4.3       ANALYSIS OF SUPPORT TECHNOLOGIES

This section presents the detailed analysis of the support
technologies described in Section 3.3.2 against the  seven
evaluation criteria.  The support technologies include planning,
pretreatment site preparation, contaminated material removal and
excavation, secondary treatment, post-treatment, and site
restoration activities.

4.3.1          Overall Protection of Human Health and the
               Environment -- Support Technologies

Support technologies would protect human health and the
environment by eliminating the risks associated with exposure of
residents to PCB-contaminated soil and rock, sediment, sludge,
solid waste, and capacitors at the six CD sites because these
materials would be permanently removed from the sites to achieve
the cleanup levels presented in Section 3.1.1.  White goods,
scrap metal, clay material, building remnants, and other solid
waste that may also be contaminated with PCBs would be
permanently removed from the six sites, thus protecting human
health and the environment.  Excavation of PCB-contaminated
material should also eliminate the potential for future releases
of PCBs to groundwater, surface water, and air.  

Support technologies for secondary contaminants will protect
human health and the environment by reducing PCB levels in (1)
the lagoon water at the Winston-Thomas Sewage Treatment Plant
site, 
(2) the decontamination water from decontamination procedures,
and (3) the treatment process water from treatment technologies
because this water would be treated using a pump-and-filter
system to meet the City of Bloomington's water quality standards
before discharge to the storm or sanitary sewer system.  Support
technologies for secondary contaminants will also protect human
health and the environment by eliminating the risks associated
with exposure of residents to pipes contaminated with PCBs at the
Winston-Thomas Sewage Treatment Plant site because the
contaminated pipes would be permanently removed from the site.

4.3.1          Overall Protection of Human Health and the
               Environment -- Support Technologies

Support technologies would protect human health and the
environment by eliminating the risks associated with exposure of
residents to PCB-contaminated soil and rock, sediment, sludge,
solid waste, and capacitors at the six CD sites because these
materials would be permanently removed from the sites to achieve
the cleanup levels presented in Section 3.1.1.  White goods,
scrap metal, clay material, building remnants, and other solid
waste that may also be contaminated with PCBs would be
permanently removed from the six sites, thus protecting human
health and the environment.  Excavation of PCB-contaminated
material should also eliminate the potential for future releases
of PCBs to groundwater, surface water, and air.  

Support technologies for secondary contaminants will protect
human health and the environment by reducing PCB levels in (1)
the lagoon water at the Winston-Thomas Sewage Treatment Plant
site, 
(2) the decontamination water from decontamination procedures,
and (3) the treatment process water from treatment technologies
because this water would be treated using a pump-and-filter
system to meet the City of Bloomington's water quality standards
before discharge to the storm or sanitary sewer system.  Support
technologies for secondary contaminants will also protect human
health and the environment by eliminating the risks associated
with exposure of residents to pipes contaminated with PCBs at the
Winston-Thomas Sewage Treatment Plant site because the
contaminated pipes would be permanently removed from the site.

4.3.2          Compliance with ARARs -- Support Technologies

Support technologies would meet all federal and state ARARs. 
Appendix B presents the ARARs and criteria TBC for support
technologies.  ARARs and criteria TBC for support technologies
are briefly discussed below.

PCBs  Support technologies should comply with federal chemical-
and action-specific ARARs because PCB-contaminated materials
would be removed and treated to meet the cleanup levels discussed
in Section 3.1.1.  Treated wastewater from the lagoon and
decontamination and process treatment operations should comply
with action- and location-specific ARARs.  Capacitors and
treatment by-products and residuals  should be incinerated or
disposed of in a TSCA landfill or at the new disposal facility in
Bloomington to meet location- and action-specific ARARs.  Pipes,
white goods, scrap metal, and building remnants contaminated with
PCBs should be disposed of in a TSCA landfill to meet location-
and action-specific ARARs.  Uncontaminated solid waste, white
goods, and scrap metal should be disposed of in solid waste
landfill to meet location-specific ARARs.

