OOOR83103
                                  SOURCE CONTROL FEASIBILITY
                                            STUDY
                                   OMC HAZARDOUS WASTE  SITE
                                     WAUKEGAN,  ILLINOIS
                                        EPA 13-5M28.Q

                                          W65328.00
                                        JULY 14, 19S3
PD998.049.1

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                              OOOR83103
  HAZARDOUS
SITE CONTROL
      DIVISION
     Remedial
    Planning/
         Field
 Investigation
         Team
     (REM/FfD
            •'  ^
       ZONE 11
CONTRACT W.-
     68-01-6692
   CH2MKH1LL
     Environment
                          SOURCE CONTROL FEASIBILITY
                                 STUDY
OMC HAZARDOUS WASTE SITE
  WAUKEGAN, ILLINOIS
                              EPA 13-5M28.0

                                W65328.00

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CONTENTS
                                                                      Page

   EXECUTIVE SUMMARY	    xiii

   1.  INTRODUCTION	     1-1

   Purpose	     1-1
   Scope of Work	     1-1
     Task 1:  Work Plan and Background Information Development....     1-1
     Task 2:  Development of Alternatives	     1-1
     Task 3:  Initial Screening of Selected Alternatives	     1-2
     Task 4:  Additional Engineering Studies	     1-2
     Task 5:  Detailed Evaluation of Feasible Alternatives	     1-2
     Task 6:  Conceptual Design	     1-3
     Task 7:  Additional Requirements	     1-3
   Site Description	     1-3
   Site History	     1-4
   Extent of the Problem	     1-6
     Waukegan Harbor	     1-6
     North Ditch/Parking Lot Area	     1-6
   Assessment of Potential Impacts	     1-7
     Effects on Fish	     1-7
     Effects on Animals	     1-8
     Impacts on Public Health and Safety	     1-8
     Potential Impacts of No Action	     1-9
   Objectives and Criteria	    1-11
     Objectives	    1-11
     Criteria	    1-12

   2.  PRELIMINARY SCREENING	     2-1

   Preliminary Screening Criteria	     2-1
   No Action	     2-2
   In-place Destruction	    2-11
     Ultraviolet/Ozonolysis	    2-11
     Biodegradation	    2-11
     Chemical Oxidation	    2-12
     Radiation (Gamma and Electron Beam)	    2-12
   In-place Fixation	    2-12
     Sorbents	    2-12
     In-place Stabilization	    2-13
     Impermeable Membrane Seal	    2-13
   In-place PCB Separation and Removal	    2-13
     Retrievable Sorbents	    2-13
     Bioharvesting	    2-14
     Oil-soaked Mats	    2-14
     Solvent Extraction	    2-14
   PCB-contaminated Solids Removal	    2-15
     Freezing Before Removal	    2-15
     Mechanical Dredges	    2-15
     Hydraulic Dredges	    2-17
     Pneumatic Dredges	    2-19
PD998.064.1                           iii

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CONTENTS (continued)
     Excavation Equipment	    2-20
   Sediment Dispersal Control	    2-21
     Single Silt Curtain	    2-21
     Double Silt Curtain		    2-21
     Water-inflated Dam.	    2-22
     Sheet Piling	    2-22
   Surface Water and Groundwater Control	    2-22
     Cofferdam	    2-22
     Dewatering	    2-22
     Injection of Grout	    2-23
     Sheet Piles	    2-23
     Slurry Walls	    2-23
   Bypass	    2-23
     Grading	    2-24
     Pipeline	    2-24
     Lined Open Ditch	    2-24
     Temporary Pumphouse	    2-24
   Initial Solids Dewatering	    2-25
     No Dewatering	    2-25
     Lagoon on OMC Property	    2-25
     Portable Sediment Processing System	    2-25
     North Ditch as Dewatering Basin	    2-26
     Barge Storage	    2-26
     Thickening with Other Project Area Solids	    2-27
     Slip No. 3 as Dewatering Basin	    2-27
     Dehydro Drying Beds	    2-27
     Gravity Thickener	    2-27
   Secondary Solids Dewatering	    2-28
     Mechanical Dewatering/Belt Press	    2-28
     Air Dry and Treat with Other Solids	    2-28
   Fixation	    2-28
   Water Treatment	    2-29
     No Water Treatment	    2-29
     Flocculation/Sedimentation	    2-29
     Filtration	    2-29
     Carbon Adsorption	    2-30
     Klensorb	    2-30
     Ultraviolet/Ozonolysis	    2-30
     Catalytic Reduction	    2-30
     Wet Oxidation	    2-31
     High-Efficiency Boilers	    2-31
     Chlorinolysis	    2-31
     The Goodyear Process	    2-31
     The Sunohio Process	    2-32
     Use of North Shore Sanitary District Wastewater Treatment
       Facility	    2-32
   Onsite Storage/Disposal	 .    2-32
     Landfill	    2-32
     Containment/Encapsulation	    2-33
     PCB Extraction	    2-33
     Chemical Destruction	    2-34
PD998.064.2                           iv

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CONTENTS (continued)
     Biological Breakdown	    2-34
     Incineration and Landfill Ash	    2-35
     Water Disposal	    2-35
   Off site Storage/Disposal	    2-35
     Landfill	    2-36
     Incineration	    2-37
   Transportation	    2-37

   3.  RECOMMENDED ALTERNATIVES FOR INITIAL SCREENING	     3-1

   Slip No. 3	     3-1
     Alternative 1:   Dredge-Fix-Dispose	     3-1
     Alternative 2:   Dredge-Dewater-Fix-Dispose	     3-1
     Alternative 3:   Dredge-Dewater-Dispose	     3-2
     Alternative 4:   Dredge-Dewater-Incinerate-Dispose	     3-3
     Alternative 5:   No Action	     3-3
   Upper Harbor	     3-3
     Alternative 1:   Dredge-Fix-Dispose	     3-3
     Alternative 2:   Dredge-Dewater-Fix-Dispose	     3-3
     Alternative 3:   Dredge-Dewater-Dispose	     3-4
     Alternative 4:   Dredge-Dewater-Incinerate-Dispose	     3-4
     Alternative 5:   No Action	     3-4
   Slip No. 3 and Upper Harbor	     3-4
     Alternative 6:   Contain-Dredge-Cap	     3-4
   North Ditch Area	     3-5
     Alternative 1:   Excavate-Dispose	     3-5
     Alternative 2:   Excavate-Incinerate-Dispose	     3-5
     Alternative 3:   Excavate-Fix-Dispose	     3-5
     Alternative 4:   Excavate-Contain-Cap	     3-6
     Alternative 5:   No Action	     3-6
   Parking Lot Area	     3-7
     Alternative 1:   Excavate-Dispose	     3-7
     Alternative 2:   Excavate-Incinerate-Dispose	     3-7
     Alternative 3:   Excavate-Fix-Dispose	     3-7
     Alternative 4:   Contain-Cap	     3-7
     Alternative 5:   No Action	     3-7

   4.  INITIAL SCREENING	     4-1

   Engineering Feasibility	     4-1
     Dredging	     4-1
     Excavation	     4-3
     Sediment Dispersal Control	     4-3
     Surface Water and Groundwater Control	     4-3
     Bypass	     4-4
     Initial Solids  Dewatering	     4-4
     Secondary Solids Dewatering	     4-6
     Fixation	     4-6
     Water Treatment	     4-7
     Containment/Encapsulation	     4-8
     Incineration	     4-9
PD998.064.3

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CONTENTS (continued)
     Water Disposal	    4-11
     Off site Landfill	    4-11
     Transportation	.	    4-12
   Estimated Incremental Costs	    4-13
     Slip No. 3	    4-13
     Upper Harbor	    4-16
     Slip No. 3 and Upper Harbor	    4-17
     North Ditch/Parking Lot Area	    4-18
   Environmental Considerations	    4-20
     Slip No. 3	    4-20
     Upper Harbor	    4-25
     Slip No. 3 and Upper Harbor	    4-30
     North Ditch Area	    4-31
     Parking Lot Area.	    4-36
   Recommended Alternatives for Detailed Evaluation	    4-40
     Slip No. 3	    4-41
     Upper Harbor	    4-41
     Slip No. 3 and Upper Harbor	    4-42
     North Ditch Area	    4-42
     Parking Lot Area	    4-42

   5.  DETAILED EVALUATION—ENGINEERING AND COST ASPECTS	     5-1

   Slip No.  3	     5-1
     Alternative 2B:  Dredge-Dewater in Lagoon-Fix-Dispose	     5-1
     Alternative 2D:  Dredge-Dewater in Barges-Fix-Dispose	    5-10
     Alternative 3:  Dredge-Dewater in Lagoon-Dispose	    5-15
   Upper Harbor	    5-18
     Alternative 2B:  Dredge-Dewater in Lagoon-Fix-Dispose	    5-18
     Alternative 3:  Dredge-Dewater in Lagoon-Dispose	    5-21
   Slip No.  3 and Upper Harbor	    5-24
     Alternative 6A:  Contain-Dredge-Cap	    5-24
     Alternative 6B:  Contain-Dredge Part of Upper Harbor-Cap	    5-31
     Subalternative I:  Select Excavation	    5-35
   North Ditch/Parking Lot Area	    5-39
     Alternative 1:  Excavate-Dispose	    5-39
     Alternative 3:  Excavate-Fix-Dispose	    5-45
     Alternative 4:  Contain-Cap (Parking Lot Area Only)	    5-47
     Alternative 4A:  Excavate-Contain-Cap  (North Ditch Area Only)    5-53
     Alternative 4B:  Excavate-Contain Part of E-W Portion of
       the North Ditch-Cap (North Ditch Area Only)	    5-57
     Subalternative I:  Select Excavation	    5-64

   6.  DETAILED EVALUATION—ENVIRONMENTAL ASPECTS	     6-1

                        Part  1:  Affected Environment

   Climate	     6-1
   Noise	     6-2
   Topography	     6-2
   Geology	     6-2
PD998.064.4                          vi

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CONTENTS (continued)
   Soils	     6-3
   Groundwater	     6-3
   Surface Water Quality	     6-4
   Terrestrial Biota	     6-5
     Vegetation	     6-6
     Animals	     6-7
     Threatened or Endangered Species—Federal Classification	     6-8
     Threatened or Endangered Species—State Classification	     6-8
   Aquatic Biota	     6-9
     Fish	     6-9
     Benthic Macroinvertebrates	     6-9
     Phytoplankton	    6-10
     Zooplankton	    6-11
     Threatened and Endangered Species	    6-11
   Land Use	    6-11
   Population	    6-12
   Employment	    6-12
   Economic Activity	    6-13
   Transportation Facilities	    6-13
     Port Facilities	    6-13
     Highway Facilities	    6-13
     Railroad Facilities	    6-14
   Recreation and Tourism	    6-14
   Sewer and Utility Lines	    6-14
     Storm and Sanitary Sewers	    6-14
     Water Lines	    6-15
     Natural Gas Lines	    6-15
     Electrical Lines	    6-15
     Telephone Lines	    6-15
   Cultural Resources	    6-15

                        Part 2:  Impacts of No Action

   Slip No. 3	    6-16
   Upper Harbor	    6-16
   North Ditch	    6-16
   Parking Lot	    6-17
   Impacts on Fish	    6-17
   Impacts on Animals	    6-18
   Impacts on Public Health and Safety	    6-20
   Socioeconomic Impacts	    6-21

                      Part 3;   Impacts of Alternatives

   Slip No. 3	    6-21
     Alternative 2B:  Dredge-Dewater in Lagoon-Fix-Dispose	    6-21
     Alternative 2D:  Dredge-Dewater in Barges-Fix-Dispose	    6-30
     Alternative 3:   Dredge-Dewater in Lagoon-Dispose	    6-38
   Upper Harbor	    6-47
     Alternative 2B:  Dredge-Dewater in Lagoon-Fix-Dispose	    6-47
     Alternative 3:   Dredge-Dewater in Lagoon-Dispose	    6-55
PD998.064.5                         vii

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CONTENTS (continued)


   Slip No.  3 and Upper Harbor	    6-63
     Alternative 6A:  Contain-Dredge-Cap	    6-63
     Alternative 6B:  Contain-Dredge Part of Upper Harbor-Cap..—    6-71
     Subalternative I:  Select Excavation	    6-80
   North Ditch/Parking Lot Area	    6-84
     Alternative 1:  Excavate-Dispose	    6-84
     Alternative 3:  Excavate-Fix-Dispose	    6-89
     Alternative 4:  Contain-Cap (Parking Lot Area Only)	    6-95
     Alternative 4A:  Excavate-Contain-Cap (North Ditch Area Only)    6-99
     Alternative 4B:  Excavate-Contain Part of E-W Portion of the
       North Ditch-Cap (North Ditch Area Only)	   6-106
     Subalternative I:  Select Excavation	   6-114

   7.  ALTERNATIVES SUGGESTED FOR PUBLIC COMMENT	     7-1

   8.  BIBLIOGRAPHY	     8-1

   Appendix  HEALTH SITE AND SAFETY PLAN	     A-l
 PD998.064.6                         viii

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TABLES


Table                                                                   Page

2-1     List of Unit Processes for Remedial Action Alternatives	      2-3

5-1     Detailed Cost Estimate, Slip No. 3, Alternative 2B:
          Dredge-Dewater in Lagoon-Fix-Dispose	      5-8

5-2     Detailed Cost Estimate, Slip No. 3, Alternative 2D:
          Dredge-Dewater in Barges-Fix-Dispose	     5-14

5-3     Detailed Cost Estimate, Slip No. 3, Alternative 3:
          Dredge-Dewater in Lagoon-Dispose	     5-19

5-4     Detailed Cost Estimate, Upper Harbor, Alternative 2B:
          Dredge-Dewater in Lagoon-Fix-Dispose	     5-22

5-5     Detailed Cost Estimate, Upper Harbor, Alternative 3:
          Dredge-Dewater in Lagoon-Dispose	     5-25

5-6     Detailed Cost Estimate, Slip No. 3 and Upper Harbor,
          Alternative 6A:  Contain-Dredge-Cap	     5-30

5-7     Detailed Cost Estimate, Slip No. 3 and Upper Harbor,
          Alternative 6B:  Contain-Dredge Part of Upper Harbor-Cap...     5-34

5-8     Detailed Cost Estimate, Slip No. 3 and Upper Harbor,
          Subalternative I:  Select Excavation	     5-38

5-9     Detailed Cost Estimate, North Ditch, Alternative 1:
          Excavate-Dispose	     5-43

5-10    Detailed Cost Estimate, Parking Lot, Alternative 1:
          Excavate-Dispose	     5-44

5-11    Detailed Cost Estimate, North Ditch, Alternative 3:
          Excavate-Fix-Dispose	     5-48

5-12    Detailed Cost Estimate, Parking Lot, Alternative 3:
          Excavate-Fix-Dispose	     5-49

5-13    Detailed Cost Estimate, Parking Lot, Alternative 4:
          Contain-Cap	     5-52

5-14    Detailed Cost Estimate, North Ditch, Alternative 4A:
          Excavate-Contain-Cap	     5-58

5-15    Detailed Cost Estimate, North Ditch, Alternative 4B:
          Excavate-Contain-Cap	     5-63

5-16    Detailed Cost Estimate, North Ditch, Subalternative  I:
          Select Excavation	     5-66
PD998.065.1                             ix

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TABLES (continued)


7-1     Summary Table, Detailed Cost Estimate and Pounds of
          PCBs Controlled, Slip No.  3 and Upper Harbor	.	„      7-2

7-2     Summary Table, Detailed Cost Estimate and Pounds of
          PCBs Controlled, North Ditch/Parking Lot Area...	      7-3

7-3     Ranking Procedure, Slip No.  3	      7-4

7-4     Ranking Procedure, Upper Harbor	      7-5

7-5     Ranking Procedure, North Ditch	      7-6

7-6     Ranking Procedure, Parking Lot	      7-7
 PD998.065.2

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FIGURES


Section 1*

 1-1      Location Map

 1-2      Site Map

Section 3

 3-1      Initial Screening Alternatives, Slip No.  3

 3-2      Initial Screening Alternatives, Upper Harbor

 3-3      Initial Screening Alternatives, Slip No.  3 and
            Upper Harbor

 3-4      Initial Screening Alternatives, North Ditch

 3-5      Initial Screening Alternatives, Parking Lot

Section 4

 4-1      Detailed Evaluation Alternatives, Slip No. 3

 4-2      Detailed Evaluation Alternatives, Upper Harbor

 4-3      Detailed Evaluation Alternatives, Slip No. 3 and
            Upper Harbor

 4-4      Detailed Evaluation Alternatives, North Ditch

 4-5      Detailed Evaluation Alternatives, Parking Lot

Section 5

 5-1      Conceptual Site Layout, Slip No. 3, Alternatives 2B,
            2D, and 3

 5-2      Conceptual Site Layout, Upper Harbor, Alternatives 2B
            and 3

 5-3      Conceptual Site Layout, Slip No. 3 and Upper Harbor,
            Alternative 6A

 5-4      Conceptual Site Layout, Slip No. 3 and Upper Harbor,
            Alternative 6B

 5-5      Conceptual Site Layout, North Ditch/Parking Lot
            Area, Alternatives 1 and 3
*Figures are found at back of section.

PD998.066.1                            xi

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FIGURES (continued)
Section 5

 5-6      Conceptual Site Layout, North Ditch/Parking Lot
            Area, Alternative 4 (Parking Lot Area Only)

 5-7      Conceptual Site Layout, North Ditch/Parking Lot Area
            Alternatives 4A and 4B (North Ditch Area Only)

Section 7

 7-1      Cumulative Project Costs Versus Cumulative Pounds
            of PCBs Controlled
PD998.066.2                            xii

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     EXECUTIVE SUMMARY
High levels of polychlorinated biphenyls  (PCBs)  in  soil  and
sediment in Waukegan Harbor and land owned by Outboard Marine
Corporation (OMC) near the North Ditch, a small tributary of
Lake Michigan, have  been discovered by various  public and
private organizations  since  1976.   Concentrations  of PCBs
exceeding 30 percent on  a dry weight basis  (300,000 parts
per million (ppm))  have been found in localized areas at the
former OMC  outfall.   PCBs have penetrated  into  the layer
underlying the harbor sediments near this outfall.  The PCBs
have spread laterally, contaminating soil,  water, and sedi-
ment in Waukegan Harbor, Lake Michigan, and on adjacent land.
PCBs have also entered the aquatic food chain, bioaccumulating
in the top carnivores, such as salmon and trout.

The immediate threat that PCBs pose to  the  water quality  of
Lake Michigan and the potential threat  to human  health have
prompted the U.S. Environmental Protection Agency (USEPA) to
commission this feasibility study to recommend the most cost-
effective source control remedial actions that are  in accor-
dance with the National Oil and Hazardous Substances Contin-
gency Plan  (NCP), 40 CFR 300.

This feasibility study  is based on the  premise  that only
PCBs in concentrations greater than 50 ppm need be  addressed
because these  concentrations  are regulated by 40 CFR 761.
Previous  investigations  estimated  that  approximately
10,900 cubic yards (yd3)  of sediment,  sand,  and silt in Slip
No. 3;  35,700 yd3  of sediment  in  the  Upper  Harbor;  and
175,800 yd3 soil from the North  Ditch/Parking Lot area  are
contaminated with PCBs in concentrations exceeding  50 ppm.

The procedures followed to develop the  recommended  alterna-
tives for cleanup action included:

     •    Reviewing identified processes with the potential
          for contributing to PCB removal

     •    Screening these  alternative  processes  based  on
          engineering  feasibility,  environmental   impact,
          cost, and  conformance  with  site-specific  objec-
          tives and the NCP

     •    Combining the processes that remained after screen-
          ing into several remedial action  alternatives  for
          Slip No. 3,  the Upper  Harbor, and the  North
          Ditch/Parking Lot area for further evaluation
PD998.067.1                   xiii

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     •    Recommending cost-effective source control remedial
          alternatives for each area  (Slip No. 3, the  Upper
          Harbor, the North Ditch, and the Parking Lot area)

     •    Interacting regularly with the regulatory agencies

The source control remedial action alternatives listed below
were based on  the  feasibility study and consultation  with
USEPA.  The alternatives resulted from a screening procedure
that initially considered over 70 unit processes.  The unit
processes retained  for further evaluation  were  assembled
into the 21 alternative remedial  action systems  for  initial
screening.  Detailed evaluation of  16 alternatives and sub-
alternatives was conducted to  address their advantages and
disadvantages.

The alternatives are consistent with the requirements of the
NCP for the selection of the lowest cost alternative that is
technologically feasible, protects human health and the envi-
ronment, and considers the need  to  balance  funds under the
Superfund Program.   In view of these considerations,  the
five cleanup  actions  listed  below comprise USEPA1s  recom-
mended cleanup plan for the OMC site.

     •    Slip No.  3  and Upper Harbor:   Subalternative  I.
          This subalternative  would be  used  only  in con-
          junction  with  Alternative 6B.  PCB-contaminated
          sediment, sand, and silt would be dredged from the
          localized area near  the former OMC  outfall.   This
          material contains the greatest PCB  concentrations
          in the harbor and represents 92 percent of all the
          PCBs now found in Slip No. 3 and the Upper Harbor.
          This alternative would remove, fix, and dispose of
          an estimated 5,700 yd3 of PCB-contaminated material
          containing about 286,500 Ib of PCBs.  The material
          would be disposed of offsite in a licensed chemical
          waste landfill.  The estimated Order-of-Magnitude
          cost is $3,150,000.

     •    Slip No.  3  and Upper Harbor;  Alternative  6B.   A
          cofferdam with a slurry wall would  be  constructed
          around the perimeter of Slip  No.  3, part  of the
          Upper Harbor sediments  would  be dredged into the
          contained area, and then the containment area would
          be capped.  The estimated  Order-of-Magnitude cost
          is $6,100,000.

     •    North Ditch Area;  Subalternative I.  This subalter-
          native would be used only in conjunction with Alter-
          native 4B.  PCB-contaminated soil would be excavated
          from the localized areas in the Crescent Ditch and
          Oval Lagoon.  This material contains the greatest
          PCB concentrations in the North Ditch area and
PD998.067.2                  xiv

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          represents 57 percent of all the PCBs now found in
          the North Ditch/Parking Lot area.  This alternative
          would remove and dispose of an estimated 5,500 yd3
          of PCB-contaminated soil containing  about  440,500
          Ib of PCBs.  The soil would be disposed of offsite
          in a licensed chemical waste  landfill.  The esti-
          mated Order-of-Magnitude cost is $740,000.

     •    North Ditch Area:  Alternative 4B.  PCB-contaminated
          soil would be contained and capped in the Crescent
          Ditch/Oval Lagoon area.  A pipeline  to bypass  the
          east-west portion of the North Ditch would also be
          constructed (with partial excavation of PCB-contami-
          nated soil to install the pipe).  The PCB-contaminated
          soil from the bypass excavation would be placed in
          the Crescent Ditch/Oval Lagoon area before capping
          the area. The estimated Order-of-Magnitude cost is
          $4,210,000.

     •    Parking Lot Area; Alternative 4.  PCB-contaminated
          soil would be contained and capped in  the  Parking
          Lot area.  The  estimated  Order-of-Magnitude cost
          is $3,210,000.

The total estimated Order-of-Magnitude cost to implement the
above alternatives is $17,410,000.

Public comments will be received during the 30-day  public
comment period.  The USEPA Record of Decision  issued  at  the
end of the public comment period will determine specifically
the  alternatives  to be  implemented,  with  modifications,
if any, resulting from public comment.

A conceptual design will be prepared for the remedial action
alternative(s)  selected by USEPA.
PD998.067.3                  xv

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     Section 1
     INTRODUCTION
This report presents  the  results  of  a  Source  Control  Feasi-
bility Study  (FS)  to  evaluate  alternative means to remove,
contain,  fix,  or otherwise treat polychlorinated  biphenyl
(PCB) contaminated soils  on the Outboard  Marine Corporation
(OMC) site and PCB-contaminated  sediments in the Waukegan,
Illinois, harbor.  This work  was  authorized by  the United
States Environmental  Protection Agency  (USEPA)  on  March 18,
1983, by Work Authorization 13-5M28.0.

PURPOSE

The purpose of this FS is to recommend the most  cost-effective
source control remedial actions in accordance with the National
Oil and Hazardous Substances Contingency Plan  (NCP) promulgated
July 16, 1982  (47 FR  31180-31243;  40 CFR 300).   A conceptual
design of the  selected remedial action alternatives, determined
by the USEPA Record of Decision, will be presented in a separate
report.  The purpose  of this report is to summarize the review
and screening process used to develop the recommended alter-
natives .

SCOPE OF WORK

A comprehensive description of the scope of work was presented
in the "Final  Work Plan,  Source  Control Feasibility Study,
OMC Site, Waukegan, Illinois," USEPA Work Authorization 13-
5M28.0, dated  March 28, 1983.  A  brief  summary  of  the  scope
of work follows.

Task 1:  Work Plan and Background Information Development

This task included development of a  detailed work  plan for
conducting the  FS;  review of existing  reports,  maps,  and
other data;  development of a concise history of  the site and
description of its current status; and a site visit.

Task 2:  Development of Alternatives

Task 2 work included  development  of  site-specific  remedial
response objectives and screening criteria;  identification
of remedial response alternatives, both from previous reports
and based on experience;  and an assessment of existing tech-
nology potentially applicable to  remedial responses at  this
site.  A  comprehensive list  of alternative unit processes
was then  developed, and preliminary  screening was done  to
assess the potential  applicability of  each  unit process to
each of four  areas of the project site.  To  conclude  this
task, the  unit processes  retained  from  the  preliminary
PD998.051                    1-1

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screening were assembled  into  remedial  action alternatives
for each  of  the  project areas.  Five or  six alternatives
were developed for  each area.  The  alternatives  selected
were reviewed by USEPA and State of Illinois staff (Illinois
Environmental  Protection  Agency  and Attorney  General's
Office).

Task 3;  Initial Screening of Selected Alternatives

In this task, the alternative  remedial actions developed  in
Task 2 for each area were  compared  in  terms of incremental
(comparative) costs, environmental effects,  and engineering
feasibility.   Based on the results of these comparisons, two
to four alternatives  for  each area were retained  for  more
detailed evaluation in Task 5.  In addition,  data  gaps that
became apparent during Tasks 2 and 3 were  identified,  and a
laboratory testing program was proposed to  USEPA to  provide
information needed for conceptual design (see Task 4).

Task 4;  Additional Engineering Studies

Initially, no additional  engineering studies were  included
in the scope of work.  As  a result of the  data gaps  identi-
fied in Tasks 2 and  3,  USEPA authorized laboratory testing
to evaluate  the practicality  of using portland cement (or
other admixtures)  to  fix  the  contaminated  sediments  and to
provide additional information about sediment dewatering and
water treatment.   It is anticipated that the results will be
available about August 1, 1983.  They  will be presented
under separate cover.

Task 5;  Detailed Evaluation of Feasible Alternatives

The purpose  of this  task  was  to develop additional details
on the alternatives  retained  from Task 3 and to determine
which  alternative would be most cost-effective.   More de-
tailed engineering  aspects of the alternatives were  con-
sidered, the potential environmental impacts  of each alter-
native were  identified in more detail, and Order-of-Magnitude
cost estimates1 were developed for each alternative.   The
results of this task were  used to recommend one alternative
for each area.  The  recommended alternatives  were  discussed
with USEPA,  and this report was prepared  to  summarize all
the work in  Tasks 1, 2, 3, and 5.
xThe American Association of Cost Engineers defines an "Order-
 of-Magnitude" estimate as "An approximate estimate made
 without detailed engineering data.  Examples include:  an
 estimate from cost-capacity curves, an estimate using scale-
 up or scale-down factors and an approximate ratio estimate.
 It is normally expected that an estimate of this type would
 be accurate within +50 percent and -30 percent."
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After USEPA review of this report,  a  revised work  plan  will
be  developed  to complete  the conceptual  design of  the
selected alternatives.

Task 6;  Conceptual Design

Conceptual design of  the selected  alternatives  will  consist
of presenting, in report form, the  data necessary  to define
the significant aspects of the conceptual design so that the
design lead agency  can accomplish  the  design.   This task
will be completed in coordination with the next lead agency,
expected to be  the  U.S. Army Corps of  Engineers  (USCOE) .
The conceptual  design report will  include the  descriptive
text and figures necessary to document  the recommended de-
signs.  Refined Order-of-Magnitude  cost estimates  for each
alternative and a master implementation schedule will also
be included.  Authorization  to proceed  with  Task 6 will be
released after public  comments  have been reviewed and  the
USEPA Record of Decision has been made.

