United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R10-92/035
April 1992
£EPA Superfund
Record of Decision:
Pacific Hide & Fur Recycling
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.:.,
,.
. "
. ~'.
NOTICE
The appendices listed in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement, but adds no further applicable information to
the content of the document. All supplemental material is, however, contained in the administrative record
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5OZ12.101
REPORT DOCUMENTATION 1'. REPORTNO.
PAGE EPA/ROD/R10-92/035
I ~
3. Reciplenta Acceaaion No.
.. 11118 and SIIbtI..
SUPERFUND RECORD OF DECISION
Pacific Hide & Fur Recycling
First Remedial Action
7. Aulhor(a)
5. Report Date
04/29/92
(Amendment), ID
6.
8. Perfonning Organization RepL No.
8. Filrfonnlng Orgalnlzllllon ...... and Add....
10. ProjectlTaaklWork UnIt No.
11. Contract(C) or Grant(G) No.
(C)
12. ~ Organization ...... and AcIdre..
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
(G)
13. Typa 0' Report & Period Covered
Agency
800/000
,..
15. 8uppIamantary No-
PB93-964602
16. Abatract (Umlt: 200 worda)
The 17-acre Pacific Hide and Fur Recycling site is located in Pocatello, Bannock
County, Idaho. From the 1950's until 1979, McCarty's Inc. operated a recycling
business which primarily accepted scrap metals, including batteries, transformers, and
capacitors filled with PCB oils, which were stored on-site on the excavated pit floor.
A 1988 ROD addressed source control using excavation and immobilization with a
provision for on site containment if the remedy proved unworkable. Prior to
implementation of this remedy, a bench-scale treatability study determined that the
remedy failed to meet several important performance criteria and tentatively identified
the presence of lead above health-based levels. EPA planned to implement the alternate
remedy, onsite containment; however, upon further review, EPA found that the design
requirements of the alternate remedy, as documented in the ROD, did not comply with
federal regulations and determined that construction of an on-site containment cell
would not be feasible because this remedy could significantly interfere with future
cleanup of on-site, lead-contaminated soils. In order to remediate the PCB-contaminated
soils in a timely and protective manner, EPA evaluated other alternatives to the on-site
containment remedy. This 1992 ROD amendment addresses remediation of the
(See Attached Page)
17. Document Analyaia .. Dncriptora
Record of Decision - Pacific Hide & Fur Recycling (Amendment)
First Remedial Action
Contaminated Media: Soil
Key Contaminants: Lead, PCBs.
b. IdentlfleralOpen-Ended Terma
c. COSA 11 Raid/Group
18. A._lability SUItement
18. SKurlty CI... (1111. Report)
None
20. Secuity CI- (This Page)
Nnnc
21. No. of Page.
34
I
22. Price
(See ANSl-Z38. t8)
&Ie IM/rUcliOM on Rave....
272 (4-17)
(FonneI1y NTI~3S)
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EPA/ROD/R10-92/035
Pacific Hide & Fur Recycling (Amendment), ID
First Remedial Action
.\bstract (Continued)
PCB-contaminated areas, as well as areas contaminated with commingled lead and PCBs with
a revised remedy. EPA is continuing to evaluate the nature and extent of lead, and
possible other contaminants at the site and may specify additional clean-up activities,
as necessary, under separate operable unit remedial actions. The primary contaminants of
concern affecting the soil and debris are organics, including PCBs; and metals, including
lead.
The amended remedial action for this site includes excavating, processing, transporting,
and offsite disposal of approximately 8,200 cubic yards of PCB-contaminated and
commingled PCB/lead-contaminated soil as follows: excavation and offsite disposal of
approximately 6,500 cubic yards of untreated PCB-contaminated soil; treating
approximately 900 cubic yards of contaminated soil commingled with over 25 mg/kg PCB and
lead levels exceeding 5 mg/kg, using solidification, followed by disposal in a permitted,
off-site hazardous waste facility; treating approximately 100 cubic yards of PCB-, lead-,
and halogenated organic compound (HOC)-contaminated waste using offsite incineration,
followed by solidifying and disposing of the ash offsite; decontaminating, stockpiling
onsite, and covering approximately 700 cubic yards of debris for possible future salvage
and recycling; and backfilling, grading, and restoring the surface drainage of the site.
The estimated present worth cost for this action ranges from $2,360,500 to $2,429,000.
There is no O&M cost associated with the remedial action.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific soil excavation goals are based on
RCRA hazardous waste and characterization regulations and TSCA PCB regulations, and
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UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION 10
1200 SIXTH AVENUE
SEATTLE, WASHINGTON
AMENDED RECORD OF DECISION,
DECISION SUMMARY,
AND RESPONSIVENESS SUMMARY
:J
FOR THE
POLYCHLORINATED BIPHENYL (PCB)-CONTAMINATED
OPERABLE UNIT REMEDIAL ACTION
MCCARTY'S/PACIFIC HIDE AND FUR
SUPERFUND SITE
SOILS
. ... . .
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,"
Declaration for the
Mccarty'sjPacific Hide and Fur
Superfund site.
Amended Record of Decision
site
McCarty's/Pacific Hide and Fur
Pocatello, Bannock County, Idaho
statement of Basis and Purpose
:J.
This decision document presents the Operable unit Remedial
Action for soils contaminated with polychlorinated biphenyls
(PCBs) at the Mccarty'sjPacific Hide and Fur site in pocatello,
Bannock County, Idaho. While the primary purpose of this
operable Unit Remedial Action is to remove PCB-contaminated soils
from the site, where soils contaminated with PCBs are commingled
with lead (Pb) , the contaminated soil will be treated and
disposed in compliance with all federal and state regulatory
requirements for both PCBs and Ph. This Amended Record of
Decision (Amended ROD) has been developed in accordance with the
comprehensive Environmental Response, compensation, and Liability
Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), 42 U.S.C. S9601 et sea., and
to the extent practicable, the National oil and Hazardous
Substances Po~lution Contingency Plan (NCP), 40 C.F.R. Part 300.
This decision is based on the Administrative Record for this
site, updated in January, 1992, to include new information
generated since the original Record of Decision was signed on
June 28, 1988. The attached index identifies the items which
comprise the Administrative Record upon which the selection of
the Operable Unit Remedial Action is based.
The state of Idaho concurs with the selected remedy.
Assessment of the Site
Actual or threatened releases of hazardous substances from
this site, if not addressed by implementing the Operable unit
Remedial.Action selected in this Amended ROD, may present an
imminent and substantial threat to public health, welfare, or the
environment.
Description of the Revised (Operable Uni~) Remedy
. .. . .
This Amended ROD addresses rem~diation of those" soils .
contaminated with PCBs, and with PCBs commingled with lead (Ph).
The areas of the site subject to cleanup of PCB- and commingled
PCB/ph-contaminated soils are indicated in Figure 2 on page 14A
of this Amended ROD.
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The Operable unit Remedial Action described below is the
response action.planned for the PCB- and commingled PCBjPb-
contaminated soils at the site. The Operable Unit Remedial
Action addresses all threats associated with PCB-contaminated
soils above PCB health-based levels through removal, off-site
treatment (to the maximum extent practicable) and disposal of
such soils. .
with respect to the PCB contamination at this site, no
groundwater remedial action is necessary at this time to ensure
protection of human health and the environment. Results from
sampling conducted o~ on-site groundwater monitoring wells have
not indicated the presence of PCBs at harmful levels, therefore,
groundwater cleanup is not a component of this Operable unit.
However, after further evaluation of all data, including
additional data to be gathered in the future at this site, EPA
may need to reconsider whether to remediate groundwater. If
necessary, cleanup of groundwater will occur under a separate
operable unit remedial action.
it
The major components of the selected Operable unit Remedial
Action for PCB- and commingled PCBjPb-contaminated soils include:
( 1)
Excavation, processing, transport and disposal of
approximately 8,200 cubic yards of PCB-contaminated and
commingled PCBjPb-contaminated soils as follows:
:J
(a)
(b)
(c)
Approximately 6,500 cubic yards of untreated PCB-
contaminated waste will be disposed in an
approved, off-site Toxic Substances Control Act
(TSCA) landfill.
Approximately 900 cubic yards of commingled
PCBjPb-contaminated soils, designated as Resource
Conservation and Recovery Act (RCRA)
characteristic wastes, will be solidified and
disposed in an approved, off-site hazardous waste
landfill. .
