PB95-963155
EPA/AMD/R05-95/284
February 1996
EPA Superfund
Record of Decision Amendment:
Carter Industrials Site,
Detroit, MI
2/28/1995
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DECLARATION FOR AMENDED RECORD OF DECISION
SITE NAME AND LOCATION
Carter Industrials Site
Detroit, Michigan
This decision document changes a decision made on September 18,
1991 in which the United States Environmental Protection Agency
(U.S. EPA) chose low-temperature thermal desorption as the remedy
for PCB contamination at the Carter Industrials Site in Detroit,
Michigan. U.S. EPA is hereby amending the 1991 Record of
Decision to select off-site disposal as-the remedy. The new
remedy was selected in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA) ,
42 U.S.C. §§ 9601-9675 (CERLCA), arid to the extent practicable,
the National Contingency Plan (NCP). This decision is based upon
information and documents contained in the administrative record
described in the index attached.
The State of Michigan Department of Natural Resources concurs
with this decision. ^
ASSESSMF*rr OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this decision document, may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
DESCRIPTION OF THE AM^HPED PRMEDY
This response action addresses remediation of PCB-contaminated
soil, debris and buildings at the Carter Industrials Site. The
principal threats posed by conditions at the Site include
inhalation of volatilized PCBs and fugitive dust, and dermal
contact with contaminated materials. The amended remedy will
eliminate these threats.
The major components of the amended remedy include:
1) Excavation of soil on the Carter Site and from designated
properties in the neighborhood near the Site containing one ppm
or more of PCBs.
2) Demolition of contaminated buildings on the Site.
3) Disposal of contaminated soil and debris at an approved,
permitted, off-site landfill.
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4) Stabilization of material containing high concentrations of
lead prior to disposal.
5) Air monitoring and dust suppression during remedial
activities.
6) Removal of an underground storage tank and its contents from
the Carter Site in accordance with Michigan regulations.
7) Restoration of areas where demolition or excavation take
place.
8) Maintenance of all existing site safety measures, including
fence, security guards, operation and maintenance of surface
water runoff collection and treatment system during remedial
activities. .
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. In this case, U.S. EPA
found that treatment of PCBs was not practicable._ Therefore,
even though the amended remedy does not employ treatment of the
principal threat, U.S. EPA is justified in determining it
utilizes permanent solutions and alternative treatment or
resource recovery technologies to the maximum extent practicable.
Since the amended remedy will not result in hazardous substances,
pollutants, or contaminants remaining at the Carter Site above
levels that allow for unlimited use and restricted exposure,
periodic review of the remedial action in accordance with Section
121(c) of CERCLA, 42 U.S.C. § 962l(c), shall not be necessary.
Valdas V. fedamkus/ ^^- Datfe/
Regional Administrator
/
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DECISION SUMMARY
Introduction
Reasons for a Change in Remedy
On September 18, 1991, the United States Environmental Protection
Agency (EPA) signed a Record of Decision (ROD) selecting low-
temperature thermal desorption (LTTD) as the remedy for PCB
contamination at the Carter Industrials Superfund Site in
Detroit, Michigan. The ROD called for an LTTD unit to be .
constructed on-site through which contaminated soil would have
been treated and contamination removed. Treated soil that did
not meet stipulated cleanup levels was to have been placed in a
landfill constructed on the Carter property. In September 1992,
14 potentially responsible parties ("the Carter Group") signed a
consent decree under which they agreed to implement the remedy
EPA selected.
On July 1, 1994, the Carter Group submitted a petition to EPA
asking that the Agency amend the 1991 ROD to change the remedy.
The Carter Group brought to EPA's attention new information that
substantially supports the need to significantly alter the
remedy. This information is summarized below:
1. The cost of off-site disposal has dropped dramatically.
At least one other landfill has become available, and another may
soon join it, capable of accepting PCB-contaminated material from
the Site at a much lower cost than EPA estimated in the 1991 ROD.