Task 7;  Additional Requirements

This task  includes  project management,  quality assurance,
and miscellaneous services not included elsewhere.

SITE DESCRIPTION

The OMC site is located near  the intersection of Grand  Ave-
nue and Sheridan Road on the  west  shore of Lake Michigan  in
Waukegan,  Illinois,  about  37 miles  north  of Chicago and
10 miles south of the Wisconsin border  (Figure  1-1).

Waukegan Harbor is an irregularly shaped harbor about 37 acres
in area.  For purposes of this FS,  the harbor has been divided
into two areas:   Slip No.  3  and the  Upper  Harbor.  These
areas are  shown on  Figure  1-2.   The  PCB concentration  for
each of the two  areas is also shown  on Figure 1-2:   Slip
No. 3 with greater than 500 parts per million (ppm) and Upper
Harbor with between  50  and 500 ppm.  Water  depths in the
harbor generally vary from 14 to  25  feet  (ft) , with some
shallower depths in parts of  Slip  No. 3.   The  harbor sedi-
ments consist of 1 to 7 ft of very  soft organic silt (muck)
overlying  typically  4  ft  of  medium dense, fine to coarse
sand.  A  very stiff  silt  (glacial till)  that  typically
ranges from 50 to more than 100 ft  thick underlies the sand.
The entire  harbor  is bordered by  20- to  25-ft-long  steel
sheet piling,  except at the  Waukegan Port District  boat
launching  areas and  at  the  retaining wall near  the  harbor
mouth.  The sheet piles generally extend into the sand layer
above the glacial till.
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The North Ditch is  a  small  tributary of Lake Michigan that
drains surface runoff  from  about  0.11 square mile (mi2)  of
CMC and North Shore Sanitary  District property.   The ditch
also drains surface runoff from an area west of OMC property
and the railroad tracks.  The North  Ditch  includes the 600-
ft-long, 20-ft-wide Crescent Ditch;  the  240-ft-long,  20-  to
40-ft-wide Oval Lagoon; and a  2,000-ft-long, 10- to  20-ft-
wide east-west portion of the North Ditch.   The U.S.  Depart-
ment of the  Interior  measured the mean daily discharge of
the ditch between March and September 1979 as 1.8 cubic  ft
per second (cfs),  with a maximum discharge of 5.3 cfs.  They
calculated the 5-year storm event to be 23 cfs (041).2

The Parking Lot area  is  located  north of OMC's Plant No.   2
and is about 9 acres in area.  There  are three entrances  to
the Parking Lot area:   two fenced entrances in the northwest
corner of CMC's property  and  one  fenced entrance southeast
of OMC's new die-cast  complex  at  the intersection of OMC's
private road and Seahorse Drive.   The generalized subsurface
conditions in the  North  Ditch/Parking Lot area  consist of
typically 30 ft of compact,  very fine to fine sand overlying
a stiff to very stiff silt  (glacial till).   The thickness  of
the glacial till typically  ranges  from 50  to more than 100
ft.

SITE HISTORY

The presence of high levels of PCBs in soils and harbor sedi-
ments  in the vicinity  of  the  OMC plant was  not  discovered
until  1975.  At that time, the Illinois Environmental Protec-
tion Agency  (IEPA)  sampled  CMC's  outfalls  in search  of the
source of PCBs discovered in a 1971 USEPA  study.   That study
showed PCB concentrations of 2.7 to 15.0 ppm in Lake Michigan
fish  (021).

Discharges from OMC are believed to be one of the major sources
of PCB contamination in Lake Michigan.  About 9 million pounds
(Ib) of PCBs were  purchased from  the Monsanto Company from
the early 1950's to 1971.  These PCBs were used as hydraulic
fluids in die-casting machines and related equipment (001).
In 1971, Monsanto  restricted  sale of PCBs  to closed system
uses  (021).

Because the hydraulic  systems  in  which the hydraulic fluids
were used leaked routinely, the  fluids containing PCBs es-
caped  from the die-cast machinery onto the surrounding floor
area.  OMC has advised USEPA  that 10 to 15  percent  of all
PCBs purchased may have escaped through floor drains and an
2Numbers in parentheses refer to the last three digits of
 the document control number.  Refer to Section 8, Bibliog-
 raphy.
PD998.051                    1-4

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oil interceptor system.  The  floor  drains  discharged  to the
North Ditch and Waukegan Harbor.   USEPA estimates that the
discharge could have been as high as 20 percent  (001, 068).

In 1976, USEPA began  to  regulate  PCB disposal.  OMC exten-
sively sampled outfalls and sealed two outfalls entering the
Crescent Ditch portion of  the North Ditch, pursuant  to an
Administrative Enforcement  Order  by USEPA  and IEPA.    OMC
declined to act on USEPA's demand for immediate  action to
remove PCB  sediments.  After  negotiations  among OMC, IEPA,
and USEPA concerning responsibility for cleanup of the  harbor
and the North Ditch  failed,  legal actions  ensued that  have
not been settled to date.

A third outfall, at the east end of the Crescent Ditch, cur-
rently discharges approximately 150,000 gallons per day (gpd)
of noncontact,  once-through cooling water.   This cooling
water supply partially originates from Slip No. 3 in Waukegan
Harbor (001).

Numerous scientific  investigations  have been  conducted to
define the  extent  of the PCB  contamination.   Alternatives
for removal/destruction of PCB-contaminated sediments in the
harbor and the North  Ditch  area have been  previously  formu-
lated and proposed.   A listing of the  data used to conduct
the FS is presented in Section 8,  Bibliography.

Remedial action, consisting of building a  bypass  around the
North Ditch, was attempted  in  December  1979.   This  activity
unearthed new areas of substantial PCB contamination beneath
OMC's North Parking Lot.  The  bypass construction was  post-
poned in early 1980, when USEPA updated its preliminary re-
medial action alternatives  assessment and  ultimate  disposal
and/or destruction alternatives to  include the Parking Lot
area of contamination.

Also in 1980, a special  congressional  appropriation in the
USEPA budget and Comprehensive Environmental  Response,  Com-
pensation,  and  Liability Act  (CERCLA)  "Superfund"  monies
became available to begin the cleanup of Waukegan Harbor.
USEPA contracted with WAPORA,  Inc., to conduct an Environmen-
tal Assessment (EA) of the site.   Funding,  site constraints,
and the time  schedule modified the  feasible  alternatives
discussed in the unpublished work by WAPORA, Inc. (002, 048) .
This funding was also used for planning and design work con-
ducted by Mason &  Hanger.  In March 1983,  the State of  Illinois
and USEPA signed the State Superfund Contract for this  site,
which included funding for this FS to assess alternatives.
PD998.051                    1-5

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EXTENT OF THE PROBLEM

Waukegan Harbor

Based on Mason  &  Hanger's  Addendum to Final Report,  dated
May 1981 (008) , and Mason & Hanger's Second Addendum to Final
Report, dated  March 1982  (016),  about  42,900  cubic yards
(yd3)  of upper sediments (muck) and 3,700 yd3 of deep sediments
(sand and silt) would have to be controlled to clean up areas
of contamination  exceeding  50  ppm PCB in Waukegan  Harbor.
These quantities were based on available data and were assumed
to be accurate to an order of  magnitude  (076).   The addenda
define the following areas of PCB contamination:

     •    Slip No. 3—About 7,200 yd3 of muck at thicknesses
          varying from  2 to  5  ft are contaminated by about
          167,200 Ib of PCBs,  with  concentrations  typically
          exceeding 500 ppm.   About 3,700 yd3  of  sand  and
          silt at an average thickness of 7  ft  are contami-
          nated by about 138,000 Ib of PCBs, with concentra-
          tions exceeding  10,000 ppm in  a  localized area
          near the former OMC outfall.

     •    Upper Harbor—About  35,700 yd3  of  muck at thick-
          nesses varying from  1  to  5  ft  are  contaminated  by
          about 5,000 Ib of  PCBs, with concentrations  typi-
          cally 50 to 500 ppm.

North Ditch/Parking Lot Area

Based on Mason  &  Hanger's  Final Report,  dated January 1981
(001), and  on  Weston's study  of March 1982 (051),  about
175,800 yd3 of material would have to be controlled to clean
up areas of contamination exceeding  50 ppm PCB  in  the  North
Ditch/Parking Lot area.  These quantities were based on avail-
able data and  were  assumed to be accurate  to  an order of
magnitude (076).  The reports  define  the following areas  of
PCB contamination:

     •    Crescent  Ditch—About  28,900 yd3  of  soil at an
          average thickness  of  25 ft  are  contaminated by
          about 403,700 Ib  of  PCBs.  Typically, concentra-
          tions are 5,000  to 38,000 ppm.  North of the die
          storage area, about  2,300 yd3  of soil  at  an average
          thickness of 3 ft are  contaminated by  about 2,000 Ib
          of PCBs.  Concentrations are typically about 200 ppm.

     •    Oval Lagoon—About 14,600 yd3  of soil  at  an average
          thickness of  27  ft are contaminated.  There  are
          about 85,500  Ib  of PCBs in the top  5 ft of the
          lagoon.  Typically,  concentrations in  the top 5 ft
          are about 26,000 ppm.   There were no data on the
          PCB concentrations or  quantities below 5  ft.
PD998.051                    1-6

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     •    North Ditch—About 25,000 yd3 of soil at an average
          thickness of  25  ft  are contaminated by at  least
          4,300 Ib of  PCBs.   About 200 ft  of the western
          portion of the ditch are contaminated with concen-
          trations typically in excess of 5,000 ppm PCB, and
          about 1,000 ft of the western and  central  portion
          of the ditch  are contaminated with concentrations
          typically ranging from 500 to 5,000 ppm.

     •    Parking Lot—Beneath the eastern half of the exist-
          ing Parking Lot, about 68,000 yd3 of soil at thick-
          nesses varying from  2  to 12 ft are contaminated.
          In the northwest portion of this contaminated area,
          an additional  37,000 yd3 of soil  at  thicknesses
          varying from 5 to 30 ft are contaminated.  Approxi-
          mately 277,700 Ib of PCBs are in these areas.  The
          northwest corner and an  area  east of the Parking
          Lot are contaminated with concentrations typically
          in excess of  5,000 ppm PCB.  The  southwest  corner
          of the Parking Lot is contaminated with concentra-
          tions typically ranging from 50 to 5,000 ppm.

ASSESSMENT OF POTENTIAL IMPACTS

Effects on Fish

The USEPA Ambient Water Quality  Criteria  for protection of
freshwater  aquatic  life  from PCB  chronic  toxicity  is
0.014 parts per billion (ppb)  (088).   The  lowest  reported
toxic  concentration  for freshwater aquatic  life for  PCB
acute  toxicity is 2.0  ppb  (085).   Total PCB concentrations
in the surface water at the CMC site vary from about 0.6 ppb
in Waukegan Harbor to  less than 0.01 ppb in  Lake Michigan
directly offshore from Waukegan Harbor.   About 60 percent of
the total harbor  PCBs  in the  water column  is in the dis-
solved form.  The water column PCB concentrations vary  over
a range of about 1.5 to 2.0 orders of magnitude  (035).

Fish accumulate PCBs  in their tissues by uptake from the
water  in which they live and by  ingestion of aquatic  organ-
isms, insects,  and plants that have taken up PCBs from their
environment.  It has been  demonstrated that  fish bioaccumu-
late PCBs to factors of 100,000  or more times the ambient
water concentrations of PCBs.  Available data indicate  that
PCBs are not excreted or degraded but are stored in skin and
adipose  (fatty) tissue.  In USEPA  studies  on Lake Michigan
fish, results ranged from  concentrations of 2.7 to 187 ppm
PCB in fatty tissue for all species.  PCB concentrations in
excess of 5 ppm were present  in  all trout and salmon more
than 12 inches long.  Positive correlations  between  size of
the fish, percent fat,  and age and the concentration of PCBs
dissolved in the water  column  have also been found.   There-
fore, larger fish with a higher percent fat content,  such as
PD998.051                    1-7

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salmon and  trout,  accumulate high concentrations of  PCBs.
Bottom feeders, such as carp, also accumulate very high  PCB
concentrations  from  contact with  PCB-contaminated  bottom
sediments (002, 021).

Bioaccumulation has been shown to  occur  at positions  higher
in the food  chain.   Carnivorous  predators,  such as large-
mouth bass,  have  markedly higher  PCB  concentrations  than
species lower on the food chain  (069, 002, 021).

Research has also shown that PCBs  interfere with growth  and
reproduction of several species of fish.  PCBs  in the water
column have been shown to inhibit phytoplankton photosynthe-
sis.  This will limit the growth of fish that require phyto-
plankton as a food source.  High PCB concentrations in bottom
sediments may  interfere with the development of eggs that
are deposited on the bottom  during spawning.  Fish fry mor-
tality has a direct  correlation  to PCB  levels  in the  water
column,  thereby artificially reducing  fish populations.
PCBs may ultimately  act to  diminish  natural  populations  of
fish species (002, 021, 049).

Effects on Animals

Physiological effects on animals  caused  by  PCB  exposure  or
ingestion include the following  (069, 086, 087):

     •    Death of lower invertebrates

     •    Swelling of livers in various species

     •    Enzyme system disturbances in various species

     •    Growth inhibition in hamsters

     •    Decrease in immunosuppression in birds and mammals

     •    Hyperkeratosis,  erethyma, blisters, and desquama-
          tion in rabbits

     •    Decreased reproduction in minks

The fact that  PCBs bioaccumulate in  animal  tissues is also
of  concern  because the contaminant  remains in the   food
chain.   PCB concentrations  bioaccumulate without  being
degraded or  eliminated  and can  reach  levels  that may be
toxic to those organisms at the top of the food chain (085) .

Impacts on Public Health and Safety

The magnitude  of  PCB effects on human health  are  not yet
known.  However, a severe accident involving PCB contamination
of rice oil  occurred in Kyushu,  Japan, in 1968, implicating
PD998.051                    1-8

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PCBs as a  health hazard.   The Japanese called the accident
Yusho  (oil  disease).   The  oil contained PCS concentrations
of 2,000 and  3,000  ppm, now  known  to  be in combination with
chlorinated  dibenzofurans  and  quaterphenyls  (049,  065).
Health effects  were documented in more than 2,000 persons.
Consumption of the  contaminated oil resulted in skin lesions,
blindness, hearing  loss, jaundice, and  abdominal pain.  Uter-
ine  ulcers,  stillbirths,  and  miscarriages also occurred.
Infants born to mothers exposed to the  contaminated rice oil
exhibited skin, gum, and fingernail discoloration, indicating
that at least some  of the contaminants  crossed the placental
membranes.  Other symptoms of Yusho toxicity in humans include:
swelling of joints, waxy secretion of eyelid glands, general
lethargy, joint pain, weakness and vomiting, abnormal menstrual
cycles, and weight  loss (085, 086, 087, 002, 021, 049).

Occupational exposure  to PCB mixtures has caused chloracne
and  liver  injuries  in  workers exposed  to  low  levels.   PCB
effects on  worker health from  occupational exposure have
also been documented (049, 002, 021).

Documented occurrences  of  high levels of PCB contamination
in humans have almost all resulted from consumption of contami-
nated foods,  accidentally  or through  accumulation in fatty
tissues through the food chain.  Inhalation of and skin contact
with PCBs are not considered a significant source of contami-
nation for  the  general public, but they are of  concern  in
occupational exposure.  The  Occupational  Safety and Health
Administration  (OSHA)  standards  (29 CFR 1910)  for  an  8-hour
work shift exposure to PCBs  in air is 1.0 milligram per liter
(mg/1)  for PCBs with 54 percent  chlorine  (Aroclor  1254)  and
0.5 mg/1 for  PCBs with 42  percent  chlorine  (Aroclor 1242).
There is no OSHA standard set for PCBs  with 48 percent chlorine
(Aroclor 1248).  Samples taken by the Environmental Research
Group,  Inc.  (ERG) on September 3,  1980, for USEPA detected
Aroclor 1242 and Aroclor 1248  in Waukegan  Harbor  sediments.
Aroclor 1254 was below detection limits (079).

USEPA Ambient  Water Quality  Criteria for carcinogenicity
protection of human health from ingestion of water and organ-
isms is 0.00079 ppb at the K>~5  risk  level.   Concentrations
that have a risk level of 10~5 are estimated to result in an
increase  of one  cancer death  per 100,000  people who
experience  PCB  exposure  over  a  lifetime.   Total  PCB
concentration vary  from 0.6  ppb  in Waukegan Harbor to less
than 0.01  ppb  in  Lake Michigan  directly offshore  from
Waukegan Harbor  (035) .   There  is  an  emergency water supply
intake for Waukegan near the mouth of the harbor.

Potential Impacts of No Action

Under the No Action alternative, surface-water bodies, sedi-
ments,  and soils would remain contaminated with a toxic substance
PD998.051                    1-9

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regulated under Toxic Substances Control Act (TSCA).   Socioe-
conomic impacts would continue and might include the following
(085) :

     •    Loss of fish for human consumption

     •    Reduction or loss of commercial fishing

     •    Decline in property values

     •    Depressed area growth

     •    Reduction in recreational activity, such as boating
          and sport fishing

     •    Reduction in commercial harbor access due  to  lack
          of harbor dredging

     •    Expenditures for laboratory analysis of area water,
          soil, and biota samples

     •    Occupational exposure

     •    Expenditures for medical services

     •    Expenditures for legal services

Slip No. 3 and Upper Harbor.  The No Action alternative will
leave an  estimated  305,200 Ib of PCBs  in  Slip  No.  3 with
concentrations in excess of 10,000 ppm in the localized area
of Slip No. 3 and in excess of  500  ppm in  the rest of Slip
No. 3 sediments; and 5,000 Ib of PCBs in the Upper Harbor in
concentrations  between  50  and  500 ppm.   Approximately
98.4 percent of all the PCBs now found in Slip No. 3 and the
Upper Harbor  sediments  are  located  in Slip No.  3.  PCBs in
these concentrations are regulated by 40 CFR 761 under TSCA.

Slip No. 3 and the Upper Harbor PCBs will continue to contrib-
ute to the estimated 22 Ib of PCBs released into Lake Michi-
gan each year from Waukegan Harbor water  (based on a steady
state model)  (035).  The Waukegan area will continue to repre-
sent the most  significant  contributor to Lake Michigan PCB
contamination, since it holds the largest  known uncontained
PCB mass in the lake basin.  The potential for volatilization
of PCBs will  continue,  contributing  to the estimated 12 to
40 Ib released  from  the  harbor  into the local airshed each
year (007,  030,  035).   Channel  dredging has been suspended
because of  PCB  contamination, and  shipping  access  to the
harbor will  eventually be eliminated.  Harbor maintenance
dredging of  PCB-contaminated  soils  is expensive  because of
disposal and  handling  requirements.   Huron Portland Cement
and National Gypsum are now and will continue to be directly
impacted, since  they depend on the  harbor  to  receive raw
material shipments.


PD998.051                   1-10

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North Ditch/Parking  Lot  Area.   The No  Action Alternative
will leave  an  estimated  773,200 Ib of  PCBs in the  North
Ditch/Parking Lot area with  levels  of PCB contamination in
excess of 10,000  ppm in  a localized  area  of the Crescent
Ditch and Oval Lagoon and  between  50  and 10,000 ppm in the
rest of  the North Ditch/Parking Lot  area  soils.   Offsite
drainage that enters the  North Ditch will continue to become
contaminated, discharging  PCBs  into Lake Michigan.  It  is
estimated that this  source discharges  7  to 20 pounds  per
year (Ib/yr) of PCBs into the lake annually  (032, 035).

Existing volatilization of PCBs from  the North Ditch waters
is estimated to be 15 Ib/yr  (004).  Although volatilization
of contaminated soils does not  appear to be occurring now,
the potential exists if existing soils  are  disturbed (004) .
Grading, trenching,  drilling, digging,  or other activities
necessary for utility installation, drainage,  or other  con-
struction projects could cause volatilization of PCBs.   Under
the No Action alternative, PCBs will continue to be released
into the airshed through volatilization.

Groundwater is within 3 feet of the surface of the Parking
Lot, resulting in contamination of these waters.  It is esti-
mated that  these  slowly moving  waters will begin releasing
some 8 Ib/yr of  PCBs into Lake Michigan in approximately
60 years (002).   This will result  in  further contamination
of local water and soil,  which could continue for decades.

The hydrologic system is  currently not well enough understood
to determine the  extent of past or  future  PCB contamination
by groundwater movement from the North Ditch.  Without cleanup
action, groundwater contamination will still exist.

OBJECTIVES AND CRITERIA

The proposed site-specific remedial response objectives  and
criteria for the OMC Hazardous Waste Site have been developed
in accordance with the NCP.   These  objectives and criteria
have been used to select  and  develop  the remedial response
measures for the OMC site.

Objectives

The primary objectives of this FS are to:

     •    Recommend  cost-effective  source  control  remedial
          action (s)  in accordance with  the  NCP  under statu-
          tory requirements of CERCLA.

     •    Prepare a conceptual design of the remedial action
          alternative (s)  selected  by  the  USEPA Record of
          Decision.
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Criteria

To meet the project objectives, the  following  site-specific
criteria were used in considering alternatives and in develop-
ing our recommendations:

     •    Economic comparisons were made on a  present-worth
          basis, considering both initial construction (capi-
          tal)  costs,  and  operation  and maintenance  (O&M)
          costs, as applicable.   For purposes of  reducing
          O&M costs to present worth, a 20-year  life was
          used,  with a discount rate of 10  percent (as estab-
          lished by Office of Management and Budget Circular
          No. A-94).

     •    During initial  screening, alternatives whose appar-
          ent cost far exceeded  (e.g., by a factor of about
          10 or more)  the  costs  of other alternatives were
          usually excluded from further consideration, unless
          there were substantially greater public  health  or
          environmental benefits.

     •    During detailed analysis of the alternatives, the
          primary cost selection  criterion  was to identify
          alternatives that would remove or contain the great-
          est mass of PCBs per present-worth dollar.   In the
          case of alternatives with approximately equal costs
          per pound of PCBs removed,  the selection criterion
          was to remove,  secure, or reduce exposure to mate-
          rial  most likely  to adversely affect the  public
          health and welfare or the environment.

     •    In considering  environmental effects, alternatives
          were eliminated when long-term adverse environmen-
          tal effects  resulting from implementation  would
          exceed the long-term mitigation benefits expected
          (i.e., the alternative  is  not  expected  to  achieve
          adequate source  control).   The potential effects
          were evaluated  based on engineering judgment, in a
          qualitative manner; quantitative analyses were not
          used.

     •    Alternatives were generally eliminated when it was
          judged that  the  permit  acquisition  process would
          unnecessarily delay  (i.e.,  beyond mid-1984) project
          startup.

     •    In general,  alternatives that  were  suitable from
          an engineering  practice viewpoint and  judged to
          provide an adequate degree of protection  of  the
          public health and welfare and the environment were
          retained, when  they could be  accomplished in a
          reasonable time  (i.e., from mid-1984 to  late 1986).
PD998.051                   1-12

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          Project timing was  determined by USEPA to  be a
          critical criterion for the OMC site.

     •    Alternatives that relied  on unproven or  experi-
          mental technology were generally eliminated  since
          their feasibility and  reliability  have not  been
          demonstrated.

     •    Alternatives that required special-order,  special-
          manufacture, or limited-availability equipment  or
          products,  because of time  delays,  were generally
          eliminated in favor of techniques using convention-
          al/available equipment or  products,  when  similar
          results could be achieved.

     •    Commonly available, conventional construction and
          process equipment and  products were selected to
          the maximum extent  possible,  whenever  such items
          conformed to the preceding criteria.

In summary, these criteria  were  directed toward  developing
remedial actions that would be effective in cleaning up the
site, environmentally sound,  economical,  and constructible
in a timely manner with generally available procedures.
PD998.051                   1-13

-------
                                           JOB SITE
                                           WAUKEGAN
                                           HARBOR
 WISCONSIN
CHICAGO


  MAMMON
         I*1
         •
         80
  ILLINOIS
                                                INDIANA
SOURCE- MASON AND HANGER (001)
W65328.00
                                         FIGURE 1-1
                                         LOCATION MAP
                                         OMC HAZARDOUS WASTE SITE
                                         WAUKEGAN, ILLINOIS
                                         EPA 13-5M28.0

-------
                         OUTBOARD MARINE CORP
                         JOHNSON OUTBOARDS OIV
                         PLANT NO 2
                   SOURCE OF BASE: MASON AND HANGER (001)
t
I
t
t
T
1-

HURON
PORTLAND
CEMENT
CO
\
       LEGEND
               PCB CONCENTRATIONS
               OVER 500 PPM

               PCB CONCENTRATIONS
               50 AND 500 PPM
BETWEEN
                                                FIGURE 1-2
                                                SITE MAP
                                                OMC HAZARDOUS WASTE SITE
                                                WAUKEGAN, ILLINOIS
                                                EPA 13-5M28.0
W6S328.00

-------
     Section 2
     PRELIMINARY SCREENING

This section  summarizes  the preliminary  screening  of the
unit processes for remedial  action  alternatives.   The unit
processes were evaluated based on the preliminary screening
criteria and in accordance with the other  site-specific  re-
medial response objectives  and  criteria discussed in  Sec-
tion 1.  The preliminary screening process narrowed the  al-
ternatives down to five or six for each area.  The retained
alternatives were evaluated  in  more detail during initial
screening (see Section 4).

PRELIMINARY SCREENING CRITERIA

All unit processes identified were  subjected  to preliminary
screening criteria to  determine  whether further evaluation
was warranted.  Development of preliminary screening criteria
was based on existing technology, availability, time require-
ments, economics, and  the  overall  remedial response objec-
tives and criteria presented in Section 1.  The preliminary
screening criteria used to  evaluate  or  eliminate  unit pro-
cesses consisted of the following:

     «    Alternatives using  unproven  or conceptual  tech-
          nologies were eliminated based on critical timing.

     •    Alternatives previously evaluated  and eliminated
          by others were eliminated when CH2M HILL concurred,
          based on elements of the NCP  (cost,  environmental
          effects, and acceptable engineering practices).

     •    Alternatives that were inefficient  or required an
          unreasonable length of time to implement were elimi-
          nated.

     •    Alternatives that  were ineffective  in  reducing
          exposure to  or  potential  health effects of  PCBs
          were eliminated.

     •    Alternatives that were judged not technically fea-
          sible were eliminated.

     •    Alternatives having conceptual costs that were not
          cost-effective (i.e.,  with costs an  order of mag-
          nitude or  more  higher than other  alternatives)
          were eliminated.

     •    Alternatives not in conformance with the site-specific
          objectives were eliminated.

     •    Alternatives not consistent with the NCP were elimi-
          nated.
PD998.052                    2-1

-------
The unit processes presented below describe various new tech-
nologies and also borrow from proven technologies  developed
for other engineering fields with similar needs.   A  list  of
potential unit processes for  remedial  action alternatives,
as well as a summary of the reasons for their further evalua-
tion or elimination, is presented in Table 2-1.  Alternatives
were divided into the following categories according to their
applicability to the problem:

          No action
          In-place destruction
          In-place fixation
          In-place PCB separation and removal
          PCB-contaminated solids removal
          Sediment dispersal control
          Surface water and groundwater control
          Bypass
          Initial solids dewatering
          Secondary solids dewatering
          Fixation
          Water treatment
          Onsite storage/disposal
          Offsite storage/disposal
          Transportation

NO ACTION

Under the No Action alternative, surface water bodies, soils,
and sediments would remain contaminated with a toxic substance
regulated under TSCA.  Socioeconomic impacts would and might
include the following (085):

     •    Loss of fish for human consumption

     •    Reduction or loss of commercial fishing

     •    Decline in property values

     •    Depressed area growth

     •    Reduction  in  recreational  activity,  such  as
          boating and sport fishing

     •    Reduction in commercial harbor  access  due  to lack
          of harbor dredging

     •    Expenditures  for laboratory  analysis  of  area
          water, soil, and biota samples

     •    Expenditures for medical services

     •    Occupational exposure

     •    Expenditures for legal services


PD998.052                    2-2

-------




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Because of the estimated large mass of uncontained  PCBs  and
their persistence in the environment,  the potential for adverse
impacts would remain high  for many years  (005, 001).  The
advantage of the No Action alternative is  that it would  not
require an immediate capital  expenditure under CERCLA.   The
No Action alternative  was  retained for further evaluation
during initial screening.

