232.192. EnvironmentalResourcesManagement

ERM

855 Springdale DriveExton, Pennsylvania 19341(610) 524-3500 *(610) 524-7335 (fax)

22 August 1997 http://www.crm.comReference: N2111.00.01

Steven DonohueWestern Pennsylvania SectionHazardous Waste Management DivisionU.S. Environmental Protection Agency841 Chestnut BuildingPhiladelphia, PA 19107

Dear Steve:

Environmental Resource Management (ERM) on behalf of LucentTechnologies Inc. (Lucent) herewith suBmits three copies of the FocusedFeasibility Study Work Plan for the Operable Unit 3. This FFS WorkPlan is being submitted in compliance with the Administrative Order onConsent (EPA Docket No. IH-97-89-DQ executed on 17 June 1997 and asscheduled with you in our phone conversation of 14 August 1997.

Please contact me or Val Jurka with any questions or comments.

Sincerely,

David P. SteeleProject Manager

DPSenclosures: Focused Feasibility Study Work Plancc: M. Mustard, PADEP

V. Jurka, LucentJ. Dixon-Williams, LucentW.Boyhan,WRBG. Emmanuel, ERM

AR30Q2H

WORK PLAN

Lucent Technologies

Operable Unit 3Focused Feasibility StudyWork PlanEastern Diversified Metals Site

22 August 1997

Environmental Resources Management855 Springdale Drive

Exton, Pennsylvania 19341

ERM. AR3002U5

WORK PLAN

Lucent Technologies

Operable Unit 3Focused Feasibility StudyWork PlanEastern Diversified Metals Site

22 August 1997 r, ,..

Environmental Resources Management855 Springdale Drive

Exton, Pennsylvania 19341

TABLE OF CONTENTS

1.0 INTRODUCTION 1

1.1 BACKGROUND 11.1.1 Site Description 12.1.2 OU3 Description 21.1.3 Site Operational History 2

12 REGULATORY BACKGROUND 31.2.1 First Record of Decision 31.2.2 Second Record of Decision 31.2.3 Third Record of Decision . 4

13 SUMMARY OF PREVIOUS INVESTIGATIONS/ STUDIES 41.3.1 Previous Site Investigations 41.3.2 Previous Studies on OU3 Materials 61.3.3 Summary of Existing Information on the OU3 Materials 9

1.4 IMPACT OF PREVIOUS INVESTIGATIONS/STUDIES ONRECYCLING REMEDY 10

USE OF EXISTING DATA FOR FFS 12

2.0. GENERAL FFS APPROACH AND BASIS 13

2.1 FFS OBJECTIVES 14

22 IDENTIFICATION OF POTENTIAL ARARS 15

23 SUMMARY OF FFS APPROACH 16

2.4 RECOMMENDED REMEDIAL ACTION 18

3.0 APPROACH TO FFS EVALUATION 19

3.1 APPROACH TO FILLING DATA GAPS 193.1.1 Separation and Washing Study 193.1.2 ' Meeting to Discuss Results of Separation and Washing Studies 213.1.3 Meeting with USEPA and TSCA 213.1.4 Additional Treatability Studies 21

flR3002i*7

EVALUATION TASKS FOR IDENTIFIED REMEDIALALTERNATIVES 223.2.1 Alternative 1 - ROD Recycling Remedy 233.2.2 Alternative 2 - On-Site Stabilization and Off-Site Disposal 233.2.3 Alternative 3 - On-Site Separation and Resource Recovery,

and Off-Site Disposal 233.2.4 Alternative 4 - Direct Current Graphite Arc Melter Technology 243.2.5 Alternative 5 - Landfill Daily Cover 24

33 SUMMARY OF EVALUATION/RANKING OF ALTERNATIVES 24

4.0 FFS PROJECT MANAGEMENT 25

4.1 FFSIEAAf 25

4.2 MEETINGS 25

43 SCHEDULE 25

4.4 REPORHNG/DELIVERABLES 26

APPENDIX A — WASHING STUDY WORK PLAN

a ftR3002l*8

LIST OF FIGURES

1-1 Site Location Map following page 14-1 Focused Feasibility Study Schedule following page 25

iu

LIST OF TABLES

1-1 Miscellaneous Debris 61-2 Fluff Quantities by Fraction following page 71-3 Leachable Lead Concentrations by Fraction following page 81-4 PCS Concentrations by Fraction following page 8

iv AR300250

1.0 INTRODUCTION

This work plan describes tasks to be performed in the completion of aFocused Feasibility Study (FFS) to evaluate a selected set of alternativesfor the remediation of a waste pile at the Eastern Diversified Metals Site(EDM). Section 1 of the work plan summarizes known Site conditions,including a synopsis of previous investigations performed, and adiscussion of regulatory requirements for work at the Site. Section 2presents the objectives of the FFS, the remedial alternatives to beevaluated, and identifies potentially applicable, relevant and appropriaterequirements for remedial action on the waste. Section 3 describes thework to be performed for the evaluation of the identified alternativesduring the FFS, including a treatability study already being conductedand provisions for additional studies as determined necessary. The finalsection presents project management for the FFS, including a schedule.

1.1 BACKGROUND

Lucent Technologies Inc. (Lucent) performed a remedial designinvestigation to determine the extent to which recycling could beperformed on a pile of waste residue from wire recycling (see Section1.1.2). The result of these investigations revealed that the plastic fractionsof the waste contain polychlorinated biphenyls (PCBs) at concentrationsthat would prohibit reuse without authorization from the U.S.Environmental Protection Agency (USEPA) under the Toxic SubstancesControl Act (TSCA). Lucent and USEPA met to review these results on 30October 1996, at which time it was agreed that a FFS is appropriate for theevaluation of alternatives to the recycling remedy selected in the 2 July1992 Record of Decision (ROD). Consequently, Lucent and USEPAarranged for the performance of the EFS by executing an AdministrativeOrder on Consent (AOC; Docket No. m 97-89-DQ.

1.1.1 Site Description

The Site is a former metals reclamation facility located in Rush Township,Schuylkill County, Pennsylvania (Figure 1-1). The Site is locatedapproximately one mile northwest of the intersection of Routes 54 and 309and 1,000 feet west of Lincoln Avenue on Liberty Street, in the village ofHometown.

The Site occupies approximately 25 acres of partially forested land and islocated in a deep east to west trending topographic valley. The Little

ERM ^ BOM-N2U1.0an-M/22/97

Site Location MapEastern Diversified Metals SiteSchuylklll County, Pennsylvania

Sourer USQS Topographic Quadrangles, ,Delano and Tamaqua, Pennsylvania, j

BRM.INC . . . . . . . • • . . . . . . 43010.(OJn EC/DS1-264C

, AR300252

Schuylkill River flows in a south-southeasterly direction approximately250 feet west of the property. A shallow stream flows westerly along thesouthern border of die Site in the valley bottom, discharging into theLittle Schuylkill River.

This remote Site is bordered by a residential property and privatelyowned forest land to the north. Adjacent to the eastern border of the Siteis a building, fronting on Lincoln Avenue, which formerly housed themetals reclamation process and is presently being used as a warehouse.Several other commercial operations are near the Site along Liberty Streetand Lincoln Avenue. State-owned game lands are located to thesouthwest and west, along the banks of the Little Schuylkill River.

1.1.2 OU3 Description

The Site's most distinctive feature is a pile of plastic wire and cableinsulation, called "fluff," which occupies a central location on theproperty. The pile covers approximately 7.5 acres of the Site withapproximate dimensions of 250 feet wide by 1,500 feet long by 5 to 60 feetdeep. This fluff represents residual material from the recycling of copperand aluminum contained in used communication and power wire and

• cable. The fluff material is composed of polyvinyl-chloride (PVQ andpolyethylene (PE) insulation chips, fiber insulation liner, and residualwire fragments. Approximately 40% to 50% of the material is PVC andPE, which is present as visible, medium to coarse sand-sized particles.The remainder of the material is a light-weight "dust"-sized fraction,which is dirt and fiber, with some fine metal and plastic fragments, andlarge sized debris, primarily consisting of stone, wood and metal cable.On the order of 235 to 350 million pounds of fluff are estimated to bepresent on the Site.

1.13 Site Operational History

Prior to EDM's use of the facility, the facility consisted of a single buildingwhich was used as a small manufacturing operation for extrudingaluminum for hospital furniture. EDM purchased the site in 1966 for thepurpose of recovering metal from used and discarded wire. Wire metalsalvage activities continued from 1966 until 1977. Plastic insulation andpaper fiber surrounding the metal cable and wire were mechanicallystripped and separated from the metal using gravitational separationtechniques. This process involved chopping the wire, stripping the plasticcoating from the wire with steel blades, and separating the wire from theplastic coverings through the use of an air clarifier and a water bath.

EBM • £ BDM.NmLM.M-M/22/97

AR300253

The fluff (paper, fiber and plastic) and debris (wooden cable spools,miscellaneous metal hardware, etc.) generated during the reclamationactivities were disposed on the ground in the topographic valley at theSite.

REGULATORY BACKGROUND

First Record of Decision

The USEPA issued a Record of Decision (ROD) on 29 March 1991 which,among other things, divided the Site into three Operable Units as follows:

Operable Unit 1 fOUll

• Hot-Spots Areas (dioxin and polychlorinated biphenyl (PCB) fluffand soil);

• Soils and Sediment contaminated with lead; and• Miscellaneous Debris.

Operable Unit 2 fOU2)• Ground Water

Operable Unit 3

• Remainder of the Site, and in particular, the remainder of the pile.

Remedial Actions have been undertaken at the Site in response toadministrative orders of 30 October 1991, 1 April 1994 and 4 August 1994.These orders have dealt principally with OU1 and OU2. The resultingremedial action activities have included miscellaneous debris removaland disposal; installation/upgrade of Site runoff control features toprevent off-site migration of fluff materials; improvements in thecollection and treatment of Site leachate and ground water upgrade of theSite treatment plant; and removal and disposal of dioxin-contaminatedfluff from the former burn area hot-spot.

1.2.2 Second Record of Decision

The USEPA issued a ROD for OU3 on 2 July 1992. OU3 consists of theremaining fluff and debris not associated with OU1 and OU2 hot-spotmaterials. The ROD requires that

. • All fluff and debris at the Site be recycled within 15 years of the dateof the ROD;

'

RR30025U IDM - NHH-00.01 - 08/22/97

• All residuals of the recycling process be tested and, if necessary,treated to eliminate hazardous characteristics;

• All hazardous and non-hazardous residuals be disposed of in an off*site landfill; W

• Soils underlying the waste materials be tested to determine thenature and extent of contamination; and

• Erosion and sedimentation controls be implemented to controldrainage and minimize erosion of exposed soils at the Site.

On 25 June 1993, USEPA issued an administrative order directing theRespondent to implement the OU3 ROD. Erosion and sedimentationcontrols have been implemented in concert with other remedial actions atthe Site.

1.23 Third Record of Decision

USEPA issued a ROD for the deep ground water portion of OU2 on 29September 1993. USEPA selected the No Action alternative for deepground water based on Lucenfs Supplemental HydrogeologicInvestigation, which demonstrated that the sources of the deep groundwater contamination were not related to the Site.

1 3 SUMMARY OF PREVIOUS INVESTIGATIONS/STUDIES

Numerous investigations have been conducted at the Site to characterizeSite conditions. A summary of the investigations that provides insightinto the characteristics of the OU3 materials is presented below.

13.1 Previous Site Investigations

1.3.1.1 ToddGiddings and Associates, Inc (1985)

The 1985 Todd Giddings and Associates, Inc. (TGAI) investigationincluded sampling and analysis of the fluff materials. Samples werecollected from a depth of approximately 3 feet at 31 locations, and fromtwo auger boreholes through the pile into the underlying soil interface.The investigation determined that the fluff contained PCBs anddemonstrated that the fluff was RCRA hazardous by characteristic forleachable lead based on Extraction Procedure (EP) Toxicity test results.

The PCB concentrations for 95% of the sampled material (hot spotsexcluded) were found to be 25 mg/kg or less with an average ,concentration of 15.7 mg/kg. One small area, later designated as the

EDM-NaUl.00.Ol-

"PCB Hotspot," was found to have concentrations of up to 5,560 mg/kg,although subsequent testing indicated that these elevated detections wereactually polychlorinated naphthalenes (PCNs). Total lead concentrations

. , were found to range from 1,490 mg/kg to over 40,000 mg/kg throughoutthe pile with an average range of 5,000 to 15,000 mg/kg. The EP Toxicityconcentrations ranged from 155 mg/L to 215 mg/L with an averageconcentration of 26 mg/L, in comparison to the RCRA hazardouscharacteristic level of 5.0 mg/L. It should be noted that the samples wereprimarily taken within the upper 3 feet of the pile surface.

1.3.1.2 Remedial Investigation (RI) Report (1990)

A Remedial Investigation Report (January, 1990), prepared byEnvironmental Resources Management (ERM), presented results of fluffsampling designed to characterize the geotechnical, hydrologic, andchemical properties of the fluff, and to determine the heterogeneity of thepile. This work was primarily intended to supplement the TGAIinformation on PCBs and metals contamination. Sampling consisted oftwo boreholes advanced through the pile to the soil interface, and fourtest pits excavated approximately 10 feet into the pile.

» '. ' ' -The results of the geotechnical study indicated an average moisturecontent of approximately 47% by weight. The natural (wet) weight of thepile materials ranged from 43 to 66 pounds per cubic foot (pcf). Thedistribution of particle sizes are similar to a well-graded sanddistribution. Approximately 90% of the material passed the ASTM 4-mesh screen and less than 8% passed the ASTM 200-mesh screen.

1.3.2.3 Analyses far Miscellaneous Debris Disposal

The 30 October 1991 administrative order required removal of the piles ofmiscellaneous debris identified on and around the Site. Most of thosepiles contained varying amounts of fluff, along with the wire, wood,metal hardware, etc., of which they were otherwise comprised. ToxicityCharacteristic Leaching Procedure (TCLP) testing performed on fourcomposite fluff samples recovered from the debris piles showed the fluffto be characteristically hazardous for lead (ranging from 8.36 to 325mg/L), and in one sample, for selenium (1.6 mg/L).

Total PCB analyses were also performed on the composite samples. Theinitial analysis of the sample MDC-2, performed using a gaschromatograph/electron capture detector (GC/ECD), was determined tobe erroneous due to the abundance of PCNs present in the sample.Sample MDC-2 was resampled and analyzed using a gaschromatograph/mass spectrometer (GC/MS) which resulted in a

AR300256

dramatically lower PCB concentration, resulting in no exceedances of theTSCA-regulated threshold of 50 ppm. Sample results have beensummarized-in the following table.

Table 1-1 Miscellaneous Debris

TCLP Metals (mg/L)Lead (5.0)Selenium (1.0)

PCBs (mg/kg)Total PCBs (50)

MDC-1

325

7.0

MDC-2

13.9

530*13.1

MDC-3

836

2.3

MDC-4

11.481.6

1.1

* PCNs interfered with the GC/ECD analysis of PCBs, resampling was performed by GC/MS.

The miscellaneous debris was removed from the Site and disposed of at .the EnviroSafe Services of Ohio, Inc. landfill in Oregon, Ohio in Aprilthrough July 1993.

132 Previous Studies on OU3 Materials

Numerous studies have been undertaken in response to the 1993administrative order for OU3. An initial investigation was performed togain a better understanding of what constituents in the fluff pile werecandidates for recycling and what relative quantities of each exist.Subsequent studies were performed to identify processes by which therecyclable fractions can be segregated and {prepared for commercial reuseand how successfully and at what cost the separation could beaccomplished.

1.3.2.1 Fluff Pile Composition Study (Law/Lockheed 1994)

Law Environmental (Law) conducted activities to characterize thephysical composition of the OU3 materials between May and October1994 Samples of the pile material were collected by a combination ofexcavation, and vertical and horizontal drilling methods. Observationsmade during the collection of the samples indicated that the OU3 fluffmaterial itself is very homogenous. However, miscellaneous debris andtrash were also found disposed of with the fluff and intermingledthroughout the pile. The results of Law's investigations are presented inthe Sampling and Analysis Report (November 1994).

EDM-NZlltOO.n»M/22/97

Law collected 247 discrete samples of the fluff and debris which weregrouped into six composite samples based on geographic location torepresent specific segments of the pile. The six composite samples weresubmitted to Lockheed Environmental Systems and Technologies(LESAT) laboratory for separation and characterization testing. Thetesting objectives were to determine the types and quantities of materialspresent, and whether each segregated fraction demonstrates hazardouscharacteristics. The component fractions of the material sampled arepresented in Table 1-2.

