PB94-964131
EPA/ROD/R05-94/257
September 1994
EPA Superfund
Record of Decision:
South Andover Salvage Yards,
Andover, MN,
5/31/1994
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SOUTH ANDOVER SALVAGE YARDS
DECLARATION FOR THE RECORD OF DECISION AMENDMENT
SITE NAME AND LOCATION
South Andover Salvage Yards,
Andover, Anoka County, Minnesota.
STATEMENT OF BASIS AND PURPOSE
This decision document represents an amendment to a Record of
Decision (ROD) issued December 24, 1991 for soil remedial action
at the South Andover Salvage Yard site (the Site). This
amendment was 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), and to the extent
practicable, consistent with the-National Oil and Hazardous
Substances Pollution contingency Plan (40 CFR Part 300). This
decision is also in accordance with the Minnesota Environmental
Response and Liability Act of 1983 (MERLA).
This decision is based upon the contents of the administrative
record for the South Andover Salvage Yard Site.
The State of Minnesota and the United States Environmental
Protection Agency (U.S. EPA) agree on the selected remedy.
ASSESSMENT OF THE SITE
Potential releases of hazardous substances from this Site, if not
addressed by implementing the response action selected in this
Amendment, may present an imminent and substantial endangerment
to public health, welfare, or the environment.
DESCRIPTION OF THE AMENDMENT
This operable unit is the second of two operable units for the
Site. The remedy for the first operable unit, groundwater, was
documented in a June 9, 1992, ROD Amendment. The major
components of the amended groundwater remedy include: short term
monitoring of groundwater; immediate re-sampling of wells if
action levels are exceeded; and proper abandonment of those wells
no longer being monitored.
U.S. EPA issued a ROD on December 24, 1991 for the second
operable unit for the remedial action of soil. The major
components of this remedy included: excavate and treat
approximately 2,100 cubic yards of predominately carcinogenic PAH
(CPAH) contaminated soils using an above-ground biological
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treatment unit: excavate and transport approximately 9,300 cubic
yards of soils contaminated with PCBs, CPAHs, lead and antimony
to an off-site solid waste landfill permitted to receive
industrial and/or commercial wastes: sample and remove drums
previously inventoried by MPCA and u.s. EPA.
u.s. EPA and MPCA are amending this decision so that the
predominately cPAH-contaminated soils would be taken off-site for
thermal treatment in either a rotary kiln incinerator or a low
temperature thermal desorption unit. Additionally, this
amendment serves to update the Maximum contaminant Levels (MCLs)
for several constituents which are currently being monitored in
groundwater. Groundwater monitoring will terminate three years
after all excavation activities have been completed.
STATUTORY DETERMINATIONS
The amended remedy is protective of human health and the
environment, complies with Federal and state requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment (or resource
recovery) technologies, to the maximum extent practicable for
this site. This amended remedy satisfies the statutory
preference for treatment.
The amended remedy when used in conjunction with the contaminated
groundwater remedy addresses the threat posed to groundwater by
eliminating or reducing the risks posed by the site. All
contaminated soi1 will either be destroyed through thermal
treatment or transported off-site where it will be contained in a
secured, permitted landfill. No contaminated soil would be left
on-site to pose a human health or environmental risk.
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(V;valdas V. Adamkus
Regional Administrator
u.s. EPA, Region V
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RECORD OF DECISION
AMENDMENT
SUMMARY
South Andover salvage Yards
Andover, Anoka County, Minnesota
INTRODUCTION
The South Andover Salvage Yards Superfund site (the Site) is
located in Anoka county, Minnesota, approximately 16 miles north-
northwest of Minneapolis and 3 miles northeast of the city of
Anoka (Figure 1). The site is comprised of several privately
owned parcels of land, which jointly encompass more than 50
acres. Bunker Lake Boulevard defines the northern extent of the
site. The eastern site boundary is roughly 500 feet west of Jay
street (Figure 2).
The lead agency documenting this amended decision is the United
States Environmental Protection Agency (U.S. EPA). The Minnesota
Pollution Control Agency (MPCA) is the support agency. The MPCA
was involved in the review and approval of those documents which
lead to the amendment of the original Record of Decision (ROD)
issued December 24, 1991.