IN-PLACE DESTRUCTION

Ultraviolet/Ozonolysis

The joint application of ultraviolet (UV)  radiation and ozone
leads to significant oxidation of  chlorinated hydrocarbons.
However, no attempts have been made to characterize end-products
or their toxicity.  The  reliance on UV radiation  limits  the
oxidation action  to  exposed  surfaces.   UV radiation  would
not penetrate deep  sediment  deposits.   The technology was
designed for use  in  a closed system rather  than  in-place
(005, 057).  UV/ozonolysis has been eliminated from further
evaluation because of  its  limited effectiveness  in miti-
gating  the  PCS  problem  due  to deep  penetration  of  PCB
contamination in soils and sediments.

Biodegradation

Biodegradation involves the use of biological agents  (e.g.,
microbes, worms)  to  transform PCBs to  nontoxic  residues.
The agent must:

     •    Be site-selected to match the environment

     •    Be able to  disperse throughout  all contaminated
          layers at all depths in both aerobic and anaerobic
          environments

     •    Not be harmful within the food chain

     •    Be able to consume  all types of  PCBs present,  in-
          cluding highly chlorinated ones

     •    Not adversely disturb the existing ecology  of  the
          area

To date, problems with in-place application and viability in
an uncontrolled  environment  have not been resolved  (001,
005); therefore,  biodegradation  has been  eliminated from
further evaluation.
PD998.052                   2-11

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Chemical Oxidation

Chemical methods developed for in-place destruction  of  PCBs
have not been promising.  One process is  limited to  the de-
struction of  PCB-contaminated  oils or liquids  and  is not
adaptable to detoxification of solids in  aqueous materials.
Another process is limited to destruction of PCB liquids and
is not applicable to contaminated  dredge  sediment slurry or
in-place use.  PCBs can be extracted from contaminated dredge
sediment slurry using  an  organic solvent, but not in very
large volumes and not in-place.  Most strong oxidizing agents
have significant environmental impacts of their own and have
never been used in an open, aquatic environment  (001, 005).
Chemical oxidation has been eliminated from  further  evalua-
tion because it is not technically feasible at this time.

Radiation (Gamma and Electron Beam)

Both gamma and electron beam radiation are capable of a step-
wise breakdown in the molecular structure of complex organics.
Sufficient doses  of  gamma radiation can  carbonize organic
compounds, leaving no trace of the parent compound.   Electron
beams produce a similar degradation of organic  compounds at
lower energy levels.  PCB levels were significantly  reduced
in studies that used radiation to disinfect municipal sewage
sludge.  Byproducts and their  toxicity have  not been inves-
tigated.  No attempt has been made to test these approaches
in-place  (005) .   Radiation has been eliminated  from  further
evaluation because it  is  not technically feasible for  in-
place application at this time.

IN-PLACE FIXATION

Sorbents

Sorbents are absorbent materials employed to  treat contami-
nation resulting  from  soluble  chemicals.   It has  been sug-
gested that these materials may be used to reduce desorption
from sediments by partitioning the contaminant between avail-
able physical and chemical phases.  At equilibrium, PCB con-
centrations in each phase would have a constant ratio.  Some
sorbents may  reduce  the  availability  of  the contaminant in
the natural system because PCBs  have a stronger affinity to
the sorbent than  the sediment, which  would then reduce the
ambient  levels  of PCBs.   Large-scale experiments to  prove
effectiveness have not yet taken place.   Furthermore,  some
areas are so highly contaminated that, even with a reduction
in availability of several orders of magnitude, contamination
levels would  remain  high  (005).   Sorbent fixation has been
eliminated from  further  evaluation because  it  may  not be
effective in  reducing  PCB concentrations  to  levels below 50
ppm.
PD998.052                   2-12

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In-place Stabilization

This process involves  pumping  a mixture of portland cement
and proprietary  reagents  into the contaminated  sediments.
This is done at many points, until the  sediment  bed becomes
a series of vertical columns stacked side by side.  The mix-
ture solidifies and traps sediment particles in an  insoluble
silicon hydroxide matrix  (001, 005).   The process is similar
to grouting.   There  is no way of knowing  how  deep or how
thoroughly the stabilizing agents penetrate.

In Slip No. 3 and the Upper Harbor area, not only would com-
plete stabilization be  difficult,  but maintenance  dredging
would require special dredging techniques to avoid  equipment
damage from the hardened surface of the stabilized  sediments.
Long-term stability of the treated sediments is not yet known.
The process was first used in Japan in 1973.

In the North Ditch/Parking Lot area,  the stabilized sediments
would be rigid enough to serve as a foundation for  construc-
tion projects, but it would be  difficult to ensure  that  all
the PCBs were stabilized because of the inaccuracies  of  the
mixing process and variabilty in the depth of contamination.
This process is significantly more expensive than containing
and capping with slurry walls.  For the above reasons, in-place
stabilization has been eliminated from further evaluation.

Impermeable Membrane Seal

Placement of an impermeable membrane  over  contaminated sed-
iments in the harbor would immobilize contaminants by block-
ing interchange of sediments and interstitial water with the
water column.  Impermeable membranes  have  a finite life  in
the environment,  however, which makes this technique a tempor-
ary process.  Breakdown is accelerated by such physical forces
as debris, strong currents, severe ice, dredging activities,
boat anchors, etc.  It  would  also  be  necessary to vent the
seal to allow for escape of gases formed in the sediments as
a result  of anaerobic biological activity.   This venting
would compromise the purpose of the film  (005).   Therefore,
sealing with  an  impermeable membrane has  been eliminated
from further evaluation.

IN-PLACE PCB SEPARATION AND REMOVAL

Retrievable Sorbents

Retrievable sorbents (see sorbents for  definition)  have  the
ability to concentrate contaminants from water and  sediments,
then be collected and  removed.   Some  sorbents  are rendered
retrievable by the incorporation of magnetic particles into
the media matrix, which can then be collected  with  magnetic
devices.   However, as discussed above for  in-place  fixation
PD998.052                   2-13

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using sorbents, some areas are  so highly  contaminated  that,
even with a  reduction  of several orders of magnitude,  the
contamination levels would remain high.   Large-scale equip-
ment has not been developed for  field  implementation  (005).
Retrievable sorbents have been eliminated from further evalua-
tion because they may not be effective at reducing  PCS  con-
centrations to levels below 50 ppm.

Bioharvesting

This process uses the ability of aquatic  species  to accumu-
late contaminants in their tissues.   The  species  are placed
in the contaminated environment, then harvested and disposed
of in a  suitable  manner.  This  process is  similar  to  the
treatment of sewage sludge by water hyacinths.

This is a slow  process,  however. Harvestable aquatic  life
takes up PCBs  from water.  At  the  OMC site,  PCB contami-
nation resides largely in sediments.   Translocation of  PCBs
from soils into plant life has not been observed.  Consequently,
PCBs cannot be removed without desorption from sediments and
solution in  the water column.   Large-scale  equipment  for
harvesting has not  been  developed  for field implementation
(005) .  Bioharvesting has been eliminated from further evalua-
tion because it is not technically feasible.

Oil-soaked Mats

This approach is  similar  in concept to the  retrievable  sor-
bents in that it  relies  on the  application  of  a  medium that
has a higher affinity  for the  contaminant than the natural
system and is in  a  form  that  is readily retrievable.   Tech-
nology for this process  is conceptual  and not  available  for
field implementation (005) .   Oil-soaked mats have been elimi-
nated from further evaluation because  the method is not tech-
nically feasible.

Solvent Extraction

Solvent extraction is conceptually like retrievable sorbents.
A lighter-than-water solvent with a high  affinity for PCBs
would be mixed with  contaminated sediments.   PCBs would de-
sorb and enter  the  solvent phase, which would then rise to
the  surface  to  be collected  and removed.   Many of the best
solvents are  toxic, however, and nontoxic  solvents could
leave toxic  residues.   Questions of  efficiency,  turbidity
associated with  mixing of sediments,  and accumulation of
solvent by organic  sediments must be  addressed before  field
implementation of this process  could take place  (005) .

The Franklin Institute's proprietary process of using mineral
oil to extract PCBs from  sediments is  still in the  developmen-
tal  stage.   Mineral  oil  is  mixed with the PCB-contaminated
PD998.052                   2-14

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sediments.  The oil is retrieved when it floats to the water
surface.  PCB removal efficiencies demonstrated in the labor-
atory with thorough mixing of a PCB-contaminated sediment do
not appear to be sufficient to reduce the levels of PCB con-
tamination below 50 ppm.   Pilot  scale testing to determine
efficiencies of the process in-place could delay the project.
Senior research engineer David Kyllonen, Franklin Institute,
provided projected costs for method development and in-place
extraction of  PCBs  from Slip No. 3 and the  Upper Harbor.
The cost is estimated at $35 million  (063).  Solvent extrac-
tion has been eliminated from further evaluation.

PCB-CONTAMINATED SOLIDS REMOVAL

Freezing Before Removal

This process,  used  in the tunneling  field,  relies  on the
presence of  water-bearing permeable  soils.   Refrigeration
probes are placed  in  the sediments at  close  intervals  and
cooled  from  a  portable refrigeration unit.   Ice crystals
grow until they coalesce,  forming a wall  of  frozen  sediment
that can be lifted out with little disturbance to the remain-
ing sediment.  The process is  extremely slow, however, be-
cause each probe can only  freeze a  zone about  1^  ft  in  dia-
meter.  This process  is  not  suitable  for field implementa-
tion because of the size of the contaminated area.  The pro-
cess is also not cost-effective  because of the high energy
requirements to freeze  large  volumes.  Therefore, freezing
before removal has been eliminated from further evaluation.

Mechanical Dredges

Mechanical dredges remove  sediments  and dump them onto  an
adjacent barge.  The sediments must be  removed from the barge
and hauled to the disposal site  or  placed into a receiving
basin for dewatering of sediment slurry.  It may be possible
to fix  (chemically bind the free water;  see FIXATION) dredged
sediments without dewatering.  Some mechanical dredges create
a high degree of sediment  suspension.   Therefore, they require
installation of a  form of sediment  dispersal  control and
removal of additional  soluble  PCBs  from the ambient  water
after completion of dredging.  Another  disadvantage of mechan-
ical dredges is that placement and depth of cut are somewhat
difficult to control,  thereby impacting removal efficiencies.

Mechanical dredges would be impractical for removal of soils
and sediments  in the  North Ditch/Parking Lot area because
dewatering the area before excavation would be more  cost-
effective than dewatering the dredged soils.

Clamshell.   A clamshell dredge uses a bi-parting bucket that
is lowered to  pick  up sediments and  raised  by a hoisting
cable.  The bucket then dumps its contents onto an adjacent
PD998.052                   2-15

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barge or possibly into a hopper on the dredge barge.  An esti-
mated 15 to 30 percent of the muck sediments may  be spilled
back into the harbor during raising of a  concentional  clam-
shell bucket, and, in deeper water, losses up  to  50 percent
may occur (001) .  PCB removal efficiency is therefore reduced.
Problems with the  clamshell dredge are  that  it excavates
only the sediments directly below the bucket, to a poorly
controllable depth.  The exact location of the excavation is
also poorly controllable.   The  next  excavation may  not  be
directly adjacent  to  the first, but may  leave a  ridge of
contaminated sediments between the two.   An average produc-
tion rate is  150  cubic  yards per hour (yd3/hr)  (005) .   An
advantage of the clamshell dredge is that it may be possible
to fix dredged sediments without dewatering.

A watertight clamshell would reduce losses in the upper water
column  as  the loaded clamshell  moves through the  water.
However, sediment  suspension within  5 ft of the  bottom  is
greater with use of a watertight  clamshell compared with an
open clamshell,  although suspended sediments nearer the bot-
tom will settle out quickly  (055).

The clamshell dredge  was retained for  further evaluation
during initial screening.

Dragline.  A dragline dredge throws the bucket  ahead of  the
dredge barge, then draws the bucket  through  the sediment
back toward the barge.   The bucket is then  raised  to the
surface and emptied onto an adjacent barge.  An average pro-
duction rate is 125 yd3/hr  (005).  This type of dredge needs
a wide maneuvering space for operation.   It  also creates a
high degree of sediment  suspension.  Therefore, the dragline
dredge has been eliminated  from further evaluation.

Dipper.  A dipper uses an articulated arm to  scoop  sediment
into a bucket that is then  raised out of the water  and swung
around to a barge, over  which the bottom of the  bucket  is
opened.  An average production rate is 100 yd3/hr (005). The
digging action is more violent than that of other mechanical
dredges, causing more severe sediment dispersion.   Therefore,
the dipper dredge has been  eliminated from further  evaluation.

Bucket Ladder.  This method uses  a continuous  line  of buckets
cycling over  a  frame  that is lowered to  the  bottom at an
angle.  Each bucket digs into the bottom  and  transports  its
contents to the surface  in  a continual motion,  bucket after
bucket.  At the surface, the dredged material  is  transferred
to a  conveyor or  chute,  which  loads  the  sediments  onto a
receiving barge.   This  type of dredge would have the  most
adverse impacts on water quality  by dispersing contaminants
over a wide range.  Because the bucket ladder dredge is becom-
ing obsolete in the United  States (005),  it has  been elimi-
nated from further evaluation.
PD998.052                   2-16

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Sauerman.  To use  a  Sauerman dredge,  a crane is positioned
on one  side  of the  harbor,  supporting a vertical  tower.
From the top of the tower, an overhead cable slopes downward
to a deadman on the opposite side of the harbor.  The dredge
bucket is a horseshoe-shaped scraper  that is  suspended  from
a pulley assembly that runs  on the overhead cable.  When the
bucket is released from the  crane, it and the pulley assembly
move across the harbor by gravity.   The crane operator can
drop the bucket in  the  harbor at any desired distance from
the crane.  The bucket  is attached to  a  tagline from the
crane and is pulled  toward the crane.   This  piles  the  sedi-
ment on the bottom of the harbor,  where a clamshell dredge
or other equipment can lift  it out of the harbor.  This type
of dredge severely disturbs  the bottom sediments and creates
a high degree of sediment suspension.  Therefore, the Sauer-
man dredge has been eliminated from further evaluation.

Hydraulic Dredges

Hydraulic dredges  use a  suction  line, a centrifugal pump,
and a discharge  line to  remove  sediments.   The discharge
line normally rests on a  series of pontoon floats and can be
extended to any desired length with the aid of booster pumps.
The dredge pump discharge provides for  "built-in"  transport
of the dredged materials  over limited  distances  without  the
need for booster pumps.    Average pump production rates range
from 2,000 to 4,000  gallons  per minute  (gpm), with  a solids
production rate of  between 100  and 200 yd3/hr  (005) .   Hy-
draulic dredges require water to mix with sediments  to  form
a slurry that can be pumped.  The  sediment slurry  (about  10
percent solids) would be  piped to  a receiving basin  for  de-
watering of sediment slurry.  The  slurry water must  then  be
removed from the  sediments  and  treated.  Hydraulic dredges
create a low to medium  degree of  sediment suspension,  but
they still require installation  of a  form of sediment dis-
persal control.

Hydraulic dredges would be impractical  for removal  of  soils
and sediments in  the North Ditch/Parking Lot area  because
dewatering the area  before  excavation would  be  more cost
effective than dewatering the dredged soils.

Hopper Dredge.  This ship-shaped vessel is  self-contained
and self-propelled.  It uses an onboard suction pump to draw
sediments through a  suction  head  and  pipe into the vessel,
where it fills large hopper  compartments.   When full,  the
vessel proceeds to a specially  prepared location,  connects
to a discharge, and pumps the water-laden sediment slurry to
an on-land disposal  site.  This  dredge requires extensive
maneuvering space, which  the harbor area does not have  (005).
Therefore,  the hopper dredge has been eliminated from further
evaluation.
PD998.052                   2-17

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Cutterhead Pipeline Suction.  This dredge uses tugs for gen-
eral positioning, then uses widespread anchors to winch for-
ward.  The cutterhead rotates to loosen hard sediment and to
direct the sediments into the suction intake.  The cutterhead
is equipped with a  shroud  that  partially covers the cutter
mechanism to lessen sediment dispersion.  Sediment dispersion
may  be  reduced  by removing the  cutterhead;  however,  this
would only allow removal of loose, unconsolidated materials.
Floating pontoons support the discharge line, which can vary
from 6  to  42 inches in diameter.  This  type of hydraulic
dredge cuts  a trench  in  the bottom sediments.  The use  of
anchors and  tugs for dredge movement can  have an adverse
impact on water quality around the suction intake  (001, 005).
The  cutterhead  dredge  was  retained for  further  evaluation
during initial screening.

Dustpan.  This is a self-propelled dredge whose suction head
is shaped like a large dustpan.   Water jets are mounted along
the  leading  edge of the  intake  to scarify hard  sediments.
The  suction head and line  are mounted on a frame  positioned
in a well section that is  located in the forward part of the
dredge.  Precise control over the depth of dredging is  pro-
vided by winch cables.  Under normal conditions, the dustpan
head is capable  of  cutting  a swath of up to  36 ft  wide  with
a controlled depth.  The dustpan dredge head is capable of
removing only loosely consolidated materials.  The sediments
are  pumped  through a discharge  line  from  800 to  1,000 ft
long to a  disposal site  (001,  005).  The  existing dustpan
dredges are  located on  the lower Mississippi River and are
engaged in constant maintenance activity.  The dustpan dredge
was  eliminated  from further evaluation  because one would
probably not be  available  for use.

Mudcat.  This dredge  is  not self-propelled,  so movement is
gained by winching  to an object onbank or to deadman anchors.
The  dredge uses  a  horizontal screw  auger mounted  on the end
of a hydraulically  operated boom.  The  auger is  designed as
two  halves that  operate in opposite directions, feeding sedi-
ments to a central  suction head.  A shield can be  hydrauli-
cally lowered over  the augers to minimize  turbidity and en-
trap sediments.   The  dredge has the capability to go  to a
depth of 10 to 15  ft while cutting an 8-ft swath on the bot-
tom.  The  discharge line floats on the  water surface and
transports the  sediment  to a disposal site  (005).  Because
almost all of the PCB-contaminated sediments are deeper than
the  Mudcat dredge  can penetrate, it has been eliminated  from
further evaluation.

Sidecaster.  This type of  dredge operates  in the same manner
as the  hopper  dredge,  except that the  dredged material is
cast overboard  from either side of the  vessel,  by a boom
with a  180-degree  swing radius.   Sidecaster  dredges are not
adaptable  to  contaminated  sediments (005).  Therefore,  the
PD998.052                   2-18

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sidecaster dredge  has  been eliminated from further evalua-
tion.

Pneumatic Dredges

Pneumatic dredges  remove  sediments  and transport them in a
discharge pipeline  to  a receiving basin  for  dewatering  of
sediment  slurry.   Often,  less water  is  conveyed with the
sediments by using a pneumatic rather than a hydraulic dredge.
Ideally,  40 percent  solids could be pumped.   Therefore, it
may be possible  to fix the dredged materials without dewa-
tering the  slurry.   They create a  low  degree of sediment
suspension but still require installation of a form of sedi-
ment dispersal control.  The operation of the pneumatic dredge
may create some volatilization of PCBs into the atmosphere.

Pneumatic dredges would be  impractical  for removal  of soils
and sediments  in the North Ditch/Parking Lot  area  because
dewatering the area  before excavation would be  more  cost-
effective than dewatering the dredged soils.

Airlift.  The  airlift  dredge  works  by injecting compressed
air near the bottom of a partially submerged vertical-recovery
pipe positioned close to the bottom.  This process  causes  a
high-velocity  flow into  the submerged base  of the recovery
pipe, near the sediments,  because  of the density reduction
in the upper pipe section and the hydraulic head of the water
outside the pipe.  The bottom sediments are transported through
the pipe  to the  surface,  where  the  sediment slurry is dis-
charged into a recovery barge.  Most of the sediments raised
from the bottom are drawn into the recovery pipe, minimizing
turbidity.  The  airlift dredge is  not  self-propelled and
excavates only the sediments directly  below the recovery
pipe; however, these units  function well in deep waters  (005).
The airlift dredge is  generally fabricated  for  a  specific
purpose, and is not commonly available equipment; therefore,
it has been eliminated from further evaluation.

Pneuma.  The Pneuma dredge operates on the same principle as
the airlift dredge.  The  system  operates  using static water
head and compressed air to  collect and  carry  sediments  into
the dredging head.  Compressed air is used to empty the sedi-
ments from the dredging head into the discharge line.  Several
dredging heads operating in offset sequence combine for con-
tinuous pumping  (005).  An average  production rate for the
Pneuma is 400 to 500 yd3/hr.  The Pneuma dredge was retained
for further evaluation during initial screening.

Namtech.  The Namtech dredge operates on  the  same  principle
as the airlift dredge.   This dredge is currently being tested
under USEPA approval.   Ideally,  this  dredge  may pump at 40
percent solids, which would minimize dewatering and/or fixa-
tion requirements.  More information  should  be  available in
PD998.052                   2-19

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early August 1983.  The Namtech  dredge  has been eliminated
from further evaluation at this time because of  insufficent
information.

Oozer.   This Japanese unit combines the principles of vacuum
and water pressure with a variety of suction head  designs
for various sediments.  The USCOE views the Oozer as effective
in controlling turbidity,  and they speak highly of its capabili-
ties.  At this time,  no Oozers are operational in the United
States  (005) .  An average  production  rate  for the Oozer is
130 yd3/hr.  The Oozer dredge was retained for further evalu-
ation during initial screening.

Excavation Equipment

The term "excavation" is used  in  this FS to mean removal  of
contaminated soils using various types of tracked or wheeled
equipment.  The degree to  which  water can be excluded from
the area of removal determines the type of excavation equip-
ment to be used.  Common equipment used in excavation creates
dust and noise and requires decontamination.

Temporary support of  excavations may be required for  deep
excavations or for excavations near structures.  Excavations
could permit volatilization of PCBs.

Excavation of the harbor  sediments  has  been eliminated be-
cause it would  require  sealing off and dewatering the har-
bor.  The potential for failure of the existing  sheet piling
is too  great to  consider  excavation  for Slip No. 3  and the
Upper Harbor.

Scraper.  A scraper is a  combination  excavating  and hauling
unit.  Scrapers may be towed or self-propelled.  The scraper
cuts a  relatively thin  layer of  soil (i.e., 3 to 6 inches)
that is collected within the scraper body.  Materials can be
hauled  any distance onsite,  then  deposited in  thin  lifts  at
the disposal site.  Scrapers generally operate on a relatively
dry soil surface.  They are not suitable for deep, localized
excavation and, therefore, have been eliminated  from further
evaluation.

Front End Loader.  A front end loader is an excavating device
that operates on  a relatively dry soil surface.   Front end
loaders pick up a desired amount of material in  a front-mounted
bucket, and dump  it  into  trucks or at  a  selected disposal
area.  Typical production rates for truck  loading are 200 to
300 yd3/hr.  Front end loaders were  retained  for further
evaluation  for  removal  of fixed  solids  from curing cells
(storage areas  for  fixation processes)  and  for  excavation
from the North Ditch/Parking Lot area.
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Backhoe.  A backhoe is a self-propelled device that normally
operates from a stationary position at the side of the exca-
vation.  Backhoes excavate materials with a bucket, normally
at depths of up to  30  ft and  distances of up  to  25  ft.   The
bucket dumps the materials into  trucks.  Typical  production
rates for truck loading are 200 to 300 yd3/hr.  Backhoes are
suitable for excavation of wet soils.  Backhoes were retained
for further evaluation for removal of solids from the initial
solids dewatering  basins  (basins used to  dewater dredged
solids) and from the North Ditch/Parking Lot area.

Dragline Crane.  A dragline crane operates from a stationary
position at the side of the excavation.  Draglines  excavate
materials with a bucket attached to a cable system, normally
at depths of up to 30  ft and distances of up to 100 ft.  The
bucket can be cast some distance beyond the end of the crane
boom.  It is then pulled toward  the  crane by  a tagline,  and
soil is loaded into the bucket  through  an  open front.  The
bucket dumps the materials onto  stockpiles  or into trucks.
An average production  rate is  75 yd3/hr,  and  a dragline is
suitable for use on wet soils.  Dragline cranes were retained
for further evaluation for removal of solids from the initial
solids dewatering basins.

SEDIMENT DISPERSAL CONTROL

Dredging operations create some degree of sediment suspension
as a result of operating the dredge head.  Therefore, during
removal of contaminated  sediments,  turbidity and  sediment
dispersal must be controlled to prevent the spread of contami-
nation and subsequent degradation of water quality  (005, 001).

Single Silt Curtain

Silt curtains consist of filter fabric suspended from floats.
They are not watertight membranes.  They are  stretched  in  a
line, defining the location to be dredged.   A single curtain
flexes or bends in  response to waves, boat  wakes,  or other
water disturbances.  This may allow water to splash over the
top or rip the curtain (001) .   Single silt  curtains have
been eliminated from further  evaluation  because  they would
not provide adquate containment.

Double Silt Curtain

A double silt curtain is two flexible silt curtains in paral-
lel, with a buffer space between them to catch any spillover.
It is more effective than a single silt curtain.   Turbidity
in the buffer space may be flocculated by use of a  cationic
polymer (001).   Double silt curtains were retained  for  fur-
ther evaluation during initial screening.
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Water-inflated Dam

A water-inflated dam  is  an ellipsoidal-shaped (egg-shaped)
dam constructed from reinforced urethane rubber.  It  is  in-
stalled at  a  site  by securing the ends  to  steel piles or
deadmen onshore, and weighting the bottom of the dam to rest
on the harbor bottom.  This  would require  some disturbance
of the  sediments  under the dam  to  provide  a tight  seal.
This type of dam can withstand a  difference  in water  eleva-
tion of several feet  (001) .  Water-inflated dams are specialized
items, normally custom-fabricated for a particular application.
They are generally not cost-effective.   Therefore,  a  water-
inflated dam has been eliminated  from further evaluation.

Sheet Piling

Steel sheet piling could also be  used for sediment dispersal
control.  Sheet piles alone are not watertight.  To minimize
movement of water  and sediment  outside  the  piling,  a lower
water level would  be maintained  inside  the  piling.  This
would require pumping  and treatment  of  harbor water.  This
type of system would  reduce  migration of PCBs dissolved in
the water  (by dredging activity)  across  the  barrier because
water would tend to flow into the contained area through all
openings in the  sheet pile barrier.   Sheet piles were  re-
tained for further evaluation during initial screening.

SURFACE WATER AND GROUNDWATER CONTROL

Cofferdam

The penetration of PCBs is apparently too deep in some areas
to permit PCB removal without  supporting the excavation to
protect existing  facilities.   The deep  contaminated  sedi-
ments would be excavated  with dredging equipment, such  as  a
clamshell  (001).   Before  the deep sediments  could be exca-
vated, the surface water  (e.g., harbor water) would have to
be controlled.  A  cofferdam  could be built  to control sur-
face water  inflow.   The  water  within the cofferdam limits
would be pumped through  the  water treatment  system  to main-
tain a lower water level  inside the  cofferdam.   A localized
cofferdam in Slip No. 3 to remove the deep contaminated  sand
and silt was retained  for further evaluation during initial
screening.

Dewatering

Open-cut excavation would require some  groundwater  control.
Applicable dewatering techniques  include using sheet piles
or  slurry  walls to  control  groundwater inflow,  and  well
points and pumping to remove groundwater.   Well points  and
pumping can be  used  alone when structural support of exca-
vations is not required.   Soils  and  sediments would then be
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excavated with conventional excavation equipment.  Dewatering
techniques for the North Ditch/Parking Lot area and the local-
ized area in Slip No. 3 were retained for further evaluation
during initial screening.

Injection of Grout

Grouts consist of liquids or suspensions that may be injected
into the  ground  and that subsequently  harden.   They fill
soil voids and bind soil particles together to form an imper-
meable mass.  In essence, they can be used to  form  in-place
cofferdams around and under the site.  It is not possible to
fully evaluate the grout's effectiveness for reducing ground-
water flow.  This is because it is very  difficult to  deter-
mine where the injected material flows to since it will take
the path of least resistance.  It is generally impossible to
be sure that no "windows" in the grouted zone remain ungrouted.
The method also would  not  be cost-effective.   Injection of
grout has been eliminated from further evaluation because it
is neither technically viable nor cost-effective.

