Engineering
Evaluation and Cost Analysis
Soil Cleanup
Technologies Recommended
Fell Iron and Metal Inc.
Bloomington, Indiana
EPA Fact Sheet
September 1989
An
engineering evaluation and cost analysis (EE/C A) to investigate and evaluate
treatment technologies of soils contaminated with polychlorinated biphenyls
(PCBs) at Fell Iron and Metal Inc. (Fell) site in Bloomington, Indiana, was
recently completed. (Words appearing in bold are identified in the Glossary).
An EE/CA is performed under “non-time” critical conditions where contamination
at the site is serious, but not an emergency. The purpose of the investigation
was to identify, screen, evaluate, and recommend treatment technologies for the
PCB contaminated soils. The goals of the EE/CA are to: provide a framework for
evaluating and selecting clean-up remedies; closely document the selection
process of the remedy; ensure that the evaluation complies with environmental
regulations; and allow the public an opportunity to provide comments during the
selection process.
This
fact sheet will explain the selection process for the final treatment
technologies evaluated for soil at Fell.
Highlights on PCB levels
The
Fell site is an active salvage yard located at 503 North Rogers Street in
Bloomington, Indiana. Business and residential areas surround the site.
Fairview Elementary School is located one block south of the site. Downtown
Bloomington is one-quarter mile southeast of Fell.
PCB-contaminated
capacitors, produced by Westinghouse, were disposed of at Fell until 1968. The
capacitors were broken open and the copper inside was removed for salvage. Some
of the remaining capacitor shells containing PCB oil were buried or piled up
on-site. In September 1984, U.S. EPA investigated the Fell site for the first
time. Soil concentrations of PCBs ranging from 753 parts per million (ppm) to
71,700 ppm were discovered where the capacitors had been stored on-site.
Because of the high PCB levels found at Fell, the accessibility of the site to
the public, and the proximity of the site to Fairview Elementary School, U.S.
EPA ordered that capacitors be removed.
A
request by the Monroe County Board of Health and the Monroe County Board of
Commissioners led U.S. EPA to conduct an assessment of the Fell site in
November 1987. Samples were collected of soils, and storm sewer runoff. PCB
levels in soil ranged from non-detectable (ND) to 1,461 ppm. Storm sewer water
samples indicated PCB concentrations of 81 parts per billion (ppb). Because the
PCB levels in soil exceeded 50 ppm, which is the removal indicator level under
the Toxic Substances Control Act, U.S. EPA issued an Administrative Order to
Westinghouse to immediately address contamination at the Fell site. All on-site
soils with PCB concentrations of 25 ppm or greater were excavated and
stockpiled beginning in October 1988. The excavated areas were then backfilled
with clean material. The contaminated soil was stockpiled on-site and
encapsulated in a synthetic liner/cap system designed to withstand weather
conditions for an approximate life-time of 15 years. By March 1989,
approximately 15,000 cubic yards of contaminated soil had been excavated. The
remaining PCB levels for the site soils overall (not including the pile)
averaged 2.5 ppm. The stockpile will remain in place until U.S. EPA chooses a
removal alternative for the contaminated soil. Based on the findings of the
EE/CA and comments from the public, U.S. EPA will prepare and sign an Action
Memorandum which designates what the final remedy will be. A copy of the Action
Memorandum will be attached to the EE/CA report. This will be available to the
public at the information repositories and the public information center in
Bloomington.
Why was a removal at Fell necessary?
According to U.S. EPA, the Fell site posed a substantial and eminent threat to public health and the environment. The threat of PCB movement through storm water runoff into the sewer system, the possibility of direct contact with contaminated soil to individuals on and near the site, as well as the potential of inhaling contaminated dust, prompted the cleanup actions at Fell.
As
a temporary means of preventing further PCB migration, the soil at Fell was
excavated, stockpiled, and encapsulated until a final decision is made on
permanent disposal of the soil.