Approximately 100 cubic yards of RCRA
characteristic, commingled PCB/Pb-contaminated
soils containing halogenated organic compounds in
excess of 1,000 parts per million (California List
Waste) will be transported to an off-site
incinerator, incinerated and the ash will be
solidified and disposed in an approved, off-site
hazardous waste landfi1.l:........
(d)
Approximately 700 cubic yards of debris (scrap
material) will. be decontaminated, stockpiled and
placed under a protective cover on-site.
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(2)
Backfilling, grading and restoration of surface
drainage will be implemented to the extent that site
restoration does not interfere with the on-going,
investigation and future remediation of other potential
soil and groundwater operable units.
Consultation
A consultation with the Office of Waste Programs
Enforcement, OSWER, regarding this Amended ROD has been conducted
pursuant to the 22nd Remedy Delegation - FY91 memorandum
(December 27, 1990). -
Declaration
This Operable unit Remedial Action is protective of human
health and the environment, complies with Federal and state
applicable or relevant and appropriate requirements, and is cost
effective. This Operable unit Remedial Action also utilizes
treatment, where feasible and practicable. Subsequent actions
will address other soil (and possibly groundwater) threats posed
by conditions at this site.
:.1
The selected Operable unit Remedial Action for addressing
PCB- and commingled PCB/pb-contaminated soils is excavation;
treatment of the contaminated soils to the maximum extent
practicable; and, off-site disposal in a permitted, hazardous, ~
waste landfill. While the selected remedy will not result in the
total destruction of the PCBs and Pb, the most potentially
hazardous component (i.e. contaminated soil exceeding the 5 parts
per million [ppm] RCRA leachate test level and containing
halogenated organic compounds in exess of 1,000 ppm) will be
incinerated and the ash solidified prior to disposal. Soils
which only fail the 5 ppm RCRA leachate test level will be
solidified and disposed in a permitted, off-site hazardous waste
landfill.
Treatment technologies considered during the initial
screening of alternatives and presented in the operable unit
focused feasibility study included off-site and on-site
incineration, bioremediation, chemical dechlorination and lime
treatment. These technologies were eliminated from further
detailed analyses as operable unit remedial alternatives for the
following reasons: '
Incineration (off-site and on-site): The use 'of this
treatment as the primary remedial' t~chnology is not feasible
due to the significant material processing requirements for
approximately 7,500 cubic yards of scrap metal intermixed
with contaminated soil. In order to successfully implement
this remedy, a stringent downstream soil contaminant size
limitation must be attained prior to treatment. In
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achieving the size limitation, considerable delays in
implementation would result. The time required to obtain
the use of an incinerator for either on- or off-site.
incineration could cause further delays in implementation of
the remedy. This cleanup technology is also substantially
greater in cost than the selected remedy. Finally,
utilization of incineration as the primary treatment
technology would not be necessary to comply with applicable
or relevant and appropriate requirements (ARARs).
,
Bioremediation and Chemical Dechlorination: These treatment
technologies also require significant material processing as
described above under Incineration. Additionally,
bioremediation and chemical dechlorination have not been
demonstrated to be effective" at reducing PCB contaminant
levels to less than 25 parts per million in soils mixed with
scrap metal. Further treatment is also likely to be
necessary following either bioremediation ~r chemical
dechlorination in order to comply with the TSCA or the RCRA
regulations.
:.1
Lime treatment: Results from an EPA study of the lime
treatment process' performance indicate that reductions in
PCB concentrations in soil were attributable mainly to
volatilization and not to the use of lime in treating the
contaminated soils.
This Operable unit Remedial Action will eliminate the source
of PCB contamination at the site. While this Operable unit
Remedial Action will effectively and permanently remove PCB-
contaminated soils from the site, other hazardous substances
(i.e. Pb and other inorganic compounds) will remain on-site above
health-based levels until EPA develops final remedial
alternatives for the remainder of the site. Because this is an
Operable unit cleanup, review of this Operable unit will continue
during development of final remedial alternatives for the
remaining contaminated areas of the site. Appropriate statutory
and policy 5-year reviews will be conducted on both the Operable
unit Remedial Action and the final Remedial Action at this site
to ensure that the remedies are providing adequate protection of
human health and the environment.
. UL:;~~
f Dana A. Rasmussen
~egional Administrator
u.s. Environmental Protection
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. t.l1 ~q , q2-
Date
Agency, Region 10
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MCCARTY'S/PACIFIC HIDE AND FUR
SUPERFUND SITE
AMENDED RECORD OF DECISION
DECISION SUMMARY
TABLE OF CONTENTS
INTRODUCTION
REASONS FOR ISSUING AMENDED ROD
SITE HISTORY AND ENFORCEMENT ACTIVITIES
SCOPE AND ROLE OF OPERABLE UNIT REMEDIAL ACTION
~
SUMMARY OF SITE CHARACTERISTICS
SUMMARY OF SITE RISKS
DESCRIPTION OF NEW SOIL OPERABLE UNIT REMEDIAL ALTERNATIVES
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
SELECTED OPERABLE UNIT REMEDIAL ACTION
STATUTORY DETERMINATIONS
DOCUMENTATION OF SIGNIFICANT CHANGES
Appendix A:
THE RESPONSIVENESS SUMMARY
Appendix B:
ADMINISTRATIVE RECORD
List of Fiqures
Figure 1
site Location
. - .
Figure 2
McCarty's/Pacific Hide & Fur operable'unit
Remedial Action Areas
Table 1
comparison of Soil Operable unit Cleanup
Alternatives
6
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Paqe
7
9
11
12'
13
14 '
15
20
. 24
26
30
31
33
7A
14A
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MCCARTY'SjPACIFIC HIDE AND FUR
SUPERFUND SITE
AMENDED RECORD OF DECISION
Decision Summary
Introduction
site Name and Location:
The Mccarty'sjpacific Hide and Fur Superfund site consists
of approximately seventeen (17) acres located in the southern
half of section 16, Township 6 South, Range 34 East of the Boise
Meridian, Bannock County, Idaho. Eleven (11) of these acres are
enclosed by a fence and are the focus of this Operable Unit
Remedial Action. The site is situated at the northwestern edge
of Pocatello, Idaho at 3500 U.S. Highway 30 West. A vicinity map
is shown in Figure 1 on page 7A of this document.
Lead and Support Aaencies:
:.1
EPA is the lead agency for this Superfund site, with the
cooperation and support of the Idaho Division of Environmental
Quality (IDEQ).
Date of the Oriqinal Record of Decision:
The original Record of Decision (ROD) was signed on June 28,
1988.
Administrative Record:
This Amended ROD will become part of the Administrative'
Record file for this site, in accordance with section
300.825(a)(2} of the NCP. The Administrative Record is available
for review at the EPA Regional Office, 1200 sixth Avenue,
Seattle, Washington, 98101, and at the Pocatello Public Library,
812 East Clark Street, Pocatello, Idaho. An index of the
Administrative Record is included with this Amended ROD.
Hiahliahts of Community Participation:
community Relations efforts prior to June 28, 1988, are
described in the community Relations section of the original
The f.ollowing community relations acti.vities are relev~nt to
Amended ROD: .
ROD.
this
July 14, 1988
Fact sheet announcing signing of the Record
of Decision.
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October 7, 1988'
October 6, 1989
October 26, 1989
January 26, 1990
..
July 1990
September 28, 1990
:t
May 9,' 1991
December 1991
January 24, 1992-
February 24, 1992
January 24, 1992
February 1992
Fact sheet announcing start-up of the pilot
treatability study.
Fact sheet announcing the start of remedial
action field work.
'. Press opportunity to allow reporters to view
, cleanup activities in progress.
Fact sheet announcing the change in remedies
selected for the site. Information provided
in the fact sheet described the alternative
remedy and the rationale for changing
remedies. .citizens were asked to contact the
EPA project manager to request an
informational meeting about the change in
remedy.
Fact sheet announcing additional soil and
groundwater sampling to be conducted.
Explanation of Significant Differences fact
sheet explaining that neither the original'
,remedy from the June 1988 ROD nor the
contingent remedy selected in January 1990
were feasible.
Fact sheet describing the results of
additional soil and groundwater sampling
conducted in July 1990. Lead contamination
was found on-site. This new information
required EPA to halt construction of the
remedy.
Fact sheet describing in more detail the
extent of the lead contamination found on-
site and explaining that the site will be
divided into operable units for purposes of
cleanup.
Public comment period for Amended ROD.
. Proposed Plan released to public on January
23, 1992. citizens were asked to contact the
EPA project manager to reque$t a public
meeting to discuss the proposed changes to
the current remedY.,. ~. ".'. .
