4.4.3.2   Compliance with ARARs -- Alternative 3

Alternative 3 relies on thermal desorption through the DAVES as
the primary treatment technology and waste excavation, sorting,
sizing, transportation, and storage as support technologies. 
Alternative 3 would meet all federal and state ARARs.  Appendix B
presents the ARARs and criteria TBC for Alternative 3.  The ARARs
and criteria TBC for Alternative 3 are briefly discussed below.

PCBs  DAVES effectively removes PCBs from soil, sediment, and
sludge to less than 2 ppm PCBs in the treatment residual;
however, DAVES creates a concentrated PCB waste stream that would
be transported to an off-site TSCA incinerator.   In combination
with high temperature incineration, DAVES 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, then the residuals can be used for clean backfill.

Air Pollution  The DAVES process has the potential to emit air
pollutants; however, DAVES is equipped with APC equipment.  This
equipment is essential to the safe operation of DAVES and to the
collection of volatilized contaminants.  When equipped with the
appropriate APC equipment, DAVES complies with the CAA and the
IAC.

Waste Treatment and Disposal  Materials not treatable by DAVES
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 in 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 3.  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 carbon adsorption.  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 3 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.