************************************************************ Soil Cleanup Technologies Recommended, (Engineering Evaluation and Cost Analysis) Fell Iron and Metal Inc. Bloomington, Indiana EPA Fact Sheet September 1989 An engineering evaluation and cost analysis (EE/C A) to investigate and evaluate treatment technologies of soils contaminated with polychlorinated biphenyls (PCBs) at Fell Iron and Metal Inc. (Fell) site in Bloomington, Indiana, was recently completed. (Words appearing in bold are identified in the Glossary). An EE/CA is performed under "non-time" critical conditions where contamination at the site is serious, but not an emergency. The purpose of the investigation was to identify, screen, evaluate, and recommend treatment technologies for the PCB contaminated soils. The goals of the EE/CA are to: provide a framework for evaluating and selecting clean-up remedies; closely document the selection process of the remedy; ensure that the evaluation complies with environmental regulations; and allow the public an opportunity to provide comments during the selection process. This fact sheet will explain the selection process for the final treatment technologies evaluated for soil at Fell. Highlights on PCB levels The Fell site is an active salvage yard located at 503 North Rogers Street in Bloomington, Indiana. Business and residential areas surround the site. Fairview Elementary School is located one block south of the site. Downtown Bloomington is one-quarter mile southeast of Fell. PCB-contaminated capacitors, produced by Westinghouse, were disposed of at Fell until 1968. The capacitors were broken open and the copper inside was removed for salvage. Some of the remaining capacitor shells containing PCB oil were buried or piled up on-site. In September 1984, U.S. EPA investigated the Fell site for the first time. Soil concentrations of PCBs ranging from 753 parts per million (ppm) to 71,700 ppm were discovered where the capacitors had been stored on-site. Because of the high PCB levels found at Fell, the accessibility of the site to the public, and the proximity of the site to Fairview Elementary School, U.S. EPA ordered that capacitors be removed. A request by the Monroe County Board of Health and the Monroe County Board of Commissioners led U.S. EPA to conduct an assessment of the Fell site in November 1987. Samples were collected of soils, and storm sewer runoff. PCB levels in soil ranged from non-detectable (ND) to 1,461 ppm. Storm sewer water samples indicated PCB concentrations of 81 parts per billion (ppb). Because the PCB levels in soil exceeded 50 ppm, which is the removal indicator level under the Toxic Substances Control Act, U.S. EPA issued an Administrative Order to Westinghouse to immediately address contamination at the Fell site. All on-site soils with PCB concentrations of 25 ppm or greater were excavated and stockpiled beginning in October 1988. The excavated areas were then backfilled with clean material. The contaminated soil was stockpiled on-site and encapsulated in a synthetic liner/cap system designed to withstand weather conditions for an approximate life-time of 15 years. By March 1989, approximately 15,000 cubic yards of contaminated soil had been excavated. The remaining PCB levels for the site soils overall (not including the pile) averaged 2.5 ppm. The stockpile will remain in place until U.S. EPA chooses a removal alternative for the contaminated soil. Based on the findings of the EE/CA and comments from the public, U.S. EPA will prepare and sign an Action Memorandum which designates what the final remedy will be. A copy of the Action Memorandum will be attached to the EE/CA report. This will be available to the public at the information repositories and the public information center in Bloomington. Why was a removal at Fell necessary? According to U.S. EPA, the Fell site posed a substantial and eminent threat to public health and the environment. The threat of PCB movement through storm water runoff into the sewer system, the possibility of direct contact with contaminated soil to individuals on and near the site, as well as the potential of inhaling contaminated dust, prompted the cleanup actions at Fell. As a temporary means of preventing further PCB migration, the soil at Fell was excavated, stockpiled, and encapsulated until a final decision is made on permanent disposal of the soil. Health Effects of PCBs According to U.S. EPA, PCBs are both toxic and long lasting in the environment. Prolonged exposure can cause a skin condition