Display ad was issued in the Idaho State
Journal newspaper describing the Amended ROD
and public comment period dates.
EPA prepared the Responsiveness Summary.
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. One citizen responded during the public comment period,
requesting a more detailed presentation, with supporting
evidence, of current site risks and risks following cleanup.
EPA's response to the citizen's comment can be found in the
Responsiveness Summary on pages 31-32 of this Amended ROD.
REASONS FOR ISSUIN~THE AMENDED ROD
circumstances Promptinq Amended ROD:
EPA has determined that an Amended ROD is necessary for this
site. The Amended ROD changes the remedy originally selected for
the site. The new approach divides the site into operable units
and this Amended ROD addresses remediation of those soils
contaminated with PCBs and commingled PCBs and lead (Pb). The
operable unit approach was made necessary by the discovery of
widespread Pb contamination in on-site soils.
Backqround:
:J
In 1988, a remedial investigation and feasibility study
(RI/FS) of PCB contamination was completed for the site. Based
on the results of the FS, EPA identified stabilization/
consolidation of the PCB-contaminated soil and debris as the
preferred treatment alternative. EPA proposed a cleanup. plan for
the PCB-contaminated soil and debris at the site and requested
public comment on the proposed plan. Following consideration o~
~he public comments, EPA decided on a site cleanup plan, which
was described in the ROD issued in June 1988.
Remedv Selected in the 1988 ROD:
The major components of the remedy selected on June 28, 1988
included: .
( 1)
Determining which portions of the contaminated
materials could practicably be excavated and processed
(screened). Factors used in making this determination
were worker and public health, and physical limitations
of excavation and processing equipment.
(2)
Excavation of all highly contaminated materials which
could practicably be excavated and processed.
. (3)
Excavation of all low level contaminated soils to 25
ppm. Excavation would cease wh~n those soils
containing contaminants that-. exceeded the 10-4. to 10-7
cancer risk values had been removed. The' 25 ppm PCB
soil cleanup level corresponded to a risk range of 3 x
10-4 to 5 X 10-6.
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(4)
Immobilization of processed material in the fixation
matrix.
Consolidation of remaining materials of concern.
(5)
(6)
Construction of a bottom liner, where necessary.
Construction of a cap over the entire unit.
(7)
(8)
Construction of groundwater monitoring wells.
(9)
Removal from service of existing groundwater monitoring
wells which were no longer needed.
Subsequent Events and New Information:
=
A provision was made in the ROD for an alternative remedy,
on-site containment, should the preferred remedy prove
unworkable. A small scale study was performed to determine
whether stabilization of PCB-contaminated soils could ensure
long-term, permanent protection from PCBs leaching into the
groundwater. The study results indicated the remedy failed to
meet several important performance criteria. The small scale.
study also revealed the potential presence of lead (Pb) above
recommended health-based levels. EPA has undertaken additional
soil and groundwater sampling following review of the data from
this study.
~
Based on the failure of several of the study's performance
criteria, EPA decided to allow for implementation of the
alternate remedy which was on-site containment. However, upon
further review of the ROD description of the alternate remedy,
EPA determined that the design requirements did not comply with
federal regulations. The containment cell design described in
the June 1988 ROD did not include a proper liner, cap or leachate
collection system to meet both TSCA and RCRA chemical waste
landfill regulatory requirements. On september 26, 1990, EPA
published an Explanation of Significant Differences (ESD). The
ESD clarified the design requirements of the on-site containment
remedy necessary to meet the federal regulations.
Summary of EPA's Rationale for Chanqina the Alternate Remedv:
In October 1990, the results from EPA's August 1990 sampling
of site soils (including the operating Pacific Ste~l Recycling
facility and adjacent Union Pacific Railrpad property) confirmed
the presence of extensive lead (Pb) cont~mination above safe
levels. EPA began to consider changing the alternate soils
remedy following receipt of this new information.
EPA determined that construction of an on-site containment
cell would not be feasible because this remedy could
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significantly interfere with future cleanup of on-site, Pb-
contaminated soils. In addition, since Pb had not been
identified as a contaminant of concern in, the RI completed in
1988, the on-site containment remedy would require either
redesign of the containment cell or further treatment of the
wastes to meet the requirements of the Resource Conservation and
Recovery Act (RCRA). As a result, EPA halted all remedial
activities at the site.
In order to remediate the PCB-contaminated soils in a timely
and protective manner, EPA evaluated other alternatives to the
on-site containment remedy. It was determined that an operable
unit approach would considerably speed the cleanup of PCB-
contaminated and commingled PCBfpp-contaminated soils and other
contaminated debris because: (1) the geographic 'extent of the PCB
contamination is confined to specific areas on-site while the Pb
contamination is widespread across the site, and (2) the RIfFS
for the PCB contamination was completed in 1988, however, a
comprehensive RIfFS evaluation associated with the Pb and
possible other inorganic contamination has not yet been performed
and will be required in order to remediate the remainder of the
site.
~
EPA is continuing to evaluate the nature and extent of the
Pb, and possible other compounds, which may be contaminating both
the soil and groundwater on the site. Additional cleanup of the
soil and groundwater, if necessary, will occur later under
~eparate operable unit remedial actions.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
In 1984, the site was added to the National Priorities List
(NPL) under CERCLA. In 1988, after completion of a detailed
study of the nature and extent of contamination and a detailed
analysis of cleanup alternatives, a remedy for the site was
selected and described in a ROD. site history and enforcement
activities prior to the original ROD are discussed in that
section of the June 28, 1988 document, to which the reader is
referred for details.
In July 1988, special notice letters were sent to Pacific
Hide and Fur, Inc., ,McCarty's, Inc., members of the McCarty
family and Idaho Power Company, who had been identified as
potentially responsible parties (PRPs) believed to have
contributed to the PCB contamination. The special notice letters
initiated negotiations on a PRP-lead reme~ial design/remedial
action (RD/RA). After a second invitation to participate in
negotiations w~s sent to the identified PRPs in January 1989
following previous, unsuccessful attempts to negotiate a
settlement, 'Idaho Power Company (IPCo) and EPA entered into a
consent decree in which IPCo agreed to complete the RD, implement
the RA, reimburse EPA for a portion of the past costs incurred by
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the government, and fund three years of operation and
maintenance. This consent decree became effective on September
25,1989.
-
In an attempt to recover the remaining outstanding past
government response costs, settlement negotiations with Pacific
Hide and Fur, Inc., the individual McCartys, and McCarty's, Inc.
were conducted by EPA in 1990. These negotiations focused on
those costs associated with PCB contamination within the fenced
portion of the McCarty owned property. settlement with these
parties has not been reached, and civil litigation is on-going in
federal district court in Idaho whereby EPA is seeking to recover
its costs from these parties. At the request of EPA, a trial
date has been postponed in this matter to allow for the time
necessary to determine the cleanup requirements for all
contamination at the site.
~
An investigation to identify PRPs who are potential sources
of the Pb contamination was completed by EPA in December 1991.
Letters were sent to several identified PRPs to notify them of
their potential liability for the site, to obtain additional
information from these parties, and to seek their cooperation in
undertaking and financing further investigation and cleanup
related to lead and other compounds found in soil and
groundwater.
SCOPE AND ROLE OF THE OPERABLE UNIT REMEDIAL ACTION
There are approximately 8,200 cubic yards of PCB-
contaminated and commingled PCB/pb-contaminated material which
exceed 25 ppm PCBs and require cleanup. The '25 ppm cleanup. level
is based on property access limited to industrial activities and
exposure risks to on-site workers within the acceptable risk
range of 10-4 to 10-6. Treatment will be required of the
commingled PCB/pb-contaminated soils (approximately 900 cubic
yards), where the concentration of Pb contamination exceeds the 5
ppm RCRA toxicity characteristic leachate (TCLP) extraction test
level. In addition, RCRA characteristic soils designated as
California list waste (i.e. exceeding the 1,000 ppm halogenated
organic compound level) must be treated as required by the RCRA
land disposal restrictions. The selected operable unit Remedial
Action will address the PCB- and commingled PCB/Pb-contaminated
soil and debris at this site.
