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Five-Year Review Report

Second Five-Year Review Report for

Chemform, Inc. Superfund Site FLD080174402

Pompano Beach Broward County, Florida

September 2010

Prepared by: United States Environmental Protection Agency

Region 4 Atlanta, Georgia

Approved by: Date:

~ Franklin E. Hill Director, Superfund Division

111111111111 II1111II11 11111 I11I1 I1111 II11I 11I11II1 10745502

Table of Contents

Section Page List of Acronyms and Abbreviations 3 Executive Summary 4 Five-Year Review Summary Form 7

1.0 Introduction 9 2.0 Site Chronology 10 3.0 Background 11

3.1 Physical Characteristics 11 3.2 Land and Resource Use 11 3.3 History of Contamination 15 3.4 Initial Response 15 3.5 Basis for Taking Action 16

4.0 Remedial Actions 17 4.1 Remedy Selection 17 4.2 Remedy Implementation 18 4.3 Operation and Maintenance (O&M) 21

5.0 Progress Since the Last Five-Year Review 21 5.1 Continue Five-Year Reviews 22 5.2 Determine Status of Monitoring Wells 22 5.3 Establish Exit Strategy and Sample Groundwater 23

6.0 Five-Year Review Process 27 6.1 Administrative Components 27 6.2 Community Involvement 27 6.3 Document Review 28 6.4 Data Review 29 6.5 Site Inspection 34 6.6 Interviews 37

7.0 Technical Assessment 39 7.1 Question A: Is the remedy functioning as intended by the decision

documents? 39

7.2 Question B: Are the exposure assumptions, Toxicity Data, Cleanup Levels, and Remedial Action Objectives (RAOs) Used at the Time of Remedy Selection Still Valid? 40

7.3 Question C: Has Any Other Information Come to Light That Could Call Into Question the Protectiveness of the Remedy? 41

7.4 Technical Assessment Summary 41 8.0 Issues 42 9.0 Recommendations and Follow-Up Actions 43

10.0 Protectiveness Statements 44 11 .0 Next Review 45

Chemform FYR 1 September 2010

List of Tables, Figures and Appendices

Tables Page 1 Chronology of Site Events 10 2 Comparison of Groundwater Concentrations to Application or Relevant and

Appropriate Requirements (ARARs) and To-Be-Considered Criteria (OU-1 ROD, Table 13) 16

3 Progress on Recommendations from the 2005 FYR 22 4 Summary of Groundwater ARAR Changes for OU-1 29 5 Analytical Data Summary for Wells sampled during 2007 and 2010 31 6 IC Summary Table 35 7 Current Issues for the Chemform Site 42 8 Recommendations to Address the Current Issues at the Chemform Site 43

Figures 1 General Location of the Chemform, Inc. Site, Pompano Beach, Florida 12 2 Site Location and Adjacent Properties 13 3 Site location and Surrounding Area, Pompano Beach, Florida 14 4 Former Monitoring Well Locations 19 5 June 2007 Sample Location 23 6 April 2010 Sample Locations 25 7 Proposed Groundwater Sampling Locations 26 8 Florida Groundwater Delineated Area Map 36

Appendices A Press Notice B Documents Reviewed C Groundwater Data Summary o Site Inspection Checklist E Photographs F Interview Documentation


List of Acronyms and Abbreviations

AOC ARAR BCHD bls CERClA CFR COC ECM EPA ESD FAC FDEP FYR IC KECO MCl MClG NCP NOV NPL O&M OU PMI PRP RA RAO RifFS ROD RPM SARA SDWA SFWMD TBC TCE UAO VOC ~g/l

Administrative Order on Consent Applicable or Relevant and Appropriate Requirements Broward County Health Department below land surface Comprehensive Environmental Response, Compensation and Liability Act Code of Federal Regulation Contaminant of Concern Electro-Chemical Milling United States Environmental Protection Agency Explanation of Significant Differences Florida Administrative Code Florida Department of Environmental Protection Five-Year Review Institutional Control Kismet Engineering Company Maximum Contaminant level Maximum Contaminant level Goal National Oil and Hazardous Substances Contingency Plan Notice of Violation National Priorities List Operation and Maintenance Operable Unit Precision Metal Industries, Inc. Potentially Responsible Party Remedial Action Remedial Action Objectives Remedial Investigation/Feasibility Study Record of Decision Remedial Project Manager Superfund Amendments and Reauthorization Act Safe Drinking Water Act South Florida Water Management District To Be Considered Trichloroethene Unilateral Administrative Order Volatile Organic Compound micrograms per liter


Executive Summary

Introduction

The Chemform, Inc. site (the "site") is located in south Florida at 1410 SW 8th Street in Pompano Beach, Broward County, Florida. The site occupies approximately four acres in a bighly industrialized section of Broward County in the municipa~ity of Pompano Beach. The site is bordered by SW 8th Street to the north, Precision Metal Industries to the east, an industrial access road to the south, and Seaboard Coastline railroad tracks to the west. The site is fenced and includes a 50,866 square-foot building.

Industrial operations at the site were initiated in 1967 by Kismet Engineering Company (KECO). The company primarily repaired and refurbished turbine engine components for the aerospace industry. It also was involved in manufacturing metal pa,rts, which included conventional machine-making as well as manufacturing high-tech electro-chemical milling (ECM) machines. Manufacturing the ECM machines involved the use of electrolytic solutions and strong electric current.

From 1967 to 1985, numerous companies, including Chemform, Inc., conducted operations at the site which generated different wastes and spent materials. Metal milling and mechanical shaping operations required cutting-oils to lubricate and cool the components. Organic solvents were used for metal cleaning. Fiber glassing and painting processes also required the use of organic solvents for thinning and cleaning purposes. ECM machine wastewater and sanitary sewage were reportedly discharged to an on-site septic tank and leach field near the southwest corner of the building. Process wastewaters were discharged to an on-site open trench in the field on the west side of the building.

On April 17, 1990, the United States Environmental Protection Agency (EPA) issued a Unilateral Administrative Order (UAO), to the Potentially Responsible Parties (PRPs), requiring them to address the removal of drums found on the site and to investigate the effect of metal concentrations in the groundwater. The PRPs commenced the removal action in October 1990, inventorying, characterizing, and disposing of over 450 waste and product containers. Based upon the results of this initial action, EPA amended the UAO to also require the PRPs to remove contaminated soil that could potentially affect the groundwater. This second phase of the removal action began in July 1991 and was completed in early 1993.

The site was divided into two Operable Units (OUs). Operable Unit I (OU-l) addresses groundwater contamination. The OU-l Record of Decision (ROD) was signed on September 22, 1992 and documented a selected remedy of "No Action with Monitoring" for groundwater. This remedy was based on the remedial investigation results and risk assessment, which indicated that for the identified Contaminants of Concern (COCs) no remediation of groundwater was needed at the site. It was expected that the removal of soil and waste in 1992 would eliminate the potential for inorganic constituents to leach from surface and subsurface soils into groundwater. The OU-I ROD required quarterly groundwater monitoring of the COCs for one year. Quarterly monitoring was conducted between October 1993 and July 1994.


On April 2, 1999, EPA approved an Explanation of Significant Differences (ESD) for OU-I. The ESD added a new COC to the remedy (vinyl chloride), required the conductance of FiveYear Reviews (FYRs), and required additional sampling as EPA deemed necessary. It also documented the existence of public water supply lines in the area, as well as State and Local groundwater use regulations (institutional controls [ICs]) which prevent a future exposure route from occurring. Groundwater sampling was conducted twice during this FYR period.

The September 16, 1993, OU-2 ROD selected remedy for soil was ''No Further Action". The decision in the OU-2 ROD was based on prior soil excavation and removal of approximately 3,000 cubic yards of contaminated material. The ROD stated that the risks posed by remaining soil contamination were within EPA's acceptable risk range. However, the PRPs excavated additional arsenic contaminated soil at the site in 1994 to meet Florida Department of Environmental Protec60n's (FDEP) risk management goal of lxlO-6

.

The site was deleted from the National Priorities List (NPL) on July 28,2000. This is the second FYR for the Chemform, Inc. site. The triggering action for this policy review is the date of approval of the previous FYR, September 30, 2005. The FYR is required due to the fact that hazardous substances, pollutants, or contaminants remain at the site above levels that allow for unlimited use and unrestricted exposure.

Technical Assessment

OU-I The remedial actions continue to operate and function as designed. The OU-l ROD required monitoring for at least one year, which was completed. The ESD documented the presence of lCs to prevent use of the contaminated groundwater aquifer, and required FYRs and groundwater sampling as deemed necessary. Groundwater was sampled twice during the past five years. Contaminant concentrations remain above ARAR levels, but have not increased significantly. lCs are in place and affected properties obtain their drinking water from Broward County. Only one of the original ten monitoring wells could be located during sampling events. However, groundwater monitoring can be performed by Geoprobe/direct push methods. Addi60nal attempts should be made to locate and properly plug and abandon any wells that lack integrity or will not be used in a future monitoring program. An assessment and monitoring program should be developed to confirm cleanup goals are eventually met.

The groundwater ARAR for arsenic is currently more stringent than it was at the time of the 1992 ROD for OU-I (10 ~glL now, 50 ~g/L in the ROD). The Baseline Risk Assessment indicated that the average groundwater arsenic concentration (24 ~glL) exceeded EPA's acceptable risk range of lxl0-4

; however the ROD used the MCL as a comparison standard. Arsenic was detected above the current ARAR in one of the twelve groundwater samples collected in 2010 in a location that is recommended for further monitoring. Because no one is exposed to the contaminated aquifer and future monitoring is recommended, the change in ARAR does not call into question the current protectiveness of the remedy. However, it is recommended that the ROD be modified to update the cleanup goal for arsenic to the current ARAR.


Land use at the site has changed slightly in that the building is now being used to store food products. EPA Region 4 Technical Services Section reviewed historical and recent groundwater data for the site and determined that because Volatile Organic Compounds (VOCs) were not detected at the top of the aquifer, the vapor intrusion pathway is not a complete exposure pathway.

Contaminant concentrations in groundwater decreased significantly after the soil removal action was completed. However, concentrations have remained about the same during the past fifteen ycars. The ESD implied that the remedial action objectives were to prevent human consumption of the groundwater until ARARs are achieved. ICs are in place and are effective at meeting that objective.

OU-2 The OU-2 ROD required no further action based on a soil removal action that had been completed prior to the ROD. However, the PRPs excavated additional soils, as required by FDEP, to achieve a 10-6 risk range. There has been no new data to suggest that the soil remedy is not protective.

Conclusion

OU-l The remedy at OU- l currently protects human health and the environment because ICs are in place that effectively prevent consumption of water from the contaminated aquifer, there currently is no unacceptable risk of vapor intrusion, and FYRs are being conducted. However, in order for the remedy to be protective in the long-term, the following actions need to be taken: modify the ROD to reflect current groundwater arsenic ARARs and require ICs as part of the remedy; attempt to locate, plug and abandon missing monitoring wells; develop and implement an assessment and monitoring program that includes vertical delineation and installation of monitoring wells with appropriate screen intervals to effectively monitor plume and confirm cleanup goals are met.

OU-2 The remedy at OU-2 is protective of human health and the environment. Contaminated soil was removed from the property to allow for unlimited use and unrestricted exposure to soil.

Site-wide The remedy at OU-l is protective in the short-term. The remedy at OU-2 is protective. Therefore, the site is considered protective of human health and the environment in the shortterm. In order for the remedy to be protective in the long-term, the following actions need to be taken: modify the ROD to reflect current groundwater arsenic ARARs and require ICs as part of the remedy; attempt to locate, plug and abandon missing monitoring wells; develop and implement an assessment and monitoring program that includes vertical delineation and installation of monitoring wells with appropriate screen intervals to effectively monitor plume and confirm cleanup goals are met.


Five-Year Review Summary Form

o NPL-Removal only o NPL State/Tribe-lead

Triggering action: o Actual RA Onsite Construction at OU# o Actual RA Start at OU# o Construction Completion IZI Previous Five-Year Review Report o Other (specify)

* ["OU" refers to operable ** [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN.)


Five-Year Review Summary Form (continued)

Issues:

1. Nine out of ten monitoring wells could not be found. 2. Missing monitoring wells may not have been plugged and abandoned according to state or federal regulations/guidelines. 3. Groundwater continues to show contamination above ARARs. There are inadequate monitoring wells to characterize the plume, monitor attenuation and confirm groundwater cleanup goals are met. 4. Arsenic in groundwater may indicate contribution from turbid sample or possible ongoing source. 5. The arsenic ARAR is now more stringent than the criteria established in the ROD and recent sampling indicated arsenic concentrations above the more stringent MeL. 6. The 1999 ESD documented the existence ofIes, but did not "require" les as part of the remedy.

Recommendations:

1. Either install new permanent monitoring wells or utilize direct push/temporary wells for future groundwater sampling. 2. Attempt to locate, and plug and abandon wells that lack integrity, or that will not be used to monitor plume or to confirm groundwater cleanup goals are met. 3. Develop and implement assessment and monitoring program that includes vertical delineation and installation of monitoring wells with appropriate screen intervals to effectively monitor plume and confirm cleanup goals are met. 4. Install/develop appropriate monitoring wells to ensure representative samples and evaluate likely sources. 5. Modify the ROD to reflect the current State and Federal ARARs for arsenic. 6. Modify the ROD to "require" les as part of the remedy.

Protectiveness Statements: OU-l The remedy at OU-l currently protects human health and the environment because res are in place that effectively prevent consumption of water from the contaminated aquifer, there currently is no unacceptable risk of vapor intrusion, and FYRs are being conducted. However, in order for the remedy to be protective in the long-term, the following actions need to be taken: modify the ROD to reflect current groundwater arsenic ARARs and require les as part of the remedy; attempt to locate, plug and abandon missing monitoring wells; develop and implement an assessment and monitoring program that includes vertical delineation and installation of monitoring wells with appropriate screen intervals to effectively monitor plume and confirm cleanup goals are met.


Site-wide The remedy at OU-1 is protective in the short-term. The remedy at OU-2 is protective. Therefore, the site is considered protective of human health and the environment in the short-term. in order for the remedy to be protective in the long-term, the following actions need to be taken: modify the ROD to reflect current groundwater arsenic ARARs and require les as part of the remedy; attempt to locate, plug and abandon missing monitoring wells ; develop and implement an assessment and monitoring program that includes vertical delineation and installation of monitoring wells with appropriate screen intervals to effectively monitor plume and confirm cleanup goals are met.

Other Comments: None


Second Five-Year Review Report for

Chemform, Inc. Site

1.0 Introduction

The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of a remedy in order to determine if the remedy will continue to be protective ofhuman health and the environment. The methods, [mdings, and conclusions ofFYRs are documented in five-year review reports. In addition, FYR reports identify issues found during the review, if any, and document recommendations to address them.

EPA prepares FYRs pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 121 and the National Oil and Hazardous Substances Contingency Plan (NCP). CERCLA § 121 states:

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

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

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

EPA Region 4 conducted the FYR and prepared this report regarding the remedy implemented at the Chemform, Inc. site in Pompano Beach, Broward County, Florida. This FYR was conducted from November 2009 through September 2010. EPA is the lead agency for developing and implementing the remedy for the PRP-financed cleanup at the site. FDEP, as the support agency representing the State of Florida, has reviewed all supporting documentation and provided input to EPA during the FYR process.

This is the second FYR for the Chemform, Inc. site. The triggering action for this policy review is the date of approval of the previous FYR, September 30, 2005. The FYR is required due to the fact that hazardous substances, pollutants, or contaminants remain at the site above levels that allow for unlimited use and unrestricted exposure. The site consists of two OUs, both of which are addressed in this FYR.


