THIRD FIVE YEAR REVIEW REPORT FOR TRANS CIRCUITS INC. … · 2020-05-29 · electronic components and subassemblies for electronic circuit boards. In 1985, the facility closed, and

THIRD FIVE-YEAR REVIEW REPORT FOR TRANS CIRCUITS INC. SUPERFUND SITE

PALM BEACH COUNTY, FLORIDA

VVtD ST4%

saa

%

\

mcat

August 2017

Franklin E. Hill Director, Superfund Division

Prepared by

U.S. Environmental Protection Agency Region 4

Atlanta, Georgia

Date

11069959

Table of ContentsLIST OF ABBREVIATIONS & ACRONYMS........................................................................................ ivI. INTRODUCTION....................................................................................................................................1

Site Background.......................................................................................................................................IFIVE-YEAR REVIEW SUMMARY FORM..........................................................................................3

II. RESPONSE ACTION SUMMARY...................................................................................................... 3Basis for Taking Action.......................................................................................................................... 3Response Actions.................................................................................................................................... 4Status of Implementation........................................................................................................................ 5Systems Operations/Operation & Maintenance...................................................................................... 6

III. PROGRESS SINCE THE LAST REVIEW..........................................................................................8IV. FIVE-YEAR REVIEW PROCESS...................................................................................................... 8

Community Notification, Involvement & Site Interviews.......................................................................8Data Review............................................................................................................................................ 9Site Inspection........................................................................................................................................13

V. TECHNICAL ASSESSMENT.............................................................................................................13QUESTION A: Is the remedy fimctioning as intended by the decision documents?...........................13QUESTION B: Are the exposure assiimptions, toxicity data, cleanup levels and RAOs used at thetime of the remedy selection still valid?................................................................................................14QUESTION C: Has any other information come to light that could call into question the protectiveness of the remedy?................................................................................................................14

VI. ISSUES/RECOMMENDATIONS......................................................................................................14OTHER FINDINGS.............................................................................................................................. 15

VII. PROTECTIVENESS STATEMENT.................................................................................................15VIII. NEXT REVIEW............................................................................................................................15APPENDIX A - REFERENCE LIST.....................................................................................................A-1APPENDIX B - CURRENT SITE STATUS......................................................................................... B-1APPENDIX C - SITE CHRONOLOGY................................................................................................ C-1APPENDIX D - SITE MAPS.................................................................................................................D-1APPENDIX E - SITE INSPECTION CHECBCLIST...............................................................................E-1APPENDIX F - PRESS NOTICE...........................................................................................................F-1APPENDIX G - SITE INSPECTION PHOTOS.................................................................................... G-1APPENDIX H - DETAILED APPLICABLE OR RELEVANT AND APPROPRIATEREQUIREMENTS (ARARS) AND TOXICITY REVIEW.................................................................. H-1APPENDIX I - INTERVIEW FORMS....................................................................................................I-lAPPENDIX J - MEMORANDUM OF AGREEMENT......................................................................... J-1

Tables

Table 1: COC Cleanup Goals.................................................................................................................... 5Table 2: Protectiveness Determinations/Statements from the 2012 FYR................................................. 8Table 3: Status of Recommendations fi-om the 2012 FYR........................................................................ 8Table 4: Maximum COC Concentrations Compared to ROD Cleanup Goals, October 2016................ 10

Table 5: Results from PAH Sampling in 2012 - BaP Equivalents.......................................................... 11Table 6: Results from Subslab Soil Vapor, April 2013.............................................................................12Table 7: Results from Ambient Air Sampling, July 2013.........................................................................12Table C-1: Site Chronology................................................................................................................ . C-1Table H-1: Groimdwater ARARs Review............................................................................................. H-1Table H-2: Soil Cleanup Goal Review.................................................................................................. H-1Table H-3: Screening Level Vapor Intrusion Assessment for Commercial Use.................................... H-2Table H-4: Screening Level Vapor Intrusion Assessment for Future Residential Use.......................... H-3

Figures

Figure 1: Detailed Site Map....................................................................................................................... 2Figure 2: Institutional Control Map........................................................................................................... 7Figure D-1: Site Vicinity Map............................................................................................................... D-1Figure D-2: Monitor Well Location Map.............................................................................................. D-2Figure D-3; Remedial Action PAH Soil Sample Locations.................................................................. D-3Figure D-4: Subslab Vapor and Air Sampling Locations...................................................................... D-4

LIST OF ABBREVIATIONS & ACRONYMS

ARAR Applicable or Relevant and Appropriate RequirementBaP Benzo(a)pyreneCERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal RegulationsCOC Contaminant of ConcernDCE DichloroethyleneEPA United States Environmental Protection AgencyESD Explanation of Significant DifferencesFDEP Florida Department of Environmental ProtectionFDER Florida Department of Environmental RegulationFYR Five-Year ReviewHI Hazard IndexHQ Hazard QuotientJ&E Johnson and EttingerMCL Maximum Contaminant Levelpg/kg Micrograms per Kilogrampg/L Micrograms per Literpg/m^ Micrograms per Meter Cubedmg/kg Milligrams per KilogramMOA Memorandum of AgreementNCP National Contingency PlanNPL National Priorities ListG&M Operation and MaintenanceOU Operable UnitPAH Polycyclic Aromatic HydrocarbonPCE TetrachloroethylenePRP Potentially Responsible PartyRAO Remedial Action ObjectiveROD Record of DecisionRPM Remedial Project ManagerRSL Regional Screening LevelSCTL Soil Cleanup Target LevelSFWMD South Florida Water Management DistrictTCE TrichloroethyleneUU/UE Unlimited Use and Unrestricted ExposureVISE Vapor Intrusion Screening LevelVOC Volatile Organic Compound

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

The U.S. Environmental Protection Agency is preparing this FYR pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 121, consistent with the National Contingency Plan (NCP) (40) Code of Federal Regulations (CFR) Section 300.430(f)(4)(ii)), and considering EPA policy.

This is the third FYR for the Trans Circuits, Inc. Superfund site (the Site). The triggering action for this policy review is the completion date of the previous FYR. The FYR has been prepared due to the fact that hazardous substances, pollutants or contaminants remain at the Site above levels that allow for unlimited use and unrestricted exposure (UU/UE).

The Site consists of one operable unit (OU), which includes contaminated soil and groundwater.

The EPA led the FYR. Participants included EPA Remedial Project Manager (RPM) Marcia O’Neal, Kelsey Helton from the Florida Department of Environmental Protection (FDEP) and Kirby Webster from EPA’s contractor Skeo. The review began on 9/12/2016. A list of documents reviewed as part of this FYR is included in Appendix A. A summary of the current site status is included in Appendix B.

Site BackgroundThe approximately l-acre Site is located at 210 Newman Road in the southwestern quadrant of Lake Park, Palm Beach County, Florida (Figure D-1). The Site is partially asphalt-paved and includes one building, a 21,000-square-foot facility owned by Florida Aero Precision. The building houses a machine shop for aircraft engine and industrial gas turbine parts (Figure 1). The Site also includes a graded area. This area, north of the building, was the location of the former evaporation-percolation pond. An inactive rail line extends across the northern portion of the Site.

From 1976 until 1978, Etched Products, Inc. owned and operated an electroplating business on site. From 1978 until 1985, Trans Circuits, Inc. operated an electroplating and manufacturing plant of electronic components and subassemblies for electronic circuit boards. In 1985, the facility closed, and the company dismantled its treatment systems. In 2001, Direct Access International began operating a recycling business transforming post-consumer materials into clothing on site. In 2004, Direct Access International purchased the Site. In 2011, Florida Aero Precision purchased the Site. Appendix C includes a site chronology. Liquid wastes from the former electroplating processes were released to the soil and groundwater. The three main source areas include: 1) the partially lined former evaporation-pereolation pond, 2) the contaminated soil detected in the former drainfield area and 3) the contaminated soil area near the old rail spur in the northeast comer of the Site (see Figure 1 for the three areas). The shallow and Floridan aquifers imderlie the Site. The shallow aquifer is unconfmed and is the sole source of potable groundwater in the area. The Floridan aquifer is below the shallow aquifer. It is brackish and is not used for potable water in the area.

Figure 1: Detailed Site Map

'mm

Code Source AreaFormer evaporation-percolation pond Former drainfield area

ion near the old rail spur

Newman Road

Sources: 2012 FYR, Esii, DeLorme, DIgItalGlobe, GeoEye, Earlhstar Geographies, CNES/Airbus DS, AND, USDA, AEX, Getmapping, Aerogrid, IGN, IGF. swisstopo, Tele Atlas, First Americat), UNEP-WCMC and USGS.

Site Boundary II I 11 Current Parking LotHR Florida Aero Precision Former Percolation Pond

NORTH

Trans Circuits, Inc. Superfund SiteCity of Lake Park, Palm Beach County, Florida

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding EPA’s response actions at the Site.

FIVE-YEAR REVIEW SUMMARY FORM

sn r IDFNIIHCATION

Site Name: Trans Circuits, Inc.

EPA ID: FLD091471904

Region: 4 State: Florida City/County: Lake Park/Palm Beach

s TF SALS

NPL Status: Final

Multiple OUs?No

Has the site achieved construction completion?Yes

KFV lENA STATUS

Lead agency: EPA

Author name: Marcia O’Neal (EPA) and Kirby Webster (Skeo)

Author affiliation: EPA and Skeo

Review period: 9/12/2016 - 9/19/2017

Date of site inspection: 1/10/2017

Type of review: Policy

Review number: 3

Triggering action date: 9/19/2012

Due date (fiveyears after triggering action date): 9/19/2017

II. RESPONSE ACTION SUMMARY

Basis for Taking ActionIn 1983, the Florida Department of Environmental Regulation (FDER, now FDEP) received an anonymous complaint concerning storage of hazardous waste at the facility. Site investigations identified visible sludge in the evaporation/percolation pond and puddles of liquid surrounding the pond perimeter. About 100 55-gallon drums of unidentified waste were located in the treatment area on site.

The Site’s 1988 Final Expanded Site Inspection/Remedial Investigation identified elevated concentrations of organic and inorganic contamination in on-site surface and subsurface soil samples. Investigations also identified elevated concentrations of organic and inorganic compounds in off-site subsurface soil samples and in groundwater. In 2000, a remedial investigation was completed. The baseline risk assessment demonstrated that future exposure of workers and residents to contaminated surface soil resulted in unacceptable health risks. In addition, future residential exposure to contaminated groundwater resulted in unacceptable health risks.

Response ActionsIn 1981, the EPA sampled the City of Riviera Beaeh public wellfield for volatile organic compounds (VOCs) as part of a study of water supplies in South Florida. Results from this sampling event and later sampling events indicated the presence of chlorinated hydrocarbons in seven of the 18 wells in the field. FDER conducted an in-depth study of groundwater contamination at the Riviera Beach wellfield from February to May 1985 and concluded that the Trans Circuits discharge was responsible for the contamination of the City of Riviera Beach municipal well PW-17.