The selected Operable unit Remedial Actio~ involves the
excavation and disposal of PCB- and comm~gled PCB/Pb-
contaminated soils in an off-site, permitted, hazardou& waste
landfill. Testing of excavated soils will be conducted to
determine the specific amount requiring special treatment prior
to off-site disposal. If deemed necessary, treatment will
include sOlidifying a portion of the soils which fail the RCRA
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TCLP extraction test into a cement-like mass. Those soils
failing TCLP and containing halogenated organic compounds in
excess of 1,000 ppm will be incinerated and the ash solidified
prior to placement in an off-site, hazardous waste landfill. Any
material greater than 6 inches in diameter will be
decontaminated, relocated and placed under protective cover on-
site to prevent interference with on-going and future cleanup
activities. Following cleanup of the contaminated soil, the site
will undergo minor restoration in those areas which will not
interfere with the on-going investigation and remediation of the
remaining contamination. Restoration will include backfilling
the excavated areas, -and grading to restore surface drainage.
The NCP encourages and authorizes the use of operable units
to speed cleanup of distinct hazardous substances or areas of a
site. By using an operable unit approach, EPA will be able to
maximize reductions in risks to human health and the environment
from hazards associated with PCB-contaminated and commingled
PCB/Pb-contaminated soils at the site consistent with the NCP.
The PCBs and commingled PCBs and Pb are present at the site in
discrete areas, while remaining areas of the site are
contaminated,with Pb and possibly other inorganic compounds at
harmful levels.
~
Because the results from sampling conducted of on-site
groundwater monitoring wells have not indicated the presence of
PCBs at harmful levels, groundwater cleanup is not a component of
this 0perable Unit Remedial Action.
SUMMARY OF SXTE CBARACTERXSTXCS
site characteristics are described in detail in the site
Characteristics-Remedial Investigation section in the original
June 28, 1988 ROD, to which the reader is referred. Information
pertinent to changes in the remedial action at the site is
presented below.
The RI/FS, conducted from 1986 to 1988, focused on PCB
contamination of soils and groundwater. The RI/FS results
documented that risks posed by the presence of PCBs in soils
exceeding 25 ppm justified taking remedial action. PCBs were not
found at harmful levels in groundwater.
Based on the ROD's preferred alternative of stabilization/
consolidation, a treatability study was undertaken in 1989-1990
to determine an appropriate mix of record and .to determine
whether the remedy could meet stringentc'performance criteria.
Soil samples, composited from four on-site areas and' two off-site
areas, were analyzed for lead in addition to PCBs. , Lead
concentrations from on-site soil samples ranged from 2,640 to
55,900 ppm. EPA determined that further evaluation of site soils
was necessary to establish the extent of the lead contamination.
-------
.
sampling conducted by EPA in August 1990 and May 1991
indicates that there is widespread Pb contamination across the
entire site. Concentrations range from 67.4 ppm to 64,700 ppm
and are commingled with PCBs where PCBs occur on-site. Figure 2
on page 14A of this document identifies those on-site areas
contaminated with PCBs and commingled Pb which will be remediated
by this Operable Unit Remedial Action. One additional location
on-site which had not been previously identified as a PCB hot
spot will be remediated as a result of additional data collected
by Idaho Power Company.
Preliminary data from additional groundwater studies
recently. conducted by EPA indicate that Pb has been found in on-
site groundwater monitoring wells at levels which may require
remediation. EPA will determine the need to remediate
groundwater following a thorough, quality-assured review of all
appropriate data. Cleanup of the remaining soils, and
groundwater, if necessary, will occur under future operable unit
remedial actions. .
SUMMARY OF SITE RISKS
~
The results of the risk assessment performed for this site
are described in the Summary of Site Risks section of the June
28, 1988 ROD, to which the reader is referred for details. The
following is a discussion of the basis for taking action to
remediate PCB- and commingled PCB/Pb-contaminated soils by thisi
Operable Unit Remedial Action.
Basis for Takinq Action to Remediate Soils:
PCBs are the contaminants of concern in this operable unit
cleanup. PCBs have been shown to produce a variety of non-cancer
health effects, including liver and thyroid diseases. Several
studies have shown that PCBs can cause cancer in laboratory
animals, and that PCBs may cause cancer in humans as well. The
portion of the Pb contamination which is commingled with the PCBs
at the site, will also be remediated as part of this operable
unit. Pb is known to cause damage to the central nervous system
and is especially harmful to fetuses and children during the
developmental stages.
An assessment of the risk posed to human health and the
environment by PCB contamination was conducted in 1988. site
risk for total exposure to PCBs was estimated to'be 2.1 x 10-3
which lies outside of EPA's acceptable risk range of 1 x 10-4 to
1 X 10-6. Direct contact with the con~aminated soils was.
determined to be the only route of exposure for PCBs' at this
site.
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'-=
Rgure 2
McCarty'sJPaclflc Hide and Fur Superfund Site, Pocatello, Idaho
....
.t-
>
- -It, U.S. Highway 30 - -
\
\
c::J Buildings "
c:::> Pit Area
- Site Fence Line
:::::Approxlmate Location of Road/Equipment Accesses
I:::ttiI:il PCB/Lead Contamination Areas
r.::"J Newly Discovered PCB/Lead Contamination Areas
,.
o 80
~ ..-:f
Scale In Feet
160
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~
In 1988, EPA's PCB Spill Cleanup Policy was used to
establish a cleanup level for the site. For restricted access
areas which would include this site, the PCB cleanup policy
called for contaminated soil to be remediated to 25 ppm. A
cancer risk range was then calculated for unprotected, PCB-
contaminated soils remaining on-site at the 25 ppm cleanup level.
The risk estimated for this cleanup level ranged from 5 in
1,000,000 (5 x 10-6) to 3 in 10,000 (3 x 10-4) which EPA has
determined to be an acceptable risk. The first example means
that if a group of 1,000,000 people were exposed to these
conditions over a 70~year lifetime, an additional 5 people would
be expected to develop cancer beyond the 25,000 cancer events
expected from other causes. Current cancer statistics indicate 1
in 4 people in the u.S. will develop cancer in their lifetime.
Although Pb poses a risk to human health and the
environment, a risk-based cleanup level associated with the Pb,
and possible other inorganic contamination in site soils and
groundwater has not yet been determined. These risks will be
calculated later as part of separate operable unit evaluations.
\<
Based on the increased risk of cancer and other diseases and
the requirements of CERCLA, EPA has determined that remediation
of PCB- and comming~ed PCB/pb-contaminated soil is necessary.
DESCRIPTION OF THE NEW SOIL OPERABLE UNIT CLEANUP ALTERNATIVES \
Explanations of the two final candidate remedies which EPA
considered for remediation of the PCB-contaminated and commingled
PCB/pb-contaminated soils operable unit are provided below.
These alternatives were developed by reviewing the focused
operable unit feasibility study, original RI/FS, ROD,
treatability study, results of the soil sampling conducted by EPA
in August 1990 and May 1991, and the quarterly groundwater -
monitoring which EPA commenced in July 1990.
Remedial actions must comply with all legally applicable or
relevant and appropriate federal and state requirements (ARARs).
ARARs were determined at the time of the 1988 ROD, but since that
ROD is being amended, ARARs have been re-evaluated and are
discussed below in relation to the final candidate alternatives.
RCRA requirements pertaining to defining, characterizing and
listing hazardous waste, land disposal restrictions, and
generator and transporter requirements w~re not listed as an ARAR
in the original 1988 ROD. However, the~presence of lead
commingled with the PCBs requires consideration of-these RCRA
requirements for cleanup under this Operable unit Remedial
Action. For those soils failing TCLP, off-site treatment and
disposal must meet RCRA land disposal restrictions. In addition,
-------
those soils failing TCLP and exceeding the 1,000 ppm RCRA
regulatory level for halogenated organic compounds must meet RCRA
treatment and disposal requirements for California list waste~
The Departm~nt of Transportation's Hazardous Materials
Regulations which address shipment of any hazardous material off-
site are also a new ARAR. This Operable unit Remedial Action
requires contaminated material be transported off-site for
treatment and disposal.
Idaho state Solid Waste Management Regulations and Standards
and additional standards for protection of state groundwater
under the. Idaho Adminstrative Procedures Act have been added as
new ARARs.
Key features of the remedy and ARARs that are common to the
two alternatives are as follows:
PCBs are the principal contaminant of concern of this
Operable Unit Remedial Action. The applicable action-
and chemical-specific federal cleanup requirements for
PCBs are described in the Toxics Substances control Act'
(TSCA) PCB regulations for storage and disposal of PCB-
contaminated media (40 C.F.R. Part 761).
:.I
Lead (Pb) commingled with the PCBs will be remediated
as part of this Operable unit Remedial Action.
Theref9re, the applicable action- and chemical-specific
federal cleanup requirements described in the Resource
Conservation and Recovery Act (RCRA) regulations and
the corresponding State of Idaho requirements must be
attained for RCRA characteristic and California list
waste resulting from the Pb and PCB contamination found
on-site.
