3.0    IDENTIFICATION AND SCREENING OF TECHNOLOGIES

This section presents the identification and screening of
technologies and the development of alternatives.  In Section
3.1, remedial action objectives (RAO) for this remedial action
are presented and potential ARARs are identified.  The RAOs and
potential ARARs will be used in subsequent sections to evaluate
the effectiveness and implementability of technologies.  Section
3.2 identifies the general response actions (GRA) available to
meet RAOs and potential ARARs.  GRAs are grouped into broad
categories such as treatment or disposal.  Section 3.3 presents
the identification and screening of technology types and process
options for each GRA.  Section 3.4 summarizes the primary
remediation technologies that will be taken forward to the
detailed analysis phase of the FS and then combines the primary
remediation technologies with appropriate support technologies to
develop alternatives.

3.1       REMEDIAL ACTION OBJECTIVES AND POTENTIAL ARARS

The purpose of Section 3.1 is to present the RAOs to be achieved
by this remedial action and to identify potential ARARs that may
need to be met by this remedial action.  Meeting RAOs and
compliance with potential ARARs are two factors used to evaluate
and screen the technologies and process options identified in
Section 3.3.  Section 3.1.1 presents RAOs for the remedial action
at the six PCB-contaminated sites.  Section 3.1.2 identifies
potential ARARs that may need to be met by the remedial action.

3.1.1          Remedial Action Objectives

This section presents RAOs for the remedial action at the six
sites.  RAOs are site-specific, qualitative, and specify
contaminants and media of concern, potential exposure pathways,
and remediation goals.  The RAOs serve as the framework for the
remainder of the FS and are used to develop and evaluate remedial
technologies and alternatives with respect to their ability to
protect human health and the environment. The RAOs for human
health and the environment for this remedial action presented
below would be achieved by removing soil and rock, sludge,
sediment, and solid waste as specified in the CD.  Confirmation
sampling should be conducted for PCBs at the Lemon Lane Landfill
in accordance with the CD.  Additional excavation of soil may
occur at the Lemon Lane Landfill site if analytical results from
the confirmational sampling indicate that PCBs are present at
concentrations of greater than 50 ppm.  Streams at Bennett Stone
Quarry, Winston-Thomas Sewage Treatment Plant, and Neal's
Landfill that were previously hydrovacuumed should have sediment
samples collected to confirm that the streams have not been
recontaminated with PCBs.


Remedial Action Objective for Soil and Rock, Sludge, Sediment,
and Solid Waste


For Human Health:
     
Prevent direct contact with, inhalation of, or ingestion of
soil and rock, sludge, sediment, and solid waste

For the Environment:

Prevent exposure of ecological receptors to soil and rock,
sludge, sediment, and solid waste 

Prevent release or leaching of contaminants from soil and rock,
sludge, sediment, and solid waste to groundwater

Prevent release or leaching of contaminants from soil and rock,
sludge, sediment, and solid waste to surface water






Besides RAOs, two additional factors will be given strong
consideration during the evaluation of process options and
development of alternatives.  First, the TSCA equivalency
standard of 2 ppm for PCBs will be considered a performance
criterion for treatment technologies.  Under TSCA, technologies
that treat PCBs to a level of 2 ppm or less in the treatment
residuals are considered equivalent in performance to
incineration.  Second, the time requirements of each alternative
to clean up the sites will be compared to the 11- to 15-year time
period necessary to incinerate the PCB-contaminated materials
under the CD.

3.1.2          Identification of Potential ARARs

This section identifies potential ARARs that should be considered
for the remedial action at the six sites.  Remedial action
decisions must include consideration of any ARARs.  Section
121(d) of CERCLA, as amended by the Superfund Amendments and
Reauthorization Act and Section 300.68(I)(1) of the NCP, require
CERCLA remedial actions to attain or exceed environmental and
public health ARARs unless specific waivers are obtained.  CERCLA
provides six specific ARAR waivers and lists specific federal
environmental laws that must be considered as part of an ARAR
analysis.  The list of laws includes the following:

          TSCA
          Safe Drinking Water Act (SDWA)
          Clean Air Act (CAA)
          Clean Water Act (CWA)
          Solid Waste Disposal Act (SWDA)/RCRA

More stringent state ARARs, if any, must also be identified and
met by CERCLA remedial actions.  

A requirement under these other environmental laws may be either
"applicable" or "relevant and appropriate," but not both. 
Identification of ARARs is site-specific, and ARARs are defined
as follows (EPA 1990a):

          Applicable requirements are cleanup standards,
          standards of control, and other substantive
          environmental protection requirements, criteria, or
          limitations promulgated under federal or state law that
          specifically address a hazardous substance, pollutant,
          or contaminant; remedial action; location; or other
          circumstance at a CERCLA site.  For a requirement to be
          considered "applicable," the hazardous substance,
          pollutant, or contaminant; remedial action; location;
          or other circumstance at the CERCLA site in question
          must meet the jurisdictional prerequisites specified in
          the applicable requirement.

          Relevant and appropriate requirements are cleanup
          standards, standards of control, and other substantive
          environmental protection requirements, criteria, or
          limitations promulgated under federal or state law
          that, while not "applicable" to a hazardous substance,
          pollutant, contaminant, remedial action, location, or
          other circumstance at a CERCLA site, address problems
          or situations sufficiently similar to those encountered
          at the CERCLA site so that their use is well suited to
          the particular site.  A specific requirement must be
          both relevant and appropriate to be considered an ARAR. 
          It is possible for individual portions of a single
          requirement to be relevant and appropriate and for
          other portions of the same requirement not to be
          relevant and appropriate.   Section 300.400 (g) of the
          NCP specifies the analysis that must be conducted to
          determine if a particular requirement is relevant and
          appropriate.

In addition to defining ARARs, the NCP directs that other
nonpromulgated criteria, advisories, and guidance issued by
federal or state governments that are not legally binding may be
used as criteria "To be considered" (TBC), although they do not
have the same status as potential ARARs.  However, criteria TBC
are considered together with ARARs in determining the necessary
level of cleanup or technology requirements to protect human
health and the environment.

The NCP identifies three categories of ARARs.  These three
categories also apply to criteria TBC and are described below
(EPA 1990a).


          Chemical-specific ARARs are usually health- or risk-based numerical values or methodologies used to
          determine acceptable concentrations of chemicals that
          may be detected in or discharged to the environment
          (such as MCLs that establish safe levels of
          contaminants in drinking water).

          Location-specific ARARs restrict actions or contaminant
          concentrations in certain environmentally sensitive
          areas.  Examples of areas regulated under various
          federal and state laws include flood plains, wetlands,
          and locations where endangered species or historically
          significant cultural resources are present.

          Action-specific ARARs are usually technology-,
          performance-, or activity-based requirements or
          limitations on actions or conditions involving special
          substances.

These types of ARARs and criteria TBC are discussed below, as
well as other requirements the remedial actions must meet at the
six sites.

3.1.2.1        Potential Chemical-Specific ARARs and Criteria TBC

Chemical-specific ARARs include state and federal requirements
regulating contaminant levels in various media.  Criteria TBC
items include proposed regulations and criteria recommended in
policy or guidance documents.  The ARARs and criteria TBC are
important in development of RAOs that comply with regulatory
requirements or guidance, as appropriate.  Summaries of potential
chemical-specific ARARs and criteria TBC for contaminated
material at the six sites are presented in Table B-1 of Appendix
B.  

The primary contaminants of concern at the six sites are PCBs
and, to a lesser degree, dioxins and furans.  Soil and rock,
sludge, sediment, and solid waste comprise the primary
contaminated materials at the six sites.  Other secondary
materials are lagoon water and piping located at the Winston-Thomas Sewage Treatment Plant site.  The solid waste that must be
remediated presents an especially challenging situation because
of heterogeneity of size and material type.  ARARs and criteria
TBC for the solid waste are discussed in Section 3.1.2.2.  The
list below identifies general potential chemical-specific ARARs
and criteria TBC for any type of remedial action taken at the six
sites.

     1.   TSCA -- TSCA regulates treatment and disposal of
          liquids, solids, and equipment contaminated with PCBs. 
          The State of Indiana has adopted federal TSCA
          requirements.  The TSCA regulations are considered
          applicable to the materials at the six sites.  TSCA
          prescribes specific treatment and disposal technologies
          to be used for different types of PCB-contaminated
          materials.  On December 4, 1994, new TSCA disposal
          regulations were proposed.  These proposed regulations
          are potential criteria TBC.
     
     2.   TSCA Spill Cleanup Policy -- The TSCA spill cleanup
          policy sets forth risk-based soil cleanup levels to be
          attained for spills of PCB-contaminated liquids. 
          Although the policy was developed to address spills
          occurring after May 4, 1987, it is considered a
          potential criteria TBC for all Superfund sites with PCB
          contamination because it provides risk-based cleanup
          levels for contaminated soil (EPA 1987).  The TSCA
          Spill Cleanup Policy is a criteria TBC because it has
          not yet been promulgated.

     3.   327 Indiana Administrative Code (IAC) 2-1-6 -- The IAC
          establishes ambient water quality standards for surface
          waters in the State of Indiana, including standards for
          PCBs.  The contaminated material at the six sites must
          be cleaned to a level that prevents runoff or leaching
          from the sites from contaminating surface water to a
          level exceeding the PCB chronic aquatic criteria of
          0.014 microgram per liter ( g/L).

     4.   SDWA -- SDWA regulations promulgate MCLs for
          contaminants in drinking water, including PCBs.  The
          contaminated material at the six sites must be cleaned
          to a level that prevents leaching of PCBs from the
          sites from contaminating groundwater to a level
          exceeding the PCB MCL of 0.5  g/L.

3.1.2.2        Potential Location-Specific ARARs and Criteria TBC

Location-specific ARARs and criteria TBC are restrictions placed
on the concentration of contaminants in hazardous substances or
on the conduct of activities that occur in specific locations. 
Some sensitive locations for which ARARs and criteria TBC exist
include karst topography, flood plains, wetlands, historic
places, and sensitive ecosystems and habitats.

One significant potential location-specific ARAR is Indiana
Regulation 329 IAC 2-10-1(D), which prohibits the siting of a
solid waste landfill in an area of karst topography.  Much of the
Bloomington area is underlain by karst formations.  This
situation precludes on-site disposal of treatment residuals and
untreated material at the six sites.  Regulation 329 IAC 2-10-1(D) is considered to be an ARAR for any off-site disposal of
treatment residuals and to any untreated material.

The list below presents other location-specific ARARs that may
also be applicable if any of the six remediation sites, the
treatment site, or the disposal site contain historically
significant cultural resources; if any of the six sites are
located within the flood plain of a river or stream; or if
actions at any of the remediation, treatment, or disposal sites
will affect wetlands.  Table B-2 of Appendix B presents more
detail on potential location-specific ARARs and criteria TBC.

          National Historic Preservation Act
          Archaeological and Historic Preservation Act
          Historic Sites, Buildings, and Antiquities Act
          Endangered Species Act
          CWA 

3.1.2.3        Potential Action-Specific ARARs and Criteria TBC

Action-specific ARARs and criteria TBC are technology- or
activity-based requirements for activities taken with respect to
remedial actions.  Action-specific ARARs do not determine the
remedial alternative but indicate how a selected alternative must
be conducted while maintaining compliance with other ARARs. 
Action-specific ARARs and criteria TBC may establish performance
levels, specify actions, or specify technologies, and can set
specific levels for discharged contaminants.  Action-specific
ARARs and criteria TBC must be considered for the contaminated
material removal and excavation, secondary treatment, post-treatment, and site restoration activities at the six sites.  The
solid waste portion of the site wastes must be dealt with not
only in regard to the PCB contamination but also as a solid
waste.  The solid waste not only triggers ARARs concerning PCBs,
but also triggers requirements for solid waste disposal and
possibly for hazardous waste treatment, storage, and disposal.

For the purpose of this FS, the waste material at the six sites
is assumed to be nonhazardous solid waste.  Available information
regarding the disposal activities at the six sites do not
indicate that any of the material is listed or characteristic
RCRA hazardous waste. If any of the material is determined to be
a characteristic or listed RCRA hazardous waste, or is a mixture
of nonhazardous and hazardous waste, then the applicability or
relevance and appropriateness of RCRA hazardous waste regulations
would need to be determined and the remedial action may need to
be amended to address RCRA requirements.

The following requirements are common action-specific standards
or references that will be used to establish action-specific
ARARs and criteria TBC.

          TSCA
          SWDA 
          CAA, National Emission Standards for Hazardous Air
          Pollutants (NESHAP)
          CWA, Storm Water Runoff Control Regulations
          CWA, NPDES, and Pretreatment Programs

TSCA is the principal action-specific ARAR for this remedial
action.  TSCA prescribes specific treatment and disposal
technologies to be used based on the type of PCB-contaminated
material being addressed.  Table B-3 of Appendix B discusses
potential action-specific ARARs and criteria TBC, including TSCA
treatment and disposal requirements.  