The Riviera Beach Water Department took the PW-17 municipal well out of service in 1984 due to the contamination. Trans Circuits discontinued operations in 1985. In 1987, Trans Circuits installed an air stripper treatment system to reduce the levels of tetrachloroethylene (PCE) and trichloroethylene (TCE). The system treated more than 1 million gallons of groundwater during its two years of operation. In 1988, the City of Riviera Beach installed air stripping towers at its water plant to treat area-wide VOC contamination in the groundwater. The City of Riviera Beach still operates large-scale air stripping towers.

Between 1989 and 1998, the EPA and FDEP conducted several investigations at the Site. By 1998, it was determined that further action under the EPA’s Superfund program was necessary. Trans Circuits did not have sufficient resources to address the contamination, and the EPA could not identify any other known viable potentially responsible parties (PRPs). Therefore, the EPA has conducted site investigations and cleanup using federal Superfund resources.

The EPA finalized the Site on the Superfund program’s National Priorities List (NPL) on February 4, 2000.

Remedial action objectives (RAOs) identified in the Site’s 2001 Record of Decision (ROD) consisted of:

• Reducing the human health risk from soil contamination to within the EPA’s acceptable risk range (i.e., total residual cancer risk between 1 x 10"^ to 1 x 10"^ and a maximum individual contaminant hazard quotient (HQ) of 1). (The 2010 Explanation of Significant Differences (ESD) updated the soil cleanup from industrial to residential exposure).

• Restoring groundwater to maximum contaminant levels (MCLs) or to within the EPA’s acceptable risk range (i.e., total residual cancer risk between 1 x 10"^ to 1 x 10'^ and a maximum

individual contaminant HQ of 1).

Remedy components identified in the Site’s 2001 OUl ROD and modified in the Site’s 2010 ESD include:

• Funding for the operation and maintenance (O&M) of the City of Riviera Beach water treatment plant air stripping towers until the plume is isolated from the wellfield by relocation of PW-17.

• Construction of a new municipal well outside of the contaminated plume area and abandonment of municipal well PW-17.

• In-situ bioremediation of the plume via injection of amendments such as ethyl lactate, through injection wells in the surficial aquifer.

• Natural attenuation of fluoride and nickel if not addressed by oxidation.

• Restriction of future potable well construction through the March 2010 Memorandum of Agreement (MOA) between the EPA and the South Florida Water Management District (SFWMD) until groundwater cleanup goals are met.

• Excavation of polycyclic aromatic hydrocarbon (PAH) contaminated surface soils and dispose of them off site to achieve UU/UE levels, if PAH contamination is confirmed to be the result of site-related activities.

Table 1 shows contaminant of concern (COC) cleanup goals defined in the decision documents.

Table 1: COC Cleanup Goals

COC ROD Soil Cleanup Goal (mg/ks)

ROD Groundwater Cleanup Goal (pg/L) Basis

Carcinogenic PAHs (toxicity equivalence factor)

O.U - FDEP SCTL

PCE ~ 3 ARAR (state primary MCL)TCE ~ 3 ARAR (state primary MCL)1,2-Dichloroethylene (DCE) - 70 ARAR (federal/state primary MCL)Chloroform

- 6 FDEP guidance concentrations and risk assessment

Vinyl chloride ~ P ARAR (state primary MCL)Nickel ~ 100 ARAR (federal/state primary MCL)Fluoride - 2,000 State secondary MCLNotes:a. The 2010 ESD updated the 2001 ROD industrial cleanup goal of 0.5 mg/kg for benzo(a)pyrene, to allow for UU/UE.b. Vinyl chloride was not detected in remedial investigation sampling but is a known breakdown product of TCE and

PCE and has been found in the Riviera Beach wellfield. Therefore, a goal was set in the 2001 ROD to address any residual vinyl chloride that might result over time from site cleanup or natural attenuation of the contaminants.

SCTL = Soil Cleanup Target LevelARAR = Applicable or Relevant and Appropriate Requirement mg/kg = milligrams per kilogram pg/L = micrograms per liter — = cleanup goal not required for this COC.Source: Table 12-3 of the 2001 ROD, unless otherwise noted.

Status of ImplementationThe EPA is implementing the Site’s remedy in three phases. Phases 1 and 2 are complete. Phase 3 is currently underway.

Phase 1 - Funding of Air Strippers: The EPA entered into an agreement with the City of Riviera Beach and used federal Superfund money to reimburse the City for O&M expenses for the City’s air stripping towers from October 2002 to January 2006. The towers removed VOCs from the municipal water supply.

Phase 2 - Municipal Supply Well Construction/Soil Excavation: The EPA began phase 2 of the cleanup in October 2002 and completed it in early 2006. During this time, the EPA designed the well to replace PW-17 and obtained the necessary permits for its construction. In 2005, the EPA also completed

construction of the well and nearly two miles of piping to transfer water from the new well to the municipal water treatment system.

The EPA recommended the City of Riviera Beach abandon PW-17. As of 2017 it has not been abandoned. It is not currently being used.

In September 2003, the EPA began excavating PAH-contaminated soil from the former percolation pond. This effort included the excavation of seven cubic yards of contaminated soil, removal of a block wall, post-excavation confirmation sampling, disposal of excavated soils and drums, and site restoration. The EPA received analytical results from the excavation area and removed additional soil in one quadrant so that all samples met industrial cleanup standards for PAHs. The EPA completed the removal action on January 26, 2004.

Additional soil sampling conducted in 2012, after the signing of the 2010 ESD, is discussed in Data Review. The 2010 ESD modified the soil remedy from industrial standards to UU/UE.

Phase 3 - Treatment of Contaminated Groundwater: Installation of monitoring wells and potential injection wells as part of the groundwater treatment remedy began in the spring of 2012. The EPA contractors completed the first bio-amendment injection on August 30, 2013. Groundwater monitoring is ongoing to monitor concentrations of COCs.

Institutional Controls ReviewAn MOA between the EPA and the SFWMD was put in place in 2010 (Appendix J). It provides the framework for the EPA and SFWMD’s agreement to restrict groundwater usage in the area of groundwater impact from the Site. Specific requirements are detailed in the MOA in Appendix J. Figure 2 shows the 2014 location of the plume, based on a limited monitoring performance monitoring data,set. It also shows the two zones of restricted groundwater use. Zone A represents the contaminated zone while Zone B represents the buffer zone. The EPA should update the Zone A and Zone B locations based on current site conditions.

Systems Operations/Operation & MaintenanceThe 2013 Enhanced In-Situ Bioremediation Injection System 0«feM Plan presents an approach to deliver electron donor and dechlorinating microorganisms to the subsurface using a network of injection wells. However, the 2013 0«feM Plan does not address requirements for injection well installation activities, monitoring or reporting. The O&M Plan should be updated to include all O&M requirements to ensure remedy performance evaluation. The 2001 ROD estimates annual O&M costs to be $42,400.

Figure 2: Institutional Control Map

'Mis:,. i

11. -1.

&I7 “* -f

•’'ill :'

ri-', '

'î %-,^

IS!-'

VI«i ia .a

r. ^ rs"' 2; T y J|

1 ,»■ ■

j:, , N

msm\\ \mî'WP-War^---'

r ? »rr|J

n-f *«' i» mm

&xf

0 250 500 1,000 I Feet

Sources: Black and Veatch, South Florida Water Managment District, 2001 ROD, 2010 MOA, 2012 FYR, Esri. DeLorme, DigitalGlobe, GeoEye, Earthstar Geographies, CNES/Airbus DS, AND. USDA.AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo. Tele Adas, First American, UNEP-WCMC and USGS.

I i Site BoundaryiZ- Zj Groundwater Contamination in 2001 ROD m Contaminant Plume in 2014 i Zone A from 2010 MOA■I Zone B from 2010 MOA

0sksKeoSOLUTIOMS NORTH

Trans Circuits, Inc. Superfund SiteCity of Lake Park, Palm Beach County, Florida


III. PROGRESS SINCE THE LAST REVIEWTables 2 and 3 includes the protectiveness determinations and statements from the last FYR as well as the recommendations from the last FYR and the current status of those recommendations.

Table 2; Protectiveness Determinations/Statements from the 2012 FYR

OU# Protectiveness DeterminationWill be Protective

Protectiveness StatementThe remedy at the Site is expected to be protective of human health and the environment upon full scale implementation. In the interim, exposure pathways that could result in unacceptable risks are being controlled. The soil remedy implemented to date is protective of the industrial use currently supported by the Site and an MOA is in place restricting use of ground water. The vapor intrusion pathway is being further evaluated to resolve the conflicting results from previous sampling events and to take into account the changes in building configuration and new VOC toxicity values which were updated in May 2012.

Table 3: Status of Recommendations from the 2012 FYR

OU# Issue

The vapor intrusion pathway needs to be further evaluated due to conflicting lines of evidence and a change in the use of the building.

Recom mendations

Conduct another sampling event in the room in question. Reevaluate the vapor intrusion based on these sample results.

CurrentStatus

Completed

CurrentImplementation Status

DescriptionThe Vapor Intrusion and Ambient Air Sampling Data Summary Report further evaluates the vapor intrusion pathway.

CompletionDate

10/28/2013

IV. FIVE-YEAR REVIEW PROCESS

Community Notification. Involvement & Site InterviewsA public notice was made available by newspaper posting in the Palm Beach Post, bn 8/10/2017. Appendix F includes the press notice. It stated that the FYR was underway and invited the public to submit any comments to EPA. The results of the review and the report will be made available at the Site’s information repository, Riviera Beach Public Library, located at 600 West Blue Heron Boulevard in Riviera Beach.

During the FYR process, interviews were conducted to document any perceived problems or successes with the remedy that has been implemented to date. Completed interview forms are included in Appendix I. The results of these interviews are summarized below.

Interviewees had a favorable impression of the remedy at the Site. EPA RPM Marcia O’Neal reported that another round of injections may be necessary for the groundwater remedy. She is not aware of any commimity concerns regarding the Site. She does not have any additional comments, suggestions or recommendations regarding the management or operation of the Site’s remedy. Greg Roof, O&M contractor, reported that the remedy appears to be effective and monitoring data appears to indicate that the contamination concentrations are decreasing. Dan Reardon, contractor for the current site owner, reported that the biggest impact on the community has been the Site’s successful reuse, which has brought jobs to the area. He reported that there have been instances of trespassing and stealing from the

8

facility. He suggested it may be helpful for Florida Aero Precision to have materials such as a newsletter or fact sheet on hand to provide site information to interested neighbors. Kelsey Helton, FDEP, provided feedback on the draft FYR. These comments are included in Appendix I. FDEP was generally in agreement with the findings of the FYR.

Data ReviewThis data review section provides a summary of the groundwater, soil and vapor intrusion data collected since the last FYR to evaluate the performance of the groundwater and soil remedy.

GroundwaterThe current extent of the groundwater plume is minimal compared to the previous location of the plume. Figure 2 shows the approximate groundwater plume location at three points in time: in 2001, when the ROD was signed; in 2010, when the MO A agreement to restrict groundwater use was put in place; and in 2014, based on a limited monitoring performance monitoring data set.

The EPA contractors completed the first bio-amendment injection within the two plume areas on August 30, 2013. Post-injection samples were collected from eight performance monitoring wells in December2013, March 2014, June 2014, September 2014 and from 11 performance monitoring wells in December2014. To provide an understanding of the current Site conditions, post-injection samples were collected from 43 monitoring wells in October 2016. These results were reported in the 2017 Technical Memorandum Remedial Action Performance for Trans Circuits Superfund Site. The location of all monitoring wells is included in Figure D-2.