In 1991, EPA did consider disposing of contaminated soil and
debris from the Site in a landfill. At that time, the only
landfill permitted to take PCB wastes was located in Emelle,
Alabama. EPA cited as one reason for rejecting this alternative
the possibility that landfill capacity might not be available
when the remedy was to begin. In addition, disposal fees in 1991
were substantially higher than now. EPA estimated that
transportation and disposal costs would be $300 per ton and
calculated that the total cost of disposing of contaminated
material from the Site, including the cost of transportation to
Alabama, would be approximately $24 million. This would have
been more than the cost of the on-site treatment and disposal
remedy that was chosen in the 1991 ROD.
In the years since 1991, a new facility, the Model City Landfill
located north of Niagara Falls, New York, has obtained a permit
to dispose of PCB-contaminated materials. The operator of the
landfill, Rust Remedial Services, Inc., a subsidiary of Waste
Management, Inc., has offered to accept and dispose of all PCB-
contaminated soil and debris from the Site at a cost of $185 per
ton, including excavation, transportation, disposal, and taxes.
In addition, one of the members of the Carter Group, the Ford
Motor Companyr has applied for a permit to dispose of PCB wastes .
at the Allen Park Clay Mine Landfill in Allen Park, Michigan.
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EPA has not made a determination on this permit yet. The Allen
Park Clay Mine Landfill may be capable of receiving PCB-
contaminated waste from the Site if its permit is approved. The
costs for excavation, transportation and disposal at the Allen
Park facility are estimated to be approximately $130 per ton.
Based on the current and projected landfill disposal charges, the
cost of cleaning up the Site using an off-site landfill would
range from approximately $5.2 million (using Allen Park Clay Mine
Landfill) to $7.7 million (using the Model City Landfill). in
comparison, the cost of cleaning up the Site using LTTD would be
approximately $14 million.
2. There is less contaminated soil than we thought.
EPA's 1991 ROD was based on an estimate of 45,250 cubic yards of
contaminated soil that would -have to be treated. However, a
survey recently completed as part of the remedial design work
shows that only 19,300 cubic yards need to be treated - less than
half the amount estimated in 1991. A change of this magnitude
substantially reduces the cost-effectiveness of an on-site remedy
like the one EPA chose in the 1991 ROD. This is because fixed
costs, such as bringing the treatment equipment to the site and
removing it later, remain approximately the same notwithstanding
the reduced quantity of soil. The total remedial cost per cubic
yard increases as the quantity of material to be treated
decreases.
3. Restrictions on interstate transport have been
struck down.
In 1991, EPA noted that there could, be problems in getting
permission to transport PCS wastes across state lines. EPA cited
this concern as a factor which favored the selection of an on-
site over an off-site remedy. Since then, the Supreme Court has
resolved this problem by holding that states may not prevent the
interstate shipment of waste. Chemical Waste Management^ Inc^ v.
Hunt. 112 S. Ct. 2009 (June 1992). Fort Gratiot Sanitary
Landfill. Inc. v. Michigan DNR. 112 S. Ct. 2019 (June 1992). C&A
Carbone. Inc. v. Town of Clarkston. 114 S. Ct. 1677 (May 1994) .
Procedure for Changing the Remedy
The information summarized above led EPA to rethink its 1991
decision. After reviewing the current status of the Site and
comparing remedial alternatives, EPA decided that the remedy for
PCB contamination at the Carter Site should be changed from on-
site LTTD to off-site disposal in a permitted landfill. Under
Section 117(c) of the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA) , 42 U.S.C. § 9617(c), if
EPA takes any remedial action which differs in any significant
respect from a final remedial action plan, the Agency is required
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to publish an explanation of the significant differences and the
reasons such changes were made. The decision by EPA to change
the remedy at the Carter Site constitutes such a significant
difference. Indeed, EPA considers this to be a fundamental
change in the remedy, necessitating the issuance of a new
proposed plan and an amended ROD. Accordingly, on December 12,
1994, EPA released a new proposed plan. EPA published a notice
of the proposed change in a major local newspaper of general
circulation and released a new proposed plan. On January 11,
1995, EPA explained the reasons for the change in remedy at a
public meeting in Detroit. Comments from the public were
accepted through January 20, 1995.