Analytical testing of the separated materials determined that all of the, fractions demonstrate RCRA hazardous characteristic for lead (Table 1-3).

Total PCB analyses were not performed on the Law/Lockheed samples,however, analyses of the TCLP leachate from unseparated fluff were non-detect for PCBs. The results of these analyses are further discussed inSection 1.3.3.

1.3.2.2 Plastics Separation (MacLeod 1995) . ,

The MacLeod Group (MacLeod) performed a pilot test at the Site inNovember 1995 to separate FVC, Polyethylene (PE) and metals

• (aluminum and copper) from the remainder of the fluff materials and tofurther evaluate the potential for use of the pile plastics in commercial ;

i j '• products. MacLeod processed approximately 10,000 pounds of generallyhomogeneous fluff material obtained from a stockpile generated by Law.The raw fluff was passed through a magnetic separator and mechanicalscreen to separate the ferrous metals and remove oversized debris. Afterscreening, the material was slurried in water and pumped to ahydrocydone and float/sink tank where the material was separated byspecific gravity into components and removed with screw augers. Theresults of this testing were presented in "Results from Sampling, Analysisand Testing Activities during MacLeod Treatability Studies" (Law, 6 May1996). The component fractions of the material sampled are presented inTablel-2. ;

The conclusions of the testing determined that the PE and PVC could beseparated through the float/sink process. The PE was easily separatedfrom the other pile materials and used to produce several plastic pots.

PVC separation, on the other hand, proved more difficult and yielded asmall percentage of good material The quality of the recoverable PVCwas judged to be of poor quality and varied significantly across the Site.

Law collected samples of raw fluff (five samples), the PE fraction (onesample), post-PE separation materials (four samples), the PVC fraction

EJEM AR300258

Table 1-2Fluff Quantities by Fraction

Eastern Diversified Metals Site

Plastics

Floating PlasticsPE

Non-Floating PlasticsPVC

Metak (Copper and Aluminum)

Other

Quantity (%)

2859-33.2920.227

22.4-39.9520.4*25

4-8»*4.23

5.68-37355.2***45

Souxce of Data

Law/LockheedMacLeodPhilip

Law/LockheedMacLeodPhilip

Law/LockheedMacLeodPhilip

Law/LockheedMacLeodPhilip

Note- * Includes rubber and others.** In concentrate. Reported 13.84 to 2832% metals concentrate (non fiber, non plastic, includingsand and clay), which had 185% copper and 9.7% aluminum.

*** Includes water.

ReferencesLaw/Lockheed - Law Engineering and Environmental Services, Inc,

Sampling and Analysis Report; Eastern Diversified Metals, November 1994.MacLeod - The MacLeod Group, Resource Recovery Inc, AT&T Hometown PA. Project 1995.Phillip - Phillip Environmental Treatability Study Report for the Recyldng of Fluffc Eastern

Diversified Metals Site, April 12,1996.

AR300259

(two samples) and the post-PVC separation materials (one sample) forTCLP lead and PCB analysis. The results of these analyses are presentedin Tables 1-3 and 1-4.

2.3.2.3 Plastics Separation (Philip Environmental 1996)

Philip Environmental evaluated the effectiveness of separating recyclableproducts from fluff materials. Philip shipped approximately 50,000pounds of fluff to their facility in Hamilton, Ontario for processing. Thisfluff was taken from the same stockpile generated by Law as described inSection 1.3.2.2. An electrostatic process was used to remove metals•followed by a plastics separation phase. The electrostatic processincluded: size classification, debris removal, drying, aspiration, andelectrostatic separation. Unexpectedly high moisture content of the fluffmaterial limited the process rate.

Plastic separation was accomplished on the basis of specific gravity andmelting points. The operation included size classification, washing,density separation, and drying. Analysis showed a purity of both PE andPVC of approximately 95% after segregation and recapture; TKecomponent fractions of the material sampled, reported in "Results fromSampling, Analysis, and Testing Activities During the Philip TreatabilityStudy" (Law, 16 May 1996), are presented in Table 1-2.

Philip concluded that their process (the Waxman Process) is a viableoption for recycling the fluff at EDM because it successfully separated theplastics and metals from non-marketable materials. Philip did not,however, perform an analytical evaluation of the separated fractions.Sample volumes of each separated material were sent to Law for furtheranalysis. Law collected the following for analysis:• Three feed fluff samples prior to rinsing;• Six samples following rinsing;* Two samples from soil and debris (removed during the rinsing

stage);• One composite sample from the metals fraction;• Three samples from the plastics fraction; and• Two samples of the separated PE and PVC.

Samples were analyzed for TCLP metals, and PCBs. Results of the sampleanalyses for TCLP lead and PCBs are presented in Tables 1-3 and 1-4.

BUM • - * 8 EDM-N2U1.00.01-W/Z2/97

RR300260

Table 1-3Leachable Lead Concentrations by Fraction

Eastern Diversified Metals Site

Sample

Huff in Pile

Raw Fluff

Raw Feed Post Rinse

Plastics Fraction

Metals Fraction

PE Fraction

PVC Fraction

Other Fraction- Post PE Separation- Post FVC Separation

Number ofSamples

317

53

4

3

1

12

21

41

ConcentrationRange (ppm)

1.55-64.36.85-213

19-2733-41

5.3-7.0

3.7-4.8

17

51.7-3.4

4.1-4.243

25-3214

AverageConcentration

(ppm)

18.9614.22

22.236

5.9

4.1

17

5255

4.243

28314

Sotuce of Date

Giddings-shallowGiddings-borings

Law/MacLeodLaw/Philip

Uw/Philip

Uw/PhiHp

Law/Philip

Law/MacLeodLaw/Philip

Law/MacLeodLaw/Philip

Law/MacLeodLaw/MacLeod

ReferencesGiddings - Todd Giddings and Associates, Site Evaluation Report September 1985.Law/MacLeod - Law Engineering and Environmental Services, Inc, Results from Sampling

Analysis and Testing Activites During the MacLeod Treatability Studies; May 6,1996.Law/PrdlHp - Law Engineering and Environmental Services, Inc, Results from Sampling

Analysis and Testing Activites During the Phfflip Treatability Studies, May 16,1996.

AR30026I

Table 1-4PCB Concentrations by FractionEastern Diversified Metals Site

SampleFluff in Pile

Raw Fluff

Raw Fluff (composites)

Raw Feed Post Rinse

Plastics Fraction

Metals Fraction

PE Fraction

PVC Fraction

Other Fraction- Post PE Separation- Post PVC Separation

Number ofSamples

317

53

66

4

3

1

1220202020

2120202020

4

1

ConcentrationRange (ppm)1.7-556010.6-41.2

15.9-2524.5-43

24*11222-125

20.1-75

46-135

46

7135-7410.4-253.8-8.411.7-1734.1-144

22.6-30.178

55-128. 1U-38.0

11.4-51.038.0-102.0

. : ' • ' ,25-53.627

AverageConcentration

(ppm)192.8/13.9*

20.4

19.933.5

52.3605

42.5

803

46

743.6.16.16.114.57.0

26.47886.7"21.724.759.0

34.5

27

Source of DataGiddings-shallowGiddings-borings

Law/MacLeodLaw/Philip

LawEnvirotech Research

Law/Philip

Law/Philip

Law/Philip

Law/MacLeodLaw /PhilipLaw/Philip BLaw/MacLeod

Envirotech/MacLeodEnvirotech/Phillip

Law/MacLeod.Law/PhilipLaw/Philip BLaw/MacLeod

Envirotech/MacLeodEnvirotech/Phillip

Law/MacLeodLaw/MacLeod

Note - Law/Philip B indicates a focused analysis on PCB concentrations In PE and PVC samples.*Dry weight basis. Average concentrations with and without maximum detection of 5360 ppm.

ReferencesLaw/MacLeod - Law Engineering and Environmental Services, Inc., Results from Sampling

Analysis and Testing Activites During me MacLeod Treatability Studies, May 6,1996.Law/Phillip - Law Engineering and Environmental Services, Inc., Results from Sampling

Analysis and Testing Activites During the Phillip Treatability Studies, May 16,1996.Law - Law Engineering and Environmental Services, Inc., Sampling and Analysis Report Eastern

Diversified Metals, November 1994.

AR300262

2.3.2.4 Raw Fluff Analysis far PCBs by Law and Envirotech Research

To confirm the results of the MacLeod and Philip studies, which indicatedthat PCBs were present in the fluff at elevated concentrations. Law >retrieved the six composite samples generated from the pile during theircharacterization study. Law analyzed each of the six composites for PCBsand subsequently submitted split samples to Envirotech Research forreplicate analysis. The results of these analyses are reflected in Table 1-4.

1.3.2.5 Additional Analysis of Separated Fluff Fractions

The initial analytical results for PCBs from the materials separated in thePhilip study contained a high degree of variability. As a result of the highvariability, and to further evaluate the PCB concentrations in the plasticsfractions, additional analytical testing was performed by Law. The 16May 1996 report prepared by Law (Results from Sampling, Analysis, andTesting Activities During the Philip Treatability Study) presented theresults of the analyses performed on the separated material fractions fromthe Philip study.

Twenty samples of each the PE and PVC fractions were analyzed for. PCBs and a statistical evaluation was performed. Trie results of theanalysis are summarized in Table 1-4.

In the May report. Law calculated a confidence level of 99% that the PCBconcentration in the PE fraction will be 22.8 ppm or less (non-parametricdistribution) and 96.5 ppm or less in the PVC fraction (natural log normaldistribution). This analysis also indicates that PCBs are concentrated inthe PVC material

133 Summary of Existing Information on the OU3 Materials

The data gathered to date from the previous investigations and studiesprovides a comprehensive understanding on the characteristics of the fluffmaterials. This information has been summarized on Tables 1-2, 1-3, and

The components of the fluff materials (Table 1-2) generally consist ofplastics (PE and PVC ranging from 20% to 33% and 20% to 40%,respectively), metals (primarily aluminum and copper ranging from 3% to8 % of the raw fluff), large debris (wood spools, cable, metal/ceramichardware) and other miscellaneous materials (wood, fiber, soil, rubber).The range in proportion of these fractions appears to derive from themethods of determination more than variability in the pile (e.g.,differences between "floating" and PE). X___ .... \ERM '' ^ EDM-N2111.0001- 06/22/97

The primary contaminants of concern in the fluff materials are leachablelead and PCBs which are summarized in fable 1-3 and 1-4. Leachablelead was found in all of the raw fluff samples above the RCRA maximumcontaminant level of 5 ppm. The separated PE and PVC fractionsgenerally have a lower lead concentration, likely due to washing whichoccurred in the separation process. PCBs were found in all fractions.However, the highest concentrations were present in the PVC fraction.Because PCBs would behave as plasticizers in PVC, it is believed thatPCBs would have migrated into the body of the PVC material and wouldnot be present merely as a result of surface contamination This is incontrast to PE and metals, where any PCB contamination would bepresent only on the surface of the particles.

1.4 IMPACT OF PREVIOUS INVESTIGATIONS/STUDIES ON RECYCLINGREMEDY

The numerous investigations discussed above have provided significantinformation in regard to the nature of the fluff pile constituents and theimpact that those characteristics have on the recycling remedy selected in2 July 1992 ROD.

The investigations have identified three constituents of potential recyclinginterest; metals (copper and aluminum), PVC and PE. To make use ofthese constituents, each must be segregated from the rest. Studiesperformed by Macleod and Philip show that segregation is physicallypossible. Law's investigations into the distribution of these constituentsthroughout the pile show that PVC and PE together account for slightlymore than one-half the pile by weight. The separation done by Philipshowed that commercially recoverable PVC and PE accounted for 52% ofthe fluff sample provided. ."

Chemical analyses of the composite fluff have consistently shown that it ischaracteristically hazardous for lead. One composite debris/fluff samplehas shown to be RCRA hazardous for selenium. The source of lead in thefluff is not fully known, but is believed to have been used as a heatstabilizer for PVC in the manufacture of insulated cable and wire.

• • " . . '-' ' * ' ' ' ' • . : ' . .Work with the segregated PE fraction has shown that the lead is, or canbe, removed in recycling processes to below levels at which the waste ishazardous for lead under RCRA. Samples of PVC separated intreatability studies do not fail TCLP for lead, indicating that theweathered PVC is easily washed to remove lead on the surf ace of theparticles. Investigation results indicate, however, that the balance of the

ERM A P Q n fi O C I EDM-N2111.00.01-M/13/77

fluff pile (i:e., the non-recyclable portion), destined for off-site disposal,will require stabilization before it can be landfilled.

The fact that lead becomes a non-issue with the separated, recyclable flufffractions is probably only of academic interest for EDM, since the materialalso contains PCBs. Beginning with the Todd Giddings study in 1985,PCBs have been identified as constituents of concern in the pile. TheToxic Substances Control Act (TSCA) has a waste management level of 50ppm. Further, the USEPA indicates that it is TSCA policy to prohibitreuse of materials with detectable levels of PCBs (2 ppm). While theGiddings report identified one area of noticeably higher concentration(the "PCB Hotspot")/ the majority of the pile (not separated into anyfractions) was found in this study to have total PCB concentrations belowthe TSCA waste management level of 50 ppm. Analyses of the separatedfluff fractions has revealed the PE and metals to have detectable levelsbelow the TSCA management level. The PVC, on the other hand, hasbeen found to contain PCB levels consistently above 50 ppm. That is, thesegregated PVC would be considered a waste regulated by TSCA.

Considering the level of PCB contamination identified,, it is- almost certain.that solvents or surfactants could be used to wash PCBs from segregated •metals down to an acceptable level for recycling. The same cannot be saidfor the plastics.

For PE, PCBs are not likely to migrate into the body of the particle. ThePCBs should be present only as surface contamination, and, therefore,possibly amenable to removal by washing with an aqueous detergentWhile organic solvents might also be Used to remove PCBs from PE, theiruse presents so many environmental and safety hazards that they will notbe considered as a possible remedy for the Site. Washing of PCBs fromseparated PE using aqueous detergents is the subject of a treatabilitystudy now underway (see Section 3.1).

While PCBs might be washed from the segregated PE with an appropriateagent, considering its nature and the level of PCB contamination, washingPCBs from the PVC down to an acceptable level is unlikely. PCBs behaveas plastidzers for PVC. They migrate into, and distribute themselvesthroughout the entire mass of the PVC particles. Any method that wouldremove PCBs would also remove all other plasticizer from the PVC,rendering the material essentially worthless for recycling purposes.

The infeasibililty of recycling the PVC fraction must be considered toseriously jeopardize the feasibility of the recycling remedy. This isfurther compromised by the PCB levels found in segregated PE andmetals, which, although not at TSCA regulated levels, appear to be at

flR3Q0265

unacceptable levels for commercial use unless washing is found to bepracticable.

13 USE OF EXISTING DATA FOR FFS

The purpose of this FFS is to examine alternatives that remain as potentialremedies. Each alternative involves processes for separating fluff fromlarge debris, possible segregation of large debris, possible separation offluff into' fractions, one or more treatment processes for each fraction, andultimate disposition offsite of each generated product or waste stream.The evaluation of alternatives will look at the technical feasibility andcosts associated with the processing of each stream.

Since the PCB concentrations in segregated PVC prevent recycling of thatfraction, this FFS will address 'the feasibility of segregating PE and metalsfractions (25% to 30% of the pile) for recycling. The viability of recyclingof any materials will be dependent on whether it is found that PCBs canbe washed from the FE fraction, or if the PE can be used for energyrecovery purposes at PCB levels present. The feasibility study mustaddress the implications of TSCA regulations on materials segregationand recycling or other reuse of the separated fractions, such as using thePE for fuel. An evaluation of off-site disposal of the remaining fractionsof the pile (those that have no recycling value) will take into account thePCB-TSCA and/or leadrRCRA hazardous characteristics of the materialand the associated stabilization requirements and other disposalrestrictions (e.g., debris disposal requirements).

