EPA/ROD/R04-94/1811994

EPA SuperfundRecord of Decision:

BMI-TEXTRONEPA ID: FLD052172954OU01LAKE PARK, FL08/11/1994

10449241

RECORD OF DECISIONFOR THE

BMI-TEXTRON SITE

THE DECLARATION

SITE NAME AND LOCATION

BMI-Textron SiteLake Park, Florida

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial actionfor the Basic Microelectronics, Incorporated (BMI)-Textron Site(BMI-Textron Site or the Site), in Lake Park, Florida, chosen inaccordance with the Comprehensive Environmental ResponseCompensation, and Liability Act of 1980 (CERCLA), as amended bythe Superfund Amendments and Reauthorization Act of 1986 (SARA),42 U.S.C. Section 9601 et .seq. and the extent practicable., theNational Oil and Hazardous Substance Pollution Contingency Plan(NCP). This decision is based on the administrative record forthis Site.

The State of Florida, as represented by the FloridaDepartment of Environmental Protection (FDEP), has been thesupport agency during the Remedial Investigation and FeasibilityStudy (RI/FS) process for the Site. In accordance with 40 CFR300.430, as the support agency, FDEP has provided theEnvironmental Protection Agency (EPA) with input. While EPAexpects written concurrence will be forthcoming from FDEP, a -letter formally recommending concurrence of the remedy has notyet been received.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances fromthis Site, if not addressed by implementing the response actionselected in this Record of Decision (ROD), may present animminent and substantial endangerment to public health, welfare,or the environment.

DESCRIPTION OF THE REMEDY

This remedy addresses the contaminated principal threat ofground water at the Site. This remedy addresses the principalthreat remaining at the Site, by using existing institutionalcontrols, and monitoring ground water contaminated with arsenic,cyanide, sodium and fluoride. Transport modeling indicates thatnatural attenuation of on-site ground water contaminants todrinking water standards should occur within 3 years. The groundwater will be monitored quarterly for one year to verify modelled

decrease of contaminant concentration. During the remaining twoyears, EPA would conduct by an annual review of monitoringfrequency. Selected wells within the existing monitor wellnetwork would be used to provide confirmation of historical dataand modeling transport data that indicates the contaminant ofpotential concerns (COPCs) will naturally degrade and/orattenuate with time. However, EPA reserves the right to increasemonitoring frequency should sampling data indicate the necessity.If after the three years of monitoring, data shows thatPerformance Standards are achieved, then the Site will beconsidered for deletion from the National.Priorities List (NPL).Should monitoring indicate that the Site has contaminants atconcentrations greater than Federal and State standards, EPA inconsultation with the State of Florida, will reconsider theprotectiveness of the selected alternative.

STATUTORY DETERMINATIONS

The selected remedy is protective of human health and theenvironment, complies with Federal and State requirements thatare legally applicable or relevant and appropriate to theremedial action, and is cost-effective. Due to the documentednaturally occurring attenuation of ground water contamination atthe Site, this remedy can be considered as a permanent solutionthat satisfies the statutory preference for reduction of thetoxicity, mobility and volume of hazardous substances. Based onthe limited area of the ground water plume; the ground watercontaminants present and their concentrations, relative todrinking water quality standards; and the fact that the source ofthe contamination (the soil) , was removed in 1984 and 1990, EPAconcluded that it was impracticable to treat the ground watereffectively. This remedy does not satisfy the statutorypreference for treatment as a principal element since treatmentwould be impracticable in this matter.

This remedy will serve to mitigate the threat to humanhealth through the natural attenuation of hazardous substancesreleased from the Site. Because this remedy may result inhazardous substances remaining on-Site above health-based levels,a review of the remedial action will be conducted within fiveyears after the initiation of the remedy to ensure that theremedy continues to provide adequate protection to human healthand the environment unless drinking water standards are achievedprior to the five-year period.

EPA has determined that its response at this site iscomplete. Ground water monitoring will be conducted to insurethe effectiveness of natural attenuation. Therefore, the site nowqualifies for inclusion on the Construction Completion List.

John H. Hankinson, j£. DateRegional Administrator

Record of Decision

Summary of Remedial Alternative Selection

BMI-Textron SiteLake Park, Florida

Prepared by:U.S. Environmental Protection Agency

Region IVAtlanta, Georgia

TABLE OF CONTENTS

Section Page1.0 Site Location and Description 1

2 . 0 Site History and Enforcement Activities 1

3.0 History of Community Participation 54 .0 Scope and Role of Response Action 5

5.0 Summary of Site Characteristics 55.1 Regional Hydrogeology 65.2 Site Soils and Hydrogeology 85.3 Summary of Remedial Investigation Results 8

5.3.1 Soils 95.3.2 Ground water 135.3.3 Well Inventory 18

5.4 Human Population Survey 185.5 Ecological Assessment 21

6.0 Summary of Site Risks 216.1 Contaminants of Potential Concern 216.2 Exposure Assessment 21

6.2.1 Conceptual Site Model 226.2.2 Exposure Point Concentrations 226.2.3 Human Intakes . . . 22

6.3 Toxicity Assessment 266.4 Risk Characterization 266.5 Current and Future Use Site Risk ; 306 . 6 Uncertainties ;' 306.7 Remedial Goals 31

7.0 Description of Alternatives 317 .1 Alternative 1: No Action 317.2 Alternative 2: Institutional Controls and Monitoring 317.3 Alternative 3: Institutional Controls, Monitoring,

Ground Water Recovery, On-Site Treatment, and Off-site Discharge 32

7.4 Alternative 4: Institutional Controls, Monitoring,Ground Water Recovery, On-Site Treatment, andDischarge 34

8 . 0 Comparative Analysis of Alternatives 348.1 Comparative Analysis of Human Health and the

Environment 351. Overall Protection of Human Health and theEnvironment 352. Compliance with ARARs 363. Long-Term Effectiveness and Permanence ....... 364. Reduction of Toxicity, Mobility or Volume .... 395. Short-Term Effectiveness 396. Implement ability 39

i-2

TABLE OF CONTENT (continued)

Section7 . Cost8. State Acceptance9. Community Acceptance

8.2 Synopsis of Comparative Analysis of Alternative ...

9 . 0 Selected Remedy .. 41A. Ground Water Remediation 41

A.I Components of Ground Water Remediation forImplementation 42

A.2 Performance Standards 42B. Compliance Testing 42

10.0 Statutory Determinations 4310.1 Protection of Human Health and the Environment ... 4310.2 Compliance with ARARs 4310 .3 Cost-Effectiveness 4310.4 Use of Permanent Solutions 4410.5 Preference for Treatment as a Principal Element .. 44

11.0 Documentation of Significant Changes 44

APPENDIX

i-3

FIGURES

FiguresFigure 1Figure 2Figure 3Figure 4Figure 5Figure 6Figure 7Figure 8Figure 9

i-4

TABLES

TablesTable 1Table 2Table 3Table 4Table 5

i-5

RECORD OF DECISIONThe Decision SummaryBMI-Textron Site

1.0 SITE LOCATION AND DESCRIPTION

The Basic Microelectronics, Incorporated (BMI)-Textron Site(the Site) is a 3.4 acre area located within the Tri-CityIndustrial Park on Silver Beach Road in Lake Park, Palm BeachCounty, Florida. A Site location map is provide as Figure 1.The Site is comprised of several buildings and paved areas.Industrial areas surround the Site to the north, east and westand a residential area is located south of the Site across SilverBeach Road. A Site plan is shown in Figure 2.

Presently, most of the surface-area on the Site is eitherpaved or covered by buildings. The average rainfall in thisportion of Palm Beach County is 60 inches per year and more than70 percent of the rain falls between May and October. Storm-water runoff is directed to shallow swales located along thestreets. Excessive stormwater runoff flows south (toward SilverBeach Road) then either east or west, further down from the Site.The nearest known surface-water body is the Earman River situatedabout one mile north of the Site.

The nearest residents are located to south (across fromSilver Beach Road) of the Site and there are no known privatedrinking-water supply wells within the vicinity. The nearestknown drinking-water production well is Riviera Beach UtilitySupply Well #16 located approximately 3,000 feet (ft) south-southeast of the BMI Textron Site. A recovery well, screenedbetween 100 and 125 ft below land surface (bis) to capture arelease of volatile organic compounds (VOC), is currentlyoperated at the Trans-Circuit plant situated in an area whichcould be considered slightly downgradient and about 300 ft north-northwest of the BMI-Textron Site. No other wells are known toexist in the immediate downgradient area. The nearest knownwells that would be considered downgradient of the BMI TextronSite are the two Price Funeral Home irrigation wells.

2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES

BMI began manufacturing operations in Lake Park, Florida inOctober 1969. Textron Inc. acquired BMI in January 1981 andbegan operating the Site as BMI-Textron. The facilitymanufactured chromium-backed glass plates used in the productionof electronic components. The actual process involved cutting,cleaning, and polishing glass plates prior to chromiumdeposition. Liquid waste from the process was disposed of onSite through a combination of percolation ponds and drainfields.BMI discharged cyanide containing wastes into Percolation Pond(PP)-l which was abandoned in August 1984. Permit compliancesampling required by Florida Department of Environmental

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I DWG DATE: 14SEP93 I PRJCT NO.: PF04SI03C IflLE NO.: BMI (DRAWING: 45101-SP I CHECKED: D.LEONARD I APPROVED: W.VOCELSONG (DRAFTER: B.OLIVA

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SITE PLAN

FORMER BMI-TEXTRON SITELAKE PARK. FLORIDA

FIGURE

Protection (FDEP), formerly Florida of Department EnvironmentalRegulation (FDER), revealed cyanide contamination of the soil andground water at the Site.

BMI-Textron and the FDEP entered into a Consent Agreement toremove contaminated soils at the Site, in December 1984 .Pursuant to the agreement, approximately 680 cubic yards ofcyanide contaminated soil were removed to a hazardous wastefacility regulated under Subtitle C of the Resource Conservationand Recovery Act. The excavated soil was taken from PP-1,formerly located at the center of the north end of the Site.

Analytical data from samples taken by FDEP in 1986 showedelevated concentrations of cyanide and fluoride in three on-Sitemonitoring wells and in the soil near PP-2 (see Figure 2). OnNovember 18, 1986, BMI-Textron and FDEP entered into anotherConsent Agreement to develop a ground water remediation plan. InApril 1990, as part of the ground water remediation plan and incompliance with the second Consent Agreement, Textron removed 206cubic yards of soil. Concentrations of chromium and cyanide wereremoved from PP-2.

In June 1988, Federal Register (52 No. 122) of the UnitedStates EPA proposed listing the BMI-Textron Site on the NationalPriority List (NPL). In August of 1990, BMI-Textron wasfinalized on the NPL with a hazardous ranking system (HRS) scoreof 37.93. On February 26, 1992, EPA Region IV, under theauthority of Section 104(e) of the CERCLA, 42 U.S.C. §9604(E),issued a Request for Information to Textron. The requestnotified Textron of the existence of a Superfund hazardoussubstance Site at their former BMI-Textron facility and soughtinformation regarding Textron's involvement at the Site. Also,on February 26, 1992, EPA Region IV, issued General and SpecialNotice Letters for Remedial Investigation/Feasibility Study(RI/FS) to previous BMI principal officers (William E. Eaton,Theodore T. Tarone), and Textron, notifying them of potentialliability as potentially responsible parties under CERCLA andestablishing a period of formal negotiations. The General andSpecial Notice Letters initiated a period of negotiation on anagreement to perform the RI/FS at the Site. On April 24, 1992,Textron submitted a Good Faith Offer to EPA, stating it waswilling to conduct an RI/FS at the Site.

