4.4.2.2   Compliance with ARARs -- Alternative 2

Alternative 2 relies on dechlorination and HTTD as the primary
treatment technology and waste excavation, sorting, sizing,
transporting, and storing as support technologies.  Alternative 2
would meet all federal and state ARARs.  Appendix B presents
ARARs and criteria TBC for Alternative 2.  The ARARs and criteria
TBC for Alternative 2 are briefly discussed below.

PCBs  Dechlorination effectively removes PCBs from soil,
sediment, and sludge and destroys the PCBs by a chemical reaction
that removes the chlorine from the PCB molecule.  Treatment
residuals from dechlorination contain less than 2 ppm PCBs,
making dechlorination equivalent in performance to high
temperature incineration.  Treatment residuals containing less
than 50 ppm of PCBs may be disposed of in a solid waste landfill
with written approval of the State.  Treatment residuals that
contain less than 1 ppm PCBs can be used as clean fill.

Air Pollution  Dechlorination uses thermal desorption and
therefore may emit air pollutants during operation. 
Dechlorination units are designed with APC devices that collect
potential pollutants for later treatment.  Of particular concern
with dechlorination is the potential for hydrochloric acid (HCl)
to be present in the stack gas.  APC equipment and careful
operation would mitigate this potential problem.  With the APC
devices and proper operation, dechlorination would meet the
requirements of the CAA and the IAC.

Waste Treatment and Disposal  Materials not treatable by
dechlorination and HTTD, such as 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 would 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 would be stored at the CTF or ISF in preparation for
treatment and disposal accordance with 40 CFR 761.65.

Waste Excavation and Handling  ARARs associated with waste
excavation and handling would be met by Alternative 2.  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 six CD 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 on site using activated carbon.  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 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 would 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 may be pumped through carbon
adsorption units and discharged to the Dillman Road POTW.

Other Requirements  Alternative 2 would also comply with other
non-ARARs, including OSHA regulations 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 CD sites handled off site must comply with the
CERCLA Off-Site Rule.