Once the PE washing study results are obtained, the data will exist forperforming the FFS. Analytical data will exist to represent thecharacteristics of each potential product or waste stream generated byeach alternative under evaluation. -

ERM • n O f\ f\ O f f 12 EDM.N2iaOO.n-Mm/97AR300266z

2.0 GENERAL JTS APPROACH AND BASIS

As noted in Section 1, Lucent and USEPA initially agreed to theappropriateness of a FFS in the meeting of 30 October 1996. A secondmeeting was conducted on 25 January 1996 to develop an appropriate listof alternatives for the focused evaluation of alternatives to recycling. Thelist of alternatives developed in the second meeting was further evaluatedby Lucent and was summarized by Law in correspondence of 28 February1997. USEPA responded in its correspondence of 8 April 1997 whereinUSEPA recommended further investigation of the following alternativesin the conduct of the FFS:1. ROD Recycling Remedy—The recycling remedy, as selected in the

ROD, will be retain as a baseline remedy for comparison. This optionwould involve the on-site separation of the fluff pile for recycling.

2* On-Site Stabilization and Off-Site Disposal—This option wouldinvolve the stabilization of the fluff in the pile, without separation,and off-site disposal at an appropriate landfill.

3. On-Site Separation and Resource Recovery/Off-Site Disposal —This option would involve the on-site separation of the fluff pile intofractions for resource recovery and/or disposal Followingseparation, each fraction would be dealt with as appropriate. Therange of options for each separated fraction are identified below.

Polyethylene• Wash to remove PCBs and recycle;• Wash to remove PCBs and send t6 a Waste to Energy facility;• Wash to remove PCBs and send to landfill;• Send to Waste to Energy facility; and• Send to landfill

Polyvinyl Chloride

• Stabilize and TSCA landfill.

Metals• Send to copper/aluminum smelter;• Wash to remove PCBs and send to smelter; and* Stabilize and send to landfill.

ERM tn/^rtnor-v 13 BDM* mm jxun* 01/22/97AR300Z67

Soil/Other -,-. -,. ^ , ,•

• Send to appropriate landfill; and• Stabilize and send to landfill.

4. Direct Current Arc Melter Technology — This option would requireconstruction of an on-site low-temperature fusion plant to treat thefluff materials.

5. Use as Daily Cover at Landfill — This option would consist of usingthe fluff material as daily cover at a TSCA or RCRA landfill.

Lucent agreed with the inclusion of the first three alternatives, as noted inLaw's correspondence of 21 April 1997, but expressed concern with theviability of the latter two alternatives (see Section 3.2).

Subsequent to the execution of the AOC, Lucent and USEPA conducted ascoping meeting on 17 July 1997 to review the major issues influencingthe evaluation of the alternatives to recycling and the general approach tothe performance of the FFS. During this meeting, USEPA expressed itsgeneral agreement with Lucenfs intended approach. It was alsoconfirmed that the coordination of requirements of TSCA with theremedial objectives of CERCLA would be of key importance in evaluationof the alternatives.

2.1 FFS OBJECTIVES

The overall objectives of the FFS are to evaluate the identified remedialalternatives, and recommend the optimal remedial action for the fluff anddebris at the Site. *

The evaluation of remedial alternatives will incorporate the following:• Knowledge of waste material conditions, including definition of the

current contaminant distribution, concentrations, and total estimatedmass, which have generally been determined through previousremedial investigations and treatability studies;

• Review of all applicable and relevant and appropriate requirements(ARARs) pertaining to the treatment, recycling and disposal of thewaste material (especially relevant are TSCA and RCRArequirements);

• Investigations into the available market for recycled materialsgenerated from the Site;

BRM ' EDM-N2Ul.00.m-08/I2/97

• Investigations into facility acceptance of the waste materials (i.e.,waste to energy, smelter and disposal); and

• Engineering economic analysis of the potential remedial alternatives.

IDENTIFICATION OF POTENTIAL ARARS

As part of the development of remedial action objectives, and to aid in theevaluation of regulatory compliance, the FFS will identify and present allARARs for remedial activities.

These ARARs will be identified from a number of sources includingprevious experience with similar sites, federal and state regulations andGuidance documents, and additional input from the USEPA andPennsylvania Department of Environmental Protection (PADEP).

To the extent standards are not applicable, but may be relevant andappropriate, consideration will be given to the factors set forth in Section300.404 (g) (2) of the National Contingency Plan, including any variances,waivers, or exemptions from the standard, and whether the standard iseither relevant or appropriate.

ARARs that have been identified to date are as follows:• Comprehensive Environmental Response, Compensation, and ^

Liability Act (CERCLA) — EDM is a Federal Superfund Site and allactivities, including FFS preparation, will be conducted incompliance with CERCLA guidance and regulations.

• Toxic Substances Control Act (TSCA)—Sample analyses haverevealed PCB concentrations above the 50 ppm TSCA threshold forwaste management. TCSA regulations will determine materialhandling and disposal protocol for all materials with PCBconcentrations above 50 ppm. The USEPA indicates that TSCA alsoprohibits reuse of materials with detectable levels of PCBs (2 ppm).

* Resource Conservation and Recovery Act (RCRA)—Sampleanalyses have revealed leachable lead concentration above the 5 ppmRCRA maximum concentration limit for lead. All materials withleachable lead concentrations above 5 ppm are characteristichazardous (D008) and will be treated and disposed according toRCRA regulations.

• Pennsylvania Residual Waste Regulations—Materials that aredetermined to be non-TSCA and non-RCRA hazardous may bedisposed in a residual waste landfill according to Pennsylvania's

004 flR^nn9fiQ ^ EDM-N21H.08.M.M/22/97

Residual Waste Regulations. Non-TSCA materials that are stabilizedfor lead contamination may be disposed in a residual waste landfill.

The feasibility of segregation of the various fluff components may begoverned by the issue of waste "dilution." TSCA policy typicallyprohibits the removal of waste components with a lower PCB content ifthe aim of such removal is to avoid the treatment of the component as aPCB waste. This policy appears to be at variance with the CERCLAremedial objective of reduction of toxicity, mobility and volume ofcontaminants. USEPA has noted that waivers to certain TSCArequirements have been granted at other CERCLA sites; the potential forsuch a waiver for EDM will be explored in evaluating the feasibility of thespecified alternatives. ,

It should be noted that, because this project is being conducted incompliance with the CERCLA, no federal, state, or local permits will be •required for any remedial activities conducted entirely onsite (40 CFRSection 121(e)). However, it is acknowledged that all remedial activitieswill be required to meet the substantive requirements of all ARARs, andany actions which extend over the site boundaries will be subject to thefull technical and administrative requirements of the ARARs.

23 SUMMARY OF fFS APPROACH, : . .. > \,/ v . ''The FFS for the Site will be conducted in accordance with the applicablerequirements of the AOC for OU3, CERCLA and the NationalContingency Plan (NCP; 40 CFR 300). The FFS will follow the generalsequence and intent for conducting Feasibility Studies as presented inUSEPA's RI/FS Guidance (USEPA, 1988).

The focused list of remedial alternatives developed for the FFS will bedescribed and analyzed in detail to present the information required forselection of the most appropriate Site remedy. Because the FFS activitiesare focused, the alternatives screening steps will not be performed as partof the FFS. In accordance with the requirements of CERCLA, eachalternative will be evaluated/ as appropriate, against the following ninecriteria:• Overall protection of human health;• Compliance with potential ARARs;• Long-term effectiveness and permanence;• Reduction of toxicity, mobility, or volume;• Short-term effectiveness;

**" • n O n ft O "7 n • ^ BDM.N211UO.01.08/22/97A R O U U L I U :

* Implementability;• Cost;• State acceptance; and•• Community acceptance.

The overall protectiveness is a measure of achieving adequate protectionof human health and largely depends on the risk during and afterimplementation of a remedy. The evaluation of overall protectivenesswill also depend on other related criteria such as long-term effectiveness,permanence, short-term effectiveness, and compliance with ARARs.

The detailed analysis will identify specific ARARs for each alternativeand describe the extent to which the alternative meets the requirements ofthe ARARs. If one of the ARARs is not met, the basis for justifyingwaiver(s) will be presented.

Each alternative will be subjected to a cost analysis that will include initialcapital costs and operation and maintenance costs. These estimates willbe based on previous experience, published cost data with site-specificadjustments, and vendor supplied information, and will consider costs forthe major construction components expected from a preliminaryconceptual design. The level of detail for these cost estimates will besufficient to provide a comparison between remedial alternatives, andwill be in accordance with the RI/FS Guidance (USEPA, 1988).

Reduction of toxidty, mobility, and volume will be evaluated for eachalternative. Evaluation of other remaining criteria will also be conductedin accordance with the RI/FS Guidance (USEPA, 1988). However,evaluation with respect to the final two criteria, state acceptance andcommunity acceptance, will be performed by USEPA after receiving thecomments from the state and community following review of the FFS.

After the presentation of each alternative evaluated in.accordance withthe criteria established above, the relative performance of each alternativewill be presented. This comparative analysis will be prepared in a matrixform to present a concise comparison of all alternatives. If applicable,additional summaries will be presented in tables and figures to aid in theselection and recommendation of the most appropriate alternate remedialaction.

AR300271 17

(•/ - (•„2.4 RECOMMENDED REMEDIAL ACTION*

A recommended remedial action alternative for the Site will be selectedbased on the evaluation and comparison of remedial alternatives. TheFFS report will include a summary of the rationale for recommending theselected option, stating its advantages over the other alternativesconsidered.

ERM •»««ts\/\J>1') 18 BOM -N211L00.01- 08/22/97RR300272

3.0 APPROACH TO FFS EVALUATION

The remedial alternatives that will be further investigated as part of theFFS activities have been developed as presented in Section 2 above. Theevaluation of these alternatives will consist of a thorough review of theexisting data and results of a separation study currently underway.

3.1 APPROACH TO FILLING DATA GAPS

As was presented in Section 1.5, sufficient information exists or iscurrently being generated on the characteristics of the fluff materials toproceed directly with the FFS. The only identified data gap isunderstanding the viability of washing PE to remove PCBs. This data gapis currently being investigated, and results are anticipated within thecoming month. Details of the study are presented below.

This FFS Work Plan will be amended if it is determined that, during thedetailed analysis of the alternatives, additional site characterization datais required to adequately define the extent and distribution ofcontamination, or quantify other site characteristics which may impact theevaluation of alternatives. Any necessary Data Gap Work Plan(s) will ,discuss data quality objectives and will present associated Sampling andAnalysis Plan(s) and Health and Safety Plan Addenda. These documentswill be prepared in accordance with applicable USEPA guidance, and willbe submitted to the USEPA.

3.1.1 Separation and Washing Study

W. R. Boyhan Associates, Inc (Boyhan), in coordination with the NewJersey Institute of Technology (NJTT), is currently performing apreliminary treatability study on samples of raw fluff. These samples arethe remainder of the six composite samples generated by Law in 1994 forthe Lockheed characterization study (see Section 1.3.2.1).

The first portion of the study involves the separation of the fluffcomposites into six fractions: trash, PE, PVC, fiber, coarse mud and finemud. Each separated fraction from each composite (except trash) will beanalyzed for PCB content

For this study trash consists of the material retained on a standard ASTM4-mesh screen. It contains rocks, clay, fiber balls, cardboard, wood, fused ' ^plastic and miscellaneous other materials. The sampling method used by —

ERM ' 19 EDM-N2m.0001-08/22/97

Law generally limited material to that which dbuld be picked up by a 2-inch split-spoon sampler. As such, the trash portion of the compositesamples cannot be fully representative of the material contained at theSite. For this reason/ and because the material is inherentlyheterogeneous and without a typical composition, no analyses will beperformed on this fraction.

The second portion of the study investigates the feasibility of usingaqueous surfactant solutions to lower the PCB content of the PE materialto less than 2 ppm. A detailed description of the study procedures ispresented in the 11 December 1996 Work Plan which has been submittedto the USEPA. This work plan is enclosed as Appendix A.

3.1.2.1 Separation Study

The separation study will be performed on the samples collected by Lawduring the characterization study performed in 1994. Fluff separationwill be performed utilizing water and a salt solution of controlled specificgravity, similar to that used by MacLeod in their study in 1995. To obtainthe sharpest separation possible between fractions, standard ASTM sievesand manual separation will be employed where appropriate.

3.1.1.2 PE Washing Study

The PE washing study will be performed on available PE separated byMacLeod during their study. The study will test eight different detergentformulations using surfactant concentrations arbitrarily standardized at10% of the manufacturer's stock solution or normal shippingconcentration. Each test will consist of a 328 gram PE sample agitated forsix minutes by a laboratory propeller mixer in 13 L of surfactant solution.The samples will be rinsed to reduce residual detergent concentration toless than 0.01%, or 1/1,000 of the working solution concentration. Thesamples will then be air-dried and analyzed for total PCBs. The results ofthe initial testing will determine what additional tests should beperformed. If one or more of the detergents show promise in reducingPCB content, refinement and further investigation will be performed,with amendments to this FFS Work Plan and schedule, as appropriate.

The results of the PE washing study are critical to the evaluation ofremedial alternatives. Hie feasibility of Alternative 3 will be evaluated onthe results of the. study arid applicable TSCA regulations and policies.

BUM AR30027U 20 BDM-N2111.00.01-W/22/97

3.1.2 Meeting td Discuss Results of Separation and Washing Studies

Within two weeks following the completion of the separation andwashing studies (including analysis and data evaluation), a meeting willbe scheduled with the USEPA to discuss the results. The results of thestudy will provide the necessary information to fill the identified data gaprelated to the characteristics of the fluff material The meeting will alsoprovide an opportunity for a redirecting of the FFS process, ifappropriate.

3.13 Meeting with USEPA and TSCA

Shortly after the review meeting on the separation and washing studies, ameeting will be scheduled with the USEPA CERCLA and TSCArepresentatives. The meeting will be focused on the role of the TSCAregulations and the impact of the regulations on the selection of theremedial alternative ), and the potential for flexibility in some of theTSCA regulations.

3.1.4 Additional Treatability Studies

In general, additional treatability studies may be appropriate when theperformance of a promising technology for site-specific conditions cannotbe adequately predicted based on previous studies or experience withthat technology. At present, it is believed that sufficient experience existswith the technologies involved in the identified alternatives to permit theevaluation of those alternatives to proceed. Should it become apparent,during detailed analysis of alternatives, that such studies are required toaid in the evaluation of specific technologies and/or alternatives, aTreatability Study Work Plan will be prepared to present the proposedscope of work. Any such Treatability Study Work Flan(s) and associatedSampling and Analysis Plan(s) and Health and Safety Plan Addendumwill be prepared in accordance with applicable USEPA guidance, and willbe submitted to the USEPA. The treatability study will include thefollowing:• Identification of Candidate Technologies Memorandum;* Treatability Testing Statement of Work;• Treatability Testing Work Plan; and• Treatability Study Evaluation Report

ftR300275 BDU'NUU.OOJn-M/22/97

32 EVALUATION TASKS FOR IDENTIFIED REMEDIAL ALTERNATIVES

Evaluation of the remedial alternatives, in essence, centers around the\ j evaluation of processes for segregation, treatment and disposition of

product and/or waste streams generated through removal of the fluffpile.

The completed investigations have shown that the remaining recyclingproduct streams of potential interest, PE and metals (copper), can be

: separated by the use of available commercial processes. These pilot testswill be extrapolated to real life scale in order to evaluate site preparationrequirements, time scales for processing and alternatives for off-siteshipment. Project costs Can then be developed for the recycling options.

Disposal of non-recyclable fractions will also involve separation processesto segregate large debris and other fractions that cannot be handledtogether with the process residuals. The process residuals, at a minimum,will likely require stabilization for off-site disposal. Each remedialalternative will generate different amounts of non-recyclable fractions.Given the size of the pile, however, the stabilization process is likely to be

- the same for the process residuals, regardless of whether or not plastics ormetals are included.

Contacts will be made with vendors of processing, materials handling- and stabilization materials/systems and equipment. Other contacts will

be made with landfills, waste to energy facilities, smelters and recyclablematerials brokers to identify material preparation requirements, preferredmodes of delivery and costs for disposal.

Disposition of each product or waste stream will involve compliance withTSCA and/or RCRA and Pennsylvania Residual Waste regulations.Contacts will be made to review the pertinent requirements.

The information accumulated above will be used together with athorough review of the available data to yield quantities of the variouspile fractions of interest Based on those quantities and pertinentregulatory requirements identified for each stream, concept processes willbe selected for handling the OU3 materials from the pile to their ultimatepoint of disposition. Again relying on the material quantities developed,cost estimates will be developed for disposition of each product or wastestream for each alternative. The total anticipated cost for each alternative

- evaluated will be the sum of the costs for handling each product or wastestream, plus additional costs for required common activities such asoversight, security, health and safety, air monitoring, etc.