It is important to note that under TSCA, soil and municipal
sludge contaminated with greater than 50 ppm PCBs can either be
incinerated, landfilled in a TSCA-compliant chemical waste
landfill, or treated by an alternative treatment technology.  If
an alternate treatment technology is used but cannot meet the
equivalency standard of less than 2 ppm PCBs in the treatment
residual, then long-term management of the residual would have to
be addressed in accordance with RCRA closure requirements and
TSCA chemical waste landfill requirements.  However, RCRA
landfill closure allows some flexibility and TSCA contains
provisions for waiving the more stringent requirements for
disposal in a TSCA-compliant landfill depending on the form of
the waste and the level of PCBs in the residual.  Only industrial
sludge with greater than 500 ppm PCBs cannot be landfilled. 
Dredged materials and municipal sewage treatment sludge that
contains 50 or more ppm of PCBs can also be disposed of by other
methods approved by the EPA Regional Administrator if it can be
demonstrated that incineration or chemical waste landfilling is
not reasonable and appropriate and that the alternative disposal
method is protective of human health and the environment.
  
The TSCA also provides regulations for the proper storage of
material contaminated with PCBs.  Pretreatment materials handling
would require sorting, sizing, and storing PCB-contaminated
material.

The CAA provides regulations for the control of fugitive dust and
NESHAP standards for some chemicals.  Every alternative would
involve the control of fugitive dust.  Fugitive dust regulations
would be applicable.  Technologies that cause the generation of
hazardous particulates, fumes, or vapors would need to address
CAA and NESHAPS requirements as promulgated under state law. 
These requirements would be applicable.

The SWDA regulates the disposal of solid waste.  Solid waste
treated for PCBs would still need to be disposed of as a solid
waste after PCB treatment.  In this case, the SWDA would be
applicable.  

NPDES discharge limitations would apply to any wastewater stream
that is treated and discharged to surface water.  Depending on
the location of the receiving stream in relation to the CERCLA
site, NPDES requirements will either be applicable or relevant
and appropriate.  Pretreatment standards are applicable to any
wastewater stream, such as the lagoon water, that is discharged
to a publicly owned treatment works (POTW).  NPDES discharge
limitations and pretreatment standards are set by the State of
Indiana and local POTW authorities.  CWA storm water runoff
regulations would apply to waste removal and site restoration
activities.  CWA storm water runoff regulations are implemented
under the IAC.  327 IAC 2-6-2 presents reporting and action-specific requirements when a spill or release of hazardous
substances threatens the water of the State of Indiana.

Table B-3 of Appendix B provides greater detail and regulatory
citations for all potential action-specific ARARs and criteria
TBC that may apply to the remediation of the six sites.

3.1.2.4        Other Requirements To Be Met

The remedial actions must also meet other requirements that are
not ARARs or criteria TBC but that do apply to the actions. 
These other requirements are not considered ARARs because they
cannot be waived using an ARAR waiver.  These requirements
include the CERCLA Offsite Rule, U.S. Department of
Transportation requirements for the packaging and transport of
hazardous material, and Occupational Safety and Health
Administration regulations for the protection of worker health
and safety.  Table B-4 of Appendix B presents information on how
these requirements apply and what specific actions or limits they
impose.

3.2       GENERAL RESPONSE ACTIONS

GRAs, such as removal, treatment, and disposal, are responses or
remedies intended to meet RAOs for the site.  GRAs identified for
the site include the following:

          Removal, treatment, and disposal
          In situ treatment
          Removal and disposal

Two common response actions, no action and containment, are not
included in this FS.  As discussed in Section 1.2, the no action
GRA is not being considered because the parties to the CD have
determined that action is required at the sites.  The containment
GRA is not being considered because evaluation of the containment
GRA does not meet the intent of IC 13-7-16.5-9, which specifies
that alternative PCB treatment technologies be evaluated before
issuing a permit to construct an incinerator for PCB treatment.

The GRAs will be applied to the PCB-contaminated material from
the six sites.  The estimates for volumes of the various types of
primary contaminated materials are presented in Table 2-9.

3.3       IDENTIFICATION AND SCREENING OF TECHNOLOGY TYPES AND
          PROCESS OPTIONS

The purpose of Section 3.3 is to identify and screen a list of
primary remediation technologies and support technologies that
can be combined into viable alternatives.  Section 3.3.1
identifies the universe of primary remediation technology types
that accomplish the GRAs identified in Section 3.2.  Section
3.3.2 identifies the universe of potentially applicable support
technologies that may be combined with a primary remediation
technology to formulate alternatives.  Section 3.3.3 identifies
specific primary remedial process options for each technology
type and presents the initial screening of the process options. 
The process options are evaluated based on their applicability to
PCBs and their availability.  Section 3.3.4 presents a more
rigorous screening of the technology types and process options
that survived the initial screening.  The more rigorous screening
evaluation is based primarily on effectiveness and implementa-
bility.  The cost of the technology type or process option is
also considered to a lesser degree.  

Implementation of the various primary remediation technologies
involves many common elements.  For example, all ex situ
treatment technologies involve waste removal and transport to the
off-site treatment site.  Limited removal and transport
technologies exist to accomplish necessary waste removal and
transport activities.  All technologies involve restoration of
the six sites.  In fact, all treatment technologies involve a
limited number of waste handling, storage, separation, or sizing
steps, and most treatment technologies require treatment
residuals disposal.  Some technologies require treatment and
disposal of a concentrated waste stream.  TSCA dictates the
specific treatment of particular waste types such as the
incineration of intact capacitors.  

This FS does not attempt to screen the various support
technologies such as waste handling and treatment residuals
disposal described above.  Instead, the FS report categorizes
these support technologies as either planning, pretreatment site
preparation, contaminated material removal and excavation,
secondary treatment, post-treatment, and site restoration
activities.  The potential support technologies identified in
Section 3.3.2 are then matched with the primary treatment
technologies that survive the screening process to form remedial
alternatives.  The selection of appropriate support technologies
is based on best professional engineering judgment considering
waste characteristics, physical needs of the technology, health
and safety concerns, and regulatory requirements.  This approach
was chosen as the most practical way to develop remedial
alternatives.

3.3.1          Identification of Primary Technology Types

This section identifies the universe of primary remediation
technology types that accomplish the GRAs identified in Section
3.2.  Within each GRA, specific remedial technology types are
identified to achieve the response action.  The GRAs and primary
technology types are as follows:


          Removal, treatment, and disposal -- Biological,
          physical/chemical, thermal destruction, thermal
          desorption, and off-site commercial treatment

          In situ treatment -- Biological, physical/chemical, and
          thermal treatment

          Removal and disposal -- Off-site commercial disposal


3.3.2          Identification of Support Technologies

Support technologies will primarily involve excavation, handling,
staging, segregation, and transportation of PCB-contaminated
material, as well as site preparation and restoration activities,
runoff and runon control, and site access control.  The support
technologies will be common to the remedial alternatives
evaluated and can generally be categorized as follows:  (1)
planning activities, (2) pretreatment site preparation
activities, (3) contaminated material removal and excavation
activities, (4) secondary treatment activities, (5) post-treatment activities, and (6) site restoration activities. 
Figure 3-1 presents the overall material flow for remediation of
the six sites, identifying key support technologies.  These
activities are discussed below.

3.3.2.1        Planning Activities

In general, a number of preliminary planning activities should be
conducted prior to actual site remediation activities.  The
remedial alternatives would require the preparation of a site-specific work plan, Health and Safety Plan (HASP), and Quality
Assurance Project Plan (QAPP).  The QAPP should include the
requirements for confirmation sampling at the Lemon Lane Landfill
and additional sediment sampling at the Bennett Stone Quarry,
Neal's Landfill, and Winston-Thomas Sewage Treatment Plant sites. 
Access routes and weight limits for transporting heavy equipment
and treated and untreated contaminated material should be
established prior to actual site remediation activities. 
Community relations and education issues should also be initiated
at this time.  All necessary, local, state, and federal permits
(for example, building, air, pollution control, wastewater, and
solid waste) must be obtained prior to initiating site
preparation activities.

3.3.2.2        Pretreatment Site Preparation Activities

Prior to actual site removal actions, each site must undergo
pretreatment site preparation.  Fenced sites may need to have the
fences removed to increase site accessibility for earthmoving
equipment and allow for easier removal of landfill caps, liners,
topsoil, and contaminated material.  On-site road improvements
should be constructed to allow for easy entrance and egress from
the sites.  Property boundaries and excavation areas should be
field-staked based on certified land surveys.  Any utilities (for
example, telephone and electricity) to support activities at each
waste site should be established.

All vehicles leaving the six sites or the central treatment
facility (CTF) should be decontaminated with a surfactant and
water to remove PCB residues.  As required in 40 Code of Federal
Regulations (CFR), Part 761, all vehicles leaving the six sites
or CTF should undergo PCB decontamination procedures specified in
TSCA.  Vehicle surfaces should be decontaminated to less than or
equal to federal and state PCB decontamination standards. 
Vehicles not meeting this decontamination requirement should be
rewashed and rechecked for PCB residues. 

The decontamination water used at all six sites should contain
about 2 percent surfactant and about 
98 percent water.  All decontamination water should be batched
mixed in 1,000- to 5,000-gallon temporary storage tanks.  The
decontamination water should be applied to all vehicles at the
six sites using a hot water and steam cleaner in an enclosed,
tent-like structure.

At each site, the decontamination area should be constructed to
capture all decontamination water for on- or off-site treatment
and disposal.  The decontamination area can be a concave gravel
base covered with a heavy, high-density polyethylene (HDPE) liner
and backfilled with smooth, round gravel of sufficient depth to
support the heaviest piece of equipment expected to be
decontaminated.  The decontamination pad should be sized to
easily accommodate either the largest equipment piece or two
trucks used to transport excavated material off site, depending
on which is larger.  The pad should also be equipped with a pit
and sump pump with a capacity adequate to collect and transport
decontamination wastewater from the sump into a 20,000-gallon,
aboveground, Baker-type storage tank.  Sites of greater than 10
acres should have a minimum of two such tanks to adequately
handle expected decontamination water volumes.
                            FIGURE 3-1
            MATERIAL FLOW FOR KEY SUPPORT TECHNOLOGIESAt the CTF, a closed-loop, 60- by 40-foot decontamination vehicle
wash station should be constructed that can handle two 40-foot
tractor trailers.  The vehicle decontamination station should be
constructed of concrete and brick and should be equipped with a
decontamination water collection pit, sump pump, and spray and
wash components.  The decontamination water should be treated
with a granular activated carbon (GAC) filter system and then
should be recycled at the wash station.  When the decontamination
water becomes spent, it should be transported to a central water
treatment system for further treatment.

A central debris washing system should be constructed that
decontaminates high-contact surface PCB-contaminated wastes such
as scrap metal, rock, white goods, and other unspecified
demolition, industrial, and municipal wastes.  The central debris
washing system could be constructed at the CTF.  The debris wash
system can be set up with (1) dual 5,000-gallon or larger spray-wash chambers connected to a detergent solution holding tank and
rinse water tank; (2) two 2,000-pound or greater wash baskets;
(3) a 5-ton crane to move the baskets in and out of the spray-wash chambers; (4) a diesel-fired, 2 million British-thermal-unit-per-hour or greater water heater; (5) a water treatment
system that uses particulate filters and an oil/water separator;
(6) an air emissions system to capture fugitive inorganic and
organic contaminants; and (7) a 100- by 100-foot concrete pad. 
About 10,000 gallons of water would be needed to operate the
debris washing system.  The debris washing system may have to be
enclosed to minimize air emissions.  The sludge collected from
the debris washing system may be dewatered or dried as needed and
treated in the treatment system for treating PCB materials.
       
All sites are vegetated with grasses, trees, or shrubs.  Prior to
excavation, mature trees should be cleared and removed, and any
building remnants should also be removed.   Trees can be felled
using chain saws, and the resulting limbs can be collected and
staged for off-site disposal using end loaders.  End loaders
should be equipped with 4- to 6-yd3 capacity buckets.  Building
remnants such as foundations and walls should be removed using
excavators, loaded on dump trucks, covered, and transported to an
approved disposal facility.  If building remnants require
treatment, they will have to be broken, crushed, and shredded to
a smaller, more uniform size.  Crushing and shredding operations
should be conducted at the CTF.  Because of anticipated low
contaminant levels in building remnants, it is recommended that
this material be visually screened and sampled, if necessary, for
PCB contamination and disposed of in an appropriate landfill.

Topsoil should be scraped from the sites and stockpiled to be
reused for site restoration.  Clay cap material should also be
stockpiled and reused if it is not contaminated.  Topsoil and
clay cap material should be sampled and analyzed for PCBs and
other contaminants as required by TSCA and other appropriate
regulations.  If contaminated, the topsoil and clay should be
removed and treated with the other PCB-contaminated material. 
Stockpiling and grading can be performed using end loaders and
bulldozers to efficiently store scraped material.  For sites of
limited space such as Neal's Dump site, which prohibits on-site
topsoil stockpiling, the potential for temporary off-site
storage, possibly on adjacent property or at the CTF, should be
evaluated.  Effective soil erosion control measures should be
implemented at all the topsoil stockpiles.

To help control air emissions generated from materials handling,
sorting, and storing activities, as well as control material
moisture content, construction of a materials sorting and storage
building is recommended at the CTF.  Construction of this
building should be completed prior to initiating site excavation
activities.  The material sorting and storage building could
house materials handling, sorting, and storing operations and
equipment prior to on- or off-site treatment and disposal.  In
addition, the building will provide protection from the elements,
thus allowing these activities to take place regardless of
inclement weather.

