1. Removal Site Evaluation
On 16-JUN-05, OSC Stilman mobilized to the Broken Sound Anthrax Site to conduct a removal site evaluation, based on a request from the Palm Beach County Health Department (PBCHD). On 12 June 2005, the PBCHD contacted EPA regarding flooding in the basement of 5401 Broken Sound Blvd. In October of 2001, 5401 Broken Sound Blvd. (former AMI Building) received a package or letter contaminated with bacillus anthracis (BA). Sampling by EPA, the Centers for Disease Control and the building owner’s contractor found BA throughout. In July of 2004, the building owner’s contractor decontaminated the three top floors using chlorine dioxide (ClO2). Before decontamination, papers, photos and other office supplies were boxed, placed on pallets and moved to the basement. Approximately 600 pallets of this material, presumed to be contaminated with BA, were originally placed in the basement. The basement was formerly used as a parking garage and is approximately four feet below ground surface and open to the air. In May of 2005, the building owner’s contractor began transporting the palletized material to an auto-clave for treatment. On 30-May-05, operations were halted due to a contract dispute. Between 01-JUN-05 and 15-JUN-05, the owner attempted to stabilize the contaminated boxes and prevent flood waters from contacted the boxes. On 15-JUN-05, the PBCHD found operations on site being conducted in an unsafe manner and halted all work. On 16-JUN-05, OSC Stilman mobilized to the Site and met with the PBCHD. On 17-JUN-05, the PBCHD and Florida Department of Health, by letter, formally requested EPA assistance with potential releases of BA from the Site. There are approximately 400 pallets with 6,000 boxes of material presumed to be contaminated with BA left in the basement. The boxes are being stored in the building’s basement. Flood waters in the basement continue to rise. The building flood water pumps are inoperative.
b. Physical Location and Site Characteristics
The Site is located at 5401 Broken Sound Boulevard, Boca Raton, Florida. The building is a four story office building with the bottom floor used as parking garage. Before receiving the BA contaminated package/letter, the building was used by a publishing company.
c. Release or Threatened Release into the Environment of a Hazardous Substance, or Pollutant or Contaminant
There are unsecured boxes containing BA contaminated material. Flood waters may have caused the boxes to breach, releasing anthrax to the environment. The building is adjacent to a frequently traveled road in an office park and a golf course also presently in use. Analytical results have shown the presence of BA, a CERCLA pollutant or contaminant.
2. Description of Threat
Explanations of how this release or threat of release meets the criteria for threats to public health or welfare or the environment in section 300.415 (b)(2) of the NCP are discussed below.
a. 300.415(b)(2)(i) "Actual or potential exposure to nearby human populations, animals, or the food chain from hazardous substances or pollutants or contaminants”
b. 300.415(b)(2)(iii) “Hazardous substances or pollutants or contaminants in drums, barrels, tanks, or other bulk storage containers, that may pose a threat of release”
There are unsecured, boxes containing pollutants or contaminants on the site. Due to the impact of flood waters, the integrity of these boxes are questionable and pose a threat of release.
c. 300.415(b)(2)(v) “Weather conditions that may cause hazardous substances or pollutants or contaminants to migrate or be released”
Area rains have caused flooding of the basement, which may have already caused a release off-site. The building’s flood water pumps are inoperative. Conditions are expected to deteriorate with each successive rain event.
ENDANGERMENT DETERMINATION
Actual or threatened releases of hazardous substances from this site, if not addressed by implementing the response action selected in this Action Memorandum, present an imminent and substantial endangerment to public health, welfare, or the environment.
EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED OR NOT TAKEN
A delay in action or no action at this Site would increase the actual or potential threats to the public and the environment.
APPROVAL
This decision document represents the selected removal action for this Site, developed in accordance with CERCLA as amended, and not inconsistent with the National Contingency Plan. This decision is based on the administrative record for the site.
Conditions at the site meet the NCP section 300.415(b)(2) criteria for a removal and through this document, the OSC approves the proposed removal actions. The total project ceiling is $250,000, of which, $ 250,000 will be funded from the Regional removal allowance.
EPA OSC Stilman initiated an emergency removal action to stabilize and secure the contaminated material, and prevent further impact by flood waters, establishing a $250,000 ceiling. The Project Ceiling has been approved by the OSC as documented in this Action Memo/ Initial Pollution Report. ERRS contractor WRS has been mobilized to conduct the removal as directed by the OSC. The PBCHD are also on site to assist with the response.
1. Proposed action description
The specific tasks involved in the proposed response to the threats include:
• Emergency stabilization of the contaminated material;
• Control and treatment of flood waters, as necessary;
• Decontamination of areas in and around the basement, as necessary;
• Determination of the extent of contamination; and,
• Movement and/or disposal of material off-site to allow for the safe conduct of this removal action.
2. Contribution to remedial performance
The proposed actions will, to the extent practicable, contribute to the efficient performance of any long-term remedial action at the site.
3. Description of Alternative Technologies
N/A
4. ARARs
The Federal ARARs identified for the site include:
RCRA Treatment, Storage and Disposal
RCRA Transportation
DOT
OSHA
FIFRA
5. Project schedule
The initial emergency action to stabilize the site is expected to be of a short duration (weeks), however, subsequent time-critical removal activity is expected.
Actions to secure and stabilize contaminated material will continue.
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