In June 1992, Textron and EPA entered into an AdministrativeOrder by Consent (AOC) for the RI/FS. Textron agreed toundertake all actions required by the terms and conditions of theAOC for the conduct and implementation of the (RI/FS). The RI/FSwas conducted to evaluate Site risks and technologies availableto respond to these related risks. The RI found arsenic,cyanide, fluoride, and sodium in ground water beneath the Site.

3.0 HISTORY OF COMMUNITY PARTICIPATION

In February of 1993, EPA started its community relationefforts by conducting community interviews and holding a publicmeeting at the Palm Beach County Library. The meeting was heldto address concerns expressed by the citizens and inform localresidences of EPA's .planned RI activities. This meeting wasattended by five citizens of West Palm and two representativesfrom FDEP.

A public comment period for the proposed remedial action washeld from April 18, 1994 through May 17, 1994. During this timea Proposed Plan fact sheet was released to the public in order toinform the citizens of EPA's findings during the RI/FS event andof EPA's preferred remedial alternative for Site cleanup. Thisevent was also held to notify the public that the details of theRI/FS reports could be found at the Lake Park Library. Inaddition, a public meeting was held on April 21, 1994. In thecourse of this meeting, EPA answered questions about thepotential risk posed by the Site and the remedial alternativesunder consideration. A response to the comments received duringthis period is included in the Responsiveness Summary, which ispart of this Record of Decision (ROD). This decision documentpresents the selected remedial action for the BMI-Textron Site,in Lake Park, Florida, chosen in accordance with CERCLA, asamended by SARA, and to the extent practicable, the NationalContingency Plan. The decision for this Site is based on theAdministrative Record, located in the EPA's repository at thePalm Beach County Library and Region IV rep/ository.

/

4.0 SCOPE AND ROLE OF RESPONSE ACTION

This ROD discloses the planned remedial activities at theBMI-Textron Site, addressing ground water. The cleanup remedywill address the ground water contaminants which remain at theSite. The function of this remedy is to reduce the risksassociated with exposure to contaminated ground water and toprotect the surficial aquifer system present beneath the Site.The ROD is the only ROD anticipated for this Site since thecontamination present at this Site will be addressed as a singleoperable unit.

5.0 SUMMARY OF SITE CHARACTERISTICS

Information on soils, geologic and hydrogeologic conditionsat the BMI-Textron Site are presented in this section, includingthe results of the well inventory ecological assessment and humanpopulation survey conducted as part of the RI. Site surfacefeatures and meteorological data were briefly discussed in theSite Description.

5.1 Regional Hydroqeoloov

The geologic formations underlying the area of Palm BeachCounty near the former BMI-Textron Site consist of the PamlicoSand, the Anastasia Formation, the Fort Thompson formation, andthe Calaoosahatchee Marl.

The Pamlico Sand (Unit 1) mantles all of eastern Palm BeachCounty and consists of sand and shell. The Anastasia Formation(Unit 2) underlies the surficial sand and is composed of sand,sandstone, limestone, coquina and shell. The Caloosahatchee Marl(Unit 4) underlies the Fort Thompson Formation (Unit 3) and iscomposed of shelly sand, sandy shell, marl, limestone andsandstone.

Two surficial aquifers are present in Palm Beach County:the Turnpike Aquifer and the Sandy Ridge Aquifer. Because theTurnpike Aquifer is situated greater than 3 miles to the west andupgradient of the BMI-Textron Site, it is unlikely that thisaquifer has been affected by the Site. This discussionconcentrates primarily on the Sandy Ridge Aquifer. The SandyRidge Aquifer is comprised of sand, shell, sandstone, limestoneor mixtures of these. In the area of the BMI-Textron Site, theSandy Ridge aquifer is reported to extend to a depth ofapproximately 210 feet below mean sea level (MSL) (See Figure 3).Regional ground water flow in this aquifer is reported to betoward the east.

The Sandy Ridge Aquifer can be divided into four hydrologicunits. Unit 1, at the surface, is generally 20 to 40 feet thickand is composed of sand and layers of shell. Unit 2 isapproximately 60 feet thick and is composed of unconsolidatedsand and shell with occasional sandstone. Unit 3 isapproximately 50 feet thick and consists of very fine sand andshell and is generally the lowest in permeability of the fourunits. Unit 4 is approximately 100 feet thick and consists offirmly cemented calcareous sand and shell with occasional layersof marl. Most of the drinking water supply (DWS) wells in thearea of this Site are completed within Unit 4 because it is thethickest and generally the most permeable section in the aquifer.This zone may have a hydraulic leaky confined aquifer, but isstill considered a component of the shallow ground water system.

According to the FDEP, along the Coastal Ridge (the area ofthe BMI-Textron Site) the hydraulic conductivity of the sedimentsis estimated to range between 1 and 50 feet/day; thetransmissivity of the Sandy Ridge Aquifer as a whole, estimatedfrom pump test data, is 7,000 feet2/day and the transmissivity ofUnit 4 is estimated as 4,000 feetVday.

The Sandy Ridge Aquifer is underlain by approximately 250 to350 feet green, shelly clay that is a unit of the Hawthorn Group.

I OWC DATE: 28JAN93 | PRJCT NO.: PF45101 RAWING: 45101CCS

LEVCL

LAND SURFACE

•"•SANDY CLAY

SANO.SHELLS AND OCCASIONALLAYERS Of SANDSTONE

CEMENTED SANDAND SMELLS AND

VCRY FINESANO AND SHELLS

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CEMENTED SAND AND SHELLSOCCASIONAL MARL LAYERS

BEOS OF VCRYFINE SAND AND SHELLS

AND LIMESTONE .USUALLY INTERBEDOEO WITHMARL AND CLAY BASE OF SHALLOW

AQUIFER

MOSTLY CLAY AND SANDSTONE

0 I MILE

400 400

SOURCE: FDER RIVIERA BEACH WELLFIELD CONTAMINATION REPORT (WATTS tt BROWN 1985).

GERAGHTYMILLER, INC.

Environmental Services

GEOLOGIC CROSS SECTION OF THE SANDY RIDGE AQUIFER

FORMER BMI-TEXTRON SITELAKT PARK. FLORIDA

FIGURE

3

This forms the main confining unit that separates the Sandy RidgeAquifer from the underlying Floridan Aquifer. The top of theFloridan Aquifer is approximately 1,000 feet below land surface.In the area of the BMI-Textron Site, the Floridan Aquifer is notan important water supply because the water is brackish (i.e.,1,000 milligrams per liter [mg/L] to 4,000 mg/L of chlorides).

5 .2 Site-Soils and Hydroqeolocry

The BMI-Textron Site is situated on the Coastal Ridgephysiographic province on soils of the Paola series. The Paolasoil consists of nearly-level, excessively drained, deep sandysoils.

The Site is underlain predominantly by unconsolidated, fine-to medium-grained sand to a depth of 210 feet below land surface(bis). The top 20 to 40 ft of subsurface material consists ofsand with occasional layers of sandstone and limestone.

The hydraulic conductivity in the uppermost portion of thisaquifer ranges from 30 to 50 feet per day (ft/day). Values oftransmissivity (35,000 gallons/day-foot) and storage coefficient(O.2) were obtained for the deeper sections of the aquifer atthis Site from the performance of short-term (two day) pumpingtest performed at a near-by facility which FDEP has investigated.In April 1987 a recovery well screened between 100 and 125 biswas pumped continuously at a rate of about 45 gallons per minute(gpm). The calculated values are consistent with range oftransmissivity and storage coefficients presented in the RivieraBeach Well Field Contamination Report prepared by the FDEP inSeptember 1985.

Based on the three rounds of-(February 19, April 5 and July15, 1993) water-level data, collected during the RI, the dominantflow direction in both the upper and lower zones of the surficialaquifer, is to the north/northeast; the depth to ground waterranged between the 15 and 20 feet bis; little or no variation inthe water-level elevations between the upper and lower surficialaquifer zones, indicating a lack of a downward ground, water flowcomponent. The data also indicated a flatter hydraulic gradientand slower ground water movement than indicated in previous Siteinvestigations; and average hydraulic gradient at this Site ofabout 0.0004 ft/ft was calculated from this information; theground water velocities at this Site averaged about 0.05 feet/dayor 19.5 feet/year.

5.3 Summary of Remedial Investigation Results

Sampling conducted during the RI at the Site indicates theprimary contaminated media is ground water which containscyanide, fluoride, arsenic, and sodium.

The absence of surface water bodies in the immediatevicinity of the Site eliminated the need for surface water andsediment sampling. The lack of exposed surface soils precludethe generation of dust containing the inorganic constituentsdisposed of at the Site.

5.3.1 Soils

Soil samples were conducted during the months of Februaryand March 1993, sampling event. Twelve soil borings wereinstalled, and 14 soil samples were collected from those borings.The borings were placed at, or as close as possible to, thesuspected source areas including the three percolation ponds,reverse Osmosis (R.O.) Drainfield, two septic tanks and sixdomestic waste drainfields. Soil samples also were collectedfrom two soil borings in areas hydraulically upgradient of theSite to develop background soil quality conditions. Samplelocation are shown in figure 4.

The results of the analyses of the soil samples from thesource areas were compared to twice the average concentration ofthe constituents detected in the background soils. For metals,the results also were compared to the concentration of theconstituent that is common to the South Florida area. If aconstituent was detected in some but not all of the backgroundsoils, then the average was calculated using the detected resultsand one-half the detection limit concentration for thosebackground samples that were free from the constituent. If aconstituent was not detected in any background sample, theresults of the analysis of the soil samples from the source areaswere compared against the average detection limit of thebackground samples.

Organics Constituents

As shown in Table 1, out of the list of TCL constituentsanalyzed only acetone and fluoranthene were present abovedetection limits. Acetone was reported above twice the averagebackground concentration in the soil samples collected from SoilBorings 93-2 and 93-3 (81 |lg/kg and 170 jig/kg, respectively) .Fluoranthene was reported to be present in the soil sample fromonly one Soil Boring, 93-3. The concentration reported was 7|lg/kg. The low detection frequency of organic constituents (3detections) and the low concentrations reported do not appear toindicate that, at the locations sampled, the waste disposal areasinvestigated are a consequential source of organic constituents.