The CTF materials sorting and storage building must be large
enough to accommodate material sorting, shredding, crushing, and
grinding, and equipment handling activities, as well as house any
other pretreatment processing equipment required by the
alternative treatment technology.  In addition, the building must
provide adequate space for staging material before and after any
sorting, shredding, and other pretreatment processing activities.

3.3.2.3        Contaminated Material Removal and Excavation
               Activities 

To help minimize potential soil erosion and divert surface water,
it is recommended that each site be excavated in a sequential
approach, replacing excavated material with clean fill material
daily as the work progresses.  This approach should be described
in an approved excavation plan that discusses excavation methods,
health and safety monitoring, runon and runoff controls, waste
sampling and analysis and waste and soil removal, allowing for
on-site presorting of excavated material at each site and the
control of contaminated surface water runon and runoff.  Using a
bulldozer making progressively deeper passes, a strip of
contaminated material can be removed and piled up.  An excavator
can then remove material from the pile and place it in a dump
truck.  If water accumulates in the excavated area, the water
should be pumped and stored in the on-site Baker tanks with the
decontamination water.  Presorting involves the excavator
operator removing material from the pile in a manner that allows
him or her to "screen out" unwanted material such as scrap metal
and white goods using the excavator bucket.  The objective of
presorting is to screen out large, bulky items not suitable for
the selected treatment technology, such as white goods and large
pieces of scrap metal, and to maximize loading and transporting
of materials with a slightly more homogeneous nature.  Material
could also be visually screened or sampled and uncontaminated
material separated from the PCB-contaminated material, if
necessary, as described in the approved excavation plan.  If
possible, PCB-contaminated capacitors should be staged separately
from other wastes.  Otherwise, PCB-contaminated capacitors mixed
with other materials can be loaded along with the contaminated
material into the dump trucks for transport to the CTF for
separation from other excavated material.  The excavators used on
the sites should be equipped with 3- to 6-yd3 buckets.  

During excavation, it may be necessary to implement some type of
screening and sampling action to assess the extent of PCB
contamination in the excavated materials and the effectiveness of
treatment, washing, and decontamination activities.

A possible scenario that assumes some of the waste material
encountered is uncontaminated requires assessing the extent of
PCB contamination to minimize the volume of material managed as
PCB- contaminated material.  This assessment will require
handling PCB-contaminated and noncontaminated materials
separately.

Sampling and analysis activities should be implemented during
excavation and conducted in accordance with an approved
excavation plan.  For excavation projects, time, cost, and
logistics are critical factors in implementing a successful
sampling program; therefore, a combination of visual assessment
and field screening should be implemented.  Visual assessment
should consist of observing excavated material for evidence of
PCB contamination such as staining, discoloration, nearby damaged
capacitors, and soiled rags.    Field sampling should then be
conducted to determine whether the material is contaminated or
not contaminated.  A waste staging and sampling plan should be
developed and implemented to ensure that wastes are handled
properly.

If a broken capacitor is found and staining is observed, one
could assume that the material is PCB-contaminated.  If no
obvious visual evidence of PCB contamination exists, samples of
the material should be collected and undergo a PCB field
screening test.  The PCB field screening test may consist of a
proven immunoassay colormetric test kit or a mobile field gas
chromatograph (GC) unit.  The immunoassay test can analyze up to
about 17 samples per hour, and the GC test can process about one
sample per hour.  Sampling at this level should be conducted to
confirm the presence or absence of PCB contamination at 50 ppm or
above only.

If the scrap metal and white goods are contaminated, they should
be loaded onto the trucks with the other contaminated material
for transport to the CTF because the excavation sites may not
have storage capabilities for PCB-contaminated materials. 
Uncontaminated scrap metal and white goods should be placed in
clean trucks and transported directly to the solid waste
landfill.  Covered trucks containing contaminated material should
be decontaminated before they leave the excavation site.  The
contaminated material could be treated at the CTF.  If specific
remediation options require further screening for size-related
and material-type processing requirements, these activities
should occur at the CTF site.  Recommended dump truck capacity is
15 to 40 yd3; however, the actual truck sizes used will depend on
the maximum load limits along the transportation routes.  In
order to hasten removal activities at the Bennett Stone Quarry,
Lemon Lane Landfill, and Neal's Landfill sites, two bulldozers,
two excavators, and ten dump trucks can be used to excavate two
strips simultaneously.  Actual site characteristics will dictate
the volumes and sizes of equipment used at each site.  As part of
the contaminated material removal, excavation, and sorting
activities, measures to minimize adverse impact of the activities
will be necessary.  For example, lightly dampening the material
being excavated with a surfactant and water dust suppressant
solution could be used to minimize fugitive dusts and odors.  

Waste characterization could largely impact the degree and
methods of material sorting.  For instance, on-site magnetic
separation at the excavation site can be used if the material
unearthed includes a large amount of metallic debris.  A magnetic
separator could be useful at the Lemon Lane Landfill, Neal's
Landfill, and possibly Bennett's Stone Quarry sites because of
the amount of mixed contaminated material anticipated.  The
objective of presorting is to simplify material handling
activities and facilitate treatment and disposal alternatives.  

The selection of a remedial alternative will also influence
sorting operation details.  Individual remedial alternatives may
be able to treat different types or sizes of materials.  As
trucks bring the contaminated material to the CTF, the material
should be unloaded at a storage area.  Contaminated white goods,
scrap metal, rock, and other unspecified demolition, industrial,
and municipal debris should be separated from the other material
at this point and washed by the central debris washing system. 
This debris should then be wipe sampled, if necessary, to assess
and to verify decontamination effectiveness.  Cleaned debris can
then be transported to the solid waste landfill.  

Remaining contaminated material consisting of soil and rock,
sludge, sediment, capacitors, and other solid waste can then be
loaded into a sorting system capable of sorting materials to meet
the needs of the selected treatment option.  Figure 3-2 presents
a flow chart that includes potential operations at the CTF.

The Winston-Thomas Sewage Treatment Plant site is unique from the
other sites because it is not a landfill but rather a former
wastewater treatment plant.  Support technologies to handle
contaminated material and waste streams with high water content
may be required and site restoration may include wetland
restoration.  This site includes a 17-acre lagoon with an
estimated water volume of about 1.2 million gallons.  Because of
the large water volume and amount of available space on site,
treatment of this water on site using a pump and filter system
may be the most effective and efficient approach to meeting the
RAOs.  Once the water is removed from the lagoon, the sludge
layer (about 0.75 feet thick) and clay liner buffer (about 2 feet
thick) can be removed using excavation techniques such as damming
sections of the lagoon bottom and scraping each section to the
required depth.  To reduce mass and allow for easier handling and
treatment, the scraped material can be dewatered, if necessary,
using equipment such as a filter press.  Generated wastewater can
then be processed through the same filtration system as the
lagoon surface water prior to sampling and discharge to the
nearest surface water body or sanitary sewer.

FIGURE 3-2     CTF MATERIALS HANDLING FLOW CHART FOR ALTERNATIVES 1
                              THROUGH 73.3.2.4        Secondary Treatment Activities

Secondary treatment technologies primarily involve handling and
disposition of residuals and by-products generated by the
selected remedial alternatives.  The secondary treatment
technologies involve contaminated materials such as residues,
ash, condensed oil and organics, decontamination and treatment
process water, solids, combustion gases, used personal protective
equipment (PPE), and spent activated carbon and filter media.  
Other secondary contaminated materials include water from the
lagoon and water and pipes contaminated with PCBs located at the
Winston-Thomas Sewage Treatment Plant site.  Secondary treatment
technologies will also address contaminated material considered
secondary to the primary contaminants of concern at the six
sites.  Secondary treatment activities include treatment of
material other than the PCB-contaminated solid waste at each site
(for example, uncontaminated solid waste and debris,
decontamination water, contaminated surface water, and treatment
by-products and residuals).   The estimated volume of these solid
wastes ranges from 0 to 74 percent of the total waste volume
anticipated at the sites.  All sites except Neal's Dump, which is
believed to contain PCB-contaminated material and capacitors
only, could require the handling and transport of solid waste
material to the appropriate solid waste landfill.

Decontamination water generated from activities at each site
should be collected at each site in the on-site Baker tanks.  The
collected decontamination water could be pumped from the Baker
tanks into tanker trailers, transported to the central water
treatment system, and placed into other 20,000-gallon Baker
tanks.  The Winston-Thomas Sewage Treatment Plant site includes a
wastewater lagoon that contains water contaminated with PCBs at
levels of up to 0.9 ppm.  This water requires treatment. 
Therefore, the Winston-Thomas Sewage Treatment Plant site could
be used to establish the central water treatment system.  The
central water treatment system should remove heavy metals and
suspended solids, dewater sludge, and reduce the PCB levels in
the water.  The dewatering operation may consist of a filter
press-type process through which water is pumped and solids
removed.  The collected solids can then be placed in appropriate
containers and transported to the CTF for treatment.  Water
effluent from the filter press system could then be processed
through a GAC filter system to remove residual organics.  A
prefilter may be necessary to remove contaminated solids in the
water.  All filter media should be processed through the selected
treatment technology if the technology is capable of treating the
filter media.  The treated filter media can then be disposed of
in the appropriate landfill (a solid waste landfill if the
material contains less than 50 ppm PCBs and a TSCA landfill if
the material contains greater than 50 ppm PCBs and does not
contain water).  If the treatment technology is unable to treat
the filter media, the filter media should be placed in approved
containers and transported off site for incineration and
landfilling.  All wastewater effluent from the central water
treatment system could be discharged to the City of Bloomington's
sewage treatment plant if PCB and other contaminant levels are
below the City of Bloomington's effluent discharge limitations.  
As an alternative, the effluent from the central water treatment
system could be discharged to surface water if a National
Pollutant Discharge Elimination System permit is applied for and
approved by IDEM.

The selected alternative treatment technology used to treat PCB-contaminated soil and debris material will likely generate a PCB-contaminated waste stream such as ash, scrubber blowdown, process
wastewater, solids, organic sludge, or other materials.  If
possible, these treatment by-products should be processed through
the treatment technology to reduce PCB levels.  If this procedure
is not possible and if by-product PCB levels cannot meet the PCB
treatment standard level of less than 2 ppm, the by-products and
residuals should be placed in approved containers and transported
off site to a TSCA landfill or incinerator.
 
3.3.2.5        Post-Treatment Activities

Post-treatment activities take place at the treatment site after
contaminated material treatment.  After treatment is complete,
all contaminated equipment used such as excavation, sorting,
material handling, and other equipment should be decontaminated. 
Because of the size and nature of the equipment, effective
decontamination is likely to be labor-intensive and costly. 
Effective decontamination methods and operating procedures should
be determined at the first site where remedial activities begin
by wipe sampling and field testing equipment used for
contaminated material excavation.  All vehicles, excavation
equipment, and other high contact surfaces should meet TSCA PCB
decontamination requirements.  As required in 40 CFR, Part
761.125(c), high contact surfaces must be decontaminated to a PCB
concentration of less than 10 microgram per cubic centimeter
( g/cm2).  Vehicles and equipment not meeting this requirement
should be rewashed.  Any decontamination water should be
collected for off-site treatment at the central water treatment
system.  The treated decontamination water should undergo
analysis prior to discharge.  Any remaining process water
generated from the remediation technology alternative should also
undergo analysis.  Waste stream characteristics will largely
influence the material handling requirements for this material.

In addition to treatment of on-site water and sludge, the
dewatering and water treatment system proposed for construction
at the Winston-Thomas Sewage Treatment Plant site could be used
to treat the sludge and water generated from excavation and
decontamination activities at the excavation sites.  Wastewater
generated from these sites could be transported to the Winston-Thomas Sewage Treatment Plant site in tanker trailers and
unloaded into Baker tanks.  

3.3.2.6        Site Restoration Activities

Prior to completing removal activities at each waste site, the
post remediation land use should be determined to assess final
backfill and grade requirements, this should include preparing a
finished topographic contour design to prevent double handling
material, maintain permanent erosion control, and contain costs. 
Appropriate clean fill material should be located and assessed. 
Once located, the material should be excavated and transported to
each site as removal activities are completed.  Using clean
earthmoving equipment, the fill should be placed in the daily
excavation at the waste site, compacted as necessary, graded, and
covered.  This way, the site can be partially restored as waste
material is removed.  This process could require some type of
segregation between contaminated and uncontaminated materials at
the daily excavation, which could be accomplished through
appropriate earthmoving actions coupled with other erosion
control methods (for example, covering exposed soil with straw or
geotextile material).  At this point, clay caps required by the
CD at the sites could also be partially installed, with final
clay cap installation occurring after waste removal completion. 
After the entire site has been excavated and partially restored,
the stockpiled topsoil should be graded over the former waste
site.  Topsoil and clay cap material should be sampled and
analyzed for PCBs and other contaminants as required by TSCA and
other appropriate regulations.  Each former waste site should
then be appropriately revegetated.

