United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R05-91/169
September 1991
oEPA Superfund
Record of Decision
Carter Industrials, Ml
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT IKX
EPA/ROD/R05-91/169
>. Redptonfe AcccMton No.
4. TMeendSubMe
SUPERFUND RECORD OF DECISION
Carter Industrials, MI
First Remedial Action
5. Report DM*
09/18/91
7. AuftorM
•. Performing Ora»nlallonHept. No.
11. CootrecHC) or Ctant(G) No.
(C)
(Q)
12. apomerinq Orgentatfion Neme Mid M*M*
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
1*. Type of Report* Period Covered
800/000
14.
15. Sup)
•yNote
16. Abefrect (Limit: 200 word*)
The 3.5-acre Carter Industrials site is a former scrap metal storage and salvage
operation in Detroit, Michigan. Surrounding land use is mixed residential and light
industrial in an urban setting. Onsite features include several buildings, two
shelters, an incinerator, a 1,000-gallon underground gasoline storage tank, and seven
piles consisting of approximately 46,000 cubic yards of PCB-contaminated soil and
debris. From 1966 until 1986, the site was used as a scrap metal salvage and storage
facility, changing ownership several times during the. period. Items accepted for
salvage included electrical capacitors and transformers. During salvage operations,
dielectric fluid containing PCBs was spilled from the capacitors and transformers
directly onto the onsite soil. Adjacent commercial, residential, and municipal
properties have been contaminated by direct runoff of spilled material, storm water
runoff, wind-blown dust, and tracking of spilled material by vehicles. In 1986, the
State identified elevated levels of PCBs in onsite soil, which was later confirmed by
EPA investigations. Consequently, in 1986, as part of a removal action, EPA stabilized
the site by diverting surface water runoff to onsite interception trenches and a
treatment system; excavating and consolidating onsite contaminated soil and debris along
(See Attached Page)
17. Document Anelysi* «. Descriptor*
Record of Decision - Carter Industrials, MI
First Remedial Action
Contaminated Media: soil, debris
Key Contaminants: organics {PCBs), metals (arsenic, cadmium, lead)
b. U*ntrRer*/Opon-End*dTenne
c. COSATI Held/Group
1*. Anfefattty SUM
19. Security CUM (Thi* Report)
None
20. Security CUM (Thta Pege)
None
21. No. of Pege*
150
22. Price
(SeeANSWW.18)
Sf» Instruction* on Rtvtat
OPTIONAL FORM 272(4-77)
(Formerty NTTS-JS)
Department of Commerce
-------
EPA/ROD/RO.5-91/169
Carter Industrials, MI
First Remedial Action
Abstract (Continued)
with offsite residential debris into seven onsite piles; decontaminating and disposing
of debris offsite; decontaminating alleys and streets within a 4-square block area; and
fencing the site. Also in 1986, the State removed and disposed of all PCB-contaminated
soil with levels between 10 to 50 mg/kg from surrounding residential areas offsite. In
1989, the PRPs covered onsite piles of contaminated material with geotextile and
vegetative cover to provide temporary containment. This Record of Decision (ROD)
addresses remediation of remaining onsite and offsite source material. A subsequent
ROD will address the need for remediation of contaminated sewer lines running from the
site. The primary contaminants of concern affecting the soil and debris are organics
including PCBs; and metals including arsenic, cadmium, and lead.
The selected remedial action for this site includes excavating approximately 46,000
cubic yards of onsite and offsite soil contaminated with greater than 1 mg/kg PCBs;
treating onsite and offsite soil and debris with greater than 10 mg/kg PCBs onsite
using low temperature thermal desorption, and solidifying any material that fails the
toxicity characteristic leaching procedure (TCLP); disposing of all onsite and offsite
material contaminated with PCBs 1 mg/kg to 10 mg/kg, including all treatment residuals
with less than 10 mg/kg PCBs in an onsite containment cell with a clay and soil cover;
disposing of any material that cannot meet the above onsite disposal criteria offsite;
installing a leachate collection and pumpout system in the containment cell;
decontaminating and demolishing three onsite buildings, and containing the
decontaminated debris in the cell; removing an underground storage tank and its
contents, with offsite treatment or disposal of the contents, and onsite
decontamination and offsite disposal of the tank; excavating and treating
tank-contaminated soil; monitoring leachate and air; and implementing institutional
controls including deed restrictions, and site access restrictions such as fencing.
The estimated present worth cost for this remedial action is $19,508,000. There are no
O&M costs associated with this remedial action.
PERFORMANCE STANDARDS OR GOALS: The clean-up goal of 1 mg/kg PCBs in soil and debris
is based on EPA Guidance on Remedial Actions for Superfund Sites with PCB
Contamination. All soil and debris with greater than 10 mg/kg PCBs will be treated
onsite. Soil and treatment residuals with 1 to 10 mg/kg PCBs.will be contained onsite.
Soil clean-up levels for metal contaminants are based on leachability testing (or
detection limits) and include arsenic 50 ug/kg, cadmium 80 ug/kg, and lead 100 ug/kg.
An ARAR waiver will be invoked for the Michigan Solid Waste Management Rule that
specifies isolation distances for sanitary landfills.
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Carter Industrials Site
Detroit, Michigan
STATEMENT OF BASIS AND PURPOSE
This decision document presents the United States Environmental Protection Agency's (U.S. EPA's)
selected remedial action for the Carter Industrials site located in Detroit, Michigan. The remedial action
was selected 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, the National Contingency Plan (NCP). This decision is
based upon information and documents contained in the administrative record for this site.
The State of Michigan Department of Natural Resources concurs with the selected remedy.
ASSESSMENT OF THF
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 TBfP SELECTED
This response action addresses remediation of PCB contaminated soil, debris and buildings at the Carter
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 selected remedy will eliminate these
threats.
The major components of the selected response alternative include:
1) Excavation of all on-site and off-she soils contaminated with PCBs at levels over 1
mg/kg;
2) Design and implementation of Low Temperature Thermal Desorption (LTTD) of the on-
site and off-site soil and debris contaminated with PCBs at levels greater than 10 mg/kg.
This treatment process must reduce the level of PCB in the solid residual to less than or
equal to 10 mg/kg for on-site disposal of residual. Any TCLP hazardous residual
material shall be solidified such that it is no longer hazardous prior to on-site
containment.
3) Design and installation of a containment cell on the Carter Site to contain all material
containing between 1 mg/kg and 10 mg/kg PCB. This would include material mat was
excavated from the adjacent neighborhood and from the site which contained 1-10
mg/kg PCB and was not to be treated using LTTD - and the solid residual from the
LTTD treatment system containing less man 10 mg/kg PCB after treatment. Off-site
disposal is required for any material not meeting the criteria for on-site containment;
-------
4) The on-site cell would be constructed as required to impede the lateral infiltration of
groundwater into the containment cell and the migration of leachate out of the
containment cell. Additional technical requirements would include: a compacted clay
liner; a leachate collection and pumpout system; a monitoring system capable of detecting
leakage from the cell; a frost protective soil cover and drainage layer; access restrictions,
such as fencing, as necessary to maintain the integrity of the cap, and a permanent
marker to demarcate the on-site cell, maintenance activities, routine inspections and
appropriate institutional controls, such as deed restrictions, would be employed to ensure
the integrity of the containment structure. The containment cell will be constructed in
accordance with the requirements of the rules implementing Michigan's Solid Waste
Management Act (Act 641) for lined type H sanitary landfills.
5) Air monitoring will be required for purposes of determining if PCBs are volatilizing or
if there is excessive emission of PCBs adsorbed to particulates during remedial activities.
Dust suppression measures will be required.
6) Decontamination and demolition of the three contaminated buildings on the Site. The
decontaminated demolition'debris will be contained in the on-site containment cell;
7) Removal of an underground storage tank (UST) and its contents in accordance with the
Michigan UST requirements; .
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 selected 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 or meets the
conditions necessary to justify a waiver of such requirements, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment or resource recovery technologies to the maximum extent
practicable and satisfies the statutory preference for remedies mat employ treatment that reduces toxicity,
mobility, or volume as a principal element Because this remedy will result in hazardous substances
remaining on-site above health-based levels, a review will be conducted within five years after
commencement of remedial action to ensure that the remedy continues to provide adequate protection of
human health and the environment.
Valdas V. Adamkus / /9 Date
Regional Administrator
U.S. EPA - Regioi/V
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DEPARTMENT OF NATURAL RESOURCES
September 11, 1991
Mr. Valdas Adamkus, Regional Administrator
United States Environmental Protection Agency
Region 5, 5RA-14
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. Adamkus:
The Michigan Department of Natural Resources (MDNR) on behalf of the State of
Michigan has reviewed the September 5, 1991, draft of the Record of Decision
(ROD) for the Carter Industrials Superfund site in Wayne County, Michigan. I
am pleased to inform you that we concur with the remedy selected in the ROD.
The major components of the remedy consist of the following:
- treatment using Low Temperature Thermal Desorption (1170) of soil
contaminated with polychlorinated biphenols (PCBs) at levels over 10
parts per million (ppm),
- containment of soils and treatment residuals contaminated
with greater than 1 ppm but less than 10 ppm PCBs 1n an on-site
containment cell,
- retreatment or off-site disposal of any residuals above 10 ppm PCBs,
• off-site disposal of any debris contaminated with greater than 10 ppm
f'CBs that cannot be treated or otherwise decontaminated,
• solidification of hazardous wastes (iCLP toxic) to render them
non-ha7ardous and disposal in the on-sitc containment cell,
• off-site disposal of debris or other hazardous wastes which fail the
""CLP test and cannot be solidified or decontaminated,
effective dust suppression measures to adequately control emissions and
air monitoring to verify that the control measures arc effective,
• decontamination and demolition of three contaminated buildings on the
site with disposal in the on-site containment cell,
• removal of the underground storage tank and its contents in accordance
with the Michigan Underground Storage Tank requirements,
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.'•'• V.
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Page Ho. 1
09/18/91
TITLE
Record of Decision, State
Concurrence Letter
Proposed Plan Public
Meeting Advertisement
Recycling Sciences
International
PRP Comnents on Proposed
Plan, Remedial Action
Plan, Type C
Justification
Testability Study Soil
Excavation Work Plan
Comnents
Letter transmitting
Michigan Case in Alger
County interpreting Act
307
Request for Preliminary
Natural Resource Survey
Technical Info re:
"SoilTech" ATP Treatment
Unit
Other Vendors of LTTD
Technology
Plans for LTTD DAVES
T Testability Study
Inquiry re: Pioneer Site
in Detroit
Response to Pioneer
Inquiry
T Testability Study Soil
Excavation Work Plan
Addendum
Comnents on PRPs Type C
Justification I Remedial
Action Plan
U.S. EPA Proposes Cleanup
Action at the Carter
Industrials Site
Thermal Desorption
Treatment - Engineering
Bulletin
Carter Industrial
Superfund Site
Informational Meeting
Michigan Act 307 Rules
ADMINISTRATIVE RECORD INDEX
CARTER INDUSTRIAL SITE
DETROIT, MICHIGAN
PATE
09/18/91
04/19/91
/ /
06/17/91
06/20/91
04/03/91
04/24/91
04/29/91
OS/06/91
05/06/91
05/15/91
06/03/91
07/02/91
07/22/91
04/01/91
05/01/91
08/08/91
11/30/90
AUTHOR
U.S. EPA
U.S. EPA
RSI
Incorporated
PRP Steering
Committee
U.S. EPA
C. Dunsky - PRP
Steering
Committee
U.S. EPA
Canonie
Environmental
U.S.EPA
PRP Steering
Connittee
MDNR
Ross Powers -
U.S. EPA
Conestoga-Rover
• I Associates
Michigan Dept.
of Natural
Resources
U.S. EPA
Office of
Research I
Development
MDNR
Michigan Dept.
RECIPIENT
Public
Public
U.S. EPA
U.S. EPA
PRP Steering
Committee
T. Thurlou -
U.S. EPA
U.S. Department
of Interior
U.S. EPA
PRP Committee
U.S.EPA
Ross Powers -
U.S. EPA
MDNR
Jon Peterson -
U.S. EPA
Jodi Traub •
U.S. EPA
Public
Public
Public
Public
DOC.
Decision Document 128
Advertisement
Brochure
Comments
Comments on
Work Plan
Cor respondence
Correspondence
Correspondence
Correspondence
Correspondence
Correspondence
Correspondence
Correspondence
Fact Sheet
Fact Sheet
Fact Sheet
Guidance Manual
1 1
10 2
124 3
2 4
29 5
2 6
13 7
2 8
2 9
4 10
2 11
4 12
50 13
6 14
8 15
2 16
168 17
Implementation Manual
of Natural
Resources
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Page Ho.
09/18/91
ADMINISTRATIVE RECORD INDEX
CARTER IROUSTRIAL SITE
DETROIT, MICHIGAN
TITLE
AUTHOR
RECIPIENT
DOC.
Modification of CERCLA
Section 106 UAO for
Carter Site
Chance Finding Offers
hope for PCB cleanup
Extension of Public
Comment Period for Carter
Industrials Site
Monthly Oversight Field
Logs for Carter
Industrials Site
Monthly Oversight Field
Logs for Carter
Industrials Site
Monthly Oversight Field
Logs for Carter
Industrials Site
Dechtorination of PCBs
using the ATP Unit at
Wide Beach Superfund Site
Public Comnents on
Proposed Plan
Michigan Solid Waste
Management Rules
Monthly Status Report for
Carter Industrials Site
Quicklime Treatment of
PCBs
Monthly Status Report for
Carter Industrials Sit*
Monthly Status Report for
Carter Industrials Site
Monthly Status Report for
Carter Industrials Sitt
Soil Erosion and
Sedimentation Control Act
of 1972
U.S. EPA Proposed Plan
Public Meeting Transcript
Additional Information
regarding Treliability
Studies
Information regarding
Treatability Studies
«MHH^»IH«^K
07/25/91
03/11/91
05/17/91
07/08/91
08/05/91
09/06/91
07/30/91
06/17/91
12/21/89
05/10/91
05/21/91
06/10/91
07/10/91
08/09/91
03/30/73
05/02/91
07/11/91
07/11/91
U.S. EPA
Chicago Tribune
U.S. EPA
BtV Waste
Science I
Technology
BftV Waste
Science t
Technology
MV Waste
Science I
Technology
Canonie
Environmental
Various Public
Parties
Department of
Natural
Resources
PRP Steering
Comittee
Risk Reduction
Engineering Lab
PRP Steering
Comittee
PRP Steering
Comittee
PRP Steering
Comittee
State of
Michigan
U.S. EPA
Canonie
Environmental
Services
RSI
Incorporated
PRP Steering
Committee
Public
Public
Jon Peterson -
U.S. EPA
Jon Peterson -
U.S. EPA
Jon Peterson -
U.S. EPA
U.S. EPA
Public
U.S. EPA
Public
U.S. EPA
U.S. EPA
U.S. EPA
State of
Michigan
Public
Jon Peterson -
U.S. EPA
Jon Peterson •
U.S. EPA
•••^-•^^•^^•la^B— MHpi^BW S
Modified UAO
News Article
Newspaper
Advertisement
Oversight
Report
Oversight
Report
Oversight
Report
Performance
Report
Public Comnents
Regulations
Status Report
Status Report
Status Report
Status Report
Status Report
. Statute
Transcript .
Treatability
Study
Information
Treatability
Study
Information
5
1
1
4
5
7
13
5
100
10
3
11
11 .
12
10
54
147
41
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
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Page Ho.
09/18/91
ADMINISTRATIVE RECORD INDEX
CARTER INDUSTRIAL SITE
DETROIT. MICHIGAN
TITLE
Volumetric Listing for
Non-participants
MDNR Act 307 Type B
Cleanup Level
Calculations
DATE
04/26/90
07/19/91
AUTHOR
Clean Sites
Inc.
Chris Flaaga -
MDNR
RECIPIENT
U.S. EPA
Jon Peterson -
U.S. EPA
DOCUMENT TYPE
Volumetric
Ranking
Worksheets
DOC.
» PACES f
8 36
20 37
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Page MO. 1
04/18/91
ADMINISTRATIVE RECORD INDEX
CARTER INDUSTRIAL SITE
DETROIT, MICHIGAN
PAGES DATE
TITLE
AUTHOR
RECIPIENT
DOCUMENT TYPE
DOCNUMBER
91/04/00
Proposed Plan
U.S. EPA Region V
Public
Agency Decision
Doc.
121 91/04/00
Feasibility Study
Report Vo. 2
Figures and Tables
B&V Uaste Science
& Technology and
J. Peterson
U.S. EPA
Agency Decision
Doc.
158 91/04/00
Feasibility Study
Report Vol. 1 •
Text
B4V Uaste-Science ft
Technology Region V
and J. Peterson
U.S. EPA
Agency Decision
Doc.
4 90/07/25
Letter re: Application
of Act 307 Rules to
Carter Industrials
Superfund site (att.is
letter 90/03/15 re:
requesting clarification
on behalf of the Berlin
ft Farro Steering Comm.)
Dunsky,C.- Honigman;
Miller Schwartz ft Conn
Rector,D.
Correspondence
90/08/29 Letter re: Enclosed is Ounsky.C. - Honigman
a copy of an August 17 Miller Schwartz and
1990 letter from Delbert Conn
Rector.
Thurlow.T. • U.S.
EPA
Correspondence
90/09/00 Letter re: Completed
review of the 15
potential
remedial action
alternatives
for Carter Industrials
Rector,D. • Mich. DNR
Bauer,R. - U.S. EPA Correspondence
90/09/27 Letter re: Appraisal of
Briquetter at Carter
Industrial Site
Brandon,B.H. -
Honigman Miller
Schwartz and Cohn
Peterson,J. - U.S. Correspondence
EPA
91/02/26 Letter re: Monthly
status report from
the PRPs Steering
Committee dated 2/9/91
Uagaw.U. - Mich.
Dept.Of Natural
Resources
Peterson,J. - U.S. Correspondence
EPA
91/02/28
Letter re: previous
Dunsky.C.
Peterson,J. - U.S. Correspondence
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Page Mo. 2
04/18/91
ADMINISTRATIVE RECORD INDEX
CARTER INDUSTRIAL SITE
DETROIT, MICHIGAN
PAGES DATE TITLE
telephone discussion
regarding Carter Indus.
has contracted with
Uestinghouse
Environmental
and Geotechnical
Services.
AUTHOR
RECIPIENT
EPA
DOCUMENT TYPE
OOCNUMBER
9 91/03/01
Potential Remedial
Technologies at the
Carter Industrials
Superfund Site
Dunsky.C. '- Monigman
Miller Schwartz
and Cohn
Peterson,J. - U.S. Correspondence
EPA
10
3 91/03/04
Letter re: Uestinghouse
Environmental and
Geotechnical Services,
Inc. has postponed its
plans for changing the
filters
Dunsky.C.- Honigman
Miller Schwartz and
Cohn
Peterson,J. - U.S. Correspondence
EPA
11
1 91/03/15
Fact Sheet re: Research
to Assess the
Disappearance
of PCB Resulting from
Treatment of Contaminated
Materials with Quicklime
U.S. EPA - Risk
Reduction Engineering
Lab - Cincinatti, OH
Fact Sheet
12
18 89/03/31
Carter NPL Listing
U.S. EPA
Federal Register 13
Not
5 83/06/28
Quality Assurance and
Quality Control
Procedures
for Demonstrating PCB
Destruction In Filing
For a PCB Disposal Permit
Guidance
U
5 85/03/19
Recommended Analytical
Requirements for PCB
Data Generated on
Site During Non-
Thermal PCB Destruction
Tests
Guidance
15
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Page No. 3
04/18/91
ADMINISTRATIVE RECORD INDEX
CARTER INDUSTRIAL SITE
DETROIT. MICHIGAN
PACES DATE
TITLE
AUTHOR
RECIPIENT
DOCUMENT TYPE
DOCNUMBER
90 86/08/21
Draft Guidelines for
Permit Applications
and Demonstration Test
Plans for PCS Disposal
By Non-Thermal
Alternative
Methods
U.S. EPA Office of
Toxic Substances
Guidance
16
89/07/00 Superfund LOR Guide U.S. EPA
*6A Obtaining a Soil OSUER Directive
and Debris Treatability * 93A7.3-06FS
Variance for Remedial
Actions
Guidance
17
150 90/08/15
Guidance on Remedial
Act i ons for Superfund
Sites with PCS
Contamination Superfund
Management Review
Longest.H.L.- U.S. EPA
Waste
Mangt.Div.Directors
Guidance
6 90/11/01
Kickoff of Treat-
ability Study at
the Carter Site
Peterson,J.- U.S. EPA
File
Meeting Notes
19
17 90/11/01
Non-Liquid PCS
Disposal Methods
to be Used as
Alternatives to • 40
CFR 761.75 PCB Chemical
Waste Landfill
Elkins.C. - U.S. EPA
Longest.H.L.-U.S.
EPA
Memorandum
20
12 91/02/22
Disappearing PCBs
A Significant
Breakthrough
Ullrich,0. - U.S. EPA
Cade,M.-Deputy Asst. Memorandum
Adro.
21
4 91/03/11 Letter re: Geosafe Corp./Hansen.j.
Geosafe test site causing
an operational acceptance
test to be terminated and
resulting in damage to
the off-gas collection
hood.
Neidergang.N.- U.S. Memorandum
EPA
22
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Page NO. 4
04/18/91
PAGES DATE
TITLE
AUTHOR
ADMINISTRATIVE RECORD INDEX
CARTER INDUSTRIAL SITE
DETROIT, MICHIGAN
RECIPIENT
DOCUMENT TYPE OOCNUMBER
1 91/03/12
EPA Discovers Way to
destroy toxic substance
Allen,F.E.
News Articles 23
1 91/03/11
Chance finding offers
hope for PCS cleanup
Swanson.S. - Chicago
Tribune
Public
News Release 24
5 90/11/06
Letter re: copy of the
field logs for oversight
activities at the Carter
Industrials site.
Peterson,j. - U.S.
EPA
Oversight Report 25
7 91/02/13
Letter re: copy of
field logs for oversight
activities at the Carter
Industrials site.
Sanders,D.- BiV Waste
Science and Technology
Corp.
Peterson,J. • U.S.
EPA
Oversight Report 26
29 91/04/03
Memo re: copy of
Opinion by the
Alger County
Circuit Court in
Mich. DNR
Dunky,C. - Honigman
Miller Schwartz and
Cohn
Peterson,J. -U.S.
EPA
Pleadings/Orders 27
15 89/04/17
X'TRAX Low Temperature
Transportable Treatment
Process For Organic
Contaminated Solids
Chemical Waste Management
Reports/Studies 28
110 90/02/20
X*TRAX n
Transportable Thermal
Separator for Solids
Contaminated with
Organics
Chemical Waste Management
Reports/Studies 29
47 90/08/02 On-Scene Coordinator's U.S. EPA Region V
Report CERLA Removal
Action Carter Industrials
Site Phase I Detroit. MI
Reports/Studies 30
34 90/08/22
On-Scene Coordinator's U.S. EPA
POOR QUALITY
ORIGINAL
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Page No. S
04/18/91
ADMINISTRATIVE RECORD INDEX
CARTER INDUSTRIAL SITE
DETROIT, MICHIGAN
PAGES DATE
TITLE
AUTHOR
RECIPIENT
DOCUMENT TYPE DOCNUMBER
34 90/08/22 On-Scene Coordinator's U.S. EPA
Report CERLA Removal Region V
Action Carter Industrials
Site Phase II
Reports/Studies 31
20 91/02/04 Final Report on the
"Disappearing PCBs"
Project
Dr. Soundararajan.R.
•RMC Environmental &
Analytical Laboratories
U.S. EPA
Reports/Studies 32
13 90/04/00 .Monthly Status Report PRP Steering Committee Peterson.J. - U.S. Status Report 33
for Carter Industrials EPA
Site
13 90/05/00 Monthly Status
Report for Carter
Industrial Site
PRP Steering Committee Peterson.J. - U.S. Status Report 34
EPA
14 90/06/00 Monthly Status
Report for Carter
Industrial Site
PRP Steering Committee Peterson.J. -U.S. Status Report 35
EPA
23 90/07/00 Monthly Status Report PRP Steering Conn.
for Carter Industrials
Site
11 90/08/00 Monthly Status Report PRP Steering Conn.
for Carter Industrial
Site
Peterson.J. • U.S. Status Report 36
EPA
Peterson.J. - U.S. Status Report 37
EPA
14 90/09/00 Monthly Status
Report for Carter
Industrial Site
PRP Steering Conn.
Peterson.J. - U.S. Status Report 38
EPA
18 90/10/00
Monthly Status
Report for Carter
Industrial Site
PRP Steering Coomittee Peterson, J.- U.S. Status Report
EPA
39
17 90/11/00
Monthly Status
Report for Carter
Industrial Site
PRP Steering Comnittee Peterson.J. - U.S. Status Report
EPA
40
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Page No. 6
04/18/91
ADMINISTRATIVE RECORD INDEX
CARTER INDUSTRIAL SITE
DETROIT. MICHIGAN
PAGES DATE
TITLE
AUTHOR
RECIPIENT
DOCUMENT TYPE DOCNUMBER
16 90/12/00
Monthly Status
Report for Carter
Industrial Site
PRP Steering Committee
Peterson,J.
EPA
U.S.
Status Report 41
30 91/01/00
Monthly Status Report
for Carter Industrial
Site
PRP Steering Committee
Peterson.J.
EPA
U.S.
Status Report 42
18 91/02/00
Monthly Status Report
for Carter Industrial
Site
PRP Steering Committee
Peterson.J. -U.S.
EPA
Status Report 43
126 90/04/20
Field Activity Report
Treatability Study
Sampling Program
Conestoga-Roverst
Associates
Treatability Study 44
155 90/09/05
X'TRAX tm (APPENDICES)
Laboratory Treatability
Study of Contaminated
Soil from the Carter
Industrial Site
Chemical Waste
Management, Inc.
PRP Steering
Comnittee
Treatability Study 45
33 90/09/05
X'TRAX tm Laboratory
Treatability Study
of Contaminated Soil
from the Carter Indus.
Site
Chemical Waste
Management, Inc.
PRP Steering
Committee
Treatability Study 46
81 90/10/00 Bench Scale Treatability Resources Conservation
Test Final Report for Company
Conestoga-Rovers &
Associates Limited
PRP Steering
Committee
Treatability Study 47
-------
Carter Industrial* site
Administrative Record testate
Date Title
06/06/86 Notes during initial
Consultation.
06/08/86 Notes
06/13/86 Motes.
07/03/86 Motes.
7/11/86 Notes.
07/14/86 Motes.
04/14/88 Analytical Results.
09/30/88 Experimental Debris
Decontamination Nodule.
11/04/88 Gas Facilities.
13/19/87 Trans&ctiona! Data Base.
05/12/86 Determination of Metals.
07/22/86 Soil/Debris Semi ing.
08/07/86 FCE Analysts.
09/05/86 Decontamination of Scrap.
09/28/88 Exemption frca Statutory
lia>it.
00/00/00 Decontamination of Structures
t Debris at Superfund Sites.
10/14/88 Pol reps *1-*9. 10/14/88
to 12/8/88.
00/00/00 Chain of Custody Seports
6/7/86-1/15/87.
00/00/00 Analytical Reports on
Author
Fabinski - ATSDR
ATSDR
ATSDR
Ueston-Sper
Baker
ATSDR
Dollhopf
Taylor
DoofckOMskf
NE1C
California Analytical Labs.
California Analytical Labs
Warner
Clark
Adankus
EPA
Dollhopf
Botiacr/UadsMorth
Recipient
Bowlus
ATSOR
NcLeod
Dollhopf
Cuminghaa
Barkley
Treece
EPA
File
File
File
Peterson
Porter
Pel
Docuaent Tvoe i
Conversation Record
Conversation Record
Conversation Record
Conversation Record
Conversation Record
Conversation Record
Correspondence
Correspondence
Data-base
Memorandum
Memorandum
Memorandum
Meaorandun
Memorandum
Report
Report
Sarrpi ing/Data
Sampl ing/Data
t Pages Volute
1 vol. 1
2 Vol. 1
3 Vol. 1
2 Vol.1
1 Vol.1
1 Vol.1
1 Vol.1
3 vol.1
2 vol . 1
1ST vol.2
3 vol.1
4 Vol.1
t Vol.1
2 Vo1. . 1
1C Vot . 1
24 vol. 3
22 Vol.3
350 vol .4
309 vol.5
PCB's froa 10/1/86 to
8/24/87.
POOR QUALITY
ORIGINAL
-------
2
n*te Title Author tecipient
00/00/00 Hazardous Waste Manifests Dollhopf-ESEPA
from 10/7/86 to 12/7/88.
00/00/00 Analytical Results for Various
PCS Sampling, 8/15/86, 10/86.
00/00/00 TAT Sampling Log t Sanpling Ueston-Sper
Results for Samples
Taken 6/7/86-8/7/86.
00/00/00 Capacitor /Drum/Cylinder Ueston-Sper
logs.
00/00/86 Air Sanpling Worksheets,
Chain-of-Cuctedy forms,
Work Assignment. Lists, X
Sanpling Results for June
t July, 1986.
00/00/86 Maps of Sampling Locations.
00/00/86 Dioxin Sanpline Results: Various
7/11/86, 7/29/86.
J7/18/86 Analysis of 7 Soil California Analytical Labs Ueston-Sper
Sasaples for Oioxins
t Furans.
8/07/86 Analytical Report-Volatile Botimer-Wadsworth P£l
Compounds*
09/12/86 Generator's Waste Material NcLeod-USEPA
Profile Sheets.
09/16/86 Analytical Report -Onj» Botiner-Uadsworth . PEI
Compatibility.
09/30/86 Site Inspections for Sites in Ueston-Sper Strictw
Vicinity of Carter Industrial.
10/08/86 Generator's Waste Material NcLeod-USEPA
Profile Sheets.
10/13/86 Analytical Report -Volatile Botiner-Wadsuorth PEI
Dry !• nt Tvoe
Sampling/Data
Sanpl ing/Data
Sampling/Data
Sanpl ing/Data
Sanpl ing/Data
Sanpl ing/Data
Sanpl ing/Data
Sanpl ing/Data
Sanpl ing/Data
Sanpl ing/Data
Sampl ing/Data
Sanpl ing/Data
Sanpl ing/Data
Sanpl ing/Data
9 Pages Volu
22 Vol
24 Vol
16S Vol
133 Vol
220 Vot
18 Vol
8 Vol
13 Vol
7 Vol
5 Vol
10 Vol
19 Vol
5 Vol
10 Vol
me
.6
.6
.7
.8
.8
.9
.9
.9
.9
.9
.9
.9
.9
.9
10/23/86
'0/30/86
Compounds.
Waste Characterization Fora. McLeod-USEPA
Dru« Conpatibility Report. Botiner-UadSMOrth
PEI
Sanpl ing/Data
Sanpl ing/Data
3 Vol.9
* Vol.9
-------
P.-HV MO.
DATE
TITLE
00/00/00 Chain-of-Custody Reports
from 6-6-86 to 1-15-87.
00/00/00 Analytical Reports:
PCB's from 10/1/86
to 8/24/87.
00/00/00 Hazardous Waste Manifests.
00/00/00 Analytical results for
PCS sampling in and
around the Carter
Industrial Site.
00/00/00 Carter Industrial TAT
Sampling Log and Sampling
Results for samples taken
between the dates of 6/7/86
and 8/7/86.
00/00/00 Drum Logs.
86/00/00 Air Sampling Worksheets,
Chain-of-Custody Forms,
Work Assignment Lists,Haps,
and Sampling Results for
June and July, 1986.
86/00/00 Haps of sampling
locations.
86/00/00 Oioxin Sampling results
from 6-U, 7-11. and
7-29-1986.
86/06/07 Carter Industrial TAT
Sampling Log.
86/07/18 Analyis of seven soil
samples for dioxins
and furans
86/08/00 Chain-of-Custody
Forms for adjacent
street sampling from
7-29-1986 to 8-7-1986.
86/08/07 Analytical Report:
..Volatile Compounds.
86/09/16 Drum Comparability
ADMINISTRATIVE RECORD SAMPLING/DATA INDEX
CARTER INDUSTRIAL SITE: DETROIT. MICHIGAN
DOOJMEHTS ARE HOT COPIED BUT HAT BE REVIEWED AT THE USEPA
REGION V OFFICES, CHICAGO, ILLINOIS.
AUTHOR
RECIPIENT
Bill Botimer-Wadsworth/Alert Tom Uey-PEI Assoc.
Ralph Dollhopf-USEPA
Various
Weston Sper
Weston-Sper
Various
DOCUMENT TYPE
Sanpl ing/Oat a
Sampling/Data
Sampling/Data
Sanpl ing/Data
Sampling/Data
Sampling/Data
Sampling/Data
California Analytical Labs.
Sampling/Data
Sampling/Data
Sampling/Data
Sally Matz-Ueston Cons. Sampling/Data
Sampling/Data
Bill Botimer-Wadswoth/Alert
Tom Uey-PEI Assoc. Sampling/Data
Bill Botimer-Uadsuorth/Alert Tom u«?v-PFI
POOR QUALITY
ORIGINAL
-------
Page Ho.
01/11/89
ADMINISTRATIVE RECORD SAMPLING/DATA INDEX
CARTER INDUSTRIAL SITE: DETROIT. MICHIGAN
DOOMENTS ARE NOT COPIED BUT NAT BE REVIEWED AT THE USEPA
REGION V OFFICES, CHICAGO. ILLINOIS.
DATE
TITLE
66/10/08 Generator's Waste Material
Profile Sheet(s).
