4.4.1.2   Compliance with ARARs -- Alternative 1

Alternative 1 relies on HTTD as the primary treatment technology
and on waste excavation, sorting, sizing, transporting, and
storing as support technologies.  Alternative 1 would meet all
federal and state ARARs.  Appendix B presents the ARARs and
criteria TBC for Alternative 1.  The ARARs and criteria TBC for
Alternative 1 are briefly discussed below.

PCBs  HTTD effectively removes PCBs from soil, sediment, and
sludge to less than 2 ppm in the treatment residual.  However,
HTTD creates a concentrated PCB waste stream that would require
off-site incineration in a TSCA incinerator.  In combination with
incineration, HTTD would meet chemical- and action-specific ARARs
for the treatment and disposal of PCBs.  Treatment residuals
containing less than 50 ppm of PCBs may be disposed of in a solid
waste landfill with written approval of the State.  If the
treatment residuals contain less than 1 ppm PCBs, the residual
could be used for clean backfill.

Air Pollution  HTTD units have the potential to emit air
pollutants but are equipped with air pollution control equipment. 
This equipment is essential for the safe operation of HTTD and
for collecting volatilized contaminants.  When equipped with the
appropriate air pollution control equipment, HTTD complies with
the CAA and the IAC.

Waste Treatment and Disposal  Materials not treatable by HTTD,
such as transformers, capacitors, PCB-contaminated solid waste,
and uncontaminated solid waste, would be sorted, sampled as
specified in an approved excavation plan, and packaged and
shipped off site for proper disposal in accordance with ARARs. 
If transformers are found, they should be drained and flushed. 
Dielectric fluid and liquids containing greater than 500 ppm PCBs
should undergo off-site incineration.  The drained and flushed
transformer carcasses may be disposed of as solid waste along
with uncontaminated solid waste from the six sites if they
contain less than 50 ppm PCBs.  Capacitors would be packaged and
transported off site for incineration at a TSCA-permitted
incinerator.  PCB-contaminated solid waste that cannot be treated
to levels equivalent to incineration would be disposed of at a
TSCA-compliant landfill or incinerator.  PCB-contaminated
material that can not be directly loaded for transportation to
the commercial facility could be stored at the CTF or ISF in
preparation for treatment and disposal in accordance with 40 CFR
761.65.

Waste Excavation and Handling  ARARs associated with waste
excavation and handling would be met by Alternative 1.  Fugitive
dust and particulates would be controlled using best management
practices such as wetting the waste material with water or foam. 
Surface water runon and runoff at the sites would 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 would be
treated using a carbon adsorption system.  As part of site
restoration activities, sediments collected by the silt fences or
the berms would be containerized and transported to the CTF for
treatment.  The excavation sites would 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  Alternative 1 would 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.