AR300276 22 EDM • N2111.00.01 - OS/22/97

32.1 Alternative 1 - ROD Recycling Remedy

Alternative 1 will be evaluated as a base-line for comparison of the otheralternatives. Recycling of the plastics and metals portion of the fluff pileinvolves separation/segregation and conversion of the raw feed to ausable product Separation technology has proven successful in previousstudies.

Off-site disposal of residuals from the separation process (non-recyclablefractions) will be an important element of this remedy option since thesecomponents make up as much as one-half of the pile. Because of thedocumented lead contamination of these fractions, stabilization will berequired for land disposal. Stabilization of lead contamination is aproven and well understood treatment technology.

3.2.2 Alternative 2 - On-Site Stabilization and Off-Site Disposal

Stabilization is required to address the RCRA hazardous characteristic forleachable lead. Stabilization technologies are well researched and aretechnically feasible for the fluff pile materials. Stabilization canpotentially be performed in situ or by processing fluff in batches withinthe confines of the Site boundary. Following stabilization, the materialwill no longer require disposal in a RCRA-hazardous landfill. PCBconcentrations of the stabilized material will determine whether thematerial will require disposal into a TSCA landfill* Previous studiesindicate that the majority (95%) of shallow samples of the fluff materialwould likely not require disposal in a TSCA landfill due to total PCBconcentrations less than 50 mg/kg. Analysis of six composited samplesduring Law's investigation indicate that two (Law analyses) or three(Envirotech Research analyses) exceeded the TSCA management levelResults of the PCB analyses on the separated fluff fractions provideadditional information on the overall PCB content of the fluff.

3.23 Alternative 3 - On-Site Separation and Resource Recovery, and Off-SiteDisposal

The on-site separation and resource recovery alternative is a subset ofAlternative 1. The principal difference between these alternatives lies inaddressing the real needs for treatment/washing the recyclable fractionsto remove lead and PCBs. TSCA approval and market acceptance of therecyclable material will depend on the extent of degradation of thematerial and the effective lack of PCB content (less than 2 mg/kg). This isonly potentially feasible for the PE and metals. The feasibility of washingseparated PE to remove PCBs will be determined from the results of thewashing study presently being completed. If recycling of the separated,

™* ^ -• -« 23 EDM-NI111.00-01-M/21/97HR300277

washed PE is not a feasible alternative for market acceptance reasons, thepotential exists for the PE material to be utilized in a resource

5 V .y -..-, 'yrecovery /waste to energy facility. If the PE material cannot besuccessfully washed of PCBs, separation of any constituents or recyclingwill likely not be viable. There is a possibility that a Waste-to-Energyfacility might accept the PE as long as the PCB content was comfortablybelow 50 ppm.

3.2.4 Alternative 4- Direct Current Graphite Arc Melter Technology

The Direct Current Graphite Arc Melter Technology is far from being a• proven technology and would require substantial research and

development to produce a working unit. Treatment of the fluff materialsusing this technology would also require treatment of toxic off gasses andsubstantial amounts of hydrochloric acid released from the PVC. Thistechnology is not a viable alternative, and will not be further investigatedduring the FFS activities.

*3.2.5 Alternative 5 - Landfill Daily Cover

The characteristics of the EDM fluff materials are not suitable for use as a. daily cover at a non-hazardous Waste disposal facility, and TSCA andhazardous waste landfills do not use daily cover in daily operation.TSCA and hazardous waste landfills have been designed and permittedto accept TSCA and hazardous wastes and are only interested inaccepting the EDM fluff material as a disposed waste. This is not a viablealternative, and will not be further investigated during the FFS activities.

3.3 SUMMARY OF EVALUATION/RANKING OF ALTERNATIVES

The remedial alternatives will be developed as described above, theevaluation process described in Section 2.3 will be performed. The resultwill be a ranking of the alternatives according to the criteria discussed inSection 2.3. From this ranking, an alternative will be selected forrecommendation in presenting the results of the FFS.

KM aoonnoTO 24 EDM.N2111.00.01.OB/22/97

4.0 FFS PROJECT MANAGEMENT

4.1 FFS TEAM

The major FFS support will be provided by the following:* Environmental Resources Management (ERM) — will assist the

Respondent in compiling relevant data and preparing the FFS report.• W & R Boyhan Associates/ Inc. — Is currently performing a

treatability study in coordination with the New Jersey Institute ofTechnology.

Additional firms may be employed if required for further technicalexpertise.

4.2 MEETINGS

Lucent anticipates regular interaction with the USEPA during the courseof the FFS process. In addition to the washing study review and TSCAmeetings identified in Sections 3.1.2 and 3.13, periodic conference calls ormeetings will be scheduled to discuss the progress of the FFS activities.An interim review meeting will be held upon substantial completion ofthe FFS analysis to review the technical findings of the study prior to thepreparation of a draft report, as shown on the attached schedule.

43 SCHEDULE

Following receipt of EPA's comments on this FFS Work Plan, if any, theplan will be revised as appropriate and submitted for approval.

A schedule for implementation of the work plan is presented on Figure 4-1. This schedule includes the general sequence and duration required forcompletion of the major FFS tasks, as well as all activities that follow theapproval of this work plan.

As described in Section 3.1, the initial task in the FFS is the completion ofthe separation and washing study (initiated in July 1997 and scheduledfor completion in September 1997). This will be followed by two reviewmeetings with USEPA in late September, where final focusing of the FFSevaluations will occur. The FFS evaluations will proceed with initial ,results reviewed during the interim FFS progress meeting, prior to the

ERM ^ BDM-N2111.00.01- OB/22/97

preparation of the FFS report. The draft FFS report will be submittedwithin two months of the final interim meeting, and the final reportsubsequent to receipt of USEPA comments. This schedule may bemodified if it is determined that additional treatability studies arerequired or if the impact of ARARs cannot be resolved with regulatoryagencies in a timely manner.

4.4 REPORTINGIDELIVERABLES

In accordance with the AOC and the FFS schedule presented in Figure 4-1, a progress report will be prepared each month to provide the following:• A description of the actions that have been taken toward achieving

compliance with the AOC;• Any results of sampling, tests and analytical data;• A description of all data anticipated and activities scheduled for the

next 30 calendar day period; and• A description of any problems encountered, any actions taken or to

be taken to remedy or mitigate such problems, and a schedule ofwhen such actions will be taken.

Upon completion of the FFS evaluation, a draft FFS report will besubmitted to the USEPA for review and comment. Upon receipt ofcomments from the USEPA, edits will be made to the report and the finalFFS report will be submitted to the USEPA for approval. The final reportwill be certified by a responsible official of Lucent.

BUM 26 EDM •N2111.0L01-06/22/97

Appendix AWashing Study Work Plan

AR300282

Lucent TechnologiesWORK PLAN - EOM FLUFF

12/11/96

1. Determination of PCBs In the various fractions of the fluff.2. Determination of the possibility to remove PCBs from PE by an aqueousprocess.

INTRODUCTION

Lucent1 s continuing effort to find a remedy for the fluff pile at Hometown, PArequires that two laboratory studies bo performed. The first study involvesseparating each of six samples of raw fluff into three specific fractions, anddetermining the polychlorinated biphenyl (PCB) content of each of theseeighteen fractions. The second study investigates the feasibility of using anaqueous "washing" process to lower the PCB content of polyethylene (PE)separated from the fluff to less than 2 ppm.

There are no standard procedures for either the separation or washingoperations. Therefore it will be necessary for a Lucent representative to activelyperform, or at least personally observe and direct them. An outline of the work tobe performed is given below.

Analysis of the separated fluff fractions, and "washed" PE will ba performed bythe laboratory for total PCBs, using standardized and approved EPA methods.There will be no direct involvement of Lucent personnel in these analyses.

OUTLINE

Fluff Separation - Lucent must determine the partitioning or distribution ofPCBs in the fluff at the site among three fractions: polyethylene (PE), potyvinylchloride (PVC), and the remainder consisting of clay, sand, fiber, copper,aluminum, iron, and other materials (OTHER).

This study will ba performed on six composited samples of fluff collected frommultiple points at the sits during a characterization study performed in 1994 byLockheed. Tha approximate quantity of material available is shown in Table 1.

The fluff will ba stirred into water and allowed to settle. Whatever floats isdefined as tha PE fraction. Tha "sinks' will then be stirred into a calcium chloridesalt solution at a specific gravity of 1.5 (Salt Solution). Whatever floats is definedas the PVC fraction. Whatever sinks in tha Salt Solution is defined as OTHER.

•iEPATEST1.DOC, WSB, 11/05/96Revised 12/11/96Printed 2/3497. 1:42 ?M

AR300283

The weight of the original fluff sample must be measured before being added towater. For PE, the drip-free and drained water-wet weights, and dried weightsmust be measured. We also require the drip-free and drained Salt Solution-wetweights, drip-free and drained water-wet weights and dried weights of PVC andOTHER. This information will be needed to estimate drag-out during processdesign of a separation facility, if it is determined that one is to be built.

The dried PE, PVC and OTHER fractions will be separated into 20 standard 30-gram sub-samples (or, if less than 600 grams is available, as many 30 gramsamples as the amount of material allows) for extraction prior to PCB analysis.Alequots of the extracts from each fraction will be composited and a single PCBanalysis performed for each fraction.

Washing PCBs Off Polyethylene —Two treatability studies performed in late1995, early 1996 indicated that polyethylene separated from the fluff by flotationtechnology has a PCB content of from 5 to 15 ppm, and possibly much higher.Lucent must determine if it is feasible to reduce the PCB content to below 2 ppmusing aqueous processes.

As a starting point, Lucent will select at least five industrial detergentformulations recommended by Shell Chemical, Petroferm, Union Carbide andsimilar companies. Samples of PE obtained during the treatability studies will besupplied to the laboratory by Lucent and subjected to vigorous agitation in amoderate strength detergent solution for a fixed period of time.

Washed PE will be rinsed and dried. Ten standard 30 gram samples will betaken and extracted. The extracts will be composited and a single analysisperformed to determine the average PCB content for each washed sample ofPE. Fewer samples for the washing tests are being taken than for theseparation tests because the only meaningful result will be if PCBs are loweredto less than 2 ppm (the standard EPA detection limit).

•" "• . ' ' ! •-•' J. " '

To provide a bench-mark and a control for the effectiveness of the washingprocess, an untreated PE sample and a sample of PE that is subjected to thesame physical washing procedure, but In pure water only, will atso be preparedand analyzed for PCBs. f~

Results of the first round of tests will determine what additional tests should beperformed. If one or more of the detergents show promise In reducing the PCBcontent, we may explore alternate agitation times, the intensity of agitation,detergent concentration, solution temperature, etc. If none of the detergentsshows significant improvement, we may consider longer and/or more vigorous

- agitation, elevated temperatures, higher concentration or alternate detergents,etc. • - . ' • ' . . . ' • " : ' • • . " •

EPATEST1.DOC, WSB. 12/05/96Revbed 12/11/96Printed 2/24*7,1:42 PM

flR30028l*

DETAILED PROCEDURES

1. Fluff Separation - Six composite samples will ba used to perform thesetests. These samples will ba created by combining and physicallyhomogenizing each pair of tha retained samples C-1 through C-6,previously used by Law and Envirotech Research to measure total PCBcontent of each composite. Tha estimated quantity available ranges fromabout 2,300 grams to almost 3,200 grams. This is shown in Table 1. Themoisture content Is unknown. However, if it is no more than tha originalmoisture content of 26.8%, there should ba at least 500 grams of each oftha three fractions derived from tha six composites.

For tha weighings required for the separation tests, precision need only bato tha nearest gram.

a) Separation of PEi) Beginning with C-1, weigh tha sampla and add it to two

gallons of delonized (Dl) water in a three gallon pail. Use nosurfactants, detergents, wetting agents or defbamers. Stirtha fluff vigorously, without entraining air bubbles, and allowto settle. Repeat until no additional air bubbles ara releasedupon stirring.

ii) Allow to stand undisturbed until clay and fiber sink.iii) Carefully remove tha floating PE by scooping and/or

decanting into a two liter beaker.iv) Add water to fill tha beaker if necessary, stir and allow to

settle.v) As In Step HI), remove tha floating PE to another two liter

beaker Return any "sinks" to the original bucketvi) Repeat Steps iv) and v) until no significant "sinks* are

observed.vii) Place tha wet PE onto a tared 100 to 200 mesh screen and

weigh after any free water stops dripping.viii) Place tha screen on a series of dry paper towels. When

fresh towels are no longer wetted by tha PE on tha screen,again weigh tha PE.

ix) Dry tha PE and again weigh. This is tha PE sampla for PCBtesting.

b) Separation of PVCi) Thoroughly drain any free water from tha residua in tha

threa gallon bucket without losing any clay, fiber or other. . -3-

EPATESTl .DOC, WSB, 12/05/96Revised 12/1I/MPrinted 2/24/97,1:42 PM

AR300285

fines. If necessary, decant the free water through filterpaper. Anything trapped on the filter paper can be returnedto the bucket in the next step.

II) Wash any material collected on the filter paper from theprevious step back into the bucket while adding about twogallons of a calcium chloride solution to the bucket. Thefinal specific gravity of the solution should be between 1.48and 1.52 at 70 to 80° F, after dilution by the water retained inthe PVC and OTHER remaining in the bucket.

iii) Stir the material and allow to settle.iv) Carefully remove the floating PVC by scooping and/or

decanting onto a tared 100 to 200 mesh screen, catchingany runoff salt water for return to the bucket. Weigh the salt-wet PVC after all free solution has stopped dripping.

v) Place the screen and PVC on paper towels and again weighthe PVC after fresh paper towels are no longer wetted by thePVC.

vi) Rinse the PVC with Dl water until the salt content of the finalrinse is lowered to less than about 5,000 ppm. (Multipleadditions of Dl water to a beaker holding the PVC, followedby careful decanting Is one way to rinse the PVC. Aconductivity meter is probably the easiest way to estimatethe salt content,) Retain any floating material with the PVC.

vii) Transfer the rinsed, wet PVC to a tared 100 to 200 meshscreen and weigh after all free water has stopped dripping.

viii) Place the screen on paper towels and again weigh afterfresh towels are no longer wetted.

be) Dry the PVC and weigh. This is the PVC sample for PCBtesting.

c) Separation of OTHERi) Carefully remove the remaining material in the bucket by

scooping and/or decanting onto filter paper on a tared 100 to200 mesh screen, catching any runoff particulates or fiberand return to the filter paper/screen. Filter paper is used onthe screen for collecting OTHER because this is the fractionwhich will contain clay and other heavy, very fineparticulates.

ii) Weigh the salt-wet OTHER after all free salt-water hasstopped dripping. Weigh a Salt Solution "drip-free" piece offilter paper to determine the weight needed to compensatefor the filter paper on the screen.

iii) Place the filter paper/screen on paper towels and againweigh after fresh towels are no longer wetted. Compensate

--4-

EPATEST1.DOC, WSB. 12/05/96Revised 12/11/96Printed 2/24/97,1:42 PM

AR300286

for the filter paper on the screen by weighing a Salt Solutionwetted piece of filter paper that has been similarly dried bycontact with paper towels.

iv) Transfer the OTHER to a beaker and rinse with Dl wateruntil the salt content of the final rinse is lowered to less thanabout 5,000 ppm.

v) Transfer the rinsed, wet OTHER to filter paper on a tared1 00 to 200 mesh screen and weigh after all free water hasstopped dripping. Compensate for tha filter paper as in ii).

vi) Place the screen on paper towels and again weigh afterfresh towels are no longer wetted by the screen.Compensate for the filter paper as in iii).

vii) Dry and weigh. This is the OTHER sample for PCB testing.d) Perform this separation on all samples C-1 through C-3. Fresh Salt

Solution should be used for each separation:a) If there are at least 600 grams of sample available, extract twenty

standard 30 gram sub-samples from each of the eighteen fractions.If there are less than 600 grams of sample available, perform asmany standard 30 gram extractions as the amount of availablematerial allows, using up all of the available material.

0 Composite aliquots from each of the extracts from tha sub-samplesfrom each fraction and measure total PCB content of tha eighteencomposited extracts thus created.