86/10/13 Analytical Report:
Volatile Compounds.
86/10/23 Waste Characterization
Form.
AUTHOR
Michael HcLeod-USEA OSC
Bill Botimer-UadSMorth/Alert
Michael McLeod-USEPA
RECIPIENT
Tom Wey-PEI Assoc.
DOCUMENT TYPE
Sampling/Data
Samp I ing/Data
Sampling/Data
86/10/30 Drun Conpatability
Report.
86/10/31 Review of data and data
package SMO case no.
SAS2461E; Data Sets
SF3499. SF3495.
86/10/31 Sampling results from
USEPA data set numbers
SF3499 and SF3495.
Bill Botimer-Uadsworth/Alert
Patrick ChuriIIo-USEPA
Tom Wey-PEI Assoc.
West Coast Analytical
USEPA
Sampl ing/Data
Sampling/Data
Sampling/Data
86/11/06 Waste Characterization
Form.
Ralph DolIhopf-USEPA
Sampling/Data
86/11/17 Multi-Element Analytical
Report.
Sampling/Data
86/12/12 PCS Laboratory Report for
samples taken from the
Carter Industrial site
files.
Tin McGarry-MONR
Chip Landman-USEPA
Sampt ing/Data
87/02/05 Chain-of-Custody
forms for sampling
from the Carter site
from 8-29-86 to
2-5-87.
Sampling/Data
87/02/05 Chain-of-Custody Report
from Tank sampling.
87/11/30 Chain-of-Custody
form for samples
collected 11-25-87
from the Humbolt
Discharge.
88/03/31 Chain-of-Custody form
for samples collected
3/29/88 from the Humbolt
C.J.Lange
Tim Launt us
Dan Capone
Sampling/Data
Sampling/Data
Sampling/Data
-------
Page No.
01/11/89
Administrative Record Index
Carter Industrials Site
Detroit. Michigan
HATE
87/01/22
87/01/27
TITLE
AUTHOR
Letter clarifying MONR's
plans to excavate and
effect off-site disposal
of residential soils which
contain greater than or
equal to ten ppm PCB and
that the amount of soil
requiring excavation will
likely be less than one
thousand cubic yards.
Letter detailing the hDNR's
intentions to transport and
dispose of off-site any
wastes generated during
excavation activities.
Ralph DOllhopf-USEPA
RECIPIENT
Brian Monroe-MDNR
ooanfur TYPE
PACTS
Correspondence
Cardan Cuyer-HONR
Valdas Adamkus-USEPA Correspondence
87/09/17 Detroit Health Oept.urges
that the Carter site be
given the highest possible
priority on the site. Also.
they express concern over
vandalism at the site
and inadequate site
security.
87/10/28 Response to 09/17/87
letter from the Detroit
Health Dept. Assurance
is given that the
site has recieved the
highest possible
* priority.
S2/OVS7 Letter reouesting that
the site be given the
fiijnest possible priority
ana reauest icnediate
rectification of the
prcblens.
Donald Name!-Detroit Health Gary Ktepper-HONR
Dept.
Correspondence
Stephen Cumingham-MONR Hamel-Detroit Health Dept Correspondence
Walter Bogerty-Oetroit Health Ralph DolIhcpf-USEPA
Sept.
Correspondence
As a follow-up to
a 7/8/88 phone
conversation, it is
requested that further
stabilization of
the site be given
a high priority.
Stephen Cunmngham-MDNR Ralph Oollhopf-USEPA
Correspondence
POOR QUALITY
ORIGINAL
-------
Page No.
01/11/89
Administrative Record Index
Carter Industrials Site
Detroit. Michigan
DATE
TITLE
AUTHOR
88/07/22
es/oa/19
00/00/00
00/00/00
CO/00/00
86/06/17
86/06/25
86/07/01
86/07/11
Request that the site
be given more immediate
attention for remediation
and that the site be
adequately secured.
Assurance that the USEPA
is monitoring the situation
and will complete interim
stabilization measures
within the year
Hazard Ranking System
Documentation Log Sheet.
Capacitor and Drum Logs.
Fact Sheet and memo on
the emergency situation
at Carter Industrials.
Situation Investigation
RECIPIENT
DOOXENT TTP6
PACES
James Cray • Detroit Health Steven Lingte-USEPA
Dept.
Correspondence
Timothy Fields-USEPA
James GrayOet.HealthDept Correspondence
USEPA
Weston Sper
Basil Constantelos-USEPA Henry Longest-USEPA
Michael 0. Hoore-HOHR
ACTION MEMORANDUM: limediate Robert Bowden-USEPA
Removal Request for Carter
Industries, Detroit.Michigan
56/C?/C«
86/C7/I8
Site Deeription/Executive
Surma ry.
ACTION MEMORANOUMtExeription
to 11,000,000 Statutory
Limit, Carter Indutrials,
Detroit, Michigan.
ACT.'CM ȣMCR>NOUM:Ceiling
Increase for Carter
Incustrial, Detroit,
Michigan.
ACTICM MEMORANDUM ADDENDUM:
Ceiling Increase for the
Carter Industrial Site,
Detroit, Michigan.
Harrington 4 Cunningham-MDNR
Valdas Adamkus-USEPA
Log
Logs
Memorandum
Memorandun
Memorandum
Memorandum
J.Winston Porter-USEPA Memorandum
Cordon D. Cuyer-MONR
Valdas Adamkus-USEPA
Valdas Adamkus-USEPA
J.Winston Portcr-USEPA He-norandi/n
Timothy Fields-USEPA
.'.Winston Portcr-USEPA Memorandum
136
2
6
3
£6/12/0? ACTION KEMORANOUMrSix-Month
Time Exemption to Allow
the Confirmation of
Michael HcLcod-USEPA:CSC ValCas Adamkus-USEPA Mcmor.indun
POOR QUALITY
ORIGINAL
-------
Page Mo. S
01/11/89
Administrative Record Index
Carter IndBtrials Site
Detroit. Michigan
TITLE
AUTHOR
87/01/13
87/01/16
87/03/31
88/02/08
86/06/17
SLfimary of results from
Carter Industrial PCS
Site, Hurbolt Street,
Detroit-Roof Cutter Air
Quality Survey.
Request for review of the
Roof Cutter Air Quality
Survey.
Memo on the Oubrinski
property Responsible
Party clean-up.
Recommendation of removal of
PCS contaminated sediments at
all areas exceeding 1.0
rog/kg total PCB's.
Discussion of off-site
PCS values with attached
sample location descriptions.
Deposition of Thomas 0.
Carter.
RECIPIENT
OOCLMEMT TYPE
PACES
Richard Johns-MDNR
Richard Johns-MDNR
Carla Lange - TAT
Dave Kenaga-MONR
86/06/24 Affidavit of Irving Oubrinsky.
87/10/08 Affidavit of Ralph Oollhopf.
00/00/00 Photographs of the site and
of surrounding area taken
between the dates of 6/9/86
and 10/28/87.
£?/Ol/CO Unilateral Administrative
Order.
Si/07/10 Preliminary Assessment.
5i/07/10 Report On Inspection lo
Determine Conpl iance with
The PCS Regulations: Carter
Incustrials, Inc. PCS
Inspection &82J72.
86/06/05 Initial Sampling Site
Safety Plan.
Lawrence Chadzynski-MONR Memorandum
Lawrence Chadzynski-HOPH Memorandum
Carter Site File
Brian Monroe-MDNR
Ralph Oollhopf-USEPA
Thomas D. Carter
Irving Oubrinsky
Ralph Dollhopf-USEPA
Craig Bel I,Carla Lange,Mary
Bell,..
USEPA
Harrington & Cunningham-MDNR
HONR
See service I ist
Memorandum
Memorandum
Doug Ballotti-USEPA Memorandum
Other
Other
Other
Photographs
Pleadings/Orders
Reports/Studies
Reports/Studies
17
122
3
4
215
26
Craig Bell-Ueston Sper
Reports/Studies
-------
Page No.
01/11/89
Administrative Record Index
Carter Industrials Site
Detroit, Michigan
PATE
TITLE
AUTHOR
86/06/10 Site Description/Executive
S urinary.
86/06/10 Preliminary Assessment.
86/06/11
86/08/11
86/09/04
86/10/00
Hazardous Waste Site
Investigation And
Emergency Response
Safety Plan.
Summary of dioxin and
furan data with cover
letter explaining the
process.
Hazardous Waste Site
Investigation And Emergency
Response Safety Plan.
Harrington & Cunningham-MDNR
Harrington & Cunningham-MONR
Tom Gainer-Weston Sper
REC1PIEMT
Sally Briand Uu
MatzSS.O.Springer-Weston Sper
Ueston Sper
USEPA
Concentrations of PCS's in MDNR-Surface Water Oual.Oiv.
Sediment Oepositional Zones
in the Upper Detroit River
along the United States Shore,
July 8 and 9, 1986, and the
18th Steet Sewer System,
Detroit Michigan, July H
and 15, 1986.
86/10/00 Final Sampling And
Analysis Plan.
86/10/H Site Inspection Report.
86/10/16 "Carter Industrial PCS Site
Munbolt And Forest Streets
vicinity Detroit, Michigan
"OKA Staff Report Of Roof
Cutter Air Quality Survey."
S6/1C/J9 Draft Screening and
Selection Document.
Roy F. Weston, Inc.
USEPA
Stephen D. Cunningham-WNR USEPA
rONR
Kurt Stinpson-Roy f.
Weston,Inc.
M.naeed-USEPA
OOOXEMT TYPE POKES
Reports/Studies 2
Reports/Studies 4
Reports/Studies S
Reports/Studies
Reports/Studies 33
Reports/Studies 13
Reports/Studies 17
Reports/Studies 14
Reports/Studies 13
Reports/Studies 10?
£6/10/30 Hazard Ranking System
Scoring Package.
£6/10/30 Documentation Records For
Hazard Ranking System.
Stephen 0. Cunningham-HDNR
Stephen 0. Cunningham-MOKR USEPA
Reports/Studies
Reports/Studies 13
-------
Page Mo.
01/11/89
Administrative Record Index
Carter Industrials Site
Detroit, Michigan
DATE
TITLE
AUTHOR
RECIPIENT
POQXEMT TYPE
86/12/11 Engineering Evaluation of
the Surface Water Runoff
Collection and Treatment
System.
R.Michael Sort-Roy F.
Ueston,Inc.
Ralph Dollhopf-USEPA Reports/Studies
86/12/18 Engineering Evaluation/
Cost Analysis.
S7/01/U Tables 1 and 2 for the
report entitled "Carter
Industrial PCS Site, Humbolt
and Forest Streets Vicinity,
Detroit, Michigan - HONR
Staff Report of Roof Cutter
Air Quality Survey".
87/03/00 "Sediment PCS Concentrations
Along The U.S.Shore Of The
Upper Detroit River, And
Sediment And Water PCB
Concentrations In Two City
Of Detroit Combined Sewers
With Overflows To Ihe Detroit
River,July And October. 1986,
And January. 1987.'•
87/06/19 Analytical Report and
Reccmnendations for the
Briquetting Press at the
Carter Site in Detroit.MI.
27/07/02 POLREP nunt>ers one
through sixty one.
Stimpson, et al -Roy F.
Ueston,inc.
Brian Monroe-MDNR
USEPA
Reports/Studies
213
Lawrence Chadzybski-MOPH Reports/Studies
HDNR
Reports/Studies
16
Paul S. Willie
Inc.
S-HAZTECH,
Teicher-Earle Erman&Assoc Reports/Studies
59
Ralph Oollhopf-USEPA '
USEPA Region V
Reports/Studies
107
;?.<:;/:0 :ncan;emfnt Assessment
Envirsmental
USEPA
Reports/Studies
172
Management
-------
Page No.
01/11/89
Administrative Record Index
Carter Industrials Site
Detroit, Michigan
TITLE
00/00/00 PRP List for Carter site
00/00/00 Transactional' database for
Carter site.
AUTHOR
U.S. EPA
NEIC
RECIPIENT
U.S. EPA
DOCUMENT TYPE PACES
List 3
Microfiche
86/06/16 Air Monitoring at Carter
Industrial Site (methods).
Mike McLeod-USEPA
Phil Campsgna-ERT
Comnunication Record 1
86/06/16 Cleanup levels and air
monitoring for Carter
Ind. Site.
Mike McLeod-USEPA
Robert Bowden-USEPA Complication Record 1
00/00/00 Adequate cleanup levels
of PCB's at the bricketter.
Daniel Patutski-USEPA
Ralph Do11hoof-USEPA Correspondence
86/07/U Update on the involvement
of the Wayne Cointy Air
Pollution Control Division
with the Carter Industrial
Site.
Allan Greenberg-Wayne Co. Ralph Dollhopf-USEPA Correspondence
86/08/17 Letter detailing work to
be performed by contractor
hired by Philip Dubrinsky
Enterprises.
R.L.Benson-Marine Pollution Michael McLeod-USEPA Correspondence
Control
86/08/22 Recommendation that normal
puttie service operations
be resumed in the vicinity
of Carter Industrial.
John Waller-Dept. of Health C.Abrams-Dept.ofPub.Works Correspondence
86/08/25 Letters reiterating the
USEPA position that
public firts are to be
' expended to take action
to abate a release or
threatened release of
hazardous substances
and offering the three
recipients an opportunity
to take the necessary
action themselves.
Letters sent to J.Ishbia,
F.Dery and T. Carter.
Basil Constantelos-USEPA
title
Correspondence
86/08/26 Notification that the Carter
Industrial area has been
cleaned of PCB's to levels
below SOppm and that
municipal services nay be
resimed in The arp.i
Ralph Dollhopf-USEPA
John Wailer-Oept.ofHealth Correspondence
-------
I.
II.
ra.
IV.
V.
VI.
VII.
vm.
IX.
X.
XI.
xn.
xm.
i.
2.
3.
4.
5.
6.
7.
8.
TABLE OF CONTENTS
SITE LOCATION AND DESCRIPTION
SITE HISTORY AND ENFORCEMENT ACnvmES
COMMUNITY RELATIONS HISTORY
SCOPE AND ROLE OF OPERABLE UNIT
SITE CHARACTERISTICS
SUMMARY OF SITE RISKS
REMEDIAL ACTION OBJECTIVES
DEVELOPMENT OF REMEDIAL ACTION ALTERNATIVES
EVALUATION OF ALTERNATIVES
THE SELECTED REMEDY
STATUTORY FINDINGS
EXPLANATION OF SIGNIFICANT CHANGES
RESPONSIVENESS SUMMARY
LIST OF FIGURES
SITE LOCATION
NEIGHBORHOOD SURROUNDING CARTER SITE
SITE STABILIZATION FACILITIES
ANNUAL WIND ROSE DETROIT CTTY AIRPORT
LOCATION OF WASTE PILES AND SITE BUILDINGS
POST STREET CLEANING SAMPLING RESULTS
POST SOIL EXCAVATION SAMPLING RESULTS
PRP SAMPLING LOCATIONS (1990)
1
1
5
6
6
9
22
25
38
42
45
50
(following) 52
-------
LIST OF TABLES
1. SITE HISTORY
2. SUMMARY OF RESULTS OF ORGANIC ANALYSIS
3. SUMMARY OF RESULTS OF INORGANIC ANALYSIS
4. SUMMARY OF RESULTS OF EP-TOXICITY TEST
5. SUMMARY OF RESULTS OF TECHNICAL PARAMETERS
6. * SUMMARY OF RESULTS OF GEOTECHNICAL ANALYSIS
7. DAILY AIR MONITORING RESULTS DURING 1986 REMOVAL ACTION
8. SUMMARY OF PCB ANALYSES DURING 1986 REMOVAL ACTION
9. MAXIMUM LEVELS OF CONTAMINANTS
10. RESULTS OF PRP'S 1990 TEST PITTING OPERATION
11. REPORTED SERUM PCB LEVELS IN URBAN AMERICANS
12. CARCINOGENS & NONCARCINOGENS AT THE CARTER SITE
13. CONTAMINANTS OF CONCERN FROM ENDANGERMENT ASSESSMENT
14. CALCULATIONS USED TO DERIVE EXPOSURE DOSES
15. PARAMETERS USED IN EXPOSURE DOSE CALCULATIONS
16. RISKS FROM INHALATION OF CONTAMINATED PARTICULATES
17. RISKS FROM INHALATION OF VOLATILIZED PCBS
18. RISKS FROM INGESTION OF CONTAMINATED SOIL (NONCARCINOGENIC)
19. RISKS FROM INGESTION OF CONTAMINATED SOIL (CARCINOGENIC)
20. RISKS FROM INGESTION OF SOIL IN NEIGHBORHOOD
21. NONCARCINOGENIC RISK FROM DIRECT CONTACT (CHILDREN)
22. NONCARCINOGENIC RISK FROM DIRECT CONTACT (ADULTS)
23. CARCINOGENIC RISK FROM DIRECT CONTACT (ON-SITE)
24. CARCINOGENIC RISK FROM DIRECT CONTACT (OFF-SITE)
25. SUMMARY OF SIGNIFICANT RISKS
26. COMPLIANCE WITH ARARs
27. COST COMPARISON
-------
DECISION SUMMARY
I. SITE LOCATION AND DESCRD7TION
The Carter Industrials facility is located at 4690 Humboldt Street in Detroit, Michigan. The Site
encompasses this and adjacent properties. It is situated approximately 1/2 mile southeast of the
intersection of interstate highways 96 and 94.
The Site covers approximately 3.5 acres and contains seven piles of PCB-contaminated soil and
debris (approximately 46,000 cubic yards). Several structures, including two buildings, two
smelters and an incinerator are located on Site. A 1000 gallon underground storage tank
containing a gasoline and water mixture is also located on the Site.
As shown on Figure 1, the Site is located in a mixed residential and light industrial
neighborhood near downtown Detroit. Directly to the north are branches of the Grand Trunk
Western and Penn Central railroads. The Site is bordered to the south by Forest Street, along
which both residential and commercial properties are located. Immediately to the east is a
residential area, and to the west is vacant property. There are two businesses which are
operating on the Site perimeter (Figure 2): an auto parts dealer and a scrap yard. The 1980
Census tracts which immediately adjoin the Carter Site reported a total population over 21,000
persons.
The nearest body of surface water is the Detroit River which is located approximately 6000 feet
south of the Site. The Site is located more than 2 miles from a 5-acre coastal wetland and more
than 1 mile from a 5-acre fresh-water wetland. There are no designated Michigan Significant
Habitats, agricultural land, or historic or landmark Sites directly or potentially affected.
IL SITE HISTORY AND ENFORCEMENT ACTIVITIES
From 1966 to 1986, the Carter Site was used to store and salvage scrap metal. From 1966 to
1971, the Site was operated by Spector-Carter Metal, while from 1971 to 1986, Carter
Industrials, Inc. operated the Site. A portion of me scrap metal items accepted at the Carter Site
included electrical capacitors and transformers.
During salvage operations at the Site, dielectric fluids containing PCBs were spilled from
electrical capacitors and transformers, contaminating on-site soil. Commercial, municipal and
residential properties adjacent to the Site were contaminated by direct runoff of spilled material,
contaminated storm water runoff, wind-blown dust, and tracking of spilled material and
contaminated soils by vehicular traffic.
In May 1986, the Michigan Department of Natural Resources (MDNR) collected soil samples
at the Site, revealing PCB contamination at concentrations of up to 510,000 parts per million
(ppm). On June 4, 1986, MDNR referred the Site to the Emergency Response Program of the
U.S. EPA (Region V). A chronology of events which occurred after referral to the Emergency
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Response Program is summarized in Table 1.
TABLE 1
June 5, 1986 - Site inspection by Ralph Dollhopf, OSC, confirmed that severe contamination
existed at the Site.
June 6,1986 - U.S. EPA's Technical Assistance Team (TAT) started an extent of contamination
study involving collection and analysis of over 2000 samples and identification of on-site and
off-site areas requiring clean-up.
June 6, 1986 - U.S. EPA's Region V Emergency Response Program initiated a removal action
to confine PCB contamination to the Carter Site. U.S. EPA's activities consisted of the
following major tasks:
Stabilization of uncontrolled Site perimeters was accomplished by pushing highly-
contaminated areas of the perimeter back towards the Site interior in order to
reduce any further migration of contaminants. In addition, some areas of the Site
surface were cleared of debris to accommodate the staging of the consolidated
contaminated soils from off-site areas.
Contaminated soils and debris from the surrounding neighborhood were excavated
and consolidated into waste piles on-site.
Identifiable PCB items (e.g. capacitors and oils) were removed from the Site for
off-site disposal (incineration).
Larger pieces of scrap metal found on the surface of the Site were decontaminated
and removed from the Site.
Municipal streets and alleys in an approximately four square block area
surrounding the Site were decontaminated.
Several alleyways adjacent to the Site were unable to be cleaned adequately and
were repaved.
The Site was graded to direct runoff toward the southeast section of the Site
where a system of interception trenches, collection tanks, and mixed media filter
units collect and treat the runoff water (Figure 3).
A 6-foot chain-link cyclone fence topped with three strands of barbed wire was
erected around the Site to prevent unauthorized entry.
Fall 1986 - The U.S. EPA and MDNR staff sampled rain gutter sediments and debris in the
vicinity of the Carter Site. The purpose of this sampling was to determine if PCBs had been
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transported aerially into the surrounding community. These data showed a general radial pattern
with PCS levels tending to decrease in a given direction as the distance from the Site is
increased. PCB levels for the rain gutters sampled ranged from non-detectable to 38 milligrams
per kilogram (mg/kg).
Fall 1986 - U.S. EPA began identifying Potentially Responsible Parties through analysis of Site
records and issuance of CERCLA Section 104(e) information requests.
October 1986 - The TAT took samples from the waste piles, surface soils, subsurface soils,
groundwater, and a seep encountered below the surface. PCBs and heavy metals were found
in on-site ash and soils.
October 1986 - Two buildings and an incinerator located on-site were sampled revealing
concentrations of PCBs ranging from 6 to 100 micrograms per 100 square centimeters for wipe
samples and 85-900 ppm for floor sweep samples.
October 1986 - A Site inspection report was prepared by the MDNR. Following this, the Site
was evaluated for the National Priorities List (NPL) using the "Uncontrolled Hazardous Waste
Site Ranking System" (MRS). The Site received a score of 37.79, making it eligible for
inclusion on the NPL.
October 1986 - Sampling undertaken by the MDNR and the City of Detroit in September and
October of 1986 detected PCB contamination at levels up to 4900 mg/kg in the city sewer lines
immediately adjacent to the Carter Site and along the connecting 18* Street line to the Detroit
River.
December 1986 - An Engineering Evaluation/Cost Analysis (EE/CA) was completed. The
EE/CA's screening and selection process for evaluation of the alternative remedial technologies
was conducted in accordance with the procedures outlined in the draft "Proposed Alternative
Treatment/Disposal Technology Guidance for Removal and Expedited Response Actions".
Fall 1986 - MDNR removed contaminated soil in the residential areas with contamination levels
between 10 and 50 mg/kg. Contaminated soil was disposed of off-site at a RCRA landfill in
Ohio.
10/86 to 10/88 - Despite security fencing, 24-hour armed guards, and stepped up Detroit Police
patrols, the Site was broken into repeatedly after the U.S. EPA removal action began. Vandals
gained access by removing security fencing, thereby providing unrestricted access to the Site by
children living nearby. Vandals repeatedly removed contaminated scrap metal, knocked out
walls and broke into contaminated buildings, and vandalized three large transformers on the Site.
In addition, vandals set fires to the vegetative cover (grass) which was planted on the waste piles
to reduce migration of contamination.
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October 1988 - U.S. EPA acted to improve Site security by repairing vandalized fencing. U.S.
EPA also attempted to reduce the attractiveness of the Site to vandals by removing as much
scrap metal and debris as possible.
November 1988 - An underground fuel storage tank was identified at the Site. The contents of
the tank consists of a 50/50 mixture of gasoline and water.
June 24, 1988 - The Site was proposed for inclusion on the NPL.
Jan. 24, 1989 - An Endangerment Assessment was completed by the U.S. EPA. This
assessment revealed that persons in the vicinity of the Site may have up to 4 x 10E-02 increased
cancer risk for inhalation of volatilized PCBs, as well as a significant non-carcinogenic hazard.
Jan. 24,1989 - U.S. EPA issued an Administrative Order to 30 PRPs pursuant to Section 106
of CERCLA, which required that the respondents undertake interim Site safety measures, such
as fence maintenance, run-off collection and treatment system operation and maintenance, and
provision of Site security. This order also called for the Respondents to undertake one of the
response options which had been reviewed in the EE/CA after opportunity for public review and
comment on the PRP's proposal and workplan.
Feb. 8,1989 - EPA/MDNR Conference regarding the 106 Order - Detroit Public Library. The
Respondents requested that they be allowed to have sufficient time to coordinate and form a
steering committee, review the administrative record, and put together a proposal as to how they
were going to proceed.
Feb. 28,1989 - EPA issued an amended order which extended the effective date until April 10,
1989.
March 23, 1989 - EPA/MDNR Technical Conference with the PRP's technical consultant
regarding feasibility of the options contained in the EE/CA.
March 31, 1989 - The Site was listed on the NPL.
April 5,1989 - EPA/MDNR Conference with PRPs to discuss PRP proposal. Proposal involved
capping of all soil and debris in place. EPA/MDNR advised Respondents that this was not
sufficiently protective of human health and the environment.
May 5, 1989 - 2nd amendment of 106 Order (Bifurcated) was issued to require the respondents
to immediately undertake interim Site stabilization measures, including: 24-hour security guards
posted at the Site; laying geotextile over the waste piles to stabilize the Site; hydroseeding
operations; assumption of the responsibility for the run-off collection and treatment system, as
well as all utilities and services at the Site. The bifurcated amended 106 order also provided a
2nd effective date tied to U.S. EPA's selection of a response alternative after an opportunity for
public review and comment on the proposed plan.
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May 25, 1989 - PRPs proposed to excavate and dispose of soils containing PCB levels over 50
ppm in an off-site landfill and to cap all the rest. Respondents were advised that cleanup level
would be at most 10 ppm due to proximity of residences, as set forth in the PCB Spill Policy.
June 1, 1989 - Geotextile cover and hydroseeding operations completed by Respondents.
August 1989 - Feasibility Study of remedial alternatives commenced by U.S. EPA.
May 1990 - Treatability Study Sampling Program conducted by Conestoga-Rovers and
Associates on behalf of PRPs.
Fall 1990 - Treatability Studies of B.E.S.T. solvent extraction and X-Trax (Low Temperature
Thermal Desorption) technology were completed for PRPs.
April 19, 1991 - Feasibility Study and Proposed Plan issued to public and comment period
commenced.
May 2, 1991 - Public Meeting on Proposed Plan held in Detroit.
June 18, 1991 - 60 day Public Comment Period Closed.
July 26,1991 - Several provisions of the 106 Order were rescinded in keeping with U.S. EPA's
decision to pursue a negotiated settlement with the PRPs.
in. COMMUNITY RELATIONS HISTORY
U.S. EPA placed the Engineering Evaluation/Cost Analysis, Endangerment Assessment, and the
106 Order in an administrative record in the Detroit Public Library, and issued a press release
announcing issuance of the 106 Order on January 24, 1989. The administrative record was
subsequently updated to include sampling/data, information as to liability and other information
which had been requested by the public. A press release was also issued on February 28, 1989.
The Feasibility Study and Proposed Plan for Selection of Preferred Response Alternative were
published on April 19, 1991 in accordance with CERCLA Section 113(k)(2)(B)(i-v). A press
release and newspaper advertisement were issued at the same time announcing the availability
of the Feasibility Study and the Proposed Plan and inviting public comment on the same. The
administrative record was again updated on this same date with all pertinent information which
had been gathered since February of 1989. Copies of the Endangerment Assessment,
Engineering Evaluation/Cost Analysis, Feasibility Study and Proposed Plan were also placed at
the Core City Neighborhood facility serving the community adjacent to the Site. The Feasibility
Study and Proposed Plan were open to public comment until June 17, 1991. Fact sheets
summarizing the Proposed Plan were mailed to interested parties on April 12, 1991.
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A public meeting was held on May 2, 1991 to present the results of the FS and the preferred
alternative as presented in the Proposed Plan for the Site. All comments which were received
by EPA prior to the end of the comment period, including those expressed verbally at the public
meeting, are addressed in the Responsiveness Summary which is attached to this Record of
Decision.
IV. SCOPE AND ROLE OF OPERABLE UNIT
This decision addresses contaminated soil and debris located at the Carter Industrials Site at 4690
Humboldt Boulevard, in Detroit, Michigan. The soils, waste piles and buildings on the Site are
contaminated with PCBs and heavy metals. This contamination constitutes a threat to human
health and the environment at the Site. It poses a risk to the surrounding residential
neighborhood resulting from on-site dermal contact with PCBs and the inhalation of PCB vapors
and contaminants which are adsorbed to particulates migrating from the Site as fugitive dust.
Prior to the selection of the response action in this ROD, U.S. EPA took several on-site
stabilization measures designed to prevent short-term migration of contaminants. These
measures included covering waste piles with geotextile materials and seeding them; installing a
fence around the Site perimeter; and installing a surface water run-off collection and treatment
system. The selected remedy calls for continued Site stabilization and security, pending the
completion of treatment of the contaminated soil. The selected remedy will address the principal
threat at the Site by distilling oil containing PCBs from contaminated soil and incinerating the
oil off-site. Contaminated debris that cannot be processed in the desorption system will be
disposed of off-site in an appropriate landfill. A later operable unit will assess and if necessary
remediate PCB contamination in the sewer lines running from the Carter Site to the Detroit
River.
V. SITE CHARACTERISTICS
Geologic Setting
The Carter Industrials Site is underlain by unconsolidated glacial deposits approximately 130 feet
thick. The major drift component is clay. Beneath the Site, the clay is at least 50 feet thick.
Isolated saturated sand lenses are known to occur within the clay, but these lenses are neither
persistent nor interconnected. Beneath the glacial deposits is the Dundee Limestone. The
Dundee Limestone consists of up to 150 feet of cherty limestones and dolomites. Cavities that
produce oil and gas are common, as are fossil-rich zones.
Hydrogeology
The Detroit area is one of the least favorable areas in the State of Michigan for developing water
production wells. Ground water, where located in the clay deposits, has a high potential for
contamination from septic tank systems due to the generally poor drainage conditions.
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The thickness of the glacial deposits (at least 590 feet) represents an obstacle to subsurface
drainage from the Site. Results of previous investigations at the Site indicate that the lacustrine
clay has a very low hydraulic conductivity (10"* cm/sec). The low hydraulic conductivity and
the clay's thickness combine to form an effective barrier to vertical contaminant migration while
the potential for horizontal movement of contaminants within the clay exists.
Dundee Limestone wells have produced water in sufficient quantity for domestic and industrial
uses. However, production rates from the Dundee Limestone are unpredictable. In addition,
water produced from the Dundee Limestone is highly mineralized, limiting its potential uses.
Climatology
Detroit is situated in the Great Lakes Region and is under the climatic influence of the lakes.
Extreme temperatures occur infrequently in the Detroit area. According to the Statistical
Abstract of the United States, the average annual rainfall is approximately 31 inches, but violent
rainstorms are rare. The number of days with precipitation over 0.01 inches is 133 per year.
The average windspeed is 10.1 miles per hour.
The annual wind rose for the Detroit City Airport (Figure 4) indicates that an average wind
speed of 4.5 meters per second from the west characterizes the prevailing wind direction. This
prevailing wind direction means that persons living east of the Site (most nearby homes are
located in this direction) will be exposed to volatiles generated at the Site.
Nature and Extent of Contamination
The quantitative extent and magnitude of on-site contamination were determined as a result of
a field investigation conducted at the Site between October 7 and October 14, 1986 and a
treatability study sampling program performed by Conestoga-Rovers Associates (CRA) on behalf
of the potentially responsible parties (PRPs) in March 1990. Several matrices (waste piles, ash,
surface and subsurface soils, buildings, etc.) were sampled and analyzed for a wide variety of
parameters. The results of these investigations are presented in the December 1986 Engineering
Evaluation / Cost Analysis and CRA's April 1990 treatability study sampling program report and
are summarized in this document.
Ground Water
As noted above in the section on Hydrogeology, the Detroit area is not underlain by any current
or potential drinking water aquifers. During October of 1986, soil borings from 10 to 50 feet
deep were advanced and sampled. Only one of the four monitoring wells drilled was installed
because no permeable zones were encountered in the other three. The one which was installed
encountered a sand lens. The overall results of the geologic investigation indicate that the Site
is underlain by at least 50 feet of clay with a very low hydraulic conductivity. Based upon this
information, the Carter Site does not present a significant threat to a drinking water aquifer.
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Oil-site Soil and Debris
Laboratory analyses were conducted on samples collected from the waste piles (both soil and
ash), surface soils, subsurface soils (borings up to 7 feet deep), groundwater, and a seep
encountered below the surface. The samples were analyzed for PCBs and other organics (Table
2), inorganics (Table 3), EP-Toxic metals (Table 4), and technical paramenters such as asbestos-
moisture-sulfur content (Table 5). Samples taken from the borings at the Site were analyzed for
geotechnical parameters (Table 6). Air samples were collected and analyzed during the Fall of
1986 while EPA was conducting its removal action (Table 7).
