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5.2.3 Institutional Criteria Typically, off-site disposal of hazardous waste involves a greater effort, in terms of institutional requirements, than a cleanup action. Disposal of contaminated sump contents would require manifestation of the waste and a substantial lead time (4-6 weeks) for permit requirements. Therefore, the cleanup alternative is rated higher than the demolition alternative for all three areas. Closure of sumps after cleanup operations involve closure plan requirements and, therefore, reuse of the facilities after a cleanup scores higher than the abandonment option for all areas. 5.2.4 Environmental and Public Health Criteria Reuse of a contaminated facility is possible if it can be cleaned up to levels of contamination that do not pose a hazard to the environment or human health. Facilities planned to be abandoned in place also need to be decontaminated to the same extent for environmental and human health protection. This requires documenting that the alternative minimizes both short and long term effects of any residual contamination and protects the public and the environment after implementation of the alternative. Demolition of a contaminated structure and disposal of its debris at a permitted TSD facility affords the most protection of the environment. This removal action alternative provides a chance for the removal of all contamination associated with the structure, and any contaminated soil surrounding the structure. However, demolitions result in the generation of hazardous waste in the form of debris that poses a certain amount of risk to the environment and public health during transportation to disposal at an off-site TSD facility. Demolition, therefore, is ranked at a high 3.5, but not a perfect 4.0, in environmental and public health criteria. The environmental and public health rating for a cleanup action alternative can vary from fair to excellent, depending on the physical condition of the structure involved and the extent of exposure of its surfaces to contamination. Following a cleanup operation, a decontaminated concrete structure can be recontaminated over a period of time due to the migration of contaminants from surrounding contaminated soil or deep recesses of the cement. For example, relatively high concentrations of PCBs (52 to 370 ppm), Cd (1.3 ppm), and lead (50 ppm) in the sump contents in Area A suggest permeation of these contaminants into the concrete matrix. This indicates a potential for the contaminants to leach out back into the sump, after the sump is cleaned and reused/abandoned. Therefore, a cleanup operation in Area A is rated lower than the demolition option. Also, the cleanup rating in Area A is lower than the cleanup ratings for Areas C and J, due to the higher extent of contamination and exposure in Area A. 19