Waste Excavation and Handling  ARARs associated with waste
excavation and handling would be met by support technologies. 
Fugitive dust and particulates should be controlled using best
management practices such as wetting the waste material with
water or foam.  Surface water runon and runoff at the sites could
be controlled during excavation using berms and silt fences and
by collecting surface water runon in the excavation area using
pumps, vacuum trucks, and storage tanks.  All collected surface
water could be treated using a carbon adsorption system.  As part
of site restoration activities, sediments collected by the silt
fences or the berms could be containerized and transported to the
CTF for treatment.  The excavation sites should also be monitored
to determine the effectiveness of dust and surface water control
systems.

Surface Water  Decontamination water and storm water runon from
the excavation sites should be collected, containerized, treated
using carbon adsorption, and discharged to a POTW or surface
water body in accordance with pretreatment standards or NPDES
limitations of the CWA.  Water from the lagoon at the Winston-
Thomas Sewage Treatment Plant site could be pumped through carbon
adsorption units and discharged to the Dillman Road POTW.

Other Requirements  Support technologies should also comply with
other non-ARARs, including OSHA rules governing worker health and
safety; INDOT regulations for the packaging, labeling, and
shipping of hazardous materials; and the CERCLA Off-Site Rule for
proper off-site disposal of CERCLA wastes.  All waste material
from the six sites handled off site must comply with the CERCLA
Off-Site Rule.

4.3.3          Long-Term Effectiveness and Permanence -- Support
               Technologies

Because PCB-contaminated material would be removed from the
sites, the support technologies would be effective in permanently
eliminating (1) the risks associated with the PCB-contaminated
material; (2) the potential for future releases of PCBs to
groundwater, surface water, and air; and (3) the migration of
PCB-contaminated particulates off site.  The support technologies
are reliable because PCB-contaminated materials would be
excavated and removed off site, and the lagoon water,
decontamination water, and process treatment water is treated
before discharge to the storm or sanitary sewer system.  No
significant residual risks are associated with support
technologies.  The long-term effectiveness of the support
technologies will depend on the effective treatment and disposal
of the excavated PCB-contaminated materials and the effective
treatment and discharge of the lagoon water, decontamination
water, and process treatment water.  Performance data, factors
that influence performance, and system limitations are not
applicable to support technology activities.

4.3.4          Reduction of Mobility, Toxicity, or Volume Through
               Treatment -- Support Technologies

The support technologies will not reduce the toxicity and volume
of PCB-contaminated soil and rock, sludge, sediment, solid waste,
and capacitors removed from the six sites.  The mobility of
contaminants in excavated contaminated material should be reduced
because the PCB-contaminated materials exceeding cleanup levels
could either be treated at the CTF using Alternative 1, 2, 3, 4,
5, 6, or 7; or incinerated and disposed of at a TSCA incinerator
or landfill using Alternative 8.  After treatment, PCB-
contaminated materials concentrated in filter media, residuals,
and sediments may be incinerated or disposed of in an appropriate
landfill.

For the treated lagoon water, decontamination water, and process
treatment water, the toxicity and mobility of the wastewater
should be reduced before discharge to the storm or sanitary sewer
system.  The toxicity and volume of pipes contaminated with PCBs
at the Winston-Thomas Sewage Treatment Plant site  would not be
reduced.  However, the mobility of pipe contaminants could be
reduced because the pipes  could be permanently removed from the
site and disposed of in an appropriate landfill.

4.3.5          Short-Term Effectiveness -- Support Technologies

The potential short-term effectiveness of support technologies
involves worker safety considerations and potential community
exposure.  The technologies impact on these areas is discussed
below.

Worker Safety

Worker safety considerations associated with application of
support technologies include general site hazards and potential
chemical hazards.  General site hazards include the following :

          Heavy equipment hazards

          Occupational noise exposure

          Potential slip, trip, or fall hazards

          Airborne dust hazards

          Heat and cold stress

Exposure to site hazards would be reduced by providing (1)
appropriate safety equipment for protection against noise, dust,
and liquid exposure; and (2) awareness training to orient
personnel with on-site physical hazards.

