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Record of Decision System (RODS)

CARTER INDUSTRIALS, INC.

Abstract

Site Name:  CARTER INDUSTRIALS, INC.
Address:  4690 HUMBOLDT 
City & State:  DETROIT  MI  48208
County:  WAYNE
 
EPA ID:  MID980274179
EPA Region:  05
 
NPL Status:  Deleted from the Final NPL
 
ROD Type:  Record of Decision
ROD ID:  EPA/ROD/R05-91/169
ROD Date:  09/18/1991
Operable Unit(s):  01
 
Media:  SOIL DEBRIS
 
Contaminant:  ORGANICS, PCBS, METALS, ARSENIC, CADMIUM, LEAD
 
Abstract:  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 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.
 
Remedy:  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;
* EXCAVATION OF ALL ON-SITE AND OFF-SITE SOILS CONTAMINATED WITH PCBS AT LEVELS OVER 1 MG/KG;
* 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.
* 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 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 CONTAINING LESS THAN 10 MG/KG PCB AFTER TREATMENT. OFF-SITE DISPOSAL IS REQUIRED FOR ANY MATERIAL NOT MEETING THE CRITERIA FOR ON-SITE CONTAINMENT;
* 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 II SANITARY LANDFILLS.
* 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.
* DECONTAMINATION AND DEMOLITION OF THE THREE CONTAMINATED BUILDINGS ON THE SITE. THE DECONTAMINATED DEMOLITION DEBRIS WILL BE CONTAINED IN THE ON-SITE CONTAINMENT CELL;
* REMOVAL OF AN UNDERGROUND STORAGE TANK (UST) AND ITS CONTENTS IN ACCORDANCE WITH THE MICHIGAN UST REQUIREMENTS;
* MAINTENANCE OF ALL EXISTING SITE SAFETY MEASURES, INCLUDING FENCE, SECURITY GUARDS, OPERATION AND MAINTENANCE OF SURFACE WATER RUNOFF COLLECTION AND TREATMENT SYSTEM DURING REMEDIAL ACTIVITIES.
 
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