TABLE i toitoofttwAfurty»l*0f 8t*wurfaoeBo«S«riipl«efortheform* BMt-T«Mr»n Bite, Uk* Park, FtorMa

Pag« 1 of 2

PARAMETER I/TEST

METHOD UNITS

DATE

O&MIOSAVANNAH 10

2/2S/B3

93/1-14-1657700

2/24/B3Dup (83-1-14/16)

Wft-257700

2/24/93

OV2-13-15S7707

2/24/03

93/3-10-1257704

93M-13-1857705

2/24/B3

83/5-13-1657706

KV9-8-1255105

2/23*3

93/7-10-1250104

Volatile Organic Compound*Acetone

Base Neutral and Add ExtraeUbl*Organic Compound*

DlethylphlhalalePhenanthreneAnthraceneCarbazoleD*-n-buty)phlh»lateFluoranthenePyren*ButytbenzylpnthalaleBenzo(a)amhraceneChrysenebto(2-Ethytri*xyi)phlhalateDt-rt-octytphtrwilateBenzo(b)fluorantheneBenzoQtjnuoranthaneBenzo(a)pyrenelndeno(i ,2>cd)pyreneDbenz(a.h)amruacene .Benzo(g.Mperytene

CLP(GC/MS)

CLP(QC/MS)

Z/ 81 170 12

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Inorganic Constituent*AluminumArsenicBariumCadmiumCalciumChromiumCopperIronLeadMagnesiumManganeseMercuryNickelSodiumVanadiumZincCyanide

CLP(CP)

(GFAA)(CP)(CP)(CP)(CP)(CP)(CP)

(QFAA)(CP)(CP)(CV)(CP)(CP)(CP)(CP)CLP

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173022 Jm•

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FOOTNOTES:

1/ ConcUuwiU not detected In any sample are not shown.

21 '•' Indicate* the constituent *a* not detected.

UJ Anarytewa* not detected or has been quaWled M undetected.

«4th further daaancatfcn a* quattalhw.J Value ha* been ctM*»M as qualitative.

U Anafytewn not detected or has been classified a* undetected,

TABLED Heeufta of me Anaty»ie of Sufeeunac* Sou t»*mp>ea tor m*former BMMextron Site. Lake Parti, Florida

Pog« 2 of 2

PARAMETER V

Y/ J lll_I_ fLjJ»J_ILLjL JULIIUU *vouraw organic coropourMaAcetone

Base Neutral and Add ExtracUbtoOrganic Com pound*

DtetnytprrthatatoPhenanthreneAnthraceneCacbazoteDi-n-butylphthalaleFhjoranthenaPyraneButytbanzytphthalataBenzo(a)anihraoanaChiyaenebto(2-Eitiytnexyf)phthalateDt-n-cclylpnthalateBenzo<b)ftuoranthene;B«nzo<k)(hxxanthanaBenzo(a)pyr»nalndeno(1,2.3-cd)pyrenaDt>enz(a.h)arrmraoaneBenzofg.h.Qpeiytene

Inorganic ConethuentsAluminumArsenicBariumCadmiumCalciumChromiumCopperIronLaadMagnesiumManganeseMercuryNickelSodiumVanadiumZincCyanide

TESTMETHOD

CLPJV^*4UCl(UC/M&)

CLP(OC/MS)

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(QFAA)

(ICP)OCP)(ICP)(ICP)(ICP)(ICP)

(QFAA)(ICP)(ICP)(CV)

(ICP)(ICP)(ICP)OCP)CLP

DATE 2/24/03

O&MD 03/8-11-13UNITS SAVANNAH 10 57701

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2/22/93

03-11-0/255106

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t1«l11501H20|

m[54](85]

114]-

[71]

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(78.5) U

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724

UJH7.8] U(1.1) UJ

-11.2][8.91 U

|1J)4.0 U

•

2/22/03 2/22/03Oup (03/12-0-2)

03/12-0-2 OOR-16S101 66103

•

•

••

-

.

67.1 U-

(.74) U-

1650(.55] U.

126\Z

V*\ u42 J..

(12.3) U

(2.5] U

-

-

(10) UJ

15)(7] UJ

W UJ-.

(8) UJ

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4870-.

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678U

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.

(8.1)1.1

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UJ

u

u

uJ

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u

FOOTNOTES:

I/ Conclluent* not detected In any aampto are not thown.

2J ••' Indicates the constituent waa no) delected.

U J Anatyte was not detected or has been quaffled as undetected.

vrflh further daasMcatton as quaftatrv*.

J Value has been ctaaaHM as qualitative.

U AnaVle waa not detected or has been classified •» undetected

'1.

Although di-n-butylphthalate was detected in several samplesat concentrations up to 18 |ig/kg, this compound was also detectedin the equipment/field and laboratory blanks. Therefore, thereported concentrations for this constituent have been classifiedas undetected. Likewise, the concentrations of pyrene (9 (ig/kg) ,butylbenzylphthalate (13 (ig/kg) and bis (2-ethylhexyl) phthalate (7(ig/kg) reported in the soil sample collected from SB-93-3 havealso been classified as undetected, due to the presence of thesecompounds in the associated blank analyses.

Inorganic Constituents

As shown in Table 1, the concentrations of inorganicconstituents present in the subsurface soil samples wererelatively low. Of the constituents measured, aluminum, arsenic,barium, calcium, iron, lead, magnesium, manganese, and vanadiumwere detected at concentrations slightly above twice the averagebackground concentration in soil sample 93/ 1-14-16. This samplewas collected from soil boring SB-93-2. The depth intervalsample is below the fill material used to fill the excavationassociated with the removal action conducted a PP-2 in 1990.

Traces of one to three metals were detected atconcentrations above twice the background concentration in soilsamples collected from five of the remaining eight borings. Thesoil borings and the associated concentrations are presentedbelow:

SB-93-3 arsenic (1.2 mg/kg), and cadmium (0.39 mg/kg)SB-93-3 arsenic (1.1 mg/kg)SB-93-3 arsenic (0.89 mg/kg)SB-93-3 chromium (13.5 mg/kg),manganese (4.7 mg/kg), and

nickel (3 mg/kg)SB-93-3 calcium (3,140 mg/kg), manganese (5.0 mg/kg), and

mercury (0.11 mg/kg)

Samples collected from the three soil borings SB-93-8, SB-93-9and SB-93-10 did not contain concentrations of metals or cyanideabove twice the background levels.

As discussed above, cyanide, which is not normally found insoils, was also detected in the soil sample collected from SoilBoring SB-93-2 (2.2 mg/kg). This low concentration of cyanide inthe soils at PP-2 as well as the lack of cyanide in the samplecollected from SB-93-1, associated with PP-1, is consistent withthe levels of cyanide detected during confirmation samplingconducted after the removal actions associated with the twosources.

Several metals were reported to be present in samples aswell as in the associated equipment/field or laboratory blanks.This led to classification of several metals results as

12

undetected. The metals affected and the maximum concentration ofeach metal that was qualified are barium (1.9 mg/kg), calcium(796 mg/kg), chromium (17.8 mg/kg), magnesium (64.9 mg/kg),manganese (3.5 mg/kg), nickel (1.8mg/kg), sodium (42.2 mg/kg),and zinc (9.8 mg/kg). Because concentrations reported in thesamples that were qualified were at trace levels, thequalification of the data does not compromise the evaluation ofthe nature and extent of impacted soil nor is qualification ofthe data expected to impact the confidence level of theconclusion developed from the risk assessment.

The analysis revealed: 1) low concentrations, <200micrograms per kilogram (|0,g/Kg) , of a very limited number oforganic constituents in only a few soil samples; 2) severalinorganic constituents (primarily metals) in concentrationslightly above twice the average background level; and 3) cyanideand fluoride above background levels. The data collected duringthe RI indicates that previous soil removal efforts done byTextron Inc., has significantly reduced any risk due to soilcontamination.

5.3.2 Ground Water

Ground water sampling was conducted in two events. Nineteenexisting monitor wells and two new monitor wells were sampled inthe first event in March 1993. The second event was conducted inJune 1993 and consisted of installing and sampling four newmonitoring. Thus making the total number of samples consist offive off-Site monitoring wells and 23 monitoring wells (includingmonitor wells previously sampled). Monitor Wells locations areshown in figure 5.

There were no organics found at concentrations greater thanFederal or State standards. Concentrations of several inorganicswere detected in the monitoring well samples, however, only twometals, arsenic and sodium, and two inorganics, cyanide andfluoride, were detected in concentrations that exceeded twice theaverage background concentration and/or the State of Floridaprimary drinking water Maximum Contaminate Level (MCL).

Sodium was found to exceed the State primary drinking waterMCL of 160,00 micrograms per liter (|J,g/L) in only one monitorwell MW-35. The concentration of sodium detected in that samplewas 298,000 p,g/L. Arsenic was found to exceed the primarydrinking water MCLs of 50 |J,g/L in only monitor well, MW-38,during the March 1993 sampling event. Arsenic was detected insamples from only three monitor wells (MW-36A, MW-36B, and MW-35)during the June 1993 sampling event which utilized the modifiedground water sampling procedure discussed in the Final RI Report.Arsenic was not detected in monitor well MW-38 during the June1993 sampling event, this procedure reduced the turbidity ofsamples and minimized the influence of sediments in the sample.

13

.1

¥,'&'•.

/

LEGEND

« Rl SOIL BORING LOCATION

(§> Rl BACKGROUND SOIL BORING LOCATION

g] DOMESTIC WASTE DRAINFIELD LOCATION

g PERCOLATION POND LOCATION

— LINE OF GEOLOGIC CROSS SECTION

•— REED RD. —

g

I2

LJ

i

FRANS-ClRCUIlPLANT

BRANT RD.

GERAGHTY^ MILLER, INC.

Services

LOCATION OF SOIL BORINGS INSTALLED DURING THE Rl

FORMFR RMI-TFJXTRON SITE

FIGURE:4

The arsenic concentrations detected in the three monitor wells inJune 1993 were below the primary drinking water MCL 50(ig/L.Arsenic was detected at a maximum concentration of 18.1|lg/L, which is below the State and Federal standards. Cyanidewas found to exceed the primary drinking water MCL of 200 |0.g/L attwo monitor well locations, MW-35 and MW-38, during the Marchand June 1993 sampling events. Both monitor well locations arein the vicinity of Percolation Pond PP-2. The data indicate theextent of ground water impacted with cyanide above the jyiCL islimited to the upper zone (upper 20 feet ) of the surficialaquifer in the immediate vicinity of Percolation Pond PP-2.Cyanide was detected at levels as high as 2170 to 3190.Fluoride was found to be slightly above the primary drinkingwater MCL of 4000 |J.g/L in samples from four monitor wells duringboth sampling events. Three of these monitor wells (MW-35, MW-36A, and MW-38) are located in the vicinity of Percolation PondPP-2. The fourth monitor" well (MW-3) is located immediately eastof PP-3. The data indicate ground water impacted with fluorideabove the MCL is localized in the upper zone of surficial aquiferin the immediate vicinity of PP-2 and PP-3. Area ofcontamination is shown is figure 6.

Manganese concentrations also exceeded twice the averagebackground concentration at\on monitor well, MW-32; there is noprimary drinking water MCL for manganese (the secondary MCL formanganese is 50 fig/L) . Because the location of MW-32 is crossgradient to the identified locations of waste disposal, and otherconstituents such as cyanide known to be associated with thedisposed waste were not detected, it appears that the elevatedmanganese concentration reported is an isol'ated occurrence andnot attributable to previous waste management practices.

16

IpI

MILLER WAY

IMW-93-I "

Q<r

5

•- REED RO. — •

LEGEND

• EXISTING MONITOR WELL LOCATION

($ MONITOR WELL LOCATION INSTALLED DURING THE Rl (FEBRUARY 1993)

© MONITOR WELL LOCATION INSTALLED DURING THE Rl (JUNE 1993)

DOMESTIC WASTE DRAINFIELD LOCATION

3 PERCOLATION POND LOCATION

MW-93-7 MW-93-6

MW- lOAfMW-10B*

oa:

L.J

TRANS-CIRCUITS

M-7

B2M

i BRANT RD.

