1.0     INTRODUCTION

This document describes a Feasibility Study (FS) of
alternative technologies to remediate material contaminated
with polychlorinated biphenyls (PCB) at six sites in the
Bloomington, Indiana, area.  This FS was conducted for the
Indiana Department of Environmental Management (IDEM) by PRC
Environmental Management, Inc. (PRC).  The FS evaluates PCB
remediation alternatives to incineration and generally
follows the U.S. Environmental Protection Agency's (EPA)
"Guidance for Conducting Remedial Investigations and
Feasibility Studies Under CERCLA" (EPA 1988).  This FS report
is divided into six sections and four appendixes. 
Section 1.0 discusses the project background and scope of the
FS.  Section 2.0 profiles each of the six sites, summarizes
the material to be remediated, and presents the chemical
characteristics of the primary contaminants of concern. 
Section 3.0 identifies and screens remedial technologies. 
Section 4.0 presents the detailed analysis of individual
remedial alternatives.  Section 5.0 compares the remedial
alternatives.  Section 6.0 presents a list of references
cited in the report.  Appendix A presents calculations of the
volumes and weights of contaminated materials.  Appendixes B
and C present potential Applicable or Relevant and
Appropriate Requirements (ARAR) and detailed cost estimates,
respectively.   Appendix D summarizes site-specific chemical
data.

1.1       PROJECT BACKGROUND

Pursuant to a Consent Decree (CD) signed on May 25, 1985, by
Westinghouse Electric Corporation (Westinghouse), EPA, IDEM,
the City of Bloomington, and Monroe County, Westinghouse is
required to remove and incinerate an estimated 627,000 cubic
yards (yd3) of PCB-contaminated material consisting mainly of
soil and rock, sludge, sediment, and solid waste from six
sites located in the Bloomington, Indiana, area (U.S.
District Court 1985).  These sites include the Anderson Road
Landfill, Bennett Stone Quarry, Lemon Lane Landfill, Neal's
Dump, Neal's Landfill, and the Winston-Thomas Sewage
Treatment Plant.  All but the Anderson Road Landfill and the
Winston-Thomas Sewage Treatment Plant sites are on EPA's
National Priorities List (NPL) of Superfund sites.  Two other
PCB sites in the Bloomington area, the Fell Iron and Metal
and the North Curry Pike Plant sites, are undergoing removal
actions pursuant to EPA administrative orders.  PCB-
contaminated soil from these two sites are not covered by the
scope of this FS but may be included in the material to be
treated under the CD.

The first phase of the cleanup effort was completed in 1987
and involved limited removal and remedial measures to contain
contamination from the six sites until the excavation of PCB-
contaminated materials begins at all of the sites except for
the Anderson Road Landfill.  An interim storage facility
(ISF) was constructed by Westinghouse in 1986 at the now
defunct Winston-Thomas Sewage Treatment Plant.  The ISF
consists of a building that presently stores PCB-contaminated
material excavated from the Anderson Road Landfill site and
from limited excavations at the other five sites.  The
contaminated material is stored in piles in the ISF.  PCB-
contaminated material attributable to Westinghouse has been
removed from the Anderson Road Landfill site has been
transported to the ISF.  Except for a limited amount of
material that has been removed, contaminated material at the
other five sites was capped in place and remains to be
excavated for future treatment.  Groundwater investigations
required by the CD are also being conducted at the six sites
as part of first phase cleanup activities.

The second phase of the cleanup effort requires Westinghouse
to construct and operate a high-temperature incinerator to
incinerate the PCB-contaminated materials excavated from the
six sites.  Westinghouse is also responsible for disposing of
the residue from the incinerator and for restoring
environmental conditions at the six sites.  This FS applies
to Phase II remediation activities involving excavation,
treatment, and disposal of the PCB-contaminated materials at
the sites (except the Anderson Road Landfill site) and at the
ISF.

There has been and continues to be a great deal of public
opposition to the high-temperature incineration of the PCB-
contaminated material.  Public concern centers around the
potential for incomplete combustion of the material and the
resulting formation of dioxins.  The public is also concerned
about potential releases of hazardous constituents to the air
in case the incinerator experiences operating difficulties. 
The public has voiced the opinion that other treatment
options for the PCB-contaminated material have not been
adequately evaluated and that other hazardous material
treatment technologies developed since 1985, when the CD was
signed, may effectively treat the wastes from the six sites.

In response to public concern and to address scientific
advances in PCB treatment technologies, in 1991, the State of
Indiana enacted a law, Indiana Code (IC) 13-7-16.5-9
requiring IDEM to conduct a study of alternative PCB
treatment technologies.  Section 1.1.1 describes the
requirements of 
IC 13-7-16.5-9 in more detail, and Section 1.1.2 presents the
objectives of this FS in light of the requirements of IC 
13-7-16.5-9.   

1.1.1          Requirements of Indiana Code 13-7-16.5-9 

IC 13-7-16.5-9 requires IDEM to conduct a study of
alternative PCB treatment technologies before IDEM can issue
or consider an application for a permit specifically
authorizing the incineration of PCBs.  In accordance with the
CD, IDEM received a Toxic Substances Control Act
(TSCA)/Resource Conservation and Recovery Act (RCRA) PCB
incinerator permit application from Westinghouse on July 30,
1991.  IDEM must conduct the FS of alternative PCB treatment
technologies before it can review the Westinghouse permit
application.