The analytical results generally indicate that on-site PCB contamination is present in seven large
waste piles located on the Site (Waste Piles 1, 2, 3, 4, 5, 6 and 7) (See Figure 5). In addition
to PCBs, these waste piles have elevated concentrations of cadmium, copper, lead and zinc. The
waste piles are divided into categories based on their estimated PCB concentration to develop
the volume of contaminated material for cost estimating purposes. There is a total of
approximately 46,000 cubic yards of contaminated soil and debris at the Site. During actual
design and remediation, more extensive sampling will be performed to segregate "hot spots"
located within a waste pile and determine the final volume of contaminated material. The results
of sampling and analysis for PCBs performed by the U.S. EPA Emergency Response Program
are summarized in Tables 8 and 9.
Underground Storage Tank
A 1000 gallon underground storage tank was discovered during the Phase I removal. The tank
is located under the driveway east of building 3. Analysis of samples of the tank contents
revealed that it is approximately 3/4 full of a 50%/50% mixture of gasoline and water. The
access pipe was capped and marked.
Off-site Contaminated Areas
The off-site residential areas were cleaned by the U.S. EPA Emergency Response Program to
SO mg/kg PCB in 1986. These areas are shown on Figure 2. The MDNR removed residential
soils contaminated with PCBs from 10 - 50 mg/kg (Fig. 2). Several areas remain with soils
contaminated with PCBs between 1 to 10 mg/kg and are shown on Figures 6 and 7.
The alleyway just to the east of the Site was unable to be decontaminated to less than 50 mg/kg,
so it was repaved as part of the Emergency Response Program's efforts in 1986.
Problems encountered during Removal activity
The Carter Site is located in an area of Detroit in which theft and vandalism are not uncommon.
Snow fencing, wire fencing, warning signs and 24-hour security guards were often ineffective
in preventing unauthorized personnel from entering the Site. This resulted in repeated
scavenging of potentially contaminated materials from the Site. The OSC's report from Phase
• 8
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I of the removal action (dated August 20, 1990) discusses this in more detail.
Treatability Study Testing Program
In May of 1990, the Potentially Responsible Parties conducted test pitting operations at the Site.
The purpose of this test pitting operation was to obtain representative samples for conducting
treatability studies and to further define the extent of contamination in on-site materials.
The locations of samples taken for the Treatability Study Testing Program conducted by the
PRPs are shown in Figure 8 and the results are summarized in Table 9.
VI. SUMMARY OF SITE RISKS
Public Health Studies
In 1987, the Michigan Department of Public Health (MDPH) studied the effects of PCB
exposure on people living near the Carter Site. MDPH issued questionnaires and collected blood
samples from residents in the more contaminated areas adjacent to the Site as well as in a less
contaminated area (Frederick neighborhood), farther away. The questionnaire covered items
known to affect PCB levels in humans, including occupational exposure, consumption of sport
fish, and age, as well as Site exposure data, such as address, length of residence, hours spent
outside, and (for children) frequency of play on the Site and in the alleys with high PCB
concentrations. Among the 235 people tested, age was the only variable that correlated well
with serum PCB levels; older people had higher levels, due to PCB accumulation. MDPH
advanced two hypotheses for the general lack of correlation: (1) serum PCB is too insensitive
a parameter to detect small but significant changes; and, (2) the affinity of PCBs for soil
prevents absorption.
Table 11 summarizes the results from this and earlier studies. The results show that, in 1987,
residents in the Carter Industrial neighborhood had serum PCB concentrations similar to or
slightly higher than those of various non-exposed populations, but lower than those of persons
eating fish from contaminated areas and persons occupationally exposed.
U.S. EPA Endangerment Assessment
U.S. EPA conducted an Endangerment Assessment in 1989 to evaluate the risks to human health
and the environment posed by the contamination at the Site. Five (5) potential carcinogens and
fifteen (15) non-carcinogens were detected with any regularity at the Site (Table 12). The goal
of this endangerment assessment was to quantify the risks from the Site. The risks to human
health are quantified by using Cancer Potency Factors for carcinogenic contaminants and
Reference Doses for noncarcinogenic contaminants.
Cancer potency factors (CPFs) have been developed by EPA's Carcinogenic Assessment Group
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for estimating excess lifetime cancer risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (mg/kg-day)"1, are multiplied by the estimated
intake of a potential carcinogen, in mg/kg-day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake level. The term "upper bound"
reflects the conservative estimate of the risks calculated from the CPF. Use of this approach
makes underestimation of the actual cancer risk highly unlikely. Cancer potency factors are
derived from the results of human epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been applied.
Reference doses (RfDs) have been developed by EPA for indicating the potential for adverse
health effects from exposure to chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg-day, are estimates of lifetime daily exposure levels for humans,
including sensitive individuals. Estimated intakes of chemicals from environmental media (e.g.,
the amount of a chemical ingested from contaminated drinking water) can be compared to the
RfD. RfDs are derived from human epidemiological studies or animal studies to which
uncertainty factors have been applied (e.g., to account for the use of animal data to predict
effects upon humans). These uncertainty factors help ensure that the RfDs will not
underestimate the potential for adverse noncarcinogenic effects to occur.
Selection of Contaminants of Concern
Four contaminants of concern were selected based upon their toxicity, mobility and persistence
in the environment. Because of extremely high levels of PCBs detected at the Site (up to
500,000 ppm), PCB contamination was the primary contaminant of concern for the Site soils.
All organic contaminants identified in Table 2 (with the exception of PCBs) were eliminated
from consideration because they were detected extremely infrequently (< 5 % of samples). PCBs
and arsenic were selected because of their carcinogenic potential (ingestion); lead was selected
because of its high toxic potential for young children (especially those from an urban
environment where ingestion of leaded paints and inhalation of automobile exhausts may have
already resulted in an elevated lead body burden). Cadmium was selected over nickel because
of its higher potency factor (both pose threats through ingestion).
Table 13 is a summary of the contaminant concentrations and the geometric means for the
contaminants of concern at the Carter Industrials Site.
Fate and Transport of Contaminants
Environmental factors, such as Site geology, hydrogeology and climatology affect movement of
contaminants of concern. The Carter Site is underlain by unconsolidated glacial deposits which
are at least 130 feet thick. From the surface to at least SO feet below the Site is a low
permeability lacustrine clay. Beneath the glacial sediments is the Dundee Limestone which may
be up to 150 feet thick. The Dundee Limestone is a known oil and gas producing formation in
the State of Michigan.
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At the Carter Site, most of the Aroclor 1260 will remain bound to the soils. Some volatilization
and photolysis could occur from surfaces exposed to the atmosphere. Small quantities of
Aroclor might also be leached from soils to the groundwater. However, as noted above in the
section on Hydrogeology, the Detroit area is not underlain by any current or potential drinking
water aquifers. The overall results of the geologic investigation indicate that the Site is
underlain by at least 50 feet of clay with a very low hydraulic conductivity. Based upon this
information, the Carter Site does not present a threat to any groundwater system.
Overall, soil will act as a sink for Aroclor 1260. Off-site transport is also possible through
particulate emission to the air and runoff.
Cadmium
The major fate processes for cadmium at the Site are complexation to organic carbon and
mineral surfaces in soils. Probable pathways for off-site transport are emission and runoff of
cadmium associated with particulate material.
Lead
Lead is not mobile in soil/water systems due to low solubility and high affinity to sorb onto
soils. However, metals will migrate more rapidly in the presence of high levels of Total
Organic Carbon (TOC). Some microorganisms can methylate lead resulting in the formation of
tetramethyl lead, which is volatile and even more toxic than inorganic lead. The primary route
of off-site transport at the Site is through emission and runoff of lead associated with particulate
material.
Arsenic
Sorption to soils appears to be the major fate process for arsenic at the Site. The primary route
of off-site transport at the Site is through emission and run-off of arsenic associated with
. particulate matter.
Exposure Pathways
Four scenarios were identified through which populations could become exposed to
contamination from the Carter Site:
o Inhalation of contaminants which have volatilized or are adsorbed to particulates
The most extensive set of air monitoring data taken at the Carter Industrials Site measured both
particulate and volatile PCBs during cleanup activities conducted between June 24 and July 27,
1986, in the neighborhood immediately surrounding the Site. These data (Table 7) revealed
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paniculate time weighted average (TWA) PCS concentrations ranging from <0.1 to 1 ug/m3
and volatile PCB concentrations ranging from 0.1 to 2 ug/m3.
To determine the approximate present day human exposure to PCfis, arsenic, cadmium, and lead
through air inhalation, a multistep estimation procedure was used. First, the separate paniculate
and volatile emission rates of these compounds from the waste piles and open areas of the Site
were estimated. These emission rates were calculated based on a range of ground cover
conditions (reflecting possible deterioration or weathering of the existing waste pile cover) and
both maximum and representative contaminant concentrations.
Using the emission rates calculated in this first step, the paniculate and volatile air
concentrations for points on-site (paniculate and volatile concentrations) and at distances greater
than 100 meters off-site (volatile concentrations only) were calculated. Next, using standard
values, the paniculate and volatile contaminant intakes or exposure doses for both adults and
children were calculated. Where appropriate, both acute and average lifetime exposure doses
were calculated.
o Ingestion of contaminated soils on-site
As discussed before, extensive sampling had been conducted of the soils at the Carter Site and
in the yards and industrial property, as well .as along the streets and boulevards of the
surrounding neighborhood. Contaminant levels are highest within the waste piles and open areas
of the Site. Neighborhood soil concentrations are much lower because cleanup operations were
conducted employing a 10 ppm PCB action level. As a result, the majority of post-excavation
PCB concentrations found in the yards and industrial property of the neighborhood are less than
1 ppm.
Pica (the desire to eat unnatural foods, especially soil) among small children is a well
documented phenomenon. With the large population of young children in the surrounding
neighborhood, ingestion of contaminated soil must be considered a likely route of exposure. The
playing habits and curiosity of these children will likely lead them through and along many of
the yards, industrial properties, streets, and boulevards surrounding the Carter Site. Children
will almost certainly gain access to the Site as well.
Although the Site is surrounded by a barbed-wire topped chain-link cyclone fence and is
guarded, several instances of on-site vandalism have been documented. Holes are periodically
dug under the fence allowing access and ladders are used to climb over the barbed wire. Thus,
despite security provisions maintained by the PRPs at this time, a certain degree of accessibility
to the Site can be expected.
The ingestion intakes of PCBs, arsenic, cadmium, and lead on-site were calculated using both
maximum and representative concentrations (representative of realistic worst case and most
probable case conditions) measured during post-excavation sampling and standard ingestion rates.
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o Dermal exposure to contaminated soils on-site
In contrast to the ingestion of contaminated soils, dermal exposure to contaminated soils is not
expected to be limited to young children but will likely include older children as well as a
portion of the adult population.
The intakes via dermal absorption of PCBs, arsenic, cadmium, and lead on-site were calculated.
These calculations 'were made using both maximum and representative soil concentrations
measured during post-excavation sampling, documented expsure rates (g/day) for adults and
children, and a range of dermal absorption rates.
o Future exposure due to the potential for on-site soils to migrate off-site with run-off and
subsequent direct contact, ingestion and/or inhalation
The extent of future re-contamination of neighborhod soils by the transport off-site of highly
contaminated on-site soil, and to the extent poosible, the resultant off-site soil concentrations in
determining the extent of dermal exposure were also considered.
Exposed Population
The population exposed to air contaminated by the Carter Site is estimated to be over 20,000.
Within 1/2 mile of the Site are one high school, two grade schools, seven churches, one public
playground and a post office.
Inhalation
Simply by living near the Carter Site, persons could be exposed to contaminants via inhalation.
However, because of the dispersal of volatiles and the settling and dispersal of particulates
generated at the Site, exposure via this scenario is expected to be greatest at. or very near, the
Site. The total number of persons (21,628) in the census tracts around the Site was used as an
estimate of the number of persons exposed to air contaminated by the Carter Site.
Furthermore, it should be noted that persons younger man 5 and older than 64 years are
generally considered to be more sensitive to contaminant exposure than the rest of the
population. This sensitive subpopulation comprises between 22 to 24 percent of the total
population around the Site.
Ingestion
Pica is generally considered to be a characteristic of children between the ages of 1 and 6 only.
Access to the Carter Industrials Site would require mobility, and the children that may
potentially gain access to the Site are likely to be slightly older, less supervised children.
Therefore, the ingestion of contaminated soils on-site was considered to be limited to children
ages 3-6. This subpopulation represents from 3 to 4 percent of the total population in the area.
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Dermal Exposure
The subpopulation exposed via this scenario will primarily include all those children aged 3-6
who could potentially gain access to the Site, as well as older children and young adults between
6 to 19 years of age. Adults may also be dermally exposed to contaminated soils via dusts
generated during work at nearby industrial operations.
Extent of Exposure
The estimated future exposure was calculated based on average (geometric mean) and upper
bound of the 95 percent confidence interval about the mean of post cleanup soil concentrations
of the contaminants of concern.
Assumptions '
The equations presented in Table 14 were used to calculate the exposure doses for the
carcinogenic and noncarcinogenic effects of the contaminants of concern (PCBs, arsenic,
cadmium, and lead) for each exposure scenario. The equations for noncarcinogenic effects
(acute exposure) are designed to give the expected body dose from a 1-day exposure. In
contrast, the equations for carcinogenic effects (chronic exposure) calculate an average daily
dose for a 70- year lifetime.
Equations for noncarcinogenic and carcinogenic effects include several parameters (for example,
concentration, percent absorbed, body weight, and frequency of contact). Values for some of
these parameters (such as body weight - adults, amount of air inhaled, and length of lifetime)
have become standardized and were adopted from the Superfund Public Health Assessment
Manual (U.S. EPA, 1986a). The remaining parameters are less standardized and were
developed to address Site-specific conditions and assumptions. Table 15 presents the parameter
values used for this endangerment assessment. These values are discussed below as they apply
to each exposure scenario.
One of the assumed parameters, percent relative absorption, needs further discussion.
Calculated exposure doses are estimates of the dose administered as opposed to a dose that is
actually absorbed into the body. In addition, the reference doses (RfD) and cancer potency
factors used in the risk characterization are based on an administered dose. However, a
problem arises when the RfD or potency factor based on one route of exposure (e.g., ingestion),
is used for another route of concern (e.g., inhalation). To evaluate the risks associated with
such an exposure, the differences in absorption rates between the two exposure mechanisms must
be considered.
First, chemical and route specific risk factors were identified. Where such factors existed (for
example, a carcinogenic potency factor has been established to evaluate exposure to PCBs via
ingestion), the assumption was made that the percent of administered dose absorbed in humans
14
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is the same as in the test animals. This assumption is represented by the use of 100% relative
absorption.
Second, for routes where such risk factors do not exist (for example, a carcinogenic potency
factor has not yet been established to evaluate exposure to PCBs via inhalation, though PCBs
are considered a B2 carcinogen via this route), exposure to contaminants is evaluated using
standards established for ingestion. In these instances the ratio between the percent absorption
for the route of concern and the percent absorption via ingestion was calculated. These ratios
are reported in Table 15 as the percent relative absorption. Calculated exposure doses were
multiplied by the percent relative absorption to obtain the relative administered dose; these doses
were then used in the risk characterization equations.
of oaninated
This scenario involves two subscenarios: (1) the inhalation of compounds volatilizing from the
Carter Industrials Site (PCBs only) and (2) the inhalation of participates to which contaminants
(PCBs, arsenic, cadmium, and lead) have adsorbed. The parameters discussed below apply to
both subscenarios. Following the discussion of the scenario-specific parameters, we discuss the
role of the cover that has been placed over areas of the Carter Industrials Site.
As stated above, the values of 1.75 mVhour and 1.1 mVhour for off-site, and 1.75 nrVhour and
1.95 mVhour for on-site, represent standard measures of the volume of air inhaled by a child
and an adult (U.S. EPA, 1988b). It should be noted that the off-site value for adults was
calculated based on the following activity level percentages: 93.2 percent light/resting activity,
5.8 percent moderate activity, and 0.9 percent heavy activity. On the other hand, the off-site
value for children is an average of the values for light and moderate activity because an activity
level breakdown similar to that for adults was not available. Likewise, the use of 70 kg to
represent the weight of an average adult (in this and the other scenarios) was also based on the
Superfund Public Health Evaluation Manual (SPHEM) (U.S. EPA, 1986a). In contrast to the
value of the 10 kg presented in the SPHEM as the average weight of a child, calculations in this
report (all scenarios) involving the exposure of children were based on an average weight of
20 kg. This higher value was selected because of conditions at the Site which would tend to
preclude persons under 3 years of age from gaining access to the Carter Industrials Site. By
eliminating younger, smaller children, we thought that 20 kg would better represent the average
weight of those children who might gain entrance to the Site and for whom exposure doses
would be calculated.
The relative percent (%) absorption for PCB was calculated based on values presented in the
literature. These values are: inhalation - 50% (U.S. EPA, 1986b) and ingestion - 30 % (U.S.
EPA, 1986b). We selected the highest values judged to be well documented to ensure a
conservative approach. Therefore, the relative percent absorption was calculated as 50/30 =
167%.
When considering inhalation exposure, it is usual to simplify the situation as if the contamination
15
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were gaseous and that all (or most) of an inhaled gas is absorbed. Gas molecules would be
inhaled as part of the ambient air and absorbed through the alveolar wall into the bloodstream.
However, with participates such as dusts (solid particles broken loose from a solid object, such .
as the mounds or open areas at the Carter Site), the situation is actually much more complicated,
as discussed in standard references, such as Dinman (1978) and Menzel and Amdur (1986).
The respiratory tract can be divided into three regions:
o The nasopharyngeal region (nose, throat, and nearby areas)
o The tracheobronchial region (the airways from the throat into the lungs)
o The alveolar region (the tiny sacs within the lung where physiological gas exchange takes
place)
Most particles over 15 urn in size are deposited in the nasopharyngeal region and are removed
by blowing and sneezing. Medium-sized particles, those about 1 to 5 um, are deposited in the
tracheobronchial region, and many are subsequently swept by ciliated cells towards the glottis,
where they are swallowed (and therefore ingested) if they were not previously coughed or
sneezed out. The smallest particles are deposited in the alveolar region where they may diffuse
through the alveolar walls.
Particles, deposited within the respiratory system may be scavenged by macrophages (part of
the body's defense system), ingested as if given by mouth, or absorbed into the bloodstream.
Because information was not available on the probable size of dust particles generated from the
Carter Industrials Site (see Appendix C of the risk assessment for a more complete discussion),
the fate (including extent of absorption) of such particles when inhaled is uncertain.
Considering the lack of specific information, the absorption values selected from the literature
for the contaminants of concern for the inhalation of both volatiles and particulates were used,
even though these values were based largely on the experimental inhalation of gases, vapors,
and smokes, and not particulates specifically.
The frequency of contact for on-site exposures was set at 6 days per year for all scenarios.
This frequency was selected primarily because of the relative security of the Carter Industrials
Site. As described in Chapter 1, the Site is surrounded by a chain-link cyclone fence and the
gate is kept locked. Though a number of instances of unwarranted entry and vandalism have
been documented (Ballotti, 1987 and Weston, 1986), unwarranted entry to the Site by the
general population is expected to be minimal. The frequency of off-site inhalation exposures
was set at 274 days per year, based on EPA guidance (U.S. EPA, 1988b). This document
concluded that it is reasonable to assume that persons would be exposed to contaminants in the
ambient air of their neighborhood for 75 percent of each year.
Finally, the years of exposure for this scenario (based on an expected lifetime of 70 years
(U.S. EPA, 1986b) were set at 67 for on-site exposures at the Carter Industrials Site. This
16
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figure is based on the assumption stated earlier that persons less than 3 years of age would not
be able to gain entry to the Site. The assumption of 70 years exposure was made for off-site
exposure.
Ingestion of Contaminated Soils
The Office of Health Effects Assessment (OHEA) document (U.S. EPA, 1986b) describes the
ingestion of soils as occurring predominantly in children ages 1 to 6. Some of this ingestion will
be incidental (playing or eating with dirty hands), while some will involve children with pica
(the desire to eat unnatural foods, especially soil).
The report by Lepow (1975) discussed in the OHEA document (U.S. EPA, 1986b), describes
the study of 10 2- to 6-year-old children in an investigation of excessive lead accumulation.
The study reported that the total average soil ingestion for a 2-year old child is 0.6 g/day. In
contrast, a study by Kimbrough and others (1986) for the Centers for Disease Control presented
as estimation of the average soil ingestion rate for various age groups of children between 0 and
5 years. The average soil ingestion rate for children 3.S to S years of age was described as
1 g/day, while the rate for a child of 5 was 0.1 g/day. Based on a review of these reports
(as described in U.S. EPA, 1986b) and the assumption that only children age 4 through 6 would
both gain entry to the Carter Site and ingest on-site soils, we chose the value of 0.1 g/day as
an average or "most-probable" ingestion rate. On the other end of the spectrum, the value of
3.0 g/day was selected to represent children with pica behavior (realistic worst case), based on
a similar use of this same value in the OHEA documents (U.S. EPA, 1986b).
As described above, the frequency of contact for on-site ingestion exposure was set at 6 days
per year. Also, exposure to soil on industrial property in the area was set at 10 days/year based
on the expected security and relative inaccessibility of these properties.
The OHEA document (U.S. EPA, 1986b) reports that children most likely to ingest soils are
between 1 and 6 years of age. Therefore, we selected 3 years (from age 3 to age 6) as the
number of years a child could be exposed to ingestion of on-site and industrial property and off-
Site soils. This figure is based on the assumption that persons under the age of 3 would not
gain entry to these properties.
Direct Contact With Contaminated Soils
The values for the average amount of the soil contacted by a child and an adult, 1.0 g/day and
6.4 g/day, respectively, were chosen based on their use in the Kimbrough and others (1984) and
U.S. EPA (1986b) reports and the Hawley (1985) report, respectively.
Because of the general lack of numerical estimates for the extent of absorption via direct
contact, the relative percent absorption was calculated using 1 percent absorption for metals and
0.1 and 5 percent absorption for PCBs (Lee, 1988). The relative absorption factors and
associated calculations are presented in Table 15.
17
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For purposes of the risk assessment, it was assumed that the the ground cover placed over the
on-site mounds wall not effectively limit contaminant migration or limit potential ingestion of
mound soils. These assumptions are based on the potential difficulties in maintaining a ground
cover at the Site, which has proven to be difficult, especially over Waste Pile #2 which contains
the most highly contaminated soil.
Exposure Dose Calculations
Using the equations presented in Table 14 and the assumptions discussed above, the body dose
levels (ug/kg/day) for the noncarcinogenic effects and average daily lifetime doses for the
carcinogenic effects of the four contaminants of concern for each of the exposure scenarios were
calculated. These calculations are presented in Chapter 3 of the Risk Assessment.
Risk Characterization
The purpose of this section is to quantify the potential risks associated with contaminants at or
released from the Carter Industrials Site. The potential risks associated with each of the
exposure scenarios evaluated for this Site are discussed. Quantitative risk assessments are
performed throughout.
Inhalation of Contaminated Air
Exposure via this scenario can occur through inhalation of contaminated particulates or
volatilized contaminants. In characterizing the risk posed to human health under this scenario,
the risk assessment evaluated the noncarcinogenic as well as carcinogenic risks posed by (1)
inhalation of contaminated particulates at the Carter Industrials Site and (2) inhalation of volatiles
both at the Site and downwind of the Site.
To determine the noncarcinogenic risk, the risk assessment calculated the hazard index (HI) for
each noncarcinogen. The HI is the ratio between the estimated exposure dose for each
contaminant and the acceptable exposure level for that same contaminant.
HI= Estimated Exposure Dose
Acceptable Exposure
The acceptable intake - chronic (AIC) was used to represent each contaminants' acceptable
exposure. A ratio greater than unity indicates an unacceptable risk. Since there is currently no
AIC for lead, the His for this exposure route could not be calculated. The only criterion
available from the Center for Disease Control (1985) establishes cleanup values between 500 to
1,000 mg/kg Pb in soils. These data indicate that no noncarcinogenic risk exists for either
children or adults associated with inhalation of contaminated particulates generated at the Carter
Industrials Site.
18
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The risk assessment determined the carcinogenic risk posed by inhalation of contaminated
particulates by calculating the incremental carcinogenic risk associated with the average lifetime
dose of the contaminants of concern for which carcinogenic potency factors for inhalation are
available (arsenic, cadmium, and PCBs). Cancer risks were calculated for both most probable
and realistic worst cases (Table 16). The calculations used the following formula:
Carcinogenic Risk = (carcinogenic potency factor) X (average lifetime dose)
The data in Table 16 show that inhalation of particulates contaminated with PCBs, arsenic, and
cadmium at the Carter Industrials Site does not present a lifetime cancer risk greater than the
U.S. EPA benchmark of 106 cancer risk (1 cancer per 1 million population) for any of these
three contaminants or for the sum of the contaminants for either most probable or worst cases.
To evaluate the risk posed by inhalation (both at the Carter Industrials Site and downwind from
the Site) of volatilized contaminants (PCBs), the risk assessment calculated the cancer risk
associated with an average lifetime dose for both the most probable and realistic worst cases
(Table 17) under four different emission and ground-cover conditions. The calculations were
made using the equation above.
The data in Table 17 indicate that a lifetime cancer risk that exceed 10* (1 cancer per 1 million
population) results from the inhalation of volatile emission in the most probable and realistic
worst cases in the first three exposure conditions: steady-state emissions without cover;
steady-state emissions with cover; and unsteady emissions without cover. In contrast, under
conditions with unsteady emissions with cover, this same risk level (10*) was exceeded only 100
meters downwind of the Site under the realistic worst case.
Ingestion of Contaminated Soils
Children between the ages of 1 and 5 are assumed to consume a certain amount of soil, ranging
from incidental ingestion to pica behavior (U.S, EPA, 1986b), in the neighborhood surrounding
the Carter Industrials Site. It is further assumed that children between the ages of 3 and 6 may
ingest soils at the Site or at nearby industrial properties. To fully evaluate the risks posed by
this scenario, the risk assessment calculated the noncarcinogenic and carcinogenic risks
associated with the ingestion of contaminated soils both at the Carter Industrials Site and in the
surrounding neighborhood.
The risk assessment first calculated the noncarcinogenic risk associated with ingestion of soils
at the Carter Industrials Site. This was accomplished by comparing the estimated contaminant
(cadmium) exposure doses to its acceptable doses (AICs). The results (Table 18) show
unacceptable non-carcinogenic risks for pica ingestion of cadmium in the most probable and
realistic worst cases.
The cancer risk posed by exposure to an average lifetime contaminant dose via ingestion of
contaminated soils at the Carter Industrials Site was calculated for both most probable and
19
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realistic worst cases (Table 19). Calculations made for the contaminants of concern for unit
cancer risks for ingestion are available. The calculations used the equation above and were
based on average lifetime doses.
The data in Table 19 indicate that a lifetime cancer risk of greater than 10"6 (1 cancer per 1
million population) did not result from ingestion (both incidental ingestion and pica behavior)
of arsenic under either most probable or worst cases. In contrast, a lifetime cancer risk of
greater than 10"* resulted in the most probable case from ingestion (pica behavior only) of soils
contaminated with PCBs in the on-site waste piles, and in the realistic worst case from ingestion
of soils in both the waste piles and open surface areas of the Carter Industrials Site.
Finally, the risk assessment calculated the cancer risk posed by exposure to an average lifetime
dose (PCBs) via ingestion of contaminated soils in the industrial property surrounding the Carter
Industrials Site. This calculation includes both most probable and realistic worst cases (Table
20).
The data in Table 20 indicate that a lifetime cancer risk greater than 10"6 was found in both the
most probable or realistic worst case exposure.
Direct Contact With Contaminated Soil
In the risk assessment, it was assumed that children and adults will come into direct contact with
contaminated soils both at the Carter Industrials Site and in the surrounding industrial property.
To fully evaluate the risk posed by this scenario, the risk assessment calculated the
noncarcinogenic and carcinogenic risks associated with direct contact with contaminated soils
both at the Site and in the surrounding industrial property.
The risk assessment first calculated the noncarcinogenic risk associated with direct contact with
soils at the Carter Industrials Site. As described above, this was done by comparing the
estimated contaminant (cadmium) dose to its acceptable doses (AICs). The results (Table 21 for
children and Table 22 for adults) indicate no unacceptable non-carcinogenic risks for direct
contact with lead-contaminated soils (both children and adults) in both the most probable and
realistic worst cases.
The cancer risk posed by exposure to an average lifetime contaminant exposure dose via direct
contact with contaminated soils at the Carter Industrials Site was calculated for both most
probable and realistic worst cases (Table 23). Calculations were made for the contaminants of
concern for which carcinogenic potency factors for ingestion were available. Carcinogenic
potency factors for dermal contact are not available for the contaminants of concern. It was
determined that considering compounds that are carcinogens via ingestion to be carcinogenic via
direct contact also was an acceptable conservative approach.
The data in Table 23 indicate that, in the most probable case and realistic worst case, a lifetime
cancer risk of greater than 10"6 will result from direct contact with PCB contaminated soils in
20
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the waste piles and open areas of the Carter Industrials Site, using 17 percent relative absorption
factor. Using a relative absorbtion factor of 0.3 percent, the lifetime cancer risk of 10"* is
exceeded only under the realistic worst case at the waste piles.
Finally, the risk assessment calculated the cancer risk posed by exposure to a lifetime average
PCB exposure dose via direct contact with contaminated soils in the industrial properties
surrounding the Carter Industrials Site for both most probable and worst cases (Table 24). The
calculations used Equation 5-2 and were based on average lifetime doses. The data in Table 24
indicate that a lifetime cancer risk of greater than 10* resulted in the most probable case and in
realistic worst case from direct contact with industrial property soils (17 percent relative
absorption factor).
Future Exposure due to the potential for off-site migration
Exposure doses calculated for contact with contaminated soils in the neighborhood surrounding
the Carter Industrials Site were based on levels of contamination remaining in these soils after
EPA completed its emergency response actions. These contaminant levels may increase in the
future. The neighborhood may become recontaminated by runoff of contaminated soils from
the Site and by the generation of and dispersal of contaminated particulates.
At present, the Carter Industrials Site is equipped with a runoff control system. This system is
expected to limit the extent of runoff from the Site. However, if this system rails (for example,
if submersible pumps break down or if the interception trenches Mil and subsequently overflow),
potentially contaminated runoffcould be released into the surrounding neighborhood.
One of the potential off-site migration pathways for PCBs is future soil runoff from the Carter
Industrials Site. The amounts of soil and PCBs that could potentially migrate from the Site (via
runoff) are calculated in Appendix D of the risk assessment. If contaminated soils do run off
the Site into the surrounding neighborhood, persons in the neighborhood who contact these soils
may receive increased (as compared with the levels described above) exposure to PCBs as well
as to arsenic, cadmium, and lead, and other contaminants identified in Tables 2, 3 and 4.
The resulting potential carcinogenic risk due to the potential for direct contact with and ingestion
of dust and surface sediments contaminated with PCBs ranges from 3E-06 to 1E-04.
The Endangerment Assessment did not address an exposure or potential exposure to
contaminated sewer sediments, but sampling by the Michigan DNR and the City of Detroit,
revealed high concentrations (4,900 mg/kg) of PCBs in sewer line sediments adjacent to the
Carter Site. As a cautionary measure against future releases from the contaminated sewer lines
to the Detroit River, the contaminated sewer line will be addressed as the final operable unit for
the Site.
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Assumptions Concerning Future Land Use
As noted above, the Carter Site is located in an area of Detroit characterized by both industrial
and residential land use, with a residential population of approximately 21,000. U.S. EPA
assumes that this mixed land use will continue, such that residents will continue to live close to
the Carter Site. U.S. EPA concludes, therefore, that without some son of remediation, residents
could be exposed to contaminants via all of the pathways identified in the Endangerment
Assessment.
SUMMARY OF GREATEST RISKS AT CARTER SITE
Inhalation The increased cancer risk from inhalation of PCBs ranges from
3E-11 to 4E-03. The most significant carcinogenic risk is on-
site (4E-02); at 100 meters downwind it is calculated at 4E-03;
at 1000 meters downwind it is 2E-OS.
Ingestion The increased cancer risk from ingestion of on-site soils from
IE-OS to 3E-06 is from pica behavior only. The non-
carcinogenic effects may have hazard indices up to 52 for
ingestion of on-site soils containing lead.
Dermal The risk from direct contact with PCBs in soils on-site from 1E-
08 to 4E-05, and this does not even consider the potential for
direct contact with the contaminated buildings on-site. The
Hazard Indices calculated were as high as 3.54 for direct
contact with lead contaminated soils on-site.
Table 25 shows a summary of all risks which were calculated for all exposure scenarios at the
Carter Industrials Site.
VII. REMEDIAL ACTION OBJECTIVES
If not addressed by implementing the response action selected in this ROD, actual or threatened
releases of hazardous substances from the Site may present an imminent and substantial
endangerment to public health, welfare, or the environment.
Action Level
U.S. EPA has chosen an action level for PCBs at the Carter Site of 1 milligram per kilogram
(mg/kg). U.S. EPA's "Guidance on Remedial Actions for Superfund Sites with PCB
Contamination" (OSWER Directive No. 9355.4-01, August 1990, p. 27) recommends 1 mg/kg
PCBs as the action level for areas characterized by residential land use. It recommends 10 to
22
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25 mg/kg PCBs as the action level for areas characterized by industrial land use. The Carter
Site is characterized by both industrial and residential land use. However, because the industrial
area is so close to residences, U.S. EPA maintains that, for purposes of choosing action and
cleanup levels, it is appropriate to treat the entire Site as if it were a residential area. U.S.
EPA's PCB Spill Policy (40 CFR 761.123) supports this decision. Under the Spill Policy,
restricted access locations, including industrial facilities, are considered residential/commercial
areas if they are located . 1 km or less from a residential area (0.1 km = 326 feet). While the
Carter Site is currently fenced, restricting public access, persons have broken into the Site as
recently as June 30, 1991, despite the presence of guards on the Site, and piles of contaminated
soil and debris lie only 20 feet from residential property.