2. Washing PCBs Off Polyethylene - Tha PE for this study comes fromtha treatability study performed by McLeod in November 1995 and tha PEfrom tha Waxman/Philip treatability study performed in early 1996. Thesematerials will ba supplied by Lucent

a) A reproducible agitation system must ba prepared by the laboratoryand approved for the testing by Lucent Wa envision tha agitationfor initial tests to ba roughly equivalent to that obtained in a Waringor Osterizer-typa blender with dulled blades at medium speed. If astandard household blender with a capacity of approximately 1,400ml is used, tha processing of 350 grams of PE will probably hava toba dona in two or more batches to provide sufficient separation ofindividual particles to prevent creating a "mud", rather than a diluteslurry. Alternately, a recirculating system using a two liter beakerand a centrifugal pump might ba used. Wa ara open to othersuggestions which would produce reproducible agitation and baamenabta to scale-up for a production system to process 5,000 to10,000 pounds of PE per hour.

-5-EPATESTl.DOC, WSB. 12/05/9*Revised 12/11/96Printed 2/24/97. 1:42PM

AR300287

b) Ultrasonic agitation is not likely to be effective on this soft,particulate material and wilt not be considered for this first round oftests.

c) Combine and blend the various PE samples supplied by Lucentfrom the treatability studies performed in 1995 -1996. Thereshould be a total of about ten kilograms (dry basis) available. Fromthis material, create twenty identical sub-samples, of approximately350-grams each (dry basis - note that the samples supplied arewet).

d) Prepare detergent solutions In accordance with the formulations. supplied by Lucent. See Table 2 for the initial formulations to beprepared. Lucent is also amenable to suggestions as to otherdetergent systems that might be effective.

e) For the first round, agitate a PE sample for exactly four minutes atapproximately room temperature. Record the temperature of thesolution before and after agitation. Agitation must start promptlyafter the PE comes In contact with the detergent solution. ,

f) Promptly and thoroughly rinse each washed sample with Dl waterat approximately room temperature (recording the temperature ofthe rinse water) to remove all detergent and separated PCBs.Discard any material that sinks In fresh water. If It weighs overone gram, first record Its dry weight

g) Repeat for all the detergent samples to be tested in this round.h) Duplicate the washing operation on one PE sample, using plain Dl

water, as a control.I) Analyze the following samples for total PCBs:

i) A baseline-a sample which has had no washing operationperformed on It

ii) A control-the sample washed in Dl wateriii) Each of the samples washed in a detergent solution.

j) Perform ten standard extractions on each sample, (presumablythere will be at least 300 grams (dry basis) available after washing),composite the extracts, and analyze for total PCBs in the combinedextracts using EPA Method 8080.

k) From the test results, determine what additional PCB-wash testingshould be performed. Variables for the washing operation include:

. 0 Detergent typeii) Detergent concentrationlit) Solution temperatureiv) Total contact time between PE and detergentv) Duration of agitationvi) Intensity of agitation

j/ j / 11fTTTTF1

EPA-n-STl.DOC, WSB, 12/05/96Revised 12/11/96Printed 2/24/97,1:42 PM

A.R300288

Sheetl

IABLE4AVAILABLE SAMPLES FOR PERFORMING 12/11/96 EDM WORKPtAN

SAMPLEC-1C-2WC-4C-«c-«

NOTES:

ENVUtRES.-flt

800700740700770700

LAWPounds

3.34.34.04.95.25.5

LAWGrama149819521816222523612497

TOTALAVAIL229826522556292531313197

PC22*3054

512591570652698713

PVC244fltt

554639616705755770

."OTHER2&ao&

618713688787842860

WATER2&8Q&

616711685784839857

CHECKSUM230026552559292831343200

1. Quantities art as reported in their possession by Law and Envirotech Research.2. Percentages are the average for all samples reported by Lockheed.3. If the samples are dryer than 26.8%. there should ba proportionately more of the-polymers and "othef available for testing.

EPATEST1.XLS. WSB. 12/11/96Printed 12/11/96. 1:29 PM

AR300289

TABLEg

Typical Detergent Formulationsto be Preparedfor PE Washing Study

High Quality Concentrate - Shell Chemical Co,

NEOOOL 1-5(2) 10.0 wt%Sodium metasilicate, pentrahydrate 12.0EDTA(1) 10.8Triton H-66 (2) 10.0Water 57.2

100.0

Dissolve NEODOL and Triton in water. Add EDTA and sodium metasilicate withvigorous stirring until homogeneous.

AH Purpose Cleaner Heavy Duty Concentrate - Union Carbide ORE 248

TRITON XL-80N Surfactant (2) 4.0 wt.%TRITON H-66 Suractant (50%) (2) $.0Sodium hydroxide (50%) 4.0Trisodium Phosphate (anhydrous), TSP 1.6Water 71.4

100.0

Dissolve TSP and sodium silicate In water. Slowly add sodium hydroxide. Thenadd TRITON H-66 followed by TRITON XL-SON. Mix until clear.

(1) Ethylenediaminetetraacetic add, tetrasodium salt (100% basis)(2) Supplied by Lucent

DETERQ.DOC, WSB. Ufll/95Printed 12/U/W, 1:27 PM

AR300290

MemorandumManagement

To: Eastern Diversified Metals- FFS File (N2111.00.01)855 Springdale Drive

From: Doug Shenk and Gary Emmanuel Exton, PA 19341Date: 15 December 1997Subject: DC Graphite Arc Melter Technology Conference Call

On 11 December 1997, a conference call was conducted with Ken Wittle ofElectro-Pyrolysis, Inc. (EPI) to review the potential applicability of DCGraphite Arc Melter Technology (AMI) at the Eastern Diversified Metals(EDM) Site in Hometown, Pennsylvania. Those who took part in theconference call are as follows:• Ken Wittle (EFI);• Valdisjurka (Lucent);• Walter Boyhan (WR Boyhan);• Gary Emmanuel (ERM); and• Doug Shenk (ERM).

Although AMI is an interesting technology, it does not appear well\. suited for the EDM site because of high electrical costs, large quantities of

residuals (e.g. coke like char, vitrified slag, hydrochloric acid). Inaddition there would be potentially significant permitting obstacles.Furthermore, public acceptance of AMI, which has yet to be used on alarge scale or on plastics, is uncertain.

Discussion Items

The call began with a review of (he pile characteristics and an explanationof the Focused Feasibility Study currently underway.

Ken described the AMI as high temperature (up to 5,000 °Qpyrolitic/vitrification process whereby the waste material is placed intothe high temperature bath of inorganic/metallic material in which theorganic portion of the waste disassociates. The AMT operates in areducing atmosphere which limits the amount of off gassing as comparedto incinerators. He noted that the Pennsylvania Department ofEnvironmental Protection does not differentiate Arc Melters fromIncinerators with regards to permitting and they've had some difficultieswith PADEP in permitting. Because of the PCBs and Pb in the fluffmaterial, TSCA/RCRA permitting would be required in addition to thePADEP permit (except for the Site's CERCLA status).

AR30029I

P A G E 2

The AMT process would be able to treat all of the pile components, somesizing of material may be required to optimize the feed process (8 to 10inches for screw feeding). Ken is confident that the AMT process wouldsufficiently destroy the PCB and Fb characteristics from the pile materialWhen questioned on the potential for generating dioxins in the process,he stated that the probability would be less than with conventionalincineration, but would make no assurances that dioxins would not be abyproduct of the process. Some metals will be recoverable as a separate .phase. A slag will result from silica-based materials. The aluminum willprobably be incorporated into this slag and not be recoverable. Kenindicates that copper may be recovered as a separate phase, but possiblynot in metallic form.

The AMT equipment is manufactured and supported in the US. Fiveunits are in operation in the US, the largest of which has a capacity of 750Ibs/hr. This unit is scheduled for shut down in the near future.

Tne AMT process could be designed to treat material at a rate of up to3,000 Ibs/hr. A unit of this capacity has not yet been built in the US. EFIindicates the units are capable of essentially continuous operation. Kensuggests that five such units operating in parallel would be required totreat the entire pile (debris, trash and fluff) of approximately 235,000,000pounds in five years.

The energy usage for the AMT is approximately 0.75 kW-hr/lb. Thisamounts to over 175,000,000 kW-hrs, at a cost of about $17,500,000 for thecost of power alone. Ken suggests it may be possible to recover andpurify hydrogen from the off-gas of the AMT, and direct it to a gasturbine or other prime-mover to generate a portion of the power needed.

During pyrolysis the carbon present in the PE and PVC will be reduced toa coke-like char, weighing approximately 60,000/000 pounds. It is notknown if this material has any commercial value, or will have to bedisposed of as a waste.

Pyrolysis of the FVC will generate about 0.5 Ibs of HO for every pound ofPVC, or about 37,500,000 pounds. Ken suggests it might be possible torecover and purify the HC1 for sale. If there is no market for the HCL itwill have to be neutralized with caustic or lime, generating about60,000,000 pounds of sodium chloride or calcium chloride, respectively. Itis unlikely this material would have any commercial value.

AR300292

MemorandumManagement

To: Valjurka ; 855 Springdale Drive"•>-. •;/ '•"••-'•' Extcix, PA 19341

From: David Steele (610)52«500rrom* " (610) 524-7796 (fax)

Date: 17 December 1997

Subject: Meetings with Landfill Representatives

ERM met with representatives of two landfill Facilities on 11 and 12December to discuss issues related to the disposal of EDM material for theFFS evaluations. Trie following is a synopsis of these discussions.

ENVIROSOURCE

On 11 December 1997, ERM met with Jon Gerhart of EnviroSource, Inc., acompany operating several RCRA treatment and disposal facilities.EnviroSource's facility in Oregon, Ohio received miscellaneous debrisfrom EDM in 1992. ERM was represented by David Steele/ GaryEmmanuel and Doug Shenk. The purpose of the meeting was to reviewissues relating to waste classification of fluff in the EDM pile and todiscuss EnviroSource facilities that might present advantages for disposalof EDM materials. The following is a synopsis of the main subjects andpoints of the meeting.

1 " " - ' " ; ' •

1. RCRA and TSCA Facilities

There is no physical difference between RCRA and TSCA facilities. Thecontrolling factor for disposal of TSCA waste is if the state has granted aTSCA acceptance letter to the facility. This usually depends on eachstate's willingness to accept TSCA waste. EnviroSource's Idaho facility isTSCA; their Ohio facility is RCRA only.

2. Debris versus Non Debris ' :

Any shipment where 51% of the material is greater than 2 3/8 inches indimension is considered debris. Debris may be treated as opposed tostabilized. Treatment is only required to meet a performance standard ofreducing the toxicity of the material. Treatment may be performed bymacroencapsulation (4 foot cubes) or nucroencapsulation (sprayingparticles in bag shaker). Both use a pozzolanic material. Macro isrequired for larger materials like pipes, with open space and is about four

AR300293

PAGE 2

times as expensive as micro. Treated characteristic debris cannot be de-characterized and must be disposed in a Class C facility. ->

Finer, non-debris sized material requires stabilization. The performancestandard is to meet the Land Disposal Restriction level (0.37 mg/L forlead) if the waste is a listed waste, or to get below the characteristic level(5 mg/L lead) if the waste is hazardous by characteristic In the formercase the stabilized material must go to a Class C facility; de-characterizedwaste may go to a Class D facility.

3. Underlying Hazardous Characteristic (UHC)

These new regulations (Phase IV) are scheduled for the first quarter of1998. They may be applied only to process waste rather thancontaminated media. The intent of UHC classification is to ensure thateach TCLP-regulated constituent is treated to meet the applicable LDR,even if the constituent isn't at characteristic levels. Thus, if only lead rails,it may be required to also treat to LDRs for other metals, etc. This is notcurrently applied to D004 through DOll-coded wastes.

4. PCB Testing

Non-TSCA facilities would typically require testing at 250 to 300 CYintervals, and more frequently when PCBs are greater than 30 ppm. Thesefacilities may set practical acceptance limits at 45 ppm to provide for amargin of error to avoid violations of TSCA. The facilities typicallyrequire 8080 analysis for PCBs. Alternatives may be proposed, but mustbe verified and accepted by facility and state. . .

5. EnviroSource Facilities

We discussed two of EnviroSource's facilities, one in Ohio and one in.Idaho. The Ohio facility takes RCRA only waste, including debris in smallloads. This facility has a small capacity and can receive waste by railStabilization can be performed at the facility. Cost is about $185/tonincluding delivery and stabilization.

The Idaho facility takes RCRA and TSCA waste and can receive by railThis facility has a customized transfer building for unloading rail cars.Stabilization can be performed at the facility. Cost is about $200/tonincluding delivery and stabilization for RCRA and/or TSCA. Cost forstabilized materials is $160/ton (would only ship TSCA waste this way).

AR300291*

P A GE 3

Waste bulking from stabilization is typically 5 to 7%.

6. TSCA Competitors

These include Chemical Waste Management with Model City, NY andEmelle, AL; US Ecology with a facility in NV and EQ with its facility in theDetroit, MI area. EQ can-only take RCRA px TSCA (it could take de-characterized RCRA if TSCA).

PINE GROVE LANDFILL

On 12 December 1997, ERM met with Tim Kerchinski of Pine GroveLandfill, a Pennsylvania Residual Waste landfill in western Schuylkill -County. ERM was represented by David Steele, Gary Emmanuel andDoug Shenk. The purpose of the meeting was to review issues relating toacceptance of fluff and debris from EDM at Pine Grove. The following is asynopsis of the main subjects and points of the meeting.

f. PCB Characterization

Pine Grove will accept PCBs at less than 50 ppm. They typically set acutoff at 45 ppm with enhanced testing at over 40 ppm. Actual acceptancemay range as high as 49, but confirmation sampling would be required.Typical sampling intervals for lower (less than 40 ppm) concentrationmaterials would be about every 250 CY. The acceptance of this wastewould require a permit amendment PADEP would establish/approvesampling intervals and limits of PCBs to correlate to the intervals. Testingcould be performed following stabilization, but would reduce theallowable concentrations in proportion to the added mass of thestabilizers.

2. Use of Stabilized Fluff for Daily Cover

PADEP often suggests the use of alternate materials for daily cover, butputs each through a rigorous evaluation process. Each application costs$5,000 and is reviewed in our region by Bill Tamako's group in Wilkes-Barre. As provided in Chapter 273.232 of the Solid Waste regulations., thematerial must demonstrate equivalency with soil cover, with regard tonon-combustibility, geotechnical characteristics particle size (40% less than2mm), etc.

AR300295

P A G E 4

If approved by PADEP, Pine Grove would take some, although they don'tcurrently need a daily cover source. Limitations on their acceptancewould be stockpiling capacity and agency requirements for stockpilemaintenance. Pine Grove currently uses about 300 to 400 tons of soil perday (250 to 300 CY). This may as much as double in the next five yearswith a landfill expansion. Pine Grove would charge for acceptance of thismaterial, possibly offering as much as a 40% discount off typical wastedisposal rates. They may have some hesitation with accepting chipped .wire for this purpose, as they had experienced problems with clogging ofdecontamination pad spray nozzles and had difficulty cleaning truck tires.

3. Cost

Rates would be expected to vary from $40/ton delivered for non debris; to$50 per ton delivered for debris. Pine Grove would be able toship/receive as much as 1,000 tons per day. They have recently taken in60,000 tons of material form C&D in one season.

AR300296TOTflL P.23

EnvironmentalResourcesManagement

855 Springdale DriveExton, Pennsylvania 19341(610) 524-3500(610) 524-7335 (fax)

24 March 1998 ' ' http://www.erm.comReference: N2111.00.01

Mr. Steven J. Donohue (3HW22)Western Pennsylvania Remedial SectionU.S. Environmental Protection Agency __841 Chestnut Building 17T7TV/fPhiladelphia, Pennsylvania 19107 UKM.

DearSteve:

The meeting on 3 February 1998 provided Lucent Technologies, Inc. andERM with the opportunity to present the findings to date ofinvestigations into the feasibility of the remedial alternatives identifiedin the Focused Feasibility Study Work Plan for the fluff pile at theEastern Diversified Metals (EDM) Site. The intent of this letter is toprovide further detail of the findings to date with regard to Alternative3, Separation and Resource Recovery/Disposal. In particular, thefindings with respect to the feasibility of metals recovery andpolyethylene (PE) separation for resource recovery are significant andwill be the focus of this letter.

Approach to Evaluation of Alternative 3 Feasibility

Focused Feasibility Study (FFS) efforts have been directed thus far in thefollowing areas:

1. Assessing the acceptability of separated PE and/ or metals, i.e.,identifying potential interested parties and the economics of itsdisposition;

2. Reviewing PE separation processes and how they would fitwith/ impact the processes for disposition of the other 70 to 80percent of the pile; and ; - ;•<-..•--;-•

3. Identifying the costs that would be associated with separation andhandling of the PE and/ or metals, including the costs for additionalactivities required for handling the balance of the fluff pile.