2.0 Site Chronology

The following table lists the dates of important events for the Chemform, Inc. site.

Table 1: Chronology of Site Events

Event Date

Contamination occurred due to spills during the manufacture of metals parts for the aerospace industry 1967 - 1985

Broward County issued a Notice of Violation to Chemform, Inc. citing unlawful industrial waste discharge on site March 23, 1977

Discovery July 1, 1979

Preliminary Assessment completed September 1, 1984

EPA collected groundwater samples August 1985

Site Inspection completed March 26, 1986 Proposed to the National Priorities List (NPl) June 24, 1988

Finalized on the NPl October 4, 1989

EPA and PRPs entered into an Administrative Order on Consent (AOC) to conduct the Remedial Investigation/Feasibility Study (RifFS) October 19, 1989

EPA issued Unilateral Administrative Order (UAO) to the PRPs for the removal of drums and investigation of the affect of metal concentrations on groundwater April 17, 1990

PRP removal action began April 30, 1990

EPA amended the April 1990 UAO December 19,1991

RifFS for OU-2 began April 7, 1992

PRP removal action completed May 11,1992

EPA removal action conducted June 8-25, 1992

RifFS for OU-1 completed September 22, 1992

Record of Decision (ROD) Signed for OU-1 September 22, 1992

Remedial Design/Remedial Action negotiations began October 27,1992

EPA and PRPs entered into an AOC to conduct groundwater monitoring July 13, 1993

RifFS for OU-2 completed, ROD and Close Out Report for OU-2 signed September 16, 1993

Quarterly groundwater monitoring began October 1993

Quarterly groundwater monitoring completed July 1994

Deep well MW-9 data submitted to FDEP. Vinyl chloride was discovered in groundwater above Florida's Maximum Contaminant level (MCl) . April 4, 1995

Due diligence sampling investigation is conducted May 1996

Vinyl chloride is detected at 3.1 ~g/l in deep well MW-10 (Florida MCl = 1 ~g/l) November 1997

Explanation of Significant Differences (ESD) Signed to add vinyl chloride as a Contaminant of Concern (COC) and require FYRs April 2, 1999

Coast to Coast began operations as building products distributor at the site 2000

Deleted from the NPl July 28, 2000

First Five-Year Review completed September 30, 2005

EPA conducted groundwater sampling June 27, 2007

Coast to Coast ceased operations at the site 2008 EPA issued Comfort/Status letter to Precision Metal Industries January 28, 2010 Phase II assessment completed for Cadiz Realty Company April 23, 2010 EPA issued Comfort/Status letter to Cadiz Realty Company May 14, 2010 Cadiz Realty Company purchased the site June 3, 2010


3.0 Background

3.1 Physical Characteristics

The Chemform, Inc. site is located in south Florida (Figure 1) at 1410 SW 8th Street in Pompano Beach, Broward County, Florida. The site occupies approximately four acres in a highly industrialized section of Broward County in the municipality of Pompano Beach. The site is bordered by SW 8th Street to the north, Precision Metal Industries to the east, an industrial access road to the south, and Seaboard Coastline railroad tracks to the west (Figure 2). The site is fenced and includes a 50,866 square-foot building. The site is located within the city limits of Pompano Beach, FL.

The Pompano Cypress Creek Canal lies an estimated 3,000 feet south of the site (Figure 3). The Canal, operated by the South Florida Water Management District, flows east toward the Biscayne Bay. Directly underlying the site is the Biscayne Aquifer, which supplies all potable water for Broward County and has been designated as a sole-source supply.

3.2 Land and Resource Use

The Chemform, Inc. site is in a commerciaVindustrial zoned area with no historical or existing residential land use. In June 2010, the site was purchased by Cadiz Realty Company from the prior owner, BARD Realty. The property will be used by The Sol Group, which operates a business across the street and wanted to expand their operations.

Broward County obtains its drinking water from underground deposits of limestone and sandstone called the Biscayne Aquifer. Drinking water is extracted from approximately 360 supply wells that pump water from 60 to 160 feet below the surface. The raw water is pumped to treatment plants where it is treated and disinfected to kill potentially harmful microbes, then it is distributed to the public. The Chemform, Inc. site receives its drinking water from Broward County.


Google maps A

marks the location of the ChemfoIID, Inc. site


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Figure 2: Site Location and Adjacent Properties

Disclaimer: "This map and any boundary lines within the map are approximate and subject to change. The map does not purport to be a survey. The map is for informational purposes only regarding EPA's response actions at the site, and is not intended for any other purpose."

Google Maps Yellow lines indicate approximate site boundaries


Figure 3: Site location and Surrounding Area, Pompano Beach, Florida

Google maps A

marks the location ofthc Chemform, Inc. site The Pompano Cypress Creek Canal is visible south of the site.


3.3 History of Contamination

Industrial operations at the site were initiated in 1967 by Kismet Engineering Company (KECO). The company primarily repaired and refurbished turbine engine components for the aerospace industry. It also was involved in manufacturing metal parts, which included conventional machine-making as well as manufacturing high-tech electro-chemical milling (ECM) machines. Manufacturing the ECM machines involved the use of electrolytic solutions and strong electric current.

From 1967 to 1985, numerous companies, including Chemform, Inc., conducted operations at the site which generated different wastes and spent materials. Metal milling and mechanical shaping operations required cutting-oils to lubricate and cool the components. Organic solvents were used for metal cleaning. Fiber glassing and painting processes also required the use of organic solvents for thinning and cleaning purposes. ECM machine wastewater and sanitary sewage were reportedly discharged to an on-site septic tank and leach field near the southwest comer of the building. Process wastewaters were discharged to an on-site open trench in the field on the west side of the building.

3.4 Initial Response

The site was regularly inspected by the Broward County Pollution Control Board (later, Broward County Environmental Quality Control Board) between 1974 and 1985 for compliance with County industrial waste regulations. On March 23, 1977, the County issued a Notice of Violation (NOV) to Chemform, Inc. for unlawfully discharging industrial waste on the site. The company performed cleanup operations over the next several months. From August 1977 through May 1985, Broward County found Chemform, Inc. to be in general compliance with regulatory requirements.

EPA conducted a Site Screening Investigation in August 1985 and discovered an outside drum rack in the paved shop yard west of the building, which contained 19 drums. Two of these drums were leaking. EPA also found approximately 47 other drums stored in the shop yard, along with four stainless steel tanks containing various quantities of oil and sludge. In July 1986, NUS Corporation, an EPA contractor, conducted a sampling investigation. After further screening, the site was included on the NPL on October 4, 1989. On October 19, 1989, four Potentially Responsible Parties (pRPS)l, entered into an Administrative Order by Consent (AOC) with EPA to conduct the Remedial Investigation/Feasibility Study (RIlFS).

On April 17, 1990, EPA issued a Unilateral Administrative Order (UAO), pursuant to Section 106 ofCERCLA, 42 U.S.C. Section 9606, to the PRPs, requiring them to address the removal of drums found on the site and to investigate the effect of metal concentrations in the groundwater. Westinghouse Environmental and Geotechnical Services Inc. was contracted by the PRPs to perform the activities required under the removal UAO. The PRPs commenced the removal action in October 1990, inventorying, characterizing, and disposing of over 450 waste and

I The four PRPs were Chemform, Inc. , New England Mutual Life Insurance Company, KMS Industries, and Smith International, Inc.


L...-___________________________ ________ ~ __ ~

product containers. Based upon the results of this initial action, EPA amended the UAO to also require the PRPs to remove contaminated soil that could potentially affect the groundwater. This second phase of the removal action began in July 1991 and was completed in early 1993.

3.5 Basis for Taking Action

The ROD for OU-l identified ten potential Contaminants of Concern in groundwater at the site. The maximum concentration detected was compared to drinking water standards in Table 13 of the ROD, which has been reproduced below as Table 2.

Table 2: Comparison of Groundwater Concentrations to Applicable or Relevant and Appropriate Requirements (ARARs) and To-Be-Considered Criteria (OU-1 ROD, Table 13)

Parameter

Maximum Concentration

detected (1J9/l)a

Maximum Contaminant level

(MCl) (lJg/l)

Maximum Contaminant level

Goal (MClG) (lJg/l)

Florida Drinking

Water Standards

(lJg/L)

Lifetime Health

Advisory (lJg/l)

Number of Values exceeding ARARor Criteriab

(lJg/l)

arsenic 55 50 NAc 50 NA 1/11 barium 39 2,000 2,000 1,000 2,000 0/10

chromium (VI) 1,300 100d 100 50 100 1/13 1 A-dichlorobenzene 2.8 75 75 75 75 0/7 methylene chloride 690 NA NA NA NA -naphthalene 76 NA NA NA 20 1/7

nickel 230 100e 100 NA 100 1/13 xylene 3.4 10,000 10,000 NA 10,000 0/17 zinc 34 5,000 NA 5,000 2,000 0/10

Notes:

a All concentrations, ARARs and criteria expressed in micrograms per liter (lJg/l)

b Number of values exceeding ARAR or criterion over total number of samples

C NA - No standard or criterion available

d This value is for unspeciated chromium

e Secondary Mel

The 1999 ESD added vinyl chloride as a COC for the site. Vinyl chloride was detected in groundwater samples from monitoring well MW-I0 at 3.1 I-lglL. The Federal and State drinking water standards for vinyl chloride are 2 and 1 I-lgIL, respectively.

The ROD for OU-2 stated that due to the extensive removal actions, no further Superfund action was needed for soils at the site. The Responsiveness Summary stated that the Risk Assessment indicated that risks to both industrial workers and future residents were within acceptable risk ranges and therefore, no institutional controls were necessary.


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4.0 Remedial Actions

In accordance with CERCLA and the NCP, the overriding goals for any remedial action are protection of human health and the environment and compliance with ARARs. A number of remedial alternatives were considered for the site, and final selection was made based on an evaluation of each alternative against nine evaluation criteria that are specified in Section 300.430(f)(5)(i) of the NCP. The nine criteria include:

1. Overall Protectiveness of Human Health and the Environment 2. Compliance with ARARs 3. Long-Term Effectiveness and Permanence 4. Reduction of Toxicity, Mobility or Volume of Contaminants through Treatment 5. Short-term Effectiveness 6. Implementability 7. Cost 8. State Acceptance 9. Community Acceptance

4.1 Remedy Selection

The Chernform, Inc site was divided into two Operable Units (OUs). Operable Unit 1 (OU-l) addresses groundwater contamination. Operable Unit 2 (OU-2) addresses site soils. There is a Record of Decision (ROD) for each operable unit.

OU-1 The OU-1 ROD was signed on September 22,1992, and documented a selected remedy of "No Action with Monitoring" for groundwater. This remedy was based on the Remedial Investigation results and Risk Assessment, which indicated that for the identified COCs no remediation of groundwater was needed at the site. It was expected that the removal of soil and waste in 1992 would eliminate the potential for inorganic constituents to leach from surface and subsurface soils into groundwater. The OU-l ROD required quarterly groundwater monitoring of the COCs for one year. The COCs identified in the OU-l ROD were selected based upon their toxicological properties, concentrations, and frequency of occurrence during the OU-l Remedial Investigation.

On April 2, 1999, EPA approved an Explanation of Significant Differences (ESD) for OU-I. The ESD added a new COC to the remedy (vinyl chloride), required the conductance ofFYRs, and required additional sampling as EPA deemed necessary. It also documented the existence of public water supply lines in the area, as well as State and Local groundwater use regulations which prevent a future exposure route from occurring.

Although Remedial Action Objectives (RAOs) were not explicitly stated in the 1992 OU-1 ROD or the 1999 ESD, it can be inferred that the RAO was to ensure that the remedy, "No Further Action with Monitoring", remains protective of human health and the environment by requiring FYRs.


OU-2 The September 16, 1993, OU-2 ROD selected remedy for soil was "No Further Action". The decision in the OU-2 ROD was based on prior soil excavation and removal of approximately 3,000 cubic yards of contaminated material. The ROD stated that the risks posed by remaining soil contamination were within EPA's acceptable risk range. Therefore, no RAOs were identified in this ROD.

4.2 Remedy Implementation

OU-I Following issuance of the OU-l ROD, the required post-ROD quarterly groundwater monitoring was initiated. The PRPs conducted the work under an AOC with EPA. To complement the six permanent monitoring wells used during the RI (MW -1 through MW -6), three more permanent monitoring wells were installed (MW -7, MW-8, and MW -9). MW-7 and MW-8 were located south of the building and screened in the surficial aquifer at depths from 2 feet to 12 feet below land surface (bls). The third monitoring well, MW-9, is also located south of the building and screened deeper, at a depth from 15 feet to 25 feet bls (Figure 4). All nine permanent monitoring wells were sampled quarterly from October 1993 to July 1994. The samples were collected in October 1993, January 1994, April 1994, and July 1994.

After the fourth groundwater monitoring report, FDEP requested a review of the data from MW-9 for concentrations of trichloroethene (TCE) and other related volatile organic compounds (VOCs). The purpose of this review was to examine any potential effects of the former, on-site septic tank system that had been located at the southwest comer of the building. The septic tank system was excavated during June 1992 as part of the soil OU-2 removal action. Testing of the tank's contents showed the presence ofTCE and related organic compounds. With a general surficial groundwater flow direction to the east, MW-9 lies approximately 40 feet to 50 feet down gradient from the septic system area. Since TCE and some related compounds have a density greater than water and only shallow (screened from 2 feet to 12 feet) monitoring wells were constructed down gradient from the septic system area for the RI, the review of analytical data from a deeper, down gradient well (MW-9) was necessary to establish whether or not such contaminants were present.

Following the quarterly groundwater sampling required by the OU-l ROD, the FDEP produced a list of five TCE related compounds that were not originally included as COCs in the OU-1 ROD. These compounds were tetrachloroethene, trichloroethene, 1, I-dichloroethene, cis/trans-I,2dichloroethene and vinyl chloride. One factor as to why TCE related compounds were not detected in significant concentrations during the RI, and subsequently not included as COCs in the OU-l ROD, was that there were only two monitoring wells (MW-5 and MW-6) in the area down gradient of the septic system and they were shallow wells. The installation of the deeper well, MW-9, was a post-ROD requirement. Therefore, the greatest potential for detecting the presence ofthe five TCE related compounds would be to evaluate the data sets from MW-9.


MW-9 data was submitted to FDEP on April 4, 1995. A review of the four data sets from MW9 for the TCE-related compounds did not reveal either tetrachloroethene or trichloroethene (the "parent compounds") above quantitation limits. Detection of two breakdown products from these compounds, cisltrans-1,2-dichloroethene and vinyl chloride, appeared in the last two quarterly sampling rounds. The concentrations of cis/trans-1 ,2-dicholoroethene, detected in the last two sampling rounds (2.8 Ilg/L and 3.3 Ilg/L respectively), were below the Florida MCL of70 Ilg/L. However, vinyl chloride was detected at 11 Ilg/L in each of the last two sampling rounds, which is above the Florida MCL of I IlgIL. It should be noted that the quantitative limits for all five compounds were lower in the last two sampling rounds (April] 994 and July 1994) than in the first two sampling rounds (October 1993 and January 1994). The laboratory explaincd that quantitative limits for the first two rounds were the standard values required by EPA Method 8240. However, prior to the last two sampling rounds, the lab changed its procedures to achieve lower quantitative limits consistent with recently revised Florida drinking water standards. Since the quantitative limit for vinyl chloride was 10 IlglL during the first two sampling rounds, this raised the question as to whether vinyl chloride was present at a level lower than 10 Ilg/L but still higher than the MCL. The lab re-verified that vinyl chloride was not detected at any concentration during the first two sampling rounds.

