PB97-963122
EPA/541/R-97/062
November 1997
EPA Superfund
Record of Decision Amendment:
Recticon/Allied Steel Corp.,
East Coventry Twp., PA
8/29/1997
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RECORD OF DECISION AMENDMENT
RECTICON/ALLIED STEEL SUPERFUND SITE
DECLARATION
SITE NAME AND LOCATION
Recticon/Allied Steel Superfund Site
Parker Ford, Chester County, Pennsylvania
STATEMENT OF BASIS AND PURPOSE
This decision document presents the amended final selected remedial action for the
Recticon/Allied Steel Superfund Site ("the Site"). The original remedial action selected in the
Record of Decision ("ROD") issued by EPA in June 1993 and the amended remedial action
selected in this ROD Amendment were 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 the National Oil
and Hazardous Substances Pollution Contingency Plan ("NCP"). This ROD Amendment is
based on the Administrative Record for the Site.
The Commonwealth of Pennsylvania has assisted EPA in the review of reports and Site
evaluations for the Site. The Commonwealth concurs with this ROD Amendment.
ASSESSMENT OF THE SITE
Pursuant to duly delegated authority, I hereby determine pursuant to Section 106 of CERCLA,
42 U.S.C. § 9606, that actual or threatened releases of hazardous substances from this Site, if not
addressed by implementing the response action selected in this Record of Decision Amendment
("ROD Amendment"), may present an imminent and substantial endangerment to the public,
health, welfare, or environment.
DESCRIPTION OF AMENDED SELECTED REMEDY
In a June 1993 ROD, EPA required the following actions to be taken to address contamination at
the Site in accordance with CERCLA and the NCP:
Installation of a Municipal Waterline.
Excavation and Off Site Disposal of Contaminated Soils.
Extraction & Treatment of Ground Water with Discharge to the Schuylkill River.
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Long-Term Ground Water Monitoring.
Verification Sampling to Determine the Source and Extent of Copper and Zinc.
Performance of a Phase I Archeological Survey.
This ROD Amendment modifies only two of the above elements:
Ground water performance standards will be MCLs. The contaminated ground water
plume will be pumped and treated until MCLs for the contaminants of concern, including,
trichloroethene, tetrachloroethene, vinyl chloride, 1,1 dichloroethene, 1,2 dichloroethane,
and 1,2 dichloroethene, are achieved.
Excavation with off-Site disposal of contaminated soil is no longer required. However,
EPA is requiring that institutional controls be implemented to prohibit soil excavation on
the Recticon property and prohibit any new wells on the property until ground water
performance standards are met.
This ROD Amendment does not modify the remaining requirements under the June, 1993 ROD.
Construction and operation of the ground water extraction and treatment system to prevent
contaminated ground water from entering the Schuylkill River, installation of the waterline, long
term monitoring, verification sampling for copper & zinc and a phase I archeological survey are
still required.
STATUTORY DETERMINATIONS
The amended selected remedy is protective of human health and the environment and is cost
effective. EPA believes that the amended selected remedy will comply with all Federal and State
requirements that are legally applicable or relevant and appropriate to the remedial action. The
amended selected remedy utilizes a permanent solution to the maximum extent practicable and
satisfies the statutory preference for a remedy that employs treatment that reduces toxicity,
mobility, or volume.
Because this amended remedy will result in hazardous substances remaining onsite above health-
based levels, a review by EPA will be conducted within five years after initiation of the remedial
action to ensure that the remedy continues to provide adequate protection of human health and
the environment.
Abraham Ferdas, Acting Director Date
Hazardous Waste Management Division
Region III
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Record of Decision Amendment
for the
Recticon/Allied Steel Site
Parker Ford, Pennsylvania
BACKGROUND
The U.S. Environmental Protection Agency ("EPA") is issuing this Record of Decision
Amendment to memorialize changes to the Record of Decision ("ROD") issued in June 1993 for
the Recticon/Allied Steel Superfund Site ("Site") located in East Coventry Township, Chester
County, Pennsylvania. EPA is making two changes to the 1993 ROD: (1) replacing excavation
and off-site disposal of contaminated soil with institutional controls limiting future use of the
Recticon property; and (2) changing the ground water clean up standards to the Maximum
Contaminant Limits ("MCLs") established under the Safe Drinking Water Act 42 U.S.C. § §
300f-300j-26
This ROD amendment summarizes information obtained from the Remedial Investigation
and Feasibility Study ("RI/FS") completed for the 1993 ROD, and relevant information obtained
since then, to explain the need for the changes.
