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COPA comment letter regarding Fell Iron & Metal
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May 23, 1995


Mr. Dave Novak (P-19J)
Community Involvement Coordinator
Office of Public Affairs
US EPA Region 5
77 West Jackson Blvd.
Chicago, IL 60604


     Re:  Fell Iron & Metal Decision Amendment Proposal


Dear Dave:

We are pleased that Westinghouse and EPA are finally proposing
remediation of the Fell Iron & Metal site because it is long
overdue.  Relocation of the 16,000 cy of PCB contaminated soil to
the USPCI facility in Utah is consistent with regulatory
preference for making use of existing permitted hazardous waste
storage facilities rather than creating a new hazardous waste
facility locally to store the material. However, an important
opportunity to apply commercially available treatment processes
that have demonstrated effectiveness in treating PCBs in soil
will be missed. 

The public is being misled by assertions from Westinghouse and
the EPA that there are currently no viable alternatives to off-
site landfilling. EPA's repeated excuses that they do not
necessarily endorse Westinghouse's positions are unacceptable. 
EPA grants the public an opportunity to comment on  proposals
that they are prepared to accept. EPA must correct objectionable
language or unacceptable proposals prior to disseminating the
information to the public. If this is not possible, EPA must
distribute its objections or comments along with the unrevised
Westinghouse document.  Failure to do so conveys EPA's
endorsement by default. The reason for overwhelming public
distrust of EPA in Bloomington is that EPA has repeatedly
demonstrated that it is unable or unwilling to balance
Westinghouse's proposals with their own proposals that are
protective of human health and the environment.  

The only reason for judging off-site incineration infeasible is
that existing facilities lack adequate treatment and storage
capacity, but the option to use a separation technology to reduce
the amount of material requiring incineration has been ignored.
Thermal desorption, solvent extraction and soil washing are three
commercially available technologies that separate PCBs from soil
to produce a concentrated PCB-bearing treatment residual that
requires further treatment or disposal.  The treated soil could
be placed back on site, solidified to immobilize metals if
appropriate, or used as daily cover in existing landfills.   

PCB separation technologies are commercially available, have
demonstrated effectiveness for PCB treatment, and have been
selected in numerous Records of Decision for PCB Superfund sites,
as detailed below.

At least four vendors of thermal desorption have full scale
equipment and experience treating PCBs: Westinghouse, SoilTech,
RUST and Canonie.  Westinghouse has applied for a National TSCA
treatment permit with General Electric and recently completed
full-scale remediation of PCB-contaminated soil at the ACME
Solvent Superfund site in Illinois. Thermal desorption was the
selected remedial action for PCB remediation at at least twelve
superfund sites through the end of 1993.  At least five other
thermal desorption vendors have pilot scale equipment and PCB
treatment experience. 

TerraKleen is a solvent extraction vendor with full scale
equipment, a National TSCA treatment permit, and PCB treatment
experience.  Resources Conservation Company and CF Systems are
solvent extraction vendors with pilot scale equipment and PCB
treatment experience.  Solvent extraction was the selected
remedial action at three PCB-contaminated Superfund sites through
the end of 1993.  

Four soil washing vendors have full scale equipment and PCB
treatment experience: ART, Bergmann USA, BioTrol, and
MTARRI/WasTech. Soil Washing was the selected remedial action at
one Superfund site with PCB waste through the end of 1993.

Further, there are several commercially available PCB destruction
technologies that deserve consideration.  Geosafe Corporation
completed a PCB treatment demonstration of in-situ vitrification
in 1994 support of a national TSCA treatment permit; this permit
application is still pending.  The operational difficulties and
equipment damage referred to by Dan Hopkins at the public meeting
occurred several years ago, and several successful demonstrations
have been performed since then.  Base catalyzed decomposition and
KPEG chemical dechlorination have been applied at full-scale for
PCB remediation by SoilTech at the Smith's Farm Brook and Wide
Beach Development Superfund sites, respectively. 

We have contacted a number of PCB treatment technology vendors
regarding the Fell Iron & Metal site and other PCB-contaminated
sites in the Bloomington area, and many of them have expressed
concern that EPA and Westinghouse are promoting off-site
landfilling as the only implementable remedial option, and that
outdated and incomplete information concerning the status of
development of these technologies is being presented to the
public.  We have asked them to relay their concerns directly to
EPA on our behalf as part of the public comment on the Fell Iron
& Metal decision amendment process.

Should EPA decide not to take advantage of the cost effective
remediation options available, excavation should occur in an
enclosure to protect the nearby residents, elementary school
students and staff, and public patronizing adjacent businesses
from contaminated dust and volatilized PCBs.  Please refer to the
EPA report titled "Demonstration of a Trial Excavation at the
McColl Superfund Site", EPA/540/AR-92/-15 describing a successful
demonstration of soil excavation under an enclosure as a means of
controlling atmospheric emissions.  If excavation is not
performed under an enclosure, it should be performed when
temperatures are below 65 degrees F to minimize volatilization of
PCBs, and should occur while elementary school students are home
for winter break to minimize their potential exposure. 

We appreciate the opportunity to comment on the proposed decision
amendment for the Fell Iron & Metal site.  


Sincerely,


Mike Baker, President
COPA

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