IC 13-7-16.5-9 specifies that the FS must include an
assessment of the efficacy and the technical and economic
feasibility of the following technologies:

          Application of lime to break down PCBs

          Low-temperature thermal desorption 

          Desorption and vaporization extraction 

          Plasma torch technology

          Bacterial remediation

          Other technologies identified by IDEM as having
          possible value in the treatment or disposal of
          PCBs

IC 13-7-16.5-9 requires the alternative technology FS to be
completed by July 1, 1995.

1.1.2          Objectives of the Feasibility Study

Based on the requirements of IC 13-7-16.5-9, IDEM solicited
contractor support to conduct the FS.  IDEM specified that
the FS is to be conducted using EPA's Remedial Investigation
and Feasibility Study (RI/FS) guidance (EPA 1988).  IDEM
further instructed that the five technologies specified in IC
13-7-16.5-9 technologies and the other potentially applicable
technologies identified by IDEM are to undergo a detailed
analysis.  The evaluation criteria specified in EPA's RI/FS
guidance will address the efficacy and technical and economic
feasibility of the alternative technologies as required by IC
13-7-16.5-9.

The objectives of this FS are to (1) evaluate and compare PCB
remediation technologies as alternatives to high-temperature
incineration; (2) evaluate and compare the merits of the
technologies specified in IC 13-7-16.5-9; and (3) identify,
evaluate, and compare other PCB remediation technologies that
vary in the degree to which long-term management of treatment
residuals or untreated waste is required.  Among other
factors, the efficiencies of the technologies will be
evaluated based on their ability to remediate all six sites
in 11 to 15 years, the time frame in which the proposed
Westinghouse incinerator will remediate the six sites, to a
level of PCBs in the treatment residuals of less than 2 parts
per million (ppm).  The 2-ppm PCB level is the TSCA
equivalency standard for alternative treatment technologies. 
Under TSCA, alternative treatment technologies that remove
PCBs to a level of less than 2 ppm in the treatment residuals
are considered equivalent to high-temperature incineration.  

1.2       SCOPE OF THE FEASIBILITY STUDY

This FS addresses soil and rock, sediment, sludge, and solid
waste contaminated with PCBs.  In accordance with EPA's RI/FS
guidance, this FS report will accomplish the following:

     (1)  Summarize site conditions and assumptions (see
          Section 2.0)
 
     (2)  Identify available technologies; screen
          technologies based on effectiveness,
          implementability, and cost; and combine the
          treatment technologies with support technologies
          to form remedial alternatives (see Section 3.0) 

     (3)  Analyze the individual alternatives in detail
          using appropriate evaluation criteria specified in
          the National Oil and Hazardous Substances
          Pollution Contingency Plan (NCP) and the EPA RI/FS
          guidance (see Section 4.0)

     (4)  Compare the alternatives to one another against
          the evaluation criteria, noting the key advantages
          and disadvantages of each alternative (see
          Section 5.0)


Groundwater cleanup is not addressed in this FS.  The impact
of excavation on groundwater when implementing a remedial
alternative should be considered.  Overall site remediation
should be coordinated to ensure that all environmental media
are cleaned up and human health and the environment is
protected.

This FS deviates from EPA's RI/FS guidance in several ways. 
First, this FS does not evaluate the "no action" alternative. 
By entering into the CD, EPA, IDEM, Westinghouse, the City of
Bloomington, and Monroe County have already determined that
action is appropriate for the six sites.  Containment also is
not evaluated because the objective of this FS is to evaluate
alternative treatment technologies.  Second, because the
objective of the FS is to evaluate alternatives to high-
temperature incineration of PCB-contaminated materials, this
FS does not evaluate high-temperature incineration.  If
Westinghouse proposes an alternative treatment technology,
however, the technology should be comparatively evaluated to
high-temperature incineration.  Third, this FS does not use
two of the nine evaluation criteria specified in the NCP:
state and community acceptance.  State acceptance is not
evaluated because this FS is not a decision document.  
Community acceptance will be evaluated in the responsiveness
summary prepared in response to public comments received on
the FS.  Finally, this FS omits the screening of alternatives
step usually conducted for FSs conducted under the
Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA).  Based on the number of viable
remediation technologies available to address PCB-
contaminated materials and because groundwater is not being
addressed as part of this FS, it was not necessary to screen
the alternatives developed in Section 3.0.  This approach is
allowed for by EPA's RI/FS guidance.

This FS report is based on waste volume information and
cleanup levels specified in the CD.  Whenever necessary
details regarding the specific components of the PCB-
contaminated material are unknown, reasonable assumptions are
made.  These assumptions are presented in Section 2.7.  The
volumes of materials to be remediated are based on the
volumes presented in the CD; however, significantly more
material may be present at the sites.  The FS proposes to use
the same off-site treatment and disposal sites located in the
Bloomington area that Westinghouse proposes to use for its
incinerator treatment residuals disposal.  A 16-acre site may
be available for staging and treating contaminated material,
and a 30-acre site may be available for residuals disposal. 
Other treatment and disposal sites may be evaluated during
the design stage of the remediation project if the proposed
Westinghouse treatment and disposal sites are not acceptable.