The Recticon/Allied Steel Site consists of two properties located on the northwest and
southeast corners of the intersection of Route 724 and Wells Road in Parker Ford, PA (see
Figures 1 & 2). From 1974 to 1981, the Recticon Corporation, a subsidiary of Rockwell
International Corporation manufactured silicon wafers for the semiconductor industry on one of
the properties. A customized, pressurized steel vessel fabricating business was operated until
1988 at another portion of the Site owned by Allied Steel since 1970.
In the 1993 ROD, EPA required the following actions to be taken to address
contamination at the Site in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended by the Superfund Amendments and
Reauthorization Act of 1986, U.S.C. § 9601 el al ("CERCLA"), and the National Oil and
Hazardous Substances Pollution Contingency Plan ("NCP"):
Installation of a Municipal Waterline.
Excavation and Off Site Disposal of Contaminated Soils.
Extraction & Treatment of Ground Water with Discharge to the Schuylkill River.
Long-Term Ground Water Monitoring.
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Verification Sampling to Determine the Source and Extent of Copper and Zinc.
Performance of a Phase I Archeological Survey.
A Responsible Party ("RP") has been complying with an EPA Unilateral Administrative Order
("UAO") issued on March 24, 1994 to implement the 1993 ROD.
This ROD Amendment modifies only two of the above elements: the requirement to
excavate and dispose off-site of a small volume of soil on the former Recticon portion of the Site,
and the requirement to achieve background levels as the ground water clean up performance
standards in accordance with the relevant and appropriate Pennsylvania Department of
Environmental Protection ("PADEP") requirements at the time of the 1993 ROD. This Proposed
ROD Amendment does not modify the remaining requirements under the 1993 ROD.
Construction and operation of the ground water extraction and treatment system to prevent
contaminated ground water from entering the Schuylkill River, installation of the waterline, long
term monitoring, verification sampling for copper & zinc and a phase I archeological survey are
still required.
REASONS FOR ISSUING ROD AMENDMENT
Ground Water Performance Standards
At the time EPA issued the 1993 ROD, the Agency considered MCLs, the maximum
permissible level of contaminants allowed in water delivered to any user of a public water
system, to be appropriate ground water performance standards. However, since the
Commonwealth had more stringent standards in place, the ground water performance standards
in the 1993 ROD were based on the Commonwealth's requirements. Under Section 264.97(1)
and (j) and 264.100(a)(9) of Title 25 of the PA Code, the Commonwealth required ground water
to be cleaned up to "background" levels. Since that time, the Commonwealth's requirements
have changed. On May 19,1995, Governor Ridge signed into law the Land Recycling and
Environmental Remediation Standards Act ("Act 2"). Act 2 became effective on July 18, 1995
and established MCLs as the protective ground water performance standards to be used in the
Commonwealth of Pennsylvania. Based on this change, EPA is hereby revising the ground
water performance standards from "background" to MCLs, which EPA had previously
determined to be protective of human health.
Table 1 lists the "background" ground water performance standards identified in the 1993
ROD and the MCLs which will be the new ground water extraction and treatment performance
standards. The "background" levels listed represent the detection limits for the analytical
methods to be used to measure the concentration of the contaminants present in the ground
water.
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Table 1.
MCLs and 1993 ROD Background Performance Standards
tetrachloroethylene
0.03
601/602
trichloroethylene
0.12
601/602
vinyl chloride
0.18
601/602
1,1 - dichloroethylene
0.13
601/602
1,2 dichloroethane
0.03
601/602
cis-1,2-dichloroethy lene
70
0.12
524.2
1 Method 601/602 40 CFR Part 136
Method 524.2 40 CFR Part 141
Soil Performance Standards
Since no applicable or relevant and appropriate requirements ("ARARs") existed to
establish the appropriate cleanup level for soils at the Site, the soil performance standards in the
1993 ROD were based on the amount of contamination that could remain in the soil without
further contributing to ground water contamination above "background" concentrations. Hence,
the Commonwealth's background ground water cleanup standards were also used to develop the
soil performance standards set forth in the 1993 ROD. Modeling was performed during the
Feasibility Study to determine the appropriate residual soil concentration. Based on this
modeling, a soil performance standard was established requiring excavation of soil with
concentrations of trichloroethylene ("TCE") above 320 parts per billion ("ppb"). The estimated
TCE concentration that could remain in soil without resulting in ground water contamination
above the MCL, using the same modeling approach, is 1,600 ppb.