Sheet Piles

Steel sheet piles  would be installed down  to  the glacial
till layer to control the movement of groundwater.  However,
they would leak at  the interlocks.   For economy, they  are
usually removed after excavating, if possible.   Sheet piles
were retained for further evaluation for control  of ground-
water inflow  in  the North Ditch/Parking Lot  area.   Sheet
piles with bracing  can  provide  temporary support of struc-
tures during  excavation and  dewatering.   Sheet piles with
bracing were retained  for further evaluation for  structural
support of the North Ditch and Crescent Ditch.

Slurry Walls

Slurry walls  would  be  constructed by excavating  a  trench
down to the glacial till layer.   During excavation,  the trench
would be kept filled with a slurry mixture to prevent movement
of groundwater and  trench collapse.  After excavation,  soil
would be placed in  the  trench and mixed  with  the slurry to
form a low-permeability  zone.   Slurry walls  are relatively
impervious, with typical permeabilities of about 10 7 centi-
meters per second  (cm/sec).  Slurry walls were  retained  for
further evaluation  for  control  of  groundwater flow in  the
North Ditch/Parking Lot area.

BYPASS

A bypass diverting surface water flow around the highly con-
taminated portions of the North Ditch would eliminate further
contamination of Lake Michigan by PCB-laden sediments eroded
from the North Ditch.  The erosion results from  essentially
noncontaminated sources of water (e.g.,  stormwater,  cooling
PD998.052                   2-23

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water) flowing through  contaminated  portions  of the ditch.
The bypass would  collect all surface water that  now runs
into the North Ditch  and direct  it  to Lake Michigan by the
shortest feasible route without contacting PCBs.  This could
be accomplished with underground pipe or an impervious lined
open ditch.  This  would have to be  done  before the North
Ditch could be excavated.

Grading

The North Ditch/Parking Lot area would be regraded to direct
surface flow away  from  the  North Ditch.   This would reduce
but not eliminated the  amount of  surface  water  available  to
erode contaminated sediments from the North Ditch.  The con-
taminated sediments could thus still be transported  to  Lake
Michigan.  Therefore, grading of the North Ditch/Parking Lot
area without a pipeline or  ditch has been eliminated  from
further evaluation.

Pipeline

A gravity  pipeline bypass could be  constructed to divert
surface water flow around the  highly contaminated areas of
the Crescent Ditch and  Oval Lagoon.   This  bypass  would  col-
lect drainage from the  36-inch-diameter storm  sewer  (that
flows north at the west edge of  CMC's  property), the OMC
property roof drains, and regraded areas  north  and  south  of
the Crescent Ditch.  This bypass would be a gravity pipeline
discharging to Lake Michigan.  It would be constructed along
the sheet piling north of the east-west portion of the North
Ditch.  The Parking  Lot area would  be  regraded to divert
surface water flow to catch basins.  A pipeline was retained
for further evaluation during initial screening.

Lined Open Ditch

The process described above, under Pipeline, could be imple-
mented using a lined open ditch in place of a pipeline along
the east-west portion of the North Ditch.   A lined open ditch
was retained for further evaluation  during initial screening.

Temporary Pumphouse

A temporary pumphouse could be installed  to intercept  flows
from the storm sewer on the west side of the OMC building to
prevent discharge  through the  Crescent Ditch.  The  storm-
water would be pumped to Lake  Michigan.  A temporary pump-
house would require  a number of large pumps.   A  full-time
operator would probably be  needed during  construction.   A
temporary pumphouse has been eliminated from further evalua-
tion because pumping is generally not cost-effective compared
with gravity flow.
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INITIAL SOLIDS DEWATERING

Dredging with  a  hydraulic or pneumatic  dredge produces a
slurry of water  and solids.   To separate the  slurry  water
from the contaminated  sediments,  initial solids dewatering
would be required.   Solids could be  dewatered by gravity
and/or mechanical means.

No Dewatering

Contaminated sediment slurry would be disposed of in whatever
form it  was  extracted, usually containing  between 10 and
25 percent solids by volume.  The dredged sediments must  be
nonflowable to be accepted at a licensed chemical waste land-
fill  (40 CFR  761.75).   Since the sediment slurry would be
flowable, the  only  practical option  for sediments  greater
than 500 ppm would be disposal by incineration.  To minimize
the energy requirements to drive off excess water, incineration
would also require dewatering.  Therefore, the No Dewatering
alternative has been eliminated from  further evaluation.

Lagoon on OMC Property

Construction of  a  dewatering lagoon  for dewatering solids
could be undertaken  on a large fenced parcel  owned by  OMC
that lies due  east  of Slip No. 3  (001) .  This area could
accommodate a  diked area of  up  to  1,200 by 800  ft using
dikes above grade.   A  lagoon could also be  constructed on
vacant land west of the railroad tracks and northwest of the
harbor  (002).  This  property is  0.5 mile from the  nearest
harbor access.   A  pipeline would be  required  to  transport
dredge sediments across a public roadway,  across several
railroad tracks,  and through private property.   The OMC prop-
erty is the preferred lagoon location.

Specific dimensions of the lagoon would be based on the type
of dredging option selected, a minimum overflow rate to allow
for 2 hours detention  (004), and a minimum water height above
the sediment  bed for volatilization  control.   The lagoon
would be constructed above ground because of the high ground-
water table and construction debris buried in the area.  The
bottom and sides of the lagoon would be sealed to  prevent
contamination of groundwater.  Supernatant would be decanted
for treatment  (005) .  A  lagoon on OMC property was  retained
for further evaluation during initial screening.

Portable Sediment Processing System

A portable sediment  processing system consists of elevated
settling bins  with  steep-sloped sides.  Elevation  of the
bins provides  head  for a bank of hydrocyclones,  in which
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solids that are heavier than water are separated by centrif-
ugal force.  Sediment slurry then flows into a Uni-Flow bag-
type filter.  Pilot  scale  studies  indicate  that the system
operates successfully; large-scale operations have  not  been
undertaken  (047).  This system  can be easily installed and
removed after use.

Two clarifier bins  in a USEPA demonstration project  (047)
each had a capacity of 36 yd3 with 144 square feet  (ft2)  of
surface area.  The process capacity was 1,500 gpm of slurry.
Four bins  could conceivably  process  slurry  from an average
dredge  (dredge  pump range 2,000-3,000 gpm).  The settled
solids could be loaded directly onto trucks by gravity flow.
The number of  hydrocyclones  and Uni-Flow filters must be
sized by the physical  characteristics of the dredged sedi-
ments and  the solids  loading rate expected.  Because of the
low expected specific gravity  (1.3)  of some of  the dredged
sediments,  hydrocyclones  may  not  be  effective in  this
application, thus producing a greater  solids loading to the
bag filters.  This  could  cause excessive head  loss at  the
filter surface and require frequent backwashing.  Additional
elevated bins  for settling may  reduce the problem.   The
portable sediment processing system was retained for further
evaluation during initial screening.

North Ditch as Dewatering Basin

The North  Ditch could conceivably act as a dewatering basin.
The east-west portion of the North Ditch is  estimated  to be
1,800 ft long, 20 ft wide, and about  3 ft deep.   If the sol-
ids settled  evenly  throughout  the  length of the  ditch  and
the supernatant was  collected over a  weir at the  end of the
ditch, it  might hold the sediments produced by  1 day of dredg-
ing operations  (assuming  dredge capacity of 150 yd3/hr and
solids 1 ft deep).  Using the Oval Lagoon and Crescent Ditch
would increase  the  capacity  for solids removal.  Initially
excavating the North  Ditch to  increase its  size would also
provide additional  capacity.   The  settled solids would be
periodically removed  for disposal.  The North Ditch was re-
tained for further evaluation during  initial screening.

Barge Storage

Contaminated sediment  slurry  removed from the harbor could
be pumped  to barges  for dewatering.   The supernatant would
be decanted with  the use  of  submersible pumps,  treated  for
contamination, and  disposed  of.  The sediment would be re-
moved from the  barges after 2 months  of dewatering (004),
fixed, and disposed  of.   Barges were  retained  for  further
evaluation for initial solids dewatering in Slip No. 3 during
initial screening.  Barges have been  eliminated from further
evaluation for initial solids dewatering in the Upper Harbor
because of the large storage volume required.
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Thickening with Other Project Area Solids

Solids from other project areas that are relatively dry when
excavated may  be  mixed with dredge slurry  to produce the
desired moisture  content  for  fixation.   This  would minimize
the degree of  dewatering  required for the  dredged slurry.
Possible sources  of  relatively dry excavated material  are
the stockpile of  sand near the OMC Parking Lot from previous
excavation and material above the water table that is easily
accessible on  the project site.   Addition of other project
area solids was retained  for  further  evaluation  during  ini-
tial screening.

Slip No. 3 as Dewatering Basin

Slip No. 3 could be used as a dewatering basin.  Sheet piling
with walers around the slip would need to  be installed  to
prevent collapse  of  the existing  sheet piles.  A  cofferdam
with slurry wall would need to be installed across the mouth
of the slip to create  a basin.  Supernatant could  be  pumped
from the surface  of  the slip and treated before  discharge
back to the harbor or  to  a  sanitary sewer.  Solids could be
removed for fixation and/or disposal  by  a clamshell dredge.
Using Slip No. 3  as  a  dewatering  basin would not  be  cost-
effective.   Therefore, Slip No. 3 as  a dewatering  basin  has
been eliminated from further evaluation.

Dehydro Drying Beds

Dehydro drying beds  assist  sedimentation  with the use of a
permeable mat  and a  vacuum system to speed dewatering.   A
flocculant is  added  to the contaminated  sediment slurry.
The sediment slurry  is then distributed  over the  permeable
mat, and water drains  through  the mat.   A vacuum  system is
activated when the volume of  the  sediment  slurry  has been
reduced by half.   The vacuum holds until the sediment slurry
cracks, allowing air through the bed.   Ninety percent of the
moisture is removed  with  this method.  The supernatant  is
collected in a central sump, and the sediment is then scraped
off and disposed of.   Loading rates are high, since evapora-
tion is not required to achieve sludge drying (061).  Dehydro
drying beds have  been eliminated from  further evaluation
because to match  the capacity of the dredging equipment,
they would require as much space as the lagoons.   In addition,
the cost of installation  is greater,  and the solids  would
have to be removed daily.

Gravity Thickener

A gravity thickener resembles a conventional circular clari-
fier,  except that it has a greater bottom slope.   A predeter-
mined hydraulic loading rate is obtained before contaminated
PD998.052                   2-27

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sediment slurry  is  added to the  thickener.   The sediment
slurry enters at the center of the thickener  and the  solids
settle into a blanket at the bottom.   The sediment slurry is
agitated gently to dislodge trapped gas, prevent bridging of
the solids, and keep the  sediment slurry moving toward the
center removal well.  The supernatant passes  over a weir  at
the outer  margin  of the thickener  (062).   Typical  harbor
sediments  have a  specific  gravity greater than the design
specific gravity  for  the unit and,  therefore,  may cause
torque overload.  In addition,  the removal of  solids  from
the thickener  using conventional pumping  equipment  would
result in  operational  difficulties.   Because the use  of  a
gravity thickener would  not  be  cost-effective due to  high
capital cost, gravity  thickeners  have  been eliminated from
further evaluation.

SECONDARY  SOLIDS DEWATERING

The secondary solids from  the  water treatment  plant  would
consist mostly of chemical floe.   The concentration of solids
taken from the sedimentation tanks would be  approximately 2
to 3 percent.  To dewater these solids, either a belt  filter
press could be used, which would bring the solids concentra-
tion up to about 40 percent, or the solids could be returned
to the dewatering basins and treated with other solids.

Mechanical Dewatering/Belt Press

Mechanical dewatering with the use of belt  pressure  filters
has been employed in wastewater treatment plants in the United
States since 1971.  This  process  requires a fairly homoge-
neous size of material in order to reduce damage to the belt
and equipment  (062).   Removal  of large  and small objects
would be required before the belt press  could  be  used in
order to have a homogeneous mixture to  process.  Mechanical
dewatering was retained for further evaluation during  initial
screening.

Air Dry and Treat with Other Solids

The secondary solids removed in the water  treatment process
could be collected  in  the sedimentation basin.  After all
water treatment  is  completed and  the  basin  drained,  the
solids could be air dried and treated with the other solids.
Treating with  other area solids  was retained for further
evaluation during initial screening.

FIXATION

Fixation is  a  chemical  process  that  binds,  hydrates,  or
otherwise  removes free water.  Chemical  fixation of  sludges
and soils  has proven effective for many classes of hazardous
PD998.052                   2-28

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waste  (089) .  Fixing  agents  such as portland  cement,  poz-
zolan, flyash,  lime,  sodium  silicate (005), and/or certain
polymers such as Locksorb  (051)  are mixed or injected into
the sludge or soil.  The material becomes like concrete or a
loose aggregate.

Fixation could  eliminate the  need  for extensive  initial
solids dewatering  if  the water  content  is  not excessive.
The advantage to fixing relatively dry excavated material  is
ease  of  transporting  to obtain  a  nonflowable consistency
within the "given" time frame.  Train, barge, or truck could
be used to transport  the  solids.   The disadvantage of this
alternative is  the added cost of the  fixing agent and of
transporting and disposing of the extra  volume.   Fixation
was retained for further evaluation during  initial screening.

WATER TREATMENT

A limit of  1 ppb PCB  concentration  in water discharges has
been set by USEPA  (005).  Therefore, a water treatment system
is necessary to treat  contaminated  water that results from
the cleanup operation.  The contaminated water would include:

          Slurry water from dredging harbor  sediments
          Water used to flush slurry lines
          Groundwater removed during area dewatering
          Rainwater and leachate (if a lagoon is used)
          Water used to clean equipment

No Water Treatment

Contaminated water would not be treated but disposed of either
with the solids or alone in an appropriate  containment vessel.
A very large volume of water would have to  be contained, which
would be less cost-effective than treating  the water.  There-
fore, the No Water Treatment alternative has been eliminated
from further evaluation.

Flocculation/Sedimentation

Flocculation/sedimentation involves the addition of a coagu-
lant material  (i.e.,  alum or  certain cationic polymers)  to
coagulate and settle  colloids  out  of solution  (001,  005).
The water to be treated would contain PCB-contaminated solids
that  need  to  be removed.  Flocculation/sedimentation was
retained for further evaluation during initial screening.

Filtration

Contaminated water could be  filtered to remove essentially
all suspended solids.   Flocculation/sedimentation  would be
required before filtration to reduce blinding  of the  filter
PD998.052                   2-29

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surface.  Filtration is based on  the entrapment  of  contami-
nated solids too  small  for removal by sedimentation  (001,
005).  Filtration was retained for further evaluation during
initial screening.

Carbon Adsorption

Adsorption is the result of interactions between the sorbate
and the surface of  the  sorbent.   Carbon particles  have  an
extensive surface area  that  attracts  and holds hydrophobic
organic materials.  Carbon  is  highly  effective in removing
the soluble fraction of PCBs to below discharge limits (less
than 1.0 ppb) (004, 005, 037).  Sedimentation and filtration
are necessary prerequisites to prevent blinding of the carbon
surface.  Carbon adsorption was retained for further evalua-
tion during initial screening.

Klensorb

Klensorb is an alternative to activated carbon (056) and can
use the same hardware as carbon adsorption.  It  may be more
cost-effective in removing those organics that are difficult
for activated carbon (i.e., oil)   (056).  Since PCBs are oily,
oils may pass through the  filtration  process and blind the
carbon  surface.   However,  at this  time,  laboratory tests
have shown that activated carbon can meet discharge require-
ments  (004)  on  Waukegan Harbor  slurry water,  but  no
laboratory  tests  have  been  conducted to  confirm the
effectiveness of  Klensorb.   This  alternative would require
laboratory scale  testing to  determine  the  effectiveness of
the technology, as well as its cost-effectiveness.  Klensorb
will not be  considered  for  further evaluation  at this time
because activated  carbon  has been  shown to  be effective.
If, however, the activated carbon should fail because of the
oily nature of PCBs, Klensorb should be reconsidered.

Ultraviolet/Ozonolysis

See IN-PLACE DESTRUCTION,  earlier in  this  section,  for a
description  of  the  UV/ozonolysis  technique.   This  process
works well with liquid  streams because large quantities of
PCBs can be removed. It requires  a  large surface  area and a
thin water  film to be  effective  (005, 057).  Destruction
efficiencies are  approximately 95 percent.  UV/ozonolysis
has been eliminated from  further  evaluation because it may
not be effective in reducing PCBs below 1 ppb.

Catalytic Reduction

Catalytic reduction of  PCBs using  a copper-iron  catalyst is
in  the  conceptual stage.   Reduction of the  chlorine  func-
tional groups on PCBs would result in  a hydrocarbon skeleton,
PD998.052                   2-30

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which would be  susceptible  to  biochemical oxidation.   How-
ever, it is unclear whether  reduction  of PCBs really takes
place or whether the apparent product  is  a  result  of  reten-
tion on the catalytic column (005).   Catalytic reduction has
been eliminated from further evaluation  because  it is  still
in the conceptual stages of development.

Wet Oxidation

This process oxidizes  organic  materials underwater by  the
addition of pressurized oxygen and elevated  temperatures.
Organic materials are converted predominantly to carbon diox-
ide, releasing  energy  in the form of  high-pressure  steam.
Steam can  then  be  recovered for  operation  of the  process
with about 80 percent  efficiency  (059).   Wet oxidation has
been eliminated from further evaluation because of excessive
energy requirements, and because it would not be cost-effective
in this application.

High-Efficiency Boilers

High-efficiency boilers can be used to decontaminate liquids
having PCB concentrations between 50 and 500 ppm.  This method
of  thermal destruction  is  very efficient,  reducing  PCB
concentrations  to  0.0  ppm (057).   High-efficiency  boilers
have been  eliminated  from further evaluation because  they
have high  energy requirements and are  not cost-effective  in
this application.

Chlorinolysis

This established technology  converts  chlorinated hydrocar-
bons to carbon  tetrachloride.   The technique involves  the
addition of chlorine under  high pressure and low  tempera-
tures without the use of a catalyst.  Other molecules may be
produced,   depending on  the  purity of the  starting  liquid.
Chlorinolysis has not been specifically  applied  to PCB  con-
taminants  (057).   Chlorinolysis has been eliminated from
further evaluation because unknown byproducts may be produced.

The Goodyear Process

This process involves the addition of  sodium  naphthalide  to
the PCB-contaminated liquid.  The reagent  removes  chlorines
from PCB molecules and forms sodium chloride  (NaCl) and non-
halogenated polyphenyls  rapidly at  room  temperature.   The
Goodyear process appears to work  well  on  Aroclors  in  the  50
to 500 ppm range.  Large-scale development has not been devel-
oped for field  implementation  (057).   The Goodyear process
has been eliminated  from further  evaluation because  it  is
not readily available and has not been field tested.
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The Sunohio Process

Sunohio has developed  a  process  called PCBX, which  breaks
PCBs in transformer oil  down  into their primary components
of biphenyl and chlorine.  This  process  appears to be able
to handle a wide  variety of PCs-contaminated fluids  and  a
wide range of  concentration.   Field  equipment is available
(057).   The Sunohio process has been eliminated from further
evaluation because use of the process has been  limited to
treatment of  transformer oils, not  sediment-laden  aqueous
streams containing PCBs.

Use  of  North  Shore Sanitary District  Wastewater  Treatment
Facility

Contaminated waters could be taken to the North Shore Sanitary
District wastewater treatment  plant,  but  treatment for PCB
removal is not currently available at the plant.   Because
the North Shore facility is currently in use, it is unavailable
and therefore, has been eliminated from further evaluation.

ONSITE STORAGE/DISPOSAL

Disposal of dredged materials  that contain PCBs is regulated
by 40 CFR 761.60(5).   The  three  disposal options available
are:  (1)  in an incinerator that complies with  40 CFR 761.70,
(2) in a chemical  waste  landfill that complies with 40 CFR
761.75, or  (3) upon  application, using  a  disposal method
approved by the USEPA Regional Administrator.

Only two options  are  available for disposal  of soils  that
contain PCBs,  as  regulated by 40 CFR 761.60(4):   (1) in an
incinerator that  complies with 40 CFR 761.70,  or  (2)  in  a
chemical waste landfill that complies with 40 CFR 761.75.

CERCLA 101(24)  (PL 96-510) defines remedial action to include,
but not be limited to, "such  actions  at  the  location of  the
release as storage, confinement,  perimeter protection using
dikes, trenches or ditches, clay cover...dredging or excava-
tion. . .collection of leachate  and runoff...and  any monitoring
reasonably required to assure  that such  actions protect  the
public health  and welfare and  the environment."

If the PCBs could be removed from the dredged material before
disposal, the  large quantity of  sediments would not need the
USEPA Regional Administrator's approval for disposal.

Landfill

A permanent storage facility  could be constructed under  the
OMC Parking Lot area south of  the North Ditch.  The  facility
would have to  meet USEPA and IEPA requirements  for an Annex II
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landfill unless a waiver is obtained from the Regional Adminis-
trator  (40 CFR 761).  The landfill would be  large  enough  to
store 224,300 yd3 of contaminated materials  with  25  percent
excess capacity.  A slurry wall would be constructed around
the perimeter down  to  the glacial till layer.  This would
allow for dewatering during construction.

The facility would  be  lined with 5  to  10  ft of compacted
clay.  After filling, it would be capped with 3 ft of com-
pacted clay and resurfaced for use as a parking lot.  A leach-
ate collection system, embedded in gravel and sandwiched  in
the clay liner, would lead to manholes for pumpout.  Ground-
water monitoring wells would be installed around the facility
to measure background water quality  (001).   Construction  of
a secure landfill at the Parking Lot would involve a number
of technical and environmental problems.  Since much of  the
soil under the Parking Lot is contaminated,  it would have to
be removed and stored during  liner construction,  then later
replaced in the  fill.  Large  quantities of  liner materials
would have to be imported.  Because of the large quantity of
material to be  disposed  of,  the  completed  landfill would
have to  extend  above existing grade.   The  landfill would
remain partially below the water table, and  extremely close
to Lake Michigan.  These conditions do not meet 40 CFR 761.75
requirements and would necessitate obtaining  a waiver.  Even
if waivers were  obtained,  this alternative  would be less
cost-effective  than  containment/encapsulation. For  these
reasons, a landfill  (as described above) on CMC property has
been eliminated from further evaluation.

Containment/Encapsulation

Containment/encapsulation, to mitigate the environmental ef-
fects from uncontained PCBs,  would  involve  sealing off the
contaminated area.   Slip No. 3 and the Oval Lagoon area would
be filled in with other PCB-contaminated sediments or soils.
The contaminated sediments would be capped with 3  ft of com-
pacted clay,  and covered with a synthetic liner (impermeable
membrane,  concrete,  or  asphalt)  to an elevation above
the 100-yr flood plain.  A  slurry wall  would be constructed
around the containment area down to the glacial till layer.
Groundwater monitoring wells  would  be  installed around the
containment area to measure background  water quality (001).
This method would  require  the Regional  Administrator's ap-
proval and would have to meet the requirements  set forth  in
40 CFR 761.60 and 40 CFR 761.75.  Containment/encapsulation
was retained for further evaluation  for Slip No.  3 and the
North Ditch/Parking Lot area.

PCS Extraction

Pollution Science International is  developing a process of
PCB extraction  (089,  090)  under  a USEPA-approved  research
PD998.052                   2-33

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and development project now in progress.  This process entails
extracting PCBs from  sediments,  disposing of the sediments
locally, and  sending  the concentrated PCBs  to  a licensed
chemical waste landfill or incinerator.  The main concern is
process economics.  The equipment is reported to be a noncon-
ventional use of  conventional and available  equipment.   The
process needs to  be demonstrated under this  nonconventional
application.   Because  of a lack of available information,
extraction has been eliminated from further consideration at
this time.  When more information becomes available (expected
in mid-October or November),  this alternative should be con-
sidered in conjunction with containment/encapsulation.

Chemical Destruction

Most processes for destruction of PCBs by chemical treatment
have been demonstrated with liquids only.  A few conceptual
processes may be  applicable for solids.  The microwave plasma
method, developed by Lockheed, destroys PCBs by a 15-kilowatt
microwave plasma  reaction, and yields products  of carbon
dioxide, water, and potentially hazardous products of carbon
monoxide and  organochlorines.   The  process may be  able  to
destroy PCB concentrations between 50 and 500 ppm effectively,
but further research is required (057).  The gamma and elec-
tron beam radiation technique, described  under  IN-PLACE  DE-
STRUCTION  (earlier  in this section) ,  may be  effective  for
destruction of PCBs  in sediments and soils  in  conjunction
with  containment/encapsulation   (005).   However,  chemical
destruction has  been  eliminated  from further  evaluation
because it is still in the developmental stages.

Biological Breakdown

Biological breakdown in conjunction with containment/encapsu-
lation was considered.  All biological disposal  methods  are
based on the  ability  of  microorganisms to break down toxic
materials.  There are many problems associated  with biolog-
ical degradation, such as:

     •    Most systems need to remain aerobic.

     •    Biological  degradation rates   are temperature
          dependent.

     •    Complete contact with  the  toxic material must be
          made (usually very time-consuming).

     •    The biologically active material must  be  disposed
          of.

More  research  is  needed  in this area  to  make it a viable
solution  (057, 005,  001).   Therefore, biological breakdown
has been eliminated from further evaluation.
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Incineration and Landfill Ash

A mobile  field  incinerator  could be used onsite to destroy
contaminated sediments and soils.  Residues may weigh between
50 and  85  percent  by weight of the original  material,  and
could be  used  as fill elsewhere  onsite.   The incinerator
used for PCB destruction must meet the requirements of 40 CFR
761.70, which states that  incineration of PCB-contaminated
sediment slurry must be brought about by maintaining a tempera-
ture of 1,200 degrees centigrade  (°C)  with a  2-second retention
time in the  secondary  combustion unit and 3 percent excess
oxygen in  the stack  gas, or by maintaining  a  temperature  of
1,600°C with a  1.5-second  retention time in  the  secondary
combustion unit  and  2 percent excess  oxygen  in the stack
gas.  Both must have a combustion efficiency of 99.9 percent
or greater.  USEPA and IEPA  monitoring  requirements must
also be met.  Onsite incineration was retained for further
evaluation during initial screening.

Water Disposal

Treated water with PCB concentrations  less  than  1  ppb  would
be conveyed back  to  the  harbor or to  a  sanitary  sewer  for
disposal.   All waters would be sufficiently treated to reach
the required discharge level  for PCB  concentration.  Water
disposal was retained for further evaluation  during initial
screening.

OFFSITE STORAGE/DISPOSAL

Three disposal  options are  available  for dredged materials
that contain PCBs  (40 CFR 761.60) are: (1) in an incinerator
that complies with 40 CFR  761.70,  (2) in a chemical waste
landfill that complies with 40 CFR 761.75, or  (3) upon appli-
cation, using a disposal method  approved by  the Regional
Administrator.

For PCB-contaminated soil,  only  two options are available:
(1)  in an  incinerator that  complies with 40 CFR 761.70, or
(2)  in  a   chemical  waste  landfill that  complies  with
40 CFR 761.75 unless  a  waiver from these  requirements is
obtained.

The definition  of  remedial  action does not  include offsite
storage/disposal "unless the  President determines  that  such
actions (A)  are more cost-effective  than other  remedial
actions,  (B)  will create new  capacity  to  manage...hazardous
substances in addition  to  those  located  at  the  affected
facility,   or (C) are necessary  to protect public health or
welfare or the environment from a present or  potential  risk
which may  be created by  further exposure to  the  continued
presence  of  such  substances  or  materials"  (CERCLA
101 (24)  (PL 96-510)) .
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Landfill

Contaminated solids could  be  taken to a licensed  chemical
waste landfill site for  long-term storage/disposal.  Land-
filling does not  destroy the contaminant  but  contains it
from further degrading  the environment.   Offsite  landfill
sites that were retained for  further  evaluation  during ini-
tial screening are listed below:

SCA Chemical Waste Services-—Model City,  New  York.  This
facility is licensed  to  receive PCBs  but is more than 500
miles from the OMC site.  There is barge service to the site.

Clermont  Environmental  Reclamation—Williamsburg,  Ohio.
This facility is  licensed  to  receive  PCBs  but  is more than
350 miles from the OMC  site.   This site has a USEPA waiver
from depth to groundwater  requirements  (40 CFR 761)  (034).
Truck service is  provided  to  the site.   CECOS was  recently
bought by Browning Ferris  Industries  but shall be  referred
to in this report as CECOS.