As part of a due diligence investigation in May 1996, samples were collected at various depths from two new locations south of the Chemform building using direct push technology. At the first location, a groundwater sample was pulled from 25 feet, 45 feet, 55 feet, and 65 feet bls. The second location collected a groundwater sample at 20 feet, 40 feet, and 63 feet bls.


Samples were also collected from MW-6 and MW-9. From all the samples collected, one TCE concentration of 5.9 IlgiL exceeded the MCL of3.0 Ilg/L at a depth of 55 feet bls. Vinyl chloride exceeded the MCL in 7 out ofthe 8 (Plus one duplicate sample) samples collected, with concentrations ranging from 0.73 Ilg/L to 29 Ilg/L. The highest concentration of29 Ilg/L was reported for the sample collected at 63 feet bls. The sampling results from the permanent and relatively shallow MW-6 and MW-9 did not reveal any concentrations above MCLs. The sampling results of the investigation were documented in a June 13, 1996, report Groundwater Sampling Oversight, Chemform Site.

A tenth permanent monitoring well (MW -10) was installed in the southeast corner of the property and screened at a depth of 55 feet to 65 feet bls in a location down gradient of the former septic system. In April 1997, a sample collected from MW-10 revealed vinyl chloride at 2.0 Ilg/L. MW-9 was also sampled at the time with all detected concentrations being below MCLs. In November 1997, are-sampling ofMW-10 showed a vinyl chloride concentration of 3.1 Ilg/L. All other detections were found to be below MCLs.

The main concern for the groundwater contamination is its potential exposure to the local population through potable water wells. Currently, conditions at the site remain protective of human health through the implementation of state and local regulations that prevent the installation of potable water wells in the area of Broward County on which the site is located. This site lies in a delineated area already designated by the FDEP to have known groundwater contamination. See Florida Administrative Code ("F.A.C.") 62-524. To the extent practicable, potable wells must be located outside of all such delineated areas of groundwater contamination. See F.A.C. 62-524(2)(i). The site and surrounding areas are currently serviced with public water supply lines, and under the terms ofF.A.C. 62-524.700(2) no new potable water wells may be installed in delineated areas where public water supply lines are accessible within 500 feet of the property boundary.

At the local level, the Broward County Health Department (BCHD) has responsibility for issuing well construction permits. The department requires that water quality be established before permits may be issued. Also, a BCHD ordinance precludes installation of a new potable water well where the property abuts a water main owned by a public or private water utility system. The Chemform, Inc. site and surrounding area are serviced by public water supply lines. These issues are addressed in Broward County Code sections 34-35 through 34-49.

The 1999 ESD required conducting FYRs until future groundwater sampling results indicate that hazardous substances, pollutants, or contaminants are no longer on-site above levels that allow for unlimited use and unrestricted exposure. The first FYR was completed in September 2005. On June 27, 2007, EPA visited the site and collected a groundwater sample from the only monitoring well that could be found (MW-9). In April 2010, Land Science Environmental Consultants and Engineers, a consultant of Cadiz Realty Company, conducted a Phase II investigation of the site and collected groundwater samples from temporary wells installed at locations and depths recommended by EPA. Results of these sampling events are described in Section 6.4, Data Review.


OU-2 The OU-2 ROD did not require any further action. However, the PRPs excavated additional arsenic contaminated soil at the site in 1994 to meet FDEP's risk management goal of lxlO-6.

4.3 Operation and Maintenance (O&M)

The OU-1 ROD only required monitoring for one year at an estimated cost of$104,000. The ESD stated that additional sampling would be conducted as EPA determined necessary. No O&M activities were required beyond these items. The only costs expended during the past five years were related to the collection of groundwater samples in 2007 and conducting the FYR.

The OU-2 ROD required no further action. Therefore, no O&M costs have been incurred for OU-2.

5.0 Progress Since the Last Five-Year Review

The protectiveness statement from the 2005 FYR for the Chemform, Inc. site stated the following:

It is the finding ofthis Five-Year Review that existing institutional controls in the form of state and local regulations prevent the construction ofgroundwater wells which might compromise the protectiveness ofhuman health and the environment.

Regarding the uncertain status of the ten (10) monitoring wells. no surface contamination was seen to exist on the site, and current site activities would not likely create a contaminant spill which might enter a defective monitoring well, ifany do exist. No other information was introduced during this first Five- Year Review that would affect the protectiveness ofthe remedy.

In conclusion, we believe that the remedy as set forth in the OUi ROD, and as modified by the Explanation ofSignificant Differences, remains protective ofhuman health and the environment. This remedy satisfies CERCLA Section 12i.

The 2005 FYR included three issues and recommendations (Table 3). Each recommendation and the current status is discussed on the following pages.


.Table 3 P rogress on Recommendati f th 2005 FYR. ons rom e

Section Recommendations Party

Responsible Milestone

Date Action Taken and

Outcome Date of Action

5.1 Continue Five-Year Reviews

EPA September

2010 Conducted 20a

FYR September

2010

5.2 Determine Status

of Monitoring Wells

EPA March 31,

2006

Only one of the ten wells could be

found.

June 27, 2007

Groundwater was

5.3

Establish Exit Strategy and

Sample Groundwater

EPA January 1,

2010

sampled in June 2007 and April 2010. EPA has drafted an Exit

June 2007 And

April 2010

Strategy.

5.1 Continue Five-Year Reviews

The 2005 FYR stated the following as the Issue associated with this recommendation: a. Continue a Five-Year Review policy to verify that institutional controls on existing groundwater use continue to provide long-term protectiveness to human heath and the environment. Five-Year Reviews shall be performed in accordance with the Explanation ofSignificant Differences dated April 2, 1999 until future groundwater sampling results indicate that hazardous substances, pollutants, or contaminants are no longer on-site above levels that allow for unlimited use and unrestricted exposure.

This document is the second FYR for the site. Because recent groundwater sampling data indicates that hazardous substances remain in groundwater at concentrations that do not allow for unlimited use and unrestricted exposure, future FYRs are required.

5.2 Determine Status of Monitoring Wells

The 2005 FYR stated the following as the Issue associated with this recommendation: b. Status ofthe ten monitoring wells must be determined. EPA and/or the PRPs should determine which, ifany, ofthe monitoring wells have been properly abandoned. Specific documentation may be recorded with the Broward County Health Department as part ofits well permitting program. Otherwise, supporting documentation may be found in older reports and correspondence. In particular, MW-4, MW-9, and MW-JO, all ofwhich may extend below the surficial aquifer, must be reached and checkedfor proper structural integrity, as specified in the well construction details. Abandonment ofpermanent monitoring wells must conform with the "plugging" requirements described in FDEP Chapter 62532.500(4), (F.A .C), and in SFWMD Rule 40E-3.531 (3) for well abandonment.

On June 27, 2007, EPA visited the site and attempted to locate all of the monitoring wells. A Schondstedt Cable Locator® was used to attempt to fmd the monitoring wells. Only MW-9 was found. In 2010, EPA visited the site and could only locate MW-9.


'-------------------------------------

5.3 Establish Exit Strategy and Sample Groundwater

The 2005 FYR stated the following as the Issue associated with this recommendation: c. To terminate the Five-Year Review Process for the Chemform site, groundwater sampling must demonstrate that the site is free ofcontaminants which would prevent unrestricted use of the site. To satisfy the recommended follow-up action (b., above), EPA and the PRPs must determine whether or not the structural integrity ofMW-J 0 would permit future sampling. Ifnot, MW-J 0 should be abandoned in the near future along with any other wells requiring such action. IfMW-J 0 can be sampled, EPA, FDEP, and the P RPs should work to establish and execute a sampling plan and exit strategy which would permitfuture sampling to stop.

On June 27,2007, EPA visited the site and collected a groundwater sample from well MW-9, the only well that could be located (Figure 5). The sample was analyzed for VOCs. All results were below MCL values.

o 125 250 375 SOOStaUon Site B01.I'Idary ."~~""~"""~======~"""F"t

In January 2010, Ben Bentkowski of EPA Region 4's Technical Services Section visited the site. He could only find one well, MW-9. After his visit to the site and review of the existing groundwater data, Mr. Bentkowski prepared a draft Exit Strategy. Mr. Bentkowski recommended using direct push technology to collect groundwater samples from four locations on the property at several different depths (one up-gradient location and three along the property line near the former MW-lO). In April 2010, Land Science


L...-_____________________________________

Environmental Consultants and Engineers, a consultant of Cadiz Realty Company, conducted a Phase II investigation of the site and collected groundwater samples from four temporary wells installed at locations and depths recommended by EPA (Figure 6). Samples were collected from 10 feet bls, 30 feet bls, and 60 feet bls and were analyzed for VOCs, arsenic and chromium. Contaminants were only detected in the two locations that are the closest to former MW -10. The results indicated:

• Arsenic was detected in one well (TMW-l(30)) at a concentration of 129 Ilg/L, which exceeds both the ROD cleanup goal (50 Ilg/L) as well as the current MCL (10 Ilg/L).

• Chromium was detected in two wells (TMW-l(30) and TMW-2(30)) at concentrations of73 and 76 Ilg/L, respectively, which exceed the ROD cleanup goal (50 Ilg/L), but is less than the current MCL (100 Ilg/L).

• Cis-l ,2-dichloroethene was detected in three samples, with a maximum concentration of3.61 Ilg/L, which is well below the current MCL (70 IlglL)

• Methylene chloride was detected in one sample (TMW-2(10)) at 4.56 IlglL, which is below the current Florida MCL (5 Ilg/L).

• Vinyl Chloride was detected in two samples (TMW-l(60) and TMW-2(60)) at concentrations of 16.1 and 14.7 IlglL, respectively, which exceed the Federal MCL (2 IlglL) and the Florida MCL (1llglL) .

After reviewing the April 2010 groundwater data, Mr. Bentkowski revised the draft Exit Strategy. The draft document is still under review by EPA and FDEP. Figure 7 includes Mr. Bentkowski's proposed sampling locations.


Figure 6: April 2010 Sample Locations

HiQXt.t mt ~N' rIJ lT~ ~illn. tOIrt~ -.m.l Ct.uno

SIllTI!'.I£Sf 9TH SfRttl'

PIID.£tT SITE BUILDING <F'MI4!:J1 CIlOt"llRH F'ACILfTY>

••••• + ~l\ ••••• J" \4-tlljl

scu.a( _ 1M I r SJ' _

~~------------~ r-----------------Ltll'IT-IlI\lVSTRIAL FACILln

'6~ ,"hwn'orm f"odKy

P'ao"np.o .~.~~_


Figure 7: Proposed Groundwater Sampling Locations

o 70 140 280 420 560

N

A Chemform NPL Site Pompano Beach. FL

Proposed Ground Water Sampling Locations

Legend: Indicates proposed monitoring well1ocation


6.0 Five-Year Review Process

6.1 Administrative Components

EPA Region 4 initiated the FYR in November 2009 and scheduled its completion for September 2010. The review team was led by Samantha Urquhart-Foster of EPA, Remedial Project Manager (RPM) for the Chemform, Inc. site. The review team consisted of the following people:

• Samantha Urquhart-Foster, RPM • Greg Luetscher, EPA Attorne/ • Brian Thompson, EPA Attorney • Kyle Bryant, Community Involvement Coordinator • Ofia Hodoh, Human Health Risk Assessor • Ben Bentkowski, Hydrogeologist • Kelsey Helton, FDEP Project Manager

On January 5, 2010, EPA held a scoping meeting with the review team to discuss the site and items of interest as they related to the protectiveness of the remedy currently in place. EPA established a review schedule that consisted of the following:

• Community notification; • Document review; • Data collection and review; • Site inspection; • Local interviews; and • FYR Report development and review.

6.2 Community Involvement

On April 20, 2010, the EPA RPM visited the Broward County Main Library, located at 100 S. Andrews Avenue in Fort Lauderdale, Florida. Ten binders of site-related documents were found on the fifth floor in section EP 1.2/2:C 42/. The most recent document in the set was the 2005 FYR.

On April 25, 20 10, EPA published a public notice in the Sun-Sentinel newspaper announcing the commencement of the FYR process for the Chemform, Inc. site, providing RPM and Community Involvement Coordinator's contact information, and inviting community participation. The press notice is available in Appendix A. No one has contacted EPA as a result of this advertisement.

EPA will make the FYR report available to the public once it has been finalized. EPA will send a copy of this document to the designated public repository: Broward County Main Library, located at 100 S. Andrews Ave, NE, in Fort Lauderdale, Florida. Upon

2 Greg Luetscher was the EPA attorney for the Chemfonn Site for many years. During the middle of the FYR process, he transferred to the RCRA section and Brian Thompson took over as the EPA attorney for the Site.


completion of the 2010 FYR, EPA will place a public notice in the Sun-Sentinel newspaper to announce the availability of the 2010 FYR report in the site document repository.

6.3 Document Review

This FYR included a review of relevant, site-related documents including the RODs, ESD, remedial action reports, the previous FYR, and groundwater data. A complete list of the documents reviewed is included in Appendix B.

ARARs Review

Section 121 (d)(2)(A) ofCERCLA specifies that Superfund remedial actions (RAs) must meet any federal standards, requirements, criteria, or limitations that are determincd to be legally ARARs. Applicable or Relevant and Appropriate Requirements are those standards, criteria, or limitations promulgated under federal or state law that specifically address a hazardous substance, pollutant, contaminant, action, location, or other circumstance at a CERCLA site. To-Be-Considered criteria (TBCs) are nonpromulgated advisories and guidance that are not legally binding, but should be considered in determining the necessary level of cleanup for protection of human health or the environment. While TBCs do not have the status of ARARs, EPA's approach to determining if a RA is protective of human health and the environment involves consideration of TBCs along with ARARs. Chemical-specific ARARs are specific numerical quantity restrictions on individually listed contaminants in specific media. Examples of chemical-specific ARARs include the MCLs specified under the Safe Drinking Water Act (SDWA) as well as the ambient water quality criteria that are enumerated under the Clean Water Act. Because there are usually numerous contaminants of potential concern for any site, various numerical quantity requirements can be ARARs.

The final remedy selected for this site was designed to meet or exceed all chemicalspecific ARARs and meet location- and action-specific ARARs. The 1993 OU-2 ROD did not include ARARs for the soil remedy of No Further Action. Table 4 includes the chemical-specific ARARs identified in the selected remedy within the 1992 OU-l ROD and subsequent ESD for the groundwater at this site and considered for this FYR for continued groundwater monitoring. The 1992 OU-l ROD did not specify which ARARs or TBCs should be used as the remediation goal. The values in the second column of Table 4 are the more stringent ofthe values listed in the 1992 OU-l ROD for either the Federal or State drinking water standards. Current Florida drinking water standards are the same as current federal drinking water standards except for the Florida standards for nickel and vinyl chloride, which are more stringent than federal standards. The Florida standard for nickel is a secondary standard; there is no federal standard for nickel. Current ARARs are the same as the OU-l ROD and ESD standards with the exception of arsenic, barium and chromium. The current arsenic standard is more stringent than the OU-1 ROD standards. The current standards for barium and chromium are less stringent than the OU-I ROD standards.


T bl 4 S ummaryofGrOUDdwater ARARChanges ~ a e : or OU 1

Contaminants of Concern

1992 ROD and 1999 ESO

ARARs (~g/l)1

Current Federal

MCl (~g/l)2

Current Florida MCl

(lJg/l)3 ARARs changed?

arsenic 50a 10 10 Yes, more stringent

barium 1,000b 2,000 2,000 Yes, less stringent

chromium (VI) 50b 100 100 Yes, less stringent

1A-dichlorobenzene 75a 75 75 No

methylene chloride NAc NA NA No naphthalene NA NA NA No

nickel 100d NA 100 No

xylene 10,0008 10,000 10,000 No

vinyl chloride 11 2 1 No

zinc 5,000a 5,000d 5,000d No

Notes:

1 The 1992 ROD did not specify which ARAR or To-Be-Considered should be used as the Remediation Goal. Notes are included for each contaminant to indicate which value is being used for comparison in this table.