3.3.3          Identification and Initial Screening of Primary
Remedial Process Options

The purpose of this section is to identify and initially screen
the primary remedial process options for the remedial action at
the six sites.  The process options for each primary remedial
technology type were selected based on the Remedial Technologies
Screening Matrix and Reference Guide (EPA 1993c).  For each
specific remedial technology type, process options corresponding
to that technology are initially screened to identify applicable
technologies for further evaluation and assembly into potential
remedial alternatives.  For example, biological treatment is a
remedial technology type that consists of the following process
options: slurry-phase biotreatment (SPB), landfarming, and
controlled solid-phase biotreatment (CSPB).  The range of process
options available for consideration at the six sites have been
reduced by screening the process options with respect to the
following activities:

          Applicability for treating PCB-contaminated material
          Exclusion from or inclusion in the FS
          Technical implementability, including current stage of
          development

Figure 3-3 presents the results of the initial process options
screening step.

3.3.4          Screening and Selection of Process Options

The purpose of this section is to identify technically
implementable process options that may be combined with support
technologies to remediate PCB-contaminated material at the six
sites.  Three criteria are used in this section to screen the
process options for each of the applicable remedial technologies
prior to the detailed analysis.  These criteria are
effectiveness, implementability, and cost.

The effectiveness evaluation considers the following:


          The potential effectiveness of each process option in
          (1) handling the estimated volume of contaminated
          materials and (2) meeting the RAOs identified in
          Section 3.1

          The effectiveness of each process option in
          eliminating, reducing, or controlling current and
          potential risks from each site

          The reliability of each process option to address the
          contaminants and conditions at the six sites

Technology types and process options that do not effectively
protect human health or the environment and those that may pose
significant adverse environmental effects or offer very limited
environmental benefits will not be considered for detailed
analysis.

The implementability evaluation considers both the technical and
institutional feasibility of implementing each technology type
and process option.  Technical implementability involves the
degree of difficulty associated with actual construction and
logistic activities.  Examples of institutional implementability
include availability of proposed remediation technologies, time
required for installation, and ability to obtain necessary
permits.  The cost evaluation is limited at this stage of the
screening process.   Relative capital and operation and
maintenance (O&M) costs are used rather than developing detailed
cost estimates.  The cost of each process is identified as either
high, medium, or low relative to other process options.  For the
process options, a low capital and O&M cost is considered less
than $200 per ton of material treated; a medium capital and O&M
cost is considered between $200 and $300 per ton of material
treated; and a high capital and O&M cost is considered greater
than $300 per ton of material treated.  The remedial technology
and process option screening results are presented in Figure 3-4.

At least one representative process option for each remedial
technology type has also been selected.  The entire remedial
technology and all its process options may be eliminated if the
technology is not technically implementable for remediation of
PCB-contaminated material from the six sites.

3.3.4.1        Biological Treatment Process Options

Two of the three types of biological treatment process options
retained after the initial screening and potentially applicable
at the six sites include SPB and CSPB.  Both of these process
options rely on indigenous or inoculated microorganisms to
degrade organic contaminants in soil, sludges, slurries, and
groundwater under controlled conditions.  In the presence of
oxygen (aerobic conditions), microorganisms will ultimately
destroy organic compounds, converting them into carbon dioxide,
water, hydrogen gas, and minerals.  In the absence of oxygen
(anaerobic conditions), halogens will be removed from halogenated
organic contaminants, and given adequate time, organic
contaminants will be ultimately metabolized to methane, carbon
dioxide, and hydrogen gas.  

Biological treatment of PCB-contaminated materials is primarily
in the research and development stage, and performance data for
pilot- and full-scale applications  are very scarce.  In
addition, laboratory-scale data are often reported in terms of
performance efficiencies; for example, in percent of removal or
destruction, which does not allow effectiveness of biological
treatment to be directly evaluated against the PCB treatment
standard level of less than 2 ppm for the six sites.  Biological
treatment is effective in terms of destroying contaminants
instead of transferring contaminants to another media or a
concentrated waste stream that requires further treatment.  The
effectiveness of PCB biodegradation is impacted by several
operating parameters, including establishing aerobic and
anaerobic environments sequentially, adding amendments and
nutrients, and adding inoculations of isolated microbial strains
versus relying on naturally-occurring microbial populations.
                            FIGURE 3-3
   IDENTIFICATION OF REMEDIAL TECHNOLOGIES AND PROCESS OPTIONS3-3IDENTIFICATION OF REMEDIAL TECHNOLOGIES AND PROCESS OPTIONS                            FIGURE 3-4
      SCREENING SUMMARY OF REMEDIAL TECHNOLOGIES AND PROCESS
OPTIONS                            FIGURE 3-4
    SCREENING OF SUMMARY OF REMEDIAL TECHNOLOGIES AND PROCESS
OPTIONSStudies have shown that biological treatment of highly
chlorinated PCBs requires sequential anaerobic-aerobic processes
to first dechlorinate the congeners anaerobically, and then to
aerobically biodegrade the resultant less-chlorinated congeners. 
The Aroclors released to the soils and sludges at the six sites
originally contained highly chlorinated congeners.  However, the
contaminated materials at the six sites have most likely been
anaerobic for several years, and intrinsic dechlorination may
have occurred during that time.  Implementation of full-scale
biological treatment should be preceded by predesign studies that
assess the current degree of chlorination of the congeners to
determine whether anaerobic treatment should necessarily precede
aerobic treatment. 

In general, biological treatment is potentially applicable to
treatment of contaminated soils, slurries, sludges, and
biodegradable elements present in solid waste, but it is not
applicable to treatment of contaminated debris and capacitors. 
The sections below describe the SPB and CSPB process options and
evaluates the effectiveness, implementability, and cost of these
options.

3.3.4.1.1 Slurry-Phase Biotreatment

SPB involves the controlled biological treatment of slurried
material in a bioreactor.  After excavation and separation of
stones and debris, the material is mixed with water to a
predetermined solids ratio dependent on the concentration of the
contaminants, the rate of biodegradation, and the physical nature
of the material.  Typically, the slurry contains 10 to 40 percent
solids by weight.  The soil is maintained in suspension in a
batch reactor and mixed with amendments and oxygen.  Amendments
may include inorganic nutrients (typically nitrogen and
phosphorous), organic substrates, and an acid or base to adjust
pH.  Oxygen is typically provided by sparging air into the
slurry.  A microorganism inoculum may also be added if a
nonindigenous strain is desired.  A continuous flow system is
advantageous over a batch system to dilute sudden high PCB
concentrations in the feed waste and to continuously maintain a
population of well acclimated microorganisms.  When
biodegradation is complete, the slurry is dewatered. 

Effectiveness

As discussed above, the effectiveness of biological treatment of
PCBs is primarily in the research and development phase.  Of the
limited data on biological treatment of PCBs available, no
performance data can be found that demonstrate that SPB can treat
PCBs to meet the cleanup goal for the six sites.  Bench- and
pilot-scale treatability studies should precede full-scale
implementation of SPB to determine the required treatment time
and other operating parameters.  At the Sheridan Disposal
Services Site in Hempstead, Texas, a pilot-scale study was
conducted to evaluate SPB using a series of bioreactors fed
semicontinuously with slurried PCB-contaminated sludge and soil. 
For tests performed using a 15-day hydraulic residence time on
feed waste containing 20 to 30 percent solids by weight, the
average PCB concentration was reduced from 43 ppm in the
untreated sludge to 12 ppm in the treated slurry (Radian 1992).

Implementability

Limitations in the implementability of SPB include the increased
volume of material requiring treatment due to the addition of
water.  In addition, bioreactors are available having volumes
typically less than the volume that can be provided by CSPB
units; therefore, numerous bioreactors may be necessary to
provide the same throughput that can be provided by CSPB.  SPB
may also require dewatering of treated slurry before disposal and
additional treatment and disposal for nonrecycled wastewaters. 
SPB also requires that materials be more thoroughly sized and
screened before treatment than CSPB.  Bioreactors and associated
equipment required for SPB are available, although not as readily
as the equipment required for CSPB. 

The SPB batch reactor provides a homogeneous mixture that allows
better control and monitoring of progress than with CSPB.  For
contaminants other than PCBs requiring aerobic treatment only,
SPB is more implementable than CSPB in terms of shorter treatment
times and less space requirements.  However, the space savings
advantage may be offset by the increased number of bioreactors
needed to provide anaerobic conditions followed by aerobic
conditions in successive bioreactors.

Cost

The relative capital and O&M costs for SPB are greater than for
CSPB because of (1) the space required for successive batch
reactors, (2) the need for equipment to dewater treated slurry,
and (3) the need for additional operational control to
continuously feed waste into the bioreactor and to remove and
dewater treated slurry.  The relative capital and O&M costs for
SPB are medium.

3.3.4.1.2 Controlled Solid-Phase Biotreatment

The CSPB process option involves mixing contaminated material
with soil amendments and placing the combined material in an
enclosed treatment unit where microorganisms degrade organic
contaminants.  CSPB units typically include leachate collection
and may be covered with an impermeable liner or contained in a
building to minimize the risk of contaminants leaching into
uncontaminated soil and groundwater and to enhance anaerobic
microbial processes.  For aerobic treatment, CSPB units include
aeration equipment.  Moisture, heat, nutrients, oxygen, and pH
can be controlled to enhance biodegradation.   

CSPB units include prepared treatment beds, biotreatment cells,
composting areas, and soil piles.  Prepared beds are aerated
either by injection of air or oxygen through perforated pipes or
by soil tilling.  If tilling is used, the contaminated soil is
typically treated in successive lifts until the entire volume of
soil has been treated.  Some prepared bed techniques involve the
continuous spray application of an amendment solution on the
soil.  Amendments are additives that are applied to contaminated
materials to enhance microbial activity and growth.  Additives
may include inorganic nutrients, organic substrate, and bacterial
inoculum, and are typically applied as a solution.   After the
solution has infiltrated through the soil, the leachate is
typically collected and recycled back onto the soil.  The
leachate may be treated in a bioreactor before recycling.  Soil
piles and biological treatment cells commonly use an air
distribution system buried under the soil to pass air through the
soil either by vacuum or by positive pressure.  With such a
system, soil piles can be up to 20 feet high. 

Composted materials are typically mixed with amendments and
bulking agents such as wood chips, mulch, or other vegetative
wastes to enhance the porosity of the mixture to be decomposed. 
The composted materials are often placed in long piles called
"windrows."  To facilitate bacterial growth, water and nutrients
are sprayed on the windrows, which may also be periodically mixed
using agricultural equipment to provide aeration. 

Effectiveness

As discussed above, the effectiveness of biological treatment of
PCBs is primarily in the research and development phase.  Limited
bench-scale performance data for CSPB indicate that sequential
anaerobic-aerobic treatment may be effective for treating PCBs. 
However, CSPB has not been proven effective at full scale for
treating PCB-contaminated materials.  Sequential
anaerobic-aerobic treatment could be provided by constructing the
CSPB unit with aeration equipment in place but not aerating the
contaminated material for an initial period of time.  By delaying
aeration and by placing a geomembrane over the contaminated
material in the CSPB unit, an anaerobic environment should be
established.  The geomembrane would also capture and contain
heat, thereby further enhancing anaerobic microbial activity. 
Aeration would be started and the geomembrane would be removed
after the highly chlorinated congeners have been dechlorinated. 
Adequacy of dechlorination could be determined by periodic
sampling and analysis of the contaminated material.  After
dechlorination, inoculations of aerobic bacterial strains may be
required.  Sequential anaerobic-aerobic treatment of
PCB-contaminated materials was attempted at the Sheboygan River
Superfund site in Sheboygan County, Wisconsin, using a CSPB unit,
but the results of this study were inconclusive as of early 1994
(EPA 1994b and 1994d).

Implementability

Relative to other treatment processes, CSPB is easily
implementable in terms of equipment and skilled personnel
requirements.  Depending on the type of CSPB unit used and the
level of controls, equipment requirements may include perforated
piping and blowers or agricultural equipment for aeration;
sprinkling systems or perforated piping for amendment solution
distribution; perforated piping, sand, an impermeable
geomembrane, and water pumps for leachate and runoff collection;
an impermeable geomembrane cover to create an anaerobic
environment and contain heat; and a concrete retaining wall,
earth berm, or building to contain the unit.  

The implementability of the CSPB option also depends on the
required size of the CSPB units, which is determined by the
minimum required batch size.  If the required batch size is very
large, adequate land area may not be available for prepared beds,
and soil piles and compost windrows may become too large for
proper control.  Biotreatment cells could be constructed with
high walls and extensive air distribution piping to enable
treatment of large volumes of contaminated material.  For a fixed
total volume of contaminated materials and allowable treatment
time, the required batch size is determined by the time required
to treat a batch.  The kinetics of the biological processes that
cause biodegradation depend on a number of factors that are very
site-specific and require predesign studies to evaluate.  

Potential releases of contaminants during implementation of CSPB
include leaching of PCBs to soil and groundwater,
PCB-contaminated runoff to soils and surface water, and
volatilized PCBs and methane gas escaping to air.  The potential
for release can be minimized by equipping the CSPB unit with
adequate controls.  An impermeable liner and leachate collection
system should be provided to collect and recycle leachate.  The
generation of contaminated leachate and runoff can be prevented
by covering the CSPB unit with an impermeable liner or enclosing
it in a building.  During aerobic treatment, aeration, tilling,
and elevated temperatures (particularly in compost piles) may
potentially cause volatilization of PCBs and their release to the
atmosphere.  The amount of mixing and aeration should be just
enough to promote bacterial growth but minimize volatilization,
which should not be significant.  PCBs are not highly volatile,
and releases to air are not expected to be a problem, but as a
preventive measure, aeration could be provided by drawing air
through the soil by vacuum and treating the exhaust.  Similarly,
during anaerobic treatment, the air distribution system could be
used as a passive methane collection system, and the off-gas
could be treated, if necessary.