Chemical Waste  Management—Calumet City,  Illinois.  This
facility is not licensed  to receive PCBs.   It  is in an in-
dustrial area with rail  access  75 miles from the OMC site.
Appropriate state and Federal  permits  would  have to be
secured.

Browning Ferris  Industries—Lake  County,  Illinois.  This
facility, 13 miles from  the OMC  site,  is  not  licensed to
receive PCBs.  It is  in a rural  setting,  and  28 buildings
(mostly residences) are  within  a 0.5-mile radius  of  the
facility.  This facility would  require  a USEPA waiver from
depth to groundwater requirements  (40 CFR  761)   (034) .

New Site No. 1—Lake County,  Illinois.  This potential land-
fill site, 7 miles from the OMC site, is in a  rural setting
with commercial,  industrial,  and residential uses within  a
2-mile radius (002) .

New Site No. 2—Lake County,  Illinois.  This potential land-
fill site, 10 miles from the  OMC  area,  is  in a rural/industrial
setting, with 38  structures located within  a 0.5-mile radius.
Four housing developments, along  with commercial,  institutional,
and industrial uses, all lie  within a 2-mile radius  (002).

Airport Site—Lake County,  Illinois.   This potential land-
fill site, approximately 5 miles  from the  OMC  site,  is in  an
industrial setting.  The Port of  Waukegan  has  suggested the
availability of property near the  Waukegan  airport  as a pos-
sible landfill site.

Environmental Services,  Incorporated—Boise,  Idaho.   This
facility is licensed to receive PCBs, but  is about  1,500 miles
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from the OMC site.  There is rail service to within 31 miles
of the site.

Incineration

See ONSITE STORAGE/DISPOSAL, earlier in this  section,  for  a
description of this technique.  Contaminated sediment slurry
would have  to  be transported to  an  approved incinerator.
Transporting, rehandling, and storage requirements for incin-
erating offsite render this option economically  infeasible.
Offsite incineration has been eliminated from further consid-
eration.

TRANSPORTATION

There are three possible means of transporting PCB-contaminated
materials to offsite disposal:  truck, barge, and train.  These
transportation modes were all retained for further evaluation
during initial screening.
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     Section 3
     RECOMMENDED ALTERNATIVES FOR INITIAL SCREENING
The unit processes  retained  for further screening were as-
sembled into alternative remedial action systems for initial
screening.  Figures 3-1 through 3-5 present the alternatives
considered for each area.  The  following paragraphs describe
these flow diagrams.

SLIP NO. 3

Alternative 1:  Dredge-Fix-Dispose

A sediment dispersal control device, consisting of  a double
silt curtain or sheet piling, would be  installed  across  the
mouth of Slip  No.  3.   Sediments in excess  of 50  ppm PCBs
would be  removed  with a mechanical  dredge and placed in
trucks for transport  to  an onsite batch plant.   Sediments
could also be removed with a pneumatic  dredge and the  sedi-
ment slurry pumped through a pipeline to the batch plant.

A mechanical dredge would be used to dredge the area of deep
contaminated sand and silt near the OMC outfall.  This deep
dredging would be performed  inside  a  cofferdam.   The water
level inside the cofferdam would be kept lower than outside
to cause water flow toward the  contained area.  The removed
water would be routed to an onsite water treatment plant for
suspended solids and PCS removal  (to 1  ppb  PCBs), then dis-
charged to the harbor or to a  sanitary sewer.  Sediments
could be thickened  by  adding other project area solids  to
minimize fixing agent addition.  The sediment  would then  be
fixed at the batch plant by adding portland cement,  Locksorb,
or another fixing agent  to hydrate the excess water.  The
mix would be transported to curing cells.   The fixed solids
would be cured until they were nonflowable.  This  is expected
to take about 1 day.  The fixed solids would then  be removed
from the curing cells by front  end  loaders for transporta-
tion by truck, train,  or barge to an approved disposal site.

Alternative 2:  Dredge-Dewater-Fix-Dispose

For this alternative,  a sediment dispersal control device as
described for Alternative  1  would  be  installed across the
mouth of Slip  No.  3.   Sediments in excess  of 50  ppm PCBs
would be removed with  a  hydraulic dredge and  the sediment
slurry pumped  through a pipeline  to  the  initial  solids
dewatering basin.  Dredging  of  the  deep contaminated  sand
and silt would be performed as  described for  Alternative  1.
Solids would be dewatered using one of  the following types
of initial solids dewatering basins:
PD998.053                    3-1

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     •    Solids dewatering in the east-west portion of  the
          North Ditch would require solids removal after one
          8-hour day of  dredging  and  16  hours  of settling.
          Solids would then be  removed by backhoe, loaded
          into trucks,  and transported to the batch plant.

     •    A clay-lined dewatering lagoon would be constructed
          on OMC property for solids dewatering.  Solids and
          1 ft of the clay liner would be removed by dragline
          2 months after dredging activities were completed,
          loaded into trucks, and  transported  to the  batch
          plant.

     •    Solids dewatering would  be  effected  in bins/cy-
          clones/filters and solids removed after one 8-hour
          day of  dredging and 16 hours  of  settling.   The
          solids would be loaded into trucks and transported
          to the batch plant.

     •    Dredged sediments would be placed in barges to
          dewater the solids.   Solids would be  removed by  a
          backhoe or dragline about 2 months after  dredging
          activities were completed and  loaded into trucks
          for transport to the batch plant.

In all the above initial solids dewatering basins, the super-
natant would be continuously decanted and routed to an onsite
water treatment plant for suspended  solids and PCB removal
(to 1 ppb PCBs), then discharged to the harbor or to a sani-
tary sewer.

The dewatered solids could be  thickened  with other project
area solids.  They would be fixed  as described  for  Alterna-
tive I to  render  solids  to a nonflowable  form,  and trans-
ported by  truck,  train,  or barge  to an  approved disposal
site.

Alternative 3:  Dredge-Dewater-Dispose

A sediment dispersal control device as described for Alter-
native 1 would be installed across the mouth of Slip No.  3.
Sediments in excess of 50 ppm  PCBs would be removed with a
hydraulic or pneumatic dredge, and the sediment  slurry pumped
through a pipeline  to the initial solids dewatering basin.
Dredging of  the deep  contaminated sand  and  silt would be
performed as described for Alternative 1.   All  solids  would
be dewatered  using  one  of the  initial  solids  dewatering
basins described  for Alternative  2.   For this alternative,
however, they would be dewatered to the  degree  necessary to
reach  a  nonflowable condition.   In general,  this  would
require more time and/or more  equipment.  The solids would
then be transported by truck  to an approved disposal site.
The supernatant would be continuously decanted and routed  to
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an onsite water treatment plant for suspended solids and PCB
removal  (to 1 ppb PCBs), then discharged back to  the  harbor
or to a sanitary sewer.

Alternative 4:  Dredge-Dewater-Incinerate-Dispose

A sediment dispersal control device as described  for  Alter-
native 1 would be installed across the mouth of Slip  No.  3.
Sediments in excess of  50 ppm PCBs would  be removed with a
hydraulic or pneumatic dredge, and the sediment slurry pumped
through a pipeline  to  an initial solids dewatering basin.
Dredging of the  deep contaminated sand and silt  would be
performed as described  for Alternative I.   All solids  would
be dewatered, using one of the  initial  solids  dewatering
basins described for Alternative 2, to a nonflowable  condi-
tion.  The  supernatant  would  be continuously decanted and
routed to  an  onsite water  treatment  plant for suspended
solids and PCB removal  (to 1 ppb PCBs), then discharged back
to the harbor or to a sanitary sewer.   The  solids would then
be removed with  a backhoe or  dragline and placed in trucks
to be transported to an onsite incinerator.  The solids would
be incinerated in an approved unit  and the ash disposed of
onsite.

Alternative 5:  No Action

The No Action alternative will  leave  PCB  concentrations in
excess of 500 ppm in Slip No.  3  sediments and PCB concentra-
tions in excess of 10,000 ppm in the localized area near the
former OMC outfall.  This alternative will not  resolve the
problem of  uncontained  toxic  waste as regulated  under 40
CFR 761.

UPPER HARBOR

Alternative 1;  Dredge-Fix-Dispose

This alternative is the same  as Slip  No.  3—Alternative 1,
except that dredging of deep  contaminated  sand  and silt is
not required and the sediment dispersal control device would
be installed at the south end of the Upper  Harbor.

Alternative 2:  Dredge-Dewater-Fix-Dispose

This alternative is  essentially the  same  as  Slip No. 3 —
Alternative 2, except  that  dredging  of deep  contaminated
sand and silt is not required; the sediment dispersal control
device would be  installed  at the south end of the Upper
Harbor; and barge dewatering  could  not be  used because  of
the large storage volume required.
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Alternative 3:  Dredge-Dewater-Dispose

This alternative is essentially the same as Slip No. 3—Alter-
native 3, except that dredging of deep contaminated sand and
silt is not required; the sediment dispersal  control  device
would be installed at the south end of the Upper Harbor; and
barge dewatering could not be used because of the large storage
volume required.

Alternative 4;  Dredge-Dewater-Incinerate-Dispose

This alternative is essentially the same as Slip No. 3—Alter-
native 4, except that dredging of deep contaminated sand and
silt is not required; the sediment dispersal  control  device
could be installed at the south end of the Upper Harbor; and
barge dewatering could not be used because of the large storage
volume required.

Alternative 5;  No Action

The No Action alternative will leave PCB concentrations between
50 and 500 ppm  in  the Upper  Harbor.   This alternative will
not resolve the problem of uncontained toxic waste as regulated
under 40 CFR  761.

SLIP NO. 3 AND UPPER HARBOR

Alternative 6;  Contain-Dredge-Cap

A sediment dispersal control  device,  consisting of  a  double
silt curtain  or sheet piling, would be  installed and  then  a
permanent cofferdam would be  constructed.  The  sediment disper-
sal control device and the cofferdam would be located at one
of the following areas:

     •    To  allow  for  dredging  of  all  Upper  Harbor
          sediments, the  sediment dispersal control device
          would be installed  at  the  south end of the Upper
          Harbor,  and  the cofferdam  would  be  constructed
          near the north end  of the Upper Harbor.

     •    To  allow for  dredging  of  the most contaminated
          Upper  Harbor  sediments, the  sediment dispersal
          control device would be installed at  the middle of
          the Upper Harbor, and the cofferdam would be  con-
          structed near the east  end of Slip No. 3.

A slurry wall extending into  the  glacial  till would be  con-
structed inside the cofferdam and around the entire perimeter
of the containment area.

Dredged sediments  from the Upper  Harbor would be placed within
the contained area.  Supernatant  would be continuously decanted
PD998.053                    3-4

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and routed to an onsite water  treatment  plant  for suspended
solids and PCB removal  (to  1 ppb  PCBs),  then discharged to
the harbor or to a sanitary sewer.  After dredging is completed,
a layer of filter fabric, a 1-ft-thick layer of  sand with  a
drainage system, and  a  3-ft-thick compacted clay cap would
cover the dredged muck.   Five  feet of fill over the clay
would serve as a surcharge  to  speed up densification of the
sediments.  Water collected from  the  drainage  system would
be treated as  described above.   Slip No.  3 would be left
permanently filled.   Groundwater  monitoring wells would be
installed around the  site for detection  of potential  PCB
migration.

After completion of all dredging  activities, the water treat-
ment plant would be removed and a new basin would be constructed
to replace Slip No.  3.  After settlement of the muck in Slip
No. 3, the surcharge would be removed and the area paved.

NORTH DITCH AREA

Alternative 1:   Excavate-Dispose

A bypass would be constructed  to  divert  surface water flow
around the highly contaminated  areas  of  the Crescent Ditch
and Oval  Lagoon.   The bypass would outfall directly into
Lake Michigan.   Construction would then begin on a structural
slurry wall (or other structural  support  system)  around the
Crescent Ditch and  a  nonstructural slurry wall  around  the
Oval Lagoon.   The soils would be  dewatered using well points
and pumps.  Well water  would be routed to  an  onsite water
treatment plant  for  suspended  solids and  PCB  removal   (to
1 ppb PCBs),  then discharged to the harbor  or  to  a  sanitary
sewer.

Soils in excess of 50 ppm PCBs would be excavated by backhoe
and placed in lined trucks for transport to an approved dis-
posal site.   The excavated areas would be backfilled.

Alternative 2:   Excavate-Incinerate-Dispose

A bypass would be constructed as  described for Alternative 1.
The excavation area would be dewatered within a slurry wall,
and the well water would be treated as described  for Alter-
native 1.  Soils in excess of 50 ppm PCBs would be excavated
by backhoe and placed in trucks to be transported to an onsite
incinerator.   Excavated  soils  would be  incinerated  in an
approved unit,  and resulting ash would be disposed of onsite.

Alternative 3;   Excavate-Fix-Dispose

A bypass would be constructed as described for Alternative 1.
The excavation area would be dewatered within a slurry wall,
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and the well water would be treated as described  for  Alter-
native 1.  Soils in excess of 50 ppm PCBs would be excavated
with a backhoe and placed in trucks to be transported to the
batch plant.   The  soil would then be  fixed  with portland
cement, Locksorb,  or  another fixing agent to  hydrate the
excess water.  The treated soil would then be transported to
the curing cells.   The fixed solids would be  cured until
they were nonflowable and then removed from the curing cells
by front end loaders for transport by truck,  train, or barge
to an approved disposal site.

Alternative 4;  Excavate-Contain-Cap

A bypass would be  constructed  to divert  surface water flow
around the highly  contaminated  areas  of  the  Crescent Ditch
and Oval Lagoon.   The bypass would outfall  directly into
Lake Michigan.   The east-west portion of  the  North Ditch
would be excavated to one of the following extents:

     •    All of  the  PCB-contaminated soils in  the North
          Ditch would be excavated to allow for construction
          of a bypass pipeline or a lined  open ditch.   This
          would require  support  of  the excavated area with
          sheet piles.

     •    All of  the  PCB-contaminated soils in  the North
          Ditch required to install a  bypass pipeline would
          be excavated.  This  would  not  require support of
          the excavated area with sheet piles.

A nonstructural  slurry wall  extending down into the under-
lying glacial till would be constructed  around the  Crescent
Ditch and  Oval  Lagoon to control movement of  contaminated
materials.   Excavated  soils  from the east-west portion  of
the North  Ditch  and the Crescent Ditch  area would be de-
watered and placed  in  the Oval Lagoon  area.  The  well water
would be treated  as described  for Alternative  1.   The site
would be capped  with  a 3-ft-thick compacted clay  layer  to
seal in  the  contaminated soils.  The  Crescent Ditch area
would then be paved and  the  Oval Lagoon  area seeded.  This
would raise the  elevation of  the Oval Lagoon area by 20 to
25  feet.   Groundwater monitoring wells would be  installed
around the site for detection of potential PCB migration.

Alternative 5;  No Action

The No Action  alternative will leave  PCB concentrations in
excess of  10,000 ppm  in  the  localized  areas of  the  Crescent
Ditch and  Oval Lagoon  and PCB  concentrations between 50  and
10,000 ppm in  the soils and sediments of  the  rest of the
North Ditch  area.   This alternative will  not  resolve the
problem  of uncontained toxic waste as regulated  under  40
CFR 761.
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PARKING LOT

Alternative 1;  Excavate-Dispose

A nonstructural slurry wall would  be  constructed  around  the
deep contamination in the Parking Lot area.  The Parking Lot
area soil would be dewatered using well points and pumps.  Well
water would be routed to an onsite water treatment plant for
suspended solids and PCB removal  (to  I  ppb  PCBs),  then dis-
charged to the harbor or to a sanitary  sewer.  Soil in excess
of 50 ppm PCBs  would  be excavated by backhoe or  front end
loader and placed in lined trucks for transport to an approved
disposal site.  The excavated areas would be backfilled.

Alternative 2:  Excavate-Incinerate-Dispose

The excavated area  would be dewatered  and  the  well water
treated as described  for Alternative  1.  Soil in excess  of
50 ppm would be excavated by backhoe or front end loader and
placed in trucks to be transported to an onsite incinerator.
Excavated soil would be incinerated in  an approved unit,  and
resulting ash would be disposed of onsite.

Alternative 3:  Excavate-Fix-Dispose

The excavated area  would be dewatered  and  the  well water
treated as described for Alternative  1.   Soils  in  excess of
50 ppm would be excavated with a backhoe or front end loader
and placed in trucks  to be transported to  a batch plant.
The soils would then be fixed with portland cement, Locksorb,
or another fixing  agent to hydrate excess  water.   Treated
soil would then be  transported  to  curing  cells.  The fixed
solids would be cured  until  they were nonflowable and then
removed from the curing cells by front  end  loaders for trans-
port by truck, train,  or barge to an approved disposal site.

Alternative 4:  Contain-Cap

A nonstructural slurry wall  extending down into the under-
lying glacial till  would be  constructed around  the Parking
Lot to control movement of contaminated materials.  The  site
would be capped with  a 3-ft-thick compacted clay  layer  to
seal in the contaminated soils and then resurfaced for park-
ing.  This would raise the elevation  of the site  by 3 to 4
ft.  Groundwater monitoring wells  would be  installed  around
the site for detection of potential PCB migration.

Alternative 5:  No Action

The No Action alternative will leave PCB concentrations  from
50 to over 5,000 ppm in the Parking Lot area.  This alterna-
tive will not resolve the problem of uncontained toxic waste
as regulated under 40 CFR 761.
PD998.053                    3-7

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     Section 4
     INITIAL SCREENING
In the initial screening process, the alternatives described
in Section 3 were evaluated based on engineering feasibility,
estimated incremental costs, environmental  effects,  and in
accordance with the  site-specific  remedial  response  objec-
tives and  criteria discussed  in Section 1.  The  initial
screening process narrowed the  alternatives to  from  two to
four for each area.   The  alternatives  remaining after ini-
tial screening are discussed in more detail in Section 5.

ENGINEERING FEASIBILITY

The unit processes considered for the remedial action alter-
natives defined in Section 3 were further evaluated based on
engineering feasibility.  The criteria used  to  evaluate  the
unit processes and  the  justification for eliminating  some
additional processes  are  presented below.   The No Action
alternative  is  discussed  later in  this section  under
ENVIRONMENTAL EFFECTS.

Dredging

The engineering feasibility screening criteria  used  to  fur-
ther evaluate the dredging unit processes consisted  of the
following:

     •    Dredging and  related activities  in  Slip No. 3,
          except in the localized area that requires dredging
          of deep contaminated sand and silt, should be accom-
          plished within 2 months to reduce impacts on Larsen
          Marine Services.

     •    Dredging and  related  activities in the localized
          area of Slip  No. 3  should be accomplished within
          2 months.  This time is in addition to the 2 months
          required to dredge Slip No. 3, as noted above.

     •    Dredging and related activities in the Upper Harbor
          should be accomplished within 3 months.  This time
          is in addition to the  4 months  required  to dredge
          Slip No. 3 and the localized area.

     •    Dredging activities should minimize the roiling of
          bottom sediments.

     •    Dredging activities should be  accomplished during
          nonfreezing weather unless provisions  are  made  to
          store all the dredge sediment slurry.

     •    Dredges selected should be readily available, con-
          ventional construction equipment.
PD102.001                    4-1

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     •    Dredging activities  must conform  to  applicable
          laws and regulations, which include (001):

               Clean Water Act of 1977 (PL 95-217)

               River and Harbor Act of 1899

               Illinois Rivers, Lakes, and Streams Act

In preliminary  screening,  all  types of mechanical  dredges
except clamshell dredges were eliminated.  Clamshell dredges
were eliminated  for  general dredging work because bucket
placement and depth of cut are difficult to control, thereby
impacting the sediment  removal efficiencies.   Also, due to
the fluid nature of the sediments, PCB-contaminated sediment
could flow into the recently dredged  area,  reducing the  PCB
removal efficiency further.  This  could  leave high concen-
trations of PCBs in pockets of sediment.   Another  disadvan-
tage is that conventional clamshells  spill  15 to  30 percent
of the sediments while the clamshell bucket is being raised.
This spillage creates a  high  degree of  sediment suspension
that increases the concentration of PCBs in solution.

A new watertight clamshell  (055)  may reduce the amount  of
sediments spilled by 35 percent, but  it  still does  not  have
a controlled removal efficiency because of the difficulty in
controlling depth and location of  cut.   A clamshell dredge
may be used, however, in the relatively small localized area
of Slip No. 3 to remove the deep contaminated sediments  (sand
and silt) below the muck.  Dredging activities  for  the  deep
sediments would  require  containment within a single  sheet
pile cofferdam.   The water would require treatment  to remove
dissolved PCBs before the cofferdam is removed.

The Pneuma and Oozer pneumatic  dredges were  retained during
preliminary screening.  They were  eliminated  during initial
screening because  they  are not  readily  available  in  the
United States,  may  be  subject to  import  restrictions,  and
have some mechanical limitations.  The Pneuma dredge used at
the Cape Fear River  had an estimated field production rate
of 36 yd3/hr, which is about 13 times less than the capabil-
ity reported by the manufacturer (005).   At that time, Pneuma
North America was evaluating redesign.   The  Oozer  dredge is
not currently available in the United States and may be sub-
ject to import restrictions.   Also, it has  a  dredging depth
of only  20  ft,  which is not sufficient  to  remove  the con-
taminated muck layer (005).

A hydraulic  dredge,  cutterhead pipeline  suction  type, is
recommended to  remove  the PCB-contaminated muck  from Slip
No. 3 and  the Upper Harbor.   This  dredge  reportedly mini-
mizes sediment  dispersion.   Careful consideration  must  be
given to selecting the proper  dredge head  to reduce  sediment
PD102.001                    4-2

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roiling and to obtain high solid-to-water ratios to minimize
dewatering requirements.

Based on  the  above criteria,  Slip No. 3—Alternative 1 and
Upper  Harbor—Alternative 1  have been  eliminated  from
further consideration.

Excavation

The engineering feasibility screening  criteria  used  to  fur-
ther evaluate  excavation unit processes  consisted of the
following:

     •    Excavation  and  related activities for the  North
          Ditch/Parking Lot area  should be accomplished with-
          in 8 months.

     •    Excavation equipment should be commonly available,
          conventional construction equipment.

Based on  these criteria, backhoes  and front end  loaders
appear to be feasible for excavation during bypass construc-
tion, and for excavation of the Crescent Ditch, Oval Lagoon,
and Parking Lot area.  Front end  loaders appear to be feasible
for removal  of fixed solids  from fixation curing cells.
Draglines and backhoes appear to  be feasible  for removal of
settled sediments from the initial solids dewatering basins.

Sediment Dispersal Control

The engineering feasibility screening criterion used to eval-
uate sediment dispersal control unit processes was that they
should minimize migration of  dissolved PCBs across the  bar-
rier.  Based on this criterion, both the double silt curtain
and steel sheet piling appear to  be feasible.   A monitoring
program to detect movement of material  out  of the dredging
area will be enacted to warn of the need for additional con-
trol measures  (shut down dredging, polymer addition,  etc.).

Surface Water and Groundwater Control

The engineering feasibility screening criterion used to eval-
uate surface water  and  groundwater control unit processes
was that they  should  reduce inflow  to the excavation area.
Based on  this  criterion,  both sheet  piles  and structural
slurry walls appear  to  be feasible to  provide structural
support and reduce inflow for the Crescent Ditch excavation
and bypass construction.  Nonstructural slurry  walls  appear
to be feasible to  reduce  inflow  at  the Oval Lagoon and the
Parking Lot area excavations.  Dewatering with well  points
and pumps would be used for all  areas.  A single sheet-pile
cofferdam appears  to  be  feasible to reduce inflow for  the
Slip No. 3 localized area.
PD102.001                    4-3

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Bypass

The engineering feasibility screening criterion used to evalu-
ate the bypass unit process was that it divert surface waters
around the highly contaminated areas.  Based on this  crite-
rion, both a  pipeline  and  a lined open ditch appear  to be
feasible.

Initial Solids Dewatering

The engineering feasibility screening criteria used to evalu-
ate  initial solids  dewatering unit processes consisted of
the following:

     •    At  least  2 hours of settling time  are  required
          before the water used to slurry the sediments can
          be removed for treatment in the onsite water treat-
          ment plant (004).

     •    Ideally, the settling time  should provide suffi-
          cient dewatering of harbor  sediments  to obtain  a
          moisture content  that is at or below the  liquid
          limit (nonflowable) for  solids  to be  disposed of
          in a licensed chemical waste landfill.

     •    Six hours is the minimum settling time recommended
          for solids to  dewater.   The longer the  retention
          time provided,  the greater the solids concentration
          expected for the dewatered  material  (004).  From
          previous experience with dewatering silts, 6 hours
          may not be adequate to produce  a  nonflowable  con-
          sistency.

     •    The water treatment plant probably will  not be
          protected against  freezing  weather.   If not pro-
          tected,  the dewatering basins cannot release slurry
          water to the treatment plant during freezing  con-
          ditions  (001).   This would  require that dredging
          operations be conducted during nonfreezing weather.

     •    Under TSCA,  PCB  soils and  sediments  with concen-
          trations greater  than 50 ppm must be nonflowable
          if they are  to be  disposed  of in  a chemical waste
          landfill (40 CFR 761.75).

Based on these  criteria, all the  initial  solids dewatering
unit processes appear  to be  feasible.  At this  time, it is
not possible to estimate how complete solids dewatering will
be;  therefore, the  impact  of thickening with other project
area solids cannot yet be  estimated.   In  addition, testing
(under Task 4) is currently  being  performed on muck  samples
(results will be  under  separate  cover)  to determine  the
amount of fixing agent required to obtain a nonflowable con-
sistency.
PD102.001                    4-4

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If the North  Ditch is used for initial  solids  dewatering,
the ditch  should  be modified to dewater dredged  sediments
from at  least 1 day of dredging activity.  This  would  re-
quire increasing the depth of the existing east-west portion
of the North  Ditch  by  about  4 ft and  widening the ditch top
width by about 25  to  35  ft.   It should also be  designed so
that all groundwater  flow  moves toward the ditch to reduce
the possibility of groundwater  contamination from  dredged
sediments.  Solids  would be removed  with  a backhoe after
settling overnight.  Dredging activities would be interrupted
intermittently for this operation.

If the sediments  are  dewatered  in a  lagoon constructed on
OMC property  or  another nearby site,  the  lagoon  would be
designed to hold and dewater all the  dredged sediments.  The
lagoon would be sized to hold 24,000  yd3 and 118,000 yd3 for
Slip No.  3 and the Upper Harbor, respectively.  Solids would
be removed from the lagoon with a dragline about 2 months
after dredging activities  are completed.   This  would allow
for some densification of the solids  (004)  .

If bins/cyclones/filters are used for dewatering  the dredged
sediments, enough bins must be supplied to dewater  sediments
from 1 day  of dredging  activity.   One hundred bins are
expected  to  be  required.    Two  hydrocyclones  would be
required.  Because of the  low specific gravity  of the  sedi-
ments,  the hydrocyclones are expected to remove only a small
portion of the solids.  Bag  filters would  be used to polish
the effluent prior  to water  treatment.   The solids  would be
removed  from  the  bins by  gravity;  it would take about  3
man-hours to  empty  each  bin.  The solids  that  are  removed
from the cyclones  (mostly  sand)  would be loaded onto trucks
to be  transported to the  curing  cells.   Solids  would  be
removed from the bag filters by backwashing.

If barges  are used to dewater  the  dredged sediments from
Slip No.  3 only,  an adequate number of barges should be pro-
vided to contain the dredged sediments and slurry water while
the water is  decanted.   It is estimated  that  ten 2,000-yd3
capacity barges would be required.  Solids could  be removed
with a backhoe or clamshell about 2  months after dredging
activities are completed.

A lagoon on OMC property or  another nearby site is  the  only
feasible initial  solids dewatering unit process  for  the
dredged sediments  from Slip  No.  3—Alternative  3  and Upper
Harbor—Alternative 3 that might not  require fixation.   The
North Ditch dewatering scheme and the bins/cyclones/filters
were eliminated because the limited storage capacity of these
unit processes would  require daily removal of  solids,  as
well as  additional dewatering before the  solids  were  dry
enough  for disposal in  a  licensed  chemical waste  landfill.
PD102.001                    4-5

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Barges were eliminated from Upper  Harbor—Alternative  3  be-
cause harbor access would be restricted indefinitely.  Addi-
tional testing is currently being  performed on muck  samples
(results will be under separate cover) to determine the maxi-
mum solids moisture content (weight of water divided by weight
of solids) that will  allow disposal  in a  landfill, and the
required  retention time  in a lagoon  before  this moisture
content can be  obtained.   Based on experience with  dredge
spoils, this period could be more than 1 year and may require
additional means of dewatering.