Table 4 shows the maximum contaminant concentrations from the 2016 sampling event for each contaminant. As shown in Table 4, total 1,2-dichloroethylene (DCE) and vinyl chloride are the only COCs currently detected above ROD cleanup goals. Concentrations of COCs at the Site have significantly reduced in many wells located within the treatment areas. The 2017 Technical Memorandum included the following observations on COC concentration trends:

• In 2012 and 2013 prior to the injection event, 25 monitoring wells associated with this Site had total-DCE concentrations in excess of ROD cleanup levels. In the most recent sampling event, the only locations with DCE in excess of the ROD cleanup levels are MW 121, MW12D, MW15D, MW51D, and MW52D. All of these wells are located significantly downgradient of the source. Monitoring well MW52D to the east of the treatment zones contained the highest DCE concentration at 496 micrograms per liter (pg/L). In 2012, prior to the injection, the

concentration was 393 pg/L, indicating the injection had little effect on the COCs in this area, which is expected since the injection occurred approximately 160 feet away from MW52D. No wells near the previous treatment zones contained a DCE concentration in excess of the ROD cleanup level, indicating the initial injection was effective at progressing the COC attenuation.

• Prior to treatment (2012 and 2013 monitoring events), vinyl chloride did not exceed ROD cleanup levels in any well at the Site. After the injection vinyl chloride increased in multiple wells. Over the 5 years since the injection, the vinyl chloride concentrations decreased. In 2016, vinyl chloride exceeded cleanup goals in eight monitoring wells MW27D, MW46D, MW47D, MW48D, MW49D, MW50D, MW52D, and MW56D. Treatment Zone A contains five of these wells. Two are located within Treatment Zone C. MW52D, located east of the treatment zones, is

the only well outside of the original treatment zones containing vinyl chloride concentrations in excess of ROD cleanup levels.

The 2017 Technical Memorandum concluded the injections were successful, however uncertainty exists relating to the more downgradient wells to the north and south. The DCE concentrations in MW12I and MW12D to the northeast and the DCE concentrations in MW15D to the southeast do not have accompanying vinyl chloride detections to indicate that a reduction is occurring at these locations. Also, due to the lack of wells in these areas, the size and severity of COCs are unknown. The 2017 Technical Memorandum provides recommended next steps for the groimdwater remedy. EPA and DEP are reviewing the recommendations and determining next steps for the groundwater remedy.

Table 4: Maximum COC Concentrations Compared to ROD Cleanup Goals, October 2016

cocPCETCETotal 1,2-DCEChloroformVinyl chlorideNickelFluoride

CleaaupGk»ab(Mg/L)

1002,000

Maximum Detectkm (Pg/L)lOUlOU49610 U

1,800

WellMW26D and MW45DMW26D and MW45D

MW52DMW26D and MW45D

MW52DMW41DER4S

Notes:U = material was analyzed for but not detected.J = estimated value |ig/L = micrograms per literSource: Remedial Action Performance for Trans Circuits Superfiind Site, April 2017.

Detection limits for PCE, TCE and chloroform exceed the ROD cleanup goal for some samples. Appropriate collection methods should be used to ensure that the sample detection limits are lower than ROD cleanup goals.

Soil - PAH SamplingSubsurface soil sampling was conducted in 2012 to determine whether on-site PAH contamination was above UU/UE levels and whether the contamination was site related. Surface and subsurface soil sampling occurred between the former rail spur and the former percolation pond area, and in the parking lot south of the building where the highest PAH concentrations were observed during the remedial design. Soil samples were collected at depths of approximately 0 to 6 inches and 6 inches to 2 feet below asphalt in the parking area and lime rock in the other areas. Table 5 shows sampling results for benzo(a)pyrene equivalents (BaP Equivalents); Figure D-3 shows the locations of the samples.’ The 2010 ESD cleanup goal for PAHs is 100 micrograms per kilogram (pg/kg), which is Florida’s residential Soil Cleanup Target Level (SCTL) for BaP.^

‘ The toxicity of the seven carcinogenic PAHs are based on the relative potency of each compound relative to that of BaP and expressed as toxic equivalents of BaP (BaP Equivalents) using toxicity equivalency factors.

^ Available at https://www.dep.state.fl.us/waste/auick topics/rules/documents/62-777/62-777 Tablell SoilCTLs.pdf.10

Table 5: Results from PAH Sampling in 2012 - BaP Equivalents

Sample Depth BaP Equivalent QtgAg) Location

106 0 to 6 inches 26.857 South Parking Lot107 0 to 6 inches 163.18 South Parking Lot108 0 to 6 inches 128.14 Between Rail Spur and Fortner Percolation Pond109 0 to 6 inches 0.09253 Between Rail Spur and Former Percolation Pond

106 6 inches to 2 feet 64.689 South Parking Lot

107 6 inches to 2 feet 14.161 South Parking Lot

108 6 inches to 2 feet 6.3177 Between Rail Spur and Former Percolation Pond

109 6 inches to 2 feet 1.5182 Between Rail Spur and Former Percolation Pond

110 2 to 4 feet 1.47220.09857 Estimated to Be Outside Former Percolation Area

2 to 4 feet 0.0755 Estimated to Be Outside Former Percolation Area2 to 4 feet 0.094 Estimated to Be Outside Former Percolation Area2 to 4 feet Estimated to Be Within Percolation Pond Area2 to 4 feet 53.471 Estimated to Be Within Percolation Pond Area

Notes:Bold = exceeds Site cleanup goal, Florida’s SCTL of 100 pg/kg pg/kg = micrograms per kilogramSource: Table 1 of the Polycyclic Aromatic Hydrocarbon Memorandum, January 2013

The 2013 PAH Memorandum concluded that samples locations where concentrations of BaP Equivalents exceed the Site’s cleanup goal are not site related. The exceedance between the rail spur and former percolation pond is considered an isolated incident, because samples below this depth and surrounding locations do not exceed the cleanup goal. Therefore, the soil does not require further excavation. Samples in the south parking lot confirm that PAH contamination found in this area is attributable to the overlying asphalt and is not site related.

Vapor Intrusion SamplingIn response to an issue raised during the last FYR, additional vapor intrusion sampling was conducted in April 2013 and July 2013. Sampling included subslab soil vapor (Table 6) and ambient air (Table 7). Five subslab samples were collected within the footprint of the room historically referred to as the Cutting Room (samples WMSOOl through WMS005). At the request of the EPA, ambient air sampling was also conducted in the Cutting Room (Sample AAOOI) in July 2013. The sampling was conducted in the vicinity of the subslab soil vapor sampling locations WMS004 and WMS005, which historically showed the highest subslab results for PCE and TCE. Background ambient air locations inside the Florida Aero Precision building (samples AA002 through AA004) and outside of the Florida Aero Precision building (samples AA005 and AA006) were sampled to assess the potential generation of COCs from ongoing manufacturing activities. The soil vapor and air sampling locations are presented in Figure D-4.

As shown in Table 6, PCE and TCE were detected in samples WMSOOl through WMS005; however, cis-DCE, trans-DCE and vinyl chloride levels were below laboratory method detection limits. As shown in Table 6, the highest subslab results for PCE and TCE were at locations WMS004 and WMS005, respectively. The Vapor Intrusion and Ambient Air Sampling Data Summary Report conducted vapor intrusion risk screening using the Vapor Intrusion Screening Level (VISE) calculator and Johnson and

Ettinger (J&E) Soil Gas Model using maximum concentrations of PCE (200 micrograms per meter cubed [pg/m^]) and TCE (190 pg/m^). The VISE model results indicated cancer risk greater than 1x10"

but within the EPA’s risk management range of 1 x 10'® to 1 x 10^ for PCE and TCE for the commercial and future residential scenarios. The noncancer HQs exceeded the target level of 1 for TCE for residential and commercial scenarios, 9 and 2, respectively. The J&E model incorporates site-specific parameters, whereas the VISE calculator uses default parameters. The J&E model risk and HQs were lower than the VISE model, with cancer risk slightly greater than 1x10'® for TCE in a future residential scenario (1.9 x 10"^) and below 1 x lO'^ for the commercial scenario; both scenarios were within the EPA risk management range. The J&E model HQ results also were below the target of 1.0 for both the commercial and future residential scenario.

Results from indoor air sampling. Table 7, indicate the slab underlying the building limits infiltration of subslab soil vapor. Much lower PCE and TCE concentrations are measured in indoor air than modeling predicts. The concentrations in the indoor air sample from the Cutting Room are similar to the concentrations in air collected from other building locations (AA002 through AA004) and outside of the building (AA005 and AA006). This FYR re-evaluates the VISE calculation for both industrial and residential exposures in Appendix H. The vapor intrusion risk results for commercial industrial exposure are within the EPA risk targets for both subslab modeled into indoor air and measured indoor air (Table H-3). The noncancer HQ is exceeded for a future resident based on modeled indoor air from subslab soil vapor (Table H-4). However, the measured indoor air indicates that the slab is mitigating this pathway; the indoor air risks are within the EPA target levels.

Table 6: Results from Subslab Soil Vapor, April 2013

Sample PCE (nB/m*) TCEWMSOOl 50 33WMS002 35 20WMS003 46 61WMS004 200 130WMS005 170 190Notes:pg/m^ = micrograms per meter cubedSource-. Table 2 of the Vapor Intrusion and Ambient Air Sampling Data SummaryReport, October 2013

Table 7: Results from Ambient Air Sampling, July 2013

Sample PCE (pg/m^) TCE (pg/m^)AAOOl 0.68 2.0AA002 0.60 1.9AA003 0.60 2.1AA004 0.95 .1.8AA005 0.43 —AA006 0.68 —Notes:— =non-detectpg/m^ = micrograms per meter cubedSource-. Vapor Intrusion and Ambient Air Sampling Data Summary Report, October 2013

Site InspectionThe site inspection took place on 1/10/2017. In attendance were Marcia O’Neal (EPA RPM), Dan Reardon (Alltech Environmental, the current property owner’s contractor), and Kirby Webster and Kelly MacDonald (Skeo). The purpose of the inspection was to assess the protectiveness of the remedy. Appendix E includes the site inspection checklist. Appendix G includes site inspection photos.

Participants viewed site groundwater wells behind JAS Marine, the property that neighbors the Site, where recent injections have occurred. All wells appeared to be in good condition, though as discussed in remedial action reports, issues with blocked screens have occurred recently. Participants discussed the location of the recent injections and rounds of monitoring since the injections. An additional round of sampling took place in October 2016. After evaluating the sampling results, the EPA will determine if an additional round of injections is necessary to reduce contamination concentrations in the groundwater plume. Generally, the groundwater plume has reduced in size and the groundwater remedy is progressing as anticipated.

Inspection participants toured Florida Aero Precision’s facility on site. The site property is fenced and gated. Surveillance cameras surrounding the building are readily visible. Participants viewed the Cutting Room, where recent vapor intrusion analysis occurred. The current site owner is interested in expanding the building (over the former percolation pond area) and discussed potential barriers to this expansion with the EPA.