After reviewing public comments, the Agency has decided to go
forward with an Amended Record of Decision, adopting the proposed
remedy change. The Amended ROD does not completely supersede the
1991 ROD. Much of the discussion in the old ROD is still
pertinent and this material is incorporated by reference in the
Amended ROD. What the Amended ROD adds is: (1) new information
concerning the volume of contamination at the Site and the cost
of off-site disposal; (2) an updated list of soil cleanup levels
based on levels that the Michigan Department of Natural Resources
(MDNR) has determined as appropriate to protect against direct
contact threats with soils on residential properties; and, (3) a
new comparison of off-site disposal versus on-site treatment
using the NCP's nine evaluation criteria (40 CFR 430(e)(9)(iii)).
This is followed by an updated description of the selected remedy
and an analysis of how the new remedy meets the statutory
criteria provided in Section 121 of CERCLA. As an attachment to
the Amended ROD, EPA is issuing a responsiveness summary that
addresses all significant comments received.
This decision document is part of an administrative record which
is available for public inspection at the Detroit Public Library,
Main Library - Reference Department, 5201 Woodward Avenue,
Detroit, Michigan. The administrative record may also be
reviewed at EPA Region 5, 77 West Jackson Boulevard, Chicago,
Illinois.
I. Site Location and Description
See page 1 of the 1991 Carter ROD.
II. Site History and Enforcement Activities
For a history of the- site and enforcement activities through June
1991, see the 1991 Carter ROD, pp. 1-5. The following
enforcement events occurred after June 1991:
September 19, 1991 - Record of Decision signed.
November 18, 1991 - Special Notice letters issued to 28 PRPs.
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January 27, 1992 - Good faith offer made on behalf of 11 PRPS.
March 26, 1992 .- Settlement reached in principle with 14 FRPa.
January 19, 1993 - Carter Consent Decree lodged.
June 4, 1993 - Carter Consent Decree entered.
July l, 1994 - Petition to Amend 1991 ROD submitted by the Carter
Group.
III. Community Relations History
For a description of EPA's community relations activities through
September 19, 1991, see the 1991 Carter ROD, pp. 5-6. As noted
above, EPA published a notice of the proposed change in remedy on
December 12, 1994; held a public meeting "on January 11, 1995 to
describe the change, answer questions, and accept comments; and
provided a public comment period running from December 12, 1994
through January 20, 1995. The Responsiveness Summary attached to
the Amended Record of Decision provides EPA's response to each of
the comments received.
IV. Scope and Role of Operable Unit
The scope and role of the operable unit remains the same as that
described in the 1991 Carter ROD (p. 6), except that the selected
remedy is now off-site disposal of contaminated soil and debris.
A later operable unit will still be necessary,to address PCS
contamination in the sewer lines running from the Carter Site to
the Detroit River.
V. Site Characteristics
The Amended ROD supplements the characteristics noted in the 1991
Carter ROD (pp. 6 - 9) by adding to the administrative record
documents generated as part of the remedial design for the
original remedy. These documents show that the amount of
contaminated soil and debris at the Site is approximately 19,300
cubic yards> rather than the 46,000 cubic yards that EPA
originally estimated.
VI. Site Risks
See the discussion in the 1991 Carter ROD, pp. 9-22.
VIZ. Remedial Action Objectives
See the discussion in the 1991 Carter ROD, pp. 22 - 25. EPA is
now adopting the following soil cleanup levels based on levels
which MDNR has determined are appropriate to protect against
direct contact threats with soils on residential properties:
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CONTAMINANT
Soil Cleanup Level
Based on
Direct Contact
l,3 -dichlorobenzene
1,4-dichlorobenzene
Xylene
Chlorobenzene
Banzo(a)anthracene
Pyrene
1,2,4-trichlorobenzene
pentachlorobenzene
tetrachlorobenzene
Lead*
Cadmium*
Arsenic*
* background if higher
6,700
16
140,000
1,500
0.18
19,000
1,200
220
88,000
400
130
.720
VIII. Development of Remedial Action Alternatives
The Amended ROD compares only two remedial alternatives for the
Carter Site: Alternative 1 is the remedy selected in the 1991
ROD - Low Temperature Thermal Desorption; Alternative 2 is of'f-
site disposal of contaminated material in a permitted landfill.