called chloracne. Irritation of the eyes, nose and throat can occur from inhalation of PCBs. Animal studies have shown that PCBs may cause damage to the reproductive system and possible cause cancer. Studies show that accidental oral intake during pregnancy has resulted in reproductive failure in humans. Exposure to high concentrations of PCBs over a long period of time can cause liver damage. PCBs are extremely slow to break down in the environment, as well as in human and animal tissue. They collect in the fatty tissue and can cause severe long-term damage. PCBs can bioaccumulate in higher members of the food chain. Time line 1948 Fell begins operations Prior to 1965 Fell accepts capacitors from Westinghouse Sept 1984 US EPA investigates the Fell site Oct 1984 - Jan 1985 US EPA removes 346 PCB-contaminated capacitors and caps two capacitor storage areas with clay Mar 1986 US EPA conducts second investigation of Fell for possible inclusion to the NPL. Fell does not meet NPL criteria Nov 1987 US EPA conducts a third site investigation for possible removal of soil. US EPA issues an order to Westinghouse to clean up PCB soil. Westinghouse complies with the order Oct 1988 Soil excavation begins at Fell Mar 1989 Approximately 15,000 cubic yards of soil are excavated, stockpiled and encapsulated on site Screening of Cleanup Technologies Nine technologies were initially examined to eliminate inappropriate alternatives for treatment of the soil stockpiled at Fell. The original alternatives considered were: - Incineration; - Landfilling; - Chemical Extraction; - Glycolate Dechlorination; - Vitrification. - No Action; - Biodegradation; - Capping; and - Soil Washing. These nine technologies were compared against four general rules, or criteria. If a particular alternative did not meet the criteria , it was eliminated from further consideration. The criteria were: general technological feasibility; time to implement; the degree of public health and environmental protection provided by the technology; and compliance of the technology with federal, state, and local regulations. Five of the nine original alternatives met the criteria and were further evaluated. The five were: incineration, landfilling, chemical extraction, glycolate dechlorination, and vitrification. The technologies are discussed in detail on pages 4, 5 and 6 of this fact sheet. The five were further screened against the following four criteria: - technical feasibility for treating specific wastes; - impacts on the environment; - reasonable cost; and again - adherence to federal, state, and local regulations. Summary of Remedial Technologies Off-Site Incineration - Rotary Kiln Rotary kilns have tilted, rotating chambers. Wastes and fuel are inserted into the upper end of the kiln and are burned as they move through the slowly rotating chamber. Rotary kiln incinerators have been widely used on a variety of hazardous wastes including PCBs. Regulations require the incinerator to destroy 99.9999% of the contamination. There are three operating incinerators of this type in the U.S.: the Chemical Waste Management (CWM/SCA) incinerator in Chicago, Illinois, the ENSCO incinerator in El Dorado, Arkansas, and the APTUS incinerator in Coffeyville,Kansas. Estimates of the cost and execution times for incineration were based on 15,000 cubic yards of contaminated soil. Execution times were calculated assuming that each incinerator would be available and operating at full capacity. Total Cost: Execution time: CWM/SCA $44,081,518 16 to 18 months ENSCO $45,881,163 2 to 3 months APTUS $29,134,583 5 months Use of the rotary kiln incinerator for Fell is still under consideration by U.S. EPA - Infrared Incineration This method of incineration is similar to the rotary kiln, with infrared radiation used to destroy the waste instead of burning. Destruction of PCBs using this method is about 99.99% effective. Two companies currently have mobile infrared incinerators available. One of the companies cannot be used due to conflict of interest. The other company, O.H. Materials in Findlay, Ohio, has a national permit to operate a mobile infrared incinerator. Cost estimates include incineration of the soil, and the expense of landfilling the residue. The cost of landfilling is dependent upon the nature of the soil. If the soil is EP toxic, it must be disposed of at a RCRA-regulated landfill. The closest RCRA landfill is in Fort Wayne, Indiana. If the soil is not EP toxic, it still must be disposed of in a landfill. Total Cost: Execution Time: EP Toxic $10,064,389 3 months Non-EP Toxic $6,867,377 3 months - Westinghouse Incinerator Westinghouse has proposed to build a rotary kiln incinerator to comply with a Consent Decree lodged in the U.S. District Court for the Southern District of Indiana in August 1985. The Consent Decree requires the incinerator for the cleanup of several other PCB-contaminated sites in the Bloomington area. The Westinghouse rotary kiln design is slightly different than any such incinerator now in use. This rotary kiln will have the capacity to burn municipal solid waste along with the contaminated soil. Ash from the incinerator will be disposed of at a RCRA/TSCA approved landfill to be constructed nearby. Greater than 99.9999% of PCBs can be destroyed using this type of incinerator. Under the Consent Decree, the proposed incinerator will burn approximately 650,000 cubic yards of PCB-contaminated soil from the other area sites before incinerating the soil at Fell. This option proposes that the Pell stockpile would be incinerated after the materials from the Consent Decree are burned. With the proposed incinerator operating at capacity, incineration of the Consent Decree wastes would take approximately 12 years. Because the Fell stockpile may be in place close to the lifetime of the current liner/cap system, this cost estimate includes the installation of a replacement containment system. Total Cost: Incineration Time: $2,880,105 3 to 4 months Use of the proposed Westinghouse incinerator for Fell is still under consideration by U.S. EPA. - Fluidized Bed Incineration This type of incineration consists of a bed of material, such as sand, within a chamber. Waste can be injected directly into the bed, or onto its surface. Air is then forced into the bed which causes the wastes to move within the chamber. Fuel is fed into the chamber to burn and destroy the PCB contaminated soil. Decontaminated soil and material that does not burn is taken out from the bottom of the chamber. With proper temperature and oxygen maintenance within the chamber. This incinerator can destroy up to 99.9999% of the PCBs. This option was not considered further because there are no mobile incinerators of this type within a reasonable distance of Fell and wastes would have to be transported at least 1,01)0 miles to such a facility. Off Site RCRA/TSCA Landfill This technology has been widely used for disposal of hazardous wastes, including PCBs. Only permitted facilities in compliance with RCRA/TSCA and all other regulations were considered. Permitted hazardous waste landfills are equipped with both a primary and secondary liner, a leachate collection system and groundwater monitoring wells. However, after November 1990 contaminants with PCB concentrations over 50 ppm cannot be acepted in RCRA/TSCA landfills. A landfill that could accept PCB-contaminated soil is located in Model City, New York. The cost of shipment and disposal of the 15,000 cubic yards of soil from Fell is estimated to be: Total Cost: Execution Time: $17,969,$57 2 months Use of off-site landfills to dispose of the Fell soils is still under consideration by U.S. EPA Chemical Extraction - B.E.S.T. This process separates contaminated soils into oil, water, and solids. Chemical extraction is accomplished by mixing liquid into the waste to form a slurry. Certain chemical solvents are added to the slurry to cause the solid particles to separate from the mixture. Next, the mixture is heated to separate the water from the oil and solvent. Distilling is the final step in order to remove the PCB oil from the solvent This process has been effective in removing over 99% of PCBs from wastes. Assuming 15,000 cubic yards of soil are treated, 3,030 gallons of PCB waste oil, with an average PCB concentration of 1,000 ppm will be produced. PCBs are not destroyed using this method, but converted to a smaller more concentrated volume. This technology has been successful in treating sludges, but has never been used on soil. Cost estimates include off-site incineration of the waste oil and disposal of the treated soil by landfilling. Incineration of liquid PCB wastes of 50 ppm or greater is required by U.S. EPA. The total cost for landfilling the treated soil depends on its EP toxicity. Total Cost: Execution Time: EP Toxic Soil $7,395,373 1.4 years Non EP Tox soil $4,291,511 1.4 years Use of this method to treat soils at Fell is still under consideration by U.S. EPA. - Critical Fluids Extraction (CFS) The critical fluids extraction process (CFS) uses liquefied gases to separate