Skeo visited the Site’s document repository, Riviera Beach Public Library, located at 600 West Blue Heron Boulevard in Riviera Beach. The repository contained all documents pertinent to the Site, except for the 2012 FYR.

V. TECHNICAL ASSESSMENT

QUESTION A: Is the remedy ftmctioning as intended by the decision documents?

Question A Summary:

The remedy is functioning as intended by decision documents. Site-related contaminated soil has been cleaned up to UU/UE. The groundwater remedy is ongoing. Part of the remedy in the 2001 ROD included the abandonment of PW-17. It has not yet been abandoned. The abandonment of PW-17 should be documented or decision documents should be updated, as appropriate. The groundwater plume has decreased significantly since the signing of the ROD. EPA contractors completed the first bioamendment injection in August 2013. To provide an imderstanding of the current Site conditions, postinjection samples were collected from 43 monitoring wells in October 2016. Post-injection monitoring indicates that residual levels of 1,2-DCE and vinyl chloride remain above cleanup goals. Detection limits of other site VOCs are greater than cleanup goals. The detection limits should be lower than ROD cleanup goals to effectively monitor remedy performance. EPA and FDEP are evaluating next steps for the groundwater remedy.

Institutional controls in the form of an MOA have been put in place with SFWMD for groundwater use. No exposures to contaminated media are occurring.

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

Question B Summary:

The exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of the remedy selection are still valid. Appendix H includes a review of ROD and ESD cleanup goals compared to current standards. During this FYR period, the EPA re-evaluated the vapor intrusion pathway using multiple lines of evidence. The noncancer HQ is exceeded for a future resident based on modeled indoor air from subslab soil vapor (Appendix H). However, the measured indoor air indicates that the slab is attenuating this pathway as the indoor air risks are within EPA target levels. If residential use is considered at this location, the vapor intrusion pathway should be re-evaluated to ensure protectiveness at that time.

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

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

VI. ISSUES/RECOMMENDATIONS

Issiics/Reconimcmlations

OU(s) without Issues/Recommendations Identified in the FYR:None

Issues and Recommendations Identified in the FYR:

OU(s): OUl Issue Category: Monitoring

Issue: Some sampling detection limits are higher than contaminant cleanup goals.

Recommendation: Ensure contaminant detection limits are lower than cleanup goals for future sampling events.

Affect Current Protectiveness

Affect Future Protectiveness

PartyResponsible

Oversight Party Milestone Date

No Yes EPA EPA 12/1/2017

OTHER FINDINGSIn addition, the following recommendations were identified during the FYR. They do not affect current and/or future protectiveness:

• The O&M Plan should be updated to reflect current site conditions to ensure remedy performance can be evaluated for both chlorinated solvent and the nickel/fluoride plumes.

• Update the map associated with the MOA with updated Zone A and Zone B areas after additional groundwater assessment is completed downgradient of the initial treatment area to determine the magnitude and extent of site related contamination.

• If Site land use changes to residential use, the vapor intrusion pathway should be re-evaluated.• Part of the remedy in the 2001 ROD included the abandonment of PW-17. It has not yet been

abandoned. Document the abandonment of PW-17 or update decision documents, as appropriate. If the well is placed back in service, routine monitoring should be required.

• Ensure Site monitoring wells are locked.

VII. PROTECTIVENESS STATEMENT

Silcnidc Pi-otcctivciuss StatementProtectiveness Determination: Short-term ProtectiveProtectiveness Statement:The remedy at the Site currently protects human health and the environment because there are no completed exposure pathways. However, in order for the remedy to be protective in the long term, contaminant detection limits need to be lower than Site cleanup goals during sampling events.

VIII. NEXT REVIEW

The next FYR Report for the Trans Circuits, Inc. Superfund site is required five years from the completion date of this review.

APPENDIX A - REFERENCE LIST

Enhanced In-Situ Bioremediation Injection System Operations & Maintenance Plan. Trans Circuits Site. Lake Park, Florida. April 2013.

EPA Superfund OUl Record of Decision: Trans Circuits, Inc. OUl Lake Park, Florida. U.S. EPA Region 4. April 12, 2001.

Explanation of Significant Differences. Trans Circuits, Inc. Superfimd Site. U.S. EPA Region 4. September 2010.

Final Expanded Site Inspection/Remedial Investigation. Trans Circuits, Inc. Lake Park, Palm Beach County, Florida. Prepared by: Black & Veatch Special Projects Corp. for the Waste Management Division. U.S. Environmental Protection Agency Region IV. October 30, 1998.

Five-Year Revie Report. Second Five-Year Review Report for Trans Circuits, Inc. Lake Park, Palm Beach County, Florida. September 9, 2012. Prepared by Skeo Solutions for U.S. EPA Region 4.

Memorandum of Agreement between U.S. Environmental Protection Agency and the South Florida Water Management District. March 11, 2000.

Memorandum: Review of Indoor Air Sampling Data. Trans Circuits, Lake Park, Florida. September 11, 2013.

Polynuclear Aromatic Hydrocarbons Memorandum. EPA Region 4. Trans Circuits Remedial Action Site. January 29, 2013.

Preliminary Close Out Report. Trans Circuits, Inc. Superfund Site. Lake Park, Palm Beach County, Florida. September 2013.

Remedial Action Implementation Status Report 1. Baseline Sampling Events - January - October 2012/March 2013. Trans Circuits Remedial Action Superfund Site. Lake Park, Palm Beach County, Florida. Prepared by Black & Veatch for U.S. Environmental Protection Agency Region 4. August 2013.

Remedial Action Implementation Status Report 2. Fourth Quarter Post First Injection Sampling Event - September 2014. Trans Circuits Remedial Action Superfimd Site. Lake Park, Palm Beach County, Florida. Prepared by Black & Veatch for U.S. Environmental Protection Agency Region 4. February 2015.

Remedial Action Implementation Status Report 3. Fifth Quarter Post First Injection Sampling Event - December 2014. Trans Circuits Remedial Action Superfimd Site. Lake Park, Palm Beach Coimty, Florida. Prepared by Black & Veatch for U.S. Environmental Protection Agency Region 4. April 2015.

Technical Memorandum Remedial Action Performance for Trans Circuits Superfimd Site. Prepared by Versar for EPA Region 4. April 2017.

A-1

Vapor Intrusion and Ambient Air Sampling Data Summary Report. Trans Circuits Site. Lake Park, Florida. October 28, 2001.

A-2

APPENDIX B - CURRENT SITE STATUS

l^nvironniental Indicators

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

Are Ncccssar\ Institutional Controls in Place?

I ^ All □ Some □ None

Has FJ’A Designated the Site as Sitewide Read> Tor Anticipated Use?

I lEI Yes □ No

Has the Site Deen Put into Reuse?

I lEI Yes □ No

B-1

APPENDIX C - SITE CHRONOLOGY

Table C-1: Site Chronology

Event DateInitial discovery of contamination July 1, 1979State fund-financed sitewide preliminary assessment completed October 1, 1984Well PW-17 taken out of service 1984Trans Circuits, Inc. discontinues operations 1985Air strippers installed for PW-17; well put back into service 1988Air strippers taken offline due to lack of funding 1990State fund-financed sitewide site inspection completed September 26, 1991The EPA-fund-financed sitewide expanded site inspection/remedial investigation began

February 27, 1997

Combined remedial investigation/feasibility study started September 30, 1998The EPA fund-financed sitewide expanded site inspection/remedial investigation completed

October 30, 1998

The EPA fund-financed Hazard Ranking Package completed December 3, 1998The EPA federal enforcement PRP search started July 27, 1999Site proposed for listing on the NPL October 22, 1999Federal enforcement notice letters issued by the EPA January 25, 2000Site listed on NPL February 4,2000Prospective purchaser agreement assessment started March 10, 2000Prospective purchaser agreement assessment completed by the EPA Administrative Order on Consent issued by the EPA

July 11,2000

Public Health Assessment completed November 19, 2000Combined remedial investigation/feasibility study completed November 28, 2000Federal enforcement PRP search completed by the EPA December 1, 2000ROD signed by the EPA April 12, 2001Direct Access International began operating a recycling business using postconsumer materiajs into clothing on site

September 2001

Remedial design phase 1 began January 18, 2002Remedial design phase 2 began February 7, 2002Remedial design phase 3 beganRemedial design phase 3 completedRemedial action phase 1 began

September 26, 2002

The EPA funding of City air strippers began October 2002Remedial design phase 1 completed September 12, 2003The EPA Superfiuid-financed removal started September 29, 2003Remedial action phase 2 began September 30, 2003Direct Access International purchased the site Summer 2004The EPA funding of City air strippers ended January 2006The EPA Superfund-financed removal completed March 3, 2006Remedial action phase I completed June 29, 2006Remedial action phase 2 completed September 25, 2006First FYR signed by the EPA September 19, 2007Remedial design phase 2 completed December 17, 2009MOA signed by the EPA and the SFWMD March 11,2010ESD signed by foe EPA September 29, 2010Remedial action phase 3 began Septernber 28, 2011Florida Aero Precision purchased foe Site and began operating a precision machine shop for aircraft engine and gas turbine parts on site

November 2011

Second FYR signed by the EPA September 19, 2012Polynuclear Aromatic Hydrocarbons Memorandum completed January 29, 2013

C-1

Event DateCompletion of first bioamendment injection for groundwater remedy August 30, 2013Completion of Vapor Intrusion and Ambient Air Sampling Data Summar>' Report October 23, 2013

C-2

APPENDIX D - SITE MAPS

Figure D-1: Site Vicinity Map

^^Trans Circuits, Inc. ^ Superfund Site

Lake Park, FL

Miami I

Trans CircuiteTInc: ^ i Ml Superfund Site

1 --.^1I1\J I

Newman Road

Site Boundary

Sources: 2012 FYR, EPA, Esii, DeLorme, DigitalGlobe, GeoEye, Earthstar Geographies, CNES/Airbus DS, AND, USDA, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo. Tele Atlas, First American, UNEP-WCMC and USGS.

0s!<^ NORTH

Trans Circuits, Inc. Superfund SiteCity of Lake Park, Palm Beach County, Ftarida


Figure D-2: Monitor Well Loeation Map

ifU9MM

• MoniortngWtfiocaloA• UHyPoit

ommaumfM

J iL'.VJJ.’l Former Pcfoolilon Pond Am* Seuree Rtmediai Aciem wort PUr> p«ek « Vtal0) 2013a)NolBr1 PvoekobUttcdirDin the Pa»n Beach CoirtyP approtfmaH.2. FofftepufpoeetfWtlgwt.ftt'SnroohetOiqrtteamaintwviartiyflfticWWed

souce «ea «M oreunttaalcr mortlofing «d bcalm conêM as part or 2012 aNeevnent acMM ay Biaet & VcrttfL

y 20T2UOG5aertaHma9erycourtNyorE^

-..'Al'-

• I I

■fo.; i%uiM.i.

i'l'iiiu iiu.'.i! i:;

irVWfielearvlam

I <Palm Bvdcli

.HTTlTir

Ikn if

H 70 K 0

NAO N stM nn noM) mL Ftd

Site LayoutTrans Circuits Supertund Site

Lake Park, Palm Beach County, Florida

Source: Remedial Implementation Status Report 3. April 2015. Prepared by Black and Veatch.