The restriction of the remedial alternatives to these two is
justified by the fact that EPA conducted an extensive comparison
in 1991. Indeed, the 1991 Carter ROD examined 15 different
remedial alternatives, including "no action" and several
treatment options. Of these, on-site low temperature thermal
desqrption was the optimum choice: it was more cost effective
than any other treatment option. EPA continues to believe that
LTTD represents the most cost effective method of achieving
treatment of PCBs at the Carter Site. It should therefore not be
necessary to compare any other treatment options with the off-
site disposal alternative. If, given the new estimate of the
volume of waste at the Site and the reduction in landfill costs,
off-site disposal is judged superior to on-site LTTD, it may
safely be assumed to be superior to any other treatment option as
well.
Alternative It On-site Low Temperature Thermal Desorption of
soils/Off-site incineration of recovered PCS oils/On-site
containment of treatment residuals
Cost: $14,014,210
Operation & Maintenance Cost:
Present Worth: $14,212,510
Duration: 19-20 months
$12,900/year
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This alternative calls for: (l) excavation of soil on the Carter
Site and from designated properties in the neighborhood near the
Site containing 1 ppm or more PCBs (estimated to be approximately
19,300 cubic yards); (2) demolition of contaminated buildings on-
site; (3) on-site low temperature thermal desorption (LTTD) of
soil and debris containing more than 10 ppm PCBs; (4) off-site
incineration of PCS oil recovered during the LTTD process; (5)
stabilization of solid residuals from LTTD system containing
concentrations of lead in excess of TCLP standards; (6)
construction of a containment cell on-site in which all
contaminated soil and solid residuals from the LTTD processor
containing more than 1 ppm, but less than 10 ppm PCBs, and
material containing stabilized lead, will be disposed; (7) long-
term operation and maintenance of the containment cell, including
long-term restrictions on property use; (8) air monitoring and
dust suppression during remedial activities; (9) removal of an
underground storage tank and its contents; (10) restoration of
areas where demolition or excavation take place; and (11)
maintenance of all existing site safety measures, including
fence, security guards, operation and maintenance of surface
water runoff collection and treatment system during remedial
activities.
Alternative 2: Excavation and disposal in an off-site permitted
landfill
Cost: $5,228,400 for Allen Park Landfill
$7,716,200 for Model City Landfill
Operation & Maintenance Cost: $ 0
Present Worth: $5,22"8,400 for Allen Park Landfill
$7,716,200 for Model City Landfill
Duration: 7-8 months
This alternative calls for: (1) excavation of contaminated soil
on the Carter Site and from designated properties in the
neighborhood near the Site containing 1 ppm or more of PCBs
(estimated to be approximately 19,300 cubic yards); (2)
demolition of contaminated buildings on-site; (3) disposal of
contaminated soil and debris at an approved, permitted, off-site
landfill; (4) stabilization of material containing high
concentrations of lead prior to disposal; (5) air monitoring and
dust suppression during remedial activities; (6) removal of an
underground storage tank and its contents; (7) restoration of
areas where demolition or excavation take place; and (8)
maintenance of all existing site safety measures, including
fence, security guards, operation and maintenance of surface
water runoff collection and treatment system during remedial
activities.
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IX. Evaluation of Alternatives
A. Evaluation Criteria
EPA's evaluation of remedial alternatives is based on the nine
criteria set forth in the National Contingency Plan (NCP) , 40 CF?.
Part 300. These criteria are described below.
