4.4.6.2   Compliance with ARARs -- Alternative 6

Alternative 6 relies on controlled solid-phase bioremediation as
the primary treatment technology on and waste excavation,
sorting, sizing, transportation, and storage as support
technologies.  Alternative 6 would meet all federal and state
ARARs.  Appendix B presents the ARARs and TBC criteria for
Alternative 6.    The ARARs and criteria TBC for Alternative 6
are briefly discussed below.

PCBs  Ex situ bioremediation will most likely not treat PCBs to
less than 2 ppm and therefore, it is not considered equivalent in
performance to incineration.  In order to comply with TSCA,
treatment residuals from bioremediation that do not meet the
cleanup standard would need to be disposed of in a TSCA-compliant
chemical waste landfill or incinerator.  The 30-acre disposal
site would be designed and operated as a TSCA-compliant chemical
waste landfill and would be closed in accordance with RCRA
landfill closure requirements.  If in situ bioremediation
achieves a PCB level of less than 10 ppm, the residuals may be
spread over the lagoon area and covered with clean soil,
containing not more than 1 ppm PCBs.  This approach complies with
the TSCA spill cleanup policy for cleanup in a residential area. 
If an industrial cleanup scenario is used, the residuals could
contain between 10 and 25 ppm 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.  

Waste Treatment and Disposal  Materials not treatable by
bioremediation, such as capacitors and some components of PCB-
contaminated 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
facility.  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 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 6.  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 6 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.