Figure D-3: Remedial Action PAH Soil Sample Locations

•SB114

BH3TCDPT11

mm

SB111

Legend• Actual RA Sample Location RA-2012• EstimetedRA Sample Location RA-2012• Proposed RA Sample Location RA-2012• Sod Sample Location RD - 2009

Monitoring Wens

• Fonner Percolation Pond AieeTrans Circutia BuMno- ' -m

I RARemediaf Action £,,:^

IP"#**-;

• z^-m

w r:

JIIW35Df^02B

r

B.10.T

□.APAH Sampllna Inveatigatlont: RD - 2009/RA - 2012

Trane Circuits Superfund Site Lake Park, Palm Baacti County. Florida

Figure1

Source: Polycyclic Aromatic Hydrocarbon Memorandum. Prepared by Black and Veatch. January 2013.

Figure D-4: Subslab Vapor and Air Sampling Locations

■.M

KT„5jf:

' • ,w- jjli;

r j-n^rnl:

iMt'

1. MX AmM imagi Cewwy or Mtoawft C«p«MMn1 re«nnl»laiiMlw IMMlor lipm-pMiparMilafti l*n MMtogi ««Nn«0 tfurins 2t ApMl »t> 0«MyMK IM V

Geoî^*caosiitunis

Source: Vapor Intrusion and Ambient Air Sampling Data Summary Report. Prepared by Geosyntec October 2013.

D-4

APPENDIX E - SITE INSPECTION CHECKLIST

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

I. SITE INFORMATIONSite Name; Trans Circuits, Inc.Location and Region: Lake Park, Florida, Region 4Agency, Office or Company Leading the Five-Year Review: EPA

Date of Inspection: I/I0/2017EPA ID: FLD09147I904

Weather/Temperature: cloudy and 70 degrees

Remedy Includes: (Check all that apply)□ Landfill cover/containment□ Access controls^ Institutional controls□ Groundwater pump and treatment□ Surface water collection and treatment ^ Other: in-situ bioremediation

^ Monitored natural attenuation□ Groundwater containment□ Vertical barrier walls

Attachments: ^ Inspection team roster attached □ Site map attached

II. INTERVIEWS (check all that apply)1. O&M Site Manager Grea Roof

NameO&M ContractorTitle

02/15/2017Date

Interviewed □ at site □ at office ^ by email Problems, suggestions □ Report attached:

Phone:

2. O&M StaffName Title Date

Interviewed □ at site □ at office □ by phone Problems/suggestions □ Report attached:

Phone:

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

AgencyContact _____ _____ _____ _____

Name TitleProblems/suggestions □ Report attached:

Date Phone No.

Agency. Contact Name

Title Date Phone No.Problems/suggestions □ Report attached:.

Agency ____Contact _____ ____


Agency. Contact

Date Phone No.

NameProblems/suggestions □ Report attached:.

Title Date Phone No.

AgencyContact

E-1


Date Phone No.

4. Other Interviews (optional) ^ Report attached: contractor for property owner

EPA RPM, Marcia O'Neal

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

O&M Documents

□ O&M manual □ Readily available □ Up to date En/a□ As-built drawings □ Readily available □ Up to date ^N/A

|~| Maintenance logs □ Readily available □ Up to date En/aRemarks:

2. Site-Specific Health and Safety Plan

r~l Contingency plan/emergency response plan

Remarks:

□ Readily available

□ Readily available

□ Up to date

□ Up to date

Kn/a^N/A

3. O&M and OSHA Training Records □ Readily available □ Up to date ^N/A

Remarks:

4. Permits and Service Agreements

□ Air discharge permit □ Readily available □ Up to date KIn/a□ Effluent discharge □ Readily available □ Up to date Kn/a□ Waste disposal, POTW □ Readily available □ Up to date Sn/an Other permits: □ Readily available □ Up to date Sn/aRemarks:

5. Gas Generation Records □ Readily available O Up to date ^N/A

Remarks:

6. Settlement Monument Records □ Readily available □ Up to date Kn/aRemarks:

7. Groundwater Monitoring Records ^ Readily available ^ Up to date □ n/aRemarks:

8. Leachate Extraction Records □ Readily available □ Up to date ^N/A

Remarks:

9. Discharge Compliance Records

□ Air □ Readily available □ Up to date ^N/A

□ Water (effluent) □ Readily available □ Up to date Sn/aRemarks:

10. Daily Access/Security Logs □ Readily available □ Up to date ^N/A .

Remarks:

IV. O&M COSTS

O&M Organization r~l State in-house

□ PRP in-house

□ Federal facility in-house

^ Site not vet in O&M phase

□ Contractor for state

r~| Contractor for PRP

□ Contractor for Federal facility

2. O&M Cost RecordsQ Readily available □ Up to date

n Funding mechanism/agreement in place Q Unavailable

Original O&M cost estimate:____ □ Breakdown attached

Total annual cost by year for review period if available

From; ____ To:_____ _____Date Date Total cost

From:

From:

To:Date

Date

Date Total cost

To:Date Total cost

From: To:Date Date Total cost

From: To:

□ Breakdown attached

r~l Breakdown attached


HU Breakdown attached


Date Date Total cost

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

V. ACCESS AND INSTITUTIONAL CONTROLS ^ Applicable □ n/aA. Fencing

1. Fencing Damaged □ Location shown on site map □ Gates secured ^N/A

Remarks:

B. Other Access Restrictions

1. Signs and Other Security Measures O Location shown on site map ^ N/A

Remarks:

C. Institutional Controls (ICs)

1. Implementation and Enforcement Site conditions imply ICs not properly implemented Site conditions imply ICs not being fully enforced Type of monitoring (e.g., self-reporting, drive by): _ Frequency:Responsible party/agency:

Contact ____

□ Yes g| No □ N/A□ Yes ^ No □ N/A

Name Title Date Phone no.

Reporting is up to date □ Yes □ No □n/aReports are verified by the lead agency □ Yes □ No □ n/aSpecific requirements in deed or decision documents have been met □ Yes □ No ^N/A

Violations have been reported □ Yes □ No □ n/aOther problems or suggestions: □ Report attached

2. Adequacy ^ ICs are adequate □ ICs are inadequate □ N/A

Remarks: MOA between EPA and SFWMD is in olace to restrict groundwater use.

D. General

1. Vandalism/Trespassing □ Location shown on site map □ No vandalism evident

Remarks: Tresnassine occurs occasionallv on the Florida Aero Precision oroDertv. but does not aonear to impact remedv protectiveness.

2. Land Use Changes On Site □ N/A

Remarks: Florida Aero Precision is considering expanding its building to cover the former percolation pond area, which includes several on-site monitoring wells.

3. Land Use Changes Off Site ^ N/A

Remarks:

VI. GENERAL SITE CONDITIONS

A. Roads □ Applicable ^ N/A

1. Roads Damaged □ Location shown on site map □ Roads adequate □ N/A

Remarks:

B. Other Site Conditions

Remarks:

VII. LANDFILL COVERS □Applicable |3 N/A

VIII. VERTICAL BARRIER WALLS □Applicable ^N/A

1. Settlement □ Location shown on site map □ Settlement not evident

Area extent: Depth:

Remarks:

2. Performance Monitoring Tvpe of monitoring:

□ Performance not monitored

Frequency: □ Evidence of breaching

Head differential:

Remarks:IX. GROUlVDWATER/SURFACE WATER REMEDIES ® Applicable □ N/A

A. Groundwater Extraction Wells, Pumps and Pipelines □ Applicable ^ N/A

I. Pumps, Wellhead Plumbing and Electrical□ Good condition □ All required wells properly operating D Needs maintenance □ N/A

Remarks:

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

□ Good condition O Needs maintenance

Remarks:

3. Spare Parts and EquipmentQ Readily available □ Good condition

Remarks:

□ Requires upgrade □ Needs to be provided

B. Surface Water Collection Structures, Pumps and Pipelines □ Applicable ^ N/A

1. Collection Structures, Pumps and Electrical Q Good condition □ Needs maintenance

Remarks:

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

□ Good condition Q Needs maintenance

Remarks:

3. Spare Parts and Equipment□ Readily available □ Good condition

Remarks:

□ Requires upgrade □ Needs to be provided

C. Treatment System □ Applicable |3 N/A

1. Treatment Train (check components that apply)□ Metals removal □ Oil/water separation

□ Air stripping □ Carbon adsorbers

□ Filters:□ Additive (e.g., chelation agent, flocculent):Q Others:r~l Good condition Q Needs maintenance□ Sampling ports properly marked and functional

□ Sampling/maintenance log displayed and up to date

r~l Equipment properly identified□ Quantity of groundwater treated annually:

□ Bioremediation

E-5

□ Quantity of surface water treated annually:

Remarks:

2. Electrical Enclosures and Panels (properly rated and functional)□ N/A O Good condition □ Needs maintenance

Remarks:

3. Tanks, Vaults, Storage Vessels n N/A O Good condition

Remarks:

□ Proper secondary containment □ Needs maintenance

Discharge Structure and Appurtenancesl~l N/A n Good condition

Remarks:

r~l Needs maintenance

5. Treatment Building(s)□ N/A □ Good condition (esp. roof and doorways)

I I Chemicals and equipment properly stored

Remarks:

r~l Needs repair

Monitoring Wells (pump and treatment remedy)□ Properly secured/locked □ Functioning □ Routinely sampled□ All required wells located □ Needs maintenance

Remarks:

□ Good condition

□ n/a

D. Monitoring Data

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

2. Monitoring Data Suggests:□ Groundwater plume is effectively contained ^ Contaminant concentrations are declining

E. Monitored Natural Attenuation1. Monitoring Wells (natural attenuation remedy)

□ Properly secured/locked

□ All required wells located

Remarks: wells were not locked

S Functioning ^ Routinely sampled

□ Needs maintenance

^ Good condition

□ n/a

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

XI. OVERALL OBSERVATIONSImplementation of the RemedyDescribe issues and observations relating to whether the remedy is effective and ftmctioning as designed. Begin with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant plume, minimize infiltration and gas emissions).Remedy implementation appears to be effective. The EPA addressed contaminated soil through excavation and remading of the former tjercolation pond. In-situ bioremediation injections appear to be addressine the contaminant plume northeast of the Site. There are currently no known exposures.

B. Adequacy of O&M

Describe issues and observations related to the implementation and scope of O&M procedures. In particular, discuss their relationship to the current and long-term protectiveness of the remedy. The Site’s remedy has not vet entered the O&M bhase.Early Indicators of Potential Remedy ProblemsDescribe 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.N/AOpportunities for OptimizationDescribe possible opportunities for optimization in monitoring tasks or the operation of the remedy. N/A.

Site Inspection Roster:

Marcia O’Neal, EPA RPMDan Reardon, Alltech Environmental, property owner contractor Kirby Webster, Skeo, EPA contractor Kelly MacDonald, Skeo, EPA contractor

E-7

APPENDIX F - PRESS NOTICE

», B»i0n4 hirdfivt-YeerThiUAErni

Review far The Trans Gmiiti.Inc Suerfund She^ Uke Perk,Patn Bb^ County. FlerMe

Purpocc/Ofafeetive: The £PA u oonduct- inp a fnv-rear Rewew of the remedy ■for the Trane Cr«uhv Inc. Suserfund site (ttw Sitcf in Lake Park. Ronda. Die pucpaie of ihe Five-Year Review is to make sure the selected cleanup actions eHeotively protect human health and the environment.