,0
The Remedial Investigation for the 1993 ROD identified one sampling location, R/A7,
(see Figure 3) on the former Recticon portion of the Site with elevated levels of TCE in the
subsurface soil. The levels of TCE identified in that sample were 1,400 ppb, respectively,
whereas the estimated TCE concentration that could remain in soil without resulting in ground
water contamination above MCLs is 1,600 ppb, as stated above. Therefore, if MCLs are used in
the modeling to determine the appropriate residual soil concentrations, no cleanup action is
required for subsurface soil. Accordingly, this ROD Amendment eliminates the requirement in
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the 1993 ROD to excavate soil from the Recticon portion of the Site and dispose it off-site. EPA
is requiring that institutional controls be implemented to prohibit soil excavation on the Recticon
property in the vicinity of the soil sample location R/A7 and prohibit any new wells on the
property until ground water performance standards are met. The controls will be implemented
through deed restrictions, and/or other appropriate means. In addition, EPA will reevaluate soil
alternatives if, during the Five Year Review, EPA determines that the soil in the area of R/A7 is
acting as a continuing source of ground water contamination and is preventing the achievement
of ground water performance standards.
COMPARATIVE ANALYSIS
EPA evaluated the remedy selected in the 1993 ROD and the amended remedy selected in this
ROD Amendment against the nine criteria specified in the NCP. These nine criteria are
categorized into three groups: threshold criteria that must be satisfied for a cleanup plan to be
considered further; primary balancing criteria used to weigh the tradeoffs or advantages and
disadvantages of the alternatives; and modifying criteria used to consider input from the state
and local community. Each of the nine criteria are described below:
Threshold Criteria:
Overall protection of human health and the environment: Whether the remedy provides
adequate protection and how risks posed through each pathway are eliminated,
reduced, or controlled through treatment, engineering controls, or institutional
controls.
Compliance with applicable or relevant and appropriate requirements ("ARARs"):
Whether or not a remedy will meet all ARARs of Federal and State environmental
statutes and/or whether there are grounds for invoking a waiver. Whether or not the
remedy complies with advisories, criteria and/or guidance that may be relevant.
Primary Balancing Criteria:
Long-term effectiveness and permanence: The ability of the remedy to afford long
term, effective and permanent protection to human health and the environment along
with the degree of uncertainty that the alternative will prove successful.
Reduction oftoxicity, mobility, or volume through treatment: The extent to which the
alternative will reduce the toxicity, mobility, or volume of the contaminants causing the
Site risks.
Short-term effectiveness: The short-term risk or impact to the community, on-site
workers, and the environment that may be posed during construction and
implementation of the alternative.
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Implementability: The technical and administrative feasibility of a remedy, including
the availability of materials and services needed to implement that remedy.
Cost: Includes estimated capital, operation and maintenance, and net present worth
costs.
Modifying Criteria:
State Acceptance: Whether the State concurs with, opposes, or has not commented on
the preferred remedial alternative.
Community Acceptance: Whether the public agrees with the preferred remedial
alternative (this will be assessed in the Record of Decision following a review of the
public comments received on the Administrative Record and the ROD Amendment).
The following summary discusses the changes to performance standards and
elimination of soil excavation called for in this ROD Amendment in terms of the nine
evaluation criteria, noting how these changes compare to the originally selected remedy.