oils from contaminated soils. The contaminated soil is processed in a separator unit. Liquefied gases flow through the separator and remove PCBs from the mixture. The clean soil is removed, and solvent and PCBs pass through another separator. The solvent is vaporized and recycled for reuse, leaving only the PCB-contaminated oil. This process has been effective in removing about 99% of PCBs from waste. PCBs are not destroyed using this method, but converted to a smaller, more concentrated volume. Assuming 15,000 cubic yards of soil are treated, about 3,000 gallons of PCB waste oil, with an average PCB concentration of 1,000 ppm, will be produced. These waste oils would be taken off-site and incinerated according to federal regulations. The disposal requirements of the waste materials are the same as stated above. Total Cost: Execution time: EP Toxic Soil $6,859,900 2 years Non-EP Toxic Soil $3,662,888 2 years Use of this method to treat soils at Fell is still under consideration by U.S. EPA. Glycolate Dechlorination (APEG) Dechlorination is a process which transforms PCBs into other nontoxic chemicals. It is accomplished by mixing PCB-contaminated soil with certain chemicals, called reagents, and applying heat. This results in chemicals that are less toxic than PCB that can be further treated with water. The soil is washed several times and the recovered reagent can be used again. This technology has been extremely effective with transformer fluids such as PCBs, but has only been demonstrated in small scale operations. Dechlorination does not destroy PCBs, but transforms them into other chemicals. A RCRA/TSCA landfill would be required to dispose of the soils that were EP Toxic. The nearest RCRA/TSCA landfill is in Ft. Wayne, Indiana. Non-EP Toxic soil could also be disposed of in a landfill. The cost of shipment and disposal of the soil is estimated to be: Total Cost: Execution time: EP Toxic Soil $9,440,480 6-12 months Non-EP Toxic Soil $6,243,407 6-12 months Use of this method to treat soils at Fell is still under consideration by U.S. EPA. In-Situ Vitrification (ISV} This process is used to treat wastes in place (in-situ). The method uses electricity to melt soil into a glass-like mass that resists weathering. One thousand tons of soil can be processed per treatment. In the process, 99.9999% of the PCBs are destroyed, however the glass-like mass may be left on site. ISV has been demonstrated to be effective, but is still in the developmental stage. Total Cost: Execution Time: $7,646,025 6 months Use of this method to treat soils at Fell is still under consideration by U.S. EPA. Analysis of Alternatives A system to weigh the advantages and disadvantages of each technology was developed. Each technology was compared against technical feasibility, institutional considerations, environmental impacts, and reasonable cost. This section discusses the advantages and disadvantages of four of the previously discussed technologies (on-site and off-site incineration, in-situ vitrification, and off-site landfill) and concludes with EPA's preferred alternative of off-site landfilling. On-Site Incineration Incineration is an available and proven technology that achieves nearly total (99.9999% destruction efficiency) destruction of PCB contaminants. It reduces the toxicity and mobility of the contaminants, can be completed within three months, and is relatively inexpensive (cost range from 7 to 10 million dollars). The incinerator would only be used to destroy the material in the stockpile and would be removed when the project is finished. However, due to the close proximity of businesses and residences, the noise and unsightly appearance of a mobile incinerator in the -neighborhood is a drawback. In the event of failure, there would be a great deal of concern over emissions from the smoke stack and their subsequent health effects. Finally, the incinerator would not effectively reduce the volume of the soil and the resulting ash would need to be disposed of in an appropriate manner on-site. Off-Site Incineration at Proposed Consent Decree Incinerator As in the on-site incineration proposal, this option effectively reduces the toxicity and mobility of the contamination. However, there are numerous drawbacks to this treatment. Because there are no firm deadlines for the construction of the incinerator, and the subsequent destruction of the 650,000 cubic yards of materials, it is difficult to determine when the Fell stockpile would be incinerated. Additionally, burning the Fell stockpile