U.S. EPA issued a ROD on December 24, 1991 which documented a
decision for remedial action of soil. The major components of
the selected remedy included: excavate and treat approximately
2,100 cubic yards of predominately carcinogenic polyaromatic
hydrocarbons (CPAH) contaminated soils using an above-ground
biological treatment unit; excavate and transport approximately
9,300 cubic yards of soils contaminated with PCBs, CPAHs, lead
and antimony to an off-site industrial and/or commercial
permitted landfill; and sample and remove drums which were
inventoried by MPCA and U.S. EPA. The cleanup standards for the
various contaminants are 2 ppm for PCBs; 4 ppm for CPAHs; 500 ppm
for lead; and 25 ppm for antimony. Figure 3 illustrates how
these various contaminants are distributed across the site. This
figure is based on data contained in the July 1991 Remedial
Investigation (RI).
During Remedial Design/Remedial Action (RD/RA) negotiations and
as a result of a Pre-Design Study, additional soil samples were
taken to refine the volume of contaminated soil. The first round
of soil sampling occurred in October 1992, the second was in July
1993. Both sampling events used a grid system which placed
sample points approximately 10 to 30 feet away from each other.
The July 1991 RI used a grid system which placed sample points
approximately 75 to 100 feet away from each other.
Results from the October 1992 and July 1993 sampling events have
shown that the CPAH contaminated soil volumes originally
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estimated in the July 1991 RI, were significantly less. The
original volume of CPAH contaminated soils was estimated at 2,100
cubic yards. Data from the more recent sampling events indicate
the volume to be approximately 250 cubic yards. Figure 4
illustrates the new hot spot configurations, based on the recent
sampling events.
As a result, u.s. EPA and MPCA are amending their December 1991
decision concerning contaminated soil at the site. Specifically,
that portion of the remedy which addresses CPAH contaminated soil
from hot spots 1, 5, and 6 will be amended to reflect off-site
thermal treatment as opposed to on-site biological treatment.
The original cleanup standards for the various soil contaminants,
however, would not change. Finally, u.S. EPA and MPCA are
updating the Maximum contaminant Levels (MCLs) of those
constituents which are currently being monitored in the
groundwater.
section 117 of the Comprehensive Environmental Response,
compensation and Liability Act (CERCLA), also known as Superfund,
and Section 300.435 (c) (2) (ii) of the National contingency Plan
(NCP), requires publication of a -notice and brief description of
the proposed amendment to the ROD. The notice of availability
for the proposed ROD Amendment was published in the April 15,
1994 edition of the Anoka Countv Union, the local newspaper.
This notice also included a new release which provided the dates
of the public comment as well as the date of the public meeting.
The public comment period began on April 18, 1994 and ended on
May 18, 1994. A response to the comments received during this
period as well as during the public meeting, is included in the
Responsiveness Summary, which is part of the ROD Amendment. A
public meeting was held on May 4, 1994 at the Andover City Hall.
The Administrative Record for the Site has been placed at the
following information repositories:
Andover city Hall
1685 Crosstown Boulevard NW
Andover, Minnesota 55303
Hours: Mon-Fri 8:00 AM - 4:30 PM
Minnesota Pollution Control Agency
520 Lafayette Road
st. Paul, Minnesota 55155
Hours: Mon-Fri 8:30 AM - 4:30 PM
u.S. EPA Docket Room
77 West Jackson Boulevard
Seventh Floor
Chicago, Illinois 60604
Hours: Mon-Fri 8:30 AM - 4:30 PM
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The Administrative Record includes all documents such as work
plans, data analyses, public comments, transcripts, and other
relevant material used in developing the remedial alternatives
for the South Andover Superfund site. As per section 300.825
(a)(2) of the NCP, the ROD Amendment will become part of the
Administrative Record.
REASONS FOR ISSUING THE ROD AMENDMENT
On February 5, 1993, the Potential Responsible Parties (PRP),
referred to as the South Andover Administrative Group (SAAG),
entered into a Consent Decree with u.S. EPA. This Consent Decree
was lodged with a federal court on April 30, 1993 and was later
entered into the same court on August 27, 1993. As part of this
Consent Decree, the SAAG agreed to perform the necessary studies
and activities required to remediate the South Andover Salvage
Yards. .
One of the activities required under the Consent Decree was the
performance of various pre-design studies. The purpose of these
studies was to gather the necessary information to fully
implement the remedial design and-remedial ,action. A task
identified in a particular pre-design study was to further
delineate the extent of soil contamination. Under this task, the
SAAG was required to put together a workplan which outlined a
sampling scheme for collecting additional contaminated soil data.
This workplan had to meet u.s. EPA's and MPCA's approval before
sampling could take place.