Both alternatives include excavation of contaminated
soils on-site by conventional and protective methods.
During these activities, air monitoring will be
conducted and dust suppressive measures will be
utilized to control the release of dust and
particulates. These measures will comply with the
applicable federal Clean Air Act requirements (42 use
7409, 7412) and the Idaho Rules and Regulations for the
Control of Air Pollution in Idaho (Citation section
16.01.1011-1012, 16.01.1251-1253, and 16.01.1501-1504).
Pocatello is a federal, nonattainment area for
particulate matter (PM10). Dust..control measu.res must
be implemented to prevent remedial activities at the
site from causing or contributing to a violation of the
national ambient air quality (NAAQS) or the state total
suspended particulate matter (TSP) standards.
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Transportation of materials from the site to disposal
facilities will be done in accordance with Department
of Transportation Hazardous Materials Regulations which
address shipment of any hazardous material off-site (49
CFR, Parts 171, 172, 173 Subparts A, B, J and N, and
177, 178 and 180, and Subchapter C), the Idaho Code
Sections 67-2929, 2930 (Supplement 1988) and 49-2201
through '2,212, and the Idaho Hazardous Waste Management
Regulations (IHWMR) section 16.01.5500.
occupational Safety and Health Act (OSHA) requirements
(29 CFR Pa~t 1910 and 1926) pertain to workers engaged
in response or other hazardous waste operations.
Excavation of the PCB- and commingled PCB/Pb-
contaminated soils is considered a hazardous waste
operation at this site.
~t
section 121(d) (2) (A) of CERCLA, 42 U.S.C.
S9621(d)(2) (A), requires on-site CERCLA remedies to
attain and maintain standards or levels of control
(i.e. maximum contaminant concentrations [MCLs) and
maximum contaminant concentration goals [MCLGs)
established under the Safe Drinking Water Act (SDWA) ,
(42 usc 390). According to the NCP (55 FR 8848), where
MCLGs are set at zero, the remedial actions shall
attain and maintain MCLs for ground or surface water
that are current or potential sources of drinking
water. The PCB MCL of 0.5 parts per billion (ppb)
shall be maintained and used as the groundwater
standard for the site. Under the Clean Water Act (CWA)
(33 'USC 1251, 40 CFR Part 230, 231), state
Antidegradation Requirements/Use Classification require
every state to classify all the waters within its
boundaries according to intended use. There are two
aquifers (Upper and Lower) beneath the site. EPA has
designated the Upper Aquifer as Class IIB since it is
potentially available for drinking water, agriculture
or other beneficial uses. The Lower Aquifer is Class I
(i.e. drinking water) as it is the primary drinking
water source for the community. CWA (40 CFR Part 122)
addresses storm water runoff from site operations.
The various Idaho state standards primarily address
solid waste management Idaho Solid Waste Management
Regulations and Standards Manual (section
16.01.6005,01, 16.01.6008,07), and protection of state
groundwater (Idaho Administ~ative Procedures ,Act
[IDAPA] section 16.01.205,0,02, 16.01.2020',D6,
16.01.2051, 16.01.2200, and 16.01.01.2800) against
unreasonable contamination or deterioration. These
standards are designed to control and regulate the
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public drinking water system in order to protect the
health of consumers.
operable unit Alternative 1:
On-site containment and Capping
This alternative would involve the construction of a
hazardous waste la~dfill cell including a liner and leachate
collection system which meet TSCA requirements, and excavation
and dispo~al of approximately 8,200 cubic yards of PCB-
contaminated and commingled PCB/pb-contaminated soils as
described below.
Because of the elevated levels of Pb found commingled with
PCBs in approximately 900 cubic y~rds of soils, additional
leachate testing required by RCRA would be conducted. Soils
failing this test would be solidified prior to disposal in the
on-site TSCA hazardous waste landfill cell as required by RCRA.
~
On July 8, 1987, EPA enacted a second phase of the RCRA land
disposal restriction program to restrict the land disposal of
California list wastes. Soils containing halogenated organic
, compounds (HOCs) in excess of the RCRA'regulatory level of 1,000
ppm are designated as California list waste. There are .
approximately 100 cubic yards of HOC-contaminated soils which
would be transported by truck to an off-site incinerator. and the
ash solidified prior to disposal in an off-site, permitted, .
hazardous waste landfill. HOCs, compounds which contain a
carbon-halogen chemical bond, are commonly found in many PCB
compounds.
The approximate remaining 6,500 cubic yards of PCB-
contaminated and commingled PCB/pb-contaminated soil which did
not fail the leachate test or did not contain HOCs in excess of
1,000 ppm and the 700 cubic yards of debris (scrap material) .
would be placed untreated into an on-site, TSCA containment cell.
Following remedial activities, the TSCA landfill cell would
be capped to meet RCRA requirements. Minor restoration would
occur such that it did not interfere with the on-going
investigation and remediation of future operable units.
Administrative and institutional controls such
groundwater monitoring, deed restrictions, leachate
system inspection, and ensuring site security would
implemented as described in the 1988 ROD. .
as
collection
also be
Cost estimate:
$4,350,000
. - . .
operable unit Alternative 2:
Off-site Treatment and Disposal
This alternative would remove all PCB-contaminated and
commingled PCB/pb-contaminated soil from the site. Treatment and
-------
.
disposal of the waste in an approved, off-site, hazardous waste
landfill facility would be determined based on leachate and HOC
testing as described in Alternative 1. The most highly.
contaminated and hazardous soils which fail either the leachate
or HOC testing will be solidified or incinerated and the ash
solidified prior to placement in an off-site, hazardous waste
landfill as required by RCRA. Those soils which do not fail the
RCRA TCLP test will. be transported by truck to an approved, off-
s~te TSCA landfill for disposal. All material removed from the
site will be transported by truck to the off-site
treatment/disposal facility. PCB-contaminated scrap and debris
too large for treatment and/or disposal in an off-site, hazardous
waste landfill would be decontaminated and stockpiled on-site for
possible future salvaging or rec~cling.
Following cleanup of the contaminated soil, the site would
undergo minor restoration in those areas which would not
interfere with the on-going investigation and remediation of
future operable units. Restoration would include backfilling the
excavated areas and grading to restore surface drainage. A
protective cover, such asa tarp, would be. placed over the
decontaminated, stockpiled scrap.
~
This operable unit alternative would not include
administrative and institutional controls such as groundwater
monitoring, leachate collection system inspections, or deed
restrictions since all PCB-contaminated soil would be removed
from the site property and PCBs have not been detected in
groundwater above maximum contaminant levels (MCLs). An existing
fence surrounds the site and is sufficiently secure to prevent
unwarranted access during on-going cleanup activities at the
site. Future administrative and institutional controls may be
required when the final remedial action has been completed and
the site is entirely cleaned up.
Cost estimate:
$2,360,500-$2,429,000
other operable unit Treatment Technoloqies considered:
The following list of additional alternatives, considered
during the initial screening of appropriate technologies and
process options, were eliminated from further detailed analyses
as operable unit remedial alternatives.
Incineration (off-site and on-site): The use of this
treatment as the primary remedial technology'was eliminated
from further consideration because~ot'the: (1) significant'
material processing requirements for approximately 7,500
cubic yards of scrap intermixed with soil. In order to
successfully implement this remedy, a stringent downstream
soil contaminant size limitation must be attained prior to
treatment.. Achieving the size limitation could result in
-------
.'
potentially' significant delays; (2) time required to obtain
the use of an incinerator for either on-or off-site
incineration; (3) substantially greater cost of the
cleanup; and, (4) utilization of incineration as the
primary treatment technology is not necessary to comply with
ARARs.
Bioremediation.and Chemical Dechlorination: These treatment
technologies also require significant material processing as
described under Incineration above. Additionally,
bioremediation and chemical dechlorination have not been
demonstrated to be effective at reducing PCB contaminant
levels to less than 25 ppm in soils mixed with scrap metal.
Further treatment is likely ~o be necessary following either
bioremediation or chemical dechlorination in order to comply
with the TSCA and RCRA regulations. For these reasons,
bioremediation and chemical dechlorination were eliminated
from further consideration as potential treatment
technologies.
