within EPA's acceptable riskrisk range. Therefore, even if the pathways were present, contaminant concentrations are low enough that any vapor intrusion would be within thecontaminant concentrations are low enough that any vapor intrusion would be within the acceptable range.acceptable riskrisk range.

recommend that institutional controls be implemented in the form of restrictiveII recommend that institutional controls be implemented in the form of aa restrictive covenant in order to ensure the asphalt cover is maintained in the future and to require thatcovenant in order to ensure the asphalt cover is maintained in the future and to require that either sampling be conducted to determine the potential for vapor intrusion or protectiveeither sampling be conducted to determine the potential for vapor intrusion or protective measures be taken during construction to prevent the potential for vapor intrusion.measures be taken during construction to prevent the potential for vapor intrusion.

AttachmentAttachment

Cc:Theresa Pepe, FDEPCc: Theresa Pepe, FDEP Jan Rogers, EPA-SFOJan Rogers, EPA-SFO

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December 19,2006December 19,2006

MEMORANDUMMEMORAJ^DUM

SUBJECT: B&B Chemical Company, Hialeah, FL -- Vapor Intrusion ConsiderationsSUBJECT: B&B Chemical Company, Hialeah, FL Vapoi Intrusion Considerations

FROM: Jan BB Rogers, RPMJanFROM: Rogers, RPM US EPA Region 4 - South Florida Office�US EPA Region 4 - South Florida Office

Bill Denman, RPMTO:TO: Bill Denman, RPM US EPA Region 44US EPA Region

1looked at the "Screening -- Level" Johnson and Ettinger Model for Soil Vapor Intrusion locatedI looked at the "Screening Level" Johnson and Ettinger Model for Soil Vapor Intrusion located on the EPA web site. Using November 15, 2005, B&B sampling results (shallowest well, highest concentration --highest concentration MWT-31) vinyl chloride gives aa "Best Estimate Cancer Risk"MWT-31) vinyl chloride gives == 5.8e-6, on the EPA web site. Using November 15, 2005, B&B sampling results (shallowest well,

"Best Estimate Cancer Risk" 5.8e-6, which is above the point of departure but within the CERCLA range. The other chemicalswhich is above the point of d~parture but within the CERCLA riskrisk range. The other chemicals

. (benzene and chlorobenzene) did not fall outside the risk goals. I've attached the results sheet(benzene and chlorobenzene) did not fall outside the risk goals. I've attached the results sheet for each calculation. II made some assumptions about depth to water, ground-water temperature,for each calculation. made some assumptions about depth to water, ground-water temperature, and soil type. They are listed is the results sheets.and soil trPe. They are listed is the results sheets.

Additional Considerations: oo Historical sampling events have shown much lower concentrations 1999 until the

Additional Considerations: Historical sampling events have shown much lower concentrations fromfrom 1999 until the 2005 event.

oo 2005 had two significant hurricane events which may have caused temporary increases in2005 had two significant hurricane events which may have caused temporary increases in groundwater concentrations.

2005 event,

groundwater concentrations. . oo Groundwater flow is to the southwestGroundwater flow is to the southwest and can swing back to the southeast depending onand can swing back to the southeast depending on

discharge/recharge influences associated with the Miami Canal.discharge/recharge influences associated with the Miami Canal.� The most susceptible building (administrative building closed in, air conditioned) isoo The most stisceptible building (administrative building -- closed in, air conditioned) is located due west of these monitoring wells (not down gradient),located due west of these monitoring wells (not down gradient).

coo The model has limited choices for bldg (i.e., slab-on-grade, basement). TheThe model has limited choices for bldg floorfloor (i.e., slab-on-grade, basement). The administration building is on an elevated pad (approximately 3-4 feet above grade). Noadministration building is on an elevated pad (approximately 3-4 feet above grade). No open space between slab and surrounding grade,open space between slab and surrounding grade.

oo Porosity of slab and HVAC operations of the building are not factored into die model. ItPorosity of slab and HVAC operations of the building are not factored into the model. It appears to be an initial screening tool with conservative assumptions.appears to be an initial screening tool with conservative assumptions.

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