Health
Effects of PCBs
According
to U.S. EPA, PCBs are both toxic and long lasting in the environment. Prolonged
exposure can cause a skin condition called chloracne. Irritation of the eyes, nose and throat can occur from inhalation
of PCBs. Animal studies have shown that
PCBs may cause damage to the reproductive system and possible cause
cancer. Studies show that accidental
oral intake during pregnancy has resulted in reproductive failure in
humans. Exposure to high concentrations
of PCBs over a long period of time can cause liver damage.
PCBs
are extremely slow to break down in the environment, as well as in human and
animal tissue. They collect in the
fatty tissue and can cause severe long-term damage. PCBs can bioaccumulate in higher members of the food chain.
Time
line
1948 Fell begins operations
Prior
to 1965 Fell accepts capacitors
from Westinghouse
Sept
1984 US EPA investigates the
Fell site
Jan
1985 US EPA removes 346 PCB-contaminated capacitors and caps two
capacitor storage areas with clay
Mar
1986 US EPA conducts second investigation of Fell for possible
inclusion to the NPL. Fell does not
meet NPL criteria
Nov 1987 US
EPA conducts a third site investigation for possible removal of soil. US EPA issues an order to Westinghouse to
clean up PCB soil. Westinghouse complies with the order
Oct
1988 Soil excavation begins at Fell
Mar
1989 Approximately 15,000
cubic yards of soil are excavated, stockpiled and encapsulated on site.
Nine
technologies were initially examined to eliminate inappropriate alternatives
for treatment of the soil stockpiled at Fell. The original alternatives
considered were:
·
Incineration;
·
Landfilling;
·
Chemical Extraction;
·
Glycolate
Dechlorination;
·
Vitrification.
·
No
Action;
·
Biodegradation;
·
Capping; and
·
Soil
Washing.
These
nine technologies were compared against four general rules, or criteria. If a
particular alternative did not meet the criteria , it was eliminated from
further consideration. The criteria
were: general technological feasibility; time to implement; the degree of
public health and environmental protection provided by the technology; and
compliance of the technology with federal, state, and local regulations.
Five
of the nine original alternatives met the criteria and were further evaluated.
The five were: ncineration,
landfilling, chemical extraction, glycolate dechlorination, and vitrification.
The technologies are discussed in detail on pages 4, 5 and 6 of this fact
sheet. The five were further screened against the following four criteria:
·
technical feasibility for treating specific
wastes;
·
impacts
on the environment;
·
reasonable cost; and
again
·
adherence
to federal, state, and local regulations.
Summary
of Remedial Technologies
·
Rotary
Kiln
Rotary
kilns have tilted, rotating chambers. Wastes and fuel are inserted into the
upper end of the kiln and are burned as they move through the slowly rotating
chamber. Rotary kiln incinerators have been widely used on a variety of
hazardous wastes including PCBs. Regulations require the incinerator to destroy
99.9999% of the contamination.
There
are three operating incinerators of this type in the U.S.: the Chemical Waste
Management (CWM/SCA) incinerator in Chicago, Illinois, the ENSCO incinerator in
El Dorado, Arkansas, and the APTUS incinerator in Coffeyville, Kansas.
Estimates
of the cost and execution times for incineration were based on 15,000 cubic
yards of contaminated soil. Execution times were calculated assuming that each
incinerator would be available and operating at full capacity.
Total Cost: Execution time:
CWM/SCA $44,081,518 16 to 18 months
ENSCO $45,881,163 2 to 3 months
APTUS $29,134,583 5 months
Use
of the rotary kiln incinerator for Fell is still under consideration by U.S.
EPA
This method of incineration is similar to the rotary kiln, with infrared radiation used to destroy the waste instead of burning. Destruction of PCBs using this method is about 99.99% effective. Two companies currently have mobile infrared incinerators available. One of the companies cannot be used due to conflict of interest. The other company, O.H. Materials in Findlay, Ohio, has a national permit to operate a mobile infrared incinerator. Cost estimates include incineration of the soil, and the expense of landfilling the residue. The cost of landfilling is dependent upon the nature of the soil. If the soil is EP toxic, it must be disposed of at a RCRA-regulated landfill. The closest RCRA landfill is in Fort Wayne, Indiana. If the soil is not EP toxic, it still must be disposed of in a landfill.