:J
Lime treatment: Results from an EPA study of the lime
treatment process' performance indicate that reductions in
PCB concentrations in soil were attributable mainly to
volatilization ,and not the use of lime in treating the
contaminated soils. These results cast sufficient doubt on
the efficacy of the lime treatment process to remove it from
further consideration as a treatment alternative. ':'
Table 1 provides a summary of the relative performance of
these treatment technologies compared to the final two operable
unit alternatives.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
For the purpose of operable unit remedy selection, the
relative performance of each remedial alternative was evaluated
in relation to three categories of criteria: (1) threshold
criteria [a required level of performance]; (2) primary
balancing criteria; and, (3) modifying criteria. The'nine
evaluation criteria and the results of the evaluation are
discussed below. A summary of relative performance of the
alternatives based on these criteria is included in Table 1 on
page 24A of this document.
fu.
,Threshold criteria
The operable unit remedial alterna~ive~ were first, evaluated
in relation to the threshold criteria: overall protection of
human health and the environment, and compliance with ARARs. The
threshold criteria are statutory requirements and must be met by
all alternatives that remain for final consideration as operable
unit remedies for the site.
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1. Overall protection of Human Health and the Environment:
This criteria addresses whether or not a remedial alternative
provides adequate protection and describes how risks are
eliminated, reduced, or controlled through treatment and
engineering or institutional controls.
Alternatives 1 and 2 are equally protective of human health
and the environment since both address the source of PCB
contamination at the site. Risks posed by both PCB- and
commingled PCB/pb-contaminated soils are eliminated since these
soils will be treated to the extent practicable and either
disposed in an approved on-site, hazardous waste landfill cell or
removed from the site and disposed in a permitted, off-site
hazardous waste landfill.
2. Compliance with Applicable or Relevant and Appropriate
Requirements (ARARS): This criteria addresses whether or not a
remedial alternative will meet all of the applicable or relevant
and appropriate requirements or provide grounds for invoking a
waiver.
~,I
Both Alternatives 1 and 2 met the applicable or relevant and
appropriate requirements (ARARs) at the time the ROD was signed
in 1988 and still do. Alternatives 1 and 2 also meet all new
ARARs. An Explanation of Significant Differences was written in
September 1~90 for Alternative 1 to clarify design requirements
necessary to meet federal regulatory requirements. :
Alternative 1 (on-site containment) does not trigger RCRA
land disposal requirements while Alternative 2 (Off-site
Disposal) does.
1h
Primary Balancinq criteria
Once an operable unit remedial alternative satisfied the
threshold criteria, five primary balancing criteria were used to
evaluate the technical and engineering aspects of the operable
unit remedial alternatives. .
3. Long-term Effectiveness and Permanence: This criteria
refers to the ability of a remedial alternative to maintain
reliable protection of human health and the environment once
remed~ation goals have been achieved. The magnitude of the
residual risk is considered as well as the adequacy and
reliability of controls. .
Alternative 2 best satisfies this criteria because all of
the PCB- and commingled PCB/Pb-contaminated soil will be removed
from the site thereby eliminating the source of the on-site PCB
contamination. Alternative 1 satisfies this criteria as long as
the cap over the containment cell is not disturbed and the bottom
liner remains intact.
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.'
Because approximately 6,500 cubic yards of PCB-contaminated
soils would not be treated prior to disposal, remedial activities
associated with these alternatives do not entirely meet the
stated preference of the Superfund law which calls for
utilization of permanent solutions and treatment to the maximum
extent practicable. However, the most hazardous component of the
soils would be tre~ted as discussed below under criteria 4.
below.
4. Reduction of Toxicity, Mobility or Volume Through Treatment:
This criteria refers to the anticipated performance of treatment
technologies which will be used in the various remedial
alternatives, such as solidification and incineration, for
example.
Both Alternatives 1 and 2 achieve the same degree of
reduction of toxicity, mobility or volume through treatment since
they both employ methods to: (1) solidify the waste component
containing leachable Pb exceeding the RCRA regulatory level of 5
ppm (toxicity characteristic level); (2) and, utilize
incineration and solidification to treat wastes containing
halogenated organic compounds above 1,000 ppm.
~
While neither alternative results in the total destruction
of the PCBs and Pb, the most potentially hazardous component
would be incinerated, and contaminated soil exceeding the 5 ppm
RCRA leachate test level would be solidified to prevent the :
likelihood of movement of leachable Pb. Therefore, both
alternatives reduce mobility, by sOlidifying a portion of the
contaminated soils, and, to some extent volume, by incineration.
However, Pb remaining in the resulting ash will be in a more
concentrated form.
s. . Short-term Effectiveness: This criteria refers to the
period of time needed to achieve protection, and any adverse
impacts on human health and the environment, specifically site
workers and community residents, that may be posed during the
construction and implementation period until cleanup goals are
achieved.
Alternatives land 2 could create some short-term risk
during excavation. Truck transport of soiis for off-site
treatment and disposal would increase short-term risks, primarily
in Alternative 2.
The off-site disposal remedy (Alternative 2) is estimated to .
take 24 weeks to implement, while the ~n~site containment remedy
(Alternative 1) is estimated to take 30 weeks. Therefore,
Alternative 2 would provide protection in a shorter timeframe
than Alternative 1. .
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'.
.
6. Implementability: This criteria refers to the technical and
administrative feasibility of a remedial alternative, including
the availability of goods and services needed to implement the
selected remedy.
Even though both Alternatives 1 and 2 can meet the 25 ppm
cleanup goal, off-site disposal (Alternative 2) would be
substantially easier to implement than on-site containment
(Alternative 1). Alternative 1 requires the construction of a
landfill cellon the site property which complies with TSCA
requirements. In addition, construction of a containment cellon
the site requires the implementation of a long-term groundwater
monitoring program, leachate collection system and the
requirement for operation and ma~ntenance of the facility for
approximately 30 years. Under Alternative 2 (the off-site
disposal alternative), both of these conditions are already met
at existing, permitted, hazardous waste landfills.
~
Commingled PCB/pb-contaminated wastes that fail RCRA
leachate tests require solidification prior to disposal in either
the on-site or the off-site, hazardous waste landfill cell.
Under both alternatives, incineration of Hoc-contaminated soil
would take place at an approved, off-site incinerator and
disposal of the solidified ash in an off-site, hazardous waste
landfil+.
services and materials for implementing th~ on-site
containment remedy are expected to be available within the state
of Idaho. In-state and out-of-state hazardous waste landfills
with the capacity for handling the off-site disposal of excavated
soils have been identified.
7. Cost: This criteria refers to the cost of implementing a
remedial alternative, including operation and maintenance (O&M)
costs. Since this cleanup is an operable unit remedial action,
to be followed by a final remedial action, O&M costs were not
considered.
Total cleanup costs for off-site disposal (Alternative 2,
the selected operable unit alternative) are estimated at
$2,429,000 while costs for on-site containment (Alternative 1)
are'$4,350,000. In the original 1988 ROD, cost projections for
the on-site containment remedy were approximately $1,200,000.
The predicted, higher cost of this alternative is a result of
cell construction requirements, RCRA treatment requirements
including solidification of soils that fail leachate tests, and
incineration and solidification of th~ a~hfrom HOC-contaminated
soils, which were not identified in the 1988 ROD. .
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.'
~
Modifvina criteria
. Modifying criteria were used in the final evaluation of the
operable unit remedial alternatives after the formal comment
period, and may have been used to modify the preferred
alternative that was discussed in the proposed plan.
8. state Acceptance: This criteria refers to whether the state
agrees with the preferred operable unit remedial alternative.
The. state of Idaho Division of Environmental Quality (IDEQ)
concurs with the selection of the preferred operable unit
remedial alternative. IDEQ has been involved with the
development and review of the operable unit focused feasibility
study, the Proposed Plan, and this amended ROD.
9. community Acceptance: This criteria refers to the public
support of a given remedial alternative.
:.t
One written comment was received during the public comment
period. The commenter did not express a preference for a
particular operable unit alternative, nor was opposition
encountered to the EPA preferred operable unit alternative.
Community response is presented in the Responsiveness Summary,
,which addresses the comment received during the public comment
period. '
THE SELECTED OPERABLE UNIT REMEDIAL ACTION
The selected Operable unit Remedial Action for soils is
Alternative 2, off-site disposal. This operable unit Remedial
Action is selected because it best satisfies the nine criteria
identified above, and it will not interfere with the on-going
investigation and future remedial activities associated with the
widespread Pb contamination. It is protective of human health
and the environment, complies with all applicable environmental
regulations, and offers a reasonable likelihood of complete
removal of harmful levels of PCBs from"the site.
In detail, the selected Operable unit Remedial Action
includes:
(a)
Excavation, processing, transport and disposal of
approximately 8,200 cubic yards of PCB-contaminated and
commingled PCB/pb-contaminated soil and debris as
follows:
. ...'.