Cost

The relative capital and O&M costs for CSPB are low.  A minimal
amount of capital equipment is required, which is mostly
inexpensive.  O&M costs would only involve labor for periodic
checks on the system and the cost of purchasing amendments.

Summary of Biological Treatment Process Options

The CSPB process option will be retained for detailed analysis as
the representative process option for biological treatment.  This
treatment process can be implemented more readily than SPB to
provide sequential anaerobic-aerobic treatment, which is most
likely necessary for successful biological treatment of the
contaminated materials at the six sites.  As stated above,
predesign treatability studies should be conducted to determine
whether the treatment standard level of less than 2 ppm can be
met using CSPB.

3.3.4.2        Physical/Chemical Treatment Process Options

The seven types of physical/chemical process options retained
after the initial screening include oxidation, reduction, solvent
extraction, soil washing, dechlorination, quicklime, and
solidification/ stabilization.  Oxidation, reduction, solvent
extraction, soil washing, dechlorination, and
solidification/stabilization process options are potentially
applicable for treating contaminated soil and rock, sediment, and
sludge.  The quicklime process option is not applicable but is
retained for analysis as required by IC 13-7-16.5-9.  The seven
physical/chemical treatment process options retained after
initial screening are discussed below.

3.3.4.2.1 Oxidation

Oxidation is a chemical process that can convert hazardous
contaminants to nonhazardous or less toxic compounds that are
more stable, less mobile, and/or inert.  Oxidation reactions
involve the transfer of electrons from one compound to another. 
The compound losing electrons is oxidized, and the compound
gaining electrons is reduced.  The oxidizing agents most commonly
used to treat hazardous contaminants are ozone, hydrogen
peroxide, hypochlorites, chlorine, and chlorine dioxide (USAEC
1994).  The immediate treatment products are phenols, but
complete oxidation to carbon dioxide can occur.  Chemical
oxidation can be accomplished using the G.E.M., Inc., technology
or super critical water oxidation (SCWO).  These processes are
described below.

          G.E.M., Inc., technology - The G.E.M., Inc., chemical
          treatment technology is a closed system process in
          which hydrocarbons undergo chemical oxidation.  The
          operating principle is based on the reaction of either
          an acid or caustic with either the contaminant or a
          mixture of the contaminant and aluminum oxide.  The
          reaction chemically converts the hydrocarbons to carbon
          and nonhazardous aluminum compounds.  Treatment occurs
          in a heated pressure chamber.  Steam and other gases
          are vented to a separate chamber for processing, if
          necessary.  Residual hazardous materials can be
          adsorbed by rehydratable alumina and retreated.

          SCWO - The SCWO technology's effectiveness is
          attributed to the enhanced solvent properties of super
          critical water.  Because of its relatively low density
          and the temperature of the reactor, the hydrogen bonds
          of the water are disrupted so that the super critical
          water can readily absorb and react with the
          contaminants.  Only contaminated materials in an
          aqueous form or a slurry (20 percent solids) can be
          treated.  The influent material is heated and
          pressurized until its watery component enters the super
          critical state.  Gaseous oxygen is then added, which
          combines with the breaking organic molecules to form
          the following compounds: carbon dioxide, clean water
          with some dissolved alkali salts, trace amounts of
          oxygen and nitrogen, and a solid powder of oxides and
          insoluble metal salts.  

Effectiveness

Oxidation is effective for the treatment of PCB-contaminated
soil, sludge, and aqueous wastes types.  Oxidation is also
effective for treating materials contaminated with dioxins, and
VOCs, and is not applicable to materials contaminated with metals
or inorganic wastes.  The toxicity of PCBs, dioxins, and VOCs is
eliminated by a chemical conversion to less harmful compounds.  
Limited data are available to determine oxidation's applicability
to the six sites' contaminants.  Both of the representative
processes have been tested extensively at the bench scale, and
the SCWO process has undergone some testing at the pilot scale. 
In tests of the SCWO process, efficiencies have reached as high
as 99.999 percent PCB destruction for aqueous wastes (Glanz
1992).  Only three batches of soil and sludge waste types have
been treated at the bench scale for the G.E.M., Inc., technology. 
No performance data are available for these bench-scale tests
(EPA 1994a).  The SCWO residuals could require off-site disposal,
but the treated soil from the G.E.M., Inc., process could, in
most applications, be backfilled on site.

Implementability

The major drawback in implementing the SCWO process option is the
necessary conversion of contaminated materials to slurry form,
which presents materials handling and staging problems. 
Additionally, salts that precipitate out during the SCWO process
tend to clump together and adhere to the walls of the reactor,
resulting in increased corrosion and eventual clogging of the
unit (Glanz 1992).  For the G.E.M., Inc., process option, the
waste should not contain excess water, and the technology is not
applicable to metals and inorganics.  The treatment materials for
the contaminated materials or slurry can be supplied by the
vendor, but no full-scale operating data are available.  The
space requirements for both oxidation process options cannot be
determined because of limited data.  Both oxidation technologies
can be mobilized to the CTF; however, once set up, the systems
cannot be easily mobilized.

The average treatment capacity of the SCWO process is about 30 to
50 gallons per hour (Glanz 1992).  G.E.M., Inc., has designed a
pilot-scale unit capable of treating 1 to 2 gallons per hour, and
a full-scale unit has been designed capable of treating 130 to
400 pounds per hour (EPA 1994a).  Larger scale testing of both
oxidation technologies needs to be conducted before any
conclusions about full-scale implementability can be made. 
Releases of contaminants to soil, groundwater, surface water, or
air associated with both representative processes are unlikely to
occur because treatment should be performed in an enclosed
building.

Cost

The relative capital and O&M costs for oxidation are high.  The
cost of oxidation depends on the quantity of waste and the amount
of preprocessing required to implement the process option.

3.3.4.2.2 Reduction

Reduction is a chemical process that can convert hazardous
contaminants to nonhazardous or less toxic compounds that are
more stable, less mobile, and/or inert.  Reduction involves the
transfer of electrons from one compound to another.  The chemical
that receives electrons is reduced, and the chemical losing
electrons is oxidized.  Reduction replaces the chlorine atoms
with hydrogen, forming biphenyl, cyclohexane, or smaller
molecules.  Chemical reduction can be accomplished using one of
the following representative processes: the Eli Eco Logic
International, Inc. (Eco Logic), process or ultraviolet (UV)
radiation.  These processes are described below.

          Eco Logic process - The Eco Logic process involves the
          gas-phase reduction of organic compounds by hydrogen at
          temperatures of 850 ¿C or higher.  Chlorinated
          hydrocarbons are chemically reduced to form methane,
          ethylene, and hydrogen chloride.  System product gas
          consists essentially of hydrogen, methane, ethylene,
          carbon monoxide, and carbon dioxide.  The hydrogen
          chloride produced is removed by the system in a caustic
          scrubber downstream of the process reactor.  The lack
          of oxygen and the use of a reducing hydrogen atmosphere
          ensures that no dioxins or furans are produced.  The
          process is ideally suited for primarily aqueous wastes
          or slurried soils and sediments.  Unlike oxidation
          reactions, the efficiency of chemical reduction
          reactions in this process is enhanced by the presence
          of water, which acts as a reducing agent and as a
          source of hydrogen.  A water shift reaction also occurs
          that produces carbon monoxide and hydrogen from methane
          and water.

          UV radiation - In this process, UV radiation light is
          used in a reducing environment to dehalogenate PCBs in
          slurried soils and sediments (20 percent solids).  Low-
          pressure mercury lamps that emit approximately 95
          percent of their energy at 2,537 angstroms provide
          adequate irradiation for PCBs.  The process was
          developed by Atlantic Research Corporation and is
          called "light activated reduction of chemicals" (LARC). 
          The contaminated materials are fed into a processing
          unit to which predetermined amounts of phosphate
          detergent and sodium hydroxide are added.  The mixture
          is held in suspension while exposed to UV radiation and
          ozone or hydrogen.  During treatment, microscopic
          turbulence is produced through ultrasonic vibration. 
          The treated slurry is fed into a cyclone where solids
          are removed, sampled, and discharged.  The separated
          water is neutralized and tested before discharge.

Effectiveness

Reduction is effective for the treatment of PCB-contaminated
soil, sludge, and sediment slurry wastes.  Reduction is also
effective for treating dioxins, furans, and other organics, and
is not applicable to metals or inorganic wastes.  Reduction is
chemically applicable to the organic contaminants at the six
sites.  Limited data are available to determine reduction's
applicability to the six sites' wastes.  The LARC reduction
process has been tested at the laboratory and bench scale, and
the Eco Logic technology has been tested at the full scale.  Test
efficiencies for the Eco Logic process have ranged from 90 to
99.999 percent PCB destruction in materials with a 500- to 1,000-ppm initial PCB concentration (EPA 1994a).  The LARC process has
demonstrated 90 to 99 percent efficiency at the laboratory scale
(Groundwater Technology 1991).

Implementability

The major drawback to implementing either of the reduction
process options is the necessary conversion of the contaminated
soils to slurry form, which presents materials handling and
staging problems.  The equipment needed to treat the contaminated
materials or slurry could be supplied by the vendor, and for the
Eco Logic process, the equipment can be mobilized to the area of
contamination.  Once the equipment is set up, it cannot be easily
mobilized.  The Eco Logic process will occupy 21,600 ft2 on site
(EPA 1994d).  Space requirements for the LARC process cannot be
assessed because no full-scale data are available.  The average
capacity of the Eco Logic process is about 200 tons per day in a
full-scale unit (EPA 1994a).  The LARC process can currently
handle 0.5 to 1.5 tons per day (Groundwater Technology 1991). 
Larger scale testing of the LARC process needs to be conducted
before any conclusions about its full-scale implementability can
be made.  Releases of contaminants to soil, groundwater, surface
water, or air associated with both representative processes are
unlikely to occur because treatment should be performed in an
enclosed building.

Cost

The relative capital and O&M costs for reduction are high.  The
cost of reduction depends on the waste characteristics and the
amount of preprocessing required to implement the process option.

3.3.4.2.3 Solvent Extraction

Extraction describes the process of separating organic
contaminants from a solid matrix using organic solvents.  Solvent
extraction is a volume reduction process.  Once PCBs have been
extracted with a suitable solvent, the solvent can be recovered
for further use.  The concentrated PCB residuals are ultimately
disposed of either by incineration or another suitable method. 
The most common solvents used for PCB extraction are kerosene,
propane, methanol, ethanol, formamiisopropanol,
dimethylformamide, ethylenediamine, triethylamine, and freon
mixtures (Groundwater Technology 1991).  Solvent extraction can
be accomplished by various process options.  The Resource
Conservation Company's (RCC) Basic Extractive Sludge Treatment
(B.E.S.T. ) process, CF Systems Corporation's Liquified Gas
Solvent Extraction (LG-SX) process, and the Terra-Kleen Response
Group, Inc., Solvent Extraction Treatment System were selected as
solvent extraction representative processes because performance
data are available for these systems and because full-scale
systems of these options have been designed or constructed. 
These processes are described below.

          B.E.S.T.  process - For the B.E.S.T.  process,
          contaminated material is screened to less than 1.0 inch
          in diameter and added to a refrigerated premix tank
          with sodium hydroxide.  The tank is then sealed and
          purged with nitrogen.  Cold triethylamine (TEA) solvent
          is then added to the tank.  The mixture is agitated and
          allowed to settle.  The resulting solution of solvated
          oil, water, and solvent is decanted from the solids and
          centrifuged.  The solvent and water are removed by
          evaporation and condensation of the mixture.  The
          remaining solids are transferred to a steam jacketed
          extractor/dryer.  Warm TEA is then added, and the
          mixture is heated, agitated, and allowed to settle,
          thereby extracting the remaining organics.  The
          remaining solids contain TEA, which is volatilized by
          heating the solids in the steam jacket.  Steam is
          injected near the end of the process to remove any
          remaining solvent and to remoisturize the soil.  The
          recovered oil fraction can then be dechlorinated or
          incinerated to destroy the organics.  The TEA is
          recovered and can be used for further extractions.

          CF Systems LG-SX process - In the CF Systems process,
          contaminated materials are screened for oversized
          particles of greater than 0.1875-inch diameter.  The
          liquid, slurried, or solid material is then fed into
          the top of an extractor.  Liquified propane solvent
          condensed by compression at 70 ¿F flows upward through
          the extractor and makes nonreactive contact with the
          waste.  The organics in the waste dissolve into the
          solvent.  The solvent/organic waste mixture then leaves
          the extractor and proceeds to the separator.  The
          treated material is discharged.  In the separator, the
          solvent/organic waste mixture is vaporized and recycled
          as fresh solvent to the extractor.  The extracted
          organics are sent off site for disposal.