A remedial alternative is first judged in terms of the threshold
criteria of protecting human health and the environment and
complying with Applicable or Relevant and Appropriate
Requirements (ARARs). If a proposed remedy meets these two
criteria, it is then evaluated against the balancing and
modifying criteria in order to arrive at a final recommended
alternative.
Threshold Criteria
1. Overall protection of human health and the environment: EPA
determines whether an alternative adequately protects human
health and the environment frbnr unacceptable risks posed by
hazardous substances, pollutants, or contaminants present at the
site.
2. Compliance with ARARs: EPA evaluates whether an
alternative attains applicable or relevant and appropriate
requirements under federal environmental laws and state
environmental or facility siting laws or provides grounds for
invoking a waiver.
Balancing Criteria
3. Long-term effectiveness and permanence: EPA considers the
ability of an alternative to maintain protection of human health
and the environment over time, and the reliability of such
protection.
4. Reduction of contaminant toxicity. mobility, or volume
through treatment; EPA evaluates the degree to which an
alternative uses treatment to address the principal threats posed
by the site.
5. Short-term effectiveness; EPA considers the length of time
needed to implement an alternative and the risks the alternative
poses to workers, residents, and the environment during
implementation.
6. Implementability; EPA considers the technical and
administrative feasibility of implementing the alternative, such
as relative availability of goods and services.
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7. Cose; EPA estimates an alternative's capital and O&M costs
and calculates the present worth cost. Present worth cost is the
total cost of an alternative over time in terms of today's
dollars.
Modifying Criteria
8. State acceptance: EPA considers any concerns the state has
raised with respect to the preferred alternative, other
alternatives or with ARARs or ARAR waivers.
9. Community Acceptance; EPA considers which .components of the
alternatives interested persons in the community support, have
reservations about, or oppose.
B. Application of the Evaluation Criteria to the two
Cleanup Alternatives
l. Overall Protection of Human Health and the Environment
The 1991 ROD and the supporting Feasibility Study ("FS") Report,
dated April 1991, indicate that both off-site landfilling and
LTTD/on-site containment would adequately protect human health
and the environment.
2. Compliance with ARARs
Alternative 1: The ARARs for the on-site remedy are discussed at
length in the 1991 ROD (pp. 46-49) . The most significant are:
regulations promulgated under the Toxic Substances Control Act
(TSCA) - which govern the disposal of the PCB materials found afc
the Site; regulations promulgated under the Resource Conservation
and Recovery Act (RCRA) - which govern the handling of wastes at
the Site containing high levels of lead; and regulations
promulgated under Michigan's Act 641 - which govern the
construction of the landfill on the Carter Site. EPA concluded
that all of these requirements would be met except for a Michigan
Act 641 requirement concerning isolation distances for siting
landfills. EPA determined that a waiver of this requirement was
appropriate.
Alternative 2: There are fewer ARARs for this alternative
because much of the activity associated with it will take place
off-site. Unlike on-site actions, the requirements regulating
off-site activity are not imposed under the authority of CERCLA.
Rather, state and federal laws and regulations pertaining to off-
site activity apply independently. As such, they cannot be
waived under Section 121 of CERCLA; nor are they frozen at the
time of the ROD. They must therefore be assessed at the time
off-site action begins to ensure compliance with all applicable
standards.
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On-site activities for this alternative consist mainly of
excavation of soils containing PCBs and lead; and the loading.of
trucks. ARARs pertaining to these actions, include: RCRA closure
requirements (40 CFR 264.258) apply to cleanup of waste piles at
the site. Michigan air pollution standards pursuant to Michigan
Act 348 - apply to activities at the Site which produce air
contaminants. EPA concluded that Alternative 2 would comply with
these ARARs.
3. Long term effectiveness
Alternative 1: Under the 1991 ROD, the residual material
remaining after LTTD processing that contains PCS concentrations
between 1 and 10 pm would remain on site in a containment cell.
The cell would be designed to minimize the possibility of leaks.