Under the pre-design workplan, soils were sampled using a tighter
grid system. Sample points were located a distance of 10 to 30
feet away from each other versus the 75 to 100 feet used in the
July 1991 RI. This tighter sampling pattern was used on areas of
suspected contamination, specifically, those areas which were
assumed to be contaminated because they existed between known
areas of contamination. These particular areas were assumed to
be contaminated when contaminated soil volumes were calculated in
the July 1991 RI.
Soil samples were collected in July 1993 using the tighter grid
system. The results indicated that the volume of CPAH
contaminated soils decreased in areas 1, 5, and 6. The original
estimate contained in the July 1991 RI was 2,100 cubic yards.
Data from the July 1993 sampling event indicate the volume to be
approximately 250 cubic yards.
Previous sampling performed independently by the SAAG, also
indicated that the CPAH soil volumes decreased. This sampling
event occurred in October 1992.
Given the new CPAH soil volume, the effectiveness of bio-
remediation for CPAH contaminated soils needed to be re-evaluated
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for this Site. Several bio-remediation vendors even refused to
take on the project due to the small amount soil contaminated
with CPAHs. Additionally, the treatment costs per cubic yard
greatly increased due to the small soil volume. The SAAG
commissioned its contractor to evaluate appropriate treatment
technologies that would effectively reduce CPAH compounds in the
soils to the cleanup level of 4 ppm.
Off-site thermal treatment in either an incinerator or low
temperature thermal desorption unit, on-site landfarming and on-
site treatment with a slurry bioreactor were evaluated. Using
U.S. EPA's nine remedy evaluation criteria, off-site thermal
treatment proved to be the best alternative when compared against
the on-site bio-remediation alternatives.
Finally, this ROD Amendment serves to update the Maximum
contaminant Levels (MCLs) for the various groundwater compounds
monitored at the site. U.S. EPA periodically updates its MCLs
via the Safe Drinking Water Act. The most recent update occurred
in December 1993. Several site-specific groundwater monitoring
compounds were. affected by this December 1993 MCL update. New
MCLs were established where previously there were none or new
levels were given to existing MCLs. The compounds affected and
their new MCLs are identified in Table 1.
DESCR~PTION OF THE NEW ALTERNAT~VE
U.S. EPA and MPCA are amending the original soil remedy by
replacing on-site biological treatment with off-site thermal
treatment of CPAH-contaminated soil. The cPAH-contaminated soil
from areas 1, 5, and 6 would be excavated and transported to a
permitted off-site facility where the material would be treated
with either a rotary kiln incinerator or a low-temperature
thermal desorption unit.
For rotary kiln incineration, the CPAH contaminated soil would be
placed in a cylindrical, refractory-lined, rotating kiln and
heated until combustion results in the breakdown and destruction
of the CPAH-contaminated soil. Ash and exhaust gases would be
collected and treated as necessary. Incineration is a well
established technology that can provide effective treatment.
Rotary kiln incineration has a destruction and removal efficiency
(DRE) of greater than 99.99%. A fixed site rotary kiln
incinerator is available in the area and currently holds a valid
operating permit.
Low temperature thermal desorption (LTTD) reduces the volume and
mobility of wastes by separating and collecting the organic
contaminants. Although it uses heat to treat the waste, it is
not an incineration process because it does not destroy the
contaminants. The material is heated in the desorber, where the
water and organic contaminants are volatilized from the soil into
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a carrier gas stream. The carrier gas stream is then treated
further with an afterburner or it is cooled in stages to condense
the volatilized water and organics into liquids. These liquids
can then be further treated with carbon filtering.
LTTD has successfully treated soils contaminated with CPAHs on a
pilot scale. A fixed site low temperature thermal desorber is
available in the area.
That portion of the remedy which addresses the contaminated soils
in areas 2, 3, 4, and 7 will remain the same. Soils from these
areas will be excavated and transported to an off-site industrial
and/or commercial permitted landfill. Soils from areas 2, 3, 4,
and 7 are contaminated with PCBs, CPAHs, lead and antimony.
The cleanup levels for the various site-specific contaminants
will not be changed due to this ROD Amendment. The cleanup
standards for the various contaminants are 2 ppm for PCBs: 4 ppm
for CPAHs: 500 ppm for lead and 25 ppm for antimony. These
performance standards will remain the same across the site.
Lastly, the ROD Amendment updates the Maximum Contaminant Levels
(MCLs) for the various groundwater monitoring parameters.