AR300297

EnvironmentalMr. Steven Donohue ResourcesN2111.00.01 Management24 March 1998Page 2

The Acceptability of EDM Metals

Discussions with vendors of metals separation technology, includingSevenson Environmental Services, Inc. (Sevenson) and PhilipEnvironmental Services, Inc. (Philip), have indicated that there would begreat difficulty in removing aluminum from the EDM fluff and a limitedmarket for it given its oxidized state. Copper recovery on the other handappears much more likely to be a viable part of the remedy for the pileremoval. The most promising processes for practical separation ofcopper for recycling are dry processes requiring some drying of the rawfluff prior to processing. Sevenson is approximately mid-way throughthe evaluation of an Inertial Density Separation process described in our 17February 1998 letter. The results of Sevenson's work will be a principalsource of information for the FFS in regards to metals separation.

The Acceptability of EDM Polyethylene

The acceptability of PE from the EDM Site is seriously impacted by thepresence of PCBs at concentrations averaging approximately 25 ppm(per the results of the Boyhan/New Jersey Institute of Technology (NJTT)washing study). As has been presented in the report on the washingstudy by Boyhan and NJTT, practical removal of the PCBs from EDM PEcannot be achieved. As a result the recent focus of the FFS efforts hasbeen on resource recovery, i.e., as a fuel for energy production.

The most viable candidates to receive EDM PE are waste-to-energyfacilities. These facilities take refuse and burn it for steam production.Other candidates conceivably include electric utility power plants andco-generation plants. LAW Environmental contacted the nearby PantherCreek co-generation facility in January 1997. They were informed thatPanther Creek cannot accept material from EDM because of the limitsthey have with regard to what they can burn (i.e., they are prohibitedfrom burning wastes). Public utilities face similar restrictions, real orperceived, in as much as the PE is a waste stream from a Superfund site.

Waste-to-energy facilities are in the business of burning wastes, and thusthe EDM PE is more readily acceptable to them. The separated PE is anattractive material given its heat content (high BTUs per pound) relativeto other wastes that these facilities handle. Other wastes received withhigh fuel value are routinely blended with low BTU wastes to achievedesired heat content and processing rates. In spite of the high BTU valueof the separated PE, waste-to-energy facilities will still charge Lucent to rt Q

EnvironmentalMr. Steven Donohue ResourcesN2111.00.01 Management24 March 1998 '" 'i $ *"£Page 3

accept this material. A discount can, however, be obtained for disposalof high fuel value wastes. Based on discussions with the LancasterCounty Solid Waste Authority/ this discount is anticipated to be on theorder of $10 to $20 per ton. V

Based on industry contacts made thus far/ a discounted tipping fee forthe separated PE at a waste-to-energy facility can be expected to be in arange from $50 to $60 per ton. The best cost found from such a facility.thus far is therefore equal to or marginally above available tipping feesfor disposal of a stabilized (de-characterized) waste at a residual wastelandfills (e.g., $40-$50 per ton), which are the competitors of the waste- ;to-energy facilities. .

Polyethylene Separation Costs

PE separation processes were tested by The Macleod Group (Macleod)and Philip. The effectiveness of their processes, in terms of the amountof PE recovered, is very similar. The extrapolation of their testing results

. , to full scale processes at the EDM Site has been explored withrepresentatives of those two firms to identify capital and operationscosts, process rates, associated waste generation/ and impacts onprocessing the other pile components for disposal or recycling.

The benefits of PE separation are a reduction in the total volume oflandfill disposal from the project and the energy that can be produced.However, these benefits are not economically viable. Using stabilizationand disposal (without PE separation) as a baseline for comparison, theadded costs for PE separation include the following:

1. The difference in disposal cost (tipping fee at the receiving facility)between a landfill and a waste-to-energy facility;

2. Separation equipment capital costs; :

3. Site preparation costs/ including protective building and stagingareas;

4. Separation equipment operations and maintenance costs;

- 5. Electric power usage; V' * . ' • • . - , . - •

6. Costs for additional labor to operate the PE separation processes; „AR300299

EnvironmentalMr. Steven Donohue ResourcesN2111.00.01 Management24 March 1998Page 4

7. Waste water treatment costs; and

8. Costs for drying and other handling measures for the remaining pileconstituents made necessary as a result of the wet PE separationprocess.

The Macleod and Philip (Waxman) processes are similar in terms of thecapital expenses. Representatives of both firms recommended systems. with throughput in the range of 5,000 to 10,000 Ibs. per hour. The capitalexpenses for systems equipment are in the range of $500,000 to $750,000for a 5,000 lbs./hr. system and $800,000 to $1,200,000 for a 10,000 lbs./hr.system. Site preparation costs, including a protective building andstaging areas, would add further to the capital costs for PE separation.

Operations and maintenance costs may also be expected to be similar forthe Macleod and Philip systems. Equipment O&M, excluding energycosts, are expected to be approximately $60,000 and $80,000 per year for5,000 lbs./hr. and 10,000 lbs./hr. systems, respectively. At theseprocessing rates and capital costs, 24-hour per day operations would beanticipated. Electrical power usage has not been identified for the PEseparation equipment or associated processes (e.g., materials drying orwaste water treatment), but would add further to the above operationsand maintenance costs.

Both the Macleod and Philip PE separation processes would require theaddition of two laborer/ operators at a minimum. An analysis has beenmade of the labor costs associated with PE separation. Using ERM'scurrent estimate for the mass of the pile, 185,000 tons, and assuming theseparation process goes on 24 hours per day, seven days a week/ for 90percent of the year/ it will take 9.4 years to process the pile at 5,000 Ibs.per hour and 4.7 years to process it at 10,000 Ibs. per hour. The labor costfor two men is calculated by multiplying the hourly rate for each by thenumber of hours required to process the pile mass. At a conservativelylow average labor rate of $40 per hour/ laborer/ operator costs are $3.3million and $6.6 million for 10,000 Ibs./hr. and 5,000 lbs./hr. systemsrespectively.

Macleod and Philip differ on the amount of waste water that would begenerated from system blowdown requiring treatment Philip believesthat a system in this throughput range would generate as much as 150 .gallons per minute of waste water requiring treatment in order that thequality/ characteristics of the water used in the floatation bath remains A .AR300300

EnvironmentalMr. Steven Donohue ResourcesN2111.00.01 Management24 March 1998 - .Page 5

satisfactory for the separation process. In contrast, Gary Volger,formerly of Macleod, suggested in a recent conversation that processingthe fluff would produce about three gallons per minute of drag-out asthe pile constituents are removed from the flotation water system. Hefelt that this "blowdown" and the subsequent fresh water make-upwould be sufficient to maintain the necessary quality of the flotationwater. We have serious reservations about the adequacy of adding only3 gpm make-up water when processing portions of the pile with highclay and/or silt content. Philip has suggested that the capital costs forwaste water treatment facilities would be on the same order ofmagnitude as the separation equipment We believe that a reasonableblow-down rate will probably fall somewhere between three and 150gallons per minute. However/ this could only be confirmed after adetailed study of the process.

Both the Macleod and Philip systems are wet systems. Therefore, therewould also be some added cost for drying the other pile materials inpreparation for copper recovery, stabilization and/or loading for landfilldisposal. Draining and evaporative drying would likely be adequate,requiring a staging area and time, except for periods of rain and highhumidity and winter months when freezing and low evaporation rateswould inhibit drying.

The attached tables have been developed to summarize the costs toseparate PE from the balance of the pile at EDM. As shown in thesetables, the cost per ton of PE processed has been computed forprocessing rates of 5/000 and 10,000 Ibs. per hour using the percentagesof PE recovered by LAW/Lockhead, Macleod, Philip and Boyhan/NJU*Clearly the more PE recovered by separation, the lower the cost will befor each pound/ ton of PE recovered. To present the most optimisticpicture of PE separation costs, the highest estimated PE content of thepile (as determined by LAW/Lockhead) of 30.5% on a dry basis has beenused. ' ' • " . • - . • • • - " ' - ; ' • • > ' • ' ' • . ' ' • '

• • . . • • ' , ; - . . . ! - . . . . . - " f / . .'.-••. . . . .As you will note in the attached tables, the labor cost alone comes toalmost $80 per ton at the 10,000 Ibs. per hour processing rate and $160per ton at the 5,000 Ibs. per hour rate. Thus, the labor costs alone exceedthe most pessimistic estimate of the cost to dispose of fluff as a stabilized,non-characteristic residual waste. Adding in the other costs identifiedthus far, and using the optimistic end of the range for each item, the totalcost for separation and resource recovery of PE exceeds the cost forstabilization and disposal (landfill) of the same mass of material by a

AR300301

EnvironmentalMr. Steven Donohue ResourcesN2111.00.01 Management24 March 1998Page 6

factor of at least two under cost conservative assumptions, assumingtransportation costs to be equal.

Other Factors/Impacts

The purity of the separated PE is a concern to receiving facilities. TheLancaster County Solid Waste Authority waste-to-energy facility haslimits on the quantity of chlorine that can be burned. The Authoritywould blend the separated PE with municipal and industrial wastes toachieve a combined heating value of approximately 10/000 BTU/ pound.The Authority has also indicated that they want the combined feed tocontain no more than 1% chlorine in order to meet air emissionsrequirements. Philip indicated that their process achieves 95 percentpurity in the PE separation and that the majority of the impurity in theEDM material would be polyvinyl-chloride (PVC), which is 50-60percent chlorine. Based on this estimate, the total chlorine content of theseparated PE would be 2-1/2% to 3%. Therefore/ the separated PE canonly be blended to make up 30 to 40 percent of the total incinerator feedstream. Tight quality control on the PE separation process would berequired to keep the PVC content within limits acceptable to thereceiving facility.

Analyses of separated PE and PVC have revealed that PCBs areconcentrated in the PVC/ with significantly lower levels in the PE.Removing PE from the pile material risks increasing the amount of pilematerial that demonstrates TSCA regulated levels.

Conclusions

As shown by a determination of the irreducible labor cost alone, PEseparation for resource recovery would add significantly to the cost ofthe Site remedy. Adding in the other costs identified thus far/ and usingthe optimistic end of the range for each item (i.e., the assumptions thatare the most favorable for PE separation), the total cost for separationand resource recovery of PE exceeds the cost for stabilization anddisposal (landfill) of the same mass of non-segregated fluff by a factor ofat least two under cost conservative assumptions.

Tied closely to the costs for separating PE from the pile is the timerequired for the separation processing. It will take from 2 to 5 timeslonger to remove the fluff pile with PE separation than to remove thepile with stabilization and disposal only. Hence, there are schedule

RR300302

EnvironmentalMr. Steven Donohue ResourcesN2111.00.01 Management24 March 1998 .' 'Page 7

impacts related to the additional time required for processing in additionto the capital, O&M and labor costs.

In light of the above, Lucent and ERM do not believe that PE separationis a viable part of the overall Site remedy. There appears to be little orno actual environmental benefit derived from incineration of 20-30percent of the pile, in lieu of disposal in a landfill, to justify the verysignificant additional time and costs involved.

Conversely, recovery of copper from the fluff pile for true recyclingappears to be potentially viable. Testing currently underway willprovide much of the information needed to complete an evaluation ofthis remedial technology for the FFS. Indications are that Sevenson'swork will provide real quantification of the value of recoverable EDMcopper. Further/ a process for copper recovery will have been fullyevaluated, providing recommended processing rates, capital equipmentO&M and labor costs, and recovery rates.

\j These are our initial findings. In light of these result with respect to theviability of PE separation, we intend to focus our attention/ movingforward, on exhausting sources with possible interest in separated PEwho might accept the material at no cost to Lucent or pay for thematerial (including transportation). We will ultimately present furtherevidence in the FFS that very significant cost and schedule impacts willbe experienced if PE separation is required as part of the Site remedy.

Should you have any questions in regards to the above, please feel freeto contact me or Val Jurka.

Sincerely, - ] ;

: Emmanuel, P.E.Proect Director

cc: Val JurkaWalter Boyhan

• Meg MustardMimi BoxwellDavid SteeleDouglas Shenk

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION IB

841 Chestnut BuildingPhiladelphia, Pennsylvania 19107

Office of Superfund Direct Dial (215) 56S-3215Stoven J. Donohue Mall Code (3HW22)

October 15, 1997

Valdis Jurka, Project ManagerLucent Technologies131 Morristown RoadBasking Ridge, NJ 07920

Re: Eastern Diversified MetalsFFS Work Plan

Dear Val:

The U.S. Environmental Protection Agency ("EPA") has'received and reviewed the August 22, 1997 Focused FeasibilityStudy Work Plan for Operable Unit 3 at the Eastern DiversifiedMetals Site ("Work Plan") . The Work Plan was submitted by DavidP. Steele of Environmental Resources Management, Inc. ("ERM") onbehalf of Lucent Technologies, Inc. The Work Plan outlines anapproach to investigate certain alternatives for the remediationof the main wire chopping fluff pile at the Site. Much of thescope of the proposed Focused Feasibility Study has beendiscussed and agreed upon during meetings and in correspondenceconducted while the EPA Administrative Order on Consent DocketNo. ITI-97-89-DC was being perfected'.

EPA has the following comments on the FFS Work plan:

Section 1.3.2.2 In the last sentence of the third paragraph itis unclear what is meant or how it was determined that, the"...quality of the recoverable PVC...varied significantly acrossthe Site." Please add text to clarify this paragraph.

Section 1.4 The text of the fifth paragraph begins by statingthat, "The fact that lead becomes a non-issue with the separated,recyclable fluff fractions is probably only of academic interestfor EDM, since the material also contains PCB". EPA believes thetotal and leachable lead concentration, as well as the PCBcontent, of the separated PE will be very important to theproj ect.

AR300306

According to Table 1-2 in the Work Plan the PE represents a rangeof between 20.2% to 33.29% of the pile. If this material isnon-hazardous for lead it could be land filled withoutstabilization or possibly be used for resource recovery by awaste to energy facility.

Section 2.2 Enclosed please find a copy of a September 17, 1997letter to me from Meg Mustard of the Pennsylvania Department ofEnvironmental Protection. 'Among other concerns, the letterprovides a preliminary list;of the Commonwealth Pennsylvania'sapplicable or relevant and appropriate regulations which shouldbe investigated and discussed in the FFS.

Additional guidance on the implication of the TSCA regulations onthe remedial alternatives under consideration has been requestedand will be forwarded under separate correspondence.

Disposal of debris encountered in the fluff pile will have tocomply with 40 CFR 268.2 and 40 CFR 268.45.

Section 3.1 EPA believes a data gap may exists relative tofused fluff boulders ("fused fluff") at the Site. The majorityof the large fused fluff would likely be screened out along withthe debris fraction in any processing of the pile. This has thepotential to account for a significant volume/mass of the pileand of the debris fraction. EPA recommends that the fused fluffbe characterized for disposal options during the FFS. ToxicityCharacteristic Leaching Procedure testing, and possibly aSynthetic Leaching Procedures testing, should be done on thefused fluff. The leaching testing and analysis for the totalSite contaminants of concern should be performed on arepresentative sample of the fused fluff to determine disposaloptions.

It may be impracticable to solidify large pieces of fused fluffalong with PVC or other loose fluff fractions. The fused fluffis already solidified into boulders of varying size.Purportedly, the fluff may have fuse into boulders when it wasplaced into containers or in a pile soon after chopping and anexothermic reaction occurred with the aluminum in the fluff.

EPA believes further discussion and consideration of the disposalof the fused fluff is warranted. EPA also believes disposal forother large debris including, metal and wood, require furtherinvestigation and discussion to determine disposal options forthis material.

AR300307

The FFS Work Plan is approved contingent upon the abovecomments being addressed in the finalized Work Plan. EPA willprovide additional input on the September 26, 1997 Memorandumfrom David Steele and Gary Emmanuel of ERM to Steve Donohue andWinston Lue of EPA following the review of the disposalscenarios. If you have any questions please feel free to contactme at the number above.