However, besides good design and construction, the integrity of
the cell would require periodic maintenance, limited access, and
land use restrictions. These may be difficult to achieve, given
the inner city location of the Carter Site. In the past, EPA has
had trouble keeping warning signs and fences in place at the
Site. Another consideration here is the effect that permanent
use restrictions would have on property that could otherwise be
redeveloped. The presence of the containment cell may discourage
reuse of property in the vicinity.
Alternative 2; The excavation and removal of PCB-contaminated
material would completely eliminate any potential threat to the
public and environment in the vicinity of the Site. Placement of
PCB-contaminated material in a secure landfill would reduce the
potential for direct ~ human contact with contaminants and for
migration of contaminants into groundwater. Any long-term risks
associated with off-site disposal would be minimized by the
landfill's conformance with its permit requirements pertaining to
leachate control, groundwater monitoring, and cap maintenance.
Land use controls, limited access, and other necessary
precautions would probably be more dependable at a commercial
landfill than at a neighborhood landfill created solely for the
Carter Site.
4. Reduction of toxicity, mobility or volume through treatment
Alternative 1; On-site soil treatment and on-site containment
would reduce toxicity, mobility and volume of PCBs in the soil.
However, high levels of lead (up to 29,000 ppm) would remain in
the soil and would require stabilization prior to disposal.
Alternative 2; Containment of the PCB-contaminated material at
an off-site TSCA landfill would reduce mobility, but not by
treatment. Stabilization of lead in soil prior to disposal would
reduce or eliminate its mobility. However, toxicity and volume
of both PCBs and lead would remain unaffected.
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5. Shore term effectiveness
Alternative 1: Cleanup activities associated with on-site
treatment would require 24 months to complete. Excavation of
soils - potentially creating dust and runoff - would take place
over a period of ten months. Operation of the LTTD unit would
have to be carefully monitored to avoid undesirable air
emissions.
Alternative 2: All on-site remedial activities would be
completed in 12 months. Excavation of soils - potentially
creating dust and runoff - would take place over a period of only
four months. Hauling of material off-site would increase truck
traffic in the vicinity of the site; but trucks would be routed
to the interstate highway in such a way as to minimize traffic
and safety problems. (See Figure 1 on page following).
Moreover, off-site transportation would have to comply with RCRA,
TSCA and Department of Transportation regulations.
6. Implementability
Alternative 1: Since 1991, several large-scale soil treatment
projects using LTTD have been completed. These projects have
demonstrated the technical feasibility of treating PCB
contaminated soils like those found at the Carter Site.
Alternative 2; All of the cleanup activities involved here -
excavation, transport off-site, disposal of contaminated soil in
a commercial landfill, site restoration - are conventional,
proven methods of hazardous waste cleanup. Potential
restrictions on interstate transportation of hazardous wastes
have been struck down in recent Supreme Court decisions. Several
commercial landfills currently have the capacity to accept soil
from the Carter Site. EPA therefore believes that this
alternative is fully implementable.
7. Cost
Alternative 1; Using the revised estimate of the amount of soil
to be treated (19,300 cubic yards), EPA projects the total cost
of the on-site treatment remedy to be $14,014,210 with an
additional $12,900 per year in long-term operation and
maintenance costs for the on-site landfill. This brings the
present worth of the remedy to $14,212,510.
Alternative 2: EPA estimates that the total cost for the off-
site disposal remedy would range from $5.2 to $7.7 million,
depending on which commercial landfill is used. The low figure
reflects the cost if the Allen Park Clay Mine Landfill in Allen
Park, Michigan is used. The high figure reflects the cost if the
Model City Landfill near Niagara Falls, New York is used. There
are no additional operation and maintenance costs associated with
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off-site disposal. The present worth of the remedy is therefore
identical to the capital costs, i.e., $5.2 to $7.7 million.
8. State acceptance
The Michigan Department of Natural Resources agrees with the
proposed change in the remedy.
9. Community acceptance
Based on the public comments received, EPA believes the community
supports the proposed change in the remedy. The comments,
together with EPA's responses, are contained in a responsiveness
summary attached to this document.