in the incinerator would require amending the existing Consent Decree and that could be a lengthy process. Finally, the liner system on the stockpile would have to be replaced which may require disruption of the materials. This short-term disruption may expose nearby residents to PCB dusts and vapors until the new liner system is in place. In-Situ Vitrification (ISV) This is an available technology that destroys the toxicity and the mobility of the PCBs in soil. It can be implemented over a relatively short period of time (between six to twelve months), is less industrial in appearance, and costs between 7 to 8 million dollars. However, this is an emerging technology and has not yet been attempted on a project as large as Fell. The system includes a "hood" to capture gasses produced in the ISV process; wind conditions may affect the efficiency of the "hood" system. The system may also be noisy while in operation. Finally, incomplete "burns" (possible during a brownout) could produce unwanted by-products such as dioxins and furans. RCRA/TSCA Landfill This alternative is an acceptable means of permanent disposal (until the RCRA Land Disposal Restrictions take place in November, 1990) that can be accomplished in a short time frame (two months) and is cost-effective (approximately 8 million dollars). Removing the pile reduces any environmental threats in the community. Finally, landfill capacity exists now for the disposal of the pile. Landfilling does not destroy the toxicity, mobility, or volume of the wastes but it does enclose the soil in a monitored environment that is much more secure than the current encapsulation at Fell. However, since the removal of the pile requires its transport through town (by rail or truck), there may be a short-term increase in risks to exposure via spills or an accident. ___________________________________________________________________ RCRA/TSCA LANDFILL IS EPA'S PREFERRED ALTERNATIVE FOR THE DISPOSAL OF THE STOCKPILE AT THE FELL IRON AND METAL SITE ____________________________________________________________________ GLOSSARY ADMINISTRATIVE ORDER A legal document signed by US EPA directing an individual or business to stop or correct an activity. It describes the violation and actions to be taken. An administrative order can be enforced in court. BIOACCUMULATE Chemicals which increase in concentration in a living creature as it breathes contaminated air, drinks contaminated water, or eats contaminated food CONSENT DECREE A legal document, approved and issued by a judge, that formalizes an agreement reached between US EPA and potentially responsible parties (PRPs) wherein PRPs will perform all or part of a Superfund site cleanup. The consent decree describes actions that PRPs are required to perform and is subject to a public comment period. ECOSYSTEM A community of animals and plants and the environment in which they live. ENGINEERING EVALUATION/COST ANALYSIS An analysis of removal alternatives for a site, similar to the feasibility study in a remedial program. An EE/CA characterizes current conditions and contaminants present at a hazardous waste site, and identifies and addresses alternative removal actions for the site. EP(EXTRACTION POTENTIAL) TOXICITY An analytical test that can determine if certain metals have the potential to leach out of wastes. PARTS PER MILLION In everyday terms, one part per million would be equal to one second in 11 days. Numerically, one part per million looks like 0.000001. PARTS PER BILLION A very small unit of measurement. One ppb can be compared to one second in thirty-two years. Because some chemicals are very toxic even at low concentrations, ppb has become a standard unit of measurement in the hazardous waste field. Numerically, a part per billion looks like 0.000000001. SLURRY A mixture of liquids and solids SOLVENT A chemical that can dissolve other chemicals TOXIC SUBSTANCES CONTROL ACT (TSCA) TSCA is the federal law authorizing US EPA to gather information on the risks of hazardous chemicals. The TSCA regulations may be found in the Code of Federal Regulations 40, part 761. RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) Regulates management and disposal of hazardous materials and wastes currently being generated, treated, stored, disposed of or distributed. ***************************************************************** Note to BBS users: the section of this Fact Sheet providing instructions for public participation was not scanned. Source: Scanned by COPA from the original EPA Fact Sheet