2 Federal Drinking Water Standards can be found at: http://www.epa.gov/safewater/contaminants/index.html

3 Florida Drinking Water Standards can be found at: http://www.dep.state.fi .us/water/drinkingwaterlstandard.htm

a State and Federal MCl value at the time of the 1992 ROD

b Florida Mel (which was more conservative than the Federal MCl)

C NA _ No standard or criterion available

d Secondary MCl.

• Federal MCL. No Florida Mel was available at the time of the ROD.

f Vinyl chloride was added as a COC in the 1999 ESD. Florida Mel was identified as the ARAR in the ESD.

6.4 Data Review

6.4.1 Soil

The OU-2 ROD for soil stated that No Further Action was required based on the previous removal actions. The ROD also did not require FYRs since the prior removal actions achieved residential cleanup standards. No soil samples have been collected or analyzed in the past five years. Therefore, EPA did not review historical soil data for this FYR.


6.4.2 Groundwater

EP A reviewed groundwater data that has been collected between 1990 and the present during this FYR. A summary of all groundwater data is included in Appendix C. In the most recent sampling event, April 2010, only three COCs had concentrations that exceeded either the OU -1 ROD standard, ESD standard, or current ARARs (if more stringent): arsenic, chromium, and vinyl chloride. It is difficult to determine if there are trends for this site because of missing wells and a large gap of time between sampling events post-RA. The concentration of arsenic detected in April 20 10, was the highest in the site's history, but was only detected above the current ARAR in one of twelve samples. In April 2010, chromium was detected above the ROD standard in two of the twelve samples, but at concentrations less than current ARARs and significantly less than during the RI. In April 2010, vinyl chloride was detected above the ESD standard in two of the twelve samples, at concentrations greater than the prior sampling event (1997), but less than the maximum historical value. All of the detected concentrations, with the exception of arsenic in one sample, fall within Florida's Natural Attenuation Default Concentrations. A summary of results obtained during the past five years are included in Table 5. A discussion of each COC's historical sampling results follows.

6.4.2.1 Arsenic

During the quarterly sampling required in the remedial action (1993-1994), all arsenic results were below the OU-I ROD standard. However, both the Florida and Federal Drinking Water Standards for arsenic have decreased from 50 ~g/L to 10 ~glL since the time the OU-1 ROD was written. Arsenic concentrations in most wells were below the more stringent standard, with the following exceptions. • MW-3 had a detection of arsenic at 12 ~g/L during the RI, but subsequent

sampling results were below 1 0 ~g/L. • MW-5 had a detection of arsenic at 14 ~glL during the RI, but subsequent

sampling results were below 10 ~glL. • MW-6 had arsenic concentrations as high as 96 ~glL during the RI, but during

the quarterly RA monitoring, results ranged from 18 to 29 ~g/L. • TMW-1 at 30 feet bls had a detection of arsenic at 129 ~g/L in April 2010.

This sample location is near the former MW-6, and is a proposed location for future monitoring.


Table 5: Analytical Data Summary for Wells sampled during 2007 and 2010

Depth (feet

below 1,4-Dichloro cis-1,2-dichloro methylene tetrachloro trichloro vinyl Well # land Date Arsenic Barium Chromium Nickel Zinc benzene ethene chloride naphthalene ethene ethylene chloride xylene

surfacel (lJg/L) (lJg/l) (lJg/l) (lJg/l) (Ilg/l ) (Ilg/l ) (Ilg/l ) (Ilg/l ) (Ilg/l ) (Ilgll ) (Ilg/l ) (Ilg/l) (Ilg/l )

Fed MCl": 2010 10 2,000 100 NS 5,000' 75 70 NS NS 5 5 2 10,000 Fl MCl': 2010 10 2,000 100 100' NS 75 70 5 NS 3 3 1 10,000

Fl NADc": 2010 100 20,000 1,000 1,000 NS 7,500 700 500 140 300 300 100 100,000 RODd

: 199211999 50 1,000 50 100 5,000 75 NS NS 20 NS NS 1 10,000 MW-9 25 Oct-93 <10 <10 <10 <40 <20 NI <5 NI Nt <5 <5 <10 Nt MW-9 25 Jan-94 <10 <10 <10 <40 <20 Nt <5 Nt Nt <5 <5 <10 NI MW-9 25 Apr-94 <10 <10 <10 Nt Nt Nt 3.3 Nt Nt <1 <1 11 Nt MW-9 25 Jut-94 <10 <10 <10 Nt <20 Nt 2.8 Nt Nt <1 <1 11 Nt MW-9 25 May-96 Nt NI Nt Nt Nt SQl <1 SQl SQl Nt SQl 0.82 SQl MW-9 25 Apr-97 Nt NI Nt Nt Nt Nt <1 Nt NI Nt Nt <1 Nt MW-9 25 Nov-97 NA NA NA NA NA NA NA NA NA NA NA NA NA MW-9 25 Jun-07 NA NA NA NA NA <0.5 0.18 J <0.5 NA <0.5 <0.5 <0.5 <1

ITMW-1(10) I 10 Apr-101 9 NA 351 NAI NAI <0.39 <0.17 <1.5 NA <0.421 <0.341 <0.0791 NAI ITMW-1 (30) I 30 Apr-101 1291 NA 73 1 NAI NAI <0.39 <0.17 <1.5 NA <0.421 <0.341 <0.0791 NAI I TMW-1(60) I 60 Apr-101 <0.7 NA <1.11 NAI NAI <0.39 3.51 <1.5 NA <0.421 <0.341 16.11 NAI

ITMW-2(1011 10 Apr-101 <0.7 NA 91 NAI NAI <0.39 <0.17 4.56 NA <0.421 <0.341 <0.0791 NAJ ITMW-2(30) I 30 Apr-101 2 NA 761 NAI NAI <0.39 <0.17 <1.51 NA <0.421 <0.341 <0.0791 NAI ITMW-2(60) I 60 Apr-101 <0.7 NA <1.11 NAI NAI <0.39 3.61 <1.5 NA <0.421 <0.341 14.71 NAI

ITMW-3(10) I 10 Apr-101 <0.7 NA 61 NAI NAI <0.391 <0.17 <1.51 NA <0.421 <0.341 <0.079 1 NAI ITMW-3(3011 30 Apr-101 <0.7 NA 71 NAI NAI <0.391 <0.1 7 <1.51 NA <0.421 <0.341 <0.079 1 NAI ITMW-3(60) I 60 Apr-101 <0.7 NA 51 NAI NAI <0.391 <0.17 <1.51 NA <0.421 <0.341 <0.079 1 NAI

ITMW-4(1011 10 Apr-101 <0.7 NA 71 NAI NAI <0.39 <0.17 <1.5 NA <0.421 <0.341 <0.0791 NAJ ITMW-4(3011 30 Apr-101 <0.7 NA 91 NAI NAI <0.39 <0.17 <1.5 NA <0.421 <0.341 <0.0791 NAI ITMW-4(6011 60 Apr-101 5 NA 51 NAI NAI <0.391 0.82 <1.5 NA <0.421 <0.341 <0.0791 NAJ

Notes:

In 2007, only MW-9 could be located. Therefore, it was the only wel l sampled during that time frame. Historical values are reported here for reference. In 2010, temporary wells were installed at four locations and sampled at three depths. TMW-1 is localed near lI1e hislorical well MW-l0, which could not be located in either 2007 or 2010 .

• Federal Drinking Water Standards, Maximum Contaminant Levels. can be found at: htlp:/lwww.epa.gov/safewater/contaminantsiindex.html

b Florida Drinking Water Standards can be found at: http://www.dep.state.fl.uslwater/drinkmgwaterlstandard.htm

, Florida Natural Attenuation Default Concentrations can be found at: http://www.dep.state.fl.uslwaste/quick_topics/rulesidocumentsl62-7771TableVNaturalAttenuationDefaultConcs4-17-05.pdf

d The ROD did not spedfy a remediation goal. It presented several ARARs for comparison. Values in this row represent the most conservative value in Table 13 of the ROD, NS for contaminants that weren't listed in the ROD, and the value

• Secondary MCL

. hllghtJbolcl font indicates concentration exceeds a cu....nt ARAil"'-___

Yellow highlight/bold font indicates concentration exceeds the ROO standard, but is less than the current ARAR.

NA = Not Analyzed

NI = No Information was available in the summary tables of the reports reviewed

NS = Not Specified

Bal = Below Quantification Limit. Quantitation limit was not induded in the summary tables of reports reviewed.

6.4.2.2 Barium

During the RI, the maximum barium concentration in groundwater was 440 Ilg/L (MW-4), which was less than the Florida Drinking Water Standard of 1,000 Ilg/L. However, it was retained as a COC in the OU-1 ROD. Concentrations decreased during the quarterly sampling required in the remedial action (1993-1994) to a maximum concentration of 24 Ilg/L (MW -6). Barium was not analyzed during the April 2010 sampling event.

6.4.2.3 Chromium

During the RI, chromium concentrations were as high as 1,400 Ilg/L (MW-5) in groundwater. Results decreased during the quarterly sampling required in the remedial action (1993-1994) to below the OU-l ROD standard (50 Ilg/L), which is below the current MCL (100 Ilg/L). During the April 2010 sampling event, two samples had concentrations which exceeded the OU-l ROD standard, but were below the current MCL. These are both at locations which are proposed for future monitoring. • TMW-1 at 30 feet bls had a detection of chromium at 73 Ilg/L. • TMW-2 at 30 feet bls had a detection of chromium at 76 IlglL.

6.4.2.4 Nickel

During the RI, nickel concentrations were as high as 1,200 Ilg/L in groundwater. Two wells had concentrations which exceeded the OU-1 ROD standard (100 Ilg/L): MW-5 and MW-6. Results decreased during the quarterly sampling required in the remedial action (1993-1994) to below the OU-l ROD standard. Nickel was not analyzed during the April 2010 sampling event.

6.4.2.5 Zinc

During the RI, the maximum zinc concentration in groundwater was 270 IlglL (MW-6), which was less than the Secondary MCL of 5,000 Ilg/L. However, it was retained as a COC in the OU-l ROD. Concentrations decreased during the quarterly sampling required in the remedial action (1993-1994) to a maximum concentration of32 Ilg/L (MW-2). Zinc was not analyzed during the April 2010 sampling event.

6.4.2.6 1,4-Dichlorobenzene

During the RI, the maximum 1,4-dichlorobenzene concentration in groundwater was 2.8 Ilg/L (MW-3), which was less than the State and Federal MCL of75 Ilg/L. However, it was retained as a COC in the OU-l ROD. 1,4-dichlorobenzene was not detected during the quarterly RA sampling, nor during the April 2010 sampling event.


6.4.2.7 Naphthalene

During the RI, naphthalene was only detected in one groundwater sample (76 f..lg/L in TW-1). There were no State or Federal MCL values for naphthalene at the time of the OU-1 ROD, nor are there today. It has not been analyzed for in subsequent sampling events.

6.4.2.8 Xylene

During the RI, xylene was only detected in one groundwater sample (3.4 f..lg/L in TW-1), which is below the Federal and State MCL of 10,000 f..lglL. It has not been analyzed for in subsequent sampling events.

6.4.2.9 cis-1 ,2-Dichloroethene

Cis-1,2-Dichloroethene was not listed as a COC in the OU-1 ROD. However, upon request by FDEP, samples were analyzed for this contaminant during the post-quarterly sampling event. The maximum concentration ofcis-l,2dichloroethene in groundwater was SO f..lg/L (MW-10), which was less than the State and Federal MCL of70 f..lg/L. During the April 2010 sampling event, the maximum concentration detected was 3.61 f..lg/L.

6.4.2.10 Tetrachloroethene

Tetrachloroethene was not listed as a COC in the OU-l ROD. However, upon request by FDEP, samples were analyzed for this contaminant during the postquarterly sampling event. Tetrachloroethene was not detected during the quarterly RA sampling, nor during the April 2010 sampling event.

6.4.2.11 Trichloroethylene

Trichloroethylene was not listed as a COC in the OU-l ROD. However, upon request by FDEP, samples were analyzed for this contaminant during the postquarterly sampling event. Trichloroethylene was detected in one sample (S.9 f..lg/L in DPl(SS)) during the post-quarterly sampling in 1996, which exceeded the State MCL (3 f..lglL). Trichloroethylene was not detected during the during the April 20 I 0 sampling event.

6.4.2.12 Vinyl Chloride

Vinyl chloride was not listed as a COC in the OU-1 ROD. However, upon request by FDEP, samples were analyzed for this contaminant during the postquarterly sampling event. Vinyl chloride was detected in several samples during the post-quarterly sampling in 1996, with a maximum concentration of 29 f..lglL, which exceeded the State MCL (1 f..lglL). Vinyl chloride was added as a COC in the ESD. During the April 2010 sampling event, two samples had concentrations


which exceeded the ESD standard (1 )lglL). These are both at locations which are proposed for future monitoring. • TMW-1 at 60 feet bls had a detection of vinyl chloride at 16.1 )lg/L. • TMW-2 at 60 feet bls had a detection of vinyl chloride at 14.7 Ilg/L.

6.5 Site Inspection

On April 20, 2010, EPA RPM Samantha Urquhart-Foster, visited the Broward County Public Library, Main Library, located at 100 S. Andrews Avenue, in Fort Lauderdale, FL. Ten binders of documents related to the Chemform site were found on the fifth floor, in the Reference Section. The ten binders were found in Section EP 1.2/2:C 42/ and included the following items:

• Removal Site Administrative Record, January 1991 • OU-2 Administrative Record, Index, September 1993 • OU-2 Administrative Record, Volume 1, September 1993 • OU-2 Administrative Record, Volume 2, September 1993 • OU-2 Administrative Record, Volume 3, September 1993 • OU-2 Administrative Record, Volume 4, September 1993 • Explanation of Significant Differences Administrative Record, Volume 1, April

1999 • Explanation of Significant Differences Administrative Record, Volume 2, April

1999 • Deletion Docket, July 2000 • Chemforrn Five-Year Review, September 2005

The Site Inspection took place on April 21, 2010, at 9 a. m. Attendees included the following people:

• Samantha Urquhart-Foster, EPA, RPM • Richard E. Marcus, co-owner (at the time of the Site Inspectioni • Peter Daniels, co-owner (at the time of the Site Inspection) • Greg Wilson, President of PMI (neighboring business)

After introductions, the team walked around the property to attempt to locate monitoring wells. Only one well, MW-9, could be found. It was located beneath a steel cover plate, which was bolted closed. The cover plate clearly identified it as a monitoring well and warns "no dumping". The property was fenced with pad-locked gates. The site inspection was documented in the FYR Site Inspection Checklist, which is located in Appendix D. Photographs from the Site Inspection are included in Appendix E. Interview Documentation is included in Appendix F.

Table 6 lists the ICs associated with areas of interest at the site.

3 Richard Marcus and Peter Daniels were co-owners of the property at the time of the Site Inspection. In June 2010, they sold the property to Cadiz Realty Company.


Table 6: Ie Summary Table

Media ICs

Needed

lCs CaUed for in the Decision

Documents

Impacted Parcel(s)

IC Objective

Instrument in Place

Notes

Ground Water

Yes Yes*

Restrict installation of drinking water wells.

(1) Florida Administrative Code chapter 62-524.

(2) Broward County Code sections 34-35 through 34-49.