Overall Protection of Human Health and the Environment
The remedy selected in the 1993 ROD and the revised remedy called for in this ROD
Amendment meet the established remedial action objectives of the 1993 ROD, and achieve
carcinogenic risks within or below EPA's target risk range (i.e., IxlO"4 to IxlO^. The remedial
investigation indicates that the contaminated soils are located nine (9) to eleven (11) feet below
the ground surface and are at levels that do not pose a human health risk based on dermal contact
and ingestion. However, rainfall infiltration into soils can cause hazardous substances to
continue to leach into the ground water. Because of this possibility, EPA developed a soil clean
up level which would protect human health by removing contaminated soil that had the potential
to cause unacceptable ground water contamination. Since ground water that meets MCLs is
protective of human health, a soil cleanup level of 1,600 ppb for TCE is protective in that it will
not prevent the restoration of ground water to MCLs in a reasonable time frame. Institutional
controls such as deed restrictions to prevent any future excavation of soil on the Recticon
property provide an additional level of protection in the long term by preventing any possible
exposure to contaminated soil.
Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
CERCLA requires that remedial actions meet ARARs of other federal and state
environmental laws, or that there be grounds for invoking a waiver. These laws may include, but
are not limited to, the Toxic Substances Act, the Clean Water Act, the Safe Drinking Water Act,
and the Resources Conservation and Recovery Act. A "legally applicable" requirement is one
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which would directly apply to the response action. A "relevant and appropriate" requirement is
one that, while not "applicable", is designed to apply to problems sufficiently similar that their
application is appropriate
At the time of the 1993 ROD, the Commonwealth of Pennsylvania identified Section
264.97(1) and 0) and 264.100(a)(9) of Title 25 of the PA Code as an ARAR for the Site. Under
the NCP, EPA is required to consider state ARARs that are more stringent than federal
requirements. Since the Commonwealth regulations required that ground water be cleaned up to
a more stringent level, the ground water and soil performance standards in the 1993 ROD
conformed to these more stringent standards. For this ROD Amendment, PADEP has identified
the Land Recycling and Environmental Remediation Standards Act, 95 Pa. Laws 2 ("Act II"), as
an ARAR for this remedy; however, EPA has determined that Act II does not on the facts and
circumstances of this remedy, impose any requirements more stringent than the federal standards.
Accordingly, ground water cleanup Maximum Contaminant Levels and non-zero Maximum
Contaminant Level Goals as set forth in accordance with Section 300g-l of the Safe Drinking
Water Act, 42 U.S.C. Section 1412, and its implementing regulations at 40 C.F.R. Part 141 are
relevant and appropriate. Therefore, both the 1993 ROD remedy and the revised remedy
recommended in this ROD Amendment comply with ARARs.
Long-Term Effectiveness and Permanence
Both the 1993 ROD remedy and the remedy recommended in this ROD Amendment will
provide long-term effectiveness and permanence. The remedial investigation indicates that the
contaminated soils are located nine (9) to eleven (11) feet below the ground surface and are at
levels that do not pose a human health risk based on dermal contact and ingestion. However,
institutional controls such as deed restrictions to prevent the excavation of soil in this location in
the future will provide an inexpensive additional level of protection in the long term by
preventing the soil from reaching any potential receptors in the future. EPA's preference to use
treatment to address the principle threats is met by the treatment of ground water as discussed
under the ground water alternatives in the 1993 ROD.
Reduction of Toxicity, Mobility or Volume through Treatment
Both the 1993 ROD remedy and the remedy changes described in this ROD Amendment
will reduce the toxicity, mobility and volume of contaminants in ground water at the Site through
ground water extraction and treatment. While the 1993 ROD remedy also required excavation
and off-site disposal of soil with TCE concentrations exceeding 320 ppb, contaminants present in
the soil would not have been treated to reduce the toxicity, mobility or volume. Therefore, the
1993 ROD remedy does not provide any significant increase in the reduction of toxicity, mobility
or volume through treatment than the revised remedy.
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Short-term Effectiveness
The remedy changes in this ROD Amendment offers a greater degree of short-term
effectiveness than the 1993 ROD remedy because short-term risks associated with excavation
and transportation of contaminated soil are avoided. However, the short-term risks associated
with excavation could be readily controlled, so both remedies are effective in the short term.
Implementability
The remedy changes in this ROD Amendment can be implemented more readily than the
1993 ROD remedy for two reasons. First, extraction and treatment of ground water to achieve
MCLs may be more attainable than treatment to "background." Second, the revised remedy no
longer requires soil excavation and off-site disposal.