Cleanup Level - PCBs
U.S. EPA has set the cleanup level for PCBs at the Carter Site to be 1 mg/kg in soils and
demolition debris. U.S. EPA's Guidance on Remedial Actions for Superfund Sites with PCB
Contamination recommends reducing PCB levels to 1 mg/kg PCBs in residential areas or
limiting exposure to concentrations above 1 mg/kg PCBs. The results of the Endangerment
Assessment conducted by U.S. EPA in January 1989, supports using this level, as discussed
below.
The Endangerment Assessment results were calculated using realistic worst case (RWC)
assumptions. These RWC risk numbers used an average concentration of 77.4 mg/kg for PCBs.
The values for carcinogenic risk obtained for inhalation, ingestion and direct contact pathways
were (4 in 100), (2 in 100,000) and (1 in 10,000) respectively.
The concentration of PCBs in the soil used for the Most Probable Case (MPC) scenarios was
4.3 mg/kg. Using this value for the concentration of PCBs resulted in MPC risks for inhalation,
ingestion and direct contact pathways of (7 in 1000), (1 in 10,000) and (3 in 100,000)
respectively.
The U.S. EPA's Guidance on Remedial Actions for Superfund Sites with PCB Contamination
presents a generic calculation of carcinogenic risk posed by PCBs at a concentration of 1 mg/kg.
Using this value for the concentration of PCBs results in risks for inhalation, ingestion and direct
contact pathways of (7 in 1,000,000), (2 in 1,000,000) and (7 in 1,000,000) respectively.
For an average value of PCBs of 77.4 mg/kg, an estimated total risk is 4 in 100. For an
average value of PCBs of 4.3 mg/kg, an estimated total risk is 7 in 1,000. For a cleanup level
of 1 mg/kg PCB, an estimated total risk is 1.6 in 100,000 - which falls within the EPA's range
of what is considered to be an acceptable risk ~ between 1 in 10,000 to 1 in 1,000,000.
Therefore, 1 mg/kg PCB was chosen as the cleanup level for the Carter Site.
Cleanup Levels for Other Contaminants
The following cleanup levels for other contaminants detected at the Site have been selected by
23
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U.S. EPA to be protective of human health and the environment in the vicinity of the Carter
Site. They also meet Michigan's Type B cleanup criteria under Act 307:
' . ' ? ',"-'/'*• ' '"
' '
s - 5 , *sr>; ,
,'
'•• .... ,,',- .. ; .... .... , s.*f"j-'J''........ '^
CONTAMINANT '; -
•• ,••' '••.,"',, ' , \
5 , - ,"", „ f \
1 ,3-dichlorobenzene
1 ,4-dichlorobenzene
Xylene
Chlorobenzene
Benzo(a)anthracene
Pyrene
1 ,2,4-trichlorobenzene
pentachlorobenzene
tetrachlorobenzene
Lead
Cadmium
Arsenic
1 ethyl 2methylbenzene
:-
s
Ground
VF&ttsfn ":
Cleaaup
&SV&/,',
- ^?b) "'
'-'f k- /
600
1
300
100
.003
200
9
6
2
5
4
0.02
MDL
Sofl Cteamip
" '-i l4V6t/, ''""
, Eequired ta ..
. %" % ^^Ep^^^j^ / <^
1 '''firwwf ?'
-7 •'*•*' %V '"
y?«^iis^M> .v
; Basis for Cle^iaup
'A - U „, iaepdk - =•- >-'
^ -s-^i^^^W'^r^
Oral Reference Dose
1 x 10-* Cancer Risk
Odor Threshold
Oral Reference Dose
1 x 10* Cancer Risk
Oral Reference Dose
Oral Reference Dose
Oral Reference Dose
Oral Reference Dose
Oral Reference Dose
Oral Reference Dose
1 x 10* Cancer Risk
The cleanup levels for soils which have been chosen for the Site are those shown in the column
labelled "Soil Cleanup Level required to protect groundwater".
The specific methodology used to calculate cleanup levels is based on Michigan's R299.5709.
The column entitled "Ground Water Cleanup Level" is included on this table because it is from
these levels that the value to be applied to soil is derived. To obtain the cleanup level for soils
which is protective of groundwater, the Ground Water Cleanup Level value is multiplied by 20
in order to estimate the value in soil which could leach into groundwater. Site specific leach
tests may be used to determine if a higher cleanup level in soils would not result in leachate
containing levels of contaminants over the "Ground Water Cleanup Level". However, in no
case can the cleanup level be set above that shown in the column entitled "Soil Cleanup Level
Based on Direct Contact".
Sampling may be performed for the following contaminants to establish background
concentrations reflecting representative concentrations existing in the environment at or
regionally proximate to the Site that are not attributable to any release at the Site: Lead,
24
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Cadmium, Arsenic, and 1 ethyl 2 methyl benzene.
In some cases, the cleanup levels derived for certain compounds are below that which can be
detected accurately in the laboratory. This is the case for two compounds on the table above.
The cleanup level set for benzo(a)anthracene is 100 ug/kg. However, the MDNR's acceptable
Method Detection Limit (MDL) is 330 ug/kg. Therefore, a cleanup level of 330 ug/kg may be
used for benzo(a)anthracene rather than the level which is based on carcinogenic risk.
The cleanup level for arsenic of 0.4 ug/kg is below the MDNR acceptable Method Detection
Limit of 50 ug/kg. Therefore, the cleanup level of 50 ug/kg may be used for arsenic rather than
the level which is based on carcinogenic risk.
DEVELOPMENT OF REMEDIAL ACTION ALTERNATIVES
During the Feasibility Study (FS), U.S. EPA identified and evaluated a number of alternatives
that could be used to address the threats and/or potential threats identified at the Site. U.S. EPA
proceeded by building upon an Engineering Evaluation/Cost Analysis (EE/CA), performed for
the Agency in 1986. The EE/CA analyzed and compared six different methods of addressing
the contaminants at the Site. In general, the EE/CA assumed that Site contamination would be
addressed via a single technology rather than a combination of technologies. The Feasibility
Study Report went beyond the EE/CA in that it evaluated some additional technologies and it
formulated a number of "hybrid" alternatives which combined remedial technologies.
The rationale for combining technologies was based on both technical and legal considerations.
On the technical side, it was clear that it would not always be feasible to treat large pieces of
contaminated debris in the same manner as contaminated soil. On the legal side, it was apparent
that the regulatory requirements governing treatment and disposal differ, depending on the nature
and the degree of contamination in question. These concerns are discussed in more detail below.
The following is a brief description of the alternatives evaluated. Additional information is
provided in the EE/CA and to the FS Report, both of which are part of the Administrative
Record for this Record of Decision.
All alternatives except the no action alternative will comply with the Land Disposal Restrictions
(LDRs) through a Treatability Variance under 40 CFR 268.44. This variance will require the
use of best management practices to decontaminate EP or TCLP toxic debris at the Site and
reduction in the levels of PCBs, cadmium, arsenic and lead in the soils.
Alternative #1: No Action
In conducting feasibility studies at Superfund Sites, U.S. EPA evaluates a no-action alternative
as required by the NCP. An analysis of the consequences of taking no further action provides
25
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a baseline for comparison with other alternatives. At the Carter Site, the no- action alternative
would consist solely of continued operation and maintenance of the Site stabilization measures
already in place, e.g., the fence surrounding the Site, and the vegetation covering the waste
piles. No other action would be taken. Because of the potential for these stabilization measures
to break down despite periodic maintenance, i.e., for the fence to be breached and for protective
cover to erode, residents living in the vicinity could be exposed to hazardous levels of PCBs and
toxic metals. Moreover, if no further action were taken, soils contaminated with PCBs at levels
between 1 and 10 mg/kg located off-site would not be addressed. Residents would continue to
face a risk of direct exposure to PCBs from these soils.
Alternative #2: Incineration, On-site
CapftalCost
'.&•*.**:&*" "A
Present Worth
$ 0
16,000
$ 246,000
This alternative calls for heating contaminated materials to high temperatures, thereby destroying
PCBs. Three different methods of incineration were examined: Rotary Kiln, Infrared, and
Circulating Bed Combustion. The rotary kiln incinerator consists of a rotating refractory-lined
cylinder mounted at a slight incline to the horizontal. This unit operates at temperatures from
800 - 1,900 degrees Farenheit. The infrared system thermally oxidizes organic wastes using
electrically powered infrared heating elements which can heat the primary chamber to 1,850
degrees Farenheit. The Circulating Bed Combustor is a fluidized bed incinerator.
For this alternative, it was assumed that incineration would take place on-site. The incinerator
would therefore have to be transported to the Site or assembled there. The table below shows
the differences between the three methods in terms of cost, fabrication time, and processing
time. It was assumed that 38,000 cubic yards (46,000 tons) of contaminated soil would be
incinerated. The incinerator would be required to meet the performance standards listed in 40
CFR 264.343. These standards were designed to ensure that air emissions from incinerators
burning hazardous wastes do not endanger public health or the environment. Since incineration
produces very little reduction in volume, it was assumed that the volume of the ash resulting
from the incineration process would also be about 38,000 cubic yards.
The ash would be tested for hazardous constituents and hazardous characteristics, including
toxicity. An undetermined amount of the residual ash may exhibit the TCLP characteristic for
metals which are unaffected by this treatment. Therefore, residual disposal could range from
$710,000 for disposal in a RCRA Subtitle D landfill to $9.66 million if all of it required disposal
in a RCRA Subtitle C facility. It may also be possible to dispose of the TCLP characteristic
materials in a RCRA Subtitle D facility if the materials were properly stabilized which would
cost more than $710,000 but much less than $9.66 million.
The Operation and Maintenance (O&M) costs shown below and institutional controls would
apply to this alternative if on-site containment of the residual were utilized. The cost and
26
-------
implementation time for the three means of incineration considered in alternative 2 are as
follows:'
Cost in Millions of Dollars
lacinerator
Fabrication
MaiBtG&ftiiGe
,,,,
CapStel
'
Rotary Kiln
6-9
450
23.878
.71-9.66
40.754-
55.599
40.864-
55.599
Infrared
6-8
511
14.178
.71-9.66
24.918-
39.763
25.030-
39.763
Circulating
Bed
815
7.032
.71-9.66
12.996-
27.841
13.107-
27.841
$12,600 (On-site Cap) to $15,600 (On-site Landfill)
$ 6,900 (On-site Cap) to $ 9,900 (On-site Landfill)
$ 13,107,000 to $ 55,599,000
Alternative #3: In-Situ Vitrification
Like incineration, in-situ vitrification ("ISV") destroys PCBs by exposing them to high
temperatures. This is achieved by passing an electric current through the ground. At the Carter
Site, ISV would involve the insertion of four electrodes into the contaminated soil in a square
array. The square would measure approximately 20 feet per side, with electrodes placed to a
depth of approximately 15 feet. The process works as follows: a path for electric current is
established by placing a small amount of a graphite and glass frit mixture on the surface soil
between the electrodes. Running a current through this material creates temperatures high
enough (up to 2000° F) to melt a layer of soil. This molten zone continues to expand downward
encompassing the contaminated soil.
As the molten or vitrified zone expands, nonvolatile hazardous elements, such as heavy metals,
are incorporated into the vitrified mass while organic compounds are destroyed. Byproducts
migrate to the surface of the vitrified zone where they bum off. A hood placed over the vitrified
area directs the gases produced by the process to an off-gas treatment system. In order to
protect human health and the environment, air emissions from the system would have to meet
the same standards as those from incineration (See alternative 2, above). The remaining ash and
27
-------
other noncombustible material dissolve or become encapsulated in the molten soil. Natural
convective currents within the molten soil tend to produce a uniform mass. The molten soil
cools to a durable glass and crystalline waste form resembling natural obsidian. The information
available regarding this technology suggests that it would be possible to achieve the 1 mg/kg
cleanup level using this type of technology.
For this alternative, we assumed roughly 46,000 cubic yards of material would have to be
treated. Since only one 20 by 20 foot cell would be treated at any one time, the ISV process
would have to be repeated in order to treat all of this contaminated material.
Doretkux
Capital Cost
O&MCost
Present Worth
739 days
$ 23,461,000
0
$ 23,461,000
Alternative #4: Pozzolonic Solidification
This alternative calls for solidification of most of the contaminated materials at the Carter Site.
Pozzolonic solidification involves the use of a silicate-based material together with lime,
gypsum, or other suitable setting agent. The process depends upon the reaction of lime with fine
grained siliceous material and water to produce a hardened material known as pozzolonic
concrete. The process has been used to stabilize a wide range of materials, including metals,
waste oil, solvents, and PCBs. Organic wastes do not chemically react with the additives.
Instead, they are encapsulated within the solidified mass, significantly reducing their ability to
leach. However, at the outset of the process, some organic compounds present in the treated
material, including PCBs, may volatilize. To minimize this, measures would be taken such as
using foam dust suppressants or wind screens.
Implementation of this alternative at the Carter Site would require the separation of some of the
metal and debris from contaminated soil, since these materials may interfere with the
solidification process. Segregated debris and metal which is also contaminated at over SO mg/kg
with PCBs would be taken to an off-site TSCA landfill. The contaminated soil remaining would
be treated on-site by pozzolonic solidification.
Once solidification process was complete, the Site would be capped with a multilayer cap similar
to the one described under alternative #6. This process would have to take place in-situ or the
Land Disposal Restrictions would be triggered for the EP or TCLP Toxic soils which contained
28
-------
over 1000 mg/kg of PCBs. If the LDRs were triggered, incineration of 6,160 cubic yards of
the material would be required. This would increase the cost of this alternative such that it
would no longer be economically attractive.
Duration
Cauital C&SL
*•
O &M Cost (Year 1)
. (y«ars^30> ,
Present Worth
60 days
$ 4,483,141
22,000
16,000
$ 4,734,141
Alternative #5: On-site RCRA Landfill
This alternative calls for disposing of the contaminated soil and debris in an on-site hazardous
waste cell. The cell would be designed to comply with federal and state regulations pertaining
to RCRA hazardous waste and TSCA chemical waste landfills. It would include a double liner,
leachate detection system, and leachate collection system. Contaminated leachate would be
treated.
Duration
Capital Ci»t
O&M€ost{Yearl>
270 days
$ 3,884,000
23,800
18,100
$ 4,167,000
Alternative #6: On-site Cap
This alternative calls for construction of a multi-layer cap over the contaminated material at the
Carter Site. The objective here would be to minimize contact between the covered wastes and
infiltrating surface water. The cap would be designed to meet the performance standards
promulgated in 40 CFR 264.310. It would consist of a low permeability layer covered by a
drainage layer, overlain by an upper vegetative layer.
Dnration
90 days
$ 1,605,000
22,000
16,000
$ 1,856,000
29
-------
Alternative #7: Off-site TSCA Landfill
This alternative involves the disposal of contaminated soil and debris in an off-site TSCA-
permitted hazardous waste landfill. For costing purposes, it was assumed that all the material
removed from the Carter Site would be transported to the TSCA landfill located in Emelle,
Alabama. This alternative may trigger LDRs if the 6,160 cubic yards of material which contain
over 1000 mg/kg of PCBs are also EP or TCLP toxic.
Duration
Capital Cost
O&MCost
' f
-------
(3) Soils and debris with PCB concentrations between 10 and 50 mg/kg were put in a category
where 50 mg/kg represents the level above which TSCA disposal restrictions are triggered, while
10 mg/kg is the cleanup level set by the TSCA Spill Policy for contaminated soil in residential
areas. (See 40 CFR 761.125(c)(4)).
(4) Soils and debris with PCB concentrations between 1 and 10 mg/kg were put in a category
where 1 mg/kg represents the cleanup level recommended by U.S. EPA's "Guidance on
Remedial Actions for Superfund Sites with PCB Contamination" - and supported by the baseline
risk assessment for the Carter Site.
(5) There are no prohibitions on disposal of the soil and debris contaminated with PCBs under
50 mg/kg in a RCRA Subtitle D facility, as long as they do not also exhibit a characteristic
which makes them hazardous under RCRA. However, while developing the cost estimates for
these alternatives, the operators of Subtitle D facilities were reluctant to give any assurances that
they would accept such wastes. Therefore, for costing purposes, it was assumed that the
materials contaminated with PCBs at levels between 10 and 50 mg/kg of PCBs would be
disposed of in a RCRA Subtitle C facility.
(6) If the soils are EP Toxic, they must be treated by stabilization prior to land disposal. The
treatment used must render the soils non-EP toxic. Thereafter, they could be placed in either
a RCRA subtitle C or D facility. However, if the soils are TCLP toxic, but not EP Toxic, they
fall into a category called "newly identified wastes" and they may be land disposed into a RCRA
Subtitle C facility without treatment, or treated to remove the characteristic and placed into a
RCRA subtitle D facility.
(7) For debris which is also EP or TCLP toxic, all of the hybrid alternatives will comply with
Land Disposal Restrictions through a Treatability Variance under 40 CFR 268.44.
EPA selected five technologies for assembly into hybrid alternatives: (1) off-site disposal in a
RCRA subtitle D (solid waste) landfill; (2) off-site disposal in a RCRA subtitle C (hazardous
waste) landfill; (3) off-site disposal in a TSCA landfill; (4) off-site incineration; (5) in-situ
vitrification. At the request of the PRP steering committee, EPA added three other technologies
to its analysis: (1) solvent extraction; (2) Critical Fluid (CF) Extraction; and (3) Low
Temperature Thermal Desorption (LTTD).
Each hybrid alternative is presented with a table showing the proposed response to various types
and degrees of contamination. In the column denoting the PCB concentration, the designation
"EP" means that it is assumed the material, besides being contaminated with PCBs, exhibits the
characteristic of EP toxicity. In the column denoting location, "WP" stands for waste pile, "SA"
stands for surface area and "Neighborhood" refers to contaminated soils in the area surrounding
the Carter facility. All locations are shown on Figure 2.
31
-------
Alternative 08 - Off-she TSCA Incinerator, off-site TSCA Landfill, off-site RCRA Landfill
Volume
Cu. Yds.
6160
347
12845
1473
15530
1650
1395
5674
480
Media
Soil
Debris
Soil
Debris
Soil
Debris
Soil
Soil
Debris
PCBin
mg/kg
>1000
>1000
50-1000
50-1000
10-50
10-50
1-10&EP
1-10
1-10
Location
WP1A, WP2A, SA5
WP1A, WP2A
WP1B, WP2B, WP3, SA4
WP1B, WP2B, WP3
WP1C, WP4, WP5, SA1&2
WP1C, WP4, WPS
WP1D
WP6&7.SA3 NHGHBORHOOD
WP6, WP7
Technology Type
TSCA Incinerator
TSCA landfill
TSCA landfill
TSCA landfill
RCRA "C" landfill
RCRA "C" landfill
RCRA "C" landfill
RCRA "D" landfill
RCRA "D" landfill
In this alternative, soil containing PCB concentrations greater than 1,000 mg/kg would be treated
in an off-site incinerator. Soil with PCB concentrations of 50 - 1,000 mg/kg and debris with
PCB concentrations of 50 mg/kg or more would be disposed of in an off-site TSCA landfill.
Soil and debris with PCB contamination in the 10 - 50 mg/kg range, together with EP toxic soil
with PCB contamination in the 1 - 10 mg/kg range, would be placed in an off-site RCRA
Subtitle C landfill. Non-EP toxic soil and debris with PCB contamination in the 1 - 10 mg/kg
range would be placed in an off-site RCRA Subtitle D landfill.
&MCttst
Present Worth
10 months
$ 50,308,000
0
$ 50,308,000
Alternative #9 - In-Situ Vitrification and off-site RCRA Landfill
Location
WP1A, WP2A, SA5
WP1A, WP2A
WP1B, WP2B, WP3, SA4
WP1B, WP2B, WP3
WP1C, WP4, WP5,SA1&2
WP1C, WP4, WPS
WP1D
WP6&7,SA3,NEIGHBORHOOD
WP6, WP7
Volume
Cu. Yds.
6160
347
12845
1473
15530
1650
1395
5674
480
Media
Soil
Debris
Soil
Debris
Soil
Debris
Soil
Soil
Debris
PCBin
mg/kg
>1000
>1000
50-1000
50-1000
10-50
10-50
1-10&EP
1-10
1-10
Technology Type
In-Situ Vitrify
In-Situ Vitrify
In-Situ Vitrify
In-Situ Vitrify
RCRA "C" landfill
RCRA "C" landfill
In-Situ Vitrify
RCRA "D" landfill
RCRA "D" landfill
In this alternative, soil and debris contaminated with PCBs over SO mg/kg and EP toxic soil with
1-10 mg/kg PCBs would be treated on-site using in-situ vitrification. Soil and debris
32
-------
contaminated with PCBs from 10-50 mg/kg would be placed in an off-site RCRA Subtitle C
landfill or in a Subtitle D facility if one could be located which is willing to accept these
materials. Non-EP toxic soil and debris contaminated with 1-10 mg/kg PCBs would be placed
in an off-site RCRA Subtitle D landfill.
i Duration - - ••
Capita! Cost
O & M Cost
Present Worth
15 months
$ 20,544,000
0
$ 20,544,000
Alternative #10 - Off-site TSCA Incinerator.
Landfill
Volume
Cu. Yds.
6160
347
12845
1473
15530
1650
1395
5674
480
Media
Soil
Debris
Soil
Debris
Soil
Debris
Soil
Soil
Debris
PCBin
mg/kg
>1000
>1000
50-1000
50-1000
10-50
10-50
1-10&EP
1-10
1-10
Location
WP1A, WP2A, SA5
WP1A, WP2A
WP1B, WP2B, WP3, SA4
WP1B, WP2B, WP3
WP1C, WP4, WP5.SA1&2
WP1C, WP4, WPS
WP1D
WP6&7.SA3.NEIGHBORHOOD
WP6, WP7
Technology Type
TSCA Incinerator
TSCA landfill
TSCA Incinerator
TSCA landfill
RCRA "C" landfill
RCRA "C" landfill
RCRA "C" landfill
RCRA "D" landfill
RCRA "D" landfill
In this alternative, all soils contaminated with PCBs over 50 mg/kg would be treated in an off-
site incinerator. Debris contaminated with PCBs over 50 mg/kg would be placed in an off-site
TSCA landfill. Soil and debris contaminated with PCBs in the 10 - 50 mg/kg range together
with TCLP toxic soil with 1-10 mg/kg PCBs would be placed in an off-site RCRA Subtitle C
landfill or a Subtitle D facility if one can be found which is willing to accept the PCB-
contaminated soil between 10 and 50 mg/kg and properly stabilized EP toxic material between
1 and 10 mg/kg. Non-EP toxic soil and debris contaminated with 1-10 mg/kg PCBs would be
placed in an off-site RCRA Subtitle D landfill.
"'"*'' v ^"i-*" ""
'Ol&afrCosr--*'
O&MCost
Present Worth
10 months
$100,718,000
0
$100,718,000
33
-------
Alternative #11 - Off-site TSCA Incinerator, off-site TSCA
Landfill
Location
WP1A, WP2A, SA5
WP1A, WP2A
WP1B, WP2B, WP3, SA4
WP1B, WP2B, WPS
WP1C, WP4, WPS, SA1&2
WP1C, WP4, WPS
WP1D
WP6&7,SA3,NEIGHBORHOOD
WP6, WP7
Volume
Cu. Yds.
6160
347
12845
1473
15530
1650
1395
5674
480
Media
Soil
Debris
Soil
Debris
Soil
Debris
Soil
Soil
Debris
PCB in
mg/kg
>1000
>1000
50-1000
50-1000
10-50
10-50
1-10&EP
1-10
1-10
f-site RCRA
Technology Type
TSCA Incinerator
TSCA landfill
TSCA landfill
TSCA landfill
TSCA landfill
TSCA landfill
RCRA "C" landfill
RCRA "D" landfill
RCRA "D" landfill
In this alternative, all soil containing PCBs over 1,000 mg/kg would be treated in an off-site
incinerator. All soil with PCB concentrations between 10 and 1,000 mg/kg and debris with PCB
concentrations over 10 mg/kg would be placed in an off-site TSCA landfill. EP toxic soil with
PCBs between 1 and 10 mg/kg would be properly stabilized and placed in an approved RCRA
subtitle C or D facility. Non-EP and non-TCLP toxic soil and debris contaminated with 1-10
mg/kg PCBs would be placed in an off-site RCRA Subtitle D landfill.
Capital Cost
Present Worth
10 months
$ 51,797,000
0
$ 51,797,000
Alternative #12 - Critical Fluid fCF) Extraction. Incineration of Residual PCB Oils, off-site
TSCA Landfill, and off-site RCRA Landfill
Volume
Cu. Yds.
6160
347
12845
1473
15530
1650
1395
5674
480
Media
Soil
Debris
Soil
Debris
Soil
Debris
Soil
Soil
Debris
PCB in
mg/kg
>1000
>1000
50-1000
50-1000
10-50
10-50
1-10&EP
1-10
1-10
Location
WP1A, WP2A, SA5
WP1A, WP2A
WP1B, WP2B, WP3, SA4
WP1B, WP2B, WP3
WP1C, WP4, WPS, SA1&2
WP1C, WP4, WPS
WP1D
WP6&7,SA3,NEIGHBORHOOD
WP6, WP7
Technology Type
CF process
TSCA landfill
CF process
TSCA landfill
CF process
RCRA "C" landfill
RCRA "C" landfill
CF process
RCRA "D" landfill
34
-------
In this alternative, all soil contaminated with PCBs at concentrations exceeding 10 mg/kg would
be treated using the CF process. The CF process extracts PCBs by means of passing
compressed propane through a slurried soil mixture to extract the PCBs. The propane and
dissolved PCBs are then passed through a pressure reducing valve to a separator. The PCBs are
then collected along with oil from the separator. Oil recovered from this extraction process
would be treated in an off-site incinerator. Debris contaminated with 50 mg/kg PCBs or greater
would be placed in an off-site TSCA landfill; debris contaminated with 10 - 50 mg/kg PCBs
would be placed in off-site RCRA Subtitle C landfill or a Subtitle D facility if one can be found
which is willing to accept such waste; while debris contaminated with 1 -10 mg/kg PCBs would
be placed in an off-site RCRA Subtitle D landfill. EP toxic soil contaminated with PCBs
between 1 and 10 mg/kg would be stabilized prior to placement in an off-site RCRA Subtitle C
or D landfill. Non-EP toxic soil contaminated with PCBs between 1 and 10 mg/kg would be
treated using the CF system.
Capital Cost
O&MCflst
36 months
$ 49,402,000
$ 49,402,000
Alternative #13 - Solvent Extraction, off-site Incineration of Residual PCS Oils, off-site
TSCA Landfill, and off-site RCRA Landfill
Volume
Cu. Yds.
6160
347
12845
1473
15530
1650
1395
5674
480
Media
Soil
Debris
Soil
Debris
Soil
Debris
Soil
Soil
Debris
PCBin
mg/kg
>1000
>1000
50-1000
50-1000
10-50
10-50
1-10&EP
1-10
1-10
Location
WP1A, WP2A, SA5
WP1A, WP2A
WP1B, WP2B, WP3, SA4
WP1B, WP2B, WPS
WP1C, WP4, WP5, SA1&2
WP1C, WP4, WPS
WP1D
WP6&7,SA3,NEIGHBORHOOD
WP6, WP7
Technology Type
Solvent Extraction
TSCA landfill
Solvent Extraction
TSCA landfill
Solvent Extraction
RCRA "C" landfill
RCRA "C" landfill
Solvent Extraction
RCRA "D" landfill
In this alternative, all soil contaminated with PCBs at concentrations exceeding 10 mg/kg would
be treated using a solvent extraction process. The solvent extraction process extracts PCBs by
using a solvent, sometimes using Triethylamine (TEA). Oil recovered from this extraction
process would be treated in an off-site incinerator. Debris contaminated with 50 mg/kg PCBs
or greater would be placed in an off-site TSCA landfill; debris contaminated with 10 - 50 mg/kg
PCBs would be placed in off-site RCRA Subtitle C landfill or a subtitle D facility if one can be
found which is willing to accept such wastes; while debris contaminated with 1-10 mg/kg PCBs
35
-------
would be placed in an off-site RCRA Subtitle D landfill. EP toxic soil contaminated with PCBs
between 1 and 10 mg/kg would be treated to remove the characteristic of toxicity and placed in
an approved RCRA Subtitle C or D landfill. Non-EP toxic soil contaminated with PCBs
between 1 and 10 mg/kg would be treated using the solvent extraction system.
Iteration
Capital Cost
O&MCost '
Present Worth
12 months
$ 20,542,000
0
$ 20,542,000
Alternative #14 - Low Temperature Thermal Pesorption (LTTD) with. Incineration of
Residual PCB Oils, off-site TSCA Landfill, and off-site RCRA landfill
(NOTE: The description of this alternative appears below as it did in the Proposed Plan and the
Feasibility Study. This was the preferred alternative in the Proposed Plan. Based upon public
comment, it has been modified slightly. The complete description of how it was modified
appears in the Selected Remedy section of this ROD (Section X). The exact components of the
originally preferred alternative which were modified and why they were modified is discussed
in the Explanation of Significant Changes - Section XII - at the end of this ROD.)
Volume
Cu. Yds.
6160
347
12845
1473
15530
1650
1395
5674
480
Media
Soil
Debris
Soil
Debris
Soil
Debris
Soil
Soil
Debris
PCB in
mg/kg
>1000
>1000
50-1000
50-1000
10-50
10-50
1-10&EP
1-10
1-10
Location
WP1A, WP2A, SA5
WP1A, WP2A
WP1B, WP2B, WP3, SA4
WP1B, WP2B, WP3
WP1C, WP4, WPS, SA1&2
WP1C, WP4, WP5
WP1D
WP6&7,SA3,NEIGHBORHOOD
WP6, WP7
Technology Type
LTTD processor
Decon./landfill
LTTD processor
Decon./landfill
LTTD Processor
landfill
landfill
LTTD processor
landfill
In this alternative, all soil contaminated with PCBs at concentrations exceeding 1 mg/kg would
be treated using a Low Temperature Thermal Desorption (LTTD) process. (The modified
remedy provides for treatment of material contaminated with PCBs at levels over 10 mg/kg
rather than 1 mg/kg.) The LTTD system extracts PCBs by using heat to separate the organics
from the soil. The system is composed of two main elements; a dryer and a gas treatment
system. Waste material, which can be either a pumpable sludge or solid, is fed into the dryer
where it is heated to a temperature between 450 to 850 degrees Farenheit. The water and
36
-------
organic materials that are volatilized in the dryer are carried to the gas treatment system. There
the gases are cooled, paniculate material removed and the water and organics are condensed.
The liquid condensates are allowed to density segregate and the organic fractions removed for
incineration or disposal. Debris larger than 2 inches in diameter could not be used in this
process and would have to be disposed of in accordance with TSCA. Therefore, debris
contaminated with 50 mg/kg PCBs or greater would be placed in a TSCA landfill; debris
contaminated with 10 - 50 mg/kg PCBs would be placed in off-site RCRA Subtitle C landfill or
a Subtitle D facility if one can be found which is willing to accept such wastes; while debris
contaminated with 1-10 mg/kg PCBs would be placed in an off-site RCRA Subtitle D landfill.
EP toxic soil would have to be treated to remove the EP toxic characteristic prior to final
disposal in a Subtitle D facility. Wastewater generated by this process may be able to be treated
using the existing on-site treatment system if it were modified to accomodate this wastestream.
The PRPs have conducted a treatability study of this technology at the Carter Site and found that
it was able to reduce the levels of PCBs from 1500 mg/kg to 11.5 mg/kg. If this treatment
process can be optimized to meet the cleanup levels for the Carter Site, the costs will be similar
to those shown below. If the treatment process is not able to achieve reduction to below the
cleanup level, the material will have to be contained at the appropriate type of landfills under
TSCA and RCRA authority.
/
This alternative will comply with LDRs through a treatability variance for the contaminated soil
and debris. The treatment level range established through a Treatability Variance that Low
Temperature Thermal Desorption will attain for each constituent as determined by the indicated
analyses are: PCBs - 0.1 to 10 ppm by method 8080; Lead - 0.1 to 3 ppm by TCLP; Cadmium
- 95 to 99.9% reduction by TCLP; Arsenic - 0.27 to 1 ppm by TCLP.
Present Worth
12 months
$ 19,508,000
0
$ 19,508,000
Note: As discussed above, this alternative has been modified based upon public comment. For
a complete description of the modified remedy, see the Explanation of Significant Changes at
the end of this ROD.
Alternative #15 - Quicklime Treatment for PCBs
Oily soils at CERCLA Sites frequently contain PCBs. In an effort to stop the spreading or
migration of oily contamination and PCBs at those Sites, lime and/or fly ash is often added in
an attempt to prevent this spreading or migration. In several instances, it has been found
37
-------
subsequent to treatment that the PCB concentration levels in the treated soils has been reduced.
The apparent reduction exceeds those explained by simple dilution. In an effort to explain this
phenomenon, EPA's Risk Reduction Engineering Laboratory (RREL) in Cincinatti initiated a
project with RMC Environmental of West Plains, Missouri to conduct controlled experiments
on PCB-contaminated soils. The research report from this study has been reviewed by both EPA
researchers and non-EPA scientists.
The results of the RMC study showed that the levels of PCB were reduced after the addition
of quicklime under the conditions of the experiments conducted by RMC. The reviewers have
suggested a number of possible interpretations and have recommended that additional studies
should be conducted to confirm RMC's results and to collect additional information to determine
whether PCB destruction or some other phenomena are occurring. RREL is conducting these
studies inhouse. Private laboratories will provide analytical support and confirmation of results.