Several site-specific groundwater parameters were affected when
U.S. EPA updated the MCLs in December 1993. The site-specific
compounds affected and their new MCLs are identified in Table 1.
Table 2 provides the full list of groundwater monitoring
parameters.
EVALUATION OF ALTERNATIVES
The nine evaluation criteria u.S. EPA considers when selecting a
remedy and a comparative analysis between the previously selected
CPAH treatment component and the new remedy are listed below:
OVerall Protection of Human Health and the Environment.
Both bio-remediation and thermal treatment are similar
in their ability to protect human health an the
environment. Both alternatives irreversibly destroy
the CPAHs, which eliminates the risk from these
contaminants. Specifically, soil treatment will remove
the source of potential groundwater contamination at
the site and reduce the public's potential exposure to
both soil and groundwater contamination. Thermal
treatment, however, can be completed in less time
(three to four months) than biological treatment (two
years).
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Comuliance with ARARs. Bio-remediation and thermal
treatment meet all of the federal and state
environmental laws concerning soil-cleanup levels.
Soil will have to be tested for total lead content,
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however, before being sent to the appropriate thermal
treatment facility. The MPCA has published guidelines
prohibiting the thermal treatment of soils if the total
lead content exceeds 100 ppm. Soils with a total lead
content greater than 100 ppm must be thermally treated
out-of-State. It is anticipated that the CPAH-
contaminated soils from areas 1, 5, and 6 have total
lead contents below the 100 ppm level.
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Lona-term Effectiveness and Permanence. Both thermal
and biological treatment would result in the removal
and destruction of CPAH-contaminated soils to a level
which is protective of human health and the
environment. No soil residuals will remain on-site
which would cause an impact to human health or the
environment. Three years of post excavation
groundwater monitoring will provide information on the
effectiveness and permanence of the final remedy as
well as confirm the continued quality of the Site
groundwater.
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Reduction of Toxicitv.-Mobilitv or Volume. Thermal
treatment is demonstrated to be effective in the
treatment of CPAH-contaminated soil. Incineration or
LTTD would provide the greatest reduction in toxicity,
mobility and volume of CPAH-contaminated soil as
opposed to biological treatment. Pilot studies which
have used incineration technologies on CPAH
contaminated soils, have documented destruction and
removal efficiencies of approximately 97 %. Biological
treatment of CPAH-contaminated soil has been done,
however, the removal efficiencies are not as high as
with thermal treatment.
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Short Term Effectiveness. Excavation of soil is a
component of both the thermal and biological treatment
remedies. Soil excavation would cause temporary dust,
noise, and traffic at the Site. However, health and
safety plans would require that all workers be
adequately protected during the work. Under the
thermal treatment remedy, contaminated soil would be
taken off-site for treatment. As originally proposed,
biological treatment of contaminated soil would occur
on-site and take longer to perform. The short term
impacts on worker health and safety are greater with
biological treatment due to the longer potential
exposure period. Also, there is no significant risk to
the surrounding community or environment with either
on-site biological treatment or off-site thermal
treatment technologies.
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Implementabilitv. Thermal and biological treatment are
technically implementable and available. Both a fixed
site rotary kiln incinerator and low temperature
thermal desorber are available in the local area. The
incinerator holds a valid operating permit: the
selected desorber would need to be issued a permit by
the MPCA for the treatment. Biological treatment could
be accomplished by constructing an on-site landfarm or
by bringing a bioreactor on-site. Both on-site
biological treatment options would require more site
preparation work than the off-site thermal treatment
options.
Cost. The estimated costs of the biological
treatment remedy versus the thermal treatment remedy
are listed below:
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Biological Treatment......................$355,OOO
Off-site Incineration......................$67,OOO
Off-site LTTD unit.........................$60,OOO
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state Acceptance.
amended remedy.
The-State of Minnesota supports the
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Community Acceptance. community acceptance" is assessed
in the attached Responsiveness Summary. The
Responsiveness summary provides a thorough review of
the public comments received on Proposed Record of
Decision Amendment and u.S. EPA's and MPCA's responses
to the comments received.
STATUTORY DETERMINATIONS
The amended remedy satisfies the requirements of Section 121 of
CERCLA in that it is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. The amended remedy
utilizes permanent solutions and alternative treatment (or
resource recovery) technologies to the maximum extent practicable
for the site. This amended remedy does satisfy the statutory
preference for treatment as a principal element because a portion
of the contaminated soil will be taken off-site to a permitted
thermal treatment facility.