MW-93-4

GERAGHTY& MILLER, INC.

.Environmental Services

LOCATION OF MONfTOR WELLS/OFFSfTIE MONFTOR WELLS

FORMER BMI-TEXTRON SITELAKC PARK. FLORIDA

FIGURE

I OWC DATE: 3/10/94 I PRJCT NO.: PF04S1.03C |FlLENO.:BMI I DRAWING: ACru0793.DCE I CHECKED: W.VOCELSONG I APPROVED: W.VOCELSONG I DRAFTER: BJH

MILLER WAY

MW-93-

Qcr

iCD

CtUJ

i/l

LEGEND• EXISTING MONITOR WELL LOCATION® MONITOR WELL LOCATION INSTALLED DURING THE Ri (FEBRUARY 1993)© MONITOR WELL LOCATION INSTALLED DURING THE Ri (JUNE 1993)

P';---'1 DOMESTIC WASTE ORAINFIELO LOCATION

ESSSSJ PERCOLATION POND LOCATION

• > MCL ISOLINE CYANIDE

~_^» > MCL ISOLINE SODIUM

> MCL ISOLINE FLUORIDE

REED RD.

MW-93-6

M W - 1 0 A <

ao:z

I.

J_

• .82N

BRANT RD.

MW-93-4

GERAGHTYAY & MILLER, INC.

Environmental Services

ISOLINES FOR COPC's DETECTED IN GROUNDWATER SAMPLES ABOVE MCLsUPPER ZONE OF THE SURFICIAL AQUIFER

FORMER BMI-TEXTRON SITELAKE PARK. FLORIDA

FIGURE6

The table below is a summary of the COPCs found at duringthe ground water investigation portion of the RI event.

BMI TEXTRON Site GROUND WATER SUMMARY

GROUND WATER

Arsenic

Sodium

Cyanide

Fluoride

Phase1

MCD(M/L)

64.4

298,000

2170

6200

PhaseII

..MCD(W/L)

18

NA

3,190

4800

Federal/State

MCL(Mg/L)

50/50

-- / 160,000

200/200

4000/4000

Note: MCD - Maximum Concentration Detected in Site GroundwaterMCL - Maximum Contaminant Level

NA - Not Analyzed

5.3.3 Well Inventory

BMI-Textron conducted a well inventory within a two mileradius of the Site. A review of South Florida Water ManagementDistrict files and a door-to-door survey in areas lying within1000 feet of the Site were performed. All permitted potablewells (a total of 30) within this area were identified andplotted on Figure 7.

No unpermitted or exempt potable wells were found to existin the area surveyed. The nearest permitted potable well foundin this survey is Public Supply Well #16 for the City of RivieraBeach (Well #21 on Figure 7). A total of 14 irrigation wellsidentified in the survey area are shown on Figure 7. Seven ofthe irrigation wells were found to exist in the residentialneighborhoods south, southeast and east of the Site. Wellconstruction information was not available for the other 5 wellsin the vicinity of the former BMI-Textron Site. The closestirrigation well (Well #7) is approximately 100 feet south of thesouthern property boundary. The RI has revealed no Site relatedwell contamination within the two mile survey.

5.4 Human Population Survey

A survey of specific demographic data within a two-mileradius of the BMI-Textron Site was performed. The nearestresidential community lies south of Silver Beach Road as shown onFigure 8. The Site is surrounded by a locked, chain-link fencewhich inhibits access by the community.

18

oUJ

5

o

oz

i

c

gccQ.

i ilS i&Z'S'•;•' '•<«'&~-f, "

"*'"«/ ' . i-Sk: / \ '-\', , , J

,...;-> r;/^\ •: H i ^ A i ' ~3/ >j- }).>>\ - • '• . . , , . i*\", ^iI JT O r H 9^^£^__==V^-J^~x, >»4 |V.^8qyr^;^>-K. ..-*JsjLur!r

J "f vJV 'i- ** -. iJ." t U\\v^Sri

i : ;•:.j: 4 ^v>.xy^. . , o i !• ' •- • -^^

::H ^> )7- H iSlX^ !!/-«Lj^-ni-—fi.yti.».17 -^-i" I !i"o!TJ- ' l i \ i

^ j23^.: \^•.-^•Ti \ \ \

LEGEND -r . ^ r»if POTABLE WELL Dn««-n fl/. . \ •*$ ««OATIOI4WELL Th«iWI I * "V—

SCALE

FEET2000 BASE MAP SOURCE: U.S.C.S. 7.5 MINUTE SERIES (TOPOGRAPHIC)

RIVIERA BEACH QUADRANGLE.

SO

WELL MVENTORY MAP

FORMER BMI-TEXTRON SITE'LAKE PARK. FLORIDA

FIGURE

7

24

n

\\

21

21 21

22

r\ rNewman Road

%\%tI

3

ty

^ fJXx BUI-

P '

fa///////.

8

ORUCR-TCXTRl*aurr

km

//

2 ///

//

W /

y

IjJ%^

!

1

200

Silver diocn

RESIDENTIAL AREA .

i v.

iBUILDING INVENTORY

1. OR. JOHN'S AUTO CLINIC2. a. AERO PRECISION (FAA REPAIR STATION)3. HOUSE OF CUSTOM CUSHIONS4 VACANT BUILDING5. HARORIVES (PAVING COMPANY)6. FIRESIDE DISTRIBUTORS7. BEACH MIRROR * CLASS/ANDERSON MASONRY8. SIGNING AMERICA CORP.9. GLOBAL ELECTRIC10. TR1-CITY LUUBER11. AAH AUTO. INC.13. OAIRS AUTOMOTIVE!4. PARK CARPET15. PARK CLASS16. 6ARON SIGN CO.~.J. BEACH A/C

56. LAKE & BAY BOATS19. DUN RIGHT MFG.20. DETAILING & WINDOW T: -T21. MISC. REPAIR SHOPS (AuTO. ETC.)22. VACANT BUILDING (FORMERLY TRANS CIRCUfTS. JNC.)23. ACTION BOLT & TOOL24. THOUSANDS OF PARTS AUTO JUNKYARD25. PALM BEACH X-RAY26. SPECIALTY WOODWORKS (KIT. CABINETS)27. CARRIER A/C2B. JAR WELDING29. NEVER WEAR ASPHALT SEALER30. MILES OF SOUND (CAR STEREOS)31: WELDING BY DAM32. NEW IMAGE AUTO BODY33. LUCtDO BROTHERS (CABINETS)

AREA VICINITY MAP

BM8-TEXTRON SITELAKE PARK, FLORIDA

FIGURE NO.

8

5.5 Ecological Assessment

The BMI-Textron Site is in an industrial park, with the areasurrounding the Site consisting of a locked, chain-link fence. Agrass-covered drainage swale, approximately 5 to 10 feet wide,located on the perimeter of the property. The majority of theSite is covered.by building, asphalt pavement, and concrete whichreduces exposure pathways (see Figure 2). Although the area ispaved or covered with a building, the ecological assessmentconcluded that no visual evidence exists that indicate biota atthe Site and surrounding areas have been adversely impacted byoperations at this Site.

6.0 Summary of Site Risks

CERCLA directs EPA to conduct a Baseline Risk Assessment(BRA) to determine whether a Superfund Site poses a current orpotential threat to human health and the environment in theabsence of any remedial action. The BRA provides the basis fortaking action and indicates contaminants and the exposurepathways that need to be addressed by the remedial action. Thissection of the ROD contains a summary of the results of the BRAconducted for this Site. The completed BRA is located in theBMI-Textron repository, located in the Palm Beach County Library.

6.1 Contaminants of Potential Concern

The objective of contaminant identification is to screen theinformation that is available on hazardous /substances present atthe Site and to identify COPC in order to focus subsequentefforts in the risk assessment process. COPC are selected basedupon their toxicological properties, concentrations and frequencyof occurrence at the Site. During the Risk Assessment for theBMI-Textron Site, the following chemicals were identified ascontaminants of potential concern in the ground water: arsenic,sodium, cyanide and fluoride. Arsenic was listed as a COPCduring the first round of sampling done in February and March1993, however, in a second round of sampling the arsenicconcentration level was below federal and state MCLs.

6.2 Exposure Assessment

Exposure assessment is conducted to identify pathwayswhereby human receptors may be exposed to Site contaminants andto estimate the frequency, duration and magnitude of suchexposures. Exposure assessment is a multiphase process thatinvolves (1) characterization of the exposure setting; (2)identification of exposure pathways; and (3) quantification ofexposure.

21

6.2.1 Conceptual Site Model

The primary source of contamination at the BMI-Textron Sitewas wastewater/sludge in Percolation Ponds (PP-1, PP-2 and PP-3).These contaminant sources were removed through previous soilremovals during Percolation Pond Closures, in December 1984 andApril 1990. The primary release mechanism for previouslyexisting contamination is to ground water. The medium availablefor human contact is ground water.

Ground water and subsurface soils beneath the BMI-TextronSite became contaminated through the disposal of thesludge/wastewater in the Percolation Ponds infiltration ofrainwater also caused ground water contamination through theleaching of contaminants from subsurface soil to ground water.Analytical results collected during the RI from both on and off-Site monitoring wells confirm the presence of contamination inground water both beneath the Site and downgradient (G&M, 1993).The potential exposure pathways are diagrammed in the conceptualSite model, Figure 9.

6.2.2 Exposure Point Concentrations

Reasonable maximum exposure (RME) point concentrations forground water were calculated using the lesser of the 95 percentupper confidence limit (UCL) on the arithmetic average for alognormal distribution or the maximum detected value. Where aCOPC was not detected, one-half the quantitation limit was usedas a concentration. RME concentrations for, the surficial aquiferreveal that exposure point concentrations for future use at theSite are oral exposure to contaminants. Concentrations ofexposure route are presented in Table 2.

6.2.3 Human Intakes

Currently, no drinking water wells are known to becontaminated. Additionally, surface soil contamination that didexist has been removed. Since there are no current completeexposure pathways, there is no risk to human health based oncurrent use of the Site.

In the future use scenario, new wells might be installedwithin the contaminant plume and utilized by workers or bypotential residents. The variables used in calculating oralintakes are presented below:

1. Residents

Ingestion rate 1 L/day-child (conservativeestimate); 2 L/day-adultExposure frequency 350 days/year

22

03

C 1

t) mS x!5 H* ;o? o§ 2

5 C/>> Hm

O •O

0mP

TU

AL

&frl2 'O0mr* .

szO

\

CONTAMINANT/ PRIMARY RELEASE/ AFFECTED EXPOSURE EXPOSURE RECEPTORSOURCE TRANSPORT MECHANISM MEDIA POINT ROUTE

i

j1ELECTRONIC

COMPONENT . ..rhin ^^__ nrmindwater _ Onsite . Inoc-tion . n^t-fnRia___ _ «i. «««—i LCdCning ^^— ^»- uivunuvraici — — i >.<iiaiiv, - iiiutjuun 1 r\U>ueiutiPRODUCTION |WASTES -^

L- Workers

'

I

Exposure duration 6 years-child, 30 years-adultBody weight 15kg-child, 70 kg-adultAveraging time 70 years for cancereffects, 6 years-child and 30years-adult non-cancer effects

2. Workers

Ingestion rate 1 L/dayExposure frequency 250 days/yearExposure duration 25 yearsBody weight 70 kgAveraging time 70 years for cancer effects, 25years non-cancer effects

Calculated intakes of ground water from the surficialaquifer for a child resident, an adult resident and a worker arepresented in Table 2.