Sincerely,

Steven J. DonohueRemedial Project Manager

enclosure

cc: Meg Mustard, PADERDavid P. Steele, ERMJohn Lombardo, USAGEAmir Kouhestani, USAGE

AR300308

Pennsylvania Department of Environmental Protection

4530 Bath PikeBethlehem, PA 18017-9074

September 17,1997

Bethlehem District Office (610) 861 -2070FAX (610)861-2072

Mr. Steve Donohue (3HW22)Remedial Project ManagerU.S. EPA -Region III841 Chestnut BuildingPhiladelphia, PA 19107 .

Re: OU3 Focused Feasibility Study Work PlanAugust 22, 1997Eastern Diversified Metals NPL SiteRush Township, Schuylkill County

Dear Steve:

The Department of Environmental Protection ("Department") has reviewed the August 22, 1 997Operable Unit 3 Focused Feasibility Study Work Plan prepared by ERM for the EasternDiversified Metals Superfund Site. The following comments result from the Department'sreview of this document:

1. Page 15, Section 2.2, Identification of Potential ARARs. The preliminary list of ARARsshould include: 1) The Pennsylvania Solid Waste Management Act (Act 97) and ThePennsylvania Hazardous Waste Regulations - This Act and regulations set the standardsand requirements for storage, treatment, transportation and disposal of hazardous wastes inPennsylvania. 2) The Pennsylvania Land Recycling and Environmental RemediationStandards Act (Act 2 of July 18, 1995) and Regulations (2$ Pa, Code Chapter 250. oAdministration of Land Recycling Program) - This Act and the accompanying regulations oestablish the standards for environmental remediations in Pennsylvania. 3) ThePennsylvania Clean Streams Law and Regulations - This Law and regulations set thestandards and requirements for erosion control, water quality and alt discharges from theremediation project to the waters of the Commonwealth. 4) The Pennsylvania AirPollution Control Act and Regulations - This Act and regulations set the standards andrequirements governing air quality and emissions from a remediation project inPennsylvania.

An Equal Opportunity/Affirmative Action Employer http://www:dep.state.pa.us Printed on Recycled Paper 1 tl

Mr. Steven Donohue 2 September 17,1997

2. Page 24, Section 3.2.5, Alternate 5 - Landfill Daily Cover. Which landfills were contacted?Landfill contact sheets should be included as an attachment. What are the specific reasonsthat this material is not suitable for use as a cover material? Which daily coverperformance standards doesn't it meet? Could the fluff material be mixed with other dailycover materials to increase the viability of this alternative?

3. The Department requests that they be kept informed of all meetings and issues involvedwith this project and that two (2) copies of all OU3 reports be sent to Meg Mustard at theabove address and one (1) copy to the following:

Mr. Tom UngPADEPRachel Carson State Office Building14th FloorP.O. Box 8471Harrisburg, PA 17105-8471

If you have any questions concerning these comments, please feel free to contact me at theabove-listed number.

Sincerely,

Meg MustardProject OfficerHazardous Sites Cleanup Section

OcoOCDCOor

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION HI

, 841 Chestnut BuildingPhiladelphia, Pennsylvania 19107 "

Office of Superfund Direct Dial (215)666-3215Steven J. Donohue : Mail Code (3HW22)

October 23, 1997

Valdis Jurka, Project Manager-;Lucent Technologies v f •„ • ' --475 South Street ; ^ ,/ i -Morristown, NJ 07962-1976; ._ , • •- : •

Re: Eastern Diversified Metals .FFS Treatability Study .-.^

Dear Val:

The U.S. Environmental Protection Agency ("EPA") hasreceived and reviewed the October 3, 1997 PolychlorinatedBiphenyl Laboratory Studies Fractionation of Composite FluffSamples and Washing of Polyethylene ("Treatability Study") forOperable Unit 3 at the Eastern Diversified Metals Site ("Site") .The Treatability Study was submitted on behalf of LucentTechnologies by W&R Boyhan Associates, Inc and the New JerseyInstitute of Technologies. The Treatability Study both validatesprevious investigations and provides new information on theimpact of polychlorinated biphenyl ("FOB") detections in thefluff and fluff fractions: EPA has the following comments on theTreatability Study: • i * - . r 'Section 1.1 This section states that, "...it is hypothesized thatthe presence of the PCBs at the EDM site may be due to theprocessing of cable from U.S. Naval ships." While EPA is awareof the studies that have found high concentrations of PCB in wirefrom naval ships, EPA is not aware of any documentation in theSite file that would indicate wire from naval ships was choppedand disposed of at the Site.

As indicated in comments presented on the FFS work Plan EPA •believes that a representative sample of fused fluff should beretrieved from the remaining composite samples and analyzed byToxicity Characteristic Leaching Procedure ("TCLP") , SyntheticPrecipitation Leaching Procedure ("SPLP") and for total metalsand PCBs.

ftR3003ll

Section 1.2.1 It would be helpful to note the size in inches andmillimeters that corresponds to the mesh sizes stated here.

Section 2.4.1 This section states that a significant portion ofthe separated dried PE sank when placed back in water followingthe initial water floatation step. It is not clear if the weightof material which sank in the second and third stage floatationsteps was recorded. Table 7 appears to present information onsecond and third stage PE sinks for the F-6 sample but no othersample.

Section 3.8 Analysis of the MacLoed PE samples for PCB should becompleted and reported to EPA by the end of October.

Section 5.1.3 EPA believes that valuable information might beobtained by sieving the mud fraction in different mesh sizes inan effort to maximize the recovery of metal in one mud fraction.It appears there is significantly more copper in the coarse mudfraction than in the fine mud fraction.

Section 6.2 EPA agrees that it would" be worthwhile to furtherexplore maximizing the capture of PE if it is determined thatthere are resource recovery/waste to energy vendors interested inthis material.

Table 1 through 6 These tables should be qualified to definewhat PE,1 and PE,2 and PVC,1 through 4 represent.

It is not clear.what is meant by the note" on Table 6. Pleaseprovide further information on the note.

If you have any questions please feel free to contact me atthe number above.

Sincerely,

Steven J. DonohueRemedial Project Manager

cc: Meg Mustard, PADERDavid P. Steele, ERMJohn Lombardo, USAGE ,Amir Kouhestani, USAGE

AR3003I2

EnvironmentalResourcesManagement

'»855 Springdale Drive

-XT , innT Exton, Pennsylvania 193414 November 1997 (610) 524-3500Reference: N2111.00.01 (610)524-7335 (fax)

http://www.erm.com

Steven DonohueWestern Pennsylvania SectionHazardous Waste Management DivisionU.S. Environmental Protection Agency841 Chestnut BuildingPhiladelphia, PA 19107 f r?T> A X

r ;J11\JYLDear Steve:

Lucent Technologies Inc. (Lucent) and Environmental Resource Management(ERM) have received your letter of 15 October 1997 regarding U.S. :Environmental Protection Agency (EPA) and Pennsylvania Department ofEnvironmental Protection (PADEP) comments on the Focused Feasibility StudyWork Plan for the Operable Unit 3 (22 August 1997). This letter providesresponses to EPA's comments and those in the enclosed letter from PADEP (17September 1997). This letter is intended to serve as an amendment to the FFSWork Plan and be incorporated as part of the Work Plan., . . i . • • ..

USEPA Comments

Section 1.3.2.2 - EPA requests clarification of how it was determined that the*.. .quality of the recoverable PVC... varied significantly across the Site/'

This statement was meant to summarize the conclusions of the MacLeod GroupResource Recovery, Inc. from the recycling treatability study performed on theSite in November, 1995. Section 1.3.2.2 is hereby amended to include thefollowing discussion: : • . ; ^

On the pages 20 to 21 in the Conclusions: General section of MacLeod's reportit was stated "Because of the nature and periodicity over which the materialwas generated, we feel that it would be prudent to approach the pile with theconcept of flexibility.. .include the ability to ... choose between capture of thePVC for resale, or encapsulate, as dictated by the on-site quality and quantityof the material." Due to material contamination with other substances,MacLeod also stated on page 20 that "...the general opinion was that it ma notbe economically feasible to recapture this particular stream of PVC at the site."

:: Section 1.4 - In response to the fifth paragraph, EPA states that the total and leachablehad content of the separated PE will be very important to the project.

AR3003I3

^ . EnvironmentalSteven Donohue ResourcesN2111.00.01 Management4 November 1997Page 2

It is agreed that the lead and PCB contents are both important to the ,disposition of the PE. Both parameters will be fully evaluated in the FFS asotherwise noted in the Work Plan.

EPA notes that Table 1-2 shows a range of 20.2% to 33.28% ofPE in the pile and thatif the material is non-hazardous for lead it could be landfilkd without stabilization orused for waste to energy resource recovery. ,

Lucent and ERM agree with this statement and these options will be fullyevaluated in performing the FFS.

Section 2.2 - EPA references correspondence from PADEP on the preliminary list ofARARs from the Commonwealth of Pennsylvania, which should be investigated anddiscussed in the FFS.

See response to PADEP Comments below.

EPA notes that additional guidance on the implication of TSCA regulations onremedial alternative will be forwarded under separate cover.

This guidance will be used in performing the FFS when received.>

EPA notes that disposal of debris encountered in the fluff pik will have to comply with40 CFR 268.2 and 40 CFR 268.45.

Section 2.2 of the Work Plan is hereby amended to include these potentialARARs. Non-fluff debris will require characterization for disposal purposes todetermine if it will be considered hazardous debris or residual waste. Wheredebris is determined to be hazardous, the disposal of that material mustcomply with Land Disposal Restrictions and the Debris Rule.

Section 3.2 - EPA notes that additional information is needed on fused fluff or "fluffboulders" because fused fluff has the potential for representing a large portion of the pileand the size of the boulders would require separate handling. The fused fluff should becharacterized and provisions for its handling evaluated. Additional discussion shouldalso be provided on the disposal of the fused fluff and of other large debris.

Section 3.1 is hereby amended to note that the FFS will provide for evaluationof contingencies for the handling of the fused fluff and debris. The FFS reportwill also outline tasks required during the Remedial Design to determinespecific detailed disposition and handling of these materials. In the FFS effortthe impact of the fused fluff and other large debris will be carefully considered \ Jin evaluation of the alternatives.

HR3003IU

EnvironmentalSteven Donohue ResourcesN2111.00.01 Management4 November 1997 $",-.•$'Page 3

PADEP Comments

Page 15, Section 2.2, Identification of Potential ARARs. PADEP has noted that thepreliminary list of ARARs should include 1) The Pennsylvania Solid WasteManagemen t Act and The Pennsylvania Hazardous Waste Regulations, 2) ThePennsylvania Land Recycling and Environmental Remediation Standards Ac.andRegulations, 3) The Pennsylvania Clean Streams Law and Regulations, and 4) ThePennsylvania Air Pollution Control Act and Regulations.

Section 2.2 is hereby amended to list these items as potential ARARs for theremediation of OU3.

Page 24, Section 3.2.5, Alternate 5 - Landfill Daily Caver. PADEP requestedadditional information on which landfills were contacted about the use of fluff as dailycover on a hazardous waste landfill and why the fluff would not be suitable.

The FFS report will provide a discussion about the feasibility of this alternativeand will provide documentation of facilities contacted and performancerequirements for daily cover. We will consult with PADEP during thisevaluation.

PADEP requests that it be kept informed of meetings and issues of the project and thattwo copies of all reports be sent to Meg Mustard and one copy to Tom ling.

PADEP will be informed of meetings and issues of the project and copies ofreports will be submitted as requested.

Please contact me or Val Jurka with any questions or comments.

Sincerely, ' .

David P. SteeleProject Manager

DPS "• . '•- ••-.. ; , ; r-, •:. - .-= .. •' , ' . .enclosures: EPA Correspondence of 15 October 1997ca M. Mustard, PADEP . ,

T.Ung,PADEP : vV. Jurka, LucentW. Boyhan, WRBG. Emmanuel, ERM

D'Shenk'ERM AR3003 I 5

n (\CUIUIH in tfio soo JtJtfl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION HI

$41 Chestnut BuildingPhiladelphia, Pennsylvania 19107

Office of Suparfund Direct Dial (215) 565-3215Steven J. Donohue Mail Code (3HW22)

October 15, 1997Valdis Jurka, Project ManagerLucent Technologies131 Morristown RoadBasking Ridge, NJ 07920

Re: Eastern Diversified MetalsFFS work Plan

Dear Val:

The U.S. Environmental Protection Agency ("EPA") hasreceived and reviewed ths August 22, 1997 Focused FeasibilityStudy Work Plan for Operable Unit 3 at the Eastern DiversifiedMetals Site ("Work Plan") . The Work Plan was submitted by DavidP.- Steele of Environmental Resources Management, Inc. {"ERM") onbehalf of Lucent Technologies, Inc. The Work Plan outlines anapproach to investigate certain alternatives for the remediationof the main wire chopping fluff pile at the Site. Much of thescope of the proposed Focused Feasibility Study has beendiscussed and agreed upon during meetings and in correspondenceconducted while the EPA Administrative Order on Consent DocketNo. III-97-89-DC was being perfected.

EPA has the following comments on the FFS Work plan:

Section 1.3.2.2 In the last sentence of tha third paragraph itis unclear what is meant or how it was determined that the"...quality of the recoverable PVC...varied significantly acrossthe site." Please add text to clarify this paragraph.

Section 1.4 The text of the fifth paragraph begins by statingthat, "The fact that lead becomes a non-issue with tha separated,recyclable fluff fractions is probably only of academic interestfor EDM, since the material also contains PCB". EPA believes thetotal and leachable lead concentration, as well as the PCBcontent, of the separatee! PE will be very important to thepro j ect.

AR3003IS

According to Table 1-2 in the Work Plan the PE represents a rangeof between 20.2V to 33.29% of the pile. If this material isnon-hazardous for lead it could be land filled withoutstabilization or possibly be used for resource recovery by awaste to energy facility.

Section 2.2 Enclosed please find a copy of a September 17, 1997letter to me from Meg Mustard of the Pennsylvania Department ofEnvironmental Protection. Among other concerns, the letterprovides a preliminary list of the Commonwealth Pennsylvania'sapplicable or relevant and appropriate regulations which shouldbe investigated and discussed in the FFS.

Additional guidance oh the implication of the TSCA regulations onthe remedial alternatives under consideration has been requestedand will be forwarded under separate correspondence.

Disposal of debris encountered in the fluff pile will have tocomply with 40 CFR 268.2 and 40 CFR 268.45. ..........

Section 3.1 EPA believes a data gap may exists relative tofused fluff boulders ("fused fluff") at the Site. The majorityof the large fused fluff would likely be screened out along withthe debris fraction in any processing of the pile. This has thepotential to account for a significant volume/mass of the pileand of the debris fraction. EPA recommends that the fused fluffbe characterized for disposal options during the FFS. ToxicityCharacteristic Leaching Procedure testing, and possibly aSynthetic Leaching Procedures testing, should be done on thefused fluff. The leaching testing and analysis for the totalSite contaminants of concern should be performed on arepresentative sample of the fused fluff to determine disposaloptions.

It may be impracticable to solidify large pieces of fused fluffalong with PVC or other loose fluff fractions. The fused fluffis already solidified into boulders of varying size.Purportedly, the fluff may have fuse into boulders when it wasplaced into containers or in a pile soon after chopping and anexothermic reaction occurred with the aluminum in the fluff.

EPA believes further discussion and consideration of the disposalof the fused fluff is warranted. EPA also believes disposal forother large debris including, metal and wood, require furtherinvestigation and discussion to determine disposal options forthis material.

AR3003I7

trH KtuluN iii 215 bbfa JB01 P.04/06

The FFS Work Plan is approved contingent upon the abovecomments being addressed in the finalized Work Plan. EPA willprovide additional input on the September 26, 1997 Memorandumfrom David Steele and Gary Emmanuel of ERM to Steve Donohue andWinston Lue of EPA following the review of the disposalscenarios. If you have any questions please feel free to contactme at the number above.