The USCOE has used vacuum underdrains and the Riverine Util-
ity Craft  (RUC) systems  to dewater dredged  sediments  (052,
053).  Tests conducted by Mason & Hanger (004) indicate that
underdrain systems of  sand or  gravel  or other media placed
in the bottom of a lagoon  for  dewatering  the dredged sedi-
ments would be relatively useless because of clogging.  There-
fore, the RUC system  shows the  most  promise for dewatering
the solids and was used  for the purpose of  cost  estimating.
The RUC system entails channeling  the surface of the sedi-
ments to  allow surface drainage of water.   This  water  would
be decanted and routed to  the onsite  water  treatment plant.
The top layer is then  dried by  evaporation.   The dried soil
(typically, the top 1 to 2 ft)  would be periodically removed
with a dragline.  The  disadvantage of this  process is that
evaporation, an integral part  of  the process, provides  an
escape route for PCBs to the environment via volatilization.

Secondary Solids Dewatering

Solids from the water  treatment process will  require treat-
ment before disposal.  A belt  press was found  to be less
cost-effective than  treating  with the  other  area solids.
Therefore, belt presses  were  eliminated from further  con-
sideration.

Fixation

Fixation  refers to a chemical process used to bind or hydrate
free water  in  the  sediments.   The engineering  feasibility
screening criteria used to evaluate the fixation unit process
consisted of the following:

     •    PCB-contaminated  sediments  fixed  with portland
          cement  (or  other fixation  materials)  should be
          transportable within 1 day.

     •    The fixed solids should  be  dry  enough to be non-
          flowable for disposal at a  licensed chemical waste
          landfill.

Based  on  the engineering  feasibility screening criteria,
fixation  appears to be feasible.   Fixation  may be required
PD102.001                    4-6

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if initial  solids  dewatering techniques cannot ensure that
the PCB-contaminated  sediments will  be nonflowable and not
lose water during transportation to the final disposal site.
Fixing agents other than portland cement are being evaluated
in Task 4.

Fixation  requires  complete  dispersion of the fixing  agent
into the  sediment  to be fixed.  A conventional,  portable,
concrete batch plant  (or  transit  mixers for small volumes)
could be  used  to  mix the fixing agent  into  the  sediments.
Storage area would  be provided onsite for curing  the mix-
ture.  The quantity of  fixing agent  used per cubic yard  can
be adjusted  to account  for variability in  the  sediment
characteristics and moisture contents.

Water Treatment

Laboratory tests were conducted by Mason & Hanger  (004) using
harbor water slurried with harbor sediments.  The tests showed
that sand  filtration  (at 3 gallons  per minute  per square
feet) would remove  suspended solids  if coagulation/sedimen-
tation were used before filtration to settle fines that could
plug or pass  through the filter.  Coagulants  found to be
effective in settling the fines were both alum and Nalco 8103,
with 2 hours of settling after coagulant addition.

Laboratory tests on carbon filtration were also conducted by
Mason & Hanger  (004).   Tests conducted on  harbor and North
Ditch samples demonstrated that carbon filtration  (15-minute
contact)  could remove PCBs to below 1 ppb.

The water treatment  system  would  be  a "package plant" that
could be  easily installed and  removed.   The same treatment
method could be used  for all alternatives.   These  units  are
commonly available.

Water in Slip No.  3 and the Upper Harbor may also need treat-
ment because dredging operations  roil the  sediments,  which
could cause increased concentrations of PCBs in  solution.
Treatment of the water behind the sediment dispersal control
device may consist of adding one or both of the following:

     •    Cationic polymer to coagulate and  settle  the fine
          suspended sediments

     •    Activated carbon to remove soluble PCBs

Additional dredging would be required to remove the activated
carbon and settled solids behind the silt curtain.

Laboratory tests conducted  by  Mason & Hanger  (004) demon-
strate that groundwater slurried with North  Ditch  sediments
removed from the North Ditch/Parking Lot area can be treated
PD102.001                    4-7

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to remove PCBs down below 1 ppb.  The water treatment plant for
Slip No. 3—Alternatives 2 and 3, Upper Harbor—Alternatives 2
and 3, and Slip No. 3 and Upper  Harbor—Alternative  6 would
be a 1,500-gpm system (assuming a hydraulic dredge operating
8 hours per  day  at a  capacity of 3,000 gpm)  consisting  of
coagulation, sedimentation, pressure filtration,  and carbon
adsorption.  The treated water would be detained in a clear-
well to be monitored for PCB  concentration  before  discharge
to the harbor or to a sanitary sewer.  A  limit  of  1  ppb  PCB
would be maintained for discharged water.   Slip No. 3—Alterna-
tive 3, Upper Harbor—Alternatives  1 and  3, and Slip No. 3
and Upper Harbor—Alternative 6 would also require a separate,
smaller, water treatment plant (200 gpm)  for treatment of rain-
water and leachate water after the larger water treatment facil-
ity is dismantled.  The water treatment plant  for  the North
Ditch—Alternatives 1, 3, and 4 and Parking Lot—Alternatives 1
and 3 would be a 200-gpm system  (assuming dewatering of sands
with a permeability of 10 * cm/sec)  consisting of coagulation,
sedimentation, pressure filtration,  and carbon adsorption.

Containment/Encapsulation

The engineering feasibility screening criteria used to evalu-
ate containment/encapsulation consisted of the following:

     •    TSCA regulations  (40 CFR 761.60) require that appli-
          cations for disposal of dredged materials that contain
          PCBs, other than  by incineration  as  prescribed in
          40 CFR 761.70 or in a chemical waste landfill that
          complies with 40 CFR 761.75,  must be made in writing
          to the USEPA Regional Administrator.  The disposal
          method must be based on technical,  environmental,
          and economic considerations,  indicating that disposal
          in an  incinerator or  chemical waste  landfill  is
          not reasonable and  appropriate.   The alternative
          disposal method must  provide  adequate protection
          to health and the environment (40 CFR 761.60(5)).

     •    CERCLA (101(24) (PL96-510) defines remedial action
          to include, but not be limited  to, "such actions
          at the  location  of the release as  storage, con-
          finement, perimeter protection using dikes, trenches
          or ditches,  clay cover...dredging or excavation...col-
          lection of leachate and runoff...and any monitoring
          reasonably required to assure that  such  actions
          protect  the  public health and  welfare and the
          environment."

Containment/encapsulation of  PCB-contaminated material  in-
place would eliminate the costs of removing and disposing of
the waste.   This alternative  was considered for Slip No. 3
with  Upper  Harbor  sediments  used as  fill, for the  North
Ditch area with the North Ditch  soils used  as  fill,  and  for
PD102.001                    4-8

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the Parking Lot area.  Disposal of the PCB-contaminated soils
by containment/encapsulation would require a waiver from the
requirements of 40 CFR 761.75  (40 CFR 761.60(4)).  Management
of the site after containment would be the responsibility of
the State, in accordance with CERCLA and the NCP.

Slip No. 3 and the Upper Harbor.   Containment/encapsulation
of Slip No. 3 would require the construction of  a  cofferdam
and slurry wall to seal off  this  portion of the harbor.  A
slurry wall 2 ft thick would be constructed through the sandy
sediments and  5 ft into  the glacial till  layer  underlying
the harbor sediments.  The slurry wall would be  constructed
completely around the  perimeter of  the  containment area.
The water  level would  then be lowered in  the  containment
area to  ensure  inward  movement of groundwater.  The water
removed would be treated in an onsite water treatment system.
The water would be discharged to the harbor or to a sanitary
sewer.    PCB-contaminated  sediments from the Upper Harbor
would then be transferred  to  the  contained area.  The con-
tained area would be completely filled.  Docking facilities
now in  Slip  No.  3 would have  to  be  relocated  (021, 002).
Groundwater monitoring wells would be  installed around the
site for detection of potential PCB migration.

North Ditch Area.   Containment/encapsulation of the Crescent
Ditch and Oval Lagoon  would require  the construction of  a
slurry wall  2  ft  thick,  extending through the  sandy soils
5 ft into  the  underlying  glacial till layer.   The slurry
wall would be  constructed completely around the Crescent
Ditch and  Oval  Lagoon  areas.   PCB-contaminated  soils  from
the east-west portion  of the  North Ditch,  excavated during
construction of the  bypass, would then be transferred,  placed,
and compacted on the Oval Lagoon area.   The top  3  ft of the
Crescent Ditch area would also be  excavated and  then trans-
ferred,  placed, and compacted on the Oval  Lagoon area.  The
Crescent Ditch and Oval Lagoon areas would be  covered with
3 ft of compacted clay, and then the Crescent Ditch area would
be resurfaced for parking and  the  Oval Lagoon  area would  be
seeded.   Groundwater monitoring wells would be installed
around the site for  detection of potential PCB  migration.

Parking Lot Area.   Containment/encapsulation within the Park-
ing Lot  would  involve  construction of a slurry  wall  2 ft
thick,  extending through the sandy soils 5 ft  into the un-
derlying glacial till layer.  The area would be covered with
3 ft of  compacted clay and then  resurfaced for parking.
Groundwater monitoring wells would be  installed around the
site for detection of potential PCB migration.

Incineration

The engineering feasibility screening criteria  used to evaluate
the incineration unit process consisted of the  following:
PD102.001                    4-9

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     •    Incinerators must be  licensed  to  incinerate PCB-
          contaminated wastes before mid-1984.

     •    Ash with  PCB  concentrations of 0.0 ppm  must be
          disposed of onsite to be cost-competitive (021).

     •    Based on USEPA regulations, incinerators must main-
          tain a temperature of 1200°C  (2192°F), a  2-second
          dwell time  in the  secondary combustion unit, and
          3 percent excess oxygen in the stack gas; or main-
          tain a temperature of 1600°C (2912°F), a 1.5-second
          dwell time  in secondary combustion, and  2 percent
          excess oxygen in the stack gas (001).

     •    Based on USEPA regulations, incinerators must oper-
          ate at a combustion efficiency of  99.9 percent  or
          greater (001).

     •    PCB disposal should be completed by late 1986.

Incineration has been eliminated  from further consideration
based on the screening criteria for engineering feasibility.
No major  advances  in incinerator technology have  occurred
since 1981, when USEPA reports  (021  and  002)  concluded that
incineration was not feasible.   An incinerator capable of
PCB destruction under the conditions  set forth  by  USEPA and
transportable to the site has not been licensed to date.  It
does not  appear that available  technology would meet USEPA
requirements without  time-consuming  and  costly  testing and
permitting.  Therefore,  incineration is not  considered a
feasible alternative.

In addition to the failure of incineration to meet engineer-
ing feasibility criteria, the costs  to  incinerate  PCB-laden
sediments are expected to be on the order of 10 times greater
than disposal costs.  According to  James Boyland  (Director
of Sales, SCA Chemical Wastes Services), charges to use the
SCA incinerator in  Chicago,  Illinois, would be from  25 to
50C per Ib of PCB-contaminated soil.  The high cost of incin-
eration is primarily  due to the low  heat value  of  the soil,
requiring addition of supplementary  fuel to  raise the soil
temperature above 2000°F.  It is assumed that if an approved
portable  incinerator unit  were available for incineration
onsite  (none is available at  this  time),  the cost would be
at least the same, if not more.  The estimated cost for incin-
eration  at  50C per  Ib  of  contaminated soil approaches
$l,000/yd3.  Consequently, incineration will  not be consid-
ered further.   Therefore,  Slip  No.  3—Alternative 4,  Upper
Harbor—'Alternative  4, North Ditch—Alternative 2, and Park-
ing Lot—Alternative  2  have been  eliminated from further
consideration.
PD102.001                   4-10

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Water Disposal

The engineering  feasibility  criterion  used to evaluate the
water disposal unit  process  was that the  water  discharged
have PCS concentrations less than 1 ppb.  Based on this cri-
terion, both discharging to  the  harbor  and discharging to a
sanitary sewer appear feasible.

Offsite Landfill

The engineering feasibility  screening criteria used to eval-
uate the offsite landfill disposal  options  consisted  of the
following:

     •    Disposal sites must  be licensed to receive  PCB-
          contaminated wastes before mid-1984.

     •    Applicable laws and regulations governing disposal
          sites include (001) :

               Clean Water Act of 1977  (PL 95-217)

               Toxic Substances Control Act

               Resource  Conservation  and  Recovery  Act
               (PL 94-580)

               Applicable State rules and regulations

Final site selection and evaluation for a potential hazardous
waste disposal site  were  performed by  Warzyn Engineering,
Inc. (034, 040).   The final  report  (034) evaluates the poten-
tial for offsite disposal at the Browning  Ferris  Industries
(BFI)  Lake County, Illinois, site and the  Clermont  Environ-
mental Reclamation  (CECOS)  Williamsburg, Ohio, site.   CECOS
was recently purchased by BFI but shall still be referred  to
in this report as CECOS.  Based on the engineering feasibility
screening criteria, both the BFI and CECOS sites are  fea-
sible.   BFI, which  is  only  13  miles from the OMC site,  is
not currently licensed  to receive  PCBs; however,  the  faci-
lity has  the  potential to be  upgraded to meet  hazardous
waste landfill requirements.   CECOS is licensed and ready  to
receive PCB-contaminated material.   The CECOS site is 350
road miles from Waukegan Harbor.

Since the publication  of  the final site evaluation  report
(034),  several other possibilities have  been considered.
Environmental Services, Incorporated (ESI), in Boise,  Idaho,
is licensed and  ready  to  receive PCB-contaminated  solids.
The cost for disposal  at ESI is  comparable to the cost for
disposal at CECOS.  Costs for transportation to Boise, how-
ever,  are expected  to  exceed the  transportation  costs to
CECOS.   The ESI  site is about  4 times  farther than CECOS.
The availability of  rail  transport (rail  station 31  miles
PD102.001                   4-11

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from disposal site)  is not expected to lower the transporta-
tion cost because of  the many railroads  affected  and the
difficulty in obtaining special freight tariffs, as discussed
under Transportation,  below.

Another site not licensed but potentially available is prop-
erty owned by the Waukegan Port Authority near  the  Waukegan
Airport.

Transportation

There are  three possible modes  of transporting the  PCB-
contaminated sediments to an offsite disposal site:  trucks,
barges, and  railroad  cars.   Variables  that  determine the
engineering feasibility of transportation modes include:

     •    Moisture content of the  soil  and/or type  of fixa-
          tion  (e.g.,  block form, friable)

     •    Proximity of disposal site to railway access

     •    Proximity of disposal site to barge access

     •    Minimization  (optimization)  of  waste  handling or
          rehandling

     •    Time  required  to  obtain  necessary  agreements/per-
          mits

If the PCB-contaminated sediments are fixed in friable  (loose
aggregate) form, dump trucks could be  used.  Railcars might
still be used,  but loading  and unloading  would  be  more com-
plicated.  Provisions should be made to prevent loss of fixed
sediments during transportation.

If the  PCB-contaminated  sediments  and soils  are not  fixed,
truck transportation would be the only feasible mode of trans-
port.  The trucks would  have  to be lined to prevent  water
loss during transport.

The BFI, CECOS, and ESI  disposal sites  include  truck  trans-
portation to their  sites as part of  the  disposal  services
for  their  landfill  operations.   Rail  transportation  would
require obtaining agreements with railroad owner(s) to trans-
port PCB-contaminated waste.  Usually,  on long hauls, more
than one  railroad is  affected.  Trucking is usually more
cost-effective  unless a  special  freight tariff can be ob-
tained from the railroads.  Special freight tariffs are usu-
ally made available only to long-term users.  If a hazardous
waste disposal  site is not  adjacent  to railway  access, then
the added cost  of double handling could outweigh the possible
cost savings of using rail transport.
PD102.001                   4-12

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Transportation by barge is  feasible  only if the final dis-
posal site  is  close  to the Lake Michigan Waterway  access.
Barges are  technically  feasible  for  transporting the toxic
wastes to  a disposal site near  the  Great Lakes Waterways
(for example,  SCA Chemical  Wastes  Services in  Model  City,
New York).  The added cost of double handling could outweigh
the advantages.

Regardless of  the type  of transportation used,  care must be
taken to reduce the chance of spillage.   Based  on the engi-
neering feasibility criteria, truck  and  barge are the only
feasible transportation modes.

ESTIMATED INCREMENTAL COSTS

Comparative capital  and O&M costs were  evaluated  for the
alternatives considered  feasible based on  the  engineering
feasibility criteria.   No incremental cost estimates are
presented  for  the No Action alternative.   The  assumptions
used to estimate incremental costs for the other alternatives
are presented below.

For the  incremental  cost estimates,  it  was assumed  that
Level C health and safety protection equipment would be worn
by all persons.

For all the  incremental cost estimates except containment/
encapsulation,  it was  assumed  that PCB-contaminated
sediments and  soils would be taken to a  licensed chemical
waste  landfill for  disposal.   An average  disposal  and
transportation cost of $50/yd3 was assumed.

Slip No.  3

An order-of-magnitude estimate of the sediment quantities to
be dredged in this area is as follows:

     Slip No. 3 (muck)                   7,200 yd3
     Slip No. 3 (sand and silt)           3,700 yd3

     Total                               10,900 yd3

The rate of solids removal from  Slip  No.  3  was  estimated to
be about 200 yd3 of solids per hour  or 3,000  gpm at 20 per-
cent solids using a  hydraulic dredge.  Under ideal condi-
tions, it would take five 8-hour days to dredge Slip No.   3.

Alternatives 2A, 2B,  2C,  and 2D.  Sediments  with greater
than 50 ppm PCBs would  be removed  with a hydraulic dredge,
dewatered in an initial solids dewatering basin, fixed with
cement or another fixing  agent to hydrate excess water,  and
disposed of in a licensed chemical waste landfill.
PD102.001                   4-13

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The difference among Alternatives 2A, 2B, 2C, and  2D  is  the
type of  initial solids dewatering  basin used.   In each
alternative, the supernatant would be continuously decanted
and routed  to  a 1,500-gpm water treatment plant to remove
suspended solids and  dissolved PCBs down to 1  ppb before
discharge back to the harbor or to a sanitary sewer.

Under Alternative 2A,  the  sediments  would be dewatered  in
the east-west portion of the North Ditch and the solids would
be removed after one 8-hour day of dredging  and  16 hours  of
settling.  A dredge production rate of 200 yd3 of  solids per
hour has been used in these calculations.  The required capac-
ity of the  North Ditch is  estimated  to  be about 7,700 yd3.
This alternative would require that the dredging activity be
discontinued every other  day to allow  for  solids  removal
from the North Ditch.   The solids would be removed by a back-
hoe after settling overnight.  The solids would then be loaded
into trucks, transported  to the batch plant  to  be fixed,
stored for  1 day for  hydration in a curing  cell,  and dis-
posed of in a licensed chemical waste landfill.

Under Alternative 2B, the  sediments would be dewatered in a
lagoon constructed on  OMC  property  and the  solids removed
after completion of the dredging activities.  The production
of the dredge is estimated to be 200 yd3 of solids per hour.
The required capacity of the lagoon is estimated to be about
24,000 yd3.   The  solids would  be  removed by a  dragline
2 months after dredging activities are completed.  The solids
would then be  loaded  into  trucks, transported to the batch
plant to be fixed,  stored for 1 day for hydration  in a curing
cell, and disposed of in a licensed chemical waste landfill.
It was assumed  that  the upper clay liner and contaminated
portions of the gravel  leachate  system  and  the  bottom clay
liner would be disposed of in a licensed chemical waste land-
fill with other contaminated solids.

Under Alternative 2C,  the  sediments  would be dewatered  in
bins/cyclones/filters and the solids removed after one 8-hour
day of dredging and 16 hours of settling.  One hundred 36-yd3
elevated bins,  2 hydrocyclones,  and 1,250  5-inch-diameter
bag filters would be  required to dewater the slurry.   This
equipment would require use  of approximately 1  acre of OMC
property.  The  solids would be  removed  and  fixed after set-
tling overnight.  This  alternative  would require  that  the
dredging activity be discontinued every other day  for solids
removal from the bins.  The solids could be emptied from the
bins by gravity into  trucks,  transported  to  the  batch plant
for fixing  and  to the  curing  cells  for  hydration,  and then
transported to  a licensed chemical  waste landfill.  Solids
removal would take about 3 man-hours to empty each bin.

Under Alternative 2D,  the  sediments  would be dewatered  in
barges.  Approximately  ten 2,000-yd3  capacity barges would
be required to dewater Slip  No. 3  sediments.   The solids


PD102.001                   4-14

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would be  removed  by a backhoe or clamshell  2  months  after
the dredging  activities  were completed.  The  solids  would
then be loaded  into trucks,  transported to the batch plant
to be fixed,  stored for  I day in a curing cell, and disposed
of in a licensed chemical waste landfill.

The common denominator of Alternatives  2A, 2B, 2C, and 2D is
the fixation  process used to render the solids to a nonflow-
able consistency  for  disposal  in  a  licensed chemical waste
landfill.  Portland cement is  locally  available and  is  an
effective way to  transform the  dredged sediments to a non-
flowable  state.   Dewatering and  fixation testing  is in
progress  to  confirm the  effectiveness of fixation  using
cement and other  agents.   Cost  estimates  are based  on using
Portland cement as the fixing agent.

Assuming  250  percent moisture  content (weight  of  water
divided by weight of solids)  in the sediments after 1 day of
initial solids  dewatering  (in-place  moisture  content  of
140 percent was  assumed  (042)),  the  in-place  volume of
solids is  expected  to be increased 50  percent by moisture
content and   be  increased an  additional  50 percent  by
addition  of  cement.  Total  disposal  volumes  used in  the
incremental cost estimates were increased by 100 percent for
Alternatives  2A and 2C  for  fixed solids.   The disposal
volume was estimated to be 21,800 yd3.

Assuming 140  percent moisture content in the sediments after
2 months of initial  solids dewatering,  the in-place volume
of solids  is  expected to be increased  by  30 percent  after
addition  of   cement.   Disposal  volumes  used  in  the
incremental cost  estimate  were  increased  by 30 percent for
Alternatives  2B and 2D  for  fixed solids.   The  disposal
volume was estimated to be 14,170 yd3.

The cement is expected to hydrate the  excess  water after
1 day of  curing.  The  1-day  storage  capacity would be pro-
vided in three 125- by 75-ft, 10-ft-deep,  earth-lined cells
with a soil-cement bottom and concrete divider walls between
cells.   Dump  trucks would collect the fixative/sediment mix-
ture from the batch plant and dump it into the curing cells.
It is estimated that 29 bags of cement would be required for
each cubic yard of  dredged sediments  settled for  1 day.   It
is estimated  that  16  bags  of cement would be  required  for
each cubic yard of  dredged sediments  settled for 2 months.
This cement content is not expected to result in any signifi-
cant structural strength.  The fixed solids would be removed
by front end  loaders and loaded into trucks for transport to
a licensed chemical waste landfill.

Alternative 3.  The sediments with greater than  50 ppm PCBs
in Slip No.3 would be removed with a  hydraulic  dredge,  de-
watered in a  lagoon  until  the  sediments reached a nonflow-
able consistency  (possibly 1 to 2 years),  and  then disposed
PD102.001                   4-15

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of in a licensed chemical waste landfill.  The disposal quan-
tity was assumed to be the same as the in-place volume.

A lagoon would  be constructed on OMC  property  or another
nearby site for initial solids dewatering.  This lagoon would
be the same size  as  the  lagoon for  Alternative 2B.  During
dredging, the supernatant would be continuously decanted and
routed to a 1,500-gpm water  treatment  plant to remove sus-
pended solids and dissolved  PCBs  down  to 1 ppb before dis-
charge to the harbor or to a sanitary sewer.  After dredging
activities are  completed,  the  solids would need to be  de-
watered for an  extended  time to reach the  desired  consis-
tency.  The surface of the pond could  be channeled to pro-
vide  for drainage  of  surface water.  For purposes  of  cost
estimating, the mechanical dewatering process was assumed to
be the RUC.  Air drying of the  surface and  periodic removal
of the dry crust  in  multiple cycles would  be performed  to
induce dewatering below in-place moisture contents.  Leachate
water and stormwater  runoff  would be treated in  a  200-gpm
water treatment plant for  the  duration of dewatering after
the dredging is completed.  The solids would be removed by a
dragline and loaded  into  trucks  for disposal in a  licensed
chemical waste  landfill.   It was assumed that the upper clay
liner and the contaminated portions of the gravel  leachate
system and the  bottom clay liner  would be disposed of in a
licensed chemical waste landfill with the other contaminated
solids.

Summary.  An Order-of-Magnitude incremental cost summary for
Slip No. 3 is presented below.  The  alternatives  are  ranked
in increasing order  of  incremental  cost.   The  lowest  cost
alternative is  used as the base cost.  The  incremental  cost
of each alternative above the base cost  is  listed below.

                                         Incremental Cost
    	Slip No. 3 Alternatives	   above Base Cost

    3   Dredge-dewater in lagoon-
        dispose                               Base
    2D  Dredge-dewater in barges-fix-
        dispose                             +$ 2,100,000
    2B  Dredge-dewater in lagoon-fix-
        dispose                             +$ 3,180,000
    2A  Dredge-dewater in North Ditch-
        fix-dispose                         +$ 4,780,000
    2C  Dredge-dewater in bins/cyclones/
        filters-fix-dispose                 +$11,160,000

Upper Harbor

An order-of-magnitude estimate of the sediment quantities to
be dredged in this area  is  35,700 yd3.   The rate of solids
removal  from  the Upper Harbor  was  estimated to  be about
PD102.001                   4-16

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200 yd3 of solids per hour or 3,000 gpm at 20 percent solids
using a hydraulic dredge.  Under ideal conditions,  it would
take 24 8-hour days to dredge the Upper Harbor.

Alternatives 2A, 2B,  and 2C.   Sediments with greater than
50 ppm PCBs would be  removed with a hydraulic  dredge,  de-
watered in an  initial solids dewatering basin,  fixed with
Portland cement  or  another fixing agent to  hydrate  excess
water, and disposed of  in a licensed chemical  waste  land-
fill.

The fixation process  for these  alternatives  is the same as
that described  for  Slip  No. 3—Alternative  2.   The fixed
solids disposal  volume  at 250  percent  moisture content for
Alternatives 2A  and 2C  is estimated  to be 71,400 yd3.  The
fixed solids disposal volume at 140 percent moisture content
for Alternative  2B is assumed to be 46,400 yd3.

The initial solids dewatering basins for  these  alternatives
are the same as  those described for Slip No.  3—Alternatives 2A,
2B,  2C,  and  2D, except  that  the lagoon  capacity  was
estimated to be  118,000 yd3,  and barges would  not be used
for dewatering.

Alternative 3.   Sediments  with  greater  than  50 ppm PCBs in
the Upper Harbor would  be removed  with a hydraulic dredge,
dewatered in a lagoon until  the  sediment  reached a  nonflow-
able consistency, and disposed of in  a  licensed chemical
waste landfill.  This alternative  is the same  as that  de-
scribed  for  Slip No. 3—Alternative 3,  except  that the
lagoon capacity was estimated to be 118,000 yd3.

Summary.   The alternatives  for  the Upper Harbor are ranked
in the same manner as for Slip No. 3.  The lowest cost alter-
native is used as the base cost.  The incremental cost  of
each alternative above the base cost appears below.

                                         Incremental Cost
    	Upper Harbor Alternatives	   above Base Cost

    3   Dredge-dewater in lagoon-
        dispose                                Base
    2B  Dredge-dewater in lagoon-fix-
        dispose                            +$11,030,000
    2A  Dredge-dewater in North Ditch-
        fix-dispose                        +$11,150,000
    2C  Dredge-dewater in bins/cyclones/
        filters-fix-dispose                +$17,780,000

Slip No.  3 and Upper Harbor

Alternative 6A.  Slip No. 3 and the northwest portion of the
Upper Harbor would be contained and encapsulated.  A coffer-
PD102.001                   4-17

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clam across the north end of the Upper Harbor, consisting  of
an earth  fill  between  two  rows of sheet  piling,  would be
constructed.   A slurry wall would be placed in the cofferdam
and completely around  the  perimeter  of  the contained area.
The water would be removed and treated  in  a  1,500-gpm  water
treatment plant.   About 33,500 yd3 of sediments dredged from
the Upper Harbor would be placed in the contained area.  The
area would then be capped  and  paved.   The surrounding area
would be monitored for PCB concentration levels.