24

Table 2Summary of Reasonable Maximum Exposure Concentrations^' for a Future Hypothetical Receptor Exposed

to Ground WaterBMI-Textron SiteLake Park, Florida

* " %*f3V^y^ %fi3?'

ArsenicSodiumCyanideFluoride

17.4298000

19336200

1.1E-031.9E+011.2E-014.0E-1

9.5E-051.6E+001.1E-023.4E-02

4.8E-048.2E+005.3E-021.7E-01

2.0E-043.5E+002.3E-027.3E-02

1.7E-042.9E+001.9E-026.1E-02

6.1 E-051.0E+006.8E-032.2E-02

Notes:

RME Reasonable Maximum ExposureADD Average Daily DoseLADD Lifetime Average Daily Dose

25

6.3 Toxicity Assessment

The purpose of a toxicity assessment is to weigh availableevidence regarding the potential of the contaminants of concernto cause adverse effects in exposed individuals and to provide anestimate likelihood of adverse effects. The toxicity assessmentis based on toxicity values which have been derived fromquantitative dose-response information. Toxicity values forcancer are known as slope factors (SFs) and those determined fornon-carcinogenic effects are referred to as reference doses(RfDs).

Slope factors (SFs), which are also known as cancer potencyfactors (CPFs), have been developed by EPA's CarcinogenicAssessment Group for estimating excess lifetime cancer risksassociated with exposure to potentially carcinogenic chemicals.SFs, which are expressed in units of (mg/kg-day) ~l, aremultiplied by the estimated intake of a potential carcinogen, inmg/kg-day, to provide an upper-bound estimate of the excesslifetime cancer risk calculated from the SF. Use of this,approach makes underestimation of the actual cancer risk highlyunlikely. SFs are derived from the results of humanepidemiological studies or chronic animal bioassays to whichanimal-to-human extrapolation and uncertainty factors have beenapplied. SFs for the contaminants of concern at BMI-Textron arelisted in Table 3.

Reference doses (RfDs) have been developed by EPA forindicating the potential for adverse health effects for exposureto chemicals exhibiting non-carcinogenic effects. RfDs, whichare expressed in units of mg/kg-day, are estimates of lifetimedaily exposure levels for human, including sensitive individuals.Estimated intakes of chemicals from environmental media (e.g. theamount of a chemical ingested from contaminated drinking water)can be compared to the RfD. RfDs are derived from humanepidemiological studies or animal studies to which uncertaintyfactors have been applied (e.g. to account for the use of animaldata to predict effects on humans). These uncertainty factorshelp ensure that the RfDs will not underestimate the potentialfor adverse non-carcinogenic effects to occur. RfDs for thecontaminants of concern at BMI-Textron Site are found in Table 3.

6.4 Risk Characterization

Human health risks are characterized for potentialcarcinogenic and non-carcinogenic effects by combining exposureand toxicity information. Excess lifetime cancer risks aredetermined by multiplying the estimated daily intake level withcancer risks with cancer potency factor. These risks areprobabilities that are generally expressed in scientific notation(e.g., IxlO'6). An excess lifetime cancer risk of IxlO"6

indicates that, as a reasonable maximum estimate, an individual

26

Table 3Cancer Slope Factor and Reference Doses for Contaminants of Concern

BMI-Textron SiteLake Park, Florida

KS/""-^4 "! '-'/ >-- ' '# " '''

ArsenicSodiumCyanide (free)Fluoride (child)Fluoride (adult)

.' csr WA*;a&M {/;\:,;Qrattv/

";V*. ; -x ; -•

1.75E+00NANANANA

' s A<£ £<

,? - - - ;--

NANANANANA

;«-:™;/j6dsSft/aw/<s<v)' : 76?Ut ?'

> *" v /

3E-04 (1)3.4E+01 (2)2E-02 (1)6E-02 (1)1E-01 (1)

-^halation-> -

NANANANA

(1) IRIS,(2) ECAO,

19931992

CSF - Cancer Slope FactorRfD - Reference DoseNA - Not Applicable

27

has a one in one million additional (above their normal risk)chance of developing cancer as a result of Site-related exposureto a carcinogen over a 70-year lifetime under the assumedspecific exposure conditions at a Site. EPA considers individualexcess cancer risks in the range of 1x10"" to IxlCT6 asprotective; however, the IxlO"6 risk level isgenerally used as the point of departure for setting cleanuplevels at superfund Sites. A summary of cancer and non cancerRisks is listed in Table 4.

The potential for non-carcinogenic effects is evaluated bycomparing an exposure level over a specified time period (e.g.,life-time) with a reference dose derived for a similar exposureperiod. The ratio of exposure to toxicity is called a hazardquotient (HQ). An HQ<1 indicates that a receptor's dose of asingle contaminant is less than the RfD, and that toxic non-carcinogenic effects from that chemical are unlikely. The HazardIndex (HI) is generated by adding the HQs for all chemical(s) ofconcern that affect the same target organ (e.g., liver) within amedium or across all media to which a given population mayreasonably be exposed. An HI<1 indicates that, based on the sumof all HQ's from different contaminants and exposure routes,toxic non-carcinogenic effects from all contaminants areunlikely.

The HQ is calculated as follows:

Non-cancer HQ=CDI/RfDi

where:

CDI=Chronic daily intake

RfD=reference dose

GDI and RfD are expressed in the same units and representthe same exposure period (i.e., chronic, subchronic, or short-term) .

To characterize the overall potential for non-carcinogeniceffects associated with exposure to multiple chemicals, EPA hasdeveloped a HI approach. This approach assumes thatsimultaneous subthreshold chronic exposures to multiple chemicalsthat effect the same target organ are additive and could resultin an adverse health effect. The HI is calculated as follows:

28

Table 4Summary of Cancer and Noncancer Risks

BMI-Textron SiteLake Park, Florida

' ' " '

l"'\ .."Adu-l t^lsid^t1

wx HI

Surficial Aquifer .2E-04 13.8 4E-04 5.9 1E-04 2.1

HI Hazard Index (non-cancer risk)

29

Hazard Index = ADDi/RfDj + ADD2/RfD2 + . .

where: ADD; = Average Daily Dose (ADD) for the toxicantRfD; = Reference Dose for the toxicant

The term ADDi/RfDi is referred to as the Hazard Quotient(HQ) . Calculation of a HI in excess of unity indicates thepotential for adverse health effects. Indices greater than onewill be generated anytime intake for any of the chemicals ofconcern exceeds its RfD. However, given a sufficient number ofchemicals under consideration, it is also possible to generate aHI greater than one even if none of the individual chemicalintakes exceeds it respective RfD.

6 . 5 Current and Future Use Site Risk

EPA has discovered no current complete exposure pathways.Thus, there is no risk to human health based on current use ofthe Site. Future risks posed by the Site consider consumption ofdrinking water from a well screened within the contaminant plumeof the surficial aquifer. Examination of the above hypotheticalrisk is consistent with the philosophy expressed in the NCP,which is to treat ground water as a valuable resource to beprotected and restored. Cancer and non-cancer risksattributable to drinking water from the surficial aquifer for achild resident are presented in Table 4. The maximum cancer riskestimate for ingestion of drinking water for an adult resident is4xlO~4, with a hazardous index of 5.9. The maximum HI calculatedwas 13.8 for the child resident scenario. Estimate of cancerrisk greater than 1 x 10"4 and non cancer risk greater than one,are outside EPA's acceptable target range for risk at Superfundsites (explaination of risk values can be found in section 6.4 ofthe ROD) . Actual or threatened releases of hazardous substanceif not addressed by implementing the response action selected inthis ROD, may present an imminent and substantial endangerment tohuman health.

6.6. Uncertainties

Reference dose factors and carcinogenic slope factors forthe COPCs were derived from the IRIS, EPA's chemical toxicitydatabase. All values in IRIS have been peer-reviewed andapproved for use. For sodium which is not included in IRIS,toxicity data were obtained for EPA's Environmental Criteria andAssessment Office.

The calculated RfD is likely overly protective, and its useresults in an overestimation of non-cancer risk. Similarly, thecancer slope factor developed by EPA are generally conservativeand represent the upper-bound limit of the carcinogenic potencyof each chemical . The use of the conservative assumptions andmodels and the conservatism built into the toxicity values are

30

believed to result in an overestimate of risk. Therefore, actualrisk may be much lower than the estimates presented in previoustables, but is not likely to be greater.

6.7 Remediation Goals

The risk assessment determined, Site-specific remediationgoals for the ground water to initially establish levels suitablefor drinking. Because all the COPCs have MCLs, the MCL valueswere utilized as remedial goals for this Site. The remediationgoals for the COPCs are included in the table listed on page 14,under Federal and State MCLs.

7.0 Description of Alternatives

The following Site specific alternatives represent a rangeof distinct actions addressing human health and environment. Theanalysis presented below reflects the fundamental components ofthe various alternatives considered feasible for this Site. Thetransport model used for establishing timeframe for each of theground water alternative is called SEFTRAN. This model reflectsa relative comparison of remedial alternatives and does notnecessarily reflect the actual remedial periods. A more detaileddiscussion of this model can be found in the ContaminantTransport Modeling section of the FS report.

Four ground water alternatives have been identified forevaluation and are listed below:

Alternative 1: No ActionAlternative 2: Institutional Controls and MonitoringAlternative 3: Institutional Controls, Monitoring,

Groundwater Recovery, On-Site Treatment, andOff-Site Discharge

Alternative 4: Institutional Controls, Monitoring, GroundWater Recovery, On-Site Treatment, andDischarge

7.1 Alternative 1; No Action

Under the "No Action" alternative, no proactive steps(including monitoring) will be taken to clean up the affectedmedia, which in this case is ground water. This means that theSite will be left as is without monitoring of any kind or deednotices or restrictions to restrict exposure to the affectedground water.

7.2 Alternative 2: Institutional Controls and Monitoring

Alternative 2 incorporates the use of institutional controlsalong with periodic Site monitoring to achieve Federal and State

31

ground water standards without any remedial construction. Thisalternative would include the following:

• Natural Degradation/Attenuation of COPCs;• Water Well Controls and Regulatory Restrictions;• Site Security; and• Monitoring.

This alternative is considered, based on ground watertransport modeling, which indicates a reduction of COPCs tofederal and state standards in approximately 3 years due tonatural attenuation mechanisms. During the 3 years, ground waterwill be monitored quarterly for one year to verify modelleddecrease of contaminant concentration. During the remaining twoyears an annual review of monitoring frequency. Selected wellswithin the existing monitoring well network would be used toprovide confirmation of historical data and modeling transportdata that indicates the COPCs will naturally degrade and/orattenuate with time. However, EPA reserves the right to increaseor decrease monitoring frequency should sampling data indicatethe necessity. If after the three years of monitoring, datashows that Performance Standards are achieved, then the Site willbe considered for deletion from the National Priorities List(NPL). However, should monitoring indicate that the Site hascontaminants above standards, EPA in consultation with the Stateof Florida, will reconsider the protectiveness of the"Institutional Controls and Monitoring" alternative.