(1) The site lies within a Florida Delineated Zone which restricts well placement.'

(2) The site lies within the area in which a BCHD ordinance precludes installation of a new potable water well where the property abuts a water main owned by a public or private water utility system.

Soil No No None None

Soil was cleaned up to residential standards. Therefore, no rcs are needed for soil.

* The 1999 ESD acknowledged the presence ofICs for groundwater. However, because the ESD did not specifically "require" rcs as part of the remedy, it is recommended that the decision documents be modified by a ROD Amendment or ESD to "require" rcs as part of the remedy until cleanup goals are achieved. 1. Florida's groundwater delineation information can be found online at: htto://www.deo.state.fl.us/water/groundwater/delineate.htm

Figure 8 shows the Florida Delineated Groundwater Zone that the site lies within. The Florida Delineated Groundwater Zone restricts well installations.


Figure 8: Florida Groundwater Delineated Area Map

wilson/chemform

Legend w.... Ounup 91tH

2.... ,. ...MIMI~WUtll.,... ~(Wl)......,.OW .....

(?,n__ -(J>US High ..."

~'''''''.h'''•. pI ....,""....

GtOI.InCI W..... o.lIMttion Citl.a Ic.na_ plana)

C Counll•• 1~","'lIud)


6.6 Interviews

During the FYR process, interviews were conducted with parties impacted by the site, including the property owners, a neighboring property owner, and regulatory agencies involved in site activities or aware of the site. The purpose of the interviews was to document the perceived status of the site and any perceived problems or successes with the phases of the remedy that have been implemented to date. Interviews are summarized below and complete interviews are included in Appendix F.

On January 11, 2010, EPA held a conference call with Gregory S. Wilson, President of neighboring Precision Metal Industries, Inc. (PM!) [formerly Wilson Concepts] and a prospective purchaser of the site property. PMI was interested in purchasing the property to expand their business and intended to use half of the building for storage purposes and the other half for production of casings for missiles for the United States Army. EPA explained the need for future groundwater monitoring on the property. Mr. Wilson stated that a Phase I investigation had been completed and he would consider having a Phase II investigation conducted having his consultant coordinate with EPA to ensure the correct locations, depths, and types of samples were collected to meet everyone's needs. EPA encouraged the re-use of the property and on January 28,2010, EPA issued a status/comfort letter to PM!.

On April 21, 2010, during the Site Inspection, the RPM interviewed the owners of the property (Richard E. Marcus and Peter Daniels, co-owners of BARD Realty) as well as the owner of the neighboring property (Greg Wilson ofPMI). Coast to Coast Building Products Inc., a company formerly owned by BARD Realty, began operations at the site in 2000. BARD Realty sold their Coast to Coast business in 2008, but has had difficulty selling the property. PM! decided not to purchase the property. At the time of the site inspection, the property was under contract for sale to Cadiz Realty Company, pending results of a Phase II investigation. The property is landscaped once a month and a former employee drives by the facility weekly. Security lights are used in the evenings. At the time of the site inspection, BARD Realty was allowing Sol Group Marketing to use the parking lot on the property. Sol Group Marketing is owned by Cadiz Realty Company and is located across the street from the Chemform site (see Figure 2). Neither Mr. Marcus, Mr. Daniels, nor Mr. Wilson were aware of any vandalism at the site. They were not aware of the location of any monitoring wells on the property, with the exception of MW-9. Mr. Daniels and Mr. Marcus stated that drinking water is provided by Broward County and there are no irrigation wells on the property. They had no concerns about the remedial action, other than how it may affect the sale of the property. The RPM informed the property owners that EPA would be glad to have a conference call and issue another status/comfort letter to prospective purchasers to answer environmental concerns that the prospective purchaser may have.

On May 3, 2010, EPA held a conference call with Cadiz Realty Company, a prospective purchaser of the property. Cadiz Realty Company wished to purchase the property to expand Sol Group Marketing's operations, which include food storage. They indicated that the only excavation activities that they intended to make at the property was to


possibly install down-ramps in order for the trucks and loading dock to be at the right height for loading/unloading. This would involve digging one or more approximate three-foot deep hole(s) near the loading dock and then covering the excavated area with either concrete or asphalt to support truck parking. Due to the extensive soil removal action that occurred at the site decades ago, EPA does not anticipate any problems with this type of construction.

Throughout the FYR process, the RPM has had several conversations with Ms. Kelsey Helton ofFDEP. Ms. Helton' s concerns regarding the site are: (1) missing monitoring wells may not have been plugged and abandoned according to state and federal regulations/guidelines, (b) groundwater continues to show concentrations above ARARs, (c) there are inadequate monitoring wells to characterize the plume, monitor attenuation, and confirm groundwater cleanup goals are met, and (d) arsenic in groundwater may indicate contribution from turbid sample or possible ongoing source . She also had concerns about EPA's draft Exit Strategy and requested that finalization be postponed until options can be explored further.


7.0 Technical Assessment

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

Remedial Action Performance The remedial actions continue to operate and function as designed. The OU-I ROD required monitoring for at least one year, which was completed. The ESD documented the presence ofICs to prevent use of the contaminated groundwater aquifer, and required FYRs and groundwater sampling as deemed necessary. Groundwater was sampled twice during the past five years. Contaminant concentrations remain above ARAR levels, but have not increased significantly. ICs are in place and affected properties obtain their drinking water from Broward County. Only one of the original ten monitoring wells could be located during sampling events. However, groundwater monitoring can be performed by Geoprobe/direct push methods. Additional attempts should be made to locate and properly plug and abandon any wells that lack integrity or will not be used in a future monitoring program. An assessment and monitoring program should be developed to confirm cleanup goals are eventually met.

The OU-2 ROD required no further action based on a soil removal action that was completed prior to the OU-2 ROD. However, the PRPs excavated additional soils, as required by FDEP, to achieve a 10-6 risk range.

System Operations/O&M There is no active treatment system at the site. Therefore, there are no system operations or O&M other than occasional monitoring.

Opportunities for Optimization The only remedy requirements are periodic groundwater sampling and FYRs. In the past five years, groundwater sampling has been conducted twice. FDEP recommends annual monitoring.

Early Indicators of Potential Issues There were no indicators of potential issues that could place protectiveness at risk.

Implementation of Institutional Controls and Other Measures The only contamination remaining at the site is in groundwater. ICs are in place that are effectively prohibiting consumption from the contaminated aquifer. The existence ofICs was documented in the 1999 ESD, but the ESD did not specifically require ICs as part of the remedy. Therefore, it is recommended that the ROD be modified to "require" ICs on groundwater until ARARs are achieved. Access controls in the form of fencing, although not required, is in place. There has been no evidence of vandalism.


7.2 Question B: Are the exposure assumptions, Toxicity Data, Cleanup Levels, and Remedial Action Objectives (RAOs) Used at the Time of Remedy Selection Still Valid?

Changes in Standards and TBCs The groundwater ARARs for arsenic, barium and chromium have changed since the time of the 1992 ROD for OU-I. The groundwater ARARs for barium and chromium have become less stringent. The groundwater ARAR for arsenic is currently more stringent than it was at the time of the 1992 ROD for OU-I (10 ~glL now, 50 ~g/L in the ROD). The Baseline Risk Assessment indicated that the average arsenic concentration in groundwater (24 ~g/L) exceeded EPA's acceptable risk range of 1 x 1 0-4; however the ROD used the MCL as a comparison standard. Arsenic was detected above the current ARAR in one of the twelve groundwater samples collected in 2010 in a location that is recommended for further monitoring. Because no one is exposed to the contaminated aquifer and future monitoring is recommended, the change in ARAR does not call into question the current protectiveness of the remedy. However, it is recommended that the ROD be modified to update the cleanup goal for arsenic to the current ARAR.

Changes in Exposure Pathways Land use near the site has not changed and remains commercial/industrial. Land use at the site has changed slightly in that the building is now being used to store food products. Because VOCs were not detected at the top of the aquifer, vapor intrusion has been determined to not be an issue. There have been no new human health or ecological routes of exposures or receptors newly identified or changed in a way that could affect the protectiveness of the remedy. There have been no newly identified contaminants or contaminant sources. There are no unanticipated toxic byproducts of the remedy not previously addressed by the decision documents.

Changes in Toxicity and Other Contaminant Characteristics Toxicity factors for contaminants of concern at the site have not changed in a way that would affect the protectiveness of the remedy. There have been no changes in contaminant characteristics that could affect the protectiveness of the remedy.

Changes in Risk Assessment Methods There have been changes in the ecological risk assessment process since the time the RODs were written. However, there are no ecological habitats at the site.

There have also been changes in risk assessment methods for evaluating vapor intrusion. The November 2002 OSWER Draft Guidancefor Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils (Subsurface Vapor Intrusion GUidance/ states that the scope is primarily towards residential settings, however, human exposures in non-residential settings may also be considered. EPA Region 4 Technical Services Section reviewed historical and recent groundwater data for the site and

4 The guidance document can be found at: http: //epa.gov/osw/hazard/correctiveaction/eis/vapor.htm


determined that because VOCs were not detected at the top of the aquifer, the vapor intrusion pathway is not a complete exposure pathway.

Expected Progress Towards Meeting RAOs Contaminant concentrations in groundwater decreased significantly after the soil removal action was completed. However, concentrations have remained about the same during the past fifteen years. The ESD for OU-l implied that the objectives were to prevent human consumption of the groundwater until ARARs are achieved. ICs are in place and are effective at meeting that objective.

7.3 Question C: Has Any Other Information Come to Light That Could Call Into Question the Protectiveness of the Remedy?

There have been no newly identified ecological risks found nor impacts from natural disasters. No new information has come to light which could affect the protectiveness of the remedy.

7.4 Technical Assessment Summary

OU-l The remedial actions continue to operate and function as designed. The OU-l ROD required monitoring for at least one year, which was completed. The ESD documented the presence ofICs to prevent use of the contaminated groundwater aquifer, and required FYRs and groundwater sampling as deemed necessary. Groundwater was sampled twice during the past five years. Contaminant concentrations remain above ARAR levels, but have not increased significantly. ICs are in place and affected properties obtain their drinking water from Broward County. Only one of the original ten monitoring wells could be located during sampling events. However, groundwater monitoring can be performed by Geoprobe/direct push methods. Additional attempts should be made to locate and properly plug and abandon any wells that lack integrity or will not be used in a future monitoring program. An assessment and monitoring program should be developed to confirm cleanup goals are eventually met.

The groundwater ARAR for arsenic is currently more stringent than it was at the time of the OU-l ROD (10 Ilg/L now, 50 Ilg/L in the ROD). Arsenic was detected above the current ARAR in one of the twelve groundwater samples collected in 2010 in a location that is recommended for further monitoring. Because no one is exposed to the contaminated aquifer and future monitoring is recommended, the change in ARAR does not call into question the protectiveness of the remedy. However, it is recommended that the ROD be modified to update the cleanup goal for arsenic to the current ARAR.

Land use at the site has changed slightly in that the building is now being used to store food products. EPA Region 4 Technical Services Section reviewed historical and recent


'------------------ -------------------------- ~- - ----"

groundwater data for the site and determined that because VOCs were not detected at the top of the aquifer, the vapor intrusion pathway is not a complete exposure pathway.

Contaminant concentrations in groundwater decreased significantly after the soil removal action was completed. However, concentrations have remained about the same during the past fifteen years. The ESD implied that the remedial action objectives were to prevent human consumption of the groundwater until ARARs are achieved. ICs are in place and are effective at meeting that objective.

OU-2 The OU-2 ROD required no further action based on a soil removal action that had been completed prior to the ROD. However, the PRPs excavated additional soils, as required by FDEP, to achieve a 10-6 risk range. There has been no new data to suggest that the soil remedy is not protective.

8.0 Issues

Table 7 summarizes the current issues for the Chemform site.

Table 7: Current Issues for the Chemform Site

Issues

Affects Protectiveness?

(Yes or No) Current Future

OU-1 : Nine out of ten monitoring wells could not be found. No Yes

OU-1: Missing monitoring wells may not have been plugged and abandoned according to state or federal regulations/guidelines. No Yes

OU-1 : Groundwater continues to show contamination above ARARs. There are inadequate monitoring wells to characterize the plume, monitor attenuation and confirm groundwater cleanup goals are met. No Yes

OU-1 : Arsenic in groundwater may indicate contribution from turbid sample or possible ongoing source. No Yes

OU-1: The arsenic groundwater ARAR is now more stringent than the criteria established in the ROD . No Yes

OU-1 : The 1999 ESD documented the existence of groundwater ICs, but did not require ICs as part of the remedy. No Yes


9.0 Recommendations and Follow-up Actions

Table 8 provides recommendations to address the current issues at the Chemforrn site

Table 8: Recommendations to Address Current Issues at the Chemform Site

Affects Recommendations Protectiveness?

Issues and Follow-up

Actions Party

Responsible Oversight Agency

Milestone Date

(Yes or No)

Current Future

OU-1 : Nine out of ten monitoring wells could not be found.

Either install new permanent monitoring wells or utilize direct push/temporary wells for future groundwater sampling.

PRPs EPA, FDEP

12/31/2011 No Yes

Attempt to locate, and plug and

OU-1: Missing abandon wells that monitoring wells may lack integrity, or not have been plugged and abandoned according

that will not be used to monitor plume orto

PRPs EPA, FDEP

12/31/2014 No Yes

to state or federal confirm regulations/guidelines. groundwater

cleanup goals are met.

Develop and implement

OU-1: Groundwater assessment and continues to show monitoring contamination above program that ARARs. There are includes vertical inadequate monitoring wells to characterize the plume, monitor

delineation and installation of monitoring wells

PRPs EPA, FDEP 12/31/2011 No Yes

attenuation and with appropriate confirm groundwater screen intervals to cleanup goals are effectively monitor met. plume and confirm

cleanup goals are met.


Affects Recommendations Protectiveness?

Issues and Follow-up

Actions Party

Responsible Oversight Agency

Milestone Date

(Yes or No)

Current Future

Install/develop OU-1: Arsenic in appropriate groundwater may monitoring wells to indicate contribution from turbid sample or

ensure representative

PRPs EPA, FDEP

12/31/2011 No Yes

possible ongoing samples and source. evaluate likely

sources.

OU-1: The arsenic groundwater ARAR is now more stringent than the criteria established in the ROD and recent sampling indicated arsenic concentrations above

Modify the ROD to reflect the current State and Federal groundwater ARARs for arsenic.

EPA EPA, FDEP

6/30/2011 No Yes

the more stringent MCl.

OU-1 : The 1999 ESD documented the existence of groundwater ICs, but did not "require" ICs as part of the remedy.

Modify the ROD to "require" ICs for groundwater as part of the remedy.

EPA EPA, FDEP

6/30/2011 No Yes

10.0 Protectiveness Statements

OU-l The remedy at OU-l currently protects human health and the environment because ICs are in place that effectively prevent consumption of water from the contaminated aquifer, there currently is no unacceptable risk of vapor intrusion, and FYRs are being conducted. However, in order for the remedy to be protective in the long-term, the following actions need to be taken: modify the ROD to reflect current groundwater arsenic ARARs and require ICs as part of the remedy; attempt to locate, plug and abandon missing monitoring wells; develop and implement an assessment and monitoring program that includes vertical delineation and installation of monitoring wells with appropriate screen intervals to effectively monitor plume and confIrm cleanup goals are met.



Site-wide The remedy at OU-l is protective in the short-term. The remedy at OU-2 is protective. Therefore, the site is considered protective ofhuman health and the environment in the shortterm. In order for the remedy to be protective in the long-term, the following actions need to be taken: modify the ROD to reflect current groundwater arsenic ARARs and require ICs as part of the remedy; attempt to locate, plug and abandon missing monitoring wells; develop and implement an assessment and monitoring program that includes vertical delineation and installation of monitoring wells with appropriate screen intervals to effectively monitor plume and conflrm cleanup goals are met.