Alternative 6B.  Slip No. 3 would be contained  and encapsu-
lated.  A cofferdam across the east end of Slip No.  3,  con-
sisting of an  earthfill  between  two rows  of  sheet piling,
would be constructed.  A slurry wall would be placed in the
cofferdam and  completely around  the  perimeter of the  con-
tained area.   The water  would  be removed  and treated  in  a
1,500-gpm water treatment plant.  About 13,100  yd3 of  sedi-
ments dredged  from the east end of Slip No.  3 and the  Upper
Harbor would be placed in the contained area.  The area would
then be  capped and  paved.   The  surrounding  area  would be
monitored for PCB concentration levels.

Summary.  An Order-of-Magnitude incremental cost summary for
Slip No.  3 and the  Upper Harbor  is  presented below.  The
alternatives are  ranked  in the  same manner  as  for  Slip
No. 3.  The  lowest  cost  alternative is  used as the  base
cost.  The incremental cost  of each alternative above  the
base cost is listed below.

          Slip No. 3 and                 Incremental Cost
    Upper Harbor Alternatives            above Base Cost

    6B  Contain-dredge part
        of Upper Harbor-cap                    Base

    6A  Contain-dredge-cap                 +$3,200,000

North Ditch/Parking Lot Area

An order-of-magnitude estimate of the soil quantities to be
excavated under this alternative is as follows:

         Crescent Ditch                    28,900 yd3
         Die storage area                  2,300 yd3
         Oval Lagoon                       14,600 yd3
         North Ditch (east-west)            25,000 yd3
         Parking Lot Area                105,000 yd3

         Total                           175,800 yd3

The rate  of  solids removal from  the  North Ditch/Parking Lot
area was  estimated to  be about 150 yd3 of solids per  hour
using a backhoe.  Under ideal conditions,  using one backhoe,
PD102.001                   4-18

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it would take  59  8-hour days to  excavate  the North Ditch
area and 88 8-hour days to excavate the Parking Lot area.

Alternative 1.  A bypass would  be constructed and soils in
excess of 50 ppm PCBs would be  excavated and  disposed  of in
a licensed chemical waste landfill.  The area would  then be
backfilled with soil.  Because of the relatively high ground-
water table, the area would require dewatering before excava-
tion.  Sheet piles or a structural slurry wall would be con-
structed to provide structural support for and reduce inflow
to the Crescent  Ditch excavation.  A nonstructural  slurry
wall would be constructed to  reduce  inflow to the Oval La-
goon and the Parking  Lot area.  Dewatering with well points
and pumps would be used for all areas.  The groundwater  re-
moved would be treated  in  a 200-gpm water treatment plant
before discharge to the harbor or to a sanitary sewer.   This
alternative assumes  that  the contaminated  soils  could be
excavated in a nonflowable state and disposed of in a licensed
chemical waste landfill.  This  is a reasonable assumption,
since the North Ditch/Parking Lot area soil is mostly sand.

Alternative 3.  A bypass would  be constructed, and  soils in
excess of 50 ppm PCBs would be excavated and then fixed before
disposal in a  licensed  chemical waste landfill.  Then  the
area would  be backfilled  with  soil.   The  excavation,
dewatering, and water treatment would  be  the same as  that
described for Alternative 1.  This alternative would ensure
that the  contaminated  soils  are  of  a  nonflowable  con-
sistency, if for some reason  the  soils  could  not  be suffi-
ciently dewatered.  The fixation  methods would  be the  same
as those described in Slip No. 3—Alternative 2.

Assuming 40 percent  moisture content in  the  soils  after
excavation, the in-place volume of solids  is  expected  to be
increased by  25 percent after addition  of cement  (13  bags
per  yd3).   Fixed  solids  disposal volumes used  in  the
incremental cost estimates were increased  by  25 percent  for
Alternative 3.  The disposal volumes were estimated to be:

           North Ditch area            88,500 yd3
           Parking Lot area           131,200 yd3

           Total                      219,700 yd3

Alternative 4  (Parking  Lot  Area  Only).  This alternative
consists of encapsulating the area of contamination in-place
beneath the Parking Lot to  minimize  groundwater contamina-
tion.  A slurry wall  surrounding  the  area  is  assumed to be
about 2 ft thick, 35 ft deep, and 2,400 ft long.  The  Park-
ing Lot area  would be returned to its  original  use after
encapsulating the contaminated  area,  regrading,  and resur-
facing the area with asphalt cement paving.  The surrounding
area would be monitored for PCB concentration levels.
PD102.001                   4-19

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Alternative 4A  (North  Ditch  Area Only).   This  alternative
consists of encapsulating the area of contamination in-place
beneath the Crescent Ditch and Oval Lagoon and filling above
the area of the  Oval Lagoon  with all of  the excavated PCB-
contaminated soils from  the  east-west portion of the North
Ditch and from the top 3 ft of the Crescent Ditch.  A slurry
wall surrounding the area is assumed to be about 2 feet thick,
35 feet deep, and 1,900  feet long.   The Crescent  Ditch  area
would be resurfaced with asphalt cement  paving.  The Oval
Lagoon area would be seeded.  The  surrounding area would  be
monitored for PCB concentration levels.

Alternative 4B  (North Ditch Area Only).  This alternative  is
the same as Alternative  4A,  except only  5,600 yd3 of PCB-
contaminated soils from  the  east-west portion of the North
Ditch would be excavated.

Summary.  An Order-of-Magnitude incremental cost summary  for
the North Ditch/Parking  Lot  area  follows.   The alternatives
are ranked  in  increasing order  of  incremental cost.   The
lowest cost  alternative  is  used  as the base cost.   The
incremental cost of  each alternative  above  the base cost
appears below.

                                      Incremental Cost
       North Ditch Alternatives       above Base Cost

       4B  Excavate-contain part
           of the North  Ditch-cap          Base
       4A  Excavate-contain-cap         +$ 4,510,000
       1   Excavate-dispose             +$12,460,000
       3   Excavate-fix-dispose         -(-$22,610,000

                                      Incremental Co-st
       Parking Lot Alternatives       above Base Cost

       4  Contain-cap                      Base
       1  Excavate-dispose              + $ 9,680,000
       3  Excavate-fix-dispose          +$30,070,000

ENVIRONMENTAL CONSIDERATIONS

The following paragraphs present quantitative estimates  of
the amount of PCBs to be removed or  contained by each alter-
native.  The  socioeconomic  aspects and permit requirements
are assessed.  The adequacy of source control to satisfy  the
response objectives and  to contribute substantially  to  pro-
tection of  public  health and the environment  is  also dis-
cussed.

Slip No. 3

Alternative 2:   Dredge-Dewater-Fix-Dispose.   This alterna-
tive -would  remove by hydraulic  dredge (clamshell for the
PD102.001                   4-20

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localized area of deep contaminated sand and silt) all sedi-
ments  from  Slip  No.  3  with PCB contamination  in  excess  of
50 ppm.  Dredging activities would  use  a  sediment dispersal
control system  (silt curtains  or sheet piling) to minimize
uncontrolled  release  of PCBs  into  the surrounding  area.
Because minimal  volatilization  is expected to occur at the
dredge  site (roughly 0.3  to  0.4 pound per  day per acre
(Ib/day/acre) from  an  exposed, agitated,  and  contaminated
water  area  (030)), only  low concentrations of  PCBs would be
released into  the air  (less  than  2 micrograms per  cubic
meter  (ug/m3)M   (007) .

Sediments would  be  dewatered onsite,  using (1) the North
Ditch,  (2)   a lagoon to be constructed on OMC property,
(3) bins/cyclones/filters, or  (4) barges.  Supernatant would
be processed through a package water treatment plant.  Solids
from the treatment  plant would be  returned  to be treated
with the other solids.  Treated water, with PCB levels below
1 ppb, would then be discharged into the harbor or to a sani-
tary sewer.

The greatest potential  for volatilization  during  dewatering
would  occur in  the  North Ditch, which would require  daily
excavation  of all the dredged  solids.   The excavation would
stir up  the sediments,  causing increased volatilization.
The lagoons or  barges  would be  excavated  only once, thus
reducing opportunities  for volatilization.   The  elevated
bins would  be decanted before the solids are removed and put
through the fixation process.   The  contaminated  sediment
would not have contact with the open air for more than about
1 hour per  bin-clearing operation.   The  highest  reported
concentration in a  Slip No.  3 sediment  sample is about
500,000 ppm PCBs  (001).  The predicted  PCB concentration in
the air from solids  removal  operations is predicted to  be
less than  200  ug/m3  for sediments  with concentrations  of
100,000 ppm PCBs  (007).   Typical PCB concentrations  range
from about  50 to  5,000 ppm PCBs.  Predicted  average  concen-
trations in air would be less than  6.6  ug/m3.   These  values
were extrapolated from  data  for sand assuming  a  3.6-mile-
per-hour (mph) wind  and an air  temperature  of 68°F.  The
volatilization rate from Waukegan Harbor muck should be less
than from sand (007) .

The remaining solids would be fixed in a nonflowable form to
allow  transport  offsite without spillage.   Volatilization
control during transport may  require  use  of covers.  Fixed
materials would be disposed of  in a licensed chemical waste
landfill,  in compliance with State and Federal standards for
PCB waste disposal.
PD102.001                   4-21

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Slip No. 3 would be  cleaned  of all sediments in excess  of
50 ppm PCBs.   If a 95 percent removal efficiency were achieved,
it would remove an estimated 290,000 Ib of PCBs in  approxi-
mately  10,900 yd3  of sediments.  This would  remove about
93.5 percent of all  the  PCBs now found in Slip No. 3 and
Upper Harbor sediments.

The most significant uncontrolled  dispersal  of  PCBs during
cleanup would result from  volatilization,  and is  estimated
to be below 1,000 ug/m3,  the OSHA standard (007).

Local land use would be temporarily impacted by the disposal,
treatment, and transport operations.   Upon project comple-
tion, existing local land  uses could resume.  A temporary
impact  on  Larsen  Marine  Services  would  occur during  the
actual  dredging operations.  Alternatives  2A  and  2C,  using
the North Ditch or bins/cyclones/filters,  would have a greater
impact  on Larsen Marine  Services  because  dredging  would be
interrupted every other day for solids removal.

Permit requirements are anticipated to include:

     •    USCOE Section 10 (dredging) permit

     •    USCOE Section 404  (disposal in waterways) permit

     •    IEPA water quality certification on all USCOE per-
          mits

     •    National Pollutant Discharge Elimination  System
           (NPDES)   permit   (State/Federal)  for point-source
          water discharge  from the water treatment plant

     •    IEPA permit  for  construction of  wastewater  treat-
          ment facilities

     •    IEPA  (Division of  Land and Noise)   special  waste
          hauler's permit

     •    City of Waukegan construction permits

     •    Local land use approval

     •    Certification of Authority to haul PCB commodities
          from Interstate Commerce Commission (ICC) and Illi-
          nois Commerce Commission  (I1CC)

     •    USEPA toxic  substances disposal approval

     •    IEPA approval  if material is disposed in a cur-
          rently non-PCB-approved site

     •    Waukegan Port Authority dredging permit
PD102.001                   4-22

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     •    Illinois Department of Transportation  (IDOT)  (Divi-
          sion of Waterways) permit for work in public water-
          ways

     •    North Shore  Sanitary  District approval  if  water
          discharge goes to the sanitary sewer

Alternative 3:  Dredge-Dewater-Dispose.  Like Alternative  2,
this alternative would  use  a  dredging system with sediment
dispersal controls to remove all sediment  with  PCB contami-
nation in excess of  50  ppm.  Because  minimal volatilization
is expected to occur at the dredge  site  (roughly  0.3  to 0.4
Ib/day/acre from an exposed, agitated, and contaminated water
area  (030) ) ,  only  low  concentrations  of PCBs would be  re-
leased into the air  (less than 2 ug/m3)  (007) .

Dredged sediments would be  dewatered  by  use  of  a lagoon on
OMC property.  Mason & Hanger's laboratory reports  (004) and
experience with dredged sediments indicate that the dredged
sediments would be  difficult to dewater.  It  was assumed
that the sediments would not obtain a moisture  content lower
than they  had in-place in  the  harbor without  mechanical
dewatering.   Vacuum  underdrainage  techniques   to  densify
fine-grained material have been successfully demonstrated by
USCOE  (053).  However, laboratory tests conducted by Mason  &
Hanger indicate that underdrain systems  of sand,  gravel, or
other media would be  relatively  ineffective  for dewatering
sediments from Waukegan Harbor (004).

The USCOE has used a RUC system to channel the  sediments for
release and  drainage  of water in dredged  sediments.   This
exposes the sediments to air for evaporation and drying  (052).
After the top layer is dry, it is removed  by a  dragline and
the RUC channeling process is repeated.  Assuming the lagoon
is 10 ft deep, the process  is expected to  require  up  to six
repetitions.  This would  result  in  substantial volatiliza-
tion of PCBs to the atmosphere,  since evaporation is a neces-
sary part of the dewatering process.

The highest reported concentration  in a  Slip No.  3 sediment
sample is about 500,000 ppm (001).  The  predicted PCB con-
centration  in  air  above sediments  with  concentrations of
100,000 ppm PCBs would be less than 200  ug/m3.   The volati-
lization rate is predicted  to  be  less than  163,000 micro-
grams per square meter per  hour (ug/m2/hr) or 63  pounds per
day  (Ib/day).  Typical  PCB  concentrations  range from about
50 to 5,000 ppm PCBs.   Predicted  average concentrations in
the air would be less than 6.6 ug/m3.   The average volatili-
zation rate from these sediments is expected to be less than
5,375 ug/m2/hr or  2  Ib/day  PCBs.   These values are extra-
polated from data for sand, assuming  a  3.6-mph  wind and an
air  temperature  of 68°F.   The  volatilization  rate from
Waukegan Harbor muck should be less than from sand  (007).
PD102.001                   4-23

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Supernatant would  be  processed through a  water treatment
plant.  Solids from the treatment plant would be returned to
be treated with the other  solids.   Treated water,  with PCB
levels below 1 ppb, would be discharged to  the  harbor  or  to
a sanitary sewer.

Once the necessary  drying  was  achieved in  each  layer,  the
sediment would be removed by a dragline and placed in trucks
with seals  (tailgate  linings,  etc.)  to  minimize spillage
during transport.  Volatilization would  occur during drag-
line and truck  loading  operations.   Sediment would finally
be disposed of in a licensed chemical waste landfill.

Slip No. 3 would be  cleaned of all sediments with  greater
than 50 ppm PCBs.   If a 95 percent  removal efficiency were
achieved, it would remove  an estimated 290,000  Ib  of  PCBs
contained in  approximately 10,900  yd3 of  sediments.   This
would remove about 93.5 percent of all the PCBs now found in
Slip No. 3 and Upper Harbor sediments.

PCB releases during cleanup would be at a maximum during the
evaporation phase  of  the dewatering  operation  and solids
removal process.  The volatilization rate of the alternative
would be expected  to average  less  than 2 Ib/day, and would
decrease as PCBs  in the top sediments  in  each layer were
depleted (007).

Local land use would be temporarily impacted by the disposal,
treatment, and transport preparation operations.  Upon proj-
ect completion, existing  local land uses  could  resume.   A
temporary impact on Larsen Marine Services  would occur dur-
ing the actual dredging operations.

Permit requirements are anticipated to include:

     •    USCOE Section 10  (dredging) permit

     •    NPDES permit  (State/Federal) for point-source water
          discharge from the water treatment plant

     •    USCOE Section 404  (disposal in waterways) permit

     •    IEPA water quality certification  on all USCOE per-
          mits

     •    IEPA permit for  construction  of  wastewater treat-
          ment facilities

     •    IEPA  (Division of Land and Noise)  special  waste
          hauler's permit

     •    City of Waukegan construction permits
PD102.001                   4-24

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     •    Local land use approval

     •    Certification of Authority to haul PCB commodities
          (ICC and I1CC)

     «    USEPA toxic substances disposal approval

     •    IEPA approval  if  material is disposed in  a  cur-
          rently non-PCB-approved site

     •    Waukegan Port Authority dredging permit

     •    IDOT  (Division of  Waterways)  permit for work  in
          public waterways

     •    North Shore  Sanitary District approval if water
          discharge goes to the sanitary sewer

Alternative 5:  No Action.  The No  Action alternative  would
leave PCB  concentrations in excess of 10,000 ppm in  the
localized area near the  former OMC  outfall  and PCB  concen-
trations in excess of 500 ppm  in the rest of Slip No. 3 sedi-
ments.  This  represents  an  estimated 305,200 Ib  of PCBs in
Slip No. 3  (001) .  PCBs  in  these concentrations are regu-
lated by 40 CFR 761 under TSCA.

Without cleanup, Slip No. 3  will  continue  to contribute to
the estimated 22 Ib of PCBs  (based  on  a steady state model)
released into Lake Michigan  each  year from Waukegan Harbor
water (035).  The Waukegan  area will continue to represent
the most significant contributor  to Lake  Michigan  PCB con-
tamination, since it holds the largest known uncontained PCB
mass in the lake basin.  The potential for volatilization of
PCBs will continue, contributing to the estimated 12 to 40 Ib
that are released  from the harbor  into the  local  airshed
each year (007, 030).

Channel dredging has been suspended because  of PCB  contami-
nation,  and shipping access to the harbor will eventually be
eliminated.  Harbor maintenance dredging of PCB-contaminated
soils is expensive because of disposal and handling  require-
ments for  sediments with PCB  concentrations  of  50 ppm or
greater.  Huron Portland Cement and National  Gypsum  are  now
and will continue to be directly impacted, since they depend
on the harbor to receive raw material shipments.

Upper Harbor

Alternative 2;  Dredge-Dewater-Fix-Dispose.   This  alterna-
tive would remove by hydraulic dredge all sediments  from the
Upper Harbor that have PCB concentrations in excess of 50 ppm.
Dredging activities would use  a sediment  dispersal control
system  (silt  curtains  or sheet piling) to minimize  uncon-
PD102.001                   4-25

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trolled release of PCBs outside the dredging  area.   Because
minimal volatilization  is  expected to occur at the  dredge
site  (roughly 0.3 to  0.4  Ib/day/acre  from an exposed, agi-
tated, and contaminanted water area (030)), only low concen-
trations of PCBs would  be  released into  the air (less than
2 ug/m3) (007).

Sediments would  be  dewatered onsite, using (1)  the  North
Ditch,  (2) a  lagoon  to  be constructed on OMC property,  or
(3) bins/cyclones/filters.  Supernatant  would be  processed
through a package water treatment plant.   Solids  from  the
treatment plant  would be  returned to be  treated  with the
other solids.  Treated  water, with PCB  levels below 1 ppb,
would be discharged into the harbor or to a sanitary sewer.

The greatest  potential  for volatilization  during  dewatering
would occur  in  the  North Ditch.   Dredged sediment slurry
would require daily removal to allow for continued dredging,
and excavation activities would cause air  exposure and  con-
sequent volatilization.   The lagoon would  be  excavated  only
once, minimizing  the handling requirements.  The  elevated
bins would experience minimal exposure to  air,  estimated at
about 1 hour  total exposure per bin-clearing operation.  The
highest reported concentration in  Upper  Harbor  sediments is
about 500 ppm PCBs.   The maximum predicted  PCB concentration
in the air from solids  removal operations is predicted to be
less than 6.6 ug/m3.  Typical concentrations  range from 50
to 500 ppm PCBs.  Average  PCB concentrations  in the  air are
expected  to  be  less  than 1.0 ug/m3  for sediments  with
100 ppm PCBs  (007) .   These values  were  extrapolated from
data for sand, assuming 3.6-mph wind and  an air  temperature
of 68°F.  The volatilization rate  from Waukegan Harbor  muck
should be less than from sand (007) .

Dewatered sediment would  be  fixed into a  nonflowable  form
for transport, minimizing uncontrolled  release of PCBs  by
spillage, leakage, or other  means.  Volatilization control
during transport may  require the  use  of  covers.   The fixed
materials would be disposed of in  a  licensed  chemical waste
landfill, in  compliance with State and Federal standards for
PCB waste disposal.

The Upper Harbor would  be cleaned of all sediments in excess
of 50 ppm PCBs.   If a  95  percent  removal efficiency were
achieved, it  would remove  an  estimated  4,800 Ib of PCBs in
approximately  35,700  yd3  of sediment.   This  would remove
about 1.5 percent of  all  the  PCBs found in Slip  No.  3  and
Upper Harbor  sediments.

The most significant  uncontrolled  dispersal of PCBs during
cleanup would result  from volatilization, and is estimated
to be under 6.6 ug/m3,  which is well below  the OSHA standard
of 1,000 ug/m3 (007).
PD102.001                   4-26

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Local land use would be temporarily impacted by the disposal,
treatment, and transport preparation operations.  Upon proj-
ect completion,  existing  local land uses could resume.   A
temporary impact on Larsen Marine  Services  would  occur  dur-
ing the actual dredging operations.  Alternatives 2A and  2C,
using the North Ditch or bins/cyclones/filters, would have a
greater impact  on  Larsen  Marine Services because  dredging
would be interrupted every other day for solids removal.

Permit requirements are anticipated to include:

     •    USCOE Section 10 (dredging) permit

     •    USCOE Section 404  (disposal in waterways) permit

     •    NPDES permit  (State/Federal) for point-source water
          discharge from the water treatment plant

     •    IEPA water quality certification on all USCOE per-
          mits

     •    IEPA permit for construction of wastewater  treat-
          ment facilities

     •    IEPA  (Division  of  Land and Noise) special  waste
          hauler's permit

     •    City of Waukegan construction permits

     •    Local land use approval

     •    Certification of Authority to haul PCB commodities
          (ICC and I1CC)

     •    USEPA toxic substances disposal approval

     •    IEPA approval if material  is  disposed in a cur-
          rently non-PCB-approved site

     •    Waukegan Port Authority dredging permit

     «    IDOT  (Division  of  Waterways)  permit for work  in
          public waterways

     •    North  Shore Sanitary District  approval if  water
          discharge goes to the sanitary sewer

Alternative  3:   Dredge-Dewater-Dispose.   This  alternative
would remove by hydraulic dredge all sediment from the Upper
Harbor that  has PCB concentrations  in  excess of  50  ppm.
Dredging activities would use  a sediment dispersal control
system (silt curtains or  sheet piling)  to  minimize uncon-
trolled release of PCBs in the  area.  Because minimal vola-
tilization is expected to occur at the dredge  site  (roughly
PD102.001                   4-27

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0.3 to 0.4  Ib/day/acre  from an exposed,  agitated, and con-
taminated water area (030)), only low concentrations of PCBs
would be released into the air  (less than 2 ug/m3) (007).

Sediments would be dewatered  in a  lagoon to be constructed
on OMC property.  Dredged sediments would require mechanical
dewatering  using  the  RUG process  (as  described  for  Slip
No. 3—Alternative 3)  and  evaporation  to allow  sufficient
water removal for final disposal.  The lagoon would be exca-
vated by dragline after the top layer was  sufficiently  dry.
The RUC process would  be  repeated until all the  sediments
were removed.  Assuming the  lagoon  is  10 ft deep, the pro-
cess is expected to require up  to six repetitions.

All dredged materials would be fully contained in the  la-
goon.  Supernatant would be processed through a package water
treatment plant.  Solids from the water treatment plant would
be returned to  be treated with the other  solids.  Treated
water, with PCB levels  below  1 ppb,  would be discharged to
the harbor or to a sanitary sewer.

These activities  would  cause significant air  exposure  and
consequent volatilization.  The highest  reported  concentra-
tion in Upper  Harbor  sediments is about 500 ppm  PCB.   The
maximum predicted PCB concentration in air above these sedi-
ments would be  less than  6.6  ug/m3, well below 1,000  ug/m3,
the OSHA standard.  The volatilization rate  is  predicted to
be less  than 5,375 ug/m2/hr.   Typical  concentrations are
about 50 to 500 ppm PCBs.   Predicted average PCB  concentra-
tions in the air  would  be  less  than  1.0  ug/m3  for sediments
with 100 ppm PCBs.  The average-volatilization rate  is ex-
pected to be about 725 ug/m2/hr or 1.4 Ib/day of PCBs.  These
values were extrapolated from data for sand, assuming a. wind
speed of 3.6-mph  and an air  temperature  of  68°F.   The vola-
tilization  rate  from  Waukegan  Harbor muck  should be less
than from sand  (007).

Dewatered sediments would  be  transported from the site  by
trucks that would use a watertight  liner (plastic sheeting,
etc.) to minimize spillage and  leakage.  The materials would
also be covered to minimize volatilization in  transit.   The
materials would be disposed of  in a  licensed chemical waste
landfill, in compliance with State and Federal standards for
PCB waste disposal.

The Upper Harbor would be cleaned of all sediments in excess
of 50 ppm PCBs, amounting  to  an estimated 4,800 Ib of PCBs
in approximately  35,700 yd3 of  sediments.  This would remove
about 1.5 percent of all  the  PCBs now found in  Slip  No.  3
and Upper Harbor  sediments.

The most significant uncontrolled  dispersal of PCBs during
cleanup would  result  from volatilization,  and is estimated
PD102.001                   4-28

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to be under 6.6 ug/m3, which is well below the OSHA standard
of 1,000 ug/m3  (007).

Local land use would be temporarily impacted by the disposal,
treatment, and  transport  operations.   Upon project comple-
tion, existing local land uses could resume.

Permit requirements are anticipated to include:

     •    USCOE Section 10  (dredging) permit

     •    USCOE Section 404  (disposal in waterways) permit

     •    IEPA water quality certification on all USCOE per-
          mits

     •    NPDES permit  (State/Federal) for point-source water
          discharge from the water treatment plant

     •    IEPA permit for construction of  wastewater  treat-
          ment facilities

     •    IEPA  (Division  of Land and Noise) special  waste
          hauler's permit

     •    City of Waukegan construction permits

     •    Local land use approval

     •    Certification of Authority to haul PCB commodities
          (ICC and I1CC)

     •    USEPA toxic substances disposal approval

     •    IEPA approval if  material  is  disposed in a  cur-
          rently non-PCB-approved site

     •    Waukegan Port Authority dredging permit

     •    IDOT  (Division  of Waterways)  permit for work  in
          public waterways

     •    North Shore Sanitary  District  approval  if  water
          discharge goes to the sanitary sewer

Alternative 5:  No Action.   The  No  Action alternative will
leave PCB concentrations between 50 and 500 ppm, representing
an estimated 5,000 Ib of PCBs, in the Upper Harbor.  PCBs in
these concentrations are regulated by 40  CFR 761 under TSCA.

The Upper Harbor  PCBs  will continue  to  contribute to the
estimated 22 Ib of  PCBs released into Lake  Michigan  each
year from Waukegan  Harbor water  (based  on  a  steady state
PD102.001                   4-29

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model)  (035).   The Waukegan area will continue  to  represent
the most significant contributor to  Lake  Michigan  PCB con-
tamination, since it holds the largest known uncontained PCB
mass in the lake basin.  The potential for volatilization of
PCBs will continue, contributing to the estimated 12 to 40 Ib
that  are released  from the harbor into the  local  airshed
each year  (007, 030, 035).

Channel dredging, has been suspended because of  PCB  contami-
nation, and shipping access to the harbor will eventually be
eliminated.  Harbor maintenance dredging of PCB-contaminated
soils is expensive because of disposal and handling require-
ments.  Huron  Portland Cement and  National Gypsum  are  now
and will continue to be directly impacted, since they depend
on the harbor to receive raw material shipments.

Slip No. 3 and Upper Harbor

Alternative 6:  Contain-Dredge-Cap.   A  cofferdam would  be
constructed and a  slurry  cutoff wall would be placed  around
the containment area to contain  the  PCBs.   The  slurry wall
would extend  down  into the natural glacial till to reduce
future dispersion of PCBs into other sediment or groundwater.
In Alternative 6A, approximately 33,500 yd3 of  contaminated
sediment would be dredged from the Upper Harbor and disposed
of within the contained area.  If a 95 percent removal effi-
ciency were achieved,  4,400 Ib of PCBs would be moved within
the containment area.   This  would  contain about 310,000 Ib
of PCBs, or almost 100 percent of all the PCBs  now found in
Slip No. 3 and the Upper Harbor.  In Alternative 6B, approxi-
mately  13,100 yd3 of contaminated sediments would be dredged
from the east portion  of Slip No. 3 and from the Upper Harbor
and disposed of within the contained area.  If  a  95 percent
removal efficiency were achieved,  3,600 Ib of PCBs would be
moved within the containment  area.  This would contain about
306,900 Ib of  PCBs,  or about  99 percent of all  the PCBs now
found in Slip No. 3 and the Upper Harbor.  PCB concentrations
in the  air from the decanting water layer are expected to be
less than 1 ug/m3  (007, 030).