FIGURE 1: POSSIBLE TRUCK ROUTE
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C. Results of Comparison Using the Nine Criteria
Both alternatives meet the two basic, threshold criteria: they
both would provide adequate protection of human health and the
environment; and they would meet ARARs or justify a waiver of
such requirements.
Moving on to the balancing criteria, Alternative 1 is clearly
superior in terms of reduction of toxicity, mobility and volume
through treatment since it would destroy most of the PCBs found
at the site. Alternative 2 would merely move the PCBs to a
different place. Alternative 2 is clearly superior in terms of
cost - it could be as much as $9 million cheaper than Alternative
l. Alternative 2 is somewhat preferable in terms of short-term
effectiveness since it would take less time. The kinds of
nuisance problems associated with both remedies - dust, noise,
etc. - would not last as long under the off-site disposal remedy
as they would under the on-site treatment remedy. Alternative 2
may also be somewhat preferable in terms of long-term
effectiveness because it eliminates the need for an on-site
landfill which, given its location, might be difficult to
maintain, and could inhibit redevelopment of the site. In terms
of implementability, the two alternatives appear equally
implementable.
EPA is mindful that the balancing criteria should not be assigned
equal weights. Since CERCLA contains a preference for treatment
over land disposal of contamination, the reduction of toxicity,
mobility and volume criterion must be given more weight than the
other balancing criteria. Even so, EPA believes that, in this
case, the scales tip toward off-site disposal. EPA has concluded
that the incremental difference in effectiveness provided by on-
site treatment is not proportional to the great increase in cost
over off-site disposal, especially considering the significant
advantages of off-site disposal in terms of short and long-term
effectiveness, described above. EPA has therefore decided to
change the remedy by amending the 1991 ROD and selecting
Alternative 2.
The final step in the comparison is to consider the two modifying
criteria: state and community acceptance. Based on comments
received from the Michigan Department of Natural Resources and
the public, EPA has concluded that the state and community
support the change in the remedy.
X. The Selected Remedy
The new remedy for the Carter Site is Alternative 2 - off-site
disposal of. PCB-contaminated material in a permitted landfill.
The main elements of the selected remedy are as follows:
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o Excavation of soil on the Carter Site and from designated
'properties in the neighborhood near the Site containing l
ppm or more of PCBs.
o Demolition of buildings on-site.
o Disposal of excavated soil and demolition debris at an
approved permitted, off-site landfill.
o Removal of decontaminated scrap metal via sale to a scrap
metal dealer or disposal in an approved, permitted, off-site
landfill.
o Any soil or debris that fails the TCLP test shall be
solidified prior to disposal such that it no longer exhibits
this characteristic. Debris that fails the TCLP test and
cannot be solidified or decontaminated shall be treated
using best management principles in accordance with a
treatability variance.
o Air monitoring and dust suppression during remedial
activities.
o Removal of underground storage tank (UST) and its contents
in the following manner: the tank contents shall be
sampled, and based on the analytical results, shall be
pumped out and transported to a permitted treatment and/or
disposal facility. The tank shall then be decontaminated
and removed in accordance with Michigan UST requirements.
The soils beneath the tank shall be inspected for evidence
of leaking. Any contaminated soils shall be excavated and
the bottom of the excavation sampled to confirm adequate
excavation. The excavated soil shall be sampled and
characterized for ultimate disposal.
o Restoration of areas where demolition or excavation take
place.
o Maintenance of all existing site safety measures, including
fence, security guards, operation and maintenance of surface
water runoff collection and treatment system during remedial
activities.
XI. Statutory Findings
Section 121 of CERCLA requires the Agency, to select remedies
that:
1. Protect human health and the environment;
2. Comply with ARARs (or meet the conditions necessary to
justify a waiver);
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3. Are cost effective;
4. utilize permanent solutions and alternative treatment
technologies to the maximum extent practicable; and
5. Satisfy a preference for treatment as a principal element of
the remedy.