Total Cost: Execution
Time:
EP
Toxic $10,064,389 3 months
Non-EP Toxic $6,867,377 3 months
Westinghouse
has proposed to build a rotary kiln incinerator to comply with a Consent Decree
lodged in the U.S. District Court for the Southern District of Indiana in
August 1985. The Consent Decree requires the incinerator for the cleanup of
several other PCB-contaminated sites in the Bloomington area. The Westinghouse rotary kiln design is slightly
different than any such incinerator now in use. This rotary kiln will have the
capacity to burn municipal solid waste along with the contaminated soil. Ash
from the incinerator will be disposed of at a RCRA/TSCA approved landfill to be
constructed nearby. Greater than 99.9999% of PCBs can be destroyed using this
type of incinerator.
Under
the Consent Decree, the proposed incinerator will burn approximately 650,000
cubic yards of PCB-contaminated soil from the other area sites before
incinerating the soil at Fell. This option proposes that the Pell stockpile
would be incinerated after the materials from the Consent Decree are burned.
With the proposed incinerator operating at capacity, incineration of the
Consent Decree wastes would take approximately 12 years. Because the Fell
stockpile may be in place close to the lifetime of the current liner/cap
system, this cost estimate includes the installation of a replacement
containment system.
Incineration
Time: 3 to 4 months
Total
Cost $2,880,105
Use
of the proposed Westinghouse incinerator for Fell is still under consideration
by U.S. EPA.
Fluidized Bed
Incineration
This
type of incineration consists of a bed of material, such as sand, within a
chamber. Waste can be injected directly into the bed, or onto its surface. Air
is then forced into the bed whichcauses
the wastes to move within the chamber. Fuel is fed into the chamber to burn and
destroy the PCB contaminated soil. Decontaminated soil and material that does
not burn is taken out from the bottom of the chamber. With proper temperature
and oxygen maintenance within the chamber. This incinerator can destroy up to
99.9999% of the PCBs.
This
option was not considered further because there are no mobile incinerators of
this type within a reasonable distance of Fell and wastes would have to be
transported at least 1,01)0 miles to such a facility.
Off Site RCRA/TSCA Landfill
This
technology has been widely used for disposal of hazardous wastes, including
PCBs. Only permitted facilities in compliance with RCRA/TSCA and all other
regulations were considered. Permitted hazardous waste landfills are equipped
with both a primary and secondary liner, a leachate collection system and
groundwater monitoring wells. However, after November 1990 contaminants with
PCB concentrations over 50 ppm cannot be acepted in RCRA/TSCA landfills. A
landfill that could accept PCB-contaminated soil is located in Model City, New
York. The cost of shipment and disposal of the 15,000 cubic yards of soil from
Fell is estimated to be:
Total
Cost: $17,969,57
Execution Time: 2 months
Use
of off-site landfills to dispose of the Fell soils is still under consideration
by U.S. EPA
Chemical
Extraction
B.E.S.T.
This
process separates contaminated soils into oil, water, and solids. Chemical
extraction is accomplished by mixing liquid into the waste to form a slurry.
Certain chemical solvents are added to the slurry to cause the solid particles
to separate from the mixture. Next, the mixture is heated to separate the water
from the oil and solvent. Distilling is the final step in order to remove the
PCB oil from the solvent. This process has been effective in removing over 99%
of PCBs from wastes. Assuming 15,000 cubic yards of soil are treated, 3,030
gallons of PCB waste oil, with an average PCB concentration of 1,000 ppm will
be produced. PCBs are not destroyed using this method, but converted to a
smaller more concentrated volume. This technology has been successful in
treating sludges, but has never been used on soil.
Cost
estimates include off-site incineration of the waste oil and disposal of the
treated soil by landfilling. Incineration of liquid PCB wastes of 50 ppm or
greater is required by U.S. EPA. The total cost for landfilling the treated
soil depends on its EP toxicity.
