4.4.7.2   Compliance with ARARs -- Alternative 7

Alternative 7 relies on solvent extraction as the primary
treatment technology and on waste excavation, sorting, sizing,
transportation, and storage as support technologies.  Alternative
7 would meet all federal and state ARARs.  Appendix B presents
the ARARs and criteria TBC for Alternative 7.  The ARARs and
criteria TBC for Alternative 7 are briefly discussed below.

PCBs  The solvent extraction process is capable of meeting
chemical- and action-specific ARARs for the treatment and
disposal of PCBs because treatment residuals contain less than 2
ppm PCBs.  Because it achieves this level of PCB removal,
Alternative 7 is considered an acceptable alternative treatment
technology to high temperature incineration.  Alternative 7 is
able to achieve required PCB removal levels through repetition of
the treatment process on batches of material that do not achieve
the required PCB removal level after the first round of
treatment.  The solvent extraction system collects and recycles
the solvent used, minimizing any releases to the air.  Monitoring
would be conducted during operation of the solvent extraction
system to ensure there are no significant air releases from the
process.  The concentrated waste stream created by the solvent
extraction system would be incinerated off site in a permitted
TSCA incinerator.  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 residuals contain 1 ppm or
less of PCBs, then the residuals would be suitable for use as
clean backfill.

Waste Treatment and Disposal  Materials not treatable by solvent
extraction such as capacitors, PCB-contaminated solid waste, and
uncontaminated solid waste would be sorted, sampled as specified
in an approved sampling plan, and packaged and shipped off site
for proper disposal in accordance with ARARs.  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 7.  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 with 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 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 7 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.