The implementation of the amended remedy at the Carter Site
satisfies these requirements as follows:
1. Protection of Human Health and the Environment
Based on the risk assessment developed for the Site, inhalation
of volatilized PCBs, incidental ingestion of on-site soils (pica
behavior), dermal contact with contaminated on-site soils and
off-site migration of contaminated soils are the identified risks
associated with the Site. The highest numerical carcinogenic
risk for the Site is 4E-02 or 4 in 100. Removal of contaminated
soil and debris and disposal in an off-site, permitted landfill
will eliminate these risks. No unacceptable short-term risks
will be caused by implementation of the remedy. Measures will be
taken to minimize the noise and dust caused by remedial
activities.
While there are no environmental impacts in the immediate
vicinity of the Site, there are potential impacts via migration
of PCBs through the sewer line leading to the Detroit River.
There is an island wildlife refuge located in the middle of the
Detroit River 6.5 miles downstream from the sewer outfall. Prior
to the installation of a runoff collection and treatment system
in 1986, contaminated soils in runoff from the Site were carried
into the sewer line. PCS-contaminated sediments were detected in
the river just downstream of the sewer outfall at somewhat higher
concentrations (40 mg/kg) than they were just upstream of the
sewer outfall (18 mg/kg). The contaminated sewer lines are to be
addressed as the final operable unit for the Site.
2. Attainment of Applicable or Relevant and Appropriate
Requirements
The selected remedy will meet all applicable or relevant and
appropriate requirements (ARARs).
a. Chemical-specific ARARs
Clean-up levels for specific chemicals at the Carter Site were
set primarily as a result of risk analysis and in consideration
of EPA's "Guidance on Remedial Actions for Superfund Sites with
PCB Contamination" (OSWER Directive No. 9355.4-01, August 1990).
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MAC R 299.5701 et aeq. - Cleanup Criteria established pursuant to
Michigan Environmental Response Act (1982 P.A. 307, as amended)
are applicable to the Carter Site. The cleanup levels
established in this ROD for specific chemicals are consistent
with these criteria.
b. Action-specific ARARs
Air Emissions
Rule 901. Michigan Department of Natural Resources^ Air Pollution
Control Commission. General Rules. Part 9 - Michigan air
pollution standards pursuant to Michigan Act 348 are applicable
to activities at the Carter Site which produce air contaminants.
If demolition at the Carter Site involves materials containing
friable asbestos, the requirements of 40 .CFR 61.152 would apply.
Cleanup of -Waste Piles
40 CFR 264.258 - RCRA closure requirements apply to cleanup of
waste piles at the Carter Site.
3. Cost Effectiveness
After an extensive comparison of off-site disposal and on-site
treatment, EPA concluded that off-site disposal offered
significant advantages in terms of cost, short term
effectiveness, and long term effectiveness, making it the more
cost effective alternative.
4. Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum
Extent Practicable
The preamble to the current version of the NCP discusses how to
evaluate the practicability of treatment:
Cost differences must also be considered in the context
of all other differences between alternatives to reach
a conclusion as to which alternative, all things
considered, provides the most appropriate solutions for
the site or site problem. It is this judgement that
determines the maximum extent to which permanent
solutions and treatment are practicable for the site or
site problem being addressed. (54 FR 8729)
In this case, the combination of the lower cost of off-site
disposal together with the advantage of eliminating an on-site
waste disposal cell made off-site disposal the most appropriate
solution for the site. EPA is therefore justified in concluding
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that treatment and permanent solutions in excess of those called
for in the amended remedy are not practicable.
5. Preference for Treatment as a Principal Element of the Remedy
In comparing alternatives, EPA did give preference to treatment
over off-site disposal. That is, EPA assigned much greater
weight to the treatment criterion than to the other balancing
criteria. However, because of the magnitude of the difference in
cost, and because two of the other balancing criteria - long and
short term effectiveness - favored off-site disposal, the off-
site landfill alternative overcame the preference for treatment.
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