Dewatering effluent  would be  treated to 1 ppb in a package
water treatment plant  before  discharge.  After  the area was
filled, it  would  be capped with  impermeable  materials to
seal  in the contaminated  soils, and  to  reduce surface water
infiltration.  Groundwater  monitoring wells would  be  con-
structed to monitor potential PCB migration.

Containment of Slip No. 3 in this manner  would require a
USEPA waiver  from  the  requirements of 40 CFR 761  of  TSCA,
since PCBs would remain in proximity to Lake Michigan and  in
an area with a high groundwater table (058).

Permit  requirements are anticipated to include:
PD102.001                   4-30

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     •    USCOE Section 404  (disposal in waterways) permit

     •    IEPA water quality certification in all USCOE per-
          mits

     •    NPDES permit  (State/Federal) for point-source water
          discharge from the water treatment plant

     •    IEPA permit for  construction of wastewater  treat-
          ment facilities

     •    City of Waukegan construction permits

     •    Local land use approval

     •    USEPA toxic substances disposal approval

     •    IEPA approval  if material is disposed in a cur-
          rently non-PCB-approved site

     •    Waukegan Port Authority dredging permit

     •    IDOT  (Division of  Waterways)  permit for work  in
          public waterways

     A    North Shore Sanitary District approval  if  water
          discharge goes to the sanitary sewer

North Ditch Area

Alternative  1;  Excavate-Dispose.   Offsite drainage  water
would be routed by either  pipeline or a  lined open ditch  to
bypass the North Ditch and outfall directly into Lake Michi-
gan.  By bypassing the  North Ditch,  this water would avoid
PCB contamination.  The existing soil in the  North  Ditch
would be dewatered via  a well and pumping system  to  allow
excavation.  The water would be treated at an onsite package
water treatment plant.  Solids from the treatment plant would
be disposed of with the other project solids.  Treated water,
with PCB levels below 1 ppb, would be discharged  into  the
harbor or to a sanitary sewer.

Soils with PCB concentrations  greater  than  50  ppm would be
excavated by backhoe and transported to  a licensed chemical
waste landfill  for  disposal in compliance with  State and
Federal standards for PCB  waste disposal.   Volatilization
control during  transport may require use of  covers.   The
excavated areas would be backfilled with  clean  materials
from an offsite borrow  pit,  causing topographic and  other
minor local impacts to the borrow area.

The highest reported concentration in the North  Ditch soils
is about 100,000 ppm  (001).  The predicted PCB concentration
PD102.001                   4-31

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in air  during  excavation would  be  about 200 ug/m3.   The
volatilization rate is predicted to be about 163,000 ug/m2/hr.
Typical concentrations  range  from 500 to  5,000 ppm PCBs.
Predicted average  PCB  concentrations in the air would be
less than  6.6  ug/m3.   The average volatilization  rate is
expected to be less than  5,375 ug/m2/hr  for  soils  with con-
centrations of 1,000 ppm  PCBs.   These  values were extrapo-
lated from data  for sand,  assuming  3.6-mph  wind and an air
temperature of 68 °F  (007) .   The volatilization  rates  from
the sandy soils  of the  North  Ditch  area  are expected to be
closely approximated by these predictions.

If a 98 percent  removal efficiency  were  achieved,  it would
remove  an  estimated  485,600 Ib  of  PCBs  in  approximately
70,800 yd3 of  soil.  This  would  remove about 63 percent of
all the PCBs now found  in the North Ditch/Parking Lot area.

The bypass system would avoid  further  contamination of off-
site drainage  waters  that currently run through the  North
Ditch.  It is  estimated that  this would  eliminate  between  7
and 20  Ib of PCBs  discharged  into Lake Michigan each  year
(032, 035) .

The hydrologic system is not well enough understood at pres-
ent to determine the extent of past or future PCB contamina-
tion by groundwater movement.   The removal of all soils with
PCB concentrations greater than 50 ppm would minimize  the
potential for  future groundwater contamination.

Permit requirements are anticipated to include:

     •    Well water removal permit  (State)

     •    USCOE  Section 404 (disposal in waterways) permit

     •    IEPA water quality certification on all USCOE per-
          mits

     •    NPDES  permit  (State/Federal) for point-source water
          discharge from the water treatment plant

     •    IEPA permit for  construction of wastewater treat-
          ment facilities

     •    IEPA  (Division  of  Land and Noise) special  waste
          hauler1s permit

     •    City of Waukegan construction permits

     •    Local  land use approval

     •    Certification of Authority to haul PCB commodities
           (ICC and IICC)
PD102.001                   4-32

-------
     •    USEPA toxic substances disposal approval

     •    IEPA approval  if  material  is disposed in a  cur-
          rently non-PCB-approved site

     •    North Shore  Sanitary  District approval if water
          discharge goes to the sanitary sewer

Alternative 3:  Excavate-Fix-Dispose.  Offsite drainage water
would be routed by  either pipeline or lined open ditch  to
bypass the North Ditch and outfall directly into Lake Michi-
gan.  By bypassing  the  North  Ditch,  this water would avoid
PCB contamination.   The existing soil in  the  North Ditch
would be dewatered  via  a well and pumping system to allow
excavation.  The water would be treated at an onsite package
water treatment plant.  Solids from the treatment plant would
be disposed of with the other project solids.  Treated water,
with PCB levels below 1 ppb, would be discharged to the har-
bor or to a sanitary sewer.

Soils with PCB concentrations greater  than 50  ppm would be
excavated by  backhoe.   If a 98 percent  removal  efficiency
were achieved, it would amount to an estimated 485,600 Ib of
PCBs in approximately 70,800 yd3 of soil.  This would remove
about 63 percent  of all the PCBs  now  found  in  the North
Ditch/Parking Lot area.

Excavated soil would be fixed in nonflowable form.  The fixed
materials would then be  disposed  of  in a licensed chemical
waste landfill, in  compliance with State and Federal stan-
dards for  PCB waste disposal.  Control  of volatilization
during transport may require  the  use of covers.   Excavated
areas would be backfilled with clean materials from an off-
site borrow pit,  causing topographic and other minor local
impacts to the borrow area.

The bypass system would  avoid further  contamination of off-
site drainage water that currently runs through the North
Ditch.  It is estimated  that this  would  eliminate between  7
and 20 Ib of  PCBs  discharged  into Lake Michigan each  year
(032, 035).

The hydrologic system is not well enough understood at pres-
ent to determine the extent of past or future PCB contamina-
tion by groundwater movement.   The removal of all soils with
PCB concentrations  greater  than  50 ppm would minimize the
potential for future groundwater contamination.

The highest reported concentration in  the  North  Ditch  soils
is about 100,000 ppm (001).  The predicted PCB concentration
in air during excavation would be about 200 ug/m3.  The vola-
tilization rate is  predicted  to  be about 163,000 ug/m2/hr.
Typical concentrations  range  from 500 to  5,000  ppm PCBs.
Predicted average PCB  concentrations in the air would be
PD102.001                   4-33

-------
less than  6.6  ug/ra3.   The average volatilization  rate is
expected to be less than 5,375 ug/m2/hr for soils with con-
centrations of 1,000 ppm  PCBs.   These  values  were  extrapo-
lated from data for sand,  assuming a 3.6-mph wind and an air
temperature of 68°F  (007).   The volatilization rates  from
the sandy soils of the North  Ditch  area  are expected to be
closely approximated by these predictions.

Permit requirements are anticipated to include:

     •    Well water removal permit (State)

     •    USCOE Section 404 (disposal in waterways)  permit

     •    IEPA water quality certification on all USCOE per-
          mits

     •    NPDES permit (State/Federal)  for point-source water
          discharge from the water treatment plant

     •    IEPA permit for construction of  wastewater treat-
          ment facilities

     •    IEPA (Division  of  Land and Noise)  special waste
          hauler's permit

     •    City of Waukegan construction permits

     •    Local land use approval

     •    Certification of Authority to haul PCB commodities
           (ICC and I1CC)

     •    USEPA toxic substances disposal approval

     •    IEPA approval if material  is disposed in  a  cur-
          rently non-PCB-approved site

     •    North Shore  Sanitary  District approval if water
          discharge goes to the sanitary sewer

Alternative 4;  Excavate-Contain-Cap.   Alternative  4 would
use a nonstructural slurry wall  around  the perimeter of the
Crescent Ditch and Oval Lagoon area.  The  slurry wall  would
extend down into the existing glacial till beneath the local
sand  (about 35 ft  deep).   This  would reduce future disper-
sion of PCBs  into  other  soil or groundwater.   The existing
soil in the North  Ditch  would be dewatered via a well and
pumping system to allow  excavation.   The water would be
treated at an onsite package  water treatment  plant.   Solids
from the treatment plant would be disposed of with the other
project solids.  Treated water, with PCB levels below  1 ppb,
would be discharged into the harbor or to a sanitary sewer.
PD102.001                   4-34

-------
In Alternative 4A,  approximately  25,000 yd3  of soils with
PCB concentrations  greater  than 50 ppm would be  excavated
from the east-west portion of the North Ditch.  If a 98 per-
cent removal efficiency were achieved, 4,200 Ib of PCBs would
be excavated.  This would contain 495,400 Ib of  PCBs,  or
almost 100 percent  of  all the  PCBs now found in  the North
Ditch/Parking Lot  area.   In Alternative 4B,  approximately
5,600 yd3 of soils with PCB concentrations greater than 50 ppm
would be excavated  from the  east-west portion of  the North
Ditch.  If a  98  percent  removal efficiency were  achieved,
800 Ib of  PCBs  would  be  excavated.   This would  contain
492,000 Ibs of PCBs, or 99 percent of all the PCBs now found
in the North  Ditch/ Parking Lot area.  The Crescent Ditch
would be excavated to a depth of 3 ft.  Excavated soils would
be placed in the Oval Lagoon area.  The area would be capped
with impermeable materials to seal in the contaminated soils
and reduce surface  water  infiltration.   The  Crescent Ditch
area would be paved and the Oval Lagoon area would be seeded.

The highest reported concentration in the east-west  portion
of the North Ditch is greater than 5,000 ppm PCB.   The maxi-
mum predicted PCB  concentration in  air  during  excavation
would be  less  than 43 ug/m3.   The volatilization rate  is
predicted to be less than 35,000 ug/m2/hr.  Typical  concen-
trations range from 500 to  5,000 ppm PCBs.  Predicted aver-
age PCB concentrations in the air  would  be  about  6.6 ug/m3
for  soils  with  concentrations  of 1,000 ppm  PCBs.  The
average volatilization rate  is  expected to  be about 5,375
ug/m2/hr.  These  values  were extrapolated  from data for
sand,  assuming  a  wind speed  of  3.6-mph  and  an air
temperature of 68°F (007).   The volatilization rates from
the sandy  soils  of the North  Ditch  are  expected to be
closely approximated by these predictions.

Containment would  protect  adjacent soils and would  reduce
groundwater contamination and volatilization.   Capping would
raise the elevation of the  Oval Lagoon area.  Groundwater
monitoring wells would be constructed to monitor  the effec-
tiveness of the slurry wall.

Containment of the North  Ditch area  in  this  manner  would
require a USEPA waiver from  the requirements  of  40 CFR 761
under TSCA, since  PCBs would remain  in  proximity to Lake
Michigan and in an area with a high groundwater table (058) .

The bypass system would avoid further contamination of offsite
drainage waters that currently  run through the North Ditch.
It is estimated that this would eliminate between 7 and 20 Ib
of PCBs discharged into Lake Michigan each year (032, 035).

Permit requirements are anticipated to include:

     •    Well water removal permit  (State)
PD102.001                   4-35

-------
     •    USCOE Section 404 (disposal in waterways) permits

     •    City of Waukegan construction permits

     •    IEPA water quality certification on all USCOE per-
          mits

     •    NPDES permit (State/Federal) for point-source water
          discharge from the water treatment plant

     •    Local land use approval

     •    IEPA permit for construction of wastewater  treat-
          ment facilities

     •    IEPA  (Division of Land and Noise) special  waste
          hauler"s permit

     •    USEPA toxic substances disposal approval

     •    Certification of Authority to haul PCB commodities
          (ICC and ILCC)

     •    IEPA approval  if  material is disposed in a cur-
          rently non-PCB-approved site

     •    North Shore  Sanitary  District approval  if  water
          discharge goes to the sanitary sewer

Alternative 5;  No Action.  The No  Action alternative will
leave PCB concentrations in excess of 10,000 ppm in areas of
the Crescent  Ditch  and Oval Lagoon and PCB  concentrations
between 50 and 10,000 ppm in the  soil and sediments of the
North  Ditch  area  (001) .   This  represents  an  estimated
495,500 Ib of PCBs in the soil  at the North  Ditch.  PCBs  in
these concentrations are regulated by 40 CFR 761 under TCSA.

Offsite drainage entering the North Ditch will continue to
become contaminated,  discharging PCBs into  Lake Michigan.
Groundwater resources will also continue to be contaminated,
with the extent of groundwater contamination unknown.   It is
estimated that 7 to  20 Ib  of  PCBs are discharged  annually
into Lake Michigan from the North Ditch (032, 035).

Existing air contamination from North Ditch  waters  is esti-
mated at 15 Ib/yr (004).  Air contamination  from local soils
is not known, although the potential for exposure from acci-
dental disturbance remains high.

Parking Lot Area

Alternative 1;  Excavate-Dispose.  Alternative 1 would dewater
existing contaminated  soils by  a well and pumping  system.
Water drawn  from the  site  would be treated  at  the  package
PD102.001                   4-36

-------
water treatment plant.  Solids from the treatment plant would
be disposed of with the other project solids.  Treated water,
with PCB  levels  below 1 ppb,  would be discharged  into  the
harbor or to a sanitary sewer.

Dewatered soil would  be excavated by backhoe or front  end
loader and transported to a licensed chemical waste landfill
for disposal in  compliance with  State and  Federal  standards
for PCB waste disposal.  Volatilization control during trans-
port may require use of covers.

The highest reported concentration in Parking Lot area soils
is less than 10,000 ppm (001).  The predicted PCB concentra-
tion in air during excavation  would  be  less than 43 ug/m3,
well below 1,000 ug/m3, the OSHA standard.   The  volatiliza-
tion rate is  predicted to be  less than 35,000  ug/m2/hr.
Typical concentrations  range   from  50  to  5,000 ppm  PCBs.
Predicted average  PCB concentrations in the  air would be
about 6.6 ug/m3  for  soils  with concentrations of 1,000 ppm
PCBs.  The average  volatilization rate is  expected  to be
about 5,375 ug/m2/hr.   These  values  were extrapolated from
data for sand assuming a 3.6-mph wind and an air temperature
of 68°F (007) .  The volatilization rates from the sandy soils
of the Parking Lot area are expected to be  closely approxi-
mated by these predictions.

Excavated areas would be backfilled with clean borrow mate-
rials brought in from offsite.   The borrow site  would prob-
ably experience topographic and other minor local impacts.

Soil with PCB levels  greater  than 50 ppm would be removed.
If a 98 percent  removal efficiency were  achieved,  it would
remove an  estimated 272,100 Ib  of PCBs in  approximately
105,000 yd3 of soils.  This would remove about 35 percent of
all the PCBs now found in the North Ditch/Parking Lot area.

Permit requirements are anticipated to include:

     •    Well water removal permit (State)

     •    USCOE Section 404 (disposal in waterways) permit

     •    IEPA water quality certification on all USCOE per-
          mits

     •    NPDES  permit  (State/Federal)  for  point-source
          water discharge from the water treatment plant

     •    IEPA permit for construction of  wastewater treat-
          ment facilities

     •    IEPA  (Division of Land and Noise)  special waste
          hauler's permit
PD102.001                   4-37

-------
     •    City of Waukegan construction permits

     •    Local land use approval

     •    Certification of Authority to haul PCB commodities
          (ICC and I1CC)

     •    USEPA toxic substances disposal approval

     •    IEPA approval if material  is disposed in a  cur-
          rently non-PCB-approved site

     •    North Shore  Sanitary  District approval if water
          discharge goes to the sanitary sewer

Alternative 3:  Excavate-Fix-Dispose.  Alternative  3  would
dewater existing  contaminated  soil by a well  and pumping
system.  Water drawn from the site would be treated at the
package water  treatment plant.   Solids from the  treatment
plant would be disposed of  with the other  project  solids.
Treated water, with  PCB levels  below 1 ppb, would  be  dis-
charged into the harbor or to a sanitary sewer.

Dewatered soils would  be  excavated by backhoe or front end
loader.  Excavated areas would be backfilled with clean bor-
row materials brought in from offsite.  The borrow site would
probably experience topographic and other minor local impacts.

The highest reported concentration in Parking Lot area soils
is less than 10,000 ppm (001).   The predicted PCB concentra-
tion in air during  excavation would  be less than 43 ug/m3,
well below 1,000 ug/m3, the OSHA standard.   The  volatiliza-
tion rate  is  predicted to be  less than 35,000  ug/m2/hr.
Typical concentrations  range  from 50  to 5,000 ppm PCBs.
Predicted average  PCB  concentrations in the  air would be
about 6.6 ug/m3  for  soils with  concentrations of 1,000 ppm
PCBs.  The  average  volatilization  rate is  expected to be
about 5,375 ug/m2/hr.   These values  were  extrapolated from
data for sand, assuming a  3.6-mph  wind and an air tempera-
ture of 68°F  (007).  The volatilization rates from the sandy
soils of the  Parking Lot  area are expected to be closely
approximated by these predictions.

Excavated soil would be fixed  into a nonflowable form for
transport to a licensed chemical waste landfill.  This would
minimize uncontrolled  release of PCBs  by spillage,  leakage,
or other means.  Control of volatilization  during transport
may  require  the  use of covers.  Fixed materials would be
disposed of in a  licensed chemical waste  landfill,  in com-
pliance with  State and  Federal  standards for PCB waste dis-
posal.  Fixation may not  be  necessary if the  contaminated
soil  (mostly sand) can  be excavated in a nonflowable state.
PD102.001                   4-38

-------
Soil with PCB  levels  greater  than 50 ppm would be removed.
If a  98 percent  removal  efficiency were achieved, it would
amount to an estimated  272,100 Ib of PCBs in approximately
105,000 yd3 of soils.  This would remove about 35 percent of
all the PCBs now found in the North Ditch/Parking Lot area.

Permit requirements are anticipated to include:

     •    Well water removal permit  (State)

     •    USCOE Section 404 (disposal in waterways) permit

     •    IEPA water quality certification on all USCOE per-
          mits

     •    NPDES permit (State/Federal) for point-source water
          discharge from the water treatment plant

     •    IEPA permit for construction  of  wastewater  treat-
          ment facilities

     •    IEPA  (Division  of  Land and Noise)  special  waste
          hauler's permit

     •    City of Waukegan construction permits

     •    Local land use approval

     •    Certification of Authority to haul PCB commodities
          (ICC and I1CC)

     •    USEPA toxic substances disposal approval

     •    IEPA approval  if material is disposed in a  cur-
          rently non-PCB-approved site

     •    North Shore Sanitary District approval if  water
          discharge goes to the sanitary sewer

Alternative 4t   Contain-Cap.   Alternative 4 would use a slurry
wall around the perzmeter of the soil with greater than 50 ppm
PCBs, containing an estimated 277,700 Ib of PCBs.  The slurry
wall would extend down into the existing glacial till beneath
the local sand (about 35 ft deep).  This would reduce future
dispersion of PCBs into other soil or groundwater.  The site
would be capped  with  impermeable materials to seal in  the
contaminated soils and to reduce surface water infiltration.
The area would be resurfaced for future parking.

Containment would protect  adjacent soils and would reduce
groundwater contamination and volatilization.  Capping would
raise the elevation of  the  Parking Lot area.   Groundwater
PD102.001                   4-39

-------
monitoring wells would be constructed to monitor  the  effec-
tiveness of the slurry wall.

Containment of the Parking  Lot in this manner would require
a USEPA waiver  from  the requirements of  40  CFR 761  under
TSCA, since PCBs would remain in proximity to Lake Michigan
and in an area with a high groundwater table (058).

Permit requirements are anticipated to include:

     •    City of Waukegan construction permit

     •    Local land use approval

     •    USEPA toxic substances disposal approval

     •    IEPA approval  if  material is disposed  in a  cur-
          rently non-PCB-approved site

Alternative 5;  No Action.   The  No  Action alternative will
leave PCB concentrations  from 50  to over 5,000 ppm in the
Parking Lot area.  This  represents  an estimated 277,700 Ib
of PCBs.   PCBs  in these  concentrations  are regulated by
40 CFR 761 under TSCA.

The groundwater is within 3 feet of the surface of the Parking
Lot, resulting in contamination of this water.  It is  estimated
that the slowly moving water will begin releasing some 8 Ib
per day of PCBs into Lake Michigan in approximately 60 years
(048).  This will  result in further contamination of  local
water and soil, which will continue for decades thereafter.

Although volatilization of  contaminated soil in the Parking
Lot does not appear to be occurring now because it is  paved,
the potential  exists  if the soil is  disturbed.  Grading,
trenching, drilling, digging, or other activities necessary
for utility  installation,  drainage, or other construction
projects could cause volatilization of PCBs.

RECOMMENDED ALTERNATIVES FOR DETAILED EVALUATION

Based on the  initial  screening  of alternatives, the recom-
mended Remedial Action Alternatives for detailed  evaluation
are presented  in  the  flow diagrams of Figures  4-1 through
4-5.  In accordance with CERCLA,  the  No  Action alternative
has been eliminated from further consideration  for all areas
because:   (1) there has  been a  release of a hazardous sub-
stance from a facility  (PL  96-510 Section 104(a) (1));   (2) lack
of remedial action at Slip  No. 3 and  the  Upper  Harbor would
impact the  local  industrial, commercial, and recreational
users of the harbor;  (3) PCB accumulation in fish would im-
pact  the  local  fishing industries;  (4) a potential exists
for spread of PCB contamination either by natural or manmade
events from uncontrolled PCBs regulated by 40 CFR 761.
PD102.001                   4-40

-------
The results of the  initial  screening  process  are  summarized
as follows:

Slip No. 3

After refining the  initial  screening  alternatives  for  engi-
neering  feasibility,  the  following alternatives were eval-
uated for cost-effectiveness and environmental impacts:
     Alternative 2A:


     Alternative 2B:

     Alternative 2C:
Dredge-Dewater in North Ditch-Fix-
  Dispose

Dredge-Dewater in Lagoon-Fix-Dispose

Dredge-Dewater in Bins/Cyclones/
  Filters-Fix-Dispose
     Alternative 2D:  Dredge-Dewater in Barges-Fix-Dispose

     Alternative 3:   Dredge-Dewater in Lagoon-Dispose

Based on the initial  screening,  the  cost-effective  alterna-
tives appear to  be 2B,  2D, and  3.   Dewatering  the  dredged
sediments in a lagoon without fixation resulted in the least
cost.  From an environmental standpoint, dewatering in barges
and fixing the material for prompt disposal  resulted  in  the
least short-term environmental impact.  These three alterna-
tives were retained for detailed evaluation.

Upper Harbor

After refining the initial screening alternatives  for engi-
neering feasibility,  the  following alternatives were  evalu-
ated for cost-effectiveness and environmental impacts:
     Alternative 2A:
Dredge-Dewater in North Ditch-Fix-
  Dispose
     Alternative 2B:  Dredge-Dewater in Lagoon-Fix-Dispose

     Alternative 2C:  Dredge-Dewater in Bins/Cyclones/Fil-
                        ters-Fix-Dispose

     Alternative 3:   Dredge-Dewater in Lagoon-Dispose

Based on the initial  screening,  the  cost-effective  alterna-
tives appear to be  2B and  3.   Dewatering dredged sediments
in a  lagoon  without  fixation resulted  in  the least cost.
From an environmental standpoint, dewatering in a lagoon and
fixing the material for prompt disposal resulted in the least
short-term environmental  impact.  These  two alternatives
were retained for detailed evaluation.
PD102.001
      4-41

-------
Slip No. 3 and Upper Harbor

After refining the initial screening alternatives for engineer-
ing feasibility, the  following  alternatives were evaluated
for cost-effectiveness and environmental impacts:

     Alternative 6A:  Contain-Dredge-Cap

     Alternative 6B:  Contain-Dredge part of Upper Harbor-Cap

Based on the initial screening, the cost-effective alternatives
for Slip No. 3 and Upper Harbor appear to be Alternatives 6A
and 6B.

North Ditch Area

After refining the  initial screening  alternatives  for engi-
neering feasibility, the  following  alternatives  were  evalu-
ated for cost-effectiveness and environmental impacts:

     Alternative 1:   Excavate-Dispose

     Alternative 3:   Excavate-Fix-Dispose

     Alternative 4A:  Excavate-Contain-Cap

     Alternative 4B:  Excavate-Contain part of the North
                      Ditch-Cap

Based on the  initial  screening,  the cost-effective alterna-
tives for the' North Ditch area  appear  to  be Alternatives  4A
and 4B.  Alternatives 1 and 3 were  also included in the al-
ternatives retained for detailed  evaluation because offsite
disposal of  PCB-contaminated  soils  resulted in lower long-
term environmental impacts, although the short-term environ-
mental  impacts would be higher  than for Alternatives  4A and
4B.

Parking Lot Area

After refining the  initial screening  alternatives  for engi-
neering feasibility, the  following  alternatives  were  evalu-
ated for cost-effectiveness and environmental impacts:

     Alternative 1:  Excavate-Dispose

     Alternative 3:  Excavate-Fix-Dispose

     Alternative 4:  Contain-Cap
PD102.001                   4-42

-------
Based on initial  screening,  the cost-effective alternative
for the Parking Lot area appears to be Alternative 4.  Alter-
natives 1 and 3 were also  included  in the alternatives re-
tained for detailed evaluation  because  offsite disposal of
PCB-contaminated soils resulted in  lower  long-term environ-
mental impacts, although the short-term environmental impacts
would be higher than for Alternative 4.
PD102.001                   4-43

-------
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     Section 5
     DETAILED EVALUATION—ENGINEERING AND COST ASPECTS
The purpose of  the  evaluation  presented in this section was
to develop detailed information to evaluate the alternatives
retained  from  initial screening.   Detailed evaluation  was
accomplished by more  fully developing the  engineering aspects
of each alternative,  identifying in more detail the potential
environmental impacts of each alternative, and developing
Order-of-Magnitude  cost  estimates  (as defined in  Section 1)
for each  alternative.   This  section discusses the detailed
engineering evaluation and costs of the alternatives retained
in Section 4.   The  environmental  aspects of these alterna-
tives are discussed in Section 6.

SLIP NO.  3

Alternative 2B;  Dredge-Dewater in Lagoon-Fix-Dispose

A sediment dispersal  control device, consisting of  a  double
silt curtain or sheet piling,  would be  installed  across the
mouth of  Slip  No.  3  (Figure 5-1) .  Sediments  with  greater
than 50 ppm PCBs would be removed with a  hydraulic dredge
and the  sediment  slurry pumped through  a  pipeline  to  the
initial  solids  dewatering lagoon.  Because  the hydraulic
dredge cannot penetrate  the  area  of deep  contaminated  sand
and silt  near the OMC outfall, a  mechanical dredge  would be
used to remove this material.

This deep dredging  would be  performed inside  a single  sheet
pile cofferdam.  The  solids would be loaded onto  trucks and
transported to  the  initial solids dewatering  lagoon.   The
water level inside  the cofferdam xvould be kept lower  than
outside to cause water  flow  toward  the  contained  area.   The
removed water would be routed to a water treatment plant for
suspended solids and  PCB removal  (to 1  ppb PCBs), then  dis-
charged to the harbor or to a sanitary sewer.

Solids would be dewatered  in a clay-lined  dewatering  lagoon
constructed on  OMC  property.   Volatilization  would  be  con-
trolled by covering the  filled lagoon  surface with organic
sludge.   The supernatant would be continuously decanted and
routed to a 1,500-gpm water  treatment  plant to remove  sus-
pended solids and dissolved PCBs down to 1 ppb before being
discharged.  After  dredging activities  are completed,  rain-
water and leachate  water would be  treated  by  the 1,500-gpm
water treatment plant for the duration  of the dewatering
process.

Solids would be removed from the lagoon by dragline  about
2 months  after  