Site Beckgreund: The 1-acre area ii la- eeted at 210 HenTnai Raad in a com- merciel and (ndustrie! area in Much- western Lake Park. Florida. Front 1076 to t98Sw Tmns Croats. Inc. made citac- trepJate electronic components and suhaisemblles for cimcit boards on site- operations included strippinp. etching, electrolysis arsd electronic platcng. and nickel and geld platirsg. Solvents. acid>basad siripping solutions and piat- ing solutions contoming IcadL tin. copper. nickel fluoride and cyanide wore used in the manufacturing proMsses. A 1983 site inspection by the Florida De- oartment of Envlronmensat Regulation (now the Florida Ospartmtnt of Emii- ronmcntal Protection) found sludge in the evaporatson pond and puddles of liquid neartiy. tn additipn. about 1Q0 large drums of unidentified waste were found in a treatmeht arM on site- Additional investigations found eii^'etod leveh of contammanis in soils. subsurface soils and groundawter. The EPA placed the Site on the Superfund Matione! Prioritim Ust (MPL> in TdOO.Oeenvp Actions; The 6PA selected the Site's final remedy in the Site^ April ;Z90i Record of Decision. It included surface soil removal. InstHwtlonai con. troll, innallatlcn of a munkipai well and chemical oxidation to treat groundwater contamination. It also In- eluded ewraaioft and ah stripping of contaminated groundwater at die Riviera Beatii water treatmem plant The EPA updated the groundv/ater remedy in 2010. changirtg treatment from chemical oxidation to in-place bScremedlatioA. The update also modified the Slteb instltuiiional convoti and included additional soil sampling.RiifYear Review Schedule: The p«a- tional Contingency Plan requires re-

of remedial actions that result In any hazardous substances poilutanis or contaminants remaining at the Site above levels that allow for vnnmited vse and unrestricted exposure every five years to ensure tiie protection of human healtit and the en^ronment The third of the Five-Year Reviews for the Site will be completed by haie 2017.

The EPA tnvius Community Partidpft- tion Ui the Five-Year Review Preceu: The CPA h conducting this Five-Year Review ee evaluate the Hfeiiiventss of the She's remedy and to ensure that the remedy remains protective of human heahh and the environment. As oart of the Five-Year Review proeesA EPA staff b available to answer any questions about the £te. CommunLty menrben wfio have questiona about the Site or the Five-Year Review proc- eu, or who. would like to perticieate in a coninuinrty intaview, are dued to contact:

Mofcxa O'NealEPA Reiriedsal Proiect Manager Phone. (M« 562-6402 Emaih oneaimarcieOâa.gov

Conunimity In Phorte: (404) S.) Sfi2-84£3 Email: 5peneefiatonyeflepa.gov

Mailing Addrea: US. EPA Region A 61 Foo^h Sacet. S.W.. 11th Ftoor, Attonca. OA 30303-6960

Addhiona) infamtstion is oimrlable at the She's local docurrient rôsitary. located at Riviera Beach Public Library. 600 West Blue Heron Boulevard Riviera Beach. FL 3MW. and online at <unuilu.«P9..gowAMpef«>wO'.rjli»s(f5>T) nlSJCfmVi|:Ô07e5^6-10(2017" ..................Boooisaaag^si

F-l

APPENDIX G - SITE INSPECTION PHOTOS

Florida Aero Precision facility

mUi.nsrnwmvm?

Florida Aero Precision facility and fencing, from Brant Road

G-1

Florida Aero Precision facility. Cutting Room

■.^ -^:‘V.

Vapor intrusion sampling location in Cutting Room

siifcifc,

Florida Aero Precision manufacturing facility

r'J'

Former percolation area and proposed area of Florida Aero Precision facility expansion

V-

■ rfss|iSlisS.5^-s<

7$'* .,:^4;s

.t^;-V. ■^ ■ 5S^^3i-'fe

i V :

- *:'?!• .-V'

;iv.'% :• ISIS"'KMIlcMffy r'?r f 1 ^ ..‘V- ^JKmi

Well in former percolation basin area and proposed area of Florida Aero Precision expansion

Injection well field behind JAS Marine building

■' ■ ■•■‘* ■. ■ "'5^

V : '■ -'^-'^-r:''- ^.'5

i ^mW

..-•'V._ '• ■' . '-.

ll,-.‘ v;V'ii?

SlSJv:p'-:-,■

;• 4 :v . / •Well in injection field behind JAS Marine building

APPENDIX H - DETAILED APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARS) AND TOXICITY REVIEW

This section evaluates whether the ARARs remain current and whether changes in toxicity values effect the validity of the ROD groundwater and soil and cleanup goals.

GroundwaterThe Site’s 2001 ROD established remedial goals for groundwater. Table H-1 compares chemical- specific ARARs from the 2001 ROD to 2017 state and federal MCLs. It shows that the MCLs remain current or are less stringent for all site COCs.

Table H-1: Groundwater ARARs Review

coc2001 ROD

Remedial Goal (ue/L)*

2017EPAMCL(pgA.)"

2017 Florida MCL (FgA.)" ARAR

PCE 3 5 3 No changeTCE 3 5 3 No change1,2-DCE 70 70' 70' No changeChloroform 6 70 - Less stringentVinyl chloride 1 2 1 No changeNickel 100 ~ 100 No changeFluoride 2,000 4,000 4,000 Less stringentNotes:a. Table 12-3 of the 2001 ROD.b. Federal Safe Drinking Water Act MCLs are available at

httD://www.er)a.aov/safewater/contaminants/index.html (accessed 1/14/2017').c. Cleanup goals for cis-1,2-DCE, the more stringent of the 1,2-DCE isomers.d. Florida MCLs are available at httnV/www.deo.state.fl.us/water/drinkinawater/standard.htm (accessed

01/14/2017).e. pg/L = micrograms per liter

SoilThe 2001 ROD identified soil cleanup goals based on FDEP SCTLs and site-specific risk assessments. The 2010 ESD updated the ROD cleanup goal to allow for UUAJE. Table H-2 compares chemical- specific cleanup goals to current residential screening levels. The 2010 ESD cleanup goal for BaP is within EPA’s acceptable risk range for residential use.

Table H-2: Soil Cleanup Goal Review

2010 ESD Remedial

EPA Residential RSL* (mg/kg) Residential Risk Level

COC Goal(mg/kg)

1x10^Risk HQ = 1 Cancer

Risk'’Noncancer

HO*SoilBenzo(a)pyrene 0.1 1.6x 10-- - 6.3 X 10-« ~Notes:a. Current Residential Screening Levels (RSLs), dated May 2016, are available at

httD;//www.eDa.aov/risk/risk-based-screenine-table-eeneric-tables (accessed 10/03/2016).H-1

2010 ESD Remedial

Goal (mg/kg)

EPA Residential RSL* (mg/kg) Rraidential Rkk Level

coc 1x10^Risk HQ = 1 Cancer

Risk"*Noncancer

HO*b. Cancer risks were calculated using the following equation, based on the fact that RSLs are

derived based on 1 x I O'* risk:Cancer risk = (remedial goal cancer RSL) x 10“^

c. The noncancer hazard index (HI) was calculated using the following equation:HI = (remedial goal noncancer RSL)

RSL = regional screening level- = noncancer RSL has not been prepared for this contaminant.mg/kg = milligrams per kilogram_______________________________

Vapor IntrusionIn response to an issue raised in the 2012 FYR, vapor intrusion was re-evaluated using multiple lines of evidence during this FYR period. In 2013, EPA contractors collected subslab soil vapor, ambient air in the Cutting Room and ambient air in background locations. The EPA evaluated these data and concluded that the ambient air samples were below or within EPA’s risk targets. The EPA concluded that based on subslab soil gas, the noncancer HQ would be exceeded for both industrial and residential exposure. However, the comparison of indoor air data to subslab data demonstrate that attenuation is occurring, resulting in measured indoor air that is within or below EPA’s risk targets. This FYR reevaluated the VISE calculation for both industrial and residential exposure. As shown in Table H-3, the vapor intrusion risk results for industrial exposures are within EPA risk targets for both subslab modeled into indoor air and measured indoor air. Table H-4 shows that the noncancer HQ is exceeded for a future resident based on modeled indoor air from subslab soil vapor. However, the measured indoor air indicate that the slab is mitigating this pathway; the indoor air risks are within EPA target levels and the noncancer hazards are below 1.0.

Table H-3: Screening Level Vapor Intrusion Assessment for Commercial Use

COC

Maximum Detection (iic/m^) Subslab VISL* Ambient Air VISL*

SMMab IndoerAir Indnstriai ^ IndustrialRisk HO Rkk HO

PCE 200(WMS004)

0.68(AAOOl) 1.3x lO-"^ 0.03 1.4x10-* 0.004

TCE 190(WMS005) 2.0 (AAOOl) 1.9x 10-* 0.65 6.7x10-’ 0.23

Notes:a. Screening-level vapor intrusion risks calculated using the EPA’s VISL Calculator, version

3.5.1, May 2016. https://semsDub.epa.gov/src/document/11/196702 ug/m^ = micrograms per meter cubed_________________________________

H-2

Table H-4: Screening Level Vapor Intrusion Assessment for Future Residential Use

cocMaximam DetectioD Subslab VISL* AfflbKut Air VISL*

Subslab ludoorAir

Residential ResidentialRisk HO Risk HO

PCE 200(WMS004)

0.68(AAOOl)

5.6x 10-" 0.14 6.3x10-* 0.016

TCE 190(WMS005)

2.0(AAOOl)

1.2 X 10-5 2.7 4.2x10-« 0.96

Notes:a. Screening-level vapor intrusion risks calculated using the EPA’s VISE Calculator, version

3.5.1, May 2016. https://semsDub.eDa.gov/src/document/l 1/196702 Bold = noncancer HQ exceeds 1.0. _______________________

APPENDIX I - INTERVIEW FORMS

Trans Circuits, Inc. Superfund Site Five-Year Review Interview FormSite Name: Trans Circuits. Inc.

Subject Name: Time: Interview Location:

Marcia O’Neal

EPAIDNo.: FLD091471904

Afniiation: EPADate: 01/17/2017

USEPA Region 4 Office

Interview Format (circle one): In Person Phone (^ma^T) Other:

Interview Category: EPA Remedial Project Manager

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

The remedial action is ongoing. The Site is well maintained and the reuse is successful.

2. What have been the effects of the Site on the surrounding community, if any?

Currently, there are no significant impacts to the surrounding community.

3. Are you aware of any complaints or inquiries regarding site-related environmental issues or remedial activities since the implementation of the cleanup?

No.

4. What is your assessment of the current performance of the remedy in place at the Site?

The most recent monitoring data has yet to be delivered. This will determine the effectiveness of the remedy and if another round of injections are necessary.

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

The current institutional controls are through the South Florida Water Management District. There are no outstanding issues at this time.