Institutional controls associated with this Site includeestablished regional well controls and use of existing wellpermitting regulations administered through the South FloridaWater Management Department (SFWMD), the Palm Beach County HealthDepartment (PBCHD), and FDEP. A Consumptive Use Permit and WaterWell Construction Permit, each approved by the SFWMD, and aproperty inspection are required for installation of any publicwater supply well and for any private well if the casing diameteris six inches or larger. All other well installations requirewell permits approved by the SFWMD.

Ground water monitoring would be used in association withthe institutional controls to document naturaldegradation/attenuation of affected ground water. These measureswould be required until cleanup goals is achieved for a minimumof two consecutive sampling periods.

7.3 Alternative 3; Institutional Controls. Monitoring. GroundWater Recovery. On-Site Treatment, and Off-Site Discharge

This alternative includes actions outlined in Alternative 2,along with ground water recovery, on-Site treatment for cyanide,and off-Site discharge to the City of Palm Beach WastewaterTreatment Plant (POTW). Based on ground water modelling this

32

alternative would reach Federal and State ground water standardswithin one year after installation. This alternative includesthe following:

Installation of Recovery Well near Monitor Well MW-38;Installation of a Recovery Well near Monitor Well MW-3;Performance of an Aquifer Pump Test to EstablishDischarge Concentrations;On-Site Treatment of Cyanide;Off-Site Discharge of Recovered Ground water to anearby Manhole for Transfer to the POTW;Pumping, Treatment, and Discharge Systems Operation;Water Well Controls and Regulatory Restrictions;Site Security (fencing); andMonitoring

The contaminant transport model indicates that installationof a recovery well near MW-38 pumping at an estimated rate of 3gallons per minute (gpm), and installation of a second recoverywell near MW-3 pumping also at an estimated rate of 3 gpm, wouldeffectively capture the contaminated ground water. The low yieldrecovery system would be designed to pump until theconcentrations of COPCs reach federal and state standards orasymptotic levels are achieved, at which time the pumping wouldcease until equilibrium is achieved, and then pumping wouldresume. The pumping system would be used in conjunction withinstitutional controls and periodic monitoring, low yieldrecovery would be an effective, implementable approach tolowering the concentrations of COPCs to acceptable levels.

To implement this alternative, an aquifer pump test would beperformed during remedial design to establish dischargeconcentrations of COPCs. The pump test would involve pumping thetwo recovery wells at an estimated total flow rate of 6 gpm, withthe recovered ground water discharged into an on-Site, portablestorage tank. Based on current data, anticipates that theconcentrations of COPCs in the extracted ground water will beacceptable for discharge to the POTW, with the exception ofcyanide which may require treatment to reduce the total cyanideconcentration to the POTW pretreatment standard of 0.7mg/L.Ground water collected by the recovery well near Monitor Well MW-38 would be treated by appropriate technology as determined bythe screening criteria to meet the POTW pre-treatment standardfor cyanide. Ground water collected by the second recovery wellnear Monitor Well MW-3 would by pass the treatment system sincethe anticipated concentration of cyanide from this well is non-detect and below the remediation goal. Ground water treatmentwould be preformed using a package alkali-chlorination treatmentsystem, including controls and instrumentation.

The treated ground water would be collected on-Site in a

33

portable storage tank for transfer to the local POTW. Twooptions for transfer of the ground water to the POTW areconsidered: 1) construction of a pipeline approximately 1600feet long with connection to an existing sewer system (manhole),or 2) trucking of the ground water to the local POTW. The chosenoption would be design during pre-design activities.

Ground water monitoring would also be used to document thereduction in concentrations of COPCs. The transport modelindicates that with continuous pumping of the recovery'wells theremediation goals would be achieve in approximately 1 year frominstallation. However, should remediation goals not be reachedin prescribed time, pumping will continue until goals arereached.

7.4 Alternative 4: Institutional Controls, Monitoring, GroundWater Recovery, On-Site Treatment, and Discharge

This alternative also incorporates the actions outlined inAlternative 2, and on-Site disposal of the water to a rechargegallery. This alternative includes the following:

Installation of a Recovery Well near Monitor Well MW-38;Installation of a Recovery Well near Monitor Well MW-3;Performance of an Aquifer Pump Test to EstablishDischarge Concentrations;On-Site Treatment of Cyanide, Fluoride, and Sodium;Installation of a Recharge Gallery;Pumping, and Discharge Systems Operation;Water Well Controls and Regulatory Restrictions;Site Security (fencing); andMonitoring.

As with Alternative 3, this alternative includes theutilization of a recovery well which would be installed nearmonitor Well MW-38, a second recovery well which would beinstalled near monitor well MW-3, along with the pumping strategyof 3 gpm each well.

The treated ground water would be collected in an on-Site,portable storage tank and a gravity feed system would be used todischarge treated water from the tank to the recharge gallery.The recharge gallery would be located upgradient of PP-2.Remedial standards are expected to be achieve approximately 1year after installation.

8.0 Comparative Analysis of Alternatives

The alternatives are evaluated against one another by usingthe following nine criteria:

34

Overall protection of human health and the environment.Compliance with Applicable or Relevant and AppropriateRequirements (ARARs).Long term effectiveness and permanence.Reduction of toxicity, mobility, or volume throughtreatment.Short term effectiveness.Implementability.Costs.State acceptance.Community acceptance.

The NCP categorized the nine criteria into three groups:

(1) Threshold criteria: the first two criteria, overallprotection of human health and the environment andcompliance with ARARs (or invoking a waiver), are theminimum criteria that must be met in order for analternative to be eligible for selection;

(2) Primary balancing criteria: the next five criteria areconsidered primary balancing criteria and are used to weighmajor trade-offs among alternative cleanup methods; and,

(3) Modifying criteria: state and community acceptance aremodifying criteria that are formally taken into accountafter public comment is received on the proposed plan.State and community acceptance is addressed in theresponsiveness summary of the ROD. ;

8.1 Comparative Analysis of Human Health and the Environment

The comparative analysis of the alternatives proposed forthis Site are presented in this section.

1. Overall Protection of Human Health and the Environment

With the exception of the Alternative 1, all of thealternatives would provide protection for human health and theenvironment. Alternative 1 and 2 rely on naturaldegradation/attenuation mechanisms to remediate the COPCs.Alternative 2 is more protective than Alternative 1, since itincludes periodic monitoring of the natural processes.Alternative 2 also uses institutional controls to restrict use ofground water.

With regard to aquifer remediation, Alternative 1 and 2 usenatural mechanisms while Alternative 3 and 4 include ground waterrecovery and treatment. Based on the current informationavailable, there is evidence to suggest that naturaldegradation/attenuation is occurring. The basic contaminant

35

transport model suggests that both Alternatives 3 and 4 wouldrequire approximately 1 year from installation to remediate theplume while Alternatives 1 and 2 would each require 3 yearwithout construction. Alternative 3 would require on-Site O&M,including sludge handling, system operators and also provides foradditional treatment at the POTW. Alternative 4 requiresincreased on-Site O&M and sludge handling which complicates thesystem management and creates a greater risk for on-Site operatorexposure and accidental spillage.

2. Compliance with ARARS

Table 5 presents a comparison of the applicability of thepotential chemical-specific, location-specific, and action-specific ARARs to each of the four remedial alternatives for theformer BMI-Textron Site. All four alternatives have thepotential to be in compliance with ARARs. Alternatives 1 and 2rely on natural degradation/attenuation mechanisms to remediatethe impacted ground water. Based on the current informationavailable, including transport modeling, there is evidence tosuggest that natural degradation/attenuation is occurring.However, Alternative 1, does not provide a mechanism such asground water monitoring to demonstrate compliance with ARARs.The pumping options, Alternatives 3 and 4 will comply with ARARsthrough ground water treatment. If the natural remediationprocesses, Alternatives 1 and 2, are found to be ineffective inreducing constituent concentrations, then Alternatives 3 and 4would, at a minimum, come closer to reaching remediationstandards since these alternatives would remove at least some ofthe COPCs.

Part 141, Subparts B,F and G; Maximum Contaminat Levels(MCLs) and Maximum Contaminant Level Goals (MCLGs) promulgatedunder the authority of the SDWA are specifically identified inSection 121 of CERCLA as well as in the NCP as remedial actionobjectives for ground waters that are current or potentialsources of drinking water supply. The ground waters underlyingthis Site are classified as Class IIA ground water (i.e., aspotentila sources of drinking water) under the EPA Guidelines forGround-Water Classification. MCLs and all non-zero MCLGs areetherefore relevant and appropriate for use as remedial actionobjectives for ground water cleanup at this Site and will have tobe attained. In that FDEP is authorized to adiminister the SDWA,the MCLs and non-zero MCLs estabished under FDEP law are therelevant and appropriate standards for this Site.

3. Lonq-Term Effectiveness and Permanence

All of the alternatives, with the exception of theAlternative 1, would reduce potential risks and/or environmentalimpacts. The remaining alternatives would utilize ground watermonitoring results to document actual effectiveness.

36

Table 5 . Applicability of Potential ARARs to Each Remedial Alternative for the Former BMI-Textron Site; Lake Park, Florida. Page 1 of 2

POTENTIAL ARARs ALTERNATIVE 1NO ACTION

ALTERNATIVE 2INSTITUTIONAL CONTROLS AND

MONITORING

ALTERNATIVE 3INSTITUTIONAL CONTROLS. MONITORING.

GROUNDWATER RECOVERY. ON-SITETREATMENT. AND OFF-SITE DISCHARGE

ALTERNATIVE 4INSTITUTIONAL CONTROLS.

MONITORING. QROUNOWATERRECOVERY. AND ON-SITE TREATMENT

AND DISCHARGE

CHEMICAL-SPECIFICARARst

40 CFR 141.11-141.18 SafeDrtnMng Water Act MaximumContAmtn&nt uvcls*

33 USC1251 dean Water Act;Section 303 - water qualityslaiHiaros hdudlny Statewater Quality standards, andSection 304 - Federal waterquality criteria.

Florida Administrative CodeFAC Rules 17-3 and 17-550Florida drtnHng waterstandards and monitoringfrequencies for contaminantsIn gr oundwater.

According to groundwater modelingresults, this alternative win achieve thechemical-specific ARARs. but ft Includes nomonitoring to demonstrate achievement ofthe chemical-specific ARARs.

According to groundwater modelingresults, this alternative will achieve thechemical-specific ARARs. and It Includesmonitoring to demonstrate achievement ofthe chemical-specific ARARs.

According to groundwater modelingresults, this alternative will achieve thechemical-specific ARARs. and It Includesmonitoring to demonstrate achievement ofthe chemical-specific ARARs.

According to groundwater modelingresults, this alternative will achieve thechemlcal-speclflc ARARs. and It Includesmonitoring to demonstrate achievementof the chemlcsl-spectflc ARARs.

LOCATION-SPECIFICARARs:

1. 29 USC 651/29 CFR 1910.120Occupational Safety andHealth Act of 1970 worker andpublic hearth requirements.