If the results confirm PCB destruction with quicklime treatment, additional studies will be
needed to determine in-field application methods, economics, reaction optimization, appropriate
wastes to be treated, and to evaluate potential reaction by-products.
This technology is still in the experimental stages. The potential for its application at the Carter
Site was considered in light of the possibility of achieving destruction of PCBs which may be
comparable to other treatment techniques but at a much lower cost. Site-specific treatability
studies of this technology would be needed if the RREL is able to confirm PCB destruction by
this treatment. The costs calculated below were estimated to be similar to the costs for the
Pozzolonic Solidification alternative, which is the treatment technology that led to this discovery.
The implementation time for the pozzolonic solidification alternative was multiplied by 5 for this
alternative since the reports show that the PCB destruction takes from 3 to 4 days to occur, as
opposed to the solidification process which can be completed on a continuous basis. The O&M
costs listed below assumes complete destruction of the PCBs such that no monitoring would be
required. The Capital Cost shown below does not include any off-site landfilling costs which
may be necessary for EP toxic materials nor the additional safety measures which would have
to be engineered to limit fugitive dust emissions from the quicklime process.
CaphalCost
350 days
$ 3,662,000
0
$ 3,662,000
IX. EVALUATION OF ALTERNATIVES
The sections which follow provide a description of the nine criteria, and a summary of U.S.
EPA's evaluation of how well the various remedial alternatives met these criteria.
38
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A. Evaluation Criteria
Overall Protection of Human Health and the Environment addresses whether or not the
remedy provides adequate protection and describes how risks are eliminated, reduced or
controlled through treatment, engineering controls, or institutional controls.
Compliance with ARARs addresses whether or not the remedy will meet all of the applicable
or relevant and appropriate requirements of other Federal and State environmental statutes and/or
provide grounds for invoking a waiver.
Long-term Effectiveness and Permanence refers to the ability of a remedy to maintain reliable
protection of human health and the environment over time once cleanup goals have been met.
Reduction of Toxicfty, Mobility, or Volume through treatment is the anticipated performance
of the treatment technologies a remedy may employ.
Short-term Effectiveness involves the period of time needed to achieve protection and any
adverse impacts on human health and the environment that may be posed during the construction
and implementation period until cleanup goals are achieved.
Implementability is the technical and administrative feasibility of a remedy, including the
availability of goods and services needed to implement the chosen solution.
Cost includes capital and operation and maintenance costs.
Support Agency Acceptance indicates whether, based on its review of the RI/FS and Proposed
Plan, the support agency concurs, opposes, or has no comment on the preferred alternative.
Community Acceptance addresses the public's comments on and concerns about the Proposed
Plan and the FS Repon. The specific responses to public comments are addressed in the
Responsiveness Summary attached to this Record of Decision.
B. Analysis
Overall Protection. All of the alternatives, except the no-action alternative, would provide
some degree of protection of human health and the environment by reducing the potential for
direct contact with or inhalation of PCBs. The no-action alternative does not provide protection
since soils contaminated with up to 10 mg/kg PCBs would remain in residential areas and
significant risks to human health are present. All of the other alternatives would reduce Site
risks to adequate levels.
Compliance with ARARs. Potential ARARs for each alternative are extensively discussed in
the FS Report. The Land Disposal Restrictions (LDRs) are ARARs for all alternatives because
of the potential presence California List Wastes (EP toxic materials which also contain over 1000
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mg/kg HOCs) that are to be addressed by this response action and "placement" of these
materials which will occur. While the EP toxic soils have been shown to be successfully
stabilized using lime, it will be difficult to stabilize EP or TCLP toxic debris in the same
manner. Disposal of EP or TCLP debris, a component of all of the alternatives, would comply
with the LDRs through a Treatability Variance. Disposal of soils which constitute California
List wastes will comply with LDRs through a treatability variance which requires percentage
reductions in concentrations.
Alternatives 4 and 6 would require a waiver of the TSCA disposal requirements. Alternatives
3, 9, 12, 13, 14, and 15 would have to demonstrate equivalence to incineration (reduce PCB
concentration to less than or equal to 2 ppm in the solid residual) to meet the TSCA disposal
requirements. (See Responsiveness Summary pages 9-10 for a discussion of this issue.) These
same alternatives will have to achieve the cleanup level of 1 mg/kg for PCBs in order for the
residual to be left on the Site unmanaged. If Alternatives 3, 9, 12, 13, 14, and 15 are not able
to meet the TSCA equivalency standard and/or if they are not able to reduce PCB contamination
to the cleanup level for the Site, the residuals will require containment in an approved facility
in accordance with RCRA, TSCA and applicable State law.
The substantive provisions, Parts 6 and 7 of the Michigan Act 307 Rules, are considered ARARs
for the remedial action to be undertaken at the Carter Site. These Rules provide, inter alia, that
remedial actions shall be protective of public health, safety, and welfare and the enviroment and
natural resources. The Act 307 Rules specify that this standard be achieved by a degree of
cleanup which conforms to one or more of the Type A, B, or C cleanup criteria. A Type A
cleanup generally achieves cleanup to background or nondetectable levels; a Type B cleanup
meets risk-based cleanup levels in all media; and a Type C cleanup considers Site specific
criteria.
Any alternatives which involve an option for on-site containment of any stabilized EP or TCLP
toxic materials would ordinarily require a variance of the State's isolation distances in siting
requirements for solid waste management facilities and compliance with Type C criteria under
Michigan's Act 307. Alternatively, an equivalent protection waiver of the isolation distances
could be invoked under CERCLA.
Long-term Effectiveness and Permanence. The alternatives that afford the highest degree of
long-term effectiveness and permanence would be the alternatives using treatment technologies
to control the risks posed by contamination at the Site. These include alternatives 2 through 4
and 8 through 14. Alternative 14 and Alternatives 3 and 9 provide the highest degree of long-
term effectiveness in that they both destroy PCBs and immobilize EP toxic metals.
Reduction of Toxicity, Mobility and Volume through Treatment. The Preferred Alternative
(#14) and Alternatives 2, 3, 8, 9, 10, 11, 12, and 13 would all reduce toxicity by destroying
PCBs to varying degrees. Alternative 4, Pozzolonic Solidification, would reduce the mobility
of the contaminants. Alternatives 5, 6, and 7 employ capping or placement of contaminated
material in a landfill and these measures do not provide for treatment to reduce toxicity,
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mobility, or volume.
Short-term Effectiveness Alternative 6, on-site capping, and Alternative 5, on-site RCRA
landfill, are anticipated to have fewer short-term adverse impacts. Some particulate and volatile
emissions may occur during implementation of these alternatives. However, dust control
measures would be used to control these risks. Other on-site alternatives including incineration
(Alternative 2), vitrification (Alternative 3 and Alternative 9), solidification (Alternative 4), the
Critical Fluid (CF) Extraction process (Alternative 12), the solvent extraction process
(Alternative 13), and the LTTD Processor (Alternative 14) could release volatile PCBs and other
contaminants during the excavation and treatment process. Alternative 13, the solvent extraction
process, sometimes uses the solvent Tri-ethyl amine (TEA) to extract PCBs from the
contaminated soils. At concentrations of 25 mg/kg in the air, TEA may cause irritation of the
eyes, nose, and throat. Stringent air emission controls and air monitoring would be required to
control these risks.
Alternatives involving off-site transportation of contaminated material, including Alternative 7
and all of the hybrid alternatives, would have more potential for short-term adverse impacts,
since a larger population and more of the environment would be potentially exposed to the
contaminated material. Of these alternatives, Alternatives 12, 13, and 14 would involve
transporting the least amount of material off-site for disposal.
Implementability.. Alternative 6, capping, would be the simplest to construct and operate.
Alternatives involving off-site incineration and/or landfill disposal (Alternative 7, 8, 10, and 11)
would not be technically difficult to implement since minimal construction and operation would
be necessary. However, the availability of off-site treatment and disposal facilities may be
limited at the time of alternative implementation and temporary storage areas may have to be
constructed on-site if previously excavated material must wait for disposal. Both incineration
and land disposal are commonly used and commercially available remedial technologies.
Manifests would be required for all alternatives involving off-site transportation of contaminated
material. In addition, the greater the amount of material requiring off-site treatment, the more
difficult the alternative may be to implement due to incinerator and landfill capacity. Off-site
alternatives would be compatible with future remediation, if required, at the Site.
The on-site RCRA landfill, Alternative 5, would be labor-intensive and would require long-term
and extensive Site monitoring and maintenance. In addition, the Carter Industrials Site would
not be able to accommodate a landfill meeting state locational requirements without a variance.
Coordinating treatment and disposal activities at the Site would also be difficult. On-site
incineration would also be complex and time-consuming to implement. During operation of the
incinerator, this alternative would require the most attention because incinerators require periodic
sampling of the residue and modification of operating parameters. The complexity of
implementing in-situ vitrification would be similar to the on-site incineration alternative and
Alternatives 12, 13, and 14. The in-situ vitrification technology was supposed to become
available for commercial scale applications in 1991; however, only one hazardous waste
contractor markets the technology so its availability is limited.
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Cost. The present worth costs of each alternative is presented in Table 4, along with the cost
of decontamination/demolition of the on-site buildings and the costs for operation and
maintenance of the runoff collection and treatment system.
Alternative #10 would be the most costly alternative to implement at a total estimated present
worth cost of $100,718,000. The total estimated present worth costs of Alternatives 8 and 11
are $50,308,000 and $51,797,000. The total estimated costs of Alternatives 12, 13, and 14 are
$49,402,000, $20,542,000, and $19,508,000, respectively. Alternative 9 is estimated to cost
$20,523,000.
The most costly alternative carried over from the 1986 EE/CA would be the on-site rotary kiln
incinerator alternative. Its total present worth would range from $40,864,000 to $55,599,000
depending upon the residual disposal method. Present worth costs for the Shirco Infrared
System would range from $25,030,000 to $39,762,688 depending upon the residual disposal
method. The cost to implement the circulating bed combustor alternative would range,
depending on the residue disposal method, from $13,107,000 to $27,840,520. The pozzolonic
solidification alternative would cost $4,734,141 (present worth) to implement. The in-situ
vitrification and off-site TSCA landfill alternative would cost, respectively, $21,691,000 and
$22,804,000 to implement. Disposal in an on-site RCRA landfill would cost $4,167,000. On-
site capping would be the least costly alternative to implement with a total present worth of
$1,856,000.
The least expensive alternatives which meet the remedial action objectives and utilize treatment
are alternatives 2, 3, 9 (using In-Situ Vitrification) and Alternatives 13 and 14 (Solvent
Extraction and LTTD methods). All of these alternatives are estimated to be in the range of $20
million.
Alternative #15 (Quicklime Treatment) has the potential for being the least expensive treatment
option. It would probably cost from 4 to 5 million dollars to implement at the Carter Site even
with the additional safety measures, and if it is proven to be effective, it will be the least
expensive treatment option which meets remedial action objectives and also results in destruction
of PCBs.
Support Agency Acceptance. The Michigan Department of Natural Resources agrees with the
remedy selected to address the contamination at the Carter Site.
X. THE SELECTED REMEDY
The selected remedy is a slight modification of the alternative originally preferred in the
Proposed Plan. During the comment period, the PRPs submitted a proposal to modify the
original proposed plan. Some elements of the PRPs' proposal were incorporated into the remedy
selected in this ROD. A description of each of the changes to the originally preferred alternative
is contained in the Explanation of Significant Changes in Section XII of this ROD.
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The main elements of the remedy selected in this ROD, incorporating modifications to the
originally preferred alternative, are listed below:
o Excavation of all on-site and off-site soils contaminated with PCBs at levels over 1
mg/kg PCS which are attributable to the Carter Site;
o Treatment of the soil and debris contaminated with PCBs at levels over 10 mg/kg
PCB using LTTD;
o Any debris contaminated with PCBs at levels above 10 mg/kg which cannot be
decontaminated or treated to less than 10 mg/kg will be taken to an approved landfill
off-site;
o Any material which fails the TCLP test shall be solidified such that it no longer
exhibits this characteristic. Debris which fails the TCLP test and cannot be solidified
or decontaminated will be disposed of off-site and will comply with the land disposal
restrictions through a treatability variance which calls for decontamination of the
debris using best management principles;
o Containment of all material containing between 1 mg/kg and 10 mg/kg PCB in an on-
site cell. This would include material that was excavated from the adjacent
neighborhood and from the Site which contained 1-10 mg/kg PCB and was not to
be treated using LTTD - and the solid residual from the LTTD treatment system
which contains less than 10 mg/kg PCB after treatment;
o The on-site cell would be constructed as required to impede the lateral infiltration of
groundwater into the containment cell and the migration of leachate out of the
containment cell. Additional technical requirements would include: a compacted clay
liner; a leachate collection and pumpout system; a monitoring system capable of
detecting leakage from the cell; access restrictions, such as fencing, to maintain
integrity of the cap, and a permanent marker to demarcate the on-site cell,
maintenance activities, routine inspections and appropriate institutional controls, such
as deed restrictions, may be imposed to ensure the integrity of the containment
structure. The cell will be constructed in accordance with the requirements of the
rules implementing Michigan's Solid Waste Management Act (Act 641) for lined type
II sanitary landfills.
o The cap for the containment cell will include a minimum of 2 feet of clay and 42
inches of vegetated soil cover for proper drainage, erosion control, and frost
protection. It would be acceptable for the deepest foot of the 42 inches of soil cover
to consist of clay, making the total clay thickness equal to 3 feet.
o Debris from the Site would be removed from the waste piles, decontaminated, and
transferred either to a scrap metal dealer, an off-site sanitary landfill, or maintained
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on-site for disposal with the LTTD residual material;
o The Underground Storage Tank (UST) would be handled in the following manner:
its contents would be sampled, and based on the analytical results, the contents of the
tank would be pumped out and transported off-site to a permitted treatment and/or
disposal facility. The tank would then be decontaminated and removed in accordance
with the Michigan UST requirements. The soils beneath the tank will be inspected
for evidence of leaking. Any contaminated soils would be excavated and the bottom
of the excavation sampled to confirm adequate excavation. The excavated soil would
be sampled and characterized for ultimate disposal. It may be possible to treat it in
the on-site LTTD process, dispose of it under the on-site cap, or transport and dispose
of it off-site at a permitted facility. The tank would then be cut up, decontaminated
and taken to a scrap metal salvage company.
o Air monitoring will be required for purposes of determining if PCBs are volatilizing
or if there is excessive emission of PCBs adsorbed to particulates during remedial
activities. Dust suppression measures will be required.
The modified remedy selected in this ROD, as discussed above, will result in a remedy which
will involve much less off-site transport of materials, lower short term risks from potential
accidents and increased handling requirements. Further, containment of up to 10 mg/kg PCB
in the on-site containment cell will provide for a protective and cost-effective remedy at the Site.
The modified remedy would also be more implementable and cost effective than the originally
preferred alternative. Consequently, the agencies have decided to modify the remedial
alternative as discussed above.
In summary, the selected remedy, Alternative #14 as modified in this ROD, Low Temperature
Thermal Desorption, would achieve substantial risk reduction through treatment of the principal
threat remaining at the Site by concentrating the PCBs into a small volume for incineration and
by providing for containment of any contaminated residual material or contaminated material that
cannot be treated which is present at the Site and in the residential areas around the Site. The
goal is to address any contamination on the Site and in the adjacent residential areas which is
over 1 mg/kg PCB. Any material contaminated with PCBs over 10 mg/kg will be treated to less
than 10 mg/kg, and any material with PCBs over 1 mg/kg but less than 10 mg/kg will be
contained in an on-site containment cell. Alternative #14 achieves this risk reduction more
completely than any other on-site treatment options except for ISV and at substantially less cost
than the off-site treatment options and is therefore cost-effective.
The preferred alternative uses an innovative technology which has undergone engineering scale
testing to verify its effectiveness at the Carter Site and to facilitate the remedial design.
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XI. STATUTORY FINDINGS
The selected remedy must satisfy the requirements of section 121(a-e) of CERCLA to:
1. Protect human health and the environment;
2. Comply with ARARs (or meet the conditions necessary to justify a waiver);
3. Be 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 Alternative 14 at the Carter Industrials Site satisfies the requirements of
CERCLA as detailed below:
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. Treatment of the on-site soil and
debris using the LTTD process, treatment of off-gases, and incineration of the concentrated PCB
oils which are extracted from the soils, as called for under Alternative #14, provides protection
to human health and the environment through removal of the PCBs by desorbing them from the
soil and debris and then incinerating them. Desorption of the PCBs and subsequent destruction
by incineration will eliminate the source of PCBs responsible for the most significant risks at
the Site. All material contaminated with PCBs at levels over 1 mg/kg will be addressed by this
remedy. Material containing up to 10 mg/kg will be contained in an engineered cell on Site.
The carcinogenic risk remaining after completion of this remedial action will be well below the
level of 1 x 10*..
No unacceptable short-term risks will be caused by implementation of the remedy. The
community and Site workers may be exposed to noise and dust during excavation of the waste
piles and off-site residential areas. Measures will be taken during remedy construction activities
to minimize the noise and dust impacts of construction upon the surrounding community. Such
measures may include the placement of earthen benhs and/or plant materials (such as trees and
shrubs) around the Site perimeter, and other necessary design elements, to effectively control
the noise and dust impacts.
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There are no environmental impacts within or around the actual Site because it impacts soils in
an urban area. However, the Site poses a potential for environmental impacts in that some
contamination of the Detroit River occurred in the past as a result of uncontrolled migration of
PCB-contaminated soil entrained in rainfall runoff from the Site. Runoff from the Site entered
the storm sewer adjacent to the Site. Prior to the installation of the runoff collection and
treatment system in 1986, contaminated soils in runoff from the Site were carried as sediments
along the 1.5 miles of sewer line leading to the Detroit River. PCB-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). There
is an island wildlife refuge located in the middle of the Detroit River 6.5 miles downstream from
the sewer outfall. This environmental impact is complicated by the fact that other sources for
PCBs are also present along the sewer line and upstream in the Detroit River. 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 OF ENVIRONMENTAL LAWS
The selected remedy will meet all applicable or relevant and appropriate requirements (ARARs),
except for a Michigan Solid Waste Management Rule specifying isolation distances for sanitary
landfills. This requirement will be waived pursuant to CERCLA Section 121(d)(4)(D) which
allows the Agency to select a remedy that does not meet an ARAR when the remedial action
selected will attain a standard of performance that is equivalent to that required under the
otherwise applicable standard, requirement, criteria, or limitation, through use of another method
or approach. (See discussion under "Location-specific ARARs" below).
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 U.S. EPA's "Guidance on Remedial Actions for Superfund
Sites with PCB Contamination" (OSWER Directive No. 9355.4-01, August 1990).
MAC R 299.5701 et seq. - 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. Location-specific ARARs
MAC R 299.4305 - This is a Michigan Solid Waste Management Rule which specifies isolation
distances for new sanitary landfills. It is applicable to the selected remedy because solid wastes
associated with the remediation will be land disposed in the State of Michigan. The rule calls
for isolation distances to be established for new sanitary landfills such that the active work area
shall not be located closer than 100 feet to adjacent property lines, road rights-of-way, or lakes
and perennial streams, or closer than 300 feet to domiciles existing at the time of issuance of
a construction permit. In addition, approval of less than 200 feet of isolation distance requires
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either a berm which is not less than 8 feet high with a 4-foot fence on top and which is
constructed around the perimeter of the active work area or natural screening which offers
equivalent protection.
The proposed location of the containment cell at the Carter Site would result in up to three
inhabited domiciles being located less than 300 feet, but greater than 200 feet, from the
containment cell. The cell would also be situated within less than 100 feet of the northern
property line. The cell would therefore not be located in accordance with the Michigan rule.
However, U.S. EPA and MDNR have concluded that the containment cell will attain a standard
of protection that is equivalent to that required under the rule as long as adequate measures are
taken for dust suppression and control of other potential air emissions. Because U.S. EPA will
require such measures be taken, the Agency has determined that an ARAR waiver is justified
in accordance with CERCLA Section 121(d)(4)(D).
MAC R 299.9603 - This is a Michigan Hazardous Waste Management Rule which specifies
location standards for treatment, storage and disposal facilities. Because hazardous wastes will
not be disposed in the on-site containment cell, this rule is not applicable to the Carter remedy.
However, because the contaminants to be disposed of, i.e., PCBs between 1 and 10 ppm, are
similar to hazardous wastes in terms of the environmental and health concerns they occasion,
U.S. EPA considers this rule to be relevant and appropriate. The rule requires the active portion
of a land disposal facility to be located not less than ISO meters from a property line. The
proposed location for the Carter containment cell will not meet this standard. However, the rule
permits the issuance of a variance after consideration of the proposed design and operation of
the facility, the location of private water wells, and the potential for fugitive emissions in
violation of Michigan Act 348. U.S. EPA has considered these factors and concluded that a
variance is justified due to the design criteria for the cell called for in the ROD, the lack of any
nearby water wells, and the Agency's commitment to ensure through air monitoring that fugitive
emissions do not exceed applicable standards (see discussion below). Because the Michigan rule
itself provides for varying the required isolation distances, there is no need for an ARAR waiver
here.
c. Action-specific ARARs
Low Temperature Thermal Desorption
40CFR 761.60faV4) - The TSCA disposal requirements for non-liquid PCBs at concentrations
of 50 ppm or greater are applicable. For a discussion of how LTTD can meet these
requirements, see pp. 9-11 in the Responsiveness Summary attached to this ROD.
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.
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Storage of PCB Oils
40 CFR 761.65 - The TSCA storage requirements apply to storage of PCB oils recovered via
the LTTD process and held for later incineration off-site.
Shipment of PCB Oils
MAC R 299.3315 - Michigan rules apply to the transportation within the State of Michigan of
the PCB oils recovered via the LTTD process.
Incineration of PCB Oils
40 CFR 761.70 - The TSCA incineration requirements apply to incineration of PCB oils
recovered via the LTTD process.
Cleanup of Waste Piles
40 CFR 264.258 - RCRA closure requirements apply to cleanup of waste piles at the Carter Site.
Land Disposal of Residue from LTTD
40 CFR 761.75 - TSCA landfill requirements apply to disposal of residual soils in excess of 1
ppm in the on-site containment cell. These requirements will be met through a waiver under
40 CFR 761.75(c)(4) (see pp. 7-10 in the Responsiveness Summary attached to this ROD).
Land Disposal of EP or TCLP Toxic Wastes
40 CFR 268 Subpart C prohibits land disposal of untreated EP or TCLP toxic waste materials.
40 CFR 268 Subpart D contains treatment standards for wastes to be land disposed. The
treatment standard for EP or TCLP toxic wastes is solidification to remove this characteristic.
EP or TCLP toxic debris for which treatment is impracticable will be disposed of in accordance
with a treatability variance. California List wastes (EP or TCLP toxic soils with over 1000
mg/kg HOCs) will meet the LDRs through a treatability variance requiring reduction in the
levels of PCBs and the EP or TCLP constituents.
Containment Cell Construction
MAC R299.4307r2Wa) - The containment cell will be subject to construction, capping and
monitoring requirements specified in the Rules implementing Michigan Act 641 and will meet
the requirements for a Type C cleanup under Michigan's Act 307. The material to be contained
in the on-site cell will consist of material contaminated with up to 10 mg/kg PCB and TCLP
hazardous material which has been solidified such that it is no longer hazardous. This material
may still have the potential to leach contaminants into groundwater. The approval of a Type C
cleanup under Michigan's Act 307 has to consider the protectiveness and long term uncertainties
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of this remedial action and to consider the goals and objectives of Act 641. In order for the on-
site containment cell to accomplish this at the Carter Site, the cell must be constructed in
accordance with the specifications of Michigan's Act 641 for lined Type n landfills.
Containment Cell Maintenance
40 CFR 264.111 - RCRA closure standards are relevant and appropriate. They do not apply to
the containment cell at the Carter Site since materials to be disposed of will not be hazardous
wastes. However, because the contaminants to be disposed of, i.e., PCBs between 1 and 10
ppm, are similar to hazardous wastes in terms of the environmental and health concerns they
occasion, U.S. EPA considers these standards to be relevant and appropriate.
40 CFR 264.310 - RCRA closure standards for landfills. See discussion for 40 CFR 264.111,
above.
3. COST-EFFECTIVENESS
Cost-effectiveness compares the effectiveness of an alternative in proportion to its cost of
providing its environmental benefits. Table 13 lists the costs associated with the implementation
of the remedies.
The alternatives which are least costly (Capping, Solidification, RCRA landfilling on-site)
provide for only reduction of mobility of the PCB-contaminated soils. The most cost effective
alternatives utilizing treatment are Alternatives 13 and 14 (solvent extraction and LTTD
methods) and alternative 2 and hybrid alternative 3 using In-Situ Vitrification. All of these
alternatives would destroy the bulk of the PCBs at the Site thereby reducing the toxicity and
volume of contaminants for a cost of approximately $20 million. The selected alternative is
cost-effective.
4. UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE
TREATMENT TECHNOLOGIES OR RESOURCE RECOVERY TECHNOLOGIES
TO THE MAXIMUM EXTENT PRACTICABLE
The selected remedy represents the maximum extent to which permanent solutions and treatment
technologies can be utilized in a cost-effective manner for the source control action at the Carter
Site. Of the alternatives that are protective of human health and the environment and comply
with ARARs, the selected remedy provides the best balance in terms of long-term effectiveness
and permanence, reduction in toxicity, mobility or volume (TMV) achieved through treatment,
short-term effectiveness, implementability, cost, the statutory preference for treatment as a
principal element and also considering State and community acceptance. The selected remedy
utilizes permanent solutions and alternative treatment technologies to the maximum extent
practicable at this time.
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The NCP established the U.S. EPA policy of giving priority to long-term effectiveness and to
reduction of TMV at a Site, stating that long-term effectiveness and reduction of TMV through
treatment are generally the key decisional factors to be considered at Superfund Sites. Once the
threshold criteria of protection of human health and the environment and ARARs-compliance
were satisfied, this key criterion was used in remedy selection for the Carter Industrials Site.
There may be minimal risks associated with the excavation and handling of Site soil and debris
for treatment and/or disposal. Any risks posed by such action will be mitigated by attempting
to employ standard dust control measures during construction. Negative short-term impacts
during implementation of the remedy will be minimized by health and safety measures. The
State of Michigan has concurred with the selected remedy. Community acceptance is addressed
in the attached responsiveness summary.
5. PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
By desorbing the PCBs from the soils and then incinerating them, the statutory preference for
treatment as a principal element is met by the selected remedy.
XH. EXPLANATION OF SIGNIFICANT CHANGES
The Proposed Plan was released on May 19, 1991. The Proposed Plan identified Alternative
#14, Low Temperature Thermal Desorption (LTTD) of PCB-contaminated soils as the preferred
alternative. Specifically, this alternative called for:
o All soil with over 1 mg/kg of PCBs to be treated by LTTD to achieve the cleanup
level of 1 mg/kg and removal to an off-site landfill if it did not meet the cleanup
level;
o All soil in the residential areas adjacent to the Site with over 1 mg/kg of PCBs to be
excavated and also treated using LTTD to achieve the cleanup level of 1 mg/kg and
removal to an off-site landfill if it did not meet the cleanup level;
o All TCLP toxic material to be stabilized and off-site landfilled;
o Site buildings to be decontaminated, demolished and off-site landfilled;
o The Underground Storage Tank on-site to be drained and removed;
o No institutional controls or Operation and Maintenance requirements since the only
material which would be left on the Site would contain less than 1 mg/kg of PCB.
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A treatability study of LTTD had shown that this technology was able to reduce the levels of
PCBs from 1,500 mg/kg to 11.5 mg/kg (99.7%). Several vendors of this technology stated that
LTTD could achieve reduction of PCBs to less than 1 mg/kg in soils from the Carter Site.
Based upon this testing, the U.S. EPA felt confident that the LTTD technology would be able
to reduce the levels of PCB to less than 10 mg/kg. If the material could not be treated down
to less than 1 mg/kg PCB, the Proposed Plan required containment in an approved landfill.
During the comment period, the PRPs submitted a justification for a Type C cleanup under
Michigan Act 307 for the Carter Site to the State. This justification was accompanied by a
proposal to modify the original proposed plan. Some elements of the PRPs' proposal were
incorporated into the remedy selected in this ROD. The primary differences between the
originally proposed remedial alternative, and the modified remedy selected in this ROD are
discussed below:
o Treatment of only the soil contaminated with PCBs at levels over 10 mg/kg PCB
(rather than 1 mg/kg as outlined the Proposed Plan) using LTTD;
o Containment of all material containing between 1 mg/kg and 10 mg/kg PCB in an on-
site cell. This would include material that was excavated from the adjacent
neighborhood and from the Site which contained 1-10 mg/kg PCB and was -not to
be treated using LTTD - and the solid residual from the LTTD treatment system
which contains less than 10 mg/kg PCB after treatment;
o On-site containment of TCLP hazardous waste which is solidified and no longer has
hazardous characteristics as well as non-hazardous debris with less than 10 mg/kg
PCB;
o The on-site cell would be constructed as required to impede the lateral infiltration of
groundwater into the containment cell and the migration of leachate out of the
containment cell. Additional technical requirements would include: a compacted clay
liner; a leachate collection and pumpout system; access restrictions, such as fencing,
to maintain integrity of the cap, and a permanent marker to demarcate the on-site cell,
maintenance activities, routine inspections and appropriate institutional controls, such
as deed restrictions, would be employed to ensure the integrity of the containment
structure. This will meet the requirements of the rules implementing Michigan's
Solid Waste Management Act (Act 641) for lined type n sanitary landfills.
o The cap for the containment cell will include a minimum of 2 feet of clay and 42
inches of vegetated soil cover for proper drainage, erosion control, and frost
protection. It would be acceptable for the deepest foot of the 42 inches of soil cover
to consist of clay, making the total clay thickness equal to 3 feet.
o Any TCLP hazardous residual material shall be solidified such that it is no longer
hazardous prior to on-site containment.
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o Off-site disposal is required for any material not meeting the criteria for on-site
containment;
o Debris from the Site would be removed from the waste piles, decontaminated, and
transferred either to a scrap metal dealer, an off-site sanitary landfill, or maintained
on-site for disposal with the LTTD residual material;
o The Underground Storage Tank (UST) would be handled in the following manner:
its contents would be sampled, and based on the analytical results, the contents of the
tank would be pumped out and transported off-site to a permitted treatment and/or
disposal facility. The tank would then be decontaminated and removed in accordance
with the Michigan UST requirements. The soils beneath the tank will be inspected
for evidence of leaking. Any contaminated soils would be excavated and the bottom
of the excavation sampled to confirm adequate excavation. The excavated soil would
be sampled and characterized for ultimate disposal. It may be possible to treat it in
the on-site LTTD process, dispose of it under the on-site cap, or transport and dispose
of it off-site at a permitted facility. The tank would then be cut up, decontaminated
and taken to a scrap metal salvage company.
The two key components of the original proposed plan which have been modified are: (1) the
requirement of off-site landfilling of TCLP toxic material and the contaminated soils which are
treated but cannot meet the cleanup level of 1 mg/kg PCB; and (2) treatment using LTTD of soil
contaminated with PCBs at levels over 1 mg/kg rather than 10 mg/kg.
The modifications represent a logical outgrowth of information contained in the Proposed Plan
and the administrative record. The agencies had information which suggested that it would be
possible to treat the soil to less than 10 mg/kg PCB; however, there was insufficient information
demonstrating that the required cleanup level of 1 mg/kg could be achieved.
In addition, the U.S. EPA and MDNR have reviewed the Remedial Action Plan submitted by
the PRPs for the Carter Site and found that some elements of the PRP's proposal if incorporated
into the remedy selected in this ROD, as discussed above, will result in a remedy which will
involve much less-off-site transport of materials, lower short term risks from potential accidents
and increased handling requirements. Further, containment of material contaminated with no
greater than 10 mg/kg PCB and TCLP-hazardous material which has been solidified such that
it is no longer hazardous in the on-site containment cell will provide for a protective and cost-
effective remedy at the Site. The modified remedy would also be more implementable and cost
effective than the originally preferred alternative. Consequently, the agencies have decided to
modify the remedial alternative as discussed above.
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RESPONSIVENESS SUMMARY
CARTER INDUSTRIALS SITE
DETROIT, MICHIGAN
This responsiveness summary is organized into sections and appendices as described below:
I. RESPONSIVENESS SUMMARY OVERVIEW. This section outlines the purposes of
the Public Comment period and the Responsiveness Summary. It also references the
appended background information leading up to the Public Comment period.
H. SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING
THE PUBLIC COMMENT PERIOD AND EPA RESPONSES TO THESE
COMMENTS. This section summarizes the oral comments received by EPA at the May
2, 1991 public meeting, and provides EPA's responses to these comments.
WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES TO THESE COMMENTS. This section contains
the letter received by EPA containing written comments, as well as EPA's written
response to that letter.
Appendix A: The Proposed Plan (PP) which was distributed to the public during the
public meeting on May 2, 1991.
Appendix B: Sign-in sheets from the Public Meeting held on May 2, 1991 at the
Michigan Health Center in Detroit, Michigan.
Appendix C: Names, addresses and phone numbers of the information repositories
designated for the Carter Industrials Site.
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I. RESPONSIVENESS SUMMARY OVERVIEW
The U.S. Environmental Protection agency (EPA) held a public comment period from April 19,
1991, through June 17, 1991, allowing interested parties to comment on the Proposed Plan for
a source control operable unit at the Carter Industrials Site in Detroit, Michigan.