Sincerely,

Steven J. DonohueRemedial Project Manager

enclosure

cc: Meg Mustard, PADERDavid P. steele, ERMJohn Lombardo, USAGEAmir Kouhestani/ USAGE

AR3Q03I3

Pennsylvania Department of Environmental Protection

Bethlehem, PA 18017-9074September 17,1997

Bethlehem District Office (610) 861-2070" • • • ' . ; F A X (610)861-2072

Mr. Steve Donohue (3HW22)Remedial Project Manager•U.S. EPA-Region III841 Chestnut BuildingPhiladelphia, PA 19107

Re: OU3 Focused Feasibility Study Work PlanAugust 22,1997

. : "Eastern Diversified Metals NPL SiteRush Township, Schuylkill County

, Dear Steve:

The Department of Environmental Protection ("Department") has reviewed the August 22, 1997Operable Unit 3 Focused Feasibility Study Work Plan prepared by ERM for the EasternDiversified Metals Superfund Site. The following comments result from the Department'sreview of this document:

I. Page IS, Section 2.2, Identification of Potential ARARs. The preliminary list of ARARsshould include: 1) The Pennsylvania Solid Waste Management Act (Act 97) and ThePennsylvania Hazardous Waste Regulations - This Act and regulations set the standardsand requirements for storage, treatment, transportation and disposal of hazardous wastes inPennsylvania. 2) The Pennsylvania Land Recycling and Environmental RemediationStandards Act (Act 2 of My 18. 1995) and Regulations (25 Pa. Code Chapter 250.Administration of Land Recycling Program) - This Act and the accompanying regulationsestablish the standards for environmental remediations in Pennsylvania. 3) ThePennsylvania Clean Streams Law and Regulations - Tills Law and regulations set thestandards and requirements for erosion control, water quality and all discharges from theremediation project to the waters of the Commonwealth. 4) The Pennsylvania Air

. Pollution Control Act and Regulations- This Act and regulations set the standards andrequirements governing air quality and emissions from a remediation project inPennsylvania.

An Equal Opportunay/Affimulfvt Action f npfnytr . hUp://*w*d«.-p »ufc.pa. us FrinmJ MI Recycled Paper

AR3003I9

. -*.,-*«• * .xo err, KCUiUN Iii ^D DbO Jldtfl P.06/06

Mr. Steven Donohue 2 September \ 7,1997

2. Page 24, Section 3.2.5; Alternate 5 • Landfill Daily Cover. Which landfills were contacted?Landfill contact sheets should be included as an attachment What are the specific reasonsthat this material is not suitable for use as a cover material? Which daily coverperformance standards doesn't it meet? Could the fluff material be mixed .with other dailycover materials to increase the viability of this alternative?

3. The Department requests that they be kept informed of all meetings and issues involvedwith this project and that two (2) copies of all OU3 reports be sent to Meg Mustard at theabove address and one (1) copy to the following:

Mr. Tom UngPADEPRachel Carson State Office Building14th FloorP.O. Box 8471Harrisburg, PA 17105-8471

If you have any questions concerning these comments, please feel free to contact me at theabove-listed number.

Sincerely,

Meg MustardProject OfficerHazardous Sites Cleanup Section

AR300320TOTflL P.06

EnvironmentalResourcesManagement

855 Springdale DriveExton, Pennsylvania 19341(610) 524-3500(610) 524-7335 (fax)

23 February 1998Reference: N2111.00.01 :

Mr. Steven J. Donohue (3HW22)Remedial Project ManagerUSEPA Region IHWestern Pennsylvania Remedial Section 171? IV >T841 Chestnut Building ' E.KJVIPhiladelphia, PA 19107

RE: Focused Feasibility StudyEastern Diversified Metals Site, Hometown, Pennsylvania

Dear Steve:

Enclosed please find a revised DRAFT outline for the Focused FeasibilityStudy (FFS) and the updated FFS Schedule. The DRAFT outline hasbeen changed to include a No Action Alternative in accordance withcomments from USEPA Legal Counsel during the 3 February 1998Preliminary FFS Progress Meeting in Philadelphia and a new section,2.6. the Preliminary Screening of Remedial Alternatives. We anticipatethat the No Action Alternative will be screened out with Alternatives 1(ROD Recycling), 4 (Direct Current Graphite Arc Melter Technology),and 5 (Landfill Daily Cover) in the section of the FFS report (Section 2.6).

The FFS schedule has been updated to include composite samplingactivities performed on 27 and 28 January 1998, and a 10 weektreatability investigation (details of the investigation are presented in the17 February 1998 letter to USEPA), performed by SevensonEnvironmental Services, Inc. (Sevenson). The schedule includes aninterim FFS progress meeting in early May, following the results of theSevenson study. The purpose of the meeting will be to present theresults of the FFS analysis of alternatives. The DRAFT submittal of theFFS Report will follow the interim meeting by approximately 6 weeks.The timing of the DRAFT FFS report submission corresponds well withthe anticipated promulgation date for the PCB (31 March 1998) andPhase IV (15 April 1998) rules. Both rules have a significant bearing onthe remedy implementation for the EDM Site and will be incorporatedinto the DRAFT report.

AR30032I

EnvironmentalSteven J. Donohue ResourcesN21 1 1 .00.01 Management23 February 1998Page 2

Copies of this letter are being forwarded under separate cover to thePennsylvania Department of Environmental Protection and the U.S.Army Corps of Engineers. Please call me if you have any questions orcomments.

Sincerely,

Douglas J. ShenkProject Engineer

enclosures: Updated Focused Feasibility Study ScheduleRevised DRAFT Focused Feasibility Study Outline

cc: V. Jurka, Lucent TechnologiesW. Boyhan, WRBM. Mustard, PADEPMBoxwell, USAGE

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DRAFT OUTLINEFOCUSED FEASIBILITY STUDYEASTERN DIVERSIFIED METALS SITEHOMETOWN, PENNSYLVANIA

EXECUTIVE SUMMARY

Brief summary of the entire FFS.• site history;• FFS scope and objectives;• development and evaluation of alternatives; and• recommended remedial alternative.

1.0 INTRODUCTION

1.1 PURPOSE AND ORGANIZATION OF .REPORT2.1.1 Purpose1.1.2 FFS Approach1.1.3 Report Organization

13 BACKGROUND1 .2. 1 Site Description and History1.2.2 Previous Remedial Actions at Site1.2.3 Summary of Pile Characteristics1.2.4 Summary of Recent Studies

2.0 DEVELOPMENT OF REMEDIAL ALTERNATIVES

2.1 INTRODUCTION• Explain history of the recycling ROD and how the process has been

focused on the five alternatives presented in the EPA's April 1997letter.

IDENTIFICATION OF POTENTIAL ARARS2.2.1 Comprehensive Environmental Response, Compensation, and Liability

AC* (CERCLA;2.2.2 Toxic Substances Control Act (TSCA)2.2.3 Resource Conservation and Recovery Act (RCRA)2.2.4 Pennsylvania Residual Waste Regulations

23 REMEDIAL ACTION OBJECTIVES

* EDM/N2111.0Q.01/02/21/98

2.4 DESCRIPTION OF CANDIDATE REMEDIAL TECHNOLOGIES2.4.1 General• evaluate the focused list of remedial technologies presented below

which are potentially applicable to remediation of the site2.4.2 Stabilization - ; ••'••'•'2.4.3 Plastics Separation2.4.4 Metals Recovery ;,2.4.5 Waste-to-Energy2.4.6 Landfill Disposal .

2.5 DESCRIPTION OF REMEDIAL ALTERNATIVES• this section will briefly describe the technologies and processes

incorporated in each alternative2.5,1 No Action Alternative2.5.2 Alternative 1 - ROD Recycling Remedy5.2.3 Alternative 2 - On-Site Stabilization and Off-Site Disposal2.5.4 Alternative 3 - On-Site Separation and Resource Recovery, and Off-Site

Disposal• (possible iterations, e.g., 3A, 3B, etc. combining the alternative

outcomes for individual pile constituents, e.g., PE, Metals, etc.)2.5.5 Alternative 4 - Direct Current Graphite Arc Melter Technology2.5.6 Alternative 5-Landfill Daily Cover

..2.6 PRELIMINARY SCREENING OF REMEDIAL ALTERNATIVES

• Section will screen the alternatives presented in Section 2.5 to focusthe list to only those alternatives with potential for implementation.This section will cite correspondence/meetings with EPA thatdocument the early dismissal of alternatives not retained for detailedevaluation.

3.0 DETAILED EVALUATION OF RETAINED REMEDIAL ALTERNATIVES

3.1 EVALUATION CRITERIA

• for each of the criterion below, explain what they mean, and how thealternatives retained from the preliminary screening will beevaluated according to the criterion.

3.1.1 Overall Protection of Human Health and the Environment3.1.2 Compliance with Potential ARARs3.1.3 Long-term Effectiveness and Permanence3.1.4 Reduction of Toxicity, Mobility or Volume3.1.5 Short-term Effectiveness3.1.6 Implementability . ,3.1.7 Cos*

AR300325 ii EDM/N211I.00.01/02/21/98

3. 1 .8 State Acceptance3.1.9 Community Acceptance

3.2 DETAILED EVALUATION Of REMEDIAL ALTERNATIVES• detailed evaluations will be made only of retained alternatives3.2.1 Alternative 2 - On-Site Stabilization and Off-Site Disposal3.2.2 Alternative 3 - On-Site Separation and Resource Recovery, and Off-Site

Disposal• retained sub-alternatives, (e.g., metals recycling and landfill disposal)

33 COMPARATIVE EVALUATION OF ALTERNATIVES• under each of the criterion presented below, a detailed comparison of

the retained alternatives1 will be presented, identifying theadvantages and disadvantages between the retained alternatives.

3.3.1 Overall Protection of Human Health and the Environment3.3.2 Compliance with ARARs3.3.3 Long-term Effectiveness and Permanence3.3.4 Reduction ofToxicity, Mobility or Volume3.3.5 Short-term Effectiveness3.3. 6 Implementability3.3.7 Cost3.3.8 Other Criteria3.3.9 Summary• present a semi-quantitative summary of the comparison of

alternatives so as to support the recommendation of a remedialalternative.

4.0 FFS SUMMARY AND ALTERNATIVE RECOMMENDATION

4.1 SUMMARY OF CRITICAL ISSUES• summarize the major conditions affecting the evaluation of remedial

alternatives for the site.

4.2 RECOMMENDED REMEDIAL ALTERNATIVE AND SUPPORTINGRATIONALE• identify the recommended remedial alternative based on the

comparative analysis of alternatives.• detail the advantages of the recommended alternative versus the

alternatives which were not recommended.

4.3 IMPLEMENTATION DETAILS AND SCHEDULE

EDM/N21U.00.01/02/21/98

provide a detailed discussion of the implementation for therecommended alternative

APPENDICES

APPENDIXA - DETAILED COSTESHMAIES

Include detailed cost summary tables and an explanation of costestimating methods and assumptions to support the cost estimatespresented as part of the detailed evaluation of alternatives.

iv EDM/N2111.00.01/02/21/98

Facsimile EnvironmentalResource*Management

To: Steve DonohueUS. Environmental Protection Agency

(610)524-3500Meg Mustard (610) 524-7335 (fox)PA Department of Environmental Protection

MimiBoxwellUS Army Corps of Engineers

Fax number (215) 566-3001(610)861-2072 TTOTV/f(410)962-2318 HJ.VI.Vi.

Prom: Gary Emmanuel

File number: N2111.00.01

Date: 17 February 1998

Number of pages: 4 including cover sheet

The attached is a description of the treatability work being performed bySevenson Environmental Services/ Inc. for the Focused Feasibility Study atthe Eastern Diversified Metals Site.

Please call me at (610) 524*3759 with any questions.

PRIVILEGE AND CONFIDENTIAUTY NOTICE

Thif message is intended only for th* use of th* individuals) to whom it is addressed and maycontain information that i* privileged and/or confidential If tht reader of this message i* notthe intended recipient or the employee or agent responsible for delivering th* message to thtintendod recipient you art hereby notified that any dissemination, distribution, or copying ofthis communication is strictly prohibited If you have received this communication in error,pleas* notify us immediately at (610) 524*7335 and return th* original message to us at th*address abov* via th* U. & Postal Service. Thank you.

flR300328

v iV" : • Environmental•V.'. . . . Resources• ' / * ' ' Management

ERM

_________19341

V*-~17 February 1998

. ' Reference N2111.00.01

>;; ] / . Mr.StevenJ. Donohue(3HW22)v'"-*'!; Western Pennsylvania Remedial Section "; U.S. Environmental Protection Agency

841 Chestnut Building' . ' . . ' Philadelphia/Pennsylvania 19107

Dear Steve:

• . The scope of sampling and analysis presented in ERM's letter of 23' . January 1998 included the preparation of « large volume composite

sample of the fluff pile at the Eastern Diversified Metals (EDM) Site.That sample was prepared on 27-28 January 1998. From that sample/ ten55-gallon drums were filled for use by Sevenson Environmental Services/Inc. (Sevenson). A discussion of the objectives of investigations to beperformed by Sevenson follows.

^ Sevenson will perform studies to evaluate two processes with potentialfor application at the EDM Site. These are:

• 1. An Inertial Density Separation process for separation of recyclablecopper; and

t 2. Application of MAECITTE® treatment a phosphate mineralization• technology/ for stabilization of the lead characteristic and other

Phase IV LDR metals.i*'' ' :' .' ,•„•'.- Sevenson previously performed preliminary testing of the Inertial Density

Separation technology with EDM fluff to determine what pile fractions. could most sucessfully be separated. Among the streams examined/

1 copper showed the most promise for obtaining a recyclable stream of.-.'• sufficient value cost effectively. The current investigation will focus on

the separation of copper. Sevenson has successfully applied theMAEdTTE® technology to similar materials. A treatability study is

' • being performed to evaluate dosage rates and secondary effects ofMAECZTTE® application on other remedial measures. The ten drums ofcomposite fluff sample have been taken to Sevenson's treatabilitylaboratory in Buffalo/ New York for this work,;.Wv, • .- , • ::; : • • ", j, >>r. ..-'. • • . . . * • ' < . , - •

*;''". ; AR300329

Mr. Stoven DonohueN2iii.oaoi17 February 1998Pag* 2

The Sevenson treatability and separation investigations have beendesigned to provide the following information which is germane to theFocused Feasibility Study:1. Copper separation process parameters/ including:

• Process effectiveness (amount of copper recovered)/• Potential processing rates,• Requirements for pre-separation drying,• Effectiveness of pre-screening and sizing, and• Processing costs.

Z An end-product user assay of recovered copper.3. MAECTirE® treatment parameters, including:

• Dosage required for lead stabilization to proposed Phase IVLDR treatment standards/ .

• Effectiveness on other Phase IV LDR parameters/• Impacts, if any, on PCBs teachability, and• Treatment costs.

4. Effects, if any/ of MAECTTTE® treatment on copper separation/including:• Pre-process drying requirements/• Separation effectiveness/ and* Impacts on copper value.

Following the completion of Sevenson's work, Lucent and ERM willhave been provided with a good indication of the feasibility of these tworemedial measures, including process descriptions and costs. Thisinformation will be factored together with related information fromother sources in completing the focused feasibility study. The Sevensoninvestigations will take ten weeks to complete.

Other testing underway

Additional use of the composite sample material is being made toaddress PCB contamination issues. As you are aware from ERM's 23January letter, laboratory testing of total and leachable FCBs in the

AR300330

._ _ » . EnvironmentalMr. Stevcn DonohueN2in.oaoi17 February 1998

composite sample is underway. Leachable levels are also beingexamined in a sample of separated PVC that remained from theMacLeod separation study.

In a meeting with Forrester Environmental Services/ Inc. (Forrester) inDecember 1997, Lucent and ERM were informed of a proprietary processthat has achieved up to 80 percent removal of PCBs in some wastestreams. The offer was made mat the technology could be tested on anEDM waste stream. Lucent and ERM view the technology as havingpotential applicability for reducing FCB concentrations to below TSCAregulated levels for disposal purposes. Because of the relatively highconcentrations of total FCBs found in separated PVC in the pastForrester has been provided with the FVC sample to test the FCBremoval technology on this fraction.

The results of leachable PCBs in the various camples sent for laboratoryanalysis per ERM's 23 January 1998 letter will provide some indicationof whether the Forrester technology has any application value for theEDM Site. That is/ mere may be no TSCA disposal concerns if leachableFCB levels are found below the 50 ppb level in the proposed regulationamendment In the meantime, performing Forrester's testing now willaddress the proof of principle that removal can be accomplished. If thetesting shows that removal can be achieved and the results obtainedfrom the laboratory work now underway show leachable FCBs at levelsappearing to require TSCA disposal the practicability of applying thetechnology will be examined. The costs of capital, labor and operationswould be compared with TSCA disposal costs.

Should you have any questions in regards to the above/ please feel freeto contact me or Val Jurka.

Sincerely,

4+~~*<Emmanuel, P.E.

Prefect Director

cc Val JurkaWalter BoyhanMeg MustardMimi Boxwell . «. *

AR30033f TOTflL P.04