.. - . .
.Approximately 6,500 cubic yards of untreated PCB-
contaminated waste disposed in an approved, off-site
TSCA landfill.
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'-
T.bl. 1
McCarty'sJPaclflc Hide and Fur - Comparison of Operable Unit Cleanup Altematlves
Evaluation Criteria: Alternatlve'1 Alternative 2 OnJOffslte Incineration BloremedlatlonlChemical Ume Treatment Process
Dechlorination
On:-slte TSCA Containment on-site DI~osal >25p~ PCBs; On- or Off-site Incln. 01 soils On-site Biorem. or Chem. Oechlor. On-sne Lime Treatment 01 soils
~m PCBSj soIldI~ RCRA solidify RC waste> pm; Incln. >2~m PCBs; Off-Sltelandfill of solis >25ppm PCBs; SOIId~ >2~m PCBs; Off.sltelndn. 01
e >5ppm; neln. OCs HOCs >1 ,00000m. (lFJ of solldined ash from RCRA waste >5 ppm; ineln. oes HO s >1 ,OOOppm; solidified ash
>1,= IncIneration. >1,OOOppm placed In off-slle IF.
Deed estrlctlons.
OVerall Protection 0' PublIc Protective. Incln. destroys HOCs ProtectIve. Incln. destroys HOCs Very Protective. Incln. permanenUy ProtecWe. if effective. B/orem. or Not Protective. Technol~ has not
Health" the Envtronment > 1 ,O()()ppm; 601ldIf.lmmoblllzes >1 ,O()()ppm; solldlf.lmmobilizes destr~ PCBs >25ppm. Chern. Dechlor. deslroys PCBs rrroven effective. PCB re uctions
RCRA waste >5~m & ash RCRA waste >5rem & ash Solidllcation of ash and Xlacement >25Rm.1ncil. desIroys HOCs >1 ,0C1J n soli attributable mainly to
resulting from In n.; call to meet resulting from In n. Potential In off-site IF eliminates sks and ~;soIkif. mm~es RCRA ~e volatilization, not lime treatment
TSCA recrnts. PotenUai t:thWays/ pathways/risks eliminated; hazardous materials at site and to >5wm and ash '=" Incin. process.
risks reduced; some po entlal for potential for alrbome releases from GW. Some potentialtranrrc0rt risk Biminalesrisks& materlaS
air releases from excavation & excavation and transport. PCB and some riSk transferred 0 LF. at site & source to GW. Risk wring .
tran~rt. PCB source to GW source to GW eliminated. Risk excavaoon and trealmen~ and some
slgnl cantly reduced. transferred to IF. risk transferred to IF. '
ComplIance w/ARARs Met all ARARs at time ROO Met all ARARs at time ROO was Met all ARARs at time ROD was Unknown. Unlikely able to meet Will not meet ARARs.
s~ned; ESD (1990) clarified TSCAI signed; still meets ARARs. signed; still meets ARARs. Tech. 2~p'm CleanU~Oal without
R RA design reqmts. not necessary to comply w/ARARs. a dltlonaltrea ent.
Long-term Effectiveness Fair. Risks of direct contact Good. Risks of direct contact Good. Risks of direct contact Unknown. "g"ottests prove Poor.
reduced; future risks to GW ellmln.; cur./fut. PCB risks to GW ellmln.; cur.nut. PCB risks 10 GW successful, Irect con. risks could
compromised If cell or cap falls. below 10-6; some risk transferred below 10-6; some risk transferred be ellm.; cUL/fUt. PCB risks to GW
tolF. tolF. <10-6, some risk transferred to IF.
Reduction 0' ToxIcity, Mobility" Fair. Most highly contam. material Fair. Most highly con tam. material Satisfies preference: 7,500 cyd. Unknown. If effective, would satisfy Poor.
Volume destro~ed. SOils with >5ppm RCRA destr°tfd. SOils with >5ppm RCRA soil with >25ppm PCBs treated by ~ef.: 7,500cy soli with >25ppm
Pb.sol .; solis> 1,OOOppm HOCs Pb sol.; solis> 1 ,OOOpJ>m HOCs Incin.; hazardous materials CBs treated by biorem. or chem.
Inclo. Ineln.; 6,SOOcyd. of non-HOC, PCB destrc;red; ash will be solidified and dechlor.; haz. materials destroyed;
solis (>25ppm) to TSCA IF. place In oll,slte IF. ash solidJdls.ln oll-sltelF.
Short-term EffectIveness Air emissions during excavation! Air emissions during excavation; Air emissions during excavation; Air emissions during excavation Poor.
consolidation; >1 year before potential distribution 01 potential distribution 01 and treatment; >1 year belore
respon~ objectives achieved. contaminated sol during transport contaminated sol during tranSJlOrI response objectives couid be
to off.sltelncln.A.F; response to off-sitelneln.A.F; > 1 year before achieved.
objectives could be achieved within response objectives could be
1 year. achieved.
Implementablllty . Tech. & admln. feasible. Requires Tech. feasible & available. Tech. Impractical; s~. material 519. material processing reqmts. Poor.
ROD amendment. B~in In 1992, Re~es ROD Amendment. Begin processl~ reqmts. otential delays Unknown whether technologies will
finish In 1993~. Cou d In 1 2, finish In 1993. due to In nerator use back~ be tech. effective. Requires ROD
SlgnlficanJ fmpact future operable R~s,ROD Amendment. In Amendment. Begin In 1992, finish
unit rem aI actions. In 1 , finish In 1994. In 1994.
Cost ROO est. = $ 1.2 M ROD est. = $ 4 M ROO.est. = $ 8-24 M Current est. = $ 4.5 M ~biO.~ Current est. = $2.5 M
Current est. = $4.4 M Current est: = $ 2.65 M Current est. = same as above Current est. = $ 2.5 M dec .)
State Acceptance State concurred In 1988. State concurs. Unacceptable for site. Unacceptable for site. Unacceptable for site.
..-'.
CommunIty Acceptance Acceptable In 1988. Acceptable; no comments No comments received. No comments received. No comments received.
received.
N
.I:"-
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(b)
."
.Approximately 900 cubic yards of
contaminated, RCRA characteristic
prior to disposal in an approved,
waste landfill.
commingled PCB/Pb-
soils solidified
off-site hazardous
.Approximately 100 cubic yards of RCRA characteristic,
commingled PCB/Pb-contaminated soils containing
halogenated organic compounds in excess of 1,000 ppm
(California List Waste) transported to an off-site
incinerator and the ash solidified prior to disposal in
an approved, off-site hazardous waste landfill.
. .Approximately.700 cubic yards of debris (scrap
material) decontaminate~, stockpiled and placed under a
protective cover on-site.
Backfilling, grading and restoration of surface
drainage to the extent that site restoration does not
interfere with on-going investigation and future
remediation of other potential soil and groundwater
operable units.
Because the sampling results conducted of on-site
groundwater monitoring wells have not indicated the presence of
PCBs at harmful levels, groundwater cleanup is not a component of
this Operable unit Remedial Action.
~j
Remedial Action Performance Standards:
. The Operable unit Remedial Action shall be completed subject
to the following standards of performance.
A.
B.
The boundaries of the Operable Unit Remedial Action
areas within which soil is to be excavated and sampled
for compliance purposes are shown in Figu~e 2.
within the Operable Unit Remedial Action areas, all
soils and debris with PCB concentrations of 25. ppm or
above shall be removed from the site, tested and
treated via solidification (if TCLP concentrations for
lead exceed 5 ppm), and incineration and solidification
of the resulting ash (if TCLP concentrations for lead
exceed 5 ppm and halogenated organic compound
concentrations exceed 1,000 ppm). PCB- and commingled
PCB/Pb-contaminated soils which do not 'fail TCLP shall
be placed in an approved, off-site T$CA landfill. All
other soils shall be treated-. 6f"f'~site and disposed in
an approved, off-site hazardous waste landfill.
Sampling methods and protocols to be utilized in
determining the character and fate of the contaminated
soils will be done in accordance with an EPA approved
sampling and analysis plan.
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.,
C.
.
D.
All contaminated metal scrap and debris excavated
within the Operable Unit Remedial Action areas which is
not treated and/or disposed in. an approved, off-site
hazardous waste landfill shall be decontaminated
subject to the PCB Spill Cleanup Policy. A protective
cover, such as a tarp, shall be placed over the
decontaminated, stockpiled scrap remaining on-site.