All contaminated soil from the site will either be destroyed
through off-site thermal treatment or transported off-site where
it will be contained in a secured, permitted landfill. No
contaminated soil will be left on-site to pose a risk to human
health or the environment.
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RESPONSIVENESS SUMMARY
SOUTH ANDOVER SUPERFUND SITE
PROPOSED ROD AMENDMENT (SOIL - OU 2)
ANOKA COUNTY MINNESOTA
At the start of the public comment period, the u.s. Environmental
Protection Agency (U.S. EPA) and the Minnesota Pollution Control
Agency (MPCA) proposed to change the plan for cleaning up soil at
the South Andover Superfund Site. The original cleanup plan was
documented in a legal Record of Decision (ROD), which u.s. EPA
approved on December 24, 1991. The major components of this
remedy included: excavate and treat approximately 2,100 cubic
yards of predominately carcinogenic PAH (CPAH) contaminated ~oils
using an above-ground biological treatment unit~ excavate and
transport approximately 9,300 cuhic yards of soils contaminated
with PCBs, CPAHs, lead and antimony to an off-site solid waste
landfill permitted to receive industrial and/or commercial
wastes~ sample and remove drums previously inventoried by MPCA
and u.s. EPA.
The Agencies' proposed changes to their original cleanup plan, as
specified in the proposed ROD Amendment, include the off-site,
thermal treatment of the predominately CPAH contaminated soils
and updating the Maximum contaminant Levels (MCLs) for several
groundwater monitoring constituents.
The public comment period for the proposed ROD Amendment began on
April 18, 1994 and ended on May 18, 1994. The notice of
availability for the proposed ROD Amendment was published in the
April 15, 1994 edition of the Anoka Countv Union. A public
meeting was held on May 4, 1994 at the Andover City Hall. A
court reporter recorded the minutes of the meeting. There were
no spoken comments received at the public meeting. Additionally,
there were no written comments received during the public comment
period.
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TABLE 1
NEW MCLs
CONSTITUENT
OLD
~
NEW
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Methylene Chloride
o
5
Tetracbloroethene
o
5
Aluminum
o
*
50 - 200 SMCL
Barium
1,000
2,000
Beryllium 0 4
Copper 1,000 SMCL * 1,300 AL**
**
Lead 50 15 AL
Nickel
o
100
Thallium
o
2
*
Secondary 11ax;mum Contam; nant Level
** Act;on Level
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TABLE 2
CONSTITUENTS TO BE MONITORED
Units: ppb
Minnesota
Maximum Recommended
Volatile Organic Contaminant Allowable
Com~ounds Level Limit
Methylene Chloride 5 50
Acetone NE 700
1,2-Dichloroethane 5 4
2-Butanone NE 300
Trichloroethene 5 30
4-Methyl-2-pentanone NE. NE
1,1,1-Trichloroethane 200 600
Tetrachloroethene 5 7
Ethyl Benzene 700 700
Styrene 100 10
Total Xylenes 10,000 10,000
Inorganic Comnounds
Aluminum 50 - 200 * NE
Arsenic 50 0.2
Barium 2,000 2,000
Beryllium 4 0.08
Calcium NE NE
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t.
Table 2 continued.
Units: ppb Minnesota
Maximu Recommended
contaminant Allowable
Inorqanic Compounds Level Limit
Copper 1,300 ** 1,000
Iron 300 * NE
Lead 15 ** 20
Magnesium NE NE
Manganese 50 * 600
Nickel 100 140
Potassium NE NE
Selenium 50 20
Sodium NE NE
strontium NE NE
Thallium 2 0.6
Vanadium NE 40
Zinc 5,000 * 1400
*
Secondary Maximum
contaminant Level
**
Action Level
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SOURCE: CH2M~L~ 1988
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SCALE IN FEET
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JULY 1991
FIGURE 1
SITE LOCATION MAP
SOUTH ANDOVER SUPERFUND SITE
DESIGN INVESTIGATION
ANDOVER, MINNESOTA
SCIESTISTS
. ESGISEERS
ARCHITECTS
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FIGURE 2
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FIGURE 3
SITE PLAN
South Andover Site'
CRA
4769(L)-APR. 27/94-REV.O (8-01 )(MN)
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FIGURE 4
SITE PLAN
South Andover Site.
CRA
"769(L)-APR. 27 /94-R~V.0 (B-01 )(MN)
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