6. Are you aware of any community concerns regarding the Site or the operation and management of its remedy? If so, please provide details.

I have not received any community concerns regarding the Site.

7. Do you have any comments, suggestions or recommendations regarding the management or operation of the Site’s remedy?

None, the implementation of the remedy is being continued until the groimdwater cleanup target levels are met.

8. Do you consent to have your name included along with your responses to this questiormaire in the FYR Report?

Ido.

Trans Circuits, Inc. Superfund Site Five-Year Review Interview FormSite Name: Trans Circuits. Inc. EPAIDNo.: FLD091471904

Subject Name: Greg Roof Affiliation: Tetra Tech. Inc.

Interview Format (circle one): In Person Phone (^maij^ Other:

Interview Category: O&M Contractor


Versar/Tetra Tech has been involved with the site for approximately 1 year. Our assignment is to review the current groundwater conditions and make recommendations for and design of a second injection phase to treat the remaining groundwater contamination associated with the site. During our time at the site, there have been no issues relating to contamination or migration horizontally or vertically beyond the previous boundaries. Additionally, the initial injection appears to have been effective in reducing the groundwater COC concentrations. I have seen nothing while involved in this project that would call into question the protectiveness of the remedy.

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

Based on work completed to date, we have indications that groundwater COCs are have been significantly reduced and the current remedy appears to be effective.

3. What are the findings from the monitoring data? What are the key trends in contaminant levels that are being documented over time at the Site?

The monitoring data appears to indicate that the contamination concentrations are decreasing. The TCE is predominantly reduced to acceptable levels. The breakdown products have also decreased. Based on the October 2016 sampling event 1,2-DCE and-vinyl chloride are the 2 COCs remaining in excess of the action levels. Total petroleum hydrocarbons are being measured in a few select wells and are below action levels. Nickel and fluoride concentrations have been decreasing this time and are mostly reduced to below action levels. Bacterial measurements indicate that concentrations of bacteria required to complete the degradation process beyond vinyl chloride are present but low. Treatment appears to have been effective.

4. Is there a continuous on-site O&M presence? If so, please describe staff responsibilities and activities. Alternatively, please describe staff responsibilities and the frequency of site inspections and activities if there is not a continuous on-site O&M presence.

There is no continuous on-site O&M presence. The only issue at the site is groundwater located more than 100 feet below land surface. The remediation selected was in-situ injection. There are no remediation system components requiring any form of oversight. The EPA is continuing monitoring to evaluate the long term effectiveness. At this time contractors are observing site conditions and reporting any issues. I have heard of no groundwater access issues or other concerns relating to the contamination associated with Trans Circuits.

5. Have there been any significant changes in site O&M requirements, maintenance schedules or sampling routines since start-up or in the last five years? If so, do they affect the protectiveness or effectiveness of the remedy? Please describe changes and impacts.

There are no significant O&M requirements. Groundwater monitoring as part of the remedy and land use controls are currently being performed. Periodic visual observations ensuring no groundwater access/use is performed during monitoring efforts.

6. Have there been unexpected O&M difficulties or costs at the Site since start-up or in the last five years? If so, please provide details.

Versar/Tetra Tech has only been involved over the past year. There have been no issues since we became involved.

7. Have there been opportunities to optimize O&M activities or sampling efforts? Please describe changes and any resulting or desired cost savings or improved efficiencies.

Versar/Tetra Tech knows of no optimization efforts performed during the first 5 years of postinjection monitoring. However, we are currently evaluating the program to determine the merit of a second injection and appropriate steps to optimize the monitoring program.

8. Do you have any comments, suggestions or recommendations regarding O&M activities and schedules at the Site?

Nothing beyond what we will provide in our evaluation memorandum and work plan for the second injection.

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

Trans Circuits, Inc. Superfund Site Five-Year Review Interview FormSite Name: Trans Circuits, Inc. EPAIDNo.: FLD091471904

Interviewer Name: Kelly MacDonaldSubject Name: Dan Reardon

Affiliation: SkeoAffiliation: Property owner ^Florida

Aero Precision) contractorSubject Contact Information: [email protected]: 10:00 a.m. Date: 01/10/2017Interview Location: Florida Aero Precision Facility

Interview Format (circle one): Person) Phone Mail Other:

Interview Category: Property owner contractor

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

Yes.


The project has been very successful.

3. What have been the effects of the Site on the surrounding community, if any?

The biggest impact has been the successful reuse of the Site as Florida Aero Precision. There are now 15 people employed in this building, bringing jobs to this area.

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

Yes. People trespass and steal from the facility, things like air conditioning units for example. It is relatively typical of an industrial/neighborhood setting for this area.

5. Has EPA kept involved parties and surrounding neighbors informed of activities at the Site? How can EPA best provide site-related information in the future?

Yes. It may be helpful for Florida Aero Precision to have material to provide to interested neighbors regarding the Site, such as a newsletter or fact sheet.

6. Do you own a private well in addition to or instead of accessing city/municipal water supplies? If so, for what purpose(s) is your private well used?

No.

7. Do you have any comments, suggestions or recommendations regarding any aspects of the project?

I have a very positive impression of this project and think it was a great use of resources. It has provided space for a manufacturing and provides jobs in the area.

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

Yes.

Email comment on the FYR draft from Kelsey Helton, FDEP (received July 17,2017)

• Section VII- Protectiveness Statement- The FYR concludes that the remedy remains protective because there are no completed exposure pathways. DEP agrees with that statement (pending well survey confirmation as discussed below). The soil remedy has been completed. As documented in the 2013 PAH Memorandum, site related soils met soil cleanup target levels for unrestricted use. An Institutional Control restricting land use to commercial/industrial is therefore not necessary. Phase 1 insitu treatment (bioremediation) of the groundwater plume has been completed and groundwater monitoring indicates good response and reduction of contaminants within the treatment area as anticipated. The EPA MOA with the Water Management District (WMD) ensures review of permit applications to ensure that exposure to remaining contaminated groundwater will not occur via permitting of new potable wells within designated delineated area.

o We recommend rewording of the 2"‘* sentence in the Protectiveness Statement to state- “In order for the remedy to be protective in the long term, groundwater contaminant levels must attain Site cleanup goals, as documented by groundwater monitoring and adequate detection limits.”

• Section VI- Issues/Recommendations- DEP agrees that adequate detection limits are critical to documenting that cleanup levels have been met. We also support the recommendation that vapor intrusion be re-evaluated if land use changes to residential, per EPA guidelines. We encourage a review of the existing O&M Plan, specifically the performance monitoring scope, based on more recent plume data, to ensure the appropriate monitoring wells are sampled to support the ongoing groundwater remedy performance evaluation.

o DEP recommends updating the map associated with the 2010 MOA (Zones A and B)after additional groundwater assessment is completed downgradient of the initial treatment area to determine the magnitude and extent of site related contamination.

o DEP recommends confirming with WMD that no new wells have been permitted in the area defined in the MOA during this FYR period.

o Review and evaluation of the O&M plan and performance monitoring scope should include both chlorinated solvent and the nickel/fluoride plumes.

o The Inspection report indicated that monitoring wells were in good condition but “not locked”. These wells should be secured with a lock.

• Other Comments-o During the 2012 FYR, DEP recommended that a well survey (% mile radius) be conducted as a

follow up to the 2000 DOH potable well survey and 2002 DOH private well sampling of the area. An initial screening identified 13 properties in the area that reportedly were without utilities (water). Palm Beach County Health Dept (PBCHD) confirmed that none of the 13 properties had private wells. EPA indicated that PBCHD would follow up with an area well survey. Please provide those survey results and discuss in the FYR, to confirm no completed pathways.

(pg 12) Data Review- The report references Figure 2 and concludes that the groundwater plume is minimal compared to the previous location of the plume. The scale of the figure does not allow confirmation of the accuracy of the 2014 projected extent. However, the red area identifying the extent of the contaminant plume in 2014 appears to be based on a limited performance monitoring data set and projection that is inconsistent with the larger plume and downgradient extent discussed in the 2017 Technical Memorandum using the more comprehensive 2016 groundwater data.

(pg 12) Data Review- The report provides a discussion of the results of the 2016 monitoring event and recommended path forward in the 2017 Technical Memorandum.

■ Please add a sentence that indicates that “EPA and DEP are reviewing those recommendations”.

■ In particular, DEP notes that MWl 5D is designated as non-site related in the Performance Monitoring Plan. DEP recommends additional groundwater contaminant characterization in the downgradient area between MW52D, MW51D and MW12D to ascertain the magnitude of contamination and to confirm that the plume identified by MW5 ID and MWl 2D is site related. DEP recommends that based on this additional characterization and delineation as necessary, the extent of Phase II insitu treatment can be determined. Based on the current data, DEP supports supplemental insitu treatment in the area of MW52D. We do not recommend additional insitu treatment in the Phase I treatment area as proposed.

(pg 13) Technical Assessment, Question A- Is remedy functioning as intended?-■ The report notes the 2017 Technical Memorandum recommendations and references

Figure D-3 which identifies areas for additional insitu bioremediation including the original treatment area, MWl 2D and MW 15D. As noted above and based on recent discussions with EPA and Contractor, it is unlikely that these proposed areas will be included in the Phase II treatment. Inclusion of Figure D-3 in the FYR may therefore be confusing.

■ Please clarify in last sentence that Institutional controls in the form of an MOA are for groundwater use.

(pg 14) Technical Assessment, Question B- Exposure assumptions, toxicity data, cleanup levels andRAOs still valid?-

■ DEP agrees that assumptions, cleanup levels etc., documented in the ROD and subsequent ESD(s) are still valid.

(Pg E-1) Inspection check list- Please check “Monitored Natural Attenuation” as a component of the remedy

APPENDIX J - MEMORANDUM OF AGREEMENT

MEMORANDUM OF AGREEMENT

This Memorandum of Agreement (“MOA”) is made this day of i Pbetween the U.S. Environmental Protection Agency, (“EPA") and the South Florida Water Management District (“SFWMD”). The purpose of this MOA is to develop a framework for cooperation between the EPA and the SFWMD and to set forth the mutual understanding of the parties concerning cooperative efforts to minimize the potential effects of groundwater contamination in areas within the SFWMD's jurisdiction that are impacted or potentially impacted by Superfund sites, including procedures for information sharing and agisting in the implementation of certain institutional controls through the application of regulatory practices within the SFWMD’s jurisdiction, to prevent potential human exposure to contaminated groundwater in areas impacted or potentially impacted by Superfund sites.