Verification sampling to evaluate the statistical
compliance with the 25 ppm cleanup level must be based
upon a sufficient number of analytical samples to
calculate a statistically valid upper confidence
interval for the mean PCB concentration.
E.
Backfilling, grading and restoration of surface
drainage shall be conducted to the extent that site
restoration does not interfere with on-going
investigation and future remediation of other potential
soils and groundwater operable units.
STATUTORY DETERMINATIONS
EPA's primary responsibility at CERCLA sites is to undertake
remedial actions that are protective of human health and the
environment. In addition, Section 121 of CERCLA, 42 U.S.C.
~9621, establishes several other statutory requirements and
preferences including: a requirement that EPA's remedial action,
when complete, must comply with applicable or relevant and
appropriate environmental standards established under federal and
.state laws unless a statutory waiver is invoked; a requirement
that EPA select a remedial action that is cost-effective and that
utilizes permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum
extent practicable; and, a statutory preference for remedies that
permanently 'and significantly reduce the volume, toxicity or
mobility of hazardous substances over remedies that do not
achieve such results through treatment. Remedial alternatives at
the site were developed taking into account these congressional
objectives and preferences.
:(
The selected Operable unit Remedial Action meets the
statutory requirements of CERCLA, and, to the extent practicable,
the NCP. The evaluation criteria are discussed below.
Protection of Human Health and the Environment:
The selected Operable unit Remedial"'.Action is prot.ective of
human health and the environment and will eliminate' the risks
posed through each pathway by removal, treatment to the extent
practicable, and disposal of both PCB- and commingled PCB/Pb-
contaminated soil.
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"
For groundwater, no remedial action under this operable unit
cleanup is necessary to protect human health and the environment.
The basis for this conclusion is that the results from quarterly
groundwater monitoring conducted in 1989-1990 and resumed in
1990-1991 have not confirmed the presence of PCBs at
concentrations above the Maximum Federal Drinking Water
contaminant Level ~hich is 0.5 parts per billion.
Preliminary data from the 1990-1991 groundwater studies
indicates the presence of Pb in on-site groundwater monitoring
wells at levels which may require remediation. EPA will continue
to monitor and evaluate potential groundwater contamination.
Following a thorough, quality-assured review of all appropriate
data, EPA will determine the need, to remediate groundwater. If
groundwater cleanup is determined to be necessary, it will occur
under another operable unit remedial action.
~
This operable unit Remedial Action will eliminate the source
of PCB contamination at the site. While this operable unit
Remedial Action will effectively and permanently remove on-site
PCB-contaminated soils, other hazardous substances (i.e. Pb and
other inorganic compounds) will remain above health-based levels
until EPA develops final remedial alternatives for the remainder
of the site. Because this is an Operable unit cleanup, review of
this Operable Unit will continue during development of final
remedial alternatives for the remaining contaminated areas Qf the
site. Appropriate statutory and policy 5-year reviews will be :
conducted on both the Operable unit Remedial Action and the final
Remedial Action at this site to ensure that the remedies are
providing adequate protection of human health and the
environment.
Compliance with Applicable or Relevant and Appropriate
Reauirements:
Pursuant to section 121(d) of CERCLA, 42 U.S.C. S9621(d) ,
remedial actions shall, upon their completion, reach a level or
standard of control for such hazardous substances, pollutants or
contaminants which at least attains legally applicable or
relevant and appropriate federal standards, requirements,
criteria, or limitations, or any promulgated standards,
requirements, criteria, or limitations under a state
environmental or facility siting law that is more stringent than
any federal standard (ARARs).
The selected Operable Unit Remedial. ~ction satisfies the
requirements of this section of CERCLA'Dycomplying with all
identified ARARs. No ARAR waivers have been sought.'or invoked
for any component of the selected Operable unit Remedial Action.
The chemical- and action-specific ARARs (there are no location-
specific ARARs for this site) include the following:
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TSCA PCB requlations (40 CFR 761.60 - 761.79) and
Subpart G - PCB spill Cleanup Policv, address the
requirements for storage, treatment and disposal of
PCB-contaminated material, and establish the 25 ppm
cleanup level at this site. These are both action- and
chemical-specific ARARs.
.
RCRA requlations (40 CFR 261 - 263 and 268), address
the requirements for defining, characterizing and
listing hazardous wastes; for generators pertaining to
manifesting, transporting, and recordkeeping; for
transporters pertaining to shipment of hazardous wastes
off-site; and, land disposal restrictions.
. .
Department of Transportation: Hazardous Materials
Requlations (49 CFR. Parts 171. 172. 173 Subparts A. B.
J and N. and 177. 178 and 180. and Subchapter C). Idaho
Code Sections 67-2929. 2930 (Supplement 1988) and 49-
2201 throuqh 2212 and IHWMR Section 16.01.5500, address
shipment of any hazardous material off-site.
,
Clean Air Act (42 USC 7409. 7412) and the Idaho Rules
and Requlations for the Control of Air Pollution in .
Idaho (Citation Section 16.01.1011-1012. 16.01.1251-
1253. and 16.01.1501-1504), address the control of
fugitive dust emissions during excavation and other
field activities, and pertain to compliance with the;
national ambient air quality standards and national
emission standards for hazardous air pollutants.
Occupational Safety and Health Act (29
and 1926), address safety requirements
engaged in response or other hazardous
operations.
CFR Parts 1910
for workers
waste
Safe Drinkinq Water Act (42 USC 300) and the Clean
Water Act (33 USC 1251. 40 CFR Part 230. 231),
establishes the development of national primary
drinking water regulations. The regulations provide
maximum contaminant level standards which drinking
water quality cannot exceed. The PCB MCL of 0.5 ppb
shall be maintained and used as. the groundwater
standard for the site.
Clean Water Act (CWA) (33 USC 1251. 40. CFR Parts 230
and 231), establishes State A~tidegradation
Requirements/Use Classificati~h.requirements .for
classification of all the waters within state
boundaries according to intended use. CWA (40 CFR Part
122), addresses storm water runoff from site
operations.
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,"
Idaho 'Solid Waste Manaaement Reaulations'and Standards
Manual (Sections 16.01.6005,01 and 16.01.6008,07),
requires that all solid wastes .be managed during
storage, collection, transfer, transport, processing,
separation, incineration, composting, treatment, reuse,
recycling, or disposal to prevent health hazards,
public n~isances, or pollution to the environment.
Idaho Administrative Procedures Act (Sections
16.01.2050,02, 16.01.2020.06. 16.01.2051. 16.01.2200,
and 16.01.2800, establishes standards for protection of
state groundwater against unreasonable contamination or
deterioration. These standards are designed to control
and regulate the public. drinking water system in order
to protect the health of consumers. .
other criteria, Advisories, or Guidance To-Be-Considered (TBC)
The following guidance was also considered:
~
Guidance on Remedial Actions for Superfund sites With
PCB contamination (OSWER Directive 9355.4-01, August
1990), which describes the recommended approach for'
evaluating and remediating CERCLA sites with PCB
contamination.
Cost-Effectiveness:
:.
The cost-effectiveness of each alternative was evaluated,
including those which were screened out prior to the final
alternatives assessment in the focused operable unit feasibility
study. The selected Operable Unit Remedial Action is cost-
effective as it affords overall effectiveness and protectiveness
proportional to costs. other remedial alternatives including
innovative treatment technologies and/or treatment of greater
quantities of the waste were considered, but were found to be
generally more costly without affording additional protectiveness
commensurate with their cost.
utilization of Permanent Solutions and Alternative Treatment
Technoloqies or Resource Recoverv Technoloaies to the Maximum
Extent Practicable:.
EPA and the state of Idaho have determined that the selected
Operable unit Remedial Action represents the best balance of
tradeoffs among the alternatives consider~d with respect to EPA's
nine evaluation criteria. It is protec~ive of human health and
the environment, and complies with all applicable environmental
regulations. This Operable unit Remedial Action also utilizes
treatment where feasible and practicable.
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Preference for Treatment As a PrinciDal Element:
Because this action does not constitute the final remedy for
the entire site, the statutory preference for remedies that
employ treatment that reduces toxicity, mobility, or volume as a
principal element, although partially addressed in this remedy;
will be considered..when addressing future remedial action.
Subsequent actions are planned to address the threats posed by
conditions in other areas of this site.
DOCUMENTATION OF SIGNIFICANT CHANGES
There have been no significant changes from the
plan. The selected Operable Unit,Remedial Action is
the preferred alternative described to the public in
23, 1992, public notice and proposed plan.
proposed
the same as
the January
~
. .. . .
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