11.0 Next Review

This is a policy site that requires ongoing FYRs as long as hazardous substances, pollutants, or contaminants remain at the site above levels that allow for unlimited use and unrestricted exposure. Because, as of April 2010, hazardous substances are still present in groundwater beneath the site, the next FYR will be due within flve years of the signature/approval date of this FYR.


Appendix A

Press Notice

LEGAL NOTICE J. S. Environmental PrOteCUOfl Agency, Region ..1

t.,nnOUrlces ~II~ Start of a Fivi?-Year R~vie ...v for tile

Cilemform, Inc. Superfund Site pompano Beach, ,olorida

-he U.S. fllvironmental Protectron AgEncy iEPA) is cOl1duclin~ J Five-Year RevlE'w at the Cllcmforlll, Inc Slipertund Site in pompano B9actl, Broward County. FloridJ. The Sup('rfund law, ~~nO'Nfl as the Comprellenslve EnvirontnC'rHJI Response. CompensaUon, and liability Act (CERClA), requires trial SuperfL!nd cleanup actions be ,evil?VI!?u every fl',It? years, to ensure tJJal the se!!?cted ,emedy' remains protec tive of human rl::'alUl and thE 2livironment. Thus trle pUrpoSe of thiS Five-Year Review, tilt? second for this site. is to evaluate the oerforfnallce and e-ffeCtiveness o~ ttle selected CleailiJp rerned..,...

The 4·acre (ll";I11lorll1, II1C. Site i)E:gan as a precision mi'tchine sr.op rnanufac· tunng metal pans for the .3t'ro:.;pace Industry. Operc'!tior:s continued from 1967 tli 1985, including COrlVentlonc11 fTi.1clwle rna~:ii1g ~s 'Nell as the manufacturing of a high·recll electro-chenOical "'illing machrne, which invOI'_'?d tile use of electrolytiC sotu!ions rtnd sHong electric: current.ITI 1977, the Broward Coullty ?ollution Control Bo.:;rd found the cOII1~an'lln violauon OT regulations for the discharge of industrial waStes Oilto tile ground ill 1935, the E?A found .he sorl and grounciwater to be cOlltaminated with t1eavy metuls Jnd ottlCr contami· nallts rhe C~ell~forrn. Inc site is located adiilc~llt to Wilsoll Concepts oi Fiori· da, InC., anOther NPL Site. Tile Siscay'ne AQuIfer IS U/l{Je:neatfl U"le sitE' and supplies alllJ1W1lC!pal water to 3rov.'ard County. Four Jllunicipal wells are located wilhin 3 rn;;es 01 the site and serve appro,irnately 93,000 peoole.

Site cleanup ellorts have been completed. Tilis site was addressed through Fede:-.;11 and notentially :-esponsib!C! parttes' aCllOIlS.

III 1990, drurll~ were removed as a part of an l!llfnediate rernolJal action. Arpro;..,:immely 600 cubic 'lardS of SOt! were excavated ill addition to the removal of Ll~bris, sod. (~lncJ SllJdge Irom two undl2rground Storage tan~:5. An <ldditionai 3.000 cutJic yards at SOd were ~emove(j durrng a subsequem relliov,ll aClion In :992

,he par;ies potentially respcnsible for site contJrninatior; completed a study of the groundwater. 9ased on tile resultS of the ground.....ater investigation. the EPA determtr,ed no fU~:!ler dction was requi:l?u in a 1QQ3 Record 01 DeciSion (ROD), I?x":ep~ for one year 0f Illoni::orlng. beCause the concentrations of c:ontamlna!lts of concern have eltller de('reused or rcrnaine·j stable. Tile year uf 1l1Oflitoring """.'''']5 ~ornpfeted if! 199J and sllo'Ned that the 'JO'Ullle and conCentr~1tlons of groundwater contal!!lnants observed Curing EPA'S Site screening studies and durrng trle earl'l phase of ~tle investigatiOn have been greatiy reuuced due to the soil (ind source area cleanup ac:ivlt!es. However, tile presencE.' of 'fin'll chloride s:igt'Hly abDve the MaY.imum COrltamin.HH Level (MeL) \\'arr.;n~ed the Agency i5suing all E;.;pliillc:ltiorl of Significant Difference (ESQ) on Apnl :2. 1999. Tnt! ESD was issued in order to add vi 11~'1 chloride as a po· tential contanlll1nflt of concern and to require a Five .. Year Re'w'l!?W repon.

After tIle required reVIew cli:d comment period, tillS Site vias delet~d from the National Prio' ity LrSt (tWL) on June 23, 2000 On September 30, 2005. the Agenc\, conducted a Five·Year review report to '.:erif'l th.3t instill/tional con~ !tols la res;riction on the constrt'cUon of lise or potable wens within the area) 011 e;·;isling ground\vatE':' uses ill the area continue to function as intended. The Five-Year reVle\v conlirrned lhQt institlltionai CO 11 trl11s continue to be effective III prOtectrng human 'le~l:tl .3fld the 8nvironment. J'he-.t..gl?ncy 'N!II conduct an· other Five·Ye(ir review ill 2010. In Dtepnfat10n lor UH.' 2010 FlvE'·Year Revie\'J, grounrlwater SJrnnlrng was conducted and showed non-detectable concentrations of vin\'1 cillorrde In .He only well tllJt couid sUIl be loca,ed clHite (1.11'1'-9) Because the monitoring w'?l1 from whicn vUlyl ctlloride WaS delected in ~997 trilW-'O} cou~d nOt be located, ::P.I\ bCli~'"cs ttlOt additional groundwater sam· p;es need to he collected in thE vicinity of ihe fo-mer monitoring well MW-l0 in order to d!?terrnille if vinyl chloride is s.tlil t.HeSe!l~. EPA is r.urrentl~' d~veloping J S~lrnplrng pl,1r]

EPA will comolete tile Five-'(eilr Review process oy September 2010. Upon cornpletion. a copy of the jinal report will be placed in the informatron reposilOry at the Broward county Milin Library (see address Ilelow)

It you would Irke r:10re inforrnation or have' any questions. comments, and/or cOllcerns about til'? Frve-Year ne'iicw, you may contact: Samantha urquhar t Foster K\'le Bryant, Environmental Scientisli RemEdial Project Manager Co!nrnunrty Involvement Coordinato U.S. EPA, Region ~ 40J-S62-9013/brya,1l.I:yle@epa gD" 6 t ForSYlIl S: .. S'd Atlaf\tii, GA 30303 jO~- S62 -B7 60/urqunart-fos ter.s"r;ran ltra@epa gov U.S. EPA - Regron J Marlrng t.ddr~s~ Local Document Reoository: superfund Oi\/ision (4SD .. SRBi BrOward county Main Library 6 i Forsyth 51. 100 S. AndreWS Ave., NE Atiantil. GA 30303 Fort Lauderd,,!e FL 33301

Online. http ... /www.epa.goviReolOnaN/aste/npl;nplfin.cIHnfrrnfl.htm April 25, 2010

SUN SENTINEL PROOF

Customer U.S EPA REGION 4 Contact: J. KYLE

Ad Number 13874082

Insert Dates: 0<1/2::/2010

Phone: 4045629073

Appendix B

Documents Reviewed

Documents Reviewed in Preparing the 2010 FYR for the Chemform, Inc. Site

FDEP, 2009. MCLs for Drinking Water in Florida. http://www.dep.state.fl.usIWATERIdrinkingwater/standard.htm. Viewed on December 4,2009.

FDEP, 1999. Concurrence Letter for Deletion of the Chemform, Inc. Superfund Site from the National Priorities List. November 4, 1999.

Land Science, 2010. Phase II Environmental Assessment Report for the Industrial Warehouse Property (Former Chemform Site). April 23, 2010.

RUST, 1998. Technical Memorandum - Groundwater Sampling. March 18, 1998.

USACE,2005. Superfund Five-Year Review Report for the Chemform, Inc. Superfund Site. September 30, 2005.

USEPA, 2010. Proposed Exit Strategy for the Chemform, Inc. Operable Unit No.1. August 2, 2010

USEPA, 2009. Drinking Water Contaminants. http://www.epa.gov/safewater/contaminants/index.html. Viewed on December 4, 2009.

USEPA,2007. Report, Groundwater Monitoring for Five-Year Review. August 17, 2007.

USEPA,2001. Comprehensive Five-Year Review Guidance. June 2001.

USEPA, 1999. Explanation of Significant Differences for OU-1. April 2, 1999.

USEPA, 1993. Record of Decision for Operable Unit 2.

USEPA, 1992. Record of Decision for Operable Unit 1.

Appendix B B-1 SEPTEMBER 2010 Chemform FYR

Appendix C

Ground Water Data Summary

Chemform, Inc. Site Ground Water Data Summary

Well # Depth Fed MCl: Fl Mel: Fl NADC: ROD': MW-1 MW-1 MW-1 MW-1 MW-1 MW-1 MW-1 MW-1 MW-1

MW-2 MW-2 MW-2 MW-2 MW-2 MW-2 MW-2 MW-2 MW-2



MW-5 MW-5

Appendix C Chemform FYR

12 12 12 12 12 12 12 12 12

12 12 12 12 12 12 12 12 12

12 12 12 12 12 12 12 12 12

50 50 50 50 50 50 50 50 50

12 12

Date 2010 2010 2010 1992

Aug-SO Mar-S1 Aug-S1 Jan-S2 Feb-S2 Oct-S3 Jan-S4 Apr-S4 Jul-S4



AUQ-SO Mar-S1 Aug-S1 Jan-S2 Feb-S2 Oct-S3 Jan-S4 Apr-S4 Jul-S4

Aug-SO Mar-S1

Arsenic Barium Chromium 10 2000 100 10 2000 100

500 1000 50 1000 50

<10 160 200 <10 <10 <10 <10 15 <10 NA NA NA NA NA NA

<10 10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10

<10 82 170 <10 <10 <10 <10 <10 <10 NA NA NA NA NA NA

<10 <10 <10 <10 10 <10 <10 <10 <10 <10 <10 <10

12 66 110 <10 <10 <10 <10 11 <10 NA NA NA NA NA NA

<10 12 <10 <10 <10 <10 <10 <10 <10 <10 15 <10

<10 440 110 <10 15 <10 <10 16 <10 NA NA NA NA NA NA

<10 12 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10

14 140 1400 <10 <10 40

Nickel Zinc NS 5,000

100b NS

100 5,000 64 61

<40 <20 <40 21 NA NA NA NA

<40 <20 <40 <20 Nle NI NI <20

<40 52 <40 <20 <40 <20 NA NA NA NA

<40 <20 <40 <20

NI NI NI 32

61 4S <40 <20 <40 <20 NA NA NA NA

<40 <20 <40 <20

NI NI NI <20

55 52 <40 <20 <40 <20 NA NA NA NA

<40 <20 <40 <20

NI NI NI <20

1200 140 <40 <20

1,4-Dichloro- CIS-1,2-dichloro- methylene tetrachloro- trichloro- vinyl benzene ethene chloride naphthalene ethene ethylene chloride xylene

75 70 NS NS 5 5 2 10,000 75 70 5 NS 3 3 1 10,000

700 500 300 300 100 75 NS NS 20 NS NS 1 10,000 <1 NI <1 <10 NI NI NI <1

NA NI <1 NA NI NI NI <1 NA NI <5 NA NI NI NI <5 NA NI NA NA NI NI NI NA NA NI NA NA NI NI NI NA NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI

<1 NI <1 <10 NI NI NI <1 NA NI <1 NA NI NI NI <1 NA NI <5 NA NI NI NI <5 NA NI NA NA NI NI NI NA NA NI NA NA NI NI NI NA NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI

2.8 NI <1 <10 NI NI NI <1 NA NI 690 <10 NI NI NI <1

<10 NI <5 NA NI NI NI <5 NA NI NA NA NI NI NI NA NA NI NA NA NI NI NI NA NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI

<1 NI <1 <10 NI NI NI <1 NA NI 2.S NA NI NI NI <1 NA NI <5 NA NI NI NI <5 NA NI NA NA NI NI NI NA NA NI NA NA NI NI NI NA NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI

<1 NI <1 <10 NI NI NI <1 NA NI <1 NA NI NI NI <1

Page 1 of 3 SEPTEMBER 2010

Well # Depth Fed MCl: Fl MCl: Fl NADC: ROD': MW-5 MW-5 MW-5 MW-5 MW-5 MW-5 MW-5

MW-6 MW-6 MW-6 MW-6 MW-6 MW-6 MW-6 MW-6 MW-6 MW-6

MW-7 MW-7 MW-7 MW-7

MW-8 MW-8 MW-8 MW-8

MW-9 MW-9 MW-9 MW-9 MW-9 MW-9 MW-9 MW-9

MW-10 MW-10

TW-1 TW-1 TW-1 TW-1

Appendix C Chemform FYR

12 12 12 12 12 12 12

12 12 12 12 12 12 12 12 12 12

12 12 12 12

12 12 12 12

25 25 25 25 25 25 25 25

65 65

Date Arsenic 2010 10 2010 10 2010 500 1992 50

Aug-91 <10 Jan-92 NA Feb-92 NA Oct-93 <10 Jan-94 <10 Apr-94 <10 Jul-94 <10

Aug-90 96 Mar-91 55 Aug-91 <10 Jan-92 33 Feb-92 NA Oct-93 18 Jan-94 29 Apr-94 29 Jul-94 28

May-96 NA

Oct-93 <10 Jan-94 <10 Apr-94 <10 Jul-94 <10

Oct-93 <10 Jan-94 <10 Apr-94 <10 Jul-94 <10

Oct-93 <10 Jan-94 <10 Apr-94 <10 Jul-94 <10

May-96 NI Apr-97 NI Nov-97 NA Jun-07 NA

Apr-97 NI Nov-97 NI

Aug-90 NA Mar-91 NA Aug-91 NA Jan-92 NA

Barium Chromium Nickel Zinc 2000 100 NS 5,000 2000 100 100b NS

1000 1000 50 100 5,000

<10 20 <40 <20 NA 1300 230 NA NA 34 55 NA

<10 <10 <40 <20 <10 54 <40 <20

12 19 NI NI 12 16 NI <20

230 510 310 270 39 47 <40 34 20 <10 <40 26 NA 15 <40 NA NA NA NA NA 24 <10 <40 23 22 <10 22 <20 23 <10 NI NI 22 <10 NI <20 NA NA NA NA

<10 <10 <40 <20 <10 <10 <40 <20 <10 <10 NI NI <10 <10 NI <20

19 24 40 <20 13 11 <40 <20 14 16 NI NI 12 33 NI 22

<10 <10 <40 <20 <10 <10 <40 <20 <10 <10 NI NI <10 <10 NI <20

NI NI NI NI NI NI NI NI

NA NA NA NA NA NA NA NA

NI NI NI NI NI NI NI NI

NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

1,4-Dichloro- cls-1,2-dichloro- methylene tetrachloro- trichloro- vinyl benzene ethene chloride naphthalene ethene ethylene chloride xylene

75 70 NS NS 5 5 2 10,000 75 70 5 NS 3 3 1 10,000

700 500 300 300 100 75 NS NS 20 NS NS 1 10,000 NA NI <5 NA NI NI NI <5 NA NI 2 NA NI NI NI <1 NA NI NA NA NI NI NI NA NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI

<1 NI <1 <10 NI NI NI <1 NA NI <1 NA NI NI NI <1 NA NI <5 NA NI NI NI <5 NA NI NA NA NI NI NI NA NA NI NA NA NI NI NI NA NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI BOL NI NI NI BOL BOL NI

NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI

NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI NI

NI <5 NI NI <5 <5 <10 NI NI <5 NI NI <5 <5 <10 NI NI 3.3 NI NI <1 <1 11 NI NI 2.8 NI NI <1 <1 11 NI

BOL <1 BOL BOL NI BOL 0.82 BOL NI <1 NI NI NI NI <1 NI

NA NA NA NA NA NA NA NA <0.5 0.18 J <0 .5 NA <0.5 <0.5 <0 .5 <1

NI 50 NI NI NI NI 2 NI NI 32 <5 NI <1 <1 3.1 <2

NA NI NA NA NI NI NI NA NA NI NA NA NI NI NI NA NA NI NA NA NI NI NI NA

<10 NI 1.1 76 NI NI NI 3.4

Page 2 of3 SEPTEMBER 2010

1,4-0ichloro- cis-1,2-dichloro- methylene tetrachloro- trichloro- vinyl Well # Depth Date Arsenic Barium Chromium Nickel Zinc benzene ethene chloride naphthalene ethene ethylene chloride xylene Fed MCL: 2010 10 2000 100 NS 5,000 75 70 NS NS 5 5 2 10,000 FL MCL: 2010 10 2000 100 100b NS 75 70 5 NS 3 3 1 10,000 FL NAOC: 2010 500 1000 700 500 300 300 100 ROD': 1992 50 1000 50 100 5,000 75 NS NS 20 NS NS 1 10,000 TW-1 Feb-92 NA NA NA NA NA NA NI NA NA NI NI NI NA

OP1(25) 25 May-96 NI NI NI NI NI NI 16 NI NI NI BOL 20 NI OP1(35) 35 May-96 NI NI NI NI NI NI BOL NI NI NI BOL 10 NI OP1(45) 45 May-96 NI NI NI NI NI NI BOL NI NI NI BOL 1.9 NI OP1(55) 55 May-96 NI NI NI NI NI NI BOL NI NI NI 5.9 6.8 NI OP1(65) 65 May-96 NI NI NI NI NI NI BOL NI NI NI BOL 1.8 NI

OP2(20) 20 May-96 NI NI NI NI NI NI BOL NI NI NI BOL 0.73 NI OP2(40) 40 May-96 NI NI NI NI NI NI BOL NI NI NI 1.6 1 NI OP2(63) 63 May-96 NI NI NI NI NI NI BOL NI NI NI BOL 29 NI

TMW-1(10) 10 Apr-10 9 NA 35 NA NA <0.39 <0.17 <1 .5 NA <0.42 <0 .34 <0.079 NA TMW-1(30) 30 Apr-10 129 NA 73 NA NA <0.39 <0.17 <1 .5 NA <0.42 <0.34 <0.079 NA TMW-1 (60) 60 Apr-10 <0.7 NA <1 .1 NA NA <0 .39 3.51 <1.5 NA <0.42 <0.34 16.1 NA

TMW-2(10) 10 Apr-10 <0.7 NA 9 NA NA <0.39 <0.17 4.56 NA <0.42 <0.34 <0.079 NA TMW-2(30) 30 AJlr-10 2 NA 76 NA NA <0 .39 <0.17 <1 .5 NA <0.42 <0.34 <0.079 NA TMW-2(60) 60 Apr-10 <0.7 NA <1 .1 NA NA <0.39 3.61 <1 .5 NA <0.42 <0.34 14.7 NA

TMW-3(101 10 Apr-10 <0.7 NA 6 NA NA <0.39 <0 .17 <1 .5 NA <0.42 <0.34 <0.079 NA TMW-3(30) 30 Apr-10 <0.7 NA 7 NA NA <0.39 <0.17 <1 .5 NA <0.42 <0.34 <0.079 NA TMW-3(60) 60 Apr-10 <0.7 NA 5 NA NA <0.39 <0.17 <1 .5 NA <0.42 <0.34 <0.079 NA

TMW-4(10) 10 Apr-10 <0.7 NA 7 NA NA <0.39 <0.17 <1 .5 NA <0.42 <0 .34 <0.079 NA TMW-4(30) 30 Apr-10 <0.7 NA 9 NA NA <0.39 <0 .17 <1 .5 NA <0.42 <0.34 <0.079 NA TMW-4(60) 60 Apr-10 5 NA 5 NA NA <0.39 0.82 <1 .5 NA <0.42 <0.34 <0.079 NA

maximum concentration: 129 440 1400 1200 270 2.8 50 690 76 0 5.9 29 3.4 Notes:

'The ROD did not specify a remediation goal. It presented several ARARs for comparison. Values in this row represent the most conservative vatue in Tabte 13 of the ROD. with the exception of the value for vinyl chloride. which was specified in the 1999 ESD.

b Secondary MCL

iBaId ....... 1ndh:Idea __ ......... ____ .. _ **-'l "...0I ........ 1tIZ ROD c:riWIa. 1191 ESP crIIttIlL.!!r.CUINIIt ARARs

BQL = Below Quantification Limit

Fed MCL = Safe Drinking Water Ac~ MaXimum Contaminant Level

FL MCL = Florida Maximum Contaminant Level

FL NADC = Florida Natural Attenuation Default Concentrations

NS = Not Specified

NA = Not Analyzed

NI = No Information in the summary tables from which this data was compiled.

Appendix C Chemform FYR Page 3 of 3 SEPTEMBER 2010

Appendix D

Site Inspection Checklist

Five-Year Review Site Inspection Checklist

"NI A" refers to "not applicable." Grey shading indicates that particular section of the form is not applicable for this Site.

I. SITE INFORMATION

Site name: Chemform Inc. Date of inspection: April 21, 2010

Location and Region: Pompano Beach, FL EPA 10: FLD080174402

Agency, office, or company leading the five-year Weather/temperature: partly cloudy with a few review: EPA, Region 4 rain sprinkles; 70°F

Remedy Includes: (Check all that apply) D Landfill cover/containment D Monitored natural attenuation D Access controls D Groundwater containment IZIlnstitutional controls D Vertical barrier walls D Groundwater pump and treatment D Surface water collection and treatment IZI Other Groundwater monitoring, Five-Year Reviews

Attachments: D Inspection team roster attached D Site map attached

II. INTERVIEWS (Check all that apply)

I. O&M site manager Name Title Date

Interviewed: D at site D at office D by phone, Phone no. Problems, suggestions: D Report attached There are no routine O&M activities reguired.

2. O&M staff Name Title Date

Interviewed: D at site D at office D by phone, Phone no. Problems, suggestions; D Report attached

Appendix D Page 1 of 15 September 2010

Chemform FYR

3. Local regulatory authorities and response agencies (i.e., State and Tribal oftices, emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices, etc.) Fill in all that apply.

Agency Florida Degartment of Environmental Protection Contact Kelse~ Helton Professional Geologist

Name Title Problems; suggestions; D Report attached

Agency Contact


Agency Contact


Agency Contact


4. Other interviews (optional) cgj Report attached.

Richard E. Marcus, co-owner of property

Peter Daniels, co-owner of property

Greg Wilson, President, PMI - neighboring property owner

Appendix D

Chemform FYR

Page 2 of 15

850-245-8969 Date Phone no.

Date Phone no.

Date Phone no.

Date Phone no.

September 2010

III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)

I. O&M Documents DO&M manllal D Readily available D As-built drawings D Readily available D Maintenance logs D Readily available Remarks

2. Site-Specific Health and Safcty !Plan D Readily available D Contingency plan/emergency response plan D Readily available Remarks

3. O&M and OSHA Training Records Remarks

4. !Permits and Service Agreemcnts D Air discharge pemlit D Effluent discharge D Waste disposal, POTW D Other pemlits Remarks

5. Gas Generation Records Remarks

6. Settlement Monument Records Remarks

7. Groundwater Monitoring Records Remarks

8. l.eachate !Extraction Records Remarks

9. Discharge Compliance Records DAir D Water (effluent) Remarks

10. Daily Access/Security Logs Remarks

Appendix 0

Chemform FYR

D Readily available

D Readily available D Readily available D Readily available D Readily available

D Readily available

D Readily available

D Readily available

D Readily available

D Readily available D Readily available

D Readily available

Page 3 of 15

D Up to date [8J N/A D Up to date [8J N/A D Up to date [8J NI A

D Up to date [8J N/A D Up to date [8J N/A

D Up to date [8J N/A

D Up to date [8J N/A D Up to date [8J N/A D Up to date [8J N/A D Up to date [8J N/A





D Up to date [8J NI A D Up to date [8J N/A


September 2010

IV. O&M COSTS

1. O&M Organization D State in-house D Contractor for State D PRP in-house [8J Contractor for PRP D Federal Facility in-house D Contractor for Federal Facility [8J Other PRPs' contractor gerformed initial monitoring at the Site as well as additional investigations. The most recent samgling events, however, were conducted b~ EPA in 2007.

2. O&M Cost Records D Readily available D Up to date D Funding mechanism/agreement in place

Original O&M cost estimate $104,000 per year D Breakdown attached

Total annllal cost by year for review period if available

From To D Breakdown attached Date Date Total cost





3. Unanticipated or Unusually High O&M Costs During Review Period Describe costs and reasons: There have been no unusuall~ high O&M costs during the review geriod. The onl~ costs during the review geriod were EPA costs for monitoring in 2007.

V. ACCESS AND INSTITUTIONAL CONTROLS [8J Applicable DN/A

A. Fencing

1. Fencing damaged D Location shown on site map [8J Gates secured DN/A Remarks Fence was intact and gates were gadlocked

B. Other Access Restrictions

1. Signs and other security measures D Location shown on site map DN/A Remarks Securing lighting at night, drive-b~ visits, currentl~ allowing use of garking lot b~ comgan~ that is under contract to gurchase the grogertv. This comgan~ is located across the street.

Appendix D Chemform FYR

Page 4 of 15 September 2010

C. Institutional Controls (ICs)

I. Implementation and enforcement Decision Document(s) call for ICs I:8J Yes DNo

[fNo, are ICs needed') DYes DNo I-lave ICs been implemented? I:8J Yes DNo

Site conditions imply lCs not properly implemented DYes I:8J No DN/A Site conditions imply ICs not being fully enforced DYes I:8J No DN/A

Type of monitoring (e.g., self-reporting, drive by) No monitoring reguired Frequency Responsible party/agency Contact

Name Title Date Phone no.

Reporting is up-to-date DYes DNo I:8J N/ A Reports are verified by the lead agency DYes DNo I:8J N/ A

Specific requirements in deed or decision documents have been met I:8J Yes DNo DN/A Violations have been reported DYes DNo I:8J N/ A Other problems or suggestions: D Report attached

2. Adequacy I:8J ICs are adequate D lCs are inadequate DN/A Remarks ProRer1Y owner confirmed that water use at the facility was Rrovided b~ municiRality. Groundwater from beneath the RroRertv is not used. This is consistent with reguirements in the E5D.

D. General

I. Vandalism/trespassing D Location shown on site map I:8J No vandalism evident Remarks There is no evidence of vandalism. Both RroRertv owners as well as the Rresident of the neighboring comRan~ stated that the~ were not aware of an~ vandalism occurring on the orooertv.

2. Land use changes on site DN/A Remarks Coast-to-Coast sold the business in 2008, but have not been able to sell the buildingLRroRertv ~et. Building is currentl~ vacant. Parking lot is being used b~ a comRan~ that is located across that street (The Sol GrouR) and is under contract to Rurchase the RroRertv, Rending the results of a Phase II investigation. The Sol GrouR distributes fruit.

3. Land use changes off site DN/A Remarks Nearb~ land use remains industrial. There have been no significant land use changes near the RroRertv.

Appendix D

Chemform FYR Page 5 of 15 September 2010

A. Roads o Applicable

1. Roads damaged Remarks

B. Other Site Conditions

Remarks


VI. GENERAL SITE CONDITIONS

ISJ N/A

o Location shown on site map o Roads adequate ISJ N/A

o Applicable ISJ N/A


VB. ILANlDn1L1L COVERS D Applicable rgJ N/A

A. lLandfill Surface

I. Settlement (Low spots) D Location shown on site map D Settlement not evident Areal extent Depth

Remarks

" Cracks D Location shown on site map D Cracking not evident ... Lengths Widths Depths

Remarks

3. Erosion D Location shown on site map D Erosion not evident Areal extent Depth Remarks

4. Holes D Location shown on site map D Holes not evident Areal extent Depth Remarks

5. Vegetative Cover D Grass D Cover properly established D No signs of stress D Trees/Shrubs (indicate size and locations on a diagram) Remarks

6. Alternative Cover (armored rock, concrete, etc.) DN/A Remarks

7. Bulges D Location shown on site map D Bulges not evident Areal extent Height Remarks

8. Wet Areas/Water lDamage D Wet areas/water damage not evident D Wet areas D Ponding D Seeps D Soft subgrade Remarks

9. Slope n nstability Areal extent Remarks

Appendix D

Chemform FYR

D Slides

D Location shown on site map Areal extent D Location shown on site map Areal extent D Location shown on site map Areal extent D !Location shown on site map Areal extent

D Location shown on site map DNo evidence of slope instability


B. Benches o Applicable DN/A (Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the nmoffto a lined channel.)

I. flows Bypass Bench o Location shown on site map o N/A or okay Remarks

2. Bench Breached o Location shown on site map o N/A or okay Remarks

3. Bench Overtopped o Location shown on site map o N/A or okay Remarks

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

1. Settlement 0 Location shown on site map o No evidence of settlement Areal extent Depth Remarks

2. Material Degradation 0 Location shown on site map o No evidence of degradation Material type Areal extent Remarks

3. !Erosion o Location shown on site map o No evidence of erosion Areal extent Depth Remarks

Appendix 0 Chemform FYR


4. Vndercutting o Location shown on site map o No evidence of undercutting Areal extent Depth Remarks

5. Obstructions Type o No obstmctions o Location shown on site map Areal extent Size Remarks

6. Excessive Vegetative Growth Type o No evidence of excessive growth o Vegetation in channels does not obstmct flow o Location shown on site map Areal extent Remarks

D. Cover Penetrations o Applicable DN/A

l. Gas Vents o Active o Passive o Properly secured/locked o Functioning o Routinely sampled o Evidence of leakage at penetration o Needs Maintenance Remarks

2. Gas Monitoring Probes o Properly secured/locked o Functioning o Routinely sampled o Evidence of leakage at penetration o Needs Maintenance Remarks

3. Monitoring Wells (within surface area of landfill) o Properly secured/locked o Functioning o Routinely sampled o Evidence of leakage at penetration o Needs Maintenance

Remarks

4. Leachate Extraction Wells o Properly secured/locked o Functioning o Routinely sampled o Evidence of leakage at penetration o Needs Maintenance Remarks

5. Settlement Monuments o Located o Routinely surveyed Remarks

Appendix D

Chemform FYR

Page 9 of 15

o Good condition DN/A




DN/A

September 2010

IE. Gas Collection and Treatment D Applicable DN/A

1. Gas Treatment facilities D Flaring D Thermal destruction D Collection for reuse D Good condition D Needs Maintenance Remarks

2. Gas Collection Wells, Manifolds and !Piping D Good condition D Needs Maintenance Remarks

3. Gas Monitoring facilities (e.g., gas monitoring of adjacent homes or buildings) D Good condition D Needs Maintenance DN/A Remarks

f. Cover Drainage !Layer D Applicable DN/A

1. Outlet !Pipes nnspected D Functioning DN/A Remarks

2. Outlet Rock Bnspected D Functioning DN/A Remarks

G. Detention/Sedimentation Ponds D Applicable DN/A

1. Siltation Areal extent Depth D Siltation not evident Remarks

2. Erosion Areal extent Depth D Erosion not evident Remarks

3. Outlet Works D Functioning DN/A Remarks

4. Dam D Functioning DN/A Remarks



H. Retaining Walls D Applicable DN/A

I. Deformations D Location shown on site map D Defonnation not evident Horizontal displacement Vertical displacement Rotational displacement Remarks