Cost
The remedy changes in this ROD Amendment avoids the cost associated with soil
excavation and off-site disposal required under the 1993 ROD remedy. The estimated present
worth cost for these activities in the 1993 ROD was $40,261. The revised costs would be those
costs associated with obtaining the appropriate deed restrictions.
State Acceptance
PADEP has assisted EPA in the review of reports and Site evaluations for the Site. The
Commonwealth concurs with this ROD Amendment.
Community Acceptance
EPA issued a Proposed ROD Amendment on January 31,1997. The Proposed ROD
Amendment was announced in local newspapers, as well as through distribution of the Proposed
ROD Amendment to all parties on EPA's mailing list for the Recticon/Allied Steel Site. The
official comment period on the Proposed ROD Amendment extended from January 31,1997
through March 1, 1997. A public meeting on the Proposed ROD Amendment was held on
February 13,1997 at the East Coventry Township Building, East Coventry, Pennsylvania. The
limited number of comments received orally at the public meeting and in writing during the
public comment period are referenced in the Responsiveness Summary attached to the ROD
Amendment.
In summary, the revised changes in this ROD Amendment provide the best balance of
trade-offs among the alternatives evaluated with respect to the nine criteria above. Based on the
information available at this time, EPA believes the revised remedy would protect human health
and the environment, would comply with ARARs, and be cost-effective.
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ROD AMENDMENTS
Ground water performance standards will be MCLs. The contaminated ground water
plume will be pumped and treated until MCLs for the contaminants of concern are
achieved.
Excavation with off-Site disposal of contaminated soil in the area of sampling location
R/A7 is no longer required. However, EPA is requiring that institutional controls be
implemented to prohibit soil excavation on the Recticon property in the vicinity of the
soil sample location R/A7 and prohibit any new wells on the property until ground water
performance standards are met. The controls will be implemented through deed
restrictions, and/or other appropriate means. In addition, EPA will reevaluate soil
alternatives if, during the Five Year Review, EPA determines that the soil in the area of
R/A7 is acting as a continuing source of ground water contamination and is preventing
the achievement of ground water performance standards.
In accordance with Section 117 of CERCLA, 42 U.S.C. § 9617, the ROD Amendment,
and background documentation for the Recticon/Allied Steel Site are available to the public in
the Administrative Record. In accordance with Section 300.825 (a) (2) of the NCP, this ROD
Amendment will become part of the Administrative Record File. For a detailed description of
the Site background and Site characteristics, see the 1993 ROD, Feasibility Study (" FS"), and
this ROD Amendment. The Administrative Record is available for review at the following
locations:
East Coventry Township Building U.S. EPA Region III
855 Ellis Woods Road 841 Chestnut Bldg.
Pottstown, Pennsylvania 19465 Philadelphia, PA 19107
(215)566-3157
Contact: Anna Butch
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SITE LOCATION
Recticon/Allied Ste<
REFERENCE: USGS 7.5 Minute Quadrangle; Phoenixville, Pennsylvania, 1983.
DAMES & MOORE
SITE LOCATION MAP
Recticon / Allied Sleel Site
Parker Ford, Pennsylvania
MARCH 1993
10839-126-032 SJR 9/28/92 SITE. 1
FIGURE 1
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OM V*n (OV)
CKcft BMkt (CB)
MOORH
srre LAYOUT
MAPCHIW?
1CWM3«-032 SJfl WS*W LAYOUT
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CKMCS* MOORE
SOIL BORING LOCATIONS
MARCH 1993
SJR «
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APPENDIX A
RESPONSIVENESS SUMMARY
FOR THE RECORD OF DECISION AMENDMENT
AT THE
RECTICON/ALLIED STEEL SUPERFUND SITE
PARKER FORD, PENNSYLVANIA
Public Comment Period:
JANUARY 31,1997 thru MARCH 1,1997
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RECTICON/ALLIED STEEL SUPERFUND SITE
RESPONSIVENESS SUMMARY
FOR THE
PROPOSED ROD AMENDMENT
Overview
On January 31,1997, EPA announced the opening of the public comment period and
published its proposed ROD Amendment for the Recticon/Allied Steel Site, located in Parker
Ford, Chester County, Pennsylvania.