2. Palm Beach CountyEnvironmental Control Rule 2requirements for permittingand Installing wells, mandatedby the Palm Beach CountyPublic Health Department.

3. Florida Administrative CodeFAC 40{e)3 • South FloridaWater Management Districtrule* regarding wellconstruction.

4. FAC Rules 17-4 and 17-S31Regarding permits and waterweds.

None of these location-specific ARARs areapplicable to this alternative.

All of these location-specific ARARs areapplicable to this alternative since ItIncludes Institutional controls andmonitoring. Location-specific ARAR No. 1.Is applicable during monitoring events,location-specific ARAR No. 4 Is applicablefor construction of the monitoring wells,and the" remaining location-specific ARARsare applicable as Institutional controls Inlimiting the Installation of wells at or nearthe former BMI-Textron site.

An of these location-specific ARARs areapplicable to this alternative since ItIncludes Institutional controls, monitoring.and on-slte workers. Location-specificARAR No. 1. Is applicable duringmonitoring events and operation of thetreatment system; location-specific ARARNos. 1 and 4 are applicable duringconstruction and operation of thegroundwater recovery and treatmentsystem: and the remaining location-specificARARs are applicable as Institutionalcontrols In limiting the Installation of wellsat or near the former BMI-Toxtron site.

All ol these location-specific ARARs areapplicable to this alternative since ItIncludes Institutional controls, monitoring,and on-slte workers. Location-specificARAR No. 1. Is applicable duringmonitoring events and operation of thetreatment system; location-specific ARARNos. 1 and 4 are applicable duringconstruction and operation ol thegrounawater recovery and treatmentsystem; and the remaining location-specific ARARs are applicable asInstitutional controls In limiting theInstallation of wells at or near the formerBMI-Textron site.

f:\prof\pf451\arartbl.w51

Table 5 >. Applicability of Potential ARARs to Each Remedial Alternatlre for the Former BMI-Textron Site; Lake Park, Florida. Page 2 of 2

POTENTIAL ARARs ALTERNATIVE 1NO ACTION

ALTERNATIVE 2INSTITUTIONAL CONTROLS AND

MONITORING

ALTERNATIVE 3INSTITUTIONAL CONTROLS. MONITORINO.

OROUNOWATER RECOVERY. ON-SITETREATMENT. AND OFF-SITE DISCHARGE

ALTERNATIVE 4INSTITUTIONAL CONTROLS.

MONITORINO. QROUNDWATERRECOVERY. AND ON-SITE TREATMENT

AND DISCHARGE

ACTION-SPECIFICARARs!

40 CFR 122.44(a) Use of bestavailable or best conventionalpollution control technology tocontrol pollutants.

40 CFR 122.41(1) Dischargemonitoring to assurecompliance using testmethods approved under 40CFR 138.1-136.4.

40 CFR 264.601 Design andoperating standards formiscellaneous units In whichhazardous waste Is treated.

40 CFR 122.41(1) Properoperation end maintenance, erfthe recovery and treatmentsystem.

Resource Conservation andRecovery Act (RCRA)requirements for sludgehandling and disposal.

40 CFR 403.9 Prohibition of. discharge of pollutants thatpass through a POTW withouttreatment. Interfere with POTWoperation, contaminate POTWsludge, or endanger the healthand safety of POTW workers.

City of West Palm BeachWastewaterTreatmentSystem (POTW) ore-treatmentstandards Including monitoringand reporting requirements.

FAC Rule 17-520 Qroundwaterclasses, standards, andexemptions regardinggroundwater classification andcriteria for discharge togroundwater.

Palm Beach County BundingDepartment building permits.

Only action-specific ARAR No. 6 Isapplicable to this alternative, and thegroundwater at the former BMI-Textronsite Is considered a Class II groundwater.

Only action-specific ARAR No. 8 Isapplicable to this alternative, and thegroundwater at the former BMI-Textronsite Is considered a Class II groundwater.

Action-specific ARARs No. 1. 3, 4. 5. 6. 7.8. and 9 are applicable to this alternativewith respect to design, construction.operation, and maintenance of therecovery and treatment system: dischargeto the POTW;-and Qroundwater beingconsidered Class II.

Actlc.n-specfflc ARARs No. 1. 2. 3. 4, 5. fl,and 9 are applicable to this alternativewith respect to design, construction,operation, and maintenance ot therecovery and treatment system; dischargeto the recharge gallery; and groundwaterbeing considered Class II.

T:\proJ\pf451\arartbl.w51

Alternatives 2, 3 and 4 would also incorporate institutionalcontrol to protect human health. Alternatives 1 and 2 usesnatural degradation. Alternatives 3 and 4 would acceleratedegradation, once treatment is initiated.

4. Reduction of Toxicity, Mobility or Volume

Alternatives 1 and 2 would reduce (to some degree) toxicity,mobility and volume of ground water impacted by COPCs, throughthe uses of natural degradation/attenuation of constituents withtime, as predicted by the transport model. Through pumping,alternative 3 and 4 would contain the area of impacted groundwater while reducing the volume of COPCs. Alternatives 3 and 4would use ground water recovery to lessen the time frame forreduction of concentrations to occur, and would limit themigration of COPC.

5. Short-Term Effectiveness

Alternatives 1 and 2 depend on the naturaldegradation/attenuation mechanisms, which ground water modelingindicates will happen in approximately 3 years. Based ontransport modeling Alternatives 3 and 4 may achieve remediationstandards in approximately 1 year following construction of thetreatment system. However, prior to completion of constructionactivities EPA will negotiate a Consent Decree with Textron, adesign would be prepared, and the system must be built. Theseactivities could take up to two years to complete.Consequently, based on the relative time fc/r remediation,Alternatives 3 and 4 would be similar.to that of Alternative 2.Alternative 3 and 4 have some inherent risks related to groundwater handling and discharge which Alternatives 1 and 2 do nothave. These risks which potentially include such things asaccidental spillage of impacted water, pass-through of untreatedwater, and potential exposure to on-Site system operators, wouldbe considered when developing a Health and Safety Plan forconstruction activities.

6. Implementability

Alternative 1 is the easiest to implement, yet it providesno protection of human health and environment. Alternatives 2 isalso easily implemented. This alternative relies oninstitutional controls that are already in place and enforced byPBCHD, SFWMD, and FDEP. Furthermore, a network of monitoringwells already exists both on-Site and off-Site to periodicallysample and analyze ground water for COPCs. Alternative 3 issimilar to alternative 4, however, implementation is contingentupon: 1) approval from the cities of Lake Park and Riviera Beachfor accessing the public right-of-ways adjacent to Reed Road andSilver Beach Road, for installation of the pipeline from the Siteto the nearest manhole; 2) approval from Riviera Beach Utilities

39

to tie-in and discharge to their manhole; 3) approval from theCity of West Palm Beach POTW to discharge ground water to theirfacility, and 4) enforcement of institutional controls andobtaining deed restrictions. In addition, system operationmaintenance would require trained personnel assigned to run thesystem. Implementation of alternative 3 is contingent uponenforcement of institutional controls, 1.5 years for systemdesign, POTW approval, EPA approval, and construction. Thissystem would also require trained personnel assigned to run thesystem.

7 . Cost

A summary of the present worth costs, including O&M, foreach of the alternatives is presented below:

Alternatives

Alternative 1

Alternative 2

Alternative 3

Alternative 4

Total Cost

$0

$253,800

$755,000

$654,200

8. State Acceptance

The State of Florida, as represented by the FDEP, has beenthe support agency during the Remedial Investigation andFeasibility Study process for the BMI-Textron Site. Inaccordance with 40 CFR 300.430, as the support agency, FDEP hasprovided EPA with input during the process. Based upon commentsreceived from FDEP, it is expected that written concurrence willbe forthcoming; however, a letter formally recommendingconcurrence with the preferred remedy has not yet been received.

9. Community Acceptance

There have been very few comments from the local community.Comments indicated that residents wish to remain informed of theprogress of remedial efforts.

8.2 Synopsis of Comparative Analysis of Alternatives

All of the alternatives, with the exception of the "NoAction", would provide acceptable degrees of overall protection

40

of human health and environment and would comply with ARARs.Alternative 2 is considered the best alternative based on thecriteria used to evaluate remedies. This alternative is believedto be protective of human health and the environment, wouldattain ARARs, and is cost effective.

9.0 Selected Remedy

Based upon consideration of the requirements of CERCLA, theNCP, the detailed analysis of alternatives and public and statecomments, and the results of the RI report, EPA has determinedthat no active remediation is necessary for the soil at the Site.With respect to ground water cfontamination, the previous datagathered from Textron along with the RI/FS and Risk Assessmentresults indicated that natural degradation/attenuation isoccurring at the Site. However, because the future potentialrisk to human health and the environment from exposure tocontaminated ground water at the Site is at a level which EPA mayconsider taking action, the ground water at and around the Sitewill be monitored quarterly for one year to confirm that themodelled decrease of contaminant concentrations to the drinkingwater standards are indicative of an actual decrease ofcontaminants on the Site. Quarterly monitoring for the firstyear. During the remaining two years EPA would conduct an annualreview of monitoring frequency will be conducted. Selected wellswithin the existing monitoring well network would be used toprovide confirmation of historical data and modeling transportdata that indicates the COPCs will naturally degrade and/orattenuate with time. The monitoring program also would be usedto provide confirmation that no off-Site migration of COPCs atconcentration greater than the remediation goals is occurring.

The total present worth cost of the selected remedy, isestimated at $253,800. There is no capital cost associated withthis remedy. However, total annual O & M is $79,200, presentworth of annual O&M cost is $207,800 and present worth ofverification of goals cost $46,000.

A. Ground Water Remediation

Natural degradation/attenuation will be the method of groundwater remediation. The progress of this natural attenuation willbe monitored with periodic ground water sampling. Existinginstitutional controls will be relied upon to protect againstpossible exposure to contaminants and to confirm that the Federaland State standards are obtained. Monitoring will use existingwells and, if necessary, the construction of additional wells.Ground water usage will be restricted via institutional controlsuntil such time as ground water reaches the goals specified in9.A.2. for a minimum of two consecutive monitoring events.

41

A.1 Components of Ground Water Remediation forImplementation

a. Institutional controls for the former BMI-Textron Siteconsist of existing regional well control whichincludes restrictions and permitting requirements forinstallation of any water supply wells in the vicinityof the impacted areas.

b. Ground water monitoring of the COPCs would beimplemented to track the movement and naturalattenuation degradation of the COPCs.

A.2 Performance Standards

The cleanup standards for the BMI-Textron Site arepresented in the following table.

BMI TEXTRON Site GROUND WATER REMEDIATION STANDARDS

GROUND WATER

Arsenic

Sodium :i

Cyanide

Fluoride

Federal

H9/L

50

—

200

4000

State

MO/L

50

160,000

200

4000

Note: MCL - Maximum Contaminant Level— No Federal Standard Exists

It may become apparent during the implementation of thisalternative that contaminant levels have ceased to decline andare remaining constant at levels higher than the above standard.In such a case, EPA in consultation with FDEP, may re-evaluatethe protection afforded by this alternative.