          Terra-Kleen process - In Terra-Kleen's process, the
          solvent extraction occurs in tanks that may have a
          variety of capacities.  After the material is loaded
          into the solvent extraction tanks, a proprietary
          solvent is pumped into the tanks and mixed with the
          soil.  Soil and solvent are held in the extraction tank
          long enough to allow organic contaminants to
          solubilize.  The contaminant/solvent mixture is then
          drained from the extraction tanks.  Contaminated
          solvent is transferred to a sedimentation tank. 
          Suspended solids are removed and tested for contaminant
          content.  Solvent washes of the solids continue until a
          site-specific soil cleanup level is attained.  After
          the solvent washes, any residual solvent in the soil is
          removed using vacuum extraction and biological
          treatment.  After biological treatment, treated soils
          are replaced on site.  The solvent regeneration process
          begins by pumping contaminant-laden solvent from the
          sedimentation tank through the microfiltration unit and
          the proprietary solvent purification station. 
          Regenerated solvent is then pumped into the clean
          solvent storage tank for reuse in subsequent wash
          cycles.

Effectiveness

Solvent extraction is effective for the treatment of PCB-contaminated soils, sludges, and sediments.  Solvent extraction
is also effective for treating of polynuclear aromatic
hydrocarbon (PAH), VOCs at low concentrations, and SVOCs.  This
treatment has limited effectiveness on dioxins and potential
effectiveness on furans, and is not applicable to metals and
inorganics.  Solvent extraction effectively concentrates PCBs,
PAHs, VOCs, SVOCs, and dioxins into an oily waste stream, which
requires secondary treatment.  The B.E.S.T.  system has proven
its full-scale effectiveness in treating PCBs in contaminated
sludge when PCBs were not the main constituent.  CF Systems has
planned a full-scale cleanup for its LG-SX process for
remediating PCBs in contaminated sediment at New Bedford Harbor
in New Bedford, Massachusetts, depending on the results of a
pilot-scale demonstration of the process.  Terra-Kleen has begun
a full-scale cleanup of contaminated soil at the Naval
Communication Station (NCS)-Stockton site in Stockton,
California, in July 1994, but no data are yet available.  Terra-Kleen also has planned a full-scale cleanup of 5,000 yd3 of soil
at the Naval Air Station North Island (NASNI), in San Diego,
California, scheduled to begin in 1995.  All of these processes
have demonstrated effectiveness at the pilot scale.  The CF
Systems pilot-scale demonstration achieved greater than 99.9
percent PCB removal efficiency in sediments contaminated with
initial PCB levels of 350 to 2,575 ppm (EPA 1990b).  The full-scale B.E.S.T.  system achieved greater than 99 percent PCB
reduction in contaminated oily sludge with initial PCB levels of
1 to 13 ppm (EPA 1993d).  The Terra-Kleen system was 98.9 percent
efficient in its pilot-scale demonstration and removed PCBs from
contaminated soil with an initial PCB level of 129 to 168 ppm
(PRC 1994a).

Implementability

Equipment and vendors are available for implementing solvent
extraction for full-scale remediation of PCB-contaminated
material.  All of the process options can be mobilized to the
CTF, but once set up, the equipment cannot be easily mobilized. 
The B.E.S.T.  process will require approximately 
10,000 ft2 of space (EPA 1993d) on site and the LG-SX and the
Terra-Kleen systems will require approximately 4,000 ft2 of space
(EPA 1990b and PRC 1994a).  The final disposal of different
phases of contaminated materials such as solids, solvent, and
water could present implementability and space problems in terms
of materials handling and temporary storage.  Flammable solvent
leaks could also present problems.  However, the systems used by
the processes discussed above are closed, and solvent is
recycled.  The concentrated organic residuals from the solvent
extraction process should be disposed of using incineration or
another suitable method.  The treated material can usually be
returned clean to the site, depending on administrative
requirements.  The capacity of the B.E.S.T.  and LG-SX processes
is 200 tons per day of soil wastes, and the Terra-Kleen system
can process 250 tons per day of soil wastes (EPA 1993d and 1990b
and PRC 1994a).  Releases of contaminants to soil, groundwater,
surface water, or air associated with solvent extraction are
unlikely to occur because treatment should be performed in an
enclosed building.

Cost

The relative capital and O&M costs for solvent extraction are
low.  The cost of solvent extraction depends on the quantity of
waste, the initial contaminant concentration, the characteristics
of the contaminated material, and the recovery percentage of the
solvent used.

3.3.4.2.4 Soil Washing

Soil washing is an innovative treatment technology for treating
contaminated material ex situ.  This process removes contaminants
by (1) concentrating contaminants into a smaller solids volume
through physical particle size separation and (2) dissolving or
suspending contaminants in the wash solution (typically water
modified by various surfactants and other chemicals), which is
then treated by conventional wastewater treatment methods.  Three
representative soil washing processes include the Bergmann USA
(Bergmann) process, the Biotrol  Soil Washing System (BSWS)
process, and the BioGenesis  PCB Sediment Washer (BPSW) process. 
These processes are described below.

          Bergmann process - The Bergmann process is a volume
          reduction technology that can use many physical
          separation techniques depending on the site
          characteristics.  These techniques include crushing,
          screening, hydraulic classification, attrition
          scrubbing, dense media separation, heavy media
          concentration, gravity concentration, froth flotation,
          dissolved air flotation, and mechanical dewatering.  In
          applications involving contaminated soil treatment, the
          Bergmann process uses one of the techniques discussed
          above to separate coarse materials from fine materials
          such as silt and clay because most organic and
          inorganic contaminants tend to bind, either chemically
          or physically, to clay, silt, and organic soil
          particles.  During physical separation, the
          contaminated fine particles are therefore separated
          from the cleaner, coarser sand particles.  The clean
          coarse fraction can then be redeposited on site or used
          as backfill or industrial sand.  Chemicals used to aid
          this process can include surfactants, chelating agents,
          coagulants, flocculants, and pH modifiers.

          BSWS process - In the BSWS process, soil is screened to
          particles with a diameter of less than 2 inches and
          slurried with water in a mixing trommel or pug mill,
          depending on the nature of the soil and the amount of
          energy required to achieve dispersion of the soil in
          water.  Next, the slurried soil is wet screened to
          remove oversized materials such as small rocks and
          pebbles.  The fine product from wet screening is then
          fed to a froth flotation circuit where the hydrophobic
          contaminants (including PCBs) and/or contaminated fine
          soils are transferred to a froth phase and removed. 
          The coarser solids are removed from the product water. 
          Exiting soil is dewatered in a spiral classifier or
          vacuum belt filter and discharged.  The froth and fine
          soil particles undergo a thickening operation to aid
          the separation of the contaminated fine solids.  The
          clarified process water exiting the dewatering
          operation is treated, if required, and recirculated.

          BPSW process - During the BPSW treatment process,
          contaminated material and water are slurried in the
          BPSW mixing tank using high-pressure air.  A low
          impact/high shear pump transfers the slurry to the
          shaker/mixing equipment.  The slurry is then pumped
          onto a shaker screen and directed to a flow-through
          mixing cell with a capacity of approximately 300
          gallons.  From the cell, the slurry is fed into a
          collision chamber.  In the collision chamber, the
          slurried stream is directed at plates of water placed
          at various angles in the chamber to facilitate the
          "stripping" of contaminants from particle surfaces.  A
          surfactant material added to the water in the plates
          coats the particles and inhibits the contaminants from
          re-adhering to their surfaces.  The resultant stream is
          then directed to a wet screening device and a
          centrifuge to remove the cleaned particles from the
          water.  The resultant water and particle mixture is
          then handled using conventional treatment technologies.

Effectiveness

Soil washing is effective for some soils and sediments and has
limited effectiveness in treating soils with large fractions of
fine-grained particles such as clay and silt.  Soil washing also
has limited effectiveness in treating materials contaminated with
heavy metals, PCBs, PAHs, pentachlorophenols (PCP), and other
organic and inorganic contaminants.  Soil washing effectively
concentrates heavy metals, PCBs, PAHs, PCPs, and other organic
and inorganic contaminants into a fine particle fraction for
secondary treatment.  Available data indicate that soil washing
will have limited effectiveness on the wastes from the six sites. 
Both the Bergmann and BSWS processes have proven effective in
bench- and pilot-scale PCB removal studies.  In addition, the
Bergmann process has treated PCB-contaminated wastes at full-scale levels.  A demonstration of the BPSW process is scheduled
to be conducted under the Superfund Innovative Technology
Evaluation (SITE) program in June 1995 (PRC 1994b).  At the bench
scale, the BSWS process treated PCBs from a level of 290 ppm down
to less than 0.1 ppm (EPA 1994a).  A pilot-scale study of the
Bergmann process demonstrated a 91 percent PCB reduction in 500
tons of PCB-contaminated sediment.  PCB levels were reduced from
initial levels of 1.6 and 5.0 ppm (EPA 1994a).  No PCB
performance data are available for the BPSW system.

Implementability

Soil washing equipment is available from various vendors. 
Residuals from the soil washing process need additional treatment
before disposal, but coarse-grained materials can usually be
returned clean to the site.  The BSWS treatment unit is a closed
system that can be mobilized to the areas of contamination.  The
BSWS pilot-scale unit is capable of treating 480 tons per day and
requires 13,000 to 21,800 ft2 for on-site setup (EPA 1992b).  The
treatment rate for the Bergmann process is 120 to 8,400 tons per
day (EPA 1994a).  No data are available for the space
requirements of the Bergmann process.  Neither the capacity nor
the space requirement for the BPSW system can be assessed because
of the lack of full-scale data.  More PCB-specific treatability
testing needs to be conducted before any conclusions concerning
the full-scale implementability of soil washing can be made
because demonstrations to date have treated materials containing
only limited amounts of PCBs.  Releases of contaminants to soil,
groundwater, surface water, or air associated with this
technology are unlikely to occur because treatment should be
performed in an enclosed building.

Cost

The relative capital and O&M costs for soil washing are low.  The
cost of soil washing depends on the contaminant concentrations
and the quantity of waste.

3.3.4.2.5 Dechlorination

Dechlorination is a chemical process that treats contaminated
materials through the addition of various reactants. 
Dechlorination is a variation of reduction, which is discussed in
Section 3.3.4.2.2, using different reagents.  When the
contaminants combine with the reactants, one or more of the
halogens present are removed through base catalyzed decomposition
(BCD) or glycolate dehalogenation.  These processes are described
below.

          BCD process - In the BCD process, contaminated material
          of greater than 2-inches in diameter is screened out. 
          The remaining materials are slurried and mixed with
          sodium bicarbonate.  The mixture is heated to above 330
          ¿C (630 ¿F) in a rotary reactor to decompose and
          partially volatilize the contaminants.  When treating
          PCBs, this process produces primarily biphenyls, low-boiling point olefins, and sodium chloride.  The
          process was developed jointly by EPA's Risk Reduction
          Engineering Laboratory (RREL) and the National
          Facilities Engineering Services Center (NFESC) and is
          licensed to vendors.

          Glycolate dehalogenation process - In the glycolate
          dehalogenation process, contaminated materials and
          alkali polyethylene glycol (APEG) reagent are mixed and
          heated in a treatment vessel.  The treatment vessel may
          be a rotary reactor for contaminated solids or tank
          reactor for contaminated liquids.  The reaction causes
          polyethylene glycol to replace halogen molecules
          through nucleophilic substitution, rendering the
          contaminant less toxic.  One reagent commonly used in
          this process is potassium polyethylene glycol (KPEG)
          reagent.  This reagent contains polyglycols, potassium
          hydroxide, and dimethyl sulfoxide (DMSO).  DMSO is
          added to enhance reaction rate kinetics, presumably by
          improving rates of extraction of the haloaromatic
          contaminants.  KPEG dehalogenates contaminants to form
          a glycol ether and/or a hydroxylated compound and a
          potassium metal salt.  The formulation of the reagent
          can be adjusted according to the conditions of the
          contaminated material.

Effectiveness

Dechlorination is potentially an effective and permanent
technology for dechlorinating PCBs in soil, sludges, sediments,
and oily wastes.  Dechlorination is only effective for treating
material contaminated with halogenated organic compounds,
potentially effective for treating material contaminated with
dioxins, furans, and pesticides, and ineffective for treating
material contaminated with non-halogenated compounds.  Available
data indicate that dechlorination can be an effective treatment
for the waste types identified at the six sites.  The glycolate
dehalogenation process has been tested at both pilot- and full-scale levels for the treatment of PCB-contaminated materials. 
PCB-contaminated soil was treated by glycolate dehalogenation
from initial PCB levels of 100 ppm to levels of below 1 ppm at
the Wide Beach Development site in Brant, New York (USAEC 1994).  
The BCD process has undergone treatability studies and pilot-scale testing on PCB-contaminated materials.  The BCD process has
been proven effective at treating PCB-contaminated sediments,
soils, oils, and sludges.  PCBs in contaminated liquids have been
reduced by the BCD process to less than 1 ppm from initial levels
as high as 300,000 ppm (EPA 1994a).