WITNESSETH

WHEREAS, pursuant to the authority of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended, 42 U.S.C. 9601 et seq., and the National Contingency Plan, 40 CFR 300 et seq., EPA has the authority to conduct response actions at Superfund sites within the State of Florida;

WHEREAS, the EPA has designated sites within the SFWMD’s geographic jurisdiction as Superfund sites;

WHEREAS, institutional controls are frequently used by EPA as part of selected response actions at Superfund sites;

WHEREAS, EPA policy defines institutional controls as non-engineering instruments such as administrative or legal controls that eliminate or minimize the potential of human exposure to contaminants and chemicals of concern and that protect the integrity of the remedy by limiting land or resource utifization. Institutional controls at a particular Superfund site may be selected as a part of a removal or remedial action. Institutional controls selected as a part of a remedial action are identified in the Record of Decision (“ROD’O and may be more specificaliy estabiished during the Remedial Design. At many Superfund sites, institutional controls are used to eliminate potential human exposure to contaminated groundwater beneath the Superfund site property and other adjacent or nearby properties;

WHEREAS, a groundwater institutionai control may be a restriction on the use of contaminated groundwater by restricting the issuance of water use permits and/or a restriction on construction of potable and irrigation wells within an area impacted by a Superfund site. . Implementation and enforcement of institutional controls for contaminated groundwater may require the assistance of regulatory authorities such as the SFWMD and various locai governmental authorities;

J-1

WHEREAS, SF=WMD has adopted rules to, govern the consumptive use of water and the construction, abandonment and repair of water wells within the geographic boundaries of SFWMD, to implement the provisions of Parts II and ill of Chapter 373, Florida Statutes (“F.S.”), respectively;

WHEREAS, such rules are adopted by SFWMD to ensure that the provisions of Chapter 373, F.S., are implemented and to preserve the water and natural resources of the state and promote the health, safety, and general welfare of the people of the state, including Chapters 40E-2, 40E-3, and 40E-20, Florida Administrative Code (“F.A.C.”);

WHEREAS, SFWMD has also adopted by reference and implements regulations promulgated by the Florida Department of Environmental Protection governing the construction of water wells, including the construction of water wells within delineated areas of contamination, as set forth in Chapters 62-532 and 62-524, F.A.C.;

WHEREAS, within the geographic boundaries of SFWMD, unless otherwise exempt, a permit must be obtained prior to the construction, repair, modification or abandonment of a water well, including wells within areas delineated pursuant to Chapter 62^524, F.A.C., which encompass areas within which ground water contamination may exist or is known to exist;

WHEREAS, the SFWMD has delegated the authority to issue permits for the construction, repair, modification or abandonment of water wells to various local governmental agencies within the geographic boundaries of the SFWMD;

WHEREAS, within the geographic boundaries of the SFWMD, unless otherwise exempt, a water use permit must be obtained prior to the use or withdrawal of water for all uses except domestic uses and fire fighting purposes;

WHEREAS, pursuant to Rules 40E-2.381 and 40E-20.381, F.A.C., the SFWMD is authorized to impose upon any water use permit issued by SFWMD such reasonable conditions as are necessary to assure that the permitted use or withdrawal will be consistent with the overall objectives of the SFWMD, and shall deny an application for a water use permit if use or withdrawal fails to meet the conditions for issuance set forth in Rules 40E-2.301 or40E-20.301, F.A.C.;

WHEREAS, EPA and the SFWMD desire to cooperate in exercising their respective regulatory authority to prevent the poteritial spread of ground water contamination, protect aquifer water quality and promote public health, safety and welfare; and

WHEREAS, the Cleari Water Act § 10â) and (b), 33 U.S.C. 1254(a) and (b), provides EPA the authority to cooperate with organizations such as SWFMD on strategies to address water pollution, including groundwater and surface water pollution.

1.

NOW THEREFORE, ERA and the SFWMD agree as follows:

As to ERA:

A. The ERA shall notify SFWMD in writing of any area of groundwater impacted by a Superfund site within the jurisdiction of SFWMD.

B. Attached hereto and incorporated herein by reference as Appendix 1 is a list of agreed-upon Superfund sites within the jurisdiction of SFWMD to which this MOA shall be applicable and which shall hereinafter be referred to as the Superfund Areas. ERA shall provide SFWMD with a written description, aerial depiction and electronic data in a format compatible with the District's Geographic Information System showing the extent of the known and potential groundwater contamination for each of the Superfund Areas contained in Appendix 1. Electronic data should be provided in a shapefile that is in State RIane Feet East Zone, North American Datum of 1983 HARN, with units in feet and vertical units in feet, NAVD 88. Geometry should be polygon, if applicable. Attributes will need column descriptions and domains, and metadata should be FGCD compliant. ERA shall periodicalty provide an updated written description, aerial depiction and electronic data to SFWMD for each Superfund Area as often as necessary to maintain an accurate boundary of the Superfund Area, or at least every five years.

C. ERA shall consult with SFWMD to establish ,an inner and outer boundary of the area of groundwater impacted or potentially impacted by a Superfund Area. The inner boundary shall be known as the contamination zone or Zone A. The area between the inner and outer boundary shall be known as the buffer zone or Zone B.

D. For each Superfund Area, consistent with ERA’S policies on conducting Five-Year Reviews, ERA will ensure a well survey is conducted at least every five years within Zones A and B or the area of the extent of groundwater contamination if greater. The well survey will be conducted through field inspection and will identify any new wells constructed or operating since the last review was conducted. ERA shall also provide to SFWMD available monitoring and other site assessment reports demonstrating the status of groundwater contamination.

E. ERA agrees that if any portion of a Superfund Area appended or proposed to be appended to this MOA is situated within an area delineated as an area of ground water contamination pursuant to Section 373.309(1 )(e), F.S., ERA will incorporate in its institutional controls for such Superfund Area provisions for complying with the regulations promulgated in Chapter 62-524, F.A.C., if applicable.

2. As to SFWMD:

A. Upon receipt of the electronic and other descriptive data for a Superfund Area including the contamination zone and buffer zone for such Superfund Area, SFWMD will transmit the same to the various state and/or iocai agencies to which

SFWMD has delegated authority to issue weil construction permits pursuant to Chapter 40E-3, F.A.C.

B. When reviewing and approving water use permit applications involving activity to be undertaken on property located within a Superfund Area (hereinafter referred to as a Permit Application), SFWMD will, where appropriate, impose such reasonable conditions as are necessary to assure that the permitted use or withdrawal will be consistent with the overall objectives of the SFWMD.

C. For well construction permits, SFWMD will request the local agency to which authority for issuance of weil construction permit has been delegated, include appropriate conditions which may include, but are not limited to, prohibiting use of the well as a potable water supply, requiring notice to well owners of potential ground water contamination, including the requirements of Chapter 62-524, F.A.C., limiting the depth of the well, or requiring specific methods of construction.

D. SFWMD agrees that following receipt of an application for a water use permit for activity located within Zone A of a Superfund Area, SFWMD will provide the EPA with a copy of the Request for Additional Information (“RAn, if one is issued, and/or a copy of the Staff Report.

E. SFWMD will request local agencies to which it has delegated authority to issue well construction permits provide the EPA with a copy of any RAI sent to the applicant, if the local agency has determined that an RAI is necessary.

F. Pursuant to Rule 40E-2 and 40E-20, F.A.C., SFWMD will recommend denial of any application for a water use permit for an activity in Zones A or B of a Superfund Area if the use or withdrawal of water would cause significant degradation of surface or groundwater quality through induced movements of pollutants into a water resource that is not polluted or the use or withdrawal othenvise fails to meet the conditions for issuance set forth in Rules 40E-2.301 and 40E-20.301, F.A.C.

G. SFWMD will request local agencies to which it has delegated authority to issue well construction pemnits deny an application for a water well construction permit for activity in Zones A or B of a Superfund Area if use of the proposed well fails to meet the conditions for issuance set fortii in Rule 40E-3.301, F.A.C.

. H. SFWMD will provide notice to EPA of the receipt of a written request for a variance or waiver pursuant to Section 120.542, F.S., and Chapter 28-104, F.A.C., or an objection or petition for an administrative hearing in relation to a water use permit application for an activity located or proposed to be located within a Superfund Area.

I. SFWMD will request local agencies to which it has delegated authority to issue well construction permits provide notice to EPA of the receipt of a written request for a variance or waiver pursuant to Section 120.542, F.S., Chapter 28-104, F.A.C., or Rule 40E-3.0511(4), F.A.C., or an objection or petition for an administrative hearing in

relation to a water well construction permit application for an activity located or proposed to be located within a Superfund Area.

3. As to both parties:

A. Both parties agree to make their staffs available for timely consultation as to the potential for Impacts to the water resource occurring within Zones A and B of a Superfund Area as a result of proposed activity for which a water use permit application or water use permit renewal applicatfon is received by SFWMD,

B. This MOA may be amended in writing upon mutual consent, as the parties deetn necessary and such amendments shall take effect upon execution by both parties.

C. Additions or deletions to the list of Superfund Areas contained in Appendix 1 hereto may be made at any time upon mutual consent of the parties.

O. Each party hereby designates the position set forth below as its contact person who shall be responsible for receiving all notices as described herein and for assisting with coordination and overall implementation of this MOA for the respective agency:

For EPA: Division DirectorU.S. Environmental Protection Agency Region IV, Superfund Division 61 Forsyth Street, MW Atlanta, Georgia 30303-8960

For SFWMD: Division DirectorWater Use Regulation Division South Florida Water Management District 3301 Gun Club Road, MSC 4324 West Palm Beach, Florida

E. This MOA shall become effective on the latest day and year executed by either the EPA or the SFWMD as noted below.

F. Either party may terminate this MOA upon written notice to the other party.

G. The parties agree that this MOA imposes no formal contractual obligations and is not enforceable by either party against the other or by any third party.

H. Neither party is responsible for the funding, payment, and/or reimbursement of any costs incurred by the other party for any activities performed pursuant to this MOA. Any provision of this MOA that may require an obligation of funds by EPA shall be subject to the availability of appropriated funds and no provision

herein shall be interpreted to require obligation or payment of funds in violation of the Anti-Deficiency Act, 31 U.S.C. §1341.

I. This MOA does not create any right or benefit, substantive or procedural, enforceable by law or equity, by persons who are not party to this agreement, against SFWMD or EPA, their officere or employees, or any other person. This MOA does not direct or apply to any person outside of SFWMD and EPA.

J. The undersigned representative(s) certify that they are fully authorized to execute this MOA.

IN WITNESS WHEREOF, each party, or a lawful representative, has executed this agreement on the date set forth next to their signature below.

U.S. Environmental Protection Agency

South Florida Water Management DistrictBy its Governing Board

A. Stanley Meiburg Acting Regional Administrator

Eric Buenfiann, Chairman

Legal Form improved:

By:/_^

mJdnnife^Bc^nkowitz. Esq.

Attested:

I DistrictClerk/Asst. Sebr Bated:-77lW?

APPENDIX 1

1. Solitron Microwave Superfiind Site, EPA ID No. FLD045459526, Port Salerno, Martin County, Florida (March 2010)

2. Trans Circuits, Inc. Superfund Site, EPA ID No. FLD091471904, Lake Park, Palm Beach County, Florida (March 2010)

J-7

LegendY/\ Trais Circuits Site . _________ _

ParkÂve ^_ V ^

_ . ? i

Wî.

r igfV">

■ *|hiummj}(!}7

w S2QffV£73'^ if:AK'-IIS-

W .~îCypress Dr - - *

S' S ™ •

jayog/yy £j|

Jh

0 so 100 200 300 <1001 ----- 1----- 1----- ------ 1----- 1----- 1----- 1----- iF«e»

NAD83 sate Plane FL East Feet

Zone A and B of theTt’ans Circuits Supeifund Site (EPA, December 2009)

-;t:

1

• T^