EPA evaluated the proposed ROD Amendment giving consideration to nine key evaluation
criteria:
Threshold criteria, including;
Overall protection of human health and the environment;
Compliance with Federal, state, and local environmental
and health laws;
Balancing criteria, including;
Long-term effectiveness and permanence;
-Reduction of mobility, toxicity, or volume of
contaminants;
-Short-term effectiveness;
Ability to implement;
Cost; and
Modifying criteria, including;
State acceptance; and
-Community acceptance.
EPA carefully considered state and community acceptance of the proposed ROD Amendment
prior to reaching the final decision regarding the remedy.
The Agency's Final ROD Amendment is outlined below.
Ground water performance standards will be Maximum Contaminant Levels ("MCLs").
The contaminated ground water plume will be pumped and treated until MCLs for the
contaminants of concern are achieved.
Excavation with off-Site disposal of contaminated soil in the area of sampling location
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R/A7 is no longer required. However, EPA is requiring that institutional controls be
implemented to prohibit soil excavation on the Recticon property in the vicinity of the
soil sample location R/A7 and prohibit any new wells on the property. The controls will
be implemented through deed restrictions, and/or other appropriate means. In addition,
EPA will reevaluate soil alternatives if, during the Five Year Review, EPA determines
that the soil in the area of R/A7 is acting as a continuing source of ground water
contamination and is preventing the achievement of ground water performance standards.
A public comment period on the proposed ROD Amendment was held from January 31,1997 to
March 1, 1997. In addition, a public meeting was held on February 13, 1997. At this meeting,
representatives from EPA answered questions about conditions at the Site and the proposed ROD
Amendment under consideration.
SUMMARY OF COMMENTORS' ISSUES AND CONCERNS
This section provides a summary of commentors* issues and concerns, and expressly
acknowledges and responds to those raised by the local community. The issues and concerns
about the proposed ROD Amendment for the Recticon/Allied Steel Site received at the public
meeting on February 13, 1997, and during the public comment period.
A citizen asked if the ground water treatment system would restore the ground water to
maximum contaminant levels more quickly if the soil excavation in the area of sampling
location R/A 7 was still required?
EPA response:
Excavating the soil in the area of sampling location R/A7 would not allow faster
restoration of the ground water at the Site. EPA shares citizens' interests in accelerating ground
water clean up. However, based on modeling performed during the Feasibility Study, water
moving through the contaminated subsurface soil would not transport unsafe levels of
trichloroethylene to the ground water. The contaminants to be treated in the ground water
extraction and treatment system are already present in the ground water beneath the Site. EPA
has estimated that 25-30 years will be required to reduce the contaminant levels in the existing
plume to the ground water standards. Predicting the actual time required to clean up ground
water is difficult. Although EPA has not revised the estimated time frame for cleanup, the
revised ground water treatment performance standards could be attainable earlier than the
original "background" levels in the 1993 ROD.
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A citizen asked what cost savings there would be as a result of the proposed ROD
amendment changes. The citizen also inquired as to who was actually realizing the cost
savings.
EPA Response:
The remedy changes in the proposed ROD Amendment avoids the cost associated with
soil excavation and off-site disposal required under the 1993 ROD remedy. The estimated
present worth cost for these activities in the 1993 ROD was $40,261. A potentially responsible
party is currently implementing EPA's selected remedy for the Recticon/Allied Steel Site under
an Administrative Order an would, therefore, realize the cost savings. The potentially
responsible party is currently bearing all costs associated with implementing EPA's selected
remedy with the exception of EPA's costs to oversee their work. However, if the potentially
responsible party would stop implementing the selected remedy, or if EPA felt the potentially
responsible party was not conducting work properly, EPA would take over implementation of the
selected remedy. EPA would use funds from the federal SUPERFUND trust fund to implement
the remedy.
Comment of Hamburg, Rubin, Mullin, Maxwell & Lupin on behalf of ffighview Gardens,
Inc: ffighview Gardens, Inc. opposes any amendment to the ROD which will allow any
contaminated soil to remain on its property and which will in any way limit the future use
of this property through a Deed Restriction and/or other means.
EPA Response:
The proposed changes in the ROD Amendment provide the best balance of trade-offs
among the alternatives evaluated with respect to the nine criteria EPA uses to evaluate clean up
alternatives. Based on the information available at this time, EPA believes the revised remedy
would protect human health and the environment, would comply with ARARs, and be cost-
effective.
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