2. Degradation D Location shown on site map D Degradation not evident Remarks

n. Perimeter I\)jtches/Off-Site I\)jscharge D Applicable DN/A

I. Siltation D Location shown on site map D Siltation not evident Areal extent Depth Remarks

2. Vegetative Growth D Location shown on site map DN/A D Vegetation does not impede flow Areal extent Type Remarks

3. Erosion D Location shown on site map D Erosion not evident Areal extent Depth Remarks

4. Discharge Structure D Functioning DN/A Remarks

VnnH. VERTnCAL BARRDlER WALLS D Applicable [8J N/A

1. Settlement D Location shown on site map D Settlement not evident Areal extent Depth Remarks

2. Performance Monitoring Type of monitoring D Perfonnance not monitored D Evidence of breaching Frequency Head differential Remarks

Appendix D

Chemform FYR


IX. GROUNDWATER/SURFACE WATER REMEDIES [8J Applicable DN/A

A. Groundwater Extraction Wells, Pumps, and Pipelines D Applicable [8J N/A

1. Pumps, Wellhead Plumbing, and Electrical D Good condition D All required wells properly operating D Needs Maintenance [8J N/A Remarks

2. Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances D Good condition D Needs Maintenance Remarks

3. Spare Parts and Equipment D Readily available D Good condition D Requires upgrade D Needs to be provided Remarks

B. Surface Water Collection Structures, Pumps, and Pipelines D Applicable [8J N/A

1. Collection Structures, Pumps, and Electrical D Good condition D Needs Maintenance Remarks

2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances D Good condition D Needs Maintenance Remarks

3. Spare Parts and Equipment D Readily available D Good condition D Requires upgrade D Needs to be provided Remarks



C. Treatment System D Applicable I2J N/A

l. Treatment Train (Check components that apply) D Metals removal D Oillwater separation D Bioremediation D Air stripping D Carbon adsorbers D Filters D Additive (e.g., chelation agent, flocculent) D Others D Good condition D Needs Maintenance D Sampling ports properly marked and functional D Sampling/maintenance log displayed and up to date D Equipment properly identified D Quantity of groundwater treated annually D Quantity of surface water treated annually Remarks

"1 IElectricallEnciosurcs and !Panels (properly rated and functional) I2J N/A .... D Good condition D Needs Maintenance Remarks

3. Tanks, Vaults, Storage Vessels I2J N/A D Good condition D Proper secondary containment D Needs Maintenance Remarks

4. Discharge Structure and Appurtenances I2J N/A D Good condition D Needs Maintenance Remarks

5. Treatment Building(s) I2J N/A D Good condition (esp. roof and doorways) D Needs repair D Chemicals and equipment properly stored Remarks

6. Monitoring Wells (pump and treatment remedy) I2J N/A D Properly secured/locked D Functioning D Routinely sampled D Good condition D All required wells located D Needs Maintenance Remarks

D. Monitoring Data

1. Monitoring Data I2J Is routinely submitted on time I2J Is of acceptable quality

2. Monitoring data suggests: D Groundwater plume is etTectively contained D Contaminant concentrations are declining

Appendix D

Chemform FYR


D. Monitored Natural Attenuation [gJ Applicable DN/A

1. Monitoring Wells (natural attenuation remedy) [gJ Properly secured/locked D Functioning D Routinely sampled D Good condition D All required wells located D Needs Maintenance Remarks Only one well (of the original ten) could be located during the FYR Site InsQection, as well as during the samQling event of 2007. The well that was located, MW-9, had a steel cover Qlate that was bolted closed. See Qhoto #5 in AQQendix E of this FYR.

X. OTHER REMEDIES

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

XI. OVERALL OBSERVATIONS

A. I mplementation of the Remedy

Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume, minimize infiltration and gas emission, etc.). The remedy is effective and functioning as designed. The ROD reQuired Quarterly monitoring for one year, which was comQleted. The ESD reQuired institutional controls, the addition of another contaminant of concern for the Site, and the reQuirement to conduct Five-Year Reviews. The ESD stated that additional monitoring may be conducted. Institutional controls have been imQlemented and are effective at Qrohibiting use of groundwater from beneath the Site as a Qotable source. This is the second FYR for the Site. Monitoring was conducted in 2007. Additional monitoring will be conducted in the future.

B. Adequacy of O&M

Describe issues and observations related to the implementation and scope of O&M procedures. In particular, discuss their relationship to the current and long-ternl protectiveness of the remedy. The ROD and ESD did not reQuire any O&M activities other than future monitoring as determined necessary. The last samQling event indicated contaminants of concern that exceed remedial goals. Additional monitoring will be reQuired to close out the Site to eliminate the need for future Five-Year Reviews.



C. Early Indicators of Potential Remedy Problems

Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of unscheduled repairs, that suggest that the protectiveness of the remedy may be compromised in the future. There are no indicators of gotential remed~ groblems, other than the need for additional monitoring wells . .

D. Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy. Because monitoring is gerformed so infreguentl~, there are no recommendations for ogtimization.

Appendix D

Chemform FYR

Page lS of lS September 2010

Appendix E

Photographs

Photo # 1: Card catalogue for Chemform Site in Broward County Public Library (April 20, 2010)

Photo #2: Binders of Chemform documents in Broward County Public Library

Appendix E Chemform FYR

·120 201

Page lof 3 September 2010


Photo #3 : Coast to Coast Building Products Inc. (date unknown)

Photo #4: Behind building, facing north. Note fence gate is locked. ·121 201


Photo #5: Monitoring Well MW-9 (April 21, 2010)

Photo #6: View of back of property, facing west. Monitoring well MW-9 is covered by the brush between the road and the fence .


. 21 201


Appendix F

Interview Summary

INTERVIEW DOCUMENTATION FORM

The following is a list of individuals interviewed for this five-year review. See the attached contact records for a detailed summary of the interviews.

Gregory S. Wilson

Name

Richard E. Marcus

Name

Peter Daniels

Name

Rodolfo Arambulo

Name

Kelsey Helton

Name

Name

Appendix F Chemform FYR

President

Title/Position

Co-Owner

Title/Position

Co-Owner

Title/Position

President

Title/Position

Precision Metal Industries, Inc.

Organization

BARD Realty

Organization

BARD Realty

Organization

Cadiz Realtv Comgany

Organization

Florida Department of Professional Geologist Environmental Protection

Title/Position Organization

Title/Position Organization

Page 1 of 6

Janua!:y 11, 2010 and Agril 21, 2010

Date

Agril 21, 2010

Date

Agril 21, 2010

Date

May 3,2010

Date

Date

Date

September 2010

I INTERVIEW RECORD

Site Name: Chemform Inc. EPA ID No.: FLD080174402

Subject: Prospective Purchaser Conference Call Time: 2:30 p.m. I Date: 01/11/2010

Type: ~ Telephone D Visit D Other D Incoming D Outgoing Location of Visit:

Contact Made By:

N arne: Samantha Urquhart-Foster I Title: Remedial Project Manager Organization: EPA, Region 4

Individual Contacted:

Name: Gregory S. Wilson I Title: President Organization: Precision Metal Industries, Inc.

Telephone No: Street Address: 1408 SW 8th ST E-Mail Address: City, State, Zip: Pompano Beach, FL 33069

Summary of Conversation

On January 11, 2010, EPA staff held a conference call with Gregory S. Wilson, President of Precision Metal Industries, Inc. (PMI) [formerly Wilson Concepts] and a prospective purchaser of the Site property. PMI is located adjacent to the Chemform property and is interested in purchasing the property to expand their business. PMI intended to use half of the building for storage purposes and the other half for production of casings for missiles for the United States Army. EPA explained the need for future ground water monitoring on the property in the near future, but that should not affect PMI's business operations. Mr. Wilson stated that a Phase I investigation had been completed and he would consider having a Phase II investigation conducted having his consultant coordinate with EPA to ensure the correct locations, depths, and types of samples were collected to meet everyone's needs. EPA encouraged the re-use of the property and stated that EPA would issue a status/comfort letter to PMI within the next two weeks.



I

INTERVIEW RECORD


Subject: Interview for purposes of 2010 Five-Year Review Time: 9:00 a.m. I Date: 04/21/2010

Type: o Telephone ~ Visit o Other o Incoming o Outgoing Location of Visit: 1410 SW 8th ST, Pompano Beach, FL

Contact Made By:

Name: Samantha Urquhart-Foster I Title: Remedial Project Manager Organization: EPA, Region 4


Name: Richard E. Marcus and Peter I Title: Co-owners of property at the Organization: BARD Realty Inc. Daniels time of the Site Inspection

Telephone No: Street Address: P.O. Drawer 160189 E-Mail Address: City, State, Zip: Miami, FL 33116-0189

Summary of Conversation During the Five-Year Review Site Inspection, the RPM interviewed the owners of the property. Coast-to-Coast, a company formerly owned by BARD Realty, began operations at the Site in 2000. BARD Realty sold their Coast-to-Coast business in 2008, but has had difficulty selling the property. At the time of the Site inspection, the property was under contract for sale to Cadiz Realty Company, pending results of a Phase II investigation. The property is landscaped once a month and a former employee drives by the facility weekly. Security lights are used in the evenings. At the time of the Site inspection, BARD Realty was allowing Sol Group Marketing to use the parking lot on the property. Sol Group Marketing is owned by Cadiz Realty Company and is located across the street from the Chemform Site. They were not aware of any vandalism at the Site. They were not aware of the location of any monitoring wells on the property, with the exception of MW-9. Mr. Daniels and Mr. Marcus stated that drinking water is provided by Broward County and there are no irrigation wells on the property. They had no concerns about the remedial action, other than how it may affect the sale of the property. The RPM informed the property owners that EPA would be glad to have a conference call and/or issue another status/comfort letter to prospective purchasers to answer environmental concerns that the prospective purchaser may have.



I llNlrJEJR VllJE W JRJECO RlIJ)

Site Name: Chemform Inc. EPA ID No.: FLDOS0174402

Subject: Interview for purposes of 2010 Five-Year Review Time: 9:30 a.m. I Date: 04/21/2010

Type: o Telephone [gI Visit o Other o Incoming o Outgoi~g Location or Visit: 1410 SW sth ST, Pompano Beach, FL

Contact Made By:



Name: Gregory S. Wilson ~ Title: President Organization: Precision Metal Industries, Inc.

Telephone No: Street Address: 140S SW Sth ST E-Mail Address: City, State, Zip: Pompano Beach, FL 33069

Summary of Conversation During the Site Inspection, the RPM interviewed the owner of the neighboring property, Precision Metal Industries, Inc. (PMI). PMI had considered purchasing the property, but decided not to. Mr. Wilson stated that he has been assisting another entity purchase the property by giving them as much background information that he had available. Mr. Wilson was very familiar with the prior soil removal action. He knew where one of the monitoring wells was located (MW-9), but did not know where any of the others were. He was not aware of any vandalism at the Site. He stated that drinking water in the area is provided by Broward County. He had no concerns about the remedial action and looked forward to the property being put back into use.

Appendix F

Chemform FYR


I

INTERVIEW RECORD

Site Name: Chemform Inc. EPA JD No.: FLD080174402

Subject: Prospective Purchaser Conference Call Time: 1:00 p.m. I Date: 05/03/2010

Type: I:8J Telephone D Visit D Other D Incoming D Outgoing Location of Visit:

Contact Made By:



Name: Rodolfo Arambulo I Title: President Organization: Cadiz Realty Company

Telephone No: Street Address: 550 Biltmore Way, Suite 730 E-Mail Address: City, State, Zip: Coral Gables, FL 33134


On May 3, 2010, EPA held a conference call with Cadiz Realty Company, a prospective purchaser of the property, and their attorneys. Cadiz Realty Company wishes to purchase the property to expand Sol Group Marketing's operations, which include food storage. Sol Group Marketing currently operates on property located across the street from the Chemform Site. They indicated that the only excavation activities that they intended to make at the property was to possibly install down-ramps in order for the trucks and loading dock to be at the right height for loading/unloading. This would involve digging one or more approximate three-foot deep hole(s) near the loading dock and then covering the excavated area with either concrete or asphalt to support truck parking. Due to the extensive soil removal action that occurred at the Site decades ago, EPA does not anticipate any problems with this type of construction. They were concerned about the possibility of vapor intrusion since they intend to use the building for food storage and volatile organic compounds have been detected in groundwater. EPA will review the recent data collected by their consultant and address this concern in a status/comfort letter which will be issued by EPA to Cadiz Realty Company within the next two weeks.

Appendix F

Chemform FYR


I INTERVIEW RECORD


Subject: Chemform FYR Time: I Date:

Type: 1:8] Telephone D Visit 1:8] Other D Incoming D Outgoing Location of Visit:

Contact Made By:

N arne: Samantha Urquhart-Foster I Title: Remedial Project Manager Organization: EPA, Region 4


Name: Kelsey Helton I Title: Professional Geologist Organization: Florida Department of Environmental Protection

Telephone No: 850-245-8969 Street Address: 2600 Blair Stone Road E-Mail Address: [email protected] City, State, Zip: Tallahassee, FL 32399


On several occasions during the FYR process, I spoke with and exchanged emails with Kelsey Helton of DEP. DEP's comments on the draft FYR are summarized below:

1) DEP agrees with the FYR recommendations that a) FYR should continue until groundwater ARARs are met; b) the status of the former ten site monitoring wells should be determined and plugged and abandoned where appropriate and wells can be located; and c) MW-10 should be located and plugged and abandoned if it lacks integrity.

2) Monitoring should include chlorinated solvents as well as arsenic with screen intervals in the appropriate zones. Since the deepest direct push sample at 60 feet below land surface still showed vinyl chloride above the cleanup goal, it appears that vertical delineation has not occurred to date. DEP recommends annual sampling until cleanup goals are met followed by two quarters of confirmatory sampling in accordance with Chapter 62-780. We would like to discuss the monitoring scope further with EPA before it is finalized.

3) The presence of significant concentrations of arsenic in TMW-1 suggest either an ongoing source or turbidity affecting the sample. Installation of permanent monitoring wells should help in resolving this and support evaluation of potential source areas. Groundwater results should be compared to the more recent arsenic groundwater standard of 10 I-Ig/I when determining that cleanup goals have been met.

4) Issues and recommendations in Tables 7 and 8, respectively, appear incomplete. DEP recommends they include the following: a) Issue- Missing monitoring wells may not have been plugged and abandoned according to state or federal regulations/guidelines. Recommendation- Locate and P&A wells that lack integrity or that will not be used to monitor plume or to confirm groundwater cleanup goals are met. b) Issue- Groundwater continues to show contamination above ARARs, particularly for chlorinated compounds particularly vinyl chloride, and arsenic. There are inadequate monitoring wells to characterize the plume, monitor attenuation and confirm groundwater cleanup goals are met. Recommendation-Develop and implement assessment and monitoring program that includes vertical delineation and installation of monitoring wells with appropriate screen intervals to effectively monitor plume and confirm cleanup goals are met. c) Issue- Arsenic in groundwater may indicate contribution from turbid sample or possible ongoing source. Recommendation- Install/develop appropriate monitoring wells to ensure representative samples and evaluate likely sources.

Each of DEP's concerns were incorporated into the revised FYR.

Appendix F

Chemform FYR


I