The Proposed Plan (PP), which has been provided as Appendix A of this document, summarizes
U.S. EPA's investigations of the Site and describes the Agency's preferred remedy.
Specifically, the PP includes information pertaining to the history of the Carter Industrials Site,
the scope of the proposed cleanup action and its role in the overall Site cleanup, the risks
presented by the Site, the descriptions of the remedial alternatives evaluated by EPA, the
identification of EPA's preferred alternative, the rationale for EPA's preferred alternative, and
the community's role in the remedy selection process.
EPA held a public meeting at 7:00 p.m. on May 2, 1991 at the Michigan Health Center, 2700
Martin Luther King, Jr. Blvd., Detroit, Michigan. At the meeting, Representatives of the U.S.
EPA and the Michigan Department of Natural Resources outlined the source control remedial
alternatives described in the PP and presented EPA's proposed remedial alternative for
controlling PCB-contaminated soil and debris on and around the Carter Industrials Site.
Following the presentations by U.S. EPA and MDNR, citizens were given the opportunity to
ask questions and to make comments for the record. '
The responsiveness summary, required by Section 117 of CERCIA, 42 U.S.C. §9617, provides
a summary of citizens' comments and concerns identified and received during the public
comment period, and EPA's responses to those comments and concerns. All comments received
by EPA during the public comment period were considered before EPA made a final decision
on a remedy to address PCB-contaminated soil and debris on and around the Carter Industrials
Site.
NEIGHBORHOOD REPOSITORY
A local information repository was set up several months prior to the public meeting at the Core
City Neighborhood facility located at 3301 23rd Street in Detroit (Contact: Sister Mary Ellen
Gondeck - 313-833-1440).
The information contained in this local repository includes:
o Endangerment Assessment - January 1989
o Engineering Evaluation / Cost Analysis - December 1986
o Feasibility Study - April 1991
o Proposed Plan - April 1991
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o Fact Sheets - April 1991
ADMINISTRATIVE RECORD
The complete administrative record is housed at the Detroit Public Library at 5201 Woodward -
- in the Department of Sociology and Economics.
This record contains the following types of information:
o All sampling results which have been collected on the Carter site from 1986 to the
present;
o Endangerment Assessment, Engineering Evaluation, OSC Reports;
o All technical documents regarding the site such as the Endangerment Assessment,
Feasibility Study, Treatability Study Sampling and Testing Reports, Proposed Plan, Fact
Sheets;
o All pertinent correspondence among the agencies and the PRPs;
o All the files which were seized from Thomas Carter and pertain to liability are
maintained on 35 rolls of microfilm and indexes accompany this documentation;
o Public Meeting Transcript.
n. SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING
THE PUBLIC COMMENT PERIOD AND EPA RESPONSES TO THESE
COMMENTS.
The public meeting was structured to allow for a question-and-answer session followed by a
public comment session. During the public comment session, no comments were received.
During the question-and-answer session which preceded it however, some questions were
answered on the spot and some were taken as comments because an answer could not be given
at that time. This section summarizes the questions and comments which were raised during the
question-and-answer session and the responses to them.
One citizen who lives adjacent to the site stated that his house was contaminated and
wanted to know what we were going to do about ft.
The U.S. EPA Remedial Project Manager (RPM) noted that the EPA removal program had
already excavated the citizen's back yard because, initially, it had PCBs over 50 mg/kg; and that
the MDNR came out in 1987 and excavated soil from his yard in areas where PCBs were
detected at levels over 10 mg/kg. Following these excavations from this citizen's yard, the
levels of PCBs remaining were less than 1 mg/kg as indicated on Figure 7 of this ROD.
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Several citizens requested that EPA purchase their homes.
U.S. EPA responded that property acquisition was usually undertaken if the homes were unable
to be rendered habitable or if the property was needed to conduct the remedial action.
One citizen wanted to know why U.S. EPA and MDNR weren't talking about the site near
4261 Lawton (the Pioneer site).
U.S. EPA responded that this area was associated with the Pioneer site, not the Carter site. We
asked him to stay and talk with us about it after the meeting and he did so.
The EPA Emergency Response Branch conducted a removal at the Pioneer site in 1987 and 1988
and addressed the immediate threat to public health and the environment posed by that site.
Following that action, the U.S. EPA recommended to the City of Detroit that they demolish that
building and remove the debris. U.S. EPA considers further actions needed to be taken at the
site to be the responsibility of State and local authorities. The MDNR has performed additional
surface soil sampling and the City of Detroit has committed to demolish the building.
The individual who owns the auto scrap yard in the middle of the she had several
questions:
1) How long will it be until we start the cleanup?
There are a number of tasks which have to be completed for the cleanup to occur. Listed below
in the order in which they occur are the tasks that U.S.EPA will undertake after the ROD is
signed to start the cleanup:
Negotiation with PRPs 120 days
Consent Decree Lodged in Court 67 days average for Region V
Consent Decree Entered by Court 118 days average for Region V
Remedial Design Completed Between 1 and 2 years
Remedial Action Commenced Between 22 to 34 months from ROD
Therefore, the best estimate of the time until the cleanup begins is from two to three years after
the Record of Decision is signed.
2) How long does he have to close down his business?
It may not be necessary for the business to be closed down because of this remedial action. The
proposed layout of treatment and disposal areas on-site does not involve any use of the auto
salvage yard property. The site remediation should involve only the areas which are currently
within the fenced portion of the site.
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3) Who would pay him for the time he is closed down?
As stated above, it is not clear that it will be necessary for this business to close down during
or after the remedial action.
4) How much will the Chy of Detroit be responsible for?
This is a matter to be negotiated with and among the PRPs.
5) He expressed a preference for en-site treatment rather than off-site landfilling.
A member of the Core City neighborhood asked several questions:
1) What effect will cleanup operation have on area businesses?
Cleaning up this area of Detroit would have to be more beneficial to local businesses in the long
run than leaving high levels of PCBs untreated at the surface. The cleanup will be conducted
under much more stringent conditions than operations at the site were conducted by the owner
for over 20 years. Therefore, the site cleanup will have less impact than normal operation of
that site had while it was still an active facility.
2) What does LTTD do to microbes in the soil?
It would probably kill anything that could not stand temperatures up to 1100 degrees Fahrenheit.
The residual material will then be contained in the on-site containment cell.
3) Could she go in and build a house and/or plant a garden on the site after it is
cleaned up?
Since the site it going to have an on-site containment cell which will contain the low level
residual from the treatment process and the integrity of this containment cell must be maintained,
institutional controls will be placed on the property such that no digging into it will be allowed.
Another member of the Core City Neighborhood asked who assumed responsibility for the
short-term health effects from the site.
John Hesse, of the MDPH, responded to this question. He indicated that the blood studies had
indicated that the levels of PCBs in those residents tested in 1986 were lower or fairly
comparable to the general population. He also indicated that there was no data to suggest that
plants would take up the PCB and the only way someone would ingest PCBs from garden
vegetables was if they did not properly wash any root produce such as potatoes or carrots.
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A member of the Core City Neighborhood asked when restitution would come to private
individuals affected by the site.
The U.S. EPA attorney present responded to this question. He indicated that U.S. EPA would
be attempting to recover past costs incurred by the government at the site but would not seek
costs on the behalf of private citizens. Citizens who believe they have a cause of action relating
to the Site should seek private legal counsel.
Another member of the Core City Neighborhood asked if the State approves of the U.S.
EPA's Proposed Plan.
Claudia Kerbawy of the MDNR responded that the State concurred with the remedy selected for
the Proposed Plan. However, the State reserved final concurrence until the public comments
were evaluated. C.
Another member of the Core City Neighborhood expressed objections to the format of the
meeting, she wanted to have questions and answers instead of questions and comments.
Dan O'Riordan responded that U.S. EPA was taking some of the questions as comments, but
that we were fully prepared to answer as many questions as possible and we would stay as long
as necessary to answer questions.
A member of the Core City Neighborhood stated that it seemed as if EPA had already
made its decision on which plan to use since we only had slides of LTTD.
U.S. EPA informed this individual that the public's comments on the proposed alternatives were
very important to us and that we have in the past altered remedies based upon public comment.
U.S. EPA also encouraged her and the other members of the public present to comment upon
other alternatives that were evaluated in the Feasibility Study and the Proposed Plan.
A member of the Core City Neighborhood wanted to know why we had picked LTTD
instead of the other alternatives.
We discussed the history of opposition in Detroit to incinerators, the safety problems with In-situ
vitrification, the ineffectiveness of non-treatment alternatives. We also indicated that this
alternative provided the best balance of tradeoffs considering the nine evaluation criteria.
The business owner in the middle of the site wanted to know what Jon Peterson's
qualifications were.
Mr. Peterson responded that he is a geologist and has worked with U.S. EPA for the last 7
years.
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WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD.
Three written comments were received from citizens in the area adjacent to the site. In general,
these comments were supportive of on-site treatment. These comments are contained in the
administrative record for the site.
The Record of Decision embodies several changes in the proposed remedy in line with comments
received from the Potentially Responsible Parties. For reasons discussed in the ROD, U.S. EPA
believes that the remedy as altered is preferable to the Agency's original proposal. However,
while the Agency has accepted in large part the PRPs' suggested changes, it should not be
assumed that the Agency accepts all of the arguments the PRPs propounded in their comments.
What follows is a series of PRP comments with which the Agency does not agree and the
Agency's response.
1. The PRPs claim that n[i]t would be arbitrary and capricious to insist that LTTD be
made to achieve 1 ppm at the Carter Site, when the information in the Administrative
Record indicates that that cannot be done." (PRP comments p. 4)
The Proposed Plan did not insist that LTTD be made to achieve a reduction of PCBs to 1 ppm.
It called for LTTD, and to the extent necessary, off-site disposal, to achieve a cleanup level of
1 ppm. Hence, if it proved impossible to reduce PCB levels to 1 ppm via LTTD, residuals in
excess of that level would be disposed of in an off-site landfill. U.S. EPA has now agreed to
alter the remedy to allow on-site disposal of residuals up to 10 ppm PCBs.
2. The PRPs cite a number of RODs which have chosen on-site containment in
"residential" areas, including the Acme Solvent Site in Region V. They imply that if the
Agency has sited PCB containment hi residential areas before, ft can do so again at the
Carter She. (PRP comments p. 7)
Every site has to be evaluated in terms of its own particular characteristics. It is somewhat
misleading to lump the Acme Site together with the Carter Site. The Acme Site is located in
a rural area of northern Illinois and covers approximately 20 acres. The Carter Site is located
in the city of Detroit and covers less than 4 acres. While there are residences in the proximity
of both sites, the Carter Site offers less land area in which to achieve horizontal separation
between containment cells and residences. Moreover, the overall population density in the
vicinity of the Carter Site is much higher than is the case for the Acme Site. Finally, sites differ
in terms of the state regulations that apply. There may well be significant differences between
Michigan and Illinois siting requirements. Having said this, the Agency nevertheless agrees that
the combination of treatment and engineering controls proposed by the PRPs for the Carter Site
as modified by the Agency in the ROD will result in a remedy that will not present any
significant long-term risks to residents in the vicinity of the Carter facility.
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3. The PRPs assert that isolation distances or other siting requirements under Michigan
Act 64 are not applicable because the material to be disposed of at the Carter Site will not
be hazardous wastes as defined under RCRA and analogous Michigan regulations. (PRP
comments p. 8)
While the Michigan Act 64 siting requirements may not be applicable, they are relevant and
appropriate. That is, while the jurisdictional prerequisites are not met here, "the circumstances
at the site are, based on best professional judgment, sufficiently similar to the problems or
situations regulated by the requirement." (CERCLA Compliance With Other Laws Manual:
Draft Guidance, August 1988, p. 1-5). It is true that PCB-contaminated residue that is not
otherwise hazardous is not regulated under RCRA or analogous Michigan regulations.
Nevertheless, the types of environmental and health concerns associated with PCBs are so
similar to those associated with RCRA hazardous wastes that the siting regulations promulgated
for hazardous wastes are relevant and appropriate for PCB disposal. The Michigan siting
regulations do offer the possibility of a variance from the prescribed isolation distances based
on the proposed design and operation of the facility, the location of private water wells, and the
potential for fugitive emissions in violation of Act 348. (Michigan Solid Waste Regulations, Rule
299.9603(3)). U.S. EPA has considered these factors and determined that the isolation distances
proposed will be sufficient.
4. The PRPs assert that, due to the industrial character of the Carter Site, it is not
accurate to describe the Site itself as residential. (PRP comments p. 11).
U.S. EPA does not dispute the fact that the Carter Industrials property is itself industrial.
However, that should not be the end of the analysis in determining whether a residential or
industrial cleanup level is appropriate. At the Carter Site, residences are located so close to the
Carter boundaries and to heavily contaminated areas that it is appropriate to choose a
"residential" cleanup level. This is in line with the TSCA Spill Policy which calls for industrial
areas within . 1 km of residences to be cleaned up in accordance with residential standards.
5. The PRPs assert that a cleanup level of 1 ppm for PCBs is not necessary to comply with
CERCLA guidelines. (PRP comments p. 11).
U.S. EPA believes there is some confusion here as to what is meant by a cleanup level. As
stated in the Proposed Plan (p. 15), we mean by a cleanup level, the degree of contamination
above which humans and the environment should not be exposed. In citing numerous instances
in Agency guidance documents which endorse on-site containment of PCB contamination, the
PRPs apparently believe there is a contradiction between those citations and our choice of a 1
ppm cleanup level. Given our definition of cleanup levels, there is no contradiction as long as
on-site containment ensures that humans and the environment are not exposed to PCBs in excess
of 1 ppm. The containment cell called for in the ROD will accomplish this.
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6. The PRPs assert that a cleanup level of 2 ppm for PCBs is not required by TSCA and
is not an ARAR. (PRP comments p. 12).
The PRP argument rests primarily on the premise that LTTD is not disposal of PCBs. The
PRPs cite TSCA Compliance Program Policy No. 6-PCB-2, which states that "it is not the
intention of this policy to require approval of physical separation activities regarding the clean-up
of leaks and spills of PCBs . . . that are not construed to be part of a disposal activity." (p. 2).
The PRPs also point out that, under the same policy, no approval is required for the separation
of aqueous from organic phases in collected water. The PRPs assert that, under their proposal
for remediating the Carter Site, disposal would not occur until the PCB oils recovered via LTTD
are incinerated and that TSCA performance standards would not apply prior to that point.
The TSCA regulations define "disposal" as "intentionally or accidentally to discard, throw away,
or otherwise complete or terminate the useful life of PCBs and PCB Items. Disposal includes
spills, leaks, and other uncontrolled discharges of PCBs as well as actions related to containing,
transporting, destroying, degrading, decontaminating, or confining PCBs and PCB Items." (40
CFR 761.3). Low temperature thermal desorption is related to destroying PCBs inasmuch as
it is the first stage in a process which ends in incineration of PCB oils. Indeed, the purpose of
implementing LTTD at the Carter Site is to destroy the PCBs in contaminated soils. TSCA
Compliance Program Policy No. 6-PCB-2 states that an approval is required for physical
separation activities that can be construed to be part of, or an initiation of a disposal activity.
(p. 1). U.S. EPA maintains that implementing LTTD at the Carter Site will initiate disposal of
PCBs and therefore must itself be construed to be a disposal activity.
The TSCA disposal requirements for non-liquid PCBs are found at 40 CFR 761.60(a)(4):
(4) any non liquid PCBs at concentrations of SO ppm or greater in the form of
contaminated soil, rags, or other debris shall be disposed of:
(i) In an incinerator which complies with § 761.70; or
(ii) In a chemical waste landfill which complies with § 761.75.
An exception which would allow other means of disposal is found at 40 CFR 761.60(e):
Any person who is required to incinerate any PCBs and PCB Items under this
subpart and who can demonstrate that an alternative method of destroying PCBs
and PCB Items exists and that this alternative method can achieve a level of
performance equivalent to § 761.70 incinerators or high efficiency boilers as
provided in paragraphs (a)(2)(iv) and (a)(3)(iv) of this section, may submit a
written request to either the Regional Administrator or the Director, Exposure
Evaluation Division for an exemption from the incineration requirements of
§ 761.70 or § 761.60.
Under this exception, if low temperature thermal desorption could meet the same performance
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standards as incineration, it could be used in lieu of incineration to dispose of PCB-contaminated
soils.
The PRPs take the curious position that since 40 CFR 761.60(a)(4) offers an alternative, i.e.,
incineration or land disposal in a TSCA landfill, one who intends to dispose of PCB-
contaminated soils cannot be deemed to be required to incinerate PCBs and is therefore not
required to meet the performance standards for incinerators. The problem with this approach
is that § 761.60(a)(4) offers only two options for disposing of PCB soils. Low temperature
thermal desorption is not one of them. LTTD is therefore not a permissible disposal option
under the TSCA regulations unless it can be brought into the TSCA regulatory scheme under
§ 761.60(e), in which case it would have to meet the performance standards for PCB
incinerators. If one took the PRP argument to its logical conclusion, no alternative disposal
options for non-liquid PCBs could be pursued via § 761 (e) because alternatives to incineration
can be proposed only in situations where incineration is required. Unlike the PRPs, the Region
maintains that, for the purposes of § 761(e), incineration is required inasmuch as if one elects
not to dispose of PCB soil in a landfill, one is required to incinerate it.
At first glance, it would seem that the TSCA regulations rule out the adoption of LTTD for PCB
disposal if it is incapable of achieving a reduction of PCB concentrations to the 2 ppm level.
However, because the TSCA regulations offer the option of either incineration or disposal in a
landfill, the Region has concluded that LTTD can be used, even if it does not achieve incinerator
performance standards, as long as the residual material is either incinerated or disposed of in a
TSCA-compliant landfill. LTTD produces two end-products: oils and solid residual material.
Under the PRP proposal, the oils would be incinerated in accordance with TSCA standards,
thereby satisfying the TSCA disposal requirements. That leaves the solid residuals. The Region
originally proposed that such material should be shipped to an off-site landfill in compliance with
the TSCA landfill regulations. However, after a careful review of the PRP proposals for an on-
site landfill, the Region has concluded that an on-site containment cell is preferable to off-site
disposal. Under 40 CFR 761.75(c)(4), the Regional Administrator has considerable discretion
in fashioning requirements for chemical waste landfills when there is evidence that the operation
of such landfill will not present an unreasonable risk of injury to health or the environment from
PCBs. The Region maintains that the favorable geology of the Site together with the
implementation of suitable institutional and engineering controls allow disposal of the solid
residual material in accordance with TSCA.
In sum, while the Region ultimately has approved of a plan for LTTD and on-site containment
of residuals, its view of the TSCA provisions regulating these activities differs from that of the
PRPs.
7. The PRPs assert that Michigan's Act 307 Rules are not ARARs.
The PRPs first argument in support of this assertion is that the legal authority for promulgating
such rules was not conferred by the Michigan legislature until July 1, 1991. Even if this were
true, since the selection of a remedy for the Carter Site occurred after July 1, 1991,
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consideration in the ROD of the Act 307 Rules as ARARs is legitimate.
The PRPs second argument is that the Act 307 Rules do not establish standards that are precise
enough to count as "promulgated standards" under Section 121(d) of CERCLA. It is undeniable
that state standards promulgated as specific numbers are easier to use than state standards
promulgated in terms of formulae or procedures. However, the legal character of the standard
does not depend upon whether it is specific or general. That the Agency expects differences in
the specificity of state ARARs is borne out by the instructions in the "CERCLA Compliance
With Other Laws Manual: Part n. Clean Air Act and Other Environmental Statutes and State
Requirements" (OSWER Directive 9234.1-02, August 1989, p. 7-3):
Promulgated State laws and regulations can contain provisions that range from
chemical-specific numerical standards, the application of which can be clearly
identified and considered, to narrative criteria, which do not contain specific
requirements. . . . The promulgated requirements that implement State
environmental laws can also range from numerical standards to non-quantitative
narrative criteria, such as toxicity testing procedures. Following the identification
of specific promulgated requirements, the application of the requirements must
be interpreted on a site-specific basis. State policies or guidance used in
implementing or interpreting narrative criteria or standards, although not ARARs,
should be considered in determining the remedy.
The Region submits that in the case of the Carter Site, the Region has interpreted the Michigan
Act 307 Rules, giving due consideration to MDNR guidance and policy.
The PRPs note that the first page of Table 4-2 of the FS states that the Michigan Act 307 Rules
"are applicable or relevant and appropriate to remedial action at this site to the extent that action
is taken using State funds." This statement is in error. The Act 307 Rules are applicable
regardless of whether State funds are expended or not. MAC R299.S107 states that "these rules
[Rules implementing Act 307] apply to all known sites of environmental contamination without
regard to whether the property is publicly or privately owned.
8) Act 307 cleanup levels for metals is not an ARAR since the State did not specify this
in their September 6,1990 letter to USEPA.
U.S. EPA chose the cleanup levels to be protective of human health and the environment. The
methodology for calculating these levels is attached. The resulting cleanup levels are consistent
with Michigan Act 307 Type B cleanup criteria.
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9) Since the method by which the cleanup levels for other organics were derived was
not specified hi the Proposed Plan, the FS, or any other document listed in the AR
index, there is no justification to establish cleanup levels or monitoring requirements
for these substances.
As discussed in the response above, the Region has considered Michigan Act 307 to be an
ARAR for the Carter site. The cleanup levels for organics were determined under Rule 711 of
the 307 rules. These calculations and supporting documentation have been included in the
administrative record.
10) The ROD should not require further remediation of non-residential properties
outside the fenced site.
The Remedial Action selected in this ROD is intended to address contamination on the site and
outside the fenced area of the site which is attributable to site activities.
11) The ROD should not require long-term ground water monitoring.
Groundwater monitoring will be required for the site since PCB-contaminated materials will be
contained on-site. Regardless of the current or potential use of the groundwater in the area of
the site as a drinking water source, any release from the containment cell will represent a release
of hazardous substances into the environment and corrective action would be necessary. The
hydrogeology of the site is little understood at the present time (only 1 monitoring well has been
installed). Further study will be necessary during or before the design of the containment cell.
Furthermore, Michigan Act 641 Rules for solid waste disposal are ARARs for the containment
cell. These rules require that a monitoring system must be installed which can adequately assess
the landfill's impact upon groundwater.
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SOURCEt UL& 6EOL06ICAL SURVEY, ItBO »
SOURCE^ GOUSHA' ROAD "ATLAS, "nm^**
figure 1
SITE LOCATION
Industrials S/Y*
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FIGURE 2
Carter Industrials
Surrounding Neighborhood
Detroit Michigan
f^^-.
Net IB Sole
/
N
/
Areas Cleaned by EPA down to 50 mg/kg PCB
Areas Qeaned by MPNR down to 10 mg/kg PCB
Areas with PCB Concentration between 1-10
-------
FIGURES
LEGEND
| ) 1OOO GAL. UNDERGROUND TANK
•O 2 x S3 GAL. SAND/CARBON FILTER
[*] 26O GAL. TANK OF CARBON
O 26O GAL. TANK OF SAND
RUNOFF FLOW DIRECTION
FILTRATION TRENCH
INTERCEPTION TRENCH
STORM SEWER GRATE
CONNECTING PIPE
VEHICULAR GATE
MAN GATE
DIRT BERN
BUILDING
FENCE
D
FIGURE 8. SITE STABILIZATION
DRAINAGE
TILE
STONE
•8'
FACILITIES. CARTER INDUSTRIAL SITE
WAYNE COUNTY, MICHIGAN.
100'
*/**?
-------
HI 4.3)
FIGURE 4
$14.7)
LE6ENO«
(S.W- MEAN WIND tff.lt
(A/»«C) FOA SECT
. WIND SPEED
(M/SEC)
>8
5.0 - 8.0
3.C-5 0
•o.c-:.o
. ANNUAL WIND ROSE (1970-1974)
DETROIT CITY AIRPORT, MICHIGAN
-------
in
w
O
WASTE M.E }
(SOL M.EI
WASTE M.E I
(SOL/ASH F-H.E)
•SURFACE *•
WASTE r«.E 6
(SON. PILE)
0
(DEMOLITION SURFACE
BURIED METAL *
\
\
NO SCALE
LEGEND
• SAMPLE LOCATIONS FROM
OCTOBER 1986 EPA SAMPLING
CFFORT-IEPA I9t6)
LOCATION OF WASTE PILES
CM UN MOuSIHUtS tilt
MfHOII ,HICMC««
-------
US EPA
CARTER 1KOUSTRIAL SITE
DETROIT. K1CHJCAH
FIGURE 6
POST-STREET CLEANIKS SVAB SAMPLING
Fi?RESEKT£ AREAS FAVEO DURING FEKOVAL/CLEAKUP ACT!OH
RESULTS ARE IK UG/100CK2
SVAB SAMPLE
-------
FIGURE?
OS EPA
CARTER INDUSTRIAL SITE
DETROIT, MICHICAH
1986
POST-SOIL EXCAVATION AND POST-STREET CLEANING SAMPLING
SHADING REPRESENTS AREAS EXCAVATED
RESULTS ARE IN PPH
_J CRAB SAMPLE COLLECTED WITHIN GRID
3 CRAB SAMPLE COLLECTED AT POINT WITHIN GRID
| CRAB SAMPLE COLLECTED AT 1 FOOT DEPTH BELOW EXCAVATION
* CRAB SAMPLE
• CRAB SAMPLE OF SEEP
1
-------
MIUI
\J-18
»«•>•&•• .-
5L_5L*ai
UMrflllUlf
1P-28
• SOLSAMPLMG
2 IOCAHON (CRA-1890)
^"* ASH SAUPUNG
UKAHON (CRA-I9M)
t
* \V
-------
TABLE1
June 5,1986 Site inspection by OSC confirmed that severe contamination
existed at the site.
June 6,1986 U.S. EPA's Technical Assistance Team (TAT) started an extent
of contamination study involving collection and analysis of
over 2000 samples and identification of on-site and off-site
areas requiring clean-up.
June 6,1986 U.S. EPA's Region V Emergency Response Program initiated a
removal action to confine PCB contamination to the Carter
site. U.S. EPA's activities consisted of the following major
tasks:
Stabilization of uncontrolled site perimeters was
accomplished by pushing highly-contaminated areas of the
perimeter back towards the site interior in order to reduce any
further migration of contaminants. In addition, some areas of
the site surface were cleared of debris to accommodate the
staging of the consolidated contaminated soils from off-site
areas.
Contaminated soils and debris from the surrounding
neighborhood with greater than 50 mg/kg PCBs were
excavated and consolidated into waste piles on-site.
Identifiable PCB items (e.g. capacitors and oils) were removed
from the site for off-site disposal (incineration).
Larger pieces of scrap metal found on the surface of the site
were decontaminated and removed from the site.
Municipal streets and alleys in an approximately four square
block area surrounding the site were decontaminated.
Several alleyways adjacent to the site were unable to be
cleaned adequately and were repaved.
The site was graded to direct runoff toward the southeast
section of the site where a system of interception trenches,
collection tanks, and mixed media filter units collect and treat
the runoff water. (Figure 3)
A 6-foot chain-link cyclone fence topped with three strands of
barbed wire was erected around the site to prevent
-------
unauthorized entry.
Fall 1986
Fall 1986
October 1986
October 1986
October 1986
October 1986
December 1986
The U.S. EPA and MDNR staff sampled rain gutter sediments
and debris in the vicinity of the Carter site. The purpose of
this sampling was to determine if PCBs had been transported
aerially into the surrounding community. These data showed
a general radial pattern with PCS levels tending to decrease in
a given direction as the distance from the site increased. PCB
levels for the rain gutters sampled ranged from non-detectable
to 38 milligrams per kilogram (mg/kg).
US. EPA began identifying Potentially Responsible Parties
through analysis of site records and issuance of CERCLA
Section 104(e) information requests.
The TAT took samples from the waste piles, surface soils,
subsurface soils, groundwater, and a seep encountered below
the surface. PCBs and heavy metals were found in on-site ash
and soils.
Two buildings and an incinerator located on-site were
sampled revealing concentrations of PCBs ranging from 6 to
100 micrograms per 100 square centimeters for wipe samples
and 85-900 ppm for floor sweep samples.
A site inspection report was prepared by the MDNR.
Following this, the site was evaluated for the National
Priorities List (NFL) using the "Uncontrolled Hazardous
Waste Site Ranking System" (HRS). The site received a score
of 37.79, making it eligible for inclusion on the NPL.
Sampling undertaken by the MDNR and the City of Detroit in
September and October of 1986 detected PCB contamination at
levels up to 4900 mg/kg in the city sewer lines immediately
adjacent to the Carter site and along the connecting 18**1 Street
line to the Detroit River.
An Engineering Evaluation/Cost Analysis (EE/CA) was
completed in December of 1986. The EE/CA's screening and
selection process for evaluation of the alternative remedial
technologies was conducted in accordance with the procedures
outlined in the draft "Proposed Alternative
Treatment/Disposal Technology Guidance for Removal and
Expedited Response Actions".
-------
Fall 1987
10/86 to 10/88
October 1988
November 1988
June 24,1988
Jan. 24,1989
Jan. 24,1989
MDNR removed contaminated soil in the residential areas
with contamination levels between 10 and 50 mg/kg.
Contaminated soil was disposed of off-site at a RCRA landfill
in Ohio.
Despite security fencing, 24-hour armed guards, and stepped
up Detroit Police patrols, the site was broken into repeatedly —
after the U.S. EPA removal action began. Vandals gained
access by removing security fencing, thereby providing
unrestricted access to the site by children living nearby.
Vandals repeatedly removed contaminated scrap metal,
knocked out walls and broke into contaminated buildings,
and vandalized three large transformers on the site. In
addition, vandals set fires to the vegetative cover (grass)
which was planted on the waste piles to reduce migration of
contamination.
U.S. EPA acted to improve site security by repairing
vandalized fencing. U.S. EPA also attempted to reduce the
attractiveness of the site to vandals by removing as much
scrap metal and debris as possible.
'Ah underground fuel storage tank was identified at the site.
The contents of the tank consists of a 50/50 mixture of
gasoline and water. This tank is to be addressed as part of this
remedial action.
The site was proposed for inclusion on the NFL.
An Endangerment Assessment was completed by the U.S.
EPA. This assessment reveals that persons in the vicinity of
the site may have up to 4 x 10E-02 increased cancer risk for
inhalation of volatilized PCBs, as well as a significant non-
carcinogenic hazard.
The U.S. EPA issued an Administrative Order to 30 PRPs
pursuant to Section 106 of CERCLA, which required that the
respondents undertake interim site safety measures, such as
fence maintenance, run-off collection and treatment system
operation and maintenance, and provision of site security.
This order also called for the Respondents to undertake one of
the response options which had been reviewed in the EE/CA
after opportunity for public review and comment on the
PRPs proposal and workplan.
-------
Feb. 8,1989
Feb. 28,1989
March 23,1989
March 31,1989
April 5,1989
May 5,1989
May 25,1989
June 1,1989
August 1989
May 1990
EPA/MDNR Conference regarding the 106 Order - Detroit
Public Library. The Respondents requested that they be
allowed to have sufficient time to coordinate and form a
steering committee, review the administrative record, and put
together a proposal as to how they were going to proceed.
EPA issued an amended order which extended the effective
date until April 10,1989.
EPA/MDNR Technical Conference with the PRPs' technical
consultant regarding feasibility of the options contained in the
EE/CA.
The site was listed on the NPL.
EPA/MDNR Conference with PRPs to discuss PRP proposal.
Proposal involved capping of all soil and debris in place
EPA/MDNR advised Respondents that this was not
sufficiently protective of human health and the environment.
2nd amendment of 106 Order was issued to require the
respondents to immediately undertake interim site
stabilization measures, including: 24-hour security guards
posted at the site; laying geotextile over the waste piles to
stabilize the site; hydroseeding operations; assumption of the
responsibility for the run-off collection and treatment system,
as well as all utilities and services at the site. The amended
106 order also provided a 2nd effective date tied to U.S. EPA's
selection of a response alternative after an opportunity for
public review and comment on the proposed plan.
PRPs proposed to excavate and dispose of soils containing PCB
levels over 50 ppm in an off-site landfill and to cap all the rest.
Respondents were advised that cleanup level would be at
most 10 ppm due to proximity of residences, as set forth in the
PCB Spill Policy.
Geotextile cover and hydroseeding operations completed by
Respondents.
Feasibility Study of remedial alternatives commenced by U.S.
EPA.
Treatability Study Sampling Program conducted by Conestoga-
Rovers and Associates on behalf of PRPs.
-------
Fall 1990 Treatability Studies of 8.E.S.T. solvent extraction and X-Trax
(low temperature thermal desorption) technology were
completed for PRPs.
April 19,1991 Feasibility Study and Proposed Plan issued to public and
comment period commenced.
May 2,1991 Public meeting on Proposed Plan held in Detroit
June 18,1991 60 day Public Comment Period Closed.