B. Compliance Testing

During the 3 years, ground water will be monitored quarterlyfor one year to verify modelled decrease of contaminateconcentration. During the remaining two years EPA would conduct

42

an annual review of monitoring frequency. Selected wells withinthe existing monitoring well network would be used to provideconfirmation of historical data and modeling transport data thatindicates the COPCs will naturally degrade and/or attenuate withtime. The monitoring program also would be used to provideconfirmation that no off-Site migration of COPCs atconcentrations greater than the above remediation goals isoccurring. However, should monitoring indicate that the Site hascontaminants at concentrations greater than standards, EPA inconsultation with the State of Florida, will reconsider theprotectiveness of the "Institutional Controls and Monitoring"alternative.

10.0 Statutory Determinations

EPA has determined that the selected remedy will satisfythe statutory determinations of Section 121 of CERCLA. Theremedy will be protective of human health and the environment,will comply with ARARs, will be cost effective, and will usepermanent solutions to the maximum extent practicable.

10.1 Protection of Human Health and The Environment

A ground water monitoring remedy has been chosen to protecthuman health and the environment by confirming that contaminantsare being reduced or by alerting EPA of potential furthermigration of the contaminated ground water and by monitoring thecontaminant concentrations in ground water until theconcentrations are less than or equal to the PerformanceStandards. Compliance with MCLs will be protective at this Site.The long-term cancer risk associated with possible ingestion ofground water will be reduced to within EPA's acceptable riskrange of IxlO"4 and IxlO'6 and the non-carcinogenic risk would bereduced to the EPA goal of 1. Periodic ground water monitoringwill be conducted to evaluate the performance of the naturaldegradation/attention process.

10.2 Compliance with ARARs

Implementation of this remedy will comply with all Federaland State ARARs and will not require a waiver. The naturaldegradation/attenuation mechanism will meet the ground waterperformance standards noted in Section 9.A.2, which are based onFederal and State MCLs. Federal and State MCLs are consideredrelevant and appropriate in the cleanup of contaminated groundwater.

10 .3 Cost-Effectiveness

The selected remedy, Alternative 2, is a cost effectiveremedy. The total estimated present worth cost of thisalternative is $253,800, which includes implementation and annual

43

operation and maintenance costs. EPA has determined that thecost of implementing the remedy is appropriate given thepotential threat posed by the contaminated ground water.

10.4 Use of Permanent Solutions and Treatment Technologies

The selected remedy uses natural degradation/attenuationmechanisms to reduce the toxicity, mobility, and volume ofcontaminants in ground water.

10.5 Preference for Treatment as a Principal Element

The statutory preference for treatment will not be met, becausethe selected remedy does not contain an actual treatment.However, the selected remedy does include Site monitoring toensure that the natural degradation/attenuation is occurring andmigration of contaminants does not exist.

11.0 Documentation of Significant Changes

The remedy described in this Record of Decision is thepreferred alternative described in the Proposed Plan for thisSite. There have been no significant changes in the selectedremedy.

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APPENDIX

RESPONSIVENESS SUMMARY

The U.S. Environmental Protection Agency (EPA) held a publiccomment period from April 18 to May 17, 1994 for interestedparties to comment on EPA's Proposed Plan for the BMI-TextronSite, which addressed contaminated ground water. During thecomment period, EPA conducted a public meeting at the RivieraBeach Municipal Complex, in Riviera Beach, Florida on April 21,1994. During this meeting, representatives of EPA presented theresults of the studies undertaken at the Site and EPA's preferredalternative for addressing ground water contamination.

A summary of EPA's response to comments received during thepublic comment period, known as the responsiveness summary, isrequired under Section 117 of CERCLA. EPA has considered all ofthe comments summarized in this responsiveness summary indetermining the final selected remedy presented in the Record ofDecision.

This responsiveness summary consists of the following sections:

A. Background of Community Involvement and Concerns: Thissection provides a brief history of community interestand concerns regarding the BMI-Textron Site.

B. Summary of Manor Questions and Comments Received Duringthe Public Comment Period and EPA's Responses:

A. Background of Community Involvement and Concerns

In accordance with Section 113 and 117 of CERCLA, EPA hasconducted community relation activities at the BMI-Textron Siteto ensure that the public remains informed on the Siteremediation progress. During the numerous investigativeactivities, EPA held meetings and telephone conversations withcity and state officials to advise them of the progress ofactivities at the Site.

A community relation plan (CRP) was developed in 1993 toestablish EPA's plan for community participation during theremedial activities. Prior to the initiation of the RemedialInvestigation/Feasibility Study (RI/FS), EPA held an AvailabilitySession in West Palm Beach, Florida to present to the public theactivities scheduled for the RI. Following completion of theRI/FS, a Proposed Plan fact sheet was mailed to local residentsand public officials in April 1994. The fact sheet detailedEPA's preferred alternative for addressing the source ofcontamination at the BMI-Textron Site. Additionally, theAdministrative Record for the Site, which contains Site relateddocuments including the RI and FS reports and the Proposed Plan,was made available for public review at the informationrepository in the Lake Park Library. A notice of the

availability of the Administrative Record for the BMI-TextronSite was published in the Palm Beach Post Newspaper, which servesLake Park, Riviera Beach and other surrounding areas, on April17, 1994, and again on April 24, 1994.

A 30-day public comment period was held for April 18, 199.4, toMay 17, 1994, to solicit public input on EPA's preferred groundwater remediation alternative. Written comments were receivedfrom representatives for Textron Inc. only. Textron agreed withthe selected remedy, but asked for clarification on EPA'sinterpretation of the preferred ground water alternative.

In addition to the comment period, EPA held a public meetingin Riviera Beach, Florida on April 21, 1994, at the Riviera BeachMunicipal Complex to discuss the remedial alternatives underconsideration and to answer any questions concerning the ProposedPlan for the BMI-Textron Superfund Site. The meeting wasattended by several concerned citizens and representatives ofTextron Inc. EPA's response to the comments received at themeeting and Textron's written comments are summarized in SectionII below. Additionally, a transcript of this public meeting wasprepared by a certified court reporter, and this document is apart of the Administrative Record upon which the remedy selectedin the Record of Decision is based.

Following the issuance of the final Record'of Decision, EPAwill continue to keep the community informed about progress atthe site through fact sheets and informational meetings asneeded. Additional, design and construction documents pertainingto the implementation of the ground water temedy will be placedin the information repository at the Lake Park Library.

B. Summary of Maior Questions and Comments Received During thePublic Comment Period and EPA's Responses

1. Comment:

The Proposed Plan indicates that Site monitoring would occur overa three-year period, based on the ground water modeling performedfor the Site. Will remediation standards be reached within thattime period.

Response:

A numerical transport model called SEFTRAN was used to simulatethe movement of contaminant of potential concern (COPC). TheSEFTRAN model is a two-dimensional ground water flow andcontaminant transport model developed to simulate the movement ofcontaminants in two dimensions through time in response to groundwater flow. This model reflects a relative comparison ofremedial alternatives and does not necessarily reflect the actualremedial periods. Site monitoring will be performed for an

anticipated period of three years, however, that period may bemodified based on certain decision criteria. For example, ifafter three years, the remedial standards have not been met andoff-Site concentrations of contaminants of concern reflect anincrease which is likely to exceed remedial standards, EPA wouldconsider if additional clean-up should take place. The three-year monitoring period is the time-frame for evaluating changesin water quality and will not necessarily preclude implementationof further actions.

2. Comment:

How often will the monitoring occur?

Response

During the 3 years, ground water will be monitored quarterly forone year to verify modelled decrease of contaminantconcentration. During the remaining two years EPA would conductan annual review of monitoring frequency. Selected wells withinthe existing monitoring well network would be used to provideconfirmation of historical data and modeling transport data thatindicates the COPCs will naturally degrade and/or attenuate withtime. Any modifications to frequency will be determined bysampling data.

3. Comment:

The Proposed Plan states that the monitoring should sample forcyanide, fluoride and sodium. The commentor did not feel sodiumwas related to operations at the Site. Although theconcentrations of sodium are above the state standard, theconcentrations are restricted to a small portion of the Site anddo not pose a threat to public health or the environment. Whyshould this constituent being sampled for when the State ofFlorida has been known to waived the State maximum contaminantlevel for sodium.

Response:

Sodium was listed as a COPC by the baseline risk assessmentduring the RI because in high volumes sodium has been known tocause problems with human health (i.e. elevated blood pressure).The State of Florida has not waived the contaminant level forsodium on this Site.

4. Comment:

The Proposed Plan states that institutional controls applicableto the Site consist of "the use of existing regional wellcontrols, and the continuance of FDEP deed restrictions." What

deed restrictions have been imposed on the Site and who has theauthority to do so?

Response:

The restrictions for the site apply to existing regional wellcontrols to restrict site usage, administered through state andlocal agenci.es. The FDEP is responsible for notifying regulatorypersonnel in the SFWMD and the PBCHD of the existence of anyCERCLA or RCRA sites within their respective jurisdiction,including the BMI-Textron site. Consequently, the permittingofficials would be expected to deny permit applications forinstallation potable water wells in the impacted area of thesurficial aquifer.

5. Comment:

How long will Alternative 4 take?

Response:

Following signature of the Record of Decision (ROD) EPA wouldnegotiate with Textron to conduct the design and construction ofthe selected alternative. Remedial design for this alternativeis expected to take up to 18 months. Ground water transportmodel indicate the remedial standards would to occur within 1year of installation. Therefore, the cleanup goals could bereached as soon as 2 1/2 to 3 years from ROD.

6. Comment:

Are there any of potential harmful effects to people thatformerly worked at BMI Facility?

Response:

The primary pathway of exposure or route of exposure in which aperson could come in contact with the COPCs is oral contact. Thismeans that for a person to be exposed to potentially harmfulcompounds the person would have to consume the contaminatedground water from the site. However, local potable watersupplies obtain their water from uncontaminated sources that aresafe from contamination by the BMI-Textron Site.

7. Comment:

Is there any danger to the residential area south of the Site?

Response:

According to data gathered during the RI, the area of the wellsthat showed contamination are east/northeast of the residential

area. Our RI further showed that the area of contamination islimited to on site. To the north, west and east are industrialareas which are on city water supply and the nearest residentialarea is located to the south which also have city water supplied,

8. Comment:

Is the problem at BMI-Textron Site along the same lines as theproblem found at Soletron?

Response:

No. The two sites are a great distance away from each other andcontain different COPCs. The BMI-Textron Site risk is due toinorganics percolating into the ground water. Soletron was anaccidental spilling of volatile organics into a sanitary watersystem and is being addressed by FDEP.

9 . Comment:

Given the location of the Transcircuit Facility and thesimilarities of the chemicals associated with both the BMI andTranscircuit Facilities, could Trancircuit be the source orpartial source of the ground water contamination?

Response:

The Transcircuit facility is located crossgradient todowngradient (depending on the pumping of the city wells) fromthe BMI-Textron Site. The RI has not shown evidence of any kindof contaminants in the areas that might join the BMI-Textron andTranscircuit Facilities together. BMI-Textron contains metalswhile the Transcircuit Facility contains metals and volatileorganic compounds as contaminants. Our data has not shown metaland organic contaminants together. Also, the area ofcontamination indicated by the RI is located approximately 300feet downgradient from the Transcircuit Facility.