Implementability

After completion of appropriate treatability studies, this
technology could be implemented.  Dechlorination is typically
used in combination with thermal desorption.  Dechlorination
reagents can either be sprayed on contaminated material before it
enters a rotary-type thermal desorption unit to allow for
dechlorination in the desorber, or the condensed liquids can be
dechlorinated in a separate reactor.  Equipment could be built to
meet space requirements at the CTF.  Both of the process options
can be mobilized to the CTF, but once set up, the equipment
cannot be easily mobilized.  Particles of soil measuring more
than 2 inches in diameter must be screened out before the
material enters the reactor.   High concentrations of metals will
interfere with the BCD process unless additional sodium
bicarbonate is added.  Treated soil can be disposed of on site in
most applications.  Materials and equipment can all be supplied
by the vendor.  The average processing capacity of the
dechlorination option varies based on waste type, but is
generally 100 to 150 tons per day (EPA 1994a).  Releases of
contaminants to soil, groundwater, surface water, or air
associated with this technology are unlikely to occur because
treatment should be performed in an enclosed building.

Cost

The relative capital and O&M costs for dechlorination are medium. 
The cost of dechlorination depends on the recycle rates of the
reagent used, the moisture content of the contaminated material,
and the types of material treated.

3.3.4.2.6 Quicklime

The quicklime treatment involves mixing one part contaminated
soil or sludge with two or more parts of quicklime (anhydrous
calcium oxide).  Water is added to the mixture and stirred to
hydrate the lime to form calcium hydroxide (known as "slaking")
and convert the mixture to a thick slurry.  The heat and very
high pH of the slaked lime result in significant decreases in the
PCB concentrations in the waste.  This effect was initially
observed while stabilizing soil with quicklime and was proposed
as a remediation technique.

Effectiveness

The quicklime treatment destroys PCBs by dechlorination,
hydroxylation, and formation of polychlorinated dibenzo-p-furan
(PCDF).  Therefore, quicklime treatment is not effective in
treating PCB-contaminated material because the total PCB
destruction is only a small fraction (no more than 5 percent) of
the PCBs in the materials treated, because none of the PCBs are
totally destroyed (mineralized), and because some treatment by-products such as PCDF are more toxic than PCBs.  Unless the
process is carried out in a totally enclosed structure, it could
cause the release of about 80 percent of the original PCBs and
PCB decomposition products into the atmosphere as vapor and
particulates.

Available research on the quicklime treatment is summarized in
one publication (Einhaus and others 1991) that includes the
original research report and the subsequent, detailed evaluation
of the process conducted by RREL and the Environmental Monitoring
Systems Laboratory (EMSL) of EPA's Office of Research and
Development (ORD).  This process has not been used in practice;
therefore, only pilot plant data are available.

Implementability

The quicklime treatment is easy to implement because equipment
and materials are readily available through numerous vendors. 
Implementation of the quicklime process would require heavy
equipment at appropriate scale, but excavation, solids mixing,
and water addition are standard processes for which many sizes of
equipment are readily available.  However, the quicklime process
results in an increase of about three times the original volume
of materials.

The primary administrative barrier to this process is the
requirement of 40 CFR, 761.60(e), stating that any "alternative
method of destroying PCBs" such as this process must demonstrate
a level of performance equivalent to incinerators or high-efficiency boilers.  These requirements include numerous process
controls and emissions of no more than 1 milligram per kilogram
(mg/kg) of PCB in treated material.   Also, as stated above,
about 80 percent of the original PCBs and its decomposition
products are emitted to the atmosphere in the quicklime process. 
However, releases of contaminants to air, soil, groundwater, or
surface water associated with this technology are unlikely to
occur because treatment should be performed in an enclosed
building.

In addition, the more quicklime used, the higher the pH of the
treated waste.  The treated waste is an aqueous liquid (slurry)
that may therefore exhibit the characteristic of corrosivity
(40 CFR 261.22).  During the quicklime process study, pH of the
treated material was not measured because the researchers stopped
the chemical reactions by acidifying the slurry so that it could
be analyzed (Einhaus and others 1991).

Cost

The relative capital and O&M costs for quicklime are medium. 
However, larger scale implementation and control of air emissions
would result in a considerably higher cost.

3.3.4.2.7 Solidification/Stabilization

The solidification and stabilization technology applies binders
to soils, sludge, and liquid wastes contaminated with organic and
inorganic compounds.  Waste solidification involves the addition
of a binding agent to the waste to form a solid material. 
Solidifying wastes improves its material handling characteristics
and reduces permeability by reducing waste porosity and exposed
surface area.  Waste stabilization involves the addition of a
binder to a waste to immobilize waste contaminants effectively.

Binding agents are selected based on the characteristics of the
waste to be treated.  The most common binding agents for
solidification/stabilization are cement, lime, natural pozzolans,
fly ash, and a mixture of these additives.  Commercial vendors
have developed proprietary processes by adding special additives
to common binders to provide better control of the
solidification/stabilization product or to enhance specific
chemical/physical properties of the treated waste.  The mixing of
the waste and binding agents can occur outside of the ground (ex
situ) in continuous feed or batch operations.  In ex situ
applications, treatment usually begins with waste excavation. 
Waste containing large pieces of debris must be prescreened for
removal of the debris.  The waste is then placed into a high-shear mixer along with binding agents and water.  The binding
agents, soil, and water are mixed until all ingredients are
blended into a pasty mixture.  The resultant mixture can be
poured into containers or molds for curing.  The ultimate
disposition of the treated soil can be either on or off site.

Over 12 vendors currently offer commercially available
solidification/stabilization technologies.  The three vendor
processes below are selected to illustrate the technology because
they are typical solidification/stabilization processes and have
been evaluated at Superfund sites as part of EPA's SITE program.

          HAZCON process -- The HAZCON process is a cement-based
          process in which the contaminated material is mixed
          with Portland cement, a patented additive called
          "Chloranan," and water.  HAZCON offers several batch
          systems that can process 100 yd3 per hour.  The systems
          consist of a feed aggregate bin where the waste feed is
          weighed, a cement feed bin, and a rotary drum mix tank. 
          The feed and cement are combined and conveyed to a mix
          tank where water and additives are added.  Various
          types of mixers can be used to achieve a homogeneous
          blend, including a screw blender, a pug mill, or ribbon
          blender.  Typical ratios of waste to cement on a weight
          basis range from one to one to three to one.  Typical
          ratios of waste to Chloranan range from ten to one to
          soil by weight.  HAZCON also offers continuous mobile
          field blending units that can process up to 10 yd3 per
          hour of untreated soil. (EPA 1989)

          Soliditech process -- The Soliditech process
          incorporates a proprietary reagent, Urrichem, into a
          mixture of contaminated material and pozzolanic fly
          ash, kiln dust, or Portland cement.  Contaminated
          materials are placed in a 10-yd3 mixer.  Urrichem
          reagent is then added to the waste and thoroughly
          dispersed by blending.  Pozzolan and water are added
          and blended with the waste mixture.  The mix typically
          contains ratios by weight of two parts contaminated
          material, one part Portland cement, one-half part
          water, and one-fiftieth part Urrichem.  Finally, the
          mixture is removed from the mixer and pumped or
          transported to containers for curing (EPA 1990d).

          Silicate Technology Corporation (STC) process -- The
          STC process utilizes two groups of proprietary silicate
          reagents: SOILSORB HM for treating inorganic waste and
          SOILSORB HC for treating organic waste.  These two
          groups of reagents can be combined to treat waste
          containing both organic and inorganic contaminants. 
          Contaminated material is loaded into a batch plant
          where it is weighed and silicate reagents are added. 
          This mixture is conveyed to a pug mill mixer (or a
          ready-mix cement truck) where water is added and the
          moisture is thoroughly blended.  Sludges are placed
          directly into the pug mill for addition of reagents and
          mixing.  The treated material is then placed into molds
          for curing.  Hardware for the treatment process
          includes processing and material handling equipment. 
          With the exception of STC's liquid reagent metering
          equipment, conventional construction equipment can be
          used.  The equipment typically has the capacity to
          treat up to 1,000 yd3 of contaminated material per day. 
          (EPA 1993a)

Effectiveness

The solidification/stabilization technology has been demonstrated
to be effective for immobilizing contaminants in soils and
sludges containing heavy metals such as lead, nickel, and
chromium.  However, the solidification/stabilization technology
is not an appropriate treatment alternative for VOCs.  The
solidification/stabilization technology tends to be effective in
treating PCBs because of strong adsorption characteristics of
PCBs to soil.  This technology would reduce the mobility of PCBs
but not its toxicity.  Some evidence indicates that the excess
hydroxides in pozzolanic materials are substituted on the
biphenyl ring of PCBs, resulting in a dechlorination reaction. 
The dechlorination product would probably be less toxic than the
parent biphenyl molecule.  However, little substantive data on
this topic are available.  In general,
solidification/stabilization is believed to be capable of
successfully treating soils and sludges contaminated with PCBs. 
The effectiveness of solidification/stabilization to treat
materials contaminated with PCBs should be measured by a suitable
extraction procedure such as relevant procedures in portions of
EPA Method 8270.  Other leachability tests such as the toxicity
characteristic leaching procedure (TCLP) may also be appropriate
in addition to Method 8270.

The selection of solidification/stabilization for treating wastes
that contain semivolatile and nonvolatile organics requires the
performance of a site- and waste-specific treatability study. 
The treatability studies must demonstrate a significant reduction
in the concentration of contaminants of concern as determined
through a total waste analysis (TWA) of the raw and treated
waste.  EPA considers a 90 to 99 percent reduction in contaminant
concentration as measured by a TWA as significant.  However, this
percentage may vary depending on the effectiveness of the
technology and the cleanup goals for the site.

The solidification/stabilization technology has been proven in
diverse situations.  Stabilized masses have shown excellent
strength and integrity in most situations; however, long-term
effectiveness of treated soil is uncertain.  Long-term management
control may therefore be required. 

The solidification/stabilization technology using Portland cement
has been used to treat PCB-contaminated soil at several sites,
including some Superfund sites (for example, the Pepper Steel
Alloy Superfund site in Florida and the Douglasville Superfund
site in Pennsylvania).  However, published performance data are
limited.  At the Pepper Steel Alloy Superfund site, approximately
48,000 yd3 of soil containing PCBs at concentrations ranging from
1.4 to 760 ppm were treated with cement and fly ash.  Analysis of
leachate from the solidified mass showed no PCBs at a detection
limit of 1 ppb.

Several waste characteristics could impact the effectiveness of
the curing process.  The expected high organic content of the
municipal solid waste at the six sites may interfere with the
bonding of the agents to the waste materials.  Certain inorganic
chemicals such as copper, lead, zinc, and sodium salts of
arsenate, borate, phosphate, iodate, and sulfide may interfere
with a cement-based solidification/stabilization process.  

Implementability

The solidification/stabilization technology is well documented
and has been accepted by regulatory agencies for use at Superfund
sites.  The solidification/stabilization technology is readily
available through numerous vendors.  Most binding agents and
additives are also widely available.  The equipment is fully
transportable and typically a self-contained unit mounted on a
flat-bed trailer; therefore, the equipment can be mobilized and
demobilized quickly.  The CTF contains sufficient space for the
solidification/stabilization technology, which would need about
20,000 ft2 for the mixing unit, reagent storage bins,
decontamination area, temporary product storage area, field
trailers, and vehicle parking.  Available equipment can typically
process about 400 yd3 per day; therefore, 177,000 yd3 of PCB-contaminated soil, sediment, and sludge from the six sites could
be processed within 2 years.  A treatability study is required
before full-scale remediation of the PCB-contaminated material at
the six sites.

The volume of treated material could increase by a large amount
depending on the moisture content of the contaminated materials
and the amount of pozzolanic materials used in the process. 
Typically, waste volume is increased by 10 to 30 percent.

Regulations promulgated pursuant to TSCA do not recognize
solidification/stabilization as an appropriate treatment for
waste containing PCBs at levels above 50 ppm because
solidification/ stabilization treatment does not meet the
incinerator equivalency level of less than 2 ppm.  To meet the
TSCA regulation, the treated material should be disposed of in a
chemical waste landfill.

Cost

The relative capital and O&M costs for
solidification/stabilization are low.  Costs vary greatly
depending on contaminant and physical characteristics that affect
the performance of the solidification/stabilization process.  

Summary of Physical/Chemical Treatment Process Options

The three physical/chemical process options below will be
retained for detailed analysis:
 
          Solvent extraction will be retained based on its
          widespread use and treatment effectiveness at Superfund
          sites and a variety of other sites.  Reliable vendors
          of this technology are available, and the technology
          has successfully treated materials containing PCBs at
          the full-scale level on a limited basis.

          Dechlorination will be retained because of its proven
          effectiveness at Superfund sites and a variety of other
          sites.  Dechlorination is an effective process option
          when combined with thermal desorption.  It is also
          required to be retained by 
          IC 13-7-16.5-9.

          Quicklime will also be retained for detailed analysis
          as required by IC 13-7-16.5-9, although its
          effectiveness has been disproved by studies subsequent
          to the enactment of IC 13-7-16.5-9.

Oxidation and reduction process options were not retained for
detailed analysis because the PCB-contaminated material needs to
be converted to a slurry form that presents materials handling
and staging problems.  Therefore, oxidation and reduction are not
easy to implement and the relative capital and O&M costs are
high.  Soil washing is potentially effective for the removal of
PCBs from contaminated soil and sediment; however, it is not
easily implementable because additional treatability studies are
required before full-scale remediation can be conducted at the
six sites.  Therefore, soil washing was not retained for a
detailed analysis.  The solidification/stabilization process
option was also not retained for a detailed analysis because its
long-term effectiveness for reducing PCB mobility is uncertain;
toxicity is not reduced; and the volume of waste is substantially
increased, resulting in a significant cost increase.

