4.4.4.2   Compliance with ARARs -- Alternative 4

Alternative 4 relies on the quicklime treatment process as the
primary technology and on waste excavation, sorting, sizing,
transportation, and storage as support technologies.  The
quicklime treatment process would not comply with chemical- or
action-specific ARARs for the treatment and disposal of PCBs. 
Appendix B presents the ARARs and criteria TBC for Alternative 4. 
The ARARs and criteria TBC for Alternative 4 are discussed below.

PCBs  The destruction of PCBs of no more than 5 percent by the
quicklime treatment process is not equivalent to the performance
of high temperature incineration as required by 40 CFR 761.60(e). 
The quicklime treatment process would also not be considered an
acceptable alternative treatment technology under the TSCA
regulations.  In addition, the treatment product includes a
considerable amount of aqueous slaked lime with a very high pH
and may classify as corrosive waste.  

Waste Treatment and Disposal  Materials not treatable by the
quicklime treatment process 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 accordance with 40 CFR 761.65.

Waste Excavation and Handling  ARARs associated with waste
excavation and handling would be met by Alternative 4.  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 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 transferred to the CTF for treatment in the
solvent extraction 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 4 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.