EP
Toxic Soil
Total
Cost: $7,395,373
Execution
Time: 1.4 years
Non
EP Toxic soil
Total
Cost: $4,291,511
Execution
Time 1.4 years
Use
of this method to treat soils at Fell is still under consideration by U.S. EPA.
Critical
Fluids Extraction (CFS)
The
critical fluids extraction process (CFS) uses liquefied gases to separate oils
from contaminated soils. The contaminated soil is processed in a separator
unit. Liquefied gases flow through the separator and remove PCBs from the
mixture. The clean soil is removed, and solvent and PCBs pass through another
separator. The solvent is vaporized and recycled for reuse, leaving only the
PCB-contaminated oil. This process has been effective in removing about 99% of
PCBs from waste. PCBs are not destroyed using this method, but converted to a
smaller, more concentrated volume. Assuming 15,000 cubic yards of soil are
treated, about 3,000 gallons of PCB waste oil, with an average PCB
concentration of 1,000 ppm, will be produced. These waste oils would be taken
off-site and incinerated according to federal regulations. The disposal
requirements of the waste materials are the same as stated above.
EP
Toxic Soil
Total
Cost: $6,859,900
Execution time: 2 years
Non-EP
Toxic Soil
Total
Cost: $3,662,888
Execution
time: 2 years
Use of this method to treat soils at Fell is still under consideration by U.S. EPA.
Glycolate Dechlorination (APEG)
Dechlorination
is a process which transforms PCBs into other nontoxic chemicals. It is
accomplished by mixing PCB-contaminated soil with certain chemicals, called
reagents, and applying heat. This results in chemicals that are less toxic than
PCB that can be further treated with water. The soil is washed several times
and the recovered reagent can be used again. This technology has been extremely
effective with transformer fluids such as PCBs, but has only been demonstrated
in small scale operations. Dechlorination does not destroy PCBs, but transforms
them into other chemicals. A RCRA/TSCA landfill would be required to dispose of
the soils that were EP Toxic. The nearest RCRA/TSCA landfill is in Ft. Wayne,
Indiana. Non-EP Toxic soil could also be disposed of in a landfill.
The
cost of shipment and disposal of the soil is estimated to be:
EP
Toxic Soil Total
Cost: $9,440,480 Execution
time: 6-12 months
Non-EP
Toxic Soil Total
Cost: $6,243,407 Execution
time: 6-12 months
Use
of this method to treat soils at Fell is still under consideration by U.S. EPA.
In-Situ
Vitrification (ISV}
This
process is used to treat wastes in place (in-situ). The method uses electricity
to melt soil into a glass-like mass that resists weathering. One thousand tons
of soil can be processed per treatment. In the process, 99.9999% of the PCBs
are destroyed, however the glass-like mass may be left on site. ISV has been
emonstrated to be effective, but is still in the developmental stage.
Total
Cost: $7,646,025 Execution Time: 6 months
Use of this method to treat soils at Fell is still under consideration by U.S. EPA.
Analysis of Alternatives
A
system to weigh the advantages and disadvantages of each technology was
developed. Each technology was compared against technical feasibility,
institutional considerations, environmental impacts, and reasonable cost. This
section discusses the advantages and disadvantages of four of the previously
discussed technologies (on-site and off-site incineration, in-situ vitrification,
and off-site landfill) and includes
with EPA’s preferred alternative of off-site landfilling.
On-Site Incineration
Incineration
is an available and proven technology that achieves nearly total (99.9999%
destruction efficiency) destruction of PCB contaminants. It reduces the
toxicity and mobility of the contaminants, can be completed within three
months, and is relatively inexpensive (cost range from 7 to 10 million
dollars). The incinerator would only be used to destroy the material in the
stockpile and would be removed when the project is finished. However, due to
the close proximity of businesses and residences, the noise and unsightly
appearance of a mobile incinerator in the –neighborhood is a drawback. In the
event of failure, here would be a great
deal of concern over emissions from the smoke stack and their subsequent health
effects. Finally, the incinerator would not effectively reduce the volume of
the soil and the resulting ash would need to be disposed of in an appropriate
manner on-site.