3.3.4.3        Thermal Destruction Treatment Process Option

One of three types of thermal destruction treatment process
options retained for effectiveness, implementability, and cost
screening is vitrification.  The representative process option
retained for evaluation is the plasma torch process, which is
specified in IC 13-7-16.5-9.

In the plasma torch process, PCB-contaminated material is
introduced into a high-temperature heating chamber where
contaminants are destroyed.  A plasma torch used as the heat
source creates intense heat that melts the waste, burns the PCBs,
and produces a nonleachable vitrified slag rather than an ash, as
in incineration.  Therefore, the plasma torch process reduces the
toxicity and mobility of the contaminants.  Plasma torch
processing encapsulates and binds inorganic compounds in the
vitrified slag as evidenced by TCLP results from tests performed
under EPA's SITE program.  Exhaust gases are treated before
venting to the atmosphere.  

The plasma torch derives its sustaining power from the
interaction of a high-frequency magnetic field and ionized gas. 
Fast-moving ions and electrons collide with other atoms to
produce ionization and intense thermal energy.  The spectroscopic
source, which is a long tail, emerges from the flame-shaped
plasma that forms near the top of the torch and above the
induction coils (Eschenbach 1993).  The plasma contacts the
contaminated material and produces extreme heat in the heating
chamber, thus melting the material.

Effectiveness

The plasma torch process is potentially effective for treating
PCB-contaminated soil, sludge, sediment, and solid waste. 
Temperatures in the plasma furnace of 1,400 to 1,700 ¿C ensure
the complete breakdown of chemical compounds and impede the
formation of other interfering compounds.  The process is
potentially capable of completely eliminating the toxicity of
PCB-contaminated materials.  Organic components are vaporized and
decomposed by the intense heat of the plasma and are oxidized by
the air used as the plasma gas before passing to the off-gas
treatment system.  Results from testing under EPA's SITE
demonstration program indicate that the plasma torch technology
can achieve a destruction and removal efficiency (DRE) of 99.9968
to 99.999 percent of chemicals similar to PCBs.  Typically, the
products of plasma torch are exhaust gases and a vitrified slag. 
Proper design of a gas or vapor recovery treatment system must be
implemented to effectively destroy harmful vapors (EPA 1992a). 
Treatability studies are recommended to evaluate the
effectiveness of the plasma torch process.

Implementability

With proper process and equipment design, the plasma torch
process is technically feasible for treating PCB-contaminated
soil, sludge, sediment, and solid waste.  The plasma torch
treatment facility can be designed and constructed to handle a
capacity necessary for the treatment of the PCB-contaminated
material.  Mobile units are available for the plasma torch
technology.  However, the amount of PCB-contaminated material
from the six sites requires a full-scale unit to treat the PCB-contaminated material.  The CTF contains sufficient space for the
plasma torch technology.  Air quality requirements must be
addressed for the stack emissions.  The processed soil could be
disposed of at a local solid waste disposal facility after
detailed analysis to ensure acceptably low levels of PCBs and
other potentially hazardous constituents.  Because the solid
treatment product is a vitrified slag, leaching is not
anticipated.

It should be noted, however, that the plasma torch process is not
easy to implement because limited vendors with full-scale
equipment and plasma torch experience are available.  In
addition, the plasma torch process has limited application to
PCB-contaminated material.  Retech, Inc., and Kennedy VanSaun are
vendors that have developed and demonstrated the plasma torch
process for treatment of contaminated soils (EPA 1992c).  The
plasma torch process methods must also be approved by local,
state, and federal agencies.  The plasma torch process is subject
to similar permit requirements as incineration.

Cost

The relative capital and O&M costs for the plasma torch process
are high.  The capital cost consists basically of the cost of
purchased equipment and installation.  O&M costs consist of the
costs of labor; materials, including fuel oil and chemicals;
electrical and utility requirements; residual solid and waste
disposal; taxes; insurance; and overhead.  The operating cost
depends in part on the nature of the feed and heat input.

Summary of Thermal Destruction Process Option

The plasma torch technology will be retained for further
evaluation in this study as mandated by 
IC 13-7-16.5-9.

3.3.4.4        Thermal Desorption Treatment Process Option

Only one of the thermal desorption treatment process options
found to be potentially applicable to the six sites is high-temperature thermal desorption (HTTD).  IC-13-7-16.5-9 requires
that both the general HTTD process option and a specific HTTD
process, the Desorption and Vaporization Extraction System
(DAVES) process, be retained for detailed analysis.  These
processes are discussed below.

HTTD processes use heat to physically separate (vaporize)
contaminants from soils, sediments, sludges, and other media. 
The separated contaminants, water vapor, and particulates are
collected and treated using conventional methods such as
condensation, adsorption, or incineration.  Condensed
contaminants and other treatment residues are typically shipped
off site for treatment and final disposal.

High-temperature thermal desorbers can be divided into the
classifications below (AAEE 1993):

          Direct-fired rotary desorbers - Waste material is
          passed through a rotating cylinder and heated by direct
          exchange with a support flame and/or combustion
          products.  Typically, lifters are attached to the
          inside surface of the cylinder to enhance gas/solid
          contact.

          Indirect-fired rotary desorbers - The metal rotary
          shell is heated on the outside by the combustion of
          natural gas or propane.  The hot shell indirectly heats
          the solids tumbling on the inside through conduction
          through the metal shell.  A sweep gas is used to
          transfer the volatilized organics and water to the off-gas treatment system.  Typically, lifters are attached
          to the inside surface of the cylinder to enhance
          gas/solid contact.

          Direct- or indirect-heated conveyor systems - Direct or
          indirect heat is applied to contaminated media
          transported through the system by screw, paddle, or
          mixing conveyors.  Sources of direct heat include
          electric resistance heaters or radiant heaters above or
          imbedded in the conveyors.  Indirect sources of heat
          typically include steam or heat transfer fluids
          recirculated in the hollow stems of screw conveyors.

          SoilTech ATP Systems, Inc. (SoilTech), Anaerobic
          Thermal Processor (ATP) system - The ATP is a specially
          designed rotary kiln containing four separate internal
          sections.  The first three sections, the preheat,
          retort, and combustion zones, progressively raise the
          temperature of the waste to vaporize the contaminants. 
          The treated solids are cooled in the fourth internal
          section, the cooling zone.  Vaporized contaminants are
          removed from the system under vacuum.

Another type of HTTD that does not fall into the general thermal
desorption classification is the DAVES process developed by
Recycling Sciences International, Inc. (RSI).  The DAVES system
directly heats wastes to separate both VOCs and SVOCs and
volatile inorganic contaminants from soil, sludge, and sediment. 
Waste materials are fed into a fluidized bed reactor (vapor
extractor) where the contaminants are volatilized at a relatively
low fluidized bed temperature of about 320 ¿F.  Hot turbulent air
at about 1,000 to 1,400 ¿F containing 1 to 2 percent oxygen from
a fuel-fired furnace directly contacts the waste material to
vaporize the contaminants.  The vaporized contaminants exit the
reactor with the hot gas and are removed in gas and water
treatment systems. 

Effectiveness

Each type of thermal desorption configuration may potentially
treat PCB-contaminated materials if the necessary temperatures
are maintained; therefore, all types of HTTD systems will be
considered in this report.  Site specific treatability testing is
needed to ensure that HTTD is effective for treating the
contaminated materials at the six sites.

HTTD is an effective technology for treating PCB-contaminated
soil, sediment, and sludge such as those found at the six sites. 
HTTD has been used at full scale at several sites and has
achieved reductions in PCB concentrations from greater than
10,000 to less than 2 mg/kg (EPA 1992d).  HTTD can treat a wide
range of media and contaminants.  High moisture content wastes
should be dewatered or dried to reduce heat requirements. 
Contaminated materials with high concentrations of organics
should be blended before treatment.  HTTD will not remove or
treat wastes contaminated with metals.

Little performance data are available to evaluate the
effectiveness of the DAVES process for treating PCB-contaminated
materials.  Data available from limited treatability testing of
PCB-contaminated harbor sediment using the full-scale DAVES
process indicate that the system can potentially reduce PCB
concentrations in wastes from about 200 to less than 2 ppm.  High
moisture content wastes should be dewatered or dried to reduce
the heat requirements.

Implementability

HTTD is a readily implementable technology.  Many vendors provide
HTTD systems, and most of the systems are transportable.  HTTD
equipment typically can be shipped in over-the-road trailers and
set up on site.  The CTF contains sufficient space for the HTTD
system.  HTTD systems are available that can treat over 200 tons
of soil per day.  A number of Superfund sites, including the
Waukegan Harbor Superfund site in Waukegan, Illinois, and the Re-Solve Superfund Site in North Dartmouth, Massachusetts, have been
remediated using HTTD systems.  Currently, about 25 commercially
available vendors offer HTTD technologies.

A full-scale DAVES treatment system has been constructed and is
currently being stored in Arizona.  DAVES equipment can be
shipped in over-the-road trailers and set up on site.  The CTF
contains sufficient space for the DAVES process, which requires
about 5,500 ft2 for equipment layout.  Contaminated materials
must be screened to remove rocks and debris greater than 1 inch
in diameter.  The system is designed to nominally treat 8.5 tons
per hour; however, RSI reports that units can be designed and
constructed capable of treating 100 tons per hour.  The DAVES
process has never been used to remediate a Superfund site.

Releases of contaminants to soil, groundwater, or surface water
associated with these systems are unlikely to occur because
treatment should be performed in an enclosed building.  Adequate
controls for preventing air releases are determined from the HTTD
and DAVES systems during the design stage based on types of
wastes and contaminants treated.

Cost

The relative capital and O&M costs for HTTD and DAVES are medium. 
The O&M costs for HTTD and DAVES primarily depend on the moisture
content and waste type being treated.

Summary of Thermal Desorption Process Options

In accordance with IC 13-7-16.5-9, the HTTD and DAVES processes
have been retained for detailed analysis.

3.3.4.5        Off-Site Commercial Treatment Process Option

The only type of off-site commercial treatment process option
retained for effectiveness, implementability, and cost screening
is treatment in a commercial TSCA incinerator.  Under this
option, PCB-contaminated material is transported by rail and
truck to an off-site, commercial, TSCA-approved incineration
facility for treatment and disposal.  The off-site, commercial
TSCA incinerator is capable of destroying PCBs in the
contaminated material.

Currently, about five off-site commercial incineration facilities
are capable of receiving contaminated material from the six
sites.  The selection of the specific commercial incinerator used
to treat the contaminated material should be based primarily on
transportation and treatment cost considerations.

Effectiveness

The TSCA incinerator is effective for destroying PCB-contaminated
soil, sludge, sediment, solid waste, capacitors, lagoon water,
and pipes; therefore, the TSCA incinerator would be effective for
treating the PCB-contaminated materials at the six sites.  Long-term risks currently associated with the sites would be minimized
by removing all PCB-contaminated material from each contaminated
site.  The TSCA incinerator is effective for reducing mobility,
toxicity, and volume of PCBs in the contaminated material at the
six sites.  Additionally, all treatment residues could be
disposed of outside of the Bloomington area.  TSCA-approved
incinerators have a DRE of 99.9999 percent.  No performance data
are required for this process option because a commercial TSCA
incinerator would be used that is already permitted.

Implementability 

Five TSCA incinerators are currently capable of treating PCB-contaminated materials from the six sites.  The nearest TSCA-approved incinerator facility is about 620 miles from the sites. 
The time required for completion of this option depends on the
available capacity of the commercial incinerators.  Adequate
materials, equipment, and skilled workers are available to
implement the technology (PRC 1995a).

Four potential sites could be used as materials handling and
transfer station locations.  They include (1) the Asea Brown
Boveri, Inc. (ABB), site in Bloomington, Indiana; (2) the Lemon
Lane Landfill site; (3) the Neal's Landfill site; and (4) the
Fell Iron and Metal site.  Neal's Landfill is the only site not
accessible to rail service.  The ABB site has a railcar loading
ramp already in place.

The off-site PCB incineration facilities proposed under this
option are RCRA- and TSCA-permitted.  Regulatory permits may also
be required for air emissions, discharge to surface water, and
waste transportation. 

Cost

The relative capital costs for an off-site commercial TSCA
incinerator are high.  No O&M costs would be incurred after all
the PCB-contaminated material has been removed from the sites.

Summary of Off-Site Commercial Treatment Process Option

The off-site TSCA incinerator process option is retained for
detailed analysis.  This process option provides a high degree of
protectiveness and, because the incinerators are already
permitted, can be readily implemented.

3.3.4.6        In Situ Biological Treatment Process Option 

One of three types of the biological treatment process option
that is potentially applicable to the six sites is in situ
biological treatment.  IC-13-7-16.5-9 requires in situ biological
treatment be retained for detailed analysis.  This process is
discussed below.

During in situ biological treatment, the activity of
naturally-occurring microorganisms is stimulated in soils and
sludges to enhance biological degradation of organic
contaminants.  Microbial activity in the contaminated material is
stimulated by applying nutrients and other amendments and by
providing oxygen for aerobic treatment.  Biological treatment of
highly-chlorinated PCB congeners, such as those presen