Memorandum
To:    Dave Novak, EPA
From:  Mike Baker, COPA
Date:  January 30, 1995
Re:    Comments on the ABB Expedited Remediation Proposal


  We are in favor of an expedited remediation of ABB.

  Transportation by rail to USPCI is, in general,  an acceptable
  remedy for the PCB-bearing soil.  However, there are a number
  of other remedies commercially available and demonstrated at
  full scale that result in permanent reduction in volume,
  mobility and/or toxicity.

  We are not in favor of switching from Superfund to TSCA until,
  and unless, the proposed TSCA revisions are in effect.  The
  reason that the Superfund process has performed rather poorly
  at the other seven Bloomington sites is not due to the
  procedures and safeguards of Superfund, but due to the Consent
  Decree.  If an expedited remediation of ABB is desired, it is
  not necessary to abandon Superfund and allow private
  remediation under TSCA to do so.  An EE/CA could be prepared
  for the ISF at ABB within two months, and several more months
  would be required for public comment and administrative tasks
  on the part of EPA.

  If EPA abandons the EE/CA-public comment process now in favor
  of private cleanup by Westinghouse under the current TSCA
  regulations, the message sent to the community will be very
  damaging. If the ISF at ABB can be disassociated from the
  other Bloomington PCB waste for purposes of implementing an
  expedited remedy under TSCA, then the ISF at ABB can be
  similarly disassociated from the other sites when performing
  an EE/CA under Superfund.

  It is essential not to shortcut the regulatory procedures that
  currently apply (EE/CA) given the level of public involvement
  and general dissatisfaction.  It is likely that an EE/CA will
  conclude that transport by rail to USPCI is an appropriate and
  cost effective remedy, but the EE/CA will also document, for
  the benefit of all parties and the public, the advantages and
  disadvantages of alternatives.

  The volume of soil stockpiled at the ISF is sufficient for
  several promising alternative technologies  to be cost
  competitive with landfilling, and they offer the advantage of
  reduction of waste volume, mobility or toxicity.

  Table 1 lists several technologies which have been
  demonstrated at full-scale for PCB treatment.  Cost data is
  detailed in Table 2.   The features of the three regulatory
  environments that concern remediation of the ISF at ABB are
  summarized in Table 3.





                Table 1: PCB Treatment Technologies

TECHNOLOGY                      Location of Full Scale Application
                                        or SITE Demonstration
_______________________        __________________________________________
class, type, function           LOCATION                VENDOR
_________________________________________________________________________
Class: Thermal Treatment        Outboard Marina         Canonie
Type: Thermal Desorption        / Waukegan              Environmental
Function: Separation            Harbor, IL              Services / Soil
                                                        Tech ATP Services
                                                        (Anaerobic
                                                        Thermal
                                                        Processor)

                                Wide Beach              Soil Tech ATP
                                Development, NY         Services
                                                        (Anaerobic
                                                        Thermal
                                                        Processor)
                                
                                ReSolve                 RUST Remedial
                                Superfund Site,         Services (XTRAX)
                                MA

                                Middleground            ELI EcoLogic
                                Landfill, MI            (Thermal
                                                        Desorption Unit)
_________________________________________________________________________
Class: Thermal Treatment        Spokane,                Geosafe
Type: Vitrification             Washington              Corporation
Function:Destruction                                    (In-Situ
                                                        Vitrification)
_________________________________________________________________________
Class: Chemical Treatment       Wide Beach              SoilTech ATP
Type: Dechlorination            Development, NY         Services (APEG)
Function:Destruction            
                                Koppers Site, NC        EPA RREL (BCD)
_________________________________________________________________________
Class: Chemical Treatment       New Bedford             CF Systems
Type: Solvent Extraction        Harbor                  (Propane
Function: Separation            Superfund Site, MA      Extraction)

                                Grand Calumet           Resources
                                River Site, IN          Conservation
                                                        Company (BEST)

                                EPA Research            Dehydro-Tech
                                Facility, NJ            (Carver- 
                                                        Greenfield
                                                        Process)

                                Naval Air               Terra-Kleen
                                Station North           Response Group
                                Island, San             (Solvent
                                Diego CA                Extraction)
_________________________________________________________________________
Class: Chemical Treatment       General                 Geo-Con (InSitu 
Type: Solidification            Electric                Solidification
Function: Immobilization        Service Shop,           and Stabilization)
                                Hialeah, FL     
                    
                                Portable                ARM
                                Equipment               (Solidification)
                                Salvage Company

                                Pepper's Steel          VFL
                                and Alloy               (Solidification)
                                Superfund site, FL

Class: Chemical/Physical        Refinery Site,MN        BioGenesis
          Treatment                                     (Soil Washing)
Type: Soil Washing
Function: Separation            MacGillis and           BioTrol
                                Gibbs Superfund         (Soil Washing)
                                Site, MN

                                Saginaw Bay             Bergmann USA 
                                Facility, MI            (Soil Washing)
_________________________________________________________________________


          Table 2: Estimates of Total Treatment Cost 
                                
                                
Technology              Total Treatment Cost for ABB Stockpile*
_________________________________________________________________________

Thermal Desorption      $250 - $400 per ton
                        
Vitrification           $465 per ton
                        
Chemical Dechlorination/
Dehalogenation          $210 per ton

Solvent Extraction      $200 - $300 per ton

Solidification          $30 - $50 per ton

Soil Washing            $300 per ton

* NOTE: Cost estimates based on information provided by
technology vendors for 10,000 to 20,000 tons of PCB-bearing
soil.  Costs shown include treatability testing, mobilization,
demobilization, excavation, pretreatment, treatment, sampling
and analysis.  Actual costs may vary based on site-specific
conditions and treatment objectives.
_________________________________________________________________________





Table 3: Comparison of Regulatory Environments


                        Superfund       Current        Revised TSCA
                        (no change)     TSCA           (as proposed)
_________________________________________________________________________

Can the soil be         YES             YES             YES
transported by rail
to USPCI?

Is the application      YES             NO              YES
of innovative 
treatment
technologies that
reduce waste volume,
toxicity or mobility
encouraged?

Would formal            YES             NO              NO
consideration of        (EE/CA or FS)
several alternative
remedies by
required?


When could              6 MO - 1 YR     3 MO            6 MO - 1 YR
remediation begin?                                      (contingent on
                                                        timely adoption 
                                                        of TSCA revisions)

Are public comment      YES             NO    
and community
relations required
or proposed?

Would remediation of     NO             NO              NO
the ISF at ABB be
linked with the
Consent Decree sites?
_________________________________________________________________________