During excavation, handling, and transportation of PCB-
contaminated material, short-term potential chemical risks to the
remediation crew through direct contact, ingestion, and
inhalation of PCB-contaminated material may result.  However,
steps should be taken during excavating, staging, and loading
PCB-contaminated materials to reduce and control any risks.  For
example, material handling equipment  could diminish air
dispersal of particulates and possible volatilization of organics
during excavation.  Also, dust suppression techniques such as
lightly dampening material with a surfactant and water solution
as it is excavated and air monitoring should also be conducted
during excavation.  For further control, the excavated material
could be transported to the CTF where it could be sorted within
an enclosed building.  All trucks transporting excavated
materials to the CTF should be covered and wetted to limit
fugitive releases.  

On-site workers should be properly safety trained and experienced
in the safe operation of equipment and chemicals used for
excavation and secondary treatment.  On-site workers would wear
the appropriate level of protection during excavation of PCB-
contaminated material and treatment of lagoon water,
decontamination water, and process treatment water.  The specific
level of protection worn will be determined by the level of
dermal and inhalation protection necessary.  Air monitoring would
be conducted to assist in determining the required level of
protection.  The OSHA PCB exposure limit for an 8-hour time
weighted average is 1.0 mg/m3.  Care should be practiced by the
remediation crew to maintain the integrity of the six sites and
minimize any potential contaminant migration through the
fractured bedrock.

Potential Community Exposure

Excavation activities may result in potential impacts on the
community.  Adults and children near the six sites may be exposed
to fugitive dust resulting from the excavation of PCB-
contaminated material requiring treatment.  However, dust
suppression measures and engineering controls should minimize any
impacts.  Continuous air monitoring will assist in determining if
dust control measures are effective and also indicate when
additional health and safety or engineering measures are
necessary.  Engineering controls would be used to reduce the
contamination of surface water and sediment by fugitive dusts
from the excavated material.  Potential surface water releases
would also be minimized by incorporating a sequential approach to
the excavation activities.  This approach includes daily
backfilling and placement of erosion control material at
excavation swaths.  

Site access at the six sites and CTF would be controlled to
greatly reduce the potential for direct contact with contaminated
materials.  Before transporting excavated materials off site, all
trucks and equipment  should be decontaminated, and the
decontamination water should be collected for treatment to
minimize off-site migration.   

4.3.6          Implementability--Support Technologies

Implementation considerations for support technologies include
technical feasibility, administrative feasibility, and
availability of services and materials.  These considerations are
discussed below.

Technical Feasibility

The reliability of the support technologies is high.  Excavation
is common and should be fairly easy to implement.  The ability to
excavate materials in a manner that minimizes runoff and off-site
migration presents a challenge.  If excavation is implemented in
a sequential approach, the amount of material exposed at any one
time should be minimized.  Landfill reclamation projects have
found this approach effective in minimizing surface water
diversion and run off problems.  The sequential approach involves
bulldozing a strip at a time in a fishbone-type pattern, and
backfilling the strips daily to avoid creating on-site ponds and
to minimize site runoff.  This approach would require extra
measures to avoid contaminating clean areas and would require
foresight in planning excavation logistics, including the use of
haul roads and the selection of decontamination area locations. 
In addition, assessing and preventing potential groundwater
migration through fractured and porous subsurface materials may
complicate implementability. 

About 1 to 3 years are required to excavate the PCB-contaminated
materials at the six sites, transport this material to the CTF,
and backfill the six sites.  The length of time required to
excavate and remove contaminated material may be affected by the
time required to conduct verification sampling to determine the
extent of excavation and the daily amount of contaminated
material that can be stored and treated at the CTF.

Construction and operation of the on-site pump-and-filter system
for the lagoon water, decontamination water, and process
treatment water; decontamination areas; CTF building; materials
handling and sorting equipment; and secondary treatment systems
can be readily implemented.  These activities should involve
proven construction and mechanical technologies and readily
available equipment.  

Administrative Feasibility

The support activities would require coordination and approval
from local planning, zoning, and utilities agencies. 
Westinghouse will be required to submit plans to show how the
support activities will be conducted in a safe manner. 

Availability of Services and Materials

Services and materials for the construction and operation of the
various buildings and systems associated with the support
technologies are readily available.  The CTF building should have
adequate capacity for equipment storage and for additional
processing equipment that may be required by specific alternative
treatment technologies.  

4.3.7          Cost -- Support Technologies

The cost of the support technologies are included in the costs
for each of the eight alternatives discussed in Section 4.4.