.Off-Site Incineration at Proposed Consent Decree
Incinerator
As
in the on-site incineration proposal, this option effectively reduces the
toxicity and mobility of the contamination. However, there are numerous
drawbacks to this treatment. Because there are no
firm
deadlines for the construction of the incinerator, and the subsequent
destruction of the 650,000 cubic yards of materials, it is difficult to
determine when the Fell stockpile would be incinerated. Additionally, burning
the Fell stockpile in the incinerator would require amending the existing
Consent Decree and that could be a lengthy process. Finally, the liner system
on the stockpile would have to be replaced which may require disruption of the
materials. This short-term disruption may expose nearby residents to PCB dusts
and vapors until the new liner system is in place.
In-Situ Vitrification (ISV)
This
is an available technology that destroys the toxicity and the mobility of the
PCBs in soil. It can be implemented over a relatively short period of time
(between six to twelve months), is less industrial in appearance, and costs
between 7 to 8 million dollars. However, this is an emerging technology and has
not yet been attempted on a project as large as Fell. The system includes a
“hood” to capture gasses produced in the ISV process; wind conditions may
affect the efficiency of the “hood” system. The system may also be noisy while
in operation. Finally, incomplete “burns” (possible during a brownout) could
produce unwanted by-products such as dioxins and furans.
RCRA/TSCA
Landfill
This
alternative is an acceptable means of permanent disposal (until the RCRA Land
Disposal Restrictions take place in November, 1990) that can be accomplished in
a short time frame (two months) and is cost-effective (approximately 8 million
dollars). Removing the pile reduces any environmental threats in the community.
Finally, landfill capacity exists now for the disposal of the pile. Landfilling
does not destroy the toxicity, mobility, or volume of the wastes but it does
enclose the soil in a monitored environment that’s much more secure than the
current encapsulation at Fell. However, since the removal of the pile requires
its transport through town (by rail or truck), there may be a short-term increase
in risks to exposure via spills or an accident.
RCRA/TSCA
LANDFILL IS EPA’S PREFERRED ALTERNATIVE FOR THE DISPOSAL OF THE STOCKPILE AT
THE FELL IRON AND METAL SITE
.GLOSSARY
ADMINISTRATIVE
ORDER
A
legal document signed by US EPA directing an individual or business to stop or
correct an activity. It describes the
violation and actions to be taken. An
administrative order can be enforced in court.
Chemicals
which increase in concentration in a living creature as it breathes
contaminated air, drinks contaminated water, or eats contaminated food
A
legal document, approved and issued by a judge, that formalizes an agreement
reached between US EPA and potentially responsible parties (PRPs) wherein PRPs
will perform all or part of a Superfund site cleanup. The consent decree describes actions that PRPs are required to
perform and is subject to a public comment period.
A
community of animals and plants and the environment in which they live.
ENGINEERING
EVALUATION/COST ANALYSIS
An
analysis of removal alternatives for a site, similar to the feasibility study
in a remedial program. An EE/CA
characterizes current conditions and contaminants present at a hazardous waste
site, and identifies and addresses alternative removal actions for the site.
EP(EXTRACTION
POTENTIAL) TOXICITY
An
analytical test that can determine if certain metals have the potential to
leach out of wastes.
In
everyday terms, one part per million would be equal to one second in 11
days. Numerically, one part per million
looks like 0.000001.
A
very small unit of measurement. One ppb
can be compared to one second in thirty-two years. Because some chemicals are very toxic even at low concentrations,
ppb has become a standard unit of measurement in the hazardous waste
field. Numerically, a part per billion
looks like 0.000000001.
A
mixture of liquids and solids
A
chemical that can dissolve other chemicals
TOXIC
SUBSTANCES CONTROL ACT (TSCA)
TSCA
is the federal law authorizing US EPA to gather information on the risks of
hazardous chemicals. The TSCA
regulations may be found in the Code of Federal Regulations 40, part 761.
RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) Regulates management and disposal
of hazardous materials and wastes currently being generated, treated, stored,
disposed of or distributed.