-------
SUMMARY OF RESULTS OF HSL ORGANIC PARAMETERS
CARTER INDUSTRIAL SITE
DETROIT, MICHIGAN
OCTOBER 1986
bird
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-------
SUMMARY OF RESULTS OF HSL ORGANICS PARAMETERS
CARTER INDUSTRIAL SITE
DETROIT, MICHIGAN
OCTOBER 1986
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-------
SUMMARY OP RESULTS OF HSL ORGANIC PARAMETERS
CARTER INDUSTRIAL SITE
DETROIT, MICHIGAN
OCTOBER 1986
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-------
SUMMARY OF RESULTS OF MSL ORGANIC PARAMETERS
CARTER INDUSTRIAL SITE
DETROIT, MICHIGAN
OCTOBER 1986
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-------
SUMMARY OP RESULTS OF HSL ORGANIC PARAMETERS
CARTER INDUSTRIAL SITE
DETROIT, MICHIGAN
OCTOBER 1986
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ORIGINAL
-------
SUMMARY OF RESULTS OF HSL ORGANIC PARAMETERS
CARTER INDUSTRIAL SITE
DETROIT, MICHIGAN
OCTOBER 1986
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ORIGINAL
-------
SUMMARY OF RESULTS OP INORGANIC PARAMETERS
CARTER INDUSTRIAL SITE
DETROIT, MICHIGAN
OCTOBER 1986
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-------
SUMMARY OF RESULTS OF INORGANICS PARAMETERS
CARTER INDUSTRIAL SITE
DETROIT, MICHIGAN
OCTOBER 1986
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-------
SUMMARY OF RESULTS OF INORGANIC PARAMETERS
CARTER INDUSTRIAL SITE
DETROIT, MICHIGAN
OCTOBER 1986
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M
IMM
•
M
DM
N
U
UNI
III
if
•
N
I.I
miTHIM KU NilW
M-I
•-1
1
II HI S
w
M
l.fj
I.I
I.M
M
f.l
I.I
1.1
tf
II
1.11
IIM
B
IMM
•
H
IIM
l.ll
III
IIMI
III
11
N
H
1.1
•-I
M '
1
II ft*lf S
w
M
1.17
41
1.1
1.1
l.f
II
1.1
N
14
M
MM
1.11
IIMI
l.f
M
IIMI
l.ll
5JI
IIMI
111
IM
n
N
II
MM
M
1
11. 1-11.]
M
I.I
11
1.1
1.1
II
11
1.1
l.ll
11
H
4fM
I.B
IflM
1.1
II
IIMI
l.ll
III
INM
IN
IM
M
H
14
•-I
l-l
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1 JJ.4-JJ.1
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I.I
II
1.1
1.1
1.1
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1.1
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11
• H
UN
I.IJ
MM!
1.1
M
IMM
It
III
IMM
IM
III
n
M
II
M-I
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M &.M j
H/II'
•
i.i
if
M
1.1
M
M
u
M
If
g
IIM
M
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1.1
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M
IN
IMM
IM
IM
m
m
f.f
M-I
l-l
1
4J.MJ.1
M
I.I
11
M
1.1
1.1
f.l
1.1
M
]I
N
8M
M
INN
J.I
M
INN
N
IM
IMM
IM
IN
U
n
ii
M-I
f-f
1
M Hi 9
w
„,
1.1
n
M
1.1
1.1
II
1.1
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11
H
UN
0
IIMI
1.1
H
INN
H
IN
IMM
IM
IM
H
g
II
M-I
•-II
1
N H1 1
-»,
M
1.1
n
i.i
i.i
1.1
u
1.1
M
11
H
14N
M
IIMI
1.1
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fMt
H
IM
UNI
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If!
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M
II
M-I
l-l II
1
S3 4.41 J
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M
M
11
l.f
f.l
f.l
11
1.1
l.ll
II
M
UN
m
4MN
l.f
M
IMM
I.I
IM
IMM
HI
IM
M
M
II
M-I
•-111
1
M.I-M.
M
1.1
11
1.1
f.l
f.l
11
1.1
l.ll
M
n
UN
0
HIM
1.1
• M
IIMI
Ml
III
IIMI
111
IM
II
M
11
If • tvllcitt
C - CMMillt lu»lt
I • lltcritt Sufli
• - III IrlKtri
M - Ihl failriri
il
oo
croc
O
-------
SUMMARY OF RESULTS OF INORGANIC PARAMETERS
CARTER INDUSTRIAL SITE
DETROIT, MICHIGAN
OCTOBER 1986
Rllrli
nut
hitll fcrtir
•MI* *n>
bwli Ulirul III)
(kill
imwiitt
iKlll*
mm
t
I.M.M.MM
tf/l|
M-I
i mnmm mi \
-I i
t i
I.M.M.MI.I
•I'M
••I
11/11
C
I.S-S.M.HM
••I m-t n ii
UN im nit nu
I llMl I Mwl
•i/i it/i */i mn
If Mile
tvln
titaln
CkrHlM
Cotlir
S*lt*ln
line
Slim
•IllIlM
fcrtlllra
Cilcln
CMtlt
Ntiinlnt CtrotlM
Irt*
•trcvi
•MINIM
Mln
fctllMf
UllIlM
VlMllll
I-S» 1
IM-MM IN
t.M-*.T I.N
HN» |M
MM W
}-Mt W
MM W
».(-! ».l
IMM 1*
M-J I.W
flMt
I.I-W t
l-«* I
».*]
N-MM tM
Ml 1
1
»-JM IN
M
1.11
44
M
II
M
1.1
2»
m
MM
•.II
1.1
•
MM
•
in
HIM
1M
II
l.t
M
I.U
1?
M
1.1
II
1.1
HM
Lit
1.1
•
MM
M
nt
IMM
m
. it
•
M
M
1.1
II
1.1
n
11
n
MM
t.tl
3MM
I.?
M
LIT
I.N
MI
!.»
Ml
m
INI
IMM
IM
IM
• M
' »
1?
• LIU LIII
• I.Mt
• LI
• Ml
I. II LIT I
• M
• I.1S
I.U I.M LM
tl M
Ml M
IH LM
LIT •
M M
in I.M
11 •
IM m
1.1 N
II Ml
M •
C • CMfMltt SNfll
I • Illtrtli
M - l
M - «ol toilriH
-------
TABLE 4
SUHMARY OF RESULTS OF EP TOXICITY TEST
CARTER INDUSTRIAL SITE
DETROIT. MICHIGAN
OCTOBER 1986
bat
Stall bttfr
h«lt litnal Ifil *r LtutlC
Ihiti
tr mitm
lil«tr
(rinic
tvim
U*IIM
OirMitt
UK
Itlni
: If m
o fBtTffllA
* Ml It" in
H/1
s
s
100
I
0.2
S
1
: MSTE tua
:
i
tn
c
1I,II,IC,I
•I/I
•
• •
1.2
'•
•
0.22
"
2
tl
C
1 2I,2I,2C
2.0
0.12
0.04
B
1.7
a
i
B7
C
U,9
I.S
0.13
I.M
0
1.)
"
4
m
c
41,40
•I/I
0.0
0.00
0.04
f
7.0
O
S » 7
cn Mi CM
t c t
94,9 W,M 74,71
H/l tf/l «i/I
0.14 0.09 0.27
• • •
1.2 1.0 1.7
" * *
!ACU
•901
!• UtTT 911 fl
!• M4II rlLft*
It
IM
1
—
•I/I
7.2
0.11
M
IN
\3
41
tro
I
—
•1/1
9.0
t.2
0.11
0
290
n
40
KTM. !
KUilltlCt •
•Mvms i
n
S7l(lf) 171
0
—
•I/I
•
n
9.4
I.I
0.1*
n
44»
_!/
i
•I/I
n
0
0.7
0.91
a
0.
a
it
a
9 • Owliciti
C - tMpeiiti
I - Micrtti
a • fct
POOR QUALi i
ORIGINAL
-------
SUMMARY OF RESULTS OF EP TOXICITY TEST
CARTER INDUSTRIAL SITE
DETROIT, MICHIGAN
OCTOBER 1986
: irm : wr«a ton :
: outoii» : Mun ITOMK
s i Mm lutt run : ii IN* «r«i : win
Ucttiw tot II tt 31 hrltct 12 fcr««ci 17 frlict H l*rlM U
tn c« tn tn en tut tm
in* tce.cct i
r uutii* »-r w »•:• *-;• *-:• *-i- i-i-
»itl nil t|/l If/1 if/1 l|/l d/l tf/l «f/l
if tnittn
lil««r J 0 • • • BO «
*r*t*ir S • • • • • t.ttl «
trim m 1.7 1.1 l.« 4.) |.| |.3 l.tt
t mum t.t* m n ».«
j • o o • an n
1.2 n n n n n n i.m
S *.N I. II LI ».* I.I O.N 0.21
i n n n • n n n
\J
9 ' tolicit*
t - C*vnitt
I - liKrttt Uwlt
n -
POORQUAUTV
ORIGINAL
-------
TABLES
SUMMARY OF RESULTS OF TECHNICAL PARAMETERS
CARTER INDUSTRIAL SITE
DETROIT, MICHIGAN
OCTOBER 1986
htrji ' I WfliniB ! «SN :
.--.-:. --.-I .'• : nmsTtrucs
< :c:^m&^::----: "•'•'•"• • —: -i
!»:•..:. •„-.."•--•$.$'.-•-?•£&£•.':. tt£-?:i'• .;•:;.» v-.-« •; » i • T ic « «
i i
taplf btirtal (It) tr UcitlM •-.:. 11,11,11,11 M.a.tt »,9 4I,O M.9 M,U »,TI - - -
lUMUCtt. MIME7DS • '. " -;•'. :•'!'". • .•
Ml Mtttn OrmtlltM l<9 . • • • • • « O O «
' fin 9N 4M IM ill ICO IX 100 JIC W
••••• m a • 0 • • « a MO MO
IT It n » U I» U V U II
» • Mlicttt
C - tOMHlt* U*lt
I • Micrtt* iMflt
0 - M kt«CM
POOR QUALITY
ORIGINAL
-------
SUMMARY OF RESULTS OF TECHNICAL PARAMETERS
CARTER INDUSTRIAL SITE
..DETROIT, MICHIGAN
OCTOBER 1986
Ittrii
avia ton
'l
-: nunnauKMtt i
: ww :
UUtiMlMt
\\ >;'}••;'? .<.*•• • ••?&•"?•?..•&
iMlUTftf '"" '."•' '"' " '" '" '' '
tM»ll UUTMl lltl V UUtiM . I
41 .
CPI
c
lilk tttntM OkrrwUltl,!
CUvi«,4|/t|
DM
•
IT
a
en
c
INO
a
U
IrlmC
M
C
IM
a
U
en
c
farfttt It
CPU ItU
C I
»-J !•»•
B
S(
HO
a
U
V • Mliutt
C • CMMtiU
I • MtcrtU *it|Ii
• - M tattctM
POOR QUALITY
ORIGINAL
-------
SUMMARY OF RESULTS OF GEOTECHNICAL ANALYSIS
CARTER INDUSTRIAL SITE
DETROIT. MICHIGAN
OCTOBER 1986
mnHu.in.ic CONDUCTUITT TCSTIMC
Co*(flclent
el
5*tur*t<4
Nydriullc
!«•»!• SI i« Conductivity Cjtlon
% W » CoMol.
lorlnt Oipih % * lilt/ % % % % e T< k « '< • dC
(It.t U5CS Cri»«l 5»n« CJjj USD* Cr«»«l l«n< lilt CUr %_ tgelj U M (la.) (In.) (»cf) (c./.tc.) UM) Ug) (,,) (,f) (»,)
••1
l-l
Hit)
MM!
w»r
4-$
«•» CL
4-S
»-io a
14-IS Cl
0 1»
1 10
1 !•
71 Cl«r LOM
7» Cl.r LOM
71 LOM
11.4
1 !• 40 10 11. S
It.S
1 11 41 1) 17.t
1 11 40 1} 14.1
17 11
10 11
1U.4 » II 1.1. 1.70 117.7 I.UIO" "'» »-° "* '•" J'U
M<0 4-S M.I
tun
HUM
• •4
t-10 Cl
i4-ii a
7-1 CL
0 11
I It
0 11
CUy/
LOM/
11 City UM
CUy/ ••
It Cl«» la«>
1 1) Jt 40 10.1
4 11 11 17 IJ.i
I 11 M 40 l*.l
17 M
171.1 11 « 1.11 L*4 111.! l.l.io"* t.OI JO.O .1 J.»J I
4t 14
r»ftt)/lll4
Cation Exchange Analysis was conducted by Aqualab, Inc. Bartlett II. All other analysis were conducted
by Patrick Engineering, Inc., Glen Ellyn, II.
POOR QUALITY
ORIGINAL
-------
SUMMT Of MILT All MUTMIM
rot Atmac rci rmiauTE «o
VOLATILE PCI* M»m EICAVATIM
Or CMTAfllMTEl SOIL
CAITEI inUSTIIAL SITE
OCTWir, RICHI6AN
UK
TABLE 7
MTE
June 24
23
JVM 27
21
•IDS
——————
2-3ook
oti of Ml
• -I ook
ort of MM
1 - IV o*
ovt of M
0*t Of MNt
2**
o«t of Mori
0«t Of Ml
EKAVATI01
ACTIVITY
ME corner of site. Coroer of
•E corker of tile. Coroer of
Mukolft tut roreit Avetwet.
Alley M ent oerioeter
of litoi lltk itreot.
Alter «• **tt pertMter
of iitei rorwt aveooe.
Alley oo e«*t perioeter
of lite.
lKkr
-------
Jily 14
13
IS
Jily 18
Jiiy 21
Jily 24
Mj 29
Mj 26
Mr 27
<3 opk
«rt of »
<3 *k
out of Sortk
<3 opk
ort of SMtk
<3 *k
ort of Hff
(3 tpk
ort of ME
<3 opk
ort of ME
<3 tpk
out of SSH
<3 ipk
Oft of SSE
<3 opk
Mt of Nortk
<3 ipk
wt of Nortk
• - S ill*r b*t«*M
HnboUt and I8tk Stmtt
lorn Afai* UdMtriti lot;
KlofiUjr'i tato farti lot.
KiRftUr't A«to Ptrti lot;
to lit*.
tori Afaii IMntrin,
Auto Part lot, OR titt.
Kid««Ur'f A«t« fart lot;
OR fiti.
A«to fart lot;
OR fit*.
lori Afain l*4i
-------
^g^^SlMWAR^^MStHTSOFPCB A^feii^;;f ^ \y1:; '/
^^^^^^^8gE^RKpQNSEA'' y"' X*A^»'i'l. L> IXTT^TTOTTIY A T O gl'I'L.' v. ,, " & /, , '* ' ' ', ,'f *,, '"'< ^ s .
•-m" '/- , - -;^;^S'%,;; '^.^ CARTER INL/UaiKlALS 5ITc ^., - /•• ,**• •- '~ ,";'-- /""'- - ;; , '
'^Lr?^'$^f*'*^;*': --'•'.'. '.\'~/$^\'I'' tvc^;^"::^;\"f : %
Sample Matrix
Waste Piles
Ash
Metal Shavings
Surface Soil Below
Waste Piles
Location
Name
Waste Pile 1
Waste Pile 2
Waste Pile 3
Waste Pile 4
Waste Pile 5
Waste Pile 6
Waste Pile 7
1C
4B
4B
5D
1A
IB
1C
ID
S2A
26
Sample
Number
CP1
51
S57
CP2
CP3
586
CP4
534
S70
S71(DP)
579
512
S19CDP)
514
S18CDP)
515
516
517
528
529
551
552
553
554
555
5158
5157
540
541
523
524
52
S3
54
55
56
Sample
Type
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Sample Interval
or Location(s)
1A, IB, 1C, ID
2A/2B,2C
3A,3B
4A,4B
5A,5B
6A,6B
7A,7B
1C
4B
46
5D
0-3"
0-3"
o-r
o-r
1-2'
2-3.5'
3.5-5'
0-3"
o-r
0-3"
o-r
1-2'
2-3.51
3.5-51
5-6'
6-7-
0-3"
o-r
0-3"
o-r
0-3"
o-r
1-2'
2-3.5'
3.5-5'
PCB
(mg/kg)<2)
240
120
9
3
13
2
7
12400
3
2
12
10
3
12
5
15
5
<1
<1
<1
6800
4100
5000
5200
70
<1
<1
<1
<1
<1
1
55
3
<1
110
1
-------
Sample Matrix
Surface Soil Below
Waste Piles
(continued)
Surface Soil in
Open Areas
Surface Soil in
Open Areas
(continued)
Location
Name
2C
3A
4A
SB
5C
6A
66
7A
7B
Surface #1
Surface #2
Surface #3
Surface #4
Surface #5
Sample
Number
S7
58
S58
S60
S64
S65CDP)
S67
S81
S83
S74
576
S87
589
S92
S94
S110
S112
S104
S106
S35
S36
546
S47
'548
549
550
S97
S98(DP)
5100
5101
5102
5115
5117
5118
5119
5125
S127
5128
5129
Sample
Type
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Sample Interval
or Location(s)
0-3"
0-1 '
0-3"
1-2'
0-3"
0-3"
1-2'
0-3"
1-2'
0-3"
1-2'
0-3"
1-2'
0-3"
1-2'
0-3"
1-2'
0-3"
1-2'
0-3"
o-r
0-3"
0-1'
1-2'
2-3.5'
3.5-5'
0-3"
0-3"
1-2'
2-35'
3.5-5'
0-3"
1-2'
2-35'
3.5-5'
0-3"
1-2'
2-3-5'
3.5-5'
PCB
(mg/kg) (2)
13
<1
<1
<1
13
8
9
<1
<1
<1
<1
<1
<1
20
<1
<1
<1
<1
<1
5
<1
95
60
30
80
5
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
-------
Sample Matrix
Location
Name
Surface #6
Surface #7
Surface #8
Surface #9
Surface #10
Sample
Number
S130
S132
S133
S134
S120
S122
S123
S124
S135
S137
S140
S142
S143
S144
S160
S16KDP)
S162
S145
S146(DP)
S148
S149
Sample
Type
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Discrete
Sample Interval
or Location(s)
0-3"
1-2'
2-35'
3.5-5'
0-3"
1-2'
2-3.5'
3.5-5'
0-3"
1-2'
0-3"
1-2'
2-33'
3.5-5'
5-6'
5-6'
6-7-
0-3"
0-3"
1-2'
2-3.5'
PCS
(rag/kg) (2)
<1
<1
<1
<1
<1
<1
<1
<1
2
<5
10
7400
7
40
130
130
170
1
<1
<1
<1
DP-Duplicate
(1) - Data taken from Table 2-2 of 1986 EE/CA (EPA 1986).
(2) - PCB's reported for Arochlor 1260 unless otherwise noted.
-------
Table 9
MAXIMUM CONCENTRATION OF CONTAMINANTS
WASTE PILES
# SAMPLES
PCB
Lead
Cadmium
Copper
Zinc
Arsenic
1,3-dichlorobenzene
1,4-dichlorobenzene
Xylene
Chlorobenzene
Benzo(a)anthracene
Pyrene
1,2,4-trichlorobenzene
pentachlorobenzene
tetrachlorobenzene
Iethyl2methylbenzene nd
ASH
7
240
990
24
1600
2,900
1.7
8
3
nd
nd
5
11
ie 11
nd
nd
lend
3
12,000
28,000
34
17,000
8,500
56
nd
nd
nd
nd
nd
nd
nd
700
1,600
nd
SOIL BELOW
WASTE PILES
44
6,800
330
2.5
36
130
4.8
nd
nd
nd
nd
nd
nd
nd
20
nd
nd
SOIL IN
OPENAREAS
41
7,400
210
6.7
310
410
1.4
180
nd
25
36
nd
nd
nd
nd
nd
1
Note: All units are in milligrams per kilogram or mg/kg — This is the
measurement in soil which is equivalent to part per million (ppm) in water.
ON-SITE BUILDINGS
On-site structures at the Carter site (Figure 2) include building 1, building 2 and an
incinerator. Sampling conducted by the U.S. EPA Emergendcy Response Program in
1986 revealed the following levels of PCB (Arochlor 1254):
Floor Sweep Samples
Wipe Samples
Building 1 Building 2
680 ppm 900 ppm
6ug/100on2 lOOug/lOOonZ
Incinerator
85 ppm
7 ug/100 on2
Note: ug/100on2 means micrograms per 100 square centimeters.
-------
Table 10
ViZ • jmf**4r '•"#« !,%!>. V - '<• f, '*-f?r4>' ,'s ' v»'4£S. »- *"* ,'*,"* '/'"•' <"-* '><.*»•<« -'»' - W>,,' "', ••:
^/'^^^^^^""^ ^m^,^ ',?."?-'; ->'r, 7; , ,-;;
'*&•*$& :, ^SUMMAkv'OF'KBlfr^ RESULTS (MG/KG) ' '/, , , '"/, , ;- : '
^y^?/K*'^<>^v,CRA*l»OTREAtAmiJlYSTUDY -' *"'^'^ ,>'':? ' ,'-i
,tl <; /C^^?^;^CARTERINrDUSTRIAtS SIH:' ^ ^ K: '/ ^-"^ ' '' -'- 1
'>^ ' ^ '' ' •• ? •• " •• ff fff _, ^' •• ' ' "" ' % f *•* ' """ /' ' A' > «• '
Test
Pit
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
LA
IB
32
33
34
35
36
37
38
Waste
PilelA
1,900
5,200
Waste
Pile IB
120
9
100
830(1 )(2)
1,100
34
Watte
Pile 1C
46(3)
1(3)
19(3)
37(3)
26
28
Waste
Pile ID
420
1
3
31(1X2)
Waste
Pile2A
3.400(1X2)
U40UX2)
Waste
Pile2B
29(1X2)
290
Waste
Pile3
990(1X2)
130
120
460
270
Waste
Pile 4
15
24
10
3
13
Waste
PileS
130
340
12
5
12
76
NOTES: PCBs reported for Anchlor 1260 unless otherwise noted.
(D-PCBsArodJorl260.
O)-PCBArochlorl242.
(3).PCBArachlorl254.
-------
TABLE 1 1
REPORTED SERUM POLVCHLORINATED BIPHENYHL (PCS) CONCENTRATIONS
IN URBAN AMERCIANS*
Study
Date
1973
1973
1930
1930
1937
1937
Not Given
Population 1
Lake Michigan random
Lake Michigan volunteer
tporrtubermen (PCB-expoMd)
Bonfiabeaten
Lake Michigan volunteer
•portfiahennen (PCB-expoeed)
Carter Industrial Neighborhood,
Detroit
Frederick Neighborhood, Detroit
Capacitor Plant Worker*
Number
of
Subieett
29
90
413
172
193
39
34
PCB Concentration
' Standard
Mean Deviation
17.3 Not Given
72.7 Not Given
6.6* Not Given
21.4*
10.7
7.0
394*
Not Given
i
11J
10.7
Not Given
fnr/mL)
Rant*
-------
Table 12
CARTER INDUSTRIAL SITE HAZARD RANKINGS BASED ON
MAXIMUM AND REPRESENTATIVE SAMPLING VALUES
CARCINOGENS
1.
2.
3.
Maximum Values
PCBs*
Arsenic*
Benzo(a)anthracene
Representative Values
Arsenic *
PCBs*
Benzo(a)anthracene
NONCARCINOGENS
Maximum Values
1. 1,3-Dichlorobenzeae
2. Lead*
3. Copper
4. 1,4-Dichlorobenzene
5. Barium
6. Nickel
7. Zinc
8. Tetrachlorobenzene
9. Cadmium *•
10. Arsenic *
11. Selenium
12. Trichlorobenzene
13. Pentachlorobenzene
14. Chlorobenzene
15. Di-n-butylphthalate
Representative Values
1,3-Dichlorobenzene
1,4-Dichlorobenzene
Barium
Lead*
Copper
Nickel
Zinc
Cadmium*
Selenium
Arsenic •
Trichlorobenzene
1,2,4-Trichlorobenzene
Chlorobenzene
Tetrachlorobenzene
Di-n-butylphthalate
* Selected as contaminants of concern
1 Cadmium is considered a Bl carcinogen via inhalation
-------
Table 13
CONCENTRATIONS OF POLYCHLORINATED BIPHENYLS,
ARSENIC, CADMIUM, AND LEAD
AT THE CARTER INDUSTRIAL SITE
Contaminant1
PCBs
n
Max
x
Arsenic
n
Max
x
Cadmium
D
Max
x
Lead
n
Max
x
Waste Piles
fmg/kg)
7
240
15 (2.8 - 77.4)
7
1.7
0.51 (0.31 • 0.84)
7
24
9.6 (5.1 - 18)
7
990
630 (406 - 979)
Soil-
Opeo Areas2
(me/kg)
12
95
2.1 (0.58 - 7.8)
3
1.4
0.84 (0.38 - 1.4)3
' i
2.7 (1.3 - 6.7)s
3
210
98 (63 - 210)3
Waste Piles
& Open Areas
Combined
Cmc/kg)
19
240
4.3 (1J - 12)
10
1.7
0.59 (0.38 - 0.91)
10
24
6.6 (3.4 - 13)
10
990
361 (173 - 753)
Notes:
Table compiled from data presented in Roy F. Weston, Inc., 1987, Site Investigation Report for
the Carter Industrial Site
Figure 1-2 shows the locations of the waste piles and the open area sample points.
1 X was computed as a geometric mean. For samples from the waste sites, open areas
(PCBs only), and waste piles and open areas combined, the numbers in the parenthesis
represent the 95 percent confidence interval for X. In most exposure calculations, the
"realistic worst case" value was selected as the upper value in this confidence interval,
while the mean was the "representative" value . For samples from the open areas (arsenic,
cadmium, and lead) the numbers in parentheses represent the range of concentrations
measured (insufficient sample numbers were available to calculate a 95 percent confidence
interval). In these cases, the maximum was used as the "realistic wont case" value.
2 "Open area" values were computed based on samples taken at depths up to one
foot beneath the surface.
s Numbers in parentheses represent the range of sample concentrations; a 95 percent
confidence interval was not computed because of the small sample size. __^
-------
Table 14
CALCULATIONS USED TO DERIVE EXPOSURE DOSES
Ic.
Infection (toil*)
Body DOM
Level -
(ug/kg/day)
Direct Contact (•
Body DOM »
Level
(ug/kg/day)
InhtlfttfoD (volftti
Body DOM «
Level
(ug/kg/day)
Ingertion (Mils)
Daily DOM
Over Lifetime
(ug/kg/day)
Direct Contact (»
Daily DOM
Over Lifetime
(ug/kg/day)
Inhalation (volati
Daily DOM
Over Lifetime
(ug/kg/day)
Concentration
in Soil *
oil*)
Concentration *
in Soil
("«/«)
le§ and particulatee)
Concentration *
in Air
(ug/m1)
Amount of
Soillngefted *
((/day)
Amount of *
Soil Contacted
((/day)
Amount of *
Air Inhaled
(mj/day)
Curinamie Effect*
» Concentration * Amount of
in Soil Soil Ingested
(ug/g) (g/day)
* Frequency of Contact fdavil
361 day*
oil*)
« Concentration • Amount of
in Soil Soil Contacted
(«(/() (f/day)
* Freamnev of Contact fdavi)
MS day*
tee and paniculate*)
* Concentration * Amount of
in Air Air Inhaled
(ug/nr) (or/day)
* Freouener of Contact fdavil
Relative
X Abeorbed
(varies for
individual
contaminant*)
Relative
X Abeorbed
(variee for •
individual
ran t uni n nn tM\
Relative
(vane* for *
individual
contaminant*)
Relative
* £ Abeorbed
Relative
i
• Body weight (kg)
1
Body weight (kg)
. 1
Body weight (kg)
• 1
Body weight (kg;
Lifetime
• 1
Body weight (kg
* Year* of Expoeure
Lifetime
Relative
• X Abeorbed • 1
* Xn
Body weight (kg
Mtdayi
-------
Table 15
PARAMETERS USED IN EXPOSURE DOSE CALCULATIONS
Exposure Scenarios
Parameter
Ingestion of
Soili
Direct Contact
with Soil*
(9)
Amount of Soil Ingested, Soil Contacted, or Air Inhaled
• child
• adult
Relative Percent Absorbed"
0.1 g/day /3.0 g/dey» 1.0 g/day
6.4 g/day
• cadmium
• lead
• PCBs
Body weight (kg)
• child
• adult
Frequency of Contact (days)
• on-site
• off-site and industrial
property
Years of Exposure (age (lifetime « 70 years)
• . on-site and industrial
property
• off-site (neighborhood)
Inhalation of
Particulate* and
Volatile
On-Site ; Off-SiU
1.75 m'/hr ; 1.75 mVhr
1.95/nVhr ; l.l/m'/hr
100
100
100
100
JO
6
10
r««r§)
3 (S-6)
3 (3-6)
1.1
14
2.0
0.3 and 17
10
70
6
10
67 (3-70)
70 (0-70)
100
100
100
167*
M
70
6 (4 hn/day)
374 (U hn/day )"
67 (3-70)
70 (0-70)
Notes:
This value repretenU the pica behavior of children.
This value auume* that inhalation may occur 36S dayi/year; however, individuals will be present in the area
only 75 percent of the tine.
For each of the contaminants of concern, the risks from exposure to these contaminant* are evaluated using risk
factor* (see Chapter 5) which are chemical and route specific. Where such factors exist, the assumption is mad*
that the degree of absorption in human* to the sam* as in the test animal*. This assumption is represented by
the use of 100% relative absorption. For routes where such factor* do not exist (direct contact and inhalation —
PCB only), exposure to contaminant* are evaluated using factors established for ingestion. Exposure dote* for
each contaminant are adjusted based on the ratio of absorption via the route of concern and ingestion (tee
footnote* d and e).
The degree of absorption of arsenic, cadmium, lead, and PCBs via direct contact is lee* than via ingestion.
Therefore, the relative degree of absorption was calculated in the following manner (see Section* 3.3.1.3 and
34.14):
Percent Percent
Absorption Via Absorption Via Percent
Ingestion Direct Contact Relative Absorption
Arsenic
Cadmium
PCB*
95
7
50
30
1
1
1
0.1 and I
1/05 « MX
1/7 « 14%
1/50 - J*
0.1/30 « OJX; 6/30 ;
17*
The percent relative absorption was used in calculating direct contact exposure do*** so that these doses could be
evaluated using risk factor* based on ingestion. (Source*: Ingestion — arsenic (Carlson and other*, 1935 and
-------
Ray-B*ttley and O'Shm, 197B), cadmium (Catantt and Doull, 1980). tad (Zitflw and othtrt, 1978 and Fribcrt.
1978), and PCB» (U.S. EPA. 1986b); Direct Contact — aMumd values (L~. 8., 1988)).
Tte dtfiM of absorption of PCBt via inhalatioa U fnattr than via iagMtion. Thu«fon, UM tvlativ* d«fn« of
abcorptioa wa» calculated in th« foUewinf mamur (»•• Section 3.3.1.1):
Pwcott Ptreaat
Absorption ria Abaorptioa via P«rc«at
Innitien Inhalation R«lativ« Abterntlan
PCS* SO 80 50/30.167%
Th« p«c«it ralathr* absorption wat uMd in calculating inhalation «xpo«u* doa«« ao that thtM docct could b«
evaluated iuin( risk facton baMd on injwtion. (SOURM: Inftttion and Inhalation — UJ. EPA. 1986b).
-------
USX CHARACTERIZATION FOR INHALATION OP KB, ARSHNK; AND CADMIUM OONTAMINATBD rARTICULATOS
AT Tim CARTUR INDUSTRIAL snu -
ar> ACO
2 INOU3H
H
Caidaofcnfc Potcaqr
Conlamiiunl fiit/kt/da*)''
PCBs (Anxtor) 1260) 7.7B43
tnenic 5.00B42
Minium &IOB43
Total Cuanofeok Risk
IDNTALCARG
INOGHNIC RISK* ASSOOATUD WfHI
ISIIMATUD unsr
Wsste Piles One* Altai
Most
3&08
3BO9
8E4»
4B4M
Realislk Most
WoraiCase Probabte OMC
IB4I7 4E4»
68-09 6E-OT
I&08 2B09
I&07 IB48
Rcalitlic
WoftlCMC
I&OJ
9B49
SBW
2B4M
MBDOSB
Waste Piles awl
OMH ARM Combti>e<^ |
Most ReaKtlic
F^^*MtifiHt Wofrt Cine
9B49 2&08
1£2 2fifl
SB4B IB07
M«e»:
Refer to Table V6 for cstinuted lifeitae data.
lacmncBUl cardaofeaic risk • ErttaMed Ufelbne docet
Ciiciao(enfe
At icpaitcd to Tong, Peter. 1Mb. U& EPA Tories IntepMiui Bmick. MCMO
-------
RISK CHARACTERIZATION TOR MIALATION (OttSTTB AND DOWNWIND OP TUB STTB) Of VOLA1HJZB>
AT TIIU CARTOR INDUSTRIALS STTB -
INCREMENTAL OUtONOOIlNIC RBKT ASSOCIATED WITH ESTIMATED U
lOOMeten LOOO Meter*
On-Site Downwind of the Site Downwind of Ife
C«i>o»ure Condition!
Steady Stale Emtatoo*
Without Cover
Mod Probable Cue
Realistic Wont Cue
leady. State ErafetioM
Vitb Cover .
Mod Probable Cue
Realislic Wont Cue
Jadeady EnbtioM
Without Cover
Mod Probable Cue
Realinic Word Cue
Uadeady EmiuioM
With Cover.
Mod Probable Cue
Realidie Word Cue
Wade
TBM
3E04
2B4TI
IB06
IBO6
5B46
3E49
IBM
Open
Arcat
9B47
3B-06
IE4B
IB-OB
5B48
4B-I1
1B-IO
Refer to TaMe 3-7 for edimated lifetime doccs.
. Carrinofeaic Potency for PCBt - 7.7B4O (oiAi
Total
§U£
7E-05
3B-04
IB-06
IB45
5B4M
3B09
1B48
/dar)'1:
Watte
Pita
7B4W
3B02
2B4K
IB4H
1B04
5E4M
3B07
IB4I6
VS. EPA. l«6a.
Open
Artat
4B4M
IB4»
IB46
5E-06
6E-06
2B-QS
6B4B
Superfwi
Total
7B03
4B02
2B«S
IB04
IB-04
SB4M
3BXT7
1B06
t f\ li IT i **-
Wade
I&04
5B-04
3B07
2B-06
IB4M
IBM
Open
6E-Ot
2&05
2B«
TBM
3B47
4B09 36-10
IBM 9B-10
ahh BnlMtkM MaMaL
WUMI
p yte .
Total
1B04
5B04
4B4J7
2B46
28-06
BB46
4B09
2B4»
Incremental CaicioofCMc Rttk • Eclimalcd Lifetime Dote • Carcteofenic Potency
-'
-------
USX CHARACTERIZATION1 BOR INOISnON faif/*r an*
OP OONTAMINATflD SOOJJ AT Tim CARTDRINDUSTRIALS STIB
FOR NONCARdNOaCMC OVBCIS
MOST rRORABU! AND REALISTIC WORST CASES
(Ratio of Edimalcd Expomic Dote to Acceptable Daw)
Acceptable Watie Pifc*
Do»e« Watte Pita Surface Soft and Surface Soft
3.0i/day
MOST PROBABLE CASE
Cadmium 1.006*00 4JOB42 I.44B*00 I.35B-02 4.05BO1 3JOB42 9.90B-OI
Lead NA - - -
tBAUSTIC WORST CASE
1.00B*00 9.00B42 2.706+00 13SB4B |j01B»00 6JOE-02 IJSBfOO
NA - - -
Refer to T«ble 3-8 for edbMted cipoMre dace*.
NA • None mikblc.
1 Rkk charMeriztihM for MMCMciMfeiifc efferti k premled m • Ibaid bdei wMck b • iwto of Ike etttawtcd cipocun AM to Ike •nephMe daw
2 AacpiiMe dace for cwtaihi«Md had- AHo«^>fe |M«kc . Cbroaic (AIC) M preteued <• T
-------
RISK aiARAcnuuzATioN ton MonsnoN BY CHILDREN (MI/*?
OP ODNTAM1NATUD SOILS ATTIID CARTDR INDUSTRIALS SHU TOR CARONOOUMC UHWCIS
ConUmliunt of Concern
MOST PROBABLE CASE:
Total Caaccr Risk
REALISTIC WORST CASE:
PCBs
Arseak
Total Cancer Risk
Notes:
Refer to Tabk J-9 for
MOSTPROBAB
INCREMENTAL CARONOGONK: RKK1 1
CardNoacalc
PotencV* Waste Piles
fm/kc/davV' O.lc/da* 3.0t/dav
7.7B#HB2) 4E4J7 IB-OS
1JB4O(A) 3&09 IB07
4B47 IB4S
b
7.7B4O(B2) 2BO6 6B4B
IJB4d(A) 5&09 2B4T7
2B4M 6BOS
estimated UCeliaM dotes.
IB AND REALISTIC WORST CASOS
issooATOD wrni DSHMATDD UFBTIMB AVBRAOB n
Waste Piles
Surface Sojff Hf4 ^fff* ^°"1
O.lt7day }.Qt/d«¥ Ui/tfU 3.0t/di
6B48 2B4M IB4J7 3B-06
Jfiffl ZMZ lEffl 1M2
7B-OB 2B4H IB4T7 3B46
2E4T7 6&06 3E4T7 1B4S
9&09 3B4T7 JEM 2E4T7
2B47 6B06 3B47 IB-OS
1 Inmmcnlal carcinofenk rick • Estimated Ufelime dote * Caitiaofcnk Potenry
/**m/lm/A**\ /Ma*/B>B>/«l«kM\"'
At reported bi Tout. Peter, 1988^ US. EPA Tc*fca lnte|ntkM BnMMk, Mow* oa Updated RcfercMC Dom Md C
. , . , PatCMy heton for Uto ta Rtt AmmMM ( J^fc Tn«.
Peter. I988b. US. EPA. Toria lnle(ratkM BruKk, Penoul CoauiMkalkM wfth lUny EON, PRC EwiroMMMl MmiimrBl. be, (DecoMber 29, 1988); MM! HKMM* Lee, 1988,
Adminiuralor, US. EPA. Memo Re: AIWMC Potency Factor, Jwe 21.
i
-------
Table 20
RISK CHARACTERIZATION FOR INGESTION (O.lg/day and 3.0g/d«y)
BY CHILDREN OF CONTAMINATED SOILS FROM THE INDUSTRAIL PROPERTY
SURROUNDING THE CARTER INDUSTRIALS SITE FOR CARCINOGENIC
EFFECTS - MOST PROBABLE AND REALISTIC WORST CASES
INCREMENTAL CARCINOGENIC RISK1 ASSOCIATED
WITH ESTIMATED LIFETIME AVERAGE DOSE
Carcinogenic Industrials Property
Contaminant Potency2 Nature of
pfConcern fug/kg/dav)'1 Exposure O.lg/dav 3.Qg/dav
PCBs 7.7E-03 Most 7E-08 ' 2E-06
Probable
Case
Realistic 9E-08 3E-06
Wont
Case
Notes:
Refer to Table 3-10 for estimated lifetime doses.
1 Incremental carcinogenic risk - Estimated Lifetime Dose * Carcinogenic Potency
(ug/kg/day) (ug/kg/day)-f
2 As reported in Tong, Peter, 1988a, UJS. EPA, Toxics Integration Branch, Memo on
Updated Reference Doses and Cancer Potency Factors for Use in Risk Assessment (July);
and Tong, Peter, 1988b. U.S. EPA, Toxics Integration Branch, Personal Communication
with Harry Ellis, PRC Environmental Management, Inc. (December 29, 1988).
-------
RISK CHARACTERIZATION1 von omacr CONTACT BY anu>RBN wrm CONTAMMATBD SOILS
AT TIIB CARTER INDUSTRIALS SITE KM. NOKCARONOGBNsC OWCR
MOOT PROBABLE AND REALISTIC WORST CASDS
Contaminant
of Concern
frelalive absofPtfaiO
Acceptable
Docc
Waste Pita
Surface Solk
W*tte Pile* and Sarfwc Soik
MOST PROBABLE CASE-
Cadmium (14%) 1.006*00
Lead (2%) NA
(0.3%) NA
(17%) NA
6.72B02
IJ9B02
442B42
OJ
RBALICTIC WORST CASK
CMtmlui (14%)
Lead (2%)
PCBi
(03%)
(17%)
l.OOB+00
NA
NA
NA
9.10643
Motet:
Refer lo Tabk 3-11 for ettiMied dpomre doie*.
NA • None Avaibbk
Risk characterization for MMCiKteofe*ic effect* to presented at • Hazard Indei whick It the ratio of the ctttaaled eipot«c.dote to UM MtcpHMt AM.
Acceptable doie tor cadmiam - Allowabte hiakc - Oironic (AIQ a* presented te Tonf, Peter, 1988a, VS. EPA, Torica lnle(nliM Bnwk, MCMO
-------
MSK CHARACTERIZATION1 fOU OtMCT CONTACT BY ADULTS WR1I OJNTAMINATflD MNU
AT-no) CARTER INDUSTRIALS snB fan HOHCMONOOIMC macra
MOST PROBABLE AND REALISTIC WORST CASBS
Coaiaminui Acceptable itonl ladei , _
of Concern Dene I
frelalfrc absent fita/to/daw Wade PHea S.rf«e SoMi Wfitt IUCT «rf StlftB »•
MOST PROBABLE CASE:
Criminal (14%) I.OOBtOO 1.23B4I 3MB4U MJB4B
Uad (2%) NA
KBi • (0.3%) NA -
(17%) NA - -
REALISTIC WORST CASE:
Cadmium (14%) I.OOB+00 2JOB4I IUB-02
Lead (2%) NA
fCBi (OJ%) NA
(17%) NA
Notes:
Refer to Table 3-11 for estimated eipotan dotes.
NA- None Available
' Risk ckaracterizatioa for aoacardoofeak effects Is preseated as • Hazaid ladei wfcica It ike latto of Ike estimated opOMie do
2 Acceptable dote for cadmium - AUowabk Intake • Ouoafc (Alt) as presented at Tong. Peter. HWa, U& EPA, Todcs bMepMioa Braack, Messo on Updated Rcfeience Dotes
and Cancer Poteacjr Factor* for Use M Risk Assessment (July); and Tong, Peter, IM8b. VS. EPA. Torict Inlegntion Brancn, Petsoaal Commaalrttlon «itk Hany EMs, PRC
Environmeaul Minafcmeat, Inc. (December 29,1988).
-------
RISK aiARACiraUZAHON FOR NRBCT COKTACT (03%. 1.1% and 17% RBLA11VB ABSORPTION)
WmiOOrffAMWAlliDSOa^ AT TIIB CARTUR INDUSTRIALS STOro^
INCREMENTAL CARCINOGENIC RISK1 ASSOCIATED WITH ESTIMATED AVBRAOB DOSES
3
.1
ConlimiiMiH
CaiciMfenk
Potency1
Watte Piles
tut/kt/d«>V
,-1
MOST PROBABLE CASE
CDs 7.7B40
ACDiC IJB43
Toul CMcer Riik3
. lEAUSTIC WORST CASE:
VC»i 7.7B43
Ancnk 1JB49
Total Cancer Rbk3
relative abmplian
I.I* 17%
Open Altai
relative absorption
OJ% 1.1% 17% 0.3% 1.1% 17%
Wane Pita and Open Arm Combined
relative absorption
5B47 - 3E4S
_s. 2B4J8 _-_
5B47 3B-QS
7B4» - 4B06
^_ . 2B48 _=.
7B48 4B46
IB47
1B-07
2B4S
8BXM
8B4M
3&06 -
_=. 2B« -_
3B46 1B-04
3B-07 - IB4S
^_ 4BM _-_
3B47 IB-OJ
4BO7
4B-07
3&4»
2B4JS
2B-05
Refer to Table 3-13 tor estimated lifetime doses.
1. Incremental caicinogeak risk • Estimated Lifetime Dose • Oudnocenic Potency
(«(/k|/day) (»l/kC/day)''
2 As reported i* Tons; Peter. 198«a, US. EPA, Tones Integration Branch, Memo on Updated Reference Doses and Cancer Potency Factors for Use In Risk Assessment (July); and
Thomas Lee, 1988, Administrator, US. EPA. Memo Re: Anenk Potency Factor, June 21.
. ' i ' •
" Total anm riU'fcM calculated summing the aneak values with each PCB value.
-------
Table 24
RISK CHARACTERIZATION FOR DIRECT CONTACT
(0.3% and 17% RELATIVE ABSORPTION) WITH CONTAMINATED SOILS IN
THE NEIGHBORHOOD SURROUNDING CARTER INDUSTRIALS SITE
FOR CARCINOGENIC EFFECTS
INCREMENTAL CARCINOGENIC RISK1
ASSOCIATED WITH ESTIMATED AVERAGE DOSES
Industrials Property
Nature of Relative Absorption
Contaminant Exposure 0.3% 17%
PCBs2 Most 8E-08 5E-06
Probable
Case
Realistic IE-07 6E-06
Wont
Case
Notes:
Refer to Table 3-14 for estimated lifetime doses.
1 Incremental carcinogenic risk • Estimated Lifetime Dose * Carcinogenic Potency
(ug/kg/day) (ug/kg/day)M
2 Carcinogenic Potency (ug/kg/day)"1 for PCB • 7.7E-03; as reported in Tong, Peter, 1988a,
U.S. EPA, Toxics Integration Branch, Memo on Updated Reference Doses and Cancer
Potency Factors for Use in Risk Assessment (July); and Tong, Peter, 1988b. U.S. EPA,
Toxics Integration Branch, Personal Communication with Harry Ellis, PRC Environmental
Management, Inc. (December 29, 1988).
-------
SUMMARY OF SKJNIHCANT RISKS IDONUHnD FOR HID CARTOK BWUSITUALS sn«
CARONOGGNIC (CA) AND NONCARONOGBMC (NCA) OmCIS
InrreaMnfal
Associaled Carriaofenk
Enwsure Route CA/NCA Contaminants Risk Ratio Ranee Risk Ranee
Table 25
1. Inhalation of CA FCBs
Volatilized
Compounds
1 Infection of NCA Cwtahua
1 Ingettioaor CA FCBe
Soib (on-fite)
Aneak
4. Ingestionof CA FCBs
Soib (off-tile)
5. Direct Contact CA FCBs
with Soib
(oo-«fc)
6. Direct Contact CA FCBs
with Soib
(off-site)
MFC 4B-lllo1E4d
RWC IB-ID to 4B42
MFC 1 J5&02 to 1.44
RWC 3.3SE-02 to 2.70
MFC oBttlolBOS
RWC 6B4>to2B4B
MFC 3B09lo2B«7
RWC 5&09lo3B«7
MFC 7B«Blo2B4M
RWC 9B4BM3&06
MFCIE«7lo3B4)S
RWC 4B47 to 1B4M
MFC 8B48to5B46
RWC IB«7lo6B46
CoanneMs 1
SitnificaM eardnofeale risk on-dte (3B4M),
100 meten doMMind (4BO2) and IJOOO mcttn
dowtmiad (5B4M) Mder wricd cataioa) awl
Unacceptabti risk for pta bekavior !• both
•Mst probable awl «onl cases.
Total cudaofeaJc riski tsjaJOcMl fer pin
bchtmtoc oflly*
Moat proM* case and realistic woA case cudswtenk
risks sifMificsfll fof pics bclwvior osly*
Cardsofeak risks ajaodMeil «4th PCB» significaiM nider
both the snat probabk and icalistk wont case cowHtton*.
Realistk Wont Case: Risks saay wX be as
to localised iM-spotC is Milker/
Table
Rtftrn
5-2
5-3
54
»
54
5-f
Notes:
MFC • most probable case; RWC • icalistk wont case
-------
l"; " ;'"^'xT;- >i'&^?^^^
JJJORKBiBVAW
CARTER UtoUS*
ITANDAKDb REQUIREMENT
CRITERIA, UMrTATON
ALTEXNATIVI1
NO ACfWN
ALTCRNATIVEl
ON-OIC mclNERATKW
ALTERNATIVES
iN-tmi VITRIFICATION
ALTERNAT1VB4
rozzoLONic
MUDinCATION
ALTOWATIVII
ON-WTI KM LANDHU.
ALTERNATIVI*
aN-MTBRCMCAr
arum
TKALANOnU
<»w»u^c^^^i;ii^
STATI
Adoll9n(Acl307)
MkM|U>AifankiUnUv«Cod«,
Rukt299jlOIHMi|.
NA
NA
AktfMllnwouUhmto
dknlMtf PCB» it Iht lilt
SwAk«Mllv«2
•rTCLPTodcntariil
far tt lo mm Tjrpt B criteite
Olh*walono
NA
fhanral tract motfuiiM
would mnl ncuMnnon
tmhalonmndardaand
thai PCBa would not bt
NA
DbM not nwd
Woiin CDDi|rf)i with PCI
tnatBMrtanddiipMal
atandania.
Soup of FCBa
(UCFR7M45)
NA
haw lo pa dnvnatfatad to
boaaidvalanlto
Inctaamloii.
Would havttokt
dcmBiMtniojl to baondvalai
tiuaoAanl to Indnantjoiii
NA
tVwUhavotoot
ISCA nqubononl* for a
ChavfejIWaanLandBE
8atAlMmll*t2
NA
NtouM new to MM! •*
NA
SaaAhmalln2
SwAkaraall*«2
NA
WouU mot thkARAB,
SaaAkamatl««2
-------
STANDARD.
REQUIREMENT,
CRITERIA, LIMITATION
1YIRID ALTERNATIVE
Off SITE TSCAINdN-
KATOR AND LANDFIU
RCRA LANDFILL
HYBRID ALTERNATIVE
N-SITU vrmincATiar
orr SITE RCRA
LANDFILL
HYBRID ALTERNATIVE.)
OFT SITE RCRA INCINER-
ATOR AND LANDFIU.
RCRA LANDFILL
HYIRJDALTERNATIVI
onsmncA
INCINERATOR AND
LANDFILL
MYIRID ALTERNATIVE I
ZrittalFUUKnEXTRACnOf SOLVENT EXTRACTION,
OTF-SmTSCA AND RCRA
LANDFILLS
HYDRII ALTERNATIVE
OFF-SITE TSCA AND
RCRA LANDFILL
HYIRID ALTERNATIVE?
•»ip4l»n (LTTDL OFF-SITE
TSCA AND RCRA LANDFILL
STATE
Ad oil W (Ad 307)
Mkhlfin AdmkiUnllv* Cod*.
Rula 29*5101 tf MS.
SxAkimattwtl
SwAtamllral
SnAlunulInZ
SwAknMllnl
8wAhifmlhrt2
To>kSubiUnc<* Control Act
(I5U9CSKL2605.
2W7, Mil, 2614, MU)
ContnictkMi at MI Oiv«lli PCB
UndWl (40 CHI 7*1.75)
MldMfu Air Pollmlon Ad of 1965
(Ad Ml, Part 9)
NA
NA
SM njpHld AinvfHMVff I
NA
S« Hybrid AkinultM I
NA
NA
NA
NA
UndnUdUpoxIwouM
mccl emlMlon lUncUnk.
artist* **rt
oxitnliuida
MmUWnaidradlo
IndimUonolICB*
(40 CTR 7*1.70)
S«Akcm«ttT«2
muUkmtoto
MtotS
(40 CFH 7*1^0)
Would hm lo btriiown
Would hn«lab«
o
•IMS
(40 CPB 7*1^5)
Sonj. would blew
iptmiialilf gulddlnw.
SM Hybrid AktmllmS
Strlrtftnl mntrob would to
iluidanb.
SOT Hjrvnd AlvMtfw 5
S« Hybrid AltoMllMS
-------
f TANDARD, REQUIREMENT
CRITERIA, LIMITATION
Soud WaKe LVapoaal Act CSrVbAI
(U USC Section 6901-0987)
Standaida rorOwnera and Operator!
of Permitted Haurdoua Waate
Treatment, Storage, and Dfapoaal
fiKflM*jfMCrK264)
• Und Traatment (Subpart M 264.271,
J73.J76.J7a.ja3)
•Cleaura with No Port Ck»ure Care
CCkandoaure) (40CFR 264.111, .178,
.197, JS8)
•Cloaura of Und Treatment Unite
(40 Cra 264780)
•Capping/Wine In Place (40 CFR
264J5M>),JIO
-------
if ip^j'; ^"^"""^I^ ^"-""T1""" ""^>™°: ^^JI^^^^^W^'SS^CO^lMJEWi^ - s ;"* >&": * *\$* i: S : " ; ?a8e 4
SS^iSS '; 3ft ;^!^SS^^^MESSISSS^^LM^lfiV - ' vi; t ^ * ?:\ ? < ^ r ; * * ° ^ ;Vfc ,:
STANDARD,
REQUIREMENT,
CRITERIA, LIMITATION
Solid Waale DUpoul Act CSWDA")
(42 USC Section 6901-6987)
Standardi for Ownen and Opetatoi
of Permitted Haiardoui Watte
Treatment, Storage, and Diipotal
Fadlklee(40CFR264)
• Und Treatment (Subpart M 264.27
Qoturt with No Poet-CloiureCtre
(Clnnaoaure) (40CFR 264.111.
.178. .197, .258)
'Clonireof Und Trutmenl Urdu
(40 CFR 264.280)
• Capping/Wane In Place (40 CFR
2MJ58(b). JlOtaUi), .117(a»
•UndtlUa
(40CFR264JIO)
(40CFR264J41.J51,J40,
JU.J42.J45)
Und DUpoul Ratridloiu
(40 CFR 268)
Occupational Heakh and Safety Act
09 USC Sect 1910)
National Pollutant Dkdiarge Ellmln
Syetem (40 CFR Parta 122. 125)
ALTERNATIVE iOll
1YBRID ALTERNATIVE
OFF SITE TSCA INQN-
•RATOR AND LANDFILI
RCRA LANDFILL
NA
NA
See Alternative 2
See Alternative 4
See Alternative 2
See Alternative 2
See Alternative 2
See Alternative 2
See Alternative 2
-ALTERNAT1VE*0|{ '
IYBR1D ALTERNATIVE
N-SITU VITRIFICATION
OFF SITE RCRA
LANDRLL
Se« Alternative 3
See Alternative 3
See Alternative 2
NA
NA
Would have to be
demonitratedtobe
equivalent to
incineration.
See Alternative 2
See Alternative 2
See Alternative 2
AtfERfjATiViWOR '
HYBRID ALTERNATIVE )
OFF SITE RCRA INCINER-
ATOR AND LANDFILL.
RCRA LANDFILL
NA
NA
SeeAkematlve2
NA
SetAkernatlve2
SeeAkernathte2
SetAkernatlve2
See Alternative 2
See Alternative 2
ALTERNATIVE 11 OR
HYBRID ALTERNATIVE 4
OFF SITE TSCA
INQNERATOR AND
LANDRLL
NA
NA
See Alternative 2
NA
Set Alternative 2
See Alternative 2
See Alternative 2
See Alternative 2
See Alternative 2
ALTERNATIVE UOR
HYBRID ALTERNATIVE %
Critical FUU ten EXTRACTION
OFF-SITE TSCA AND RCRA
LANDFILLS
NA
Ckture of treatment unit
wouU meet thae
requirement.
See AkemaHvt.2
doaurt of treatment unit
would meet thew
requlremenla.
SetAkematlvt2
See Hybrid Alternative 2
SeeAkemative2
SeeAkematlvt2
SetAkemativt2
ALTERNATIVE UOR
HYDRIB ALTERNATIVE «
SOLVENT EXTRACTION,
OFF-SITE TSCA AND
RCRA LANDFILL
NA
See Hybrid Alternative 5
Set Alternative 2
Set Hybrid Alternative 5
Set Alternative 2
See Hybrid Alternative 2
Set Alternative 2
See Alternative 2
See Alternative 2
ALTERNATIVE 14 OR
HYBRID ALTERNATIVE 7
Low Temperature Thermal D»
eorpdon (LTTD), OFF-SITE
TSCA AND RCRA LANDFILL
NA
See Hybrid Akernative 5
See Alternative 2
See Hybrid Akernative 5
See Alternative 2
See Hybrid Akernative 2.
Stringent air emlulon
contrail would be required
to meet emlulon
•tindirdi.
See Alternative Z
See Alternative 2
See Alternative 2
-------
ll||Sjf f "^ -^ * ;^.^lvf>< ^ ^ ^ ^ s T ~ - v% > " '! * ^ ^B6 5
^ililii^^'** AV<$^ s **' % >»V\^*% '
/^w^'fy''' -^ fi>- " -^v : ' I ,&oi°* -s ^icj^iro^im^ils-lrtw^^ Slini?^
STANDARD, REQUIREMENT
CRITERIA, LIMITATION
STATE
Michigan Soil and Sedimentation
Control Act of 1972 (Ad 347)
Michigan Hazardous Waale Manageme
Ad of 1979 (Ad 64)
Michigan Solid Watte Act of 1978
(Ad Ml)
Michigan Water Reaourcea
Comml».lon Act of 1929 (Ad 245)
Michigan Environmental
Reaponae Act of 19(2 (Ad 307)
Michigan Admlnlatratlve
Code, Rule* 29JSI01 el aeq.
FEDERAL
New PCS Landfill
(40 CTR 741.75)
STATE
Michigan Soil and Sedimentation
Control Act of 1972 (Ad 347)
Michigan Haiardoua Waale Manageme
Act of 1979 (Act M)
ALTERNATIVE!
NO ACTION
NA
NA
NA
NA
NA
NA
.
NA
NA
NA
ALTERNATIVE!
ON-SITE INCINERATION
Controla would be
mplcmented to prevent
eroaion.
Material handling, thermal
treatment, and final dlapoae
would meet requirement*.
Material remaining on-*Ue
would be placed In cell bulk
according to theae rule*.
All dkchargee would be
monitored.
Compliance would be
achieved through
Implementation of a
remedial adlon.
Would not meet Type A or
Type B cleanup criteria
NA
Controla would be
Implemented to prevent
eroalon.
Realdualaolldbpoaalbi
an on-eke RCRA landBU
would not meet these
ALTERNATIVES
IN-SITU VITRIFICATION
See Alternative 2
ffflliiaMri ... j.jj. BlkJ!
stnn|cnl tionti ou and
confirmatory aampllng wouh
be nacaiaary to enaure that
material handling and thenru
requlmnenta.
SceAhematn>e2
See Alternative 2
. See Alternative 2
See Alternative 2
*'^«*s''^W** '
NA
See Alternative 2
Alternative would not meet
diauncerequinHnentator
Ireatment fadlitlea.
ALTERNATIVE*
POZZOLONIC
SOLIDIFICATION
SeeAkernative2
?!•!• i ••• nil H|I nil i il
Mrlngenl tiontfoli a nd
confirmatory umpling
would be necenary to
maun Hut material
handling and thermal
treatment would meet
MqulfVflMnra.
See Akeriutlve 2
See Akcrnatlve 2
S**Akeriutlve2
SeeAkernaUvt2
w»m*
NA
SeeAkernative2
On-*ke cap would not
meet requlrement>
^ *%S^^T^s4;«!^^*i*^^^*1"' > "
ALTERNATIVE*
ON-SITE RCRA LANDHLL
SeeAhematlve2
Material handling and
landfill would meet
requiremente.
SeeAHematlv*2
SeeAthrmalhre}
See Alternative 2
See Alternative 2
NA
See Alternative 2
On-aietandftB would no«
meet reqidrementa.
ALTERNATIVE*
ON-SITE RCRA CAP
See Alter native 2
Material handling and cap)
would meet requlrementi.
SeeAkcrnatlve2
See Aker native 2
SeeAkernatlve2
SeeAkematlve2
>m*w« * ^r^»
NA
SetAktrnathre2
SeeAkemalrve*
ALTERNATIVE 7
OFF-SITE
TSCA LANDHLL
See Alternative 2
See Alternative 5
See Alternative 2
Sea Alternative 2
Sea Alternative 2
See Alternative 2
sW* -*!f ,« *
NA
See Alternative 2
NA
-------
lAPPtt^B^ORRElBVAHTANDAFPROPJ
l^^^CARTER INDUSTRIALS SITB v "
'mSSSm ~"~ ^
"AltERNAttvluOR'
HYIRID ALTERNATIVE S
Mdal n«U Cn EKTRACnCM
OFMiranCA AND ROU
LANDFILU
STANDARD.
•eQUIIimENT,
OITEMA. UMITAHON
SID*
Mkfc%»SoUu%ui Solid Wu»t Act of 1971
(Ad Ml)
CommlMton Art of 1929 (Ad 24S)
MUitui Bnvlionmrtll
R»panM Ad of l«(2 (Ad 307)
Mkhlfin AdmbiWra
-------
STANDARD, REQUIREMENT
CRITERIA, LIMITATION
ALTERNATIVE!
NO ACTION
ALTERNATIVE!
ON-SITE INQNEIIATION
ALTERNATIVES
IN-SITU VITRIFICATION
ALTERNATIVE*
rOZZOLONIC
SOUDII (CATION
ALTERNATIVE 1
ON-SITE RCRA LANDFILL
ALTERNATIVE*
ON-SITE RCRA CAT
ALTERNATIVE 1
OFF-SITE
TSCA LANDFILL
Mtdi%«n Solid Wule Act of 1971
(Ad 641)
NA
boUtlondlXancn would
have lo be wilved or •
variance granod by Ihf
SMAhematlv«2
See Alternative 2
SeeAkernallvtl
See Alternative 2
PCB Spill Policy
(40CFR76ISubpirtC)
NA
UoOMldcnd,
alternative would b* In
oomplianot.
SeeAktmatlvtJ.
rraatmcnt IKhnotogy would
Wv» to b* dainoimraltd to
beoqulvalentto
Indnetatlon.
SvAKarnaUve}.
rnutmcnt technology
would have lo be
dcmonjintcdtobc
equivalent to
Incineration.
Orralte RCRA landau
would meet TSCA
dUpoMlrequlrementa.
OiMltt capping would
require a waiver of the
TSCA requirement! (or
a chemical WMU landfill.
Ofl-ahe TSCA landfill
would meet the TSCA
diepoaal requlrementa.
-------
STANDARD,
REQUIREMENT,
CRITERIA, LIMITATION
ALTERNATIVE I OR
4YMID ALTERNATIVE
Off SITE TSCAINCIN-
XATDR AND LANDFIU
ROLA LANDFILL
IVIRID ALTERNATIVE
N-IITU VITRIFICATION
onrunitCHA
LANDFILL
HVBRID ALTERNATIVE I
off sire RCRA INCINER-
ATOM AND LANDnU.
•OLA LANDFILL
KYI RID ALTERNATIVE 4
OFF SITE TfCA
INONERATOR AND
LANDHLL
HYBRID AITONATIVII
QMIol n«M IO) BXTBACIKW
OfF-im TKA AND ROU
LANDFILLS
HYDRII ALTERNATIVE t
SOLVENT EXTmACnOH
OFF-Sm TSCA AND
RCRA LANDFILL
HYIRID ALTERNATIVE 7
U* To^pmtan TkoMl D»
«MpdMi ttTTDL OFF-SITE
TSCA AND RCRA LANDFILL
MkM|M Solid WM(« Ad
-------
Table 27
COST COMPARISON
TOTAL PRESENT
2A.
1XXX) ing/kg: off-site TSCA Incinerator
50-1,000 mg/kg: off-site TSCA Landfill
10-50 mg/kg; off-site RCRA Landfill
$0
$42,732,032
$40,754,000
$55,599,000
$42,556X»0
$26XW6/432
$24,917,936
$39,762,688
$26720XXX)
$14,974,264
$12,995768
$27,840,520
$14797X08
$23y461XXX)
$3^62XX»
$3,884,000
$ljB05flOO
$22XV4XXX)
$50^08XX»
S16XXX)
Y«r M15,600;Yiw2-30»$8.900
'w 1«$12,600;Y«tf 2-30-S6.900
$0
$0
Y«r M12,600;Y««f 2-30^6,000
$0
$0
Y«r M1S.600:Y«ff 2-30^0.901
$0
$0
$0
Yearl- $22,000
Year 2-30- $16XXX)
Yearl- $22JOOO
Year 2- $18,100
Yearl- $22,000
Year 2-30- $16XXX)
$0
$0
S246JOQO
$43,167X100
$27X)50XX)0
$25X)30XXX)
$39,762^88
$15/128XXX)
$13,107XXX3
$27XM0420
$14,797,828
S23A61JOOO
$4,167XXX)
$22X«4XXX)
SSQJ08JOOO
-------
*
1
TABLE 37 (continued)
COST COMPARISON
fc
'$':,
&
) '/
'f'^'j
*%.*>&.
mi
?jj%
•w^
W4fc
w*»S
*S?
< f
*' S*
«£
-i'*t
x^
V£.
ip'
V*^s
'id
8fr
^
^
^v^ £
' * /J
V
f^^M^M'y/^:
', ;' -" VV/Aft^1^^ "ft /-' -V/^ '- ''-',
'?-v?";''^'^j^?^'^ V^"^" '%- f"''^*,/'
Hybrid Alternative 2
>50 mg/kg: In-situ Vitrification
10-50 mg/kg: off-site RCRA Landfill
Hybrid Alternative 3
>50 mg/kg: off-site TSCA Incinerator
10-50 mg/kg: off-site RCRA Landfill
Hybrid Alternative 4
>1,000 mg/kg: off-site TSCA Incinerator
10-1/XX) mg/kg: off-site TSCA Landfill
Hybrid Alternative 5
>IJOOO mg/kg: CF Systems Process
10-ljOOO mg/kg: CF Systems Process
Hybrid Alternative 6
>1,000 mg/kg: B.ES.T. Process
10-1/XX) mg/kg: B.E5.T. Process
Hybrid Alternative 7
Low Temperature Thermal Desorption
Additional Cost for Subtitle D Containmen
Quicklime Treatment
'^£CM&L
,:' •\/'>'CQSTS ^'| i
; r'A'"'\v^ ;!. ^'
S20344XXX)
$100718^00
$51797^00
$49,402,000
$20342XXX)
$19^08XX»
$1X)11X)00
$3^62^00
^c^nc^'
"MAINTENAN'CE'
^r* '">••."-'. ;-'A "? -
$0
$0
$0
$0
$0
$0
$0
$0
t^tl^SE^
" WORTH ST;j
'*&'' V'-i" -'' "^
$20344^00
$100,718^00
$51797XX»
549,402^)00
$20342,000
$19,508,000
$1X)HXXX)
$3^62XX)0
'% * ,-*&>'*» ^«^^^^^^^^fe4^^te^4 ' - '•> X *** 5 ',-,"" ^. i. -•?',' s?^«'1> ,') „,-# ^f^^^sK' 'S^*' '"> ' :
29 ^J J, • J» JHUVl iCXM Jt ^flli.Ky TMTWT^^ t". fj^T F^^tiSil;Tj»yjfc it Jt^f jPr f "" % "' ^ ^ •, \ > ^w % f f £ Jy%£' A v / '^ s *
i ^"^iv v«, W^f*M»^^^^^^H|i*y*'''ft^t, Jt'i'* ^ f^f/ w ' < ' '^v^^.-*"%%'^' C^X*' '?''^' ' '*' ' ' s"»J%A' ' f , * /4?>'~tJ
•v •* ^ -i/ ** ,•• •-w3"f^3^. ^xv'&'''- <• '<• ^? &**&/#•, <^f v f ff ^ 'j'^xy J ^ ' ftt ff fff "" ''f-.''
A Decontamination/Demolition of $512^00
Qn-Site Buildings
B Runoff Collection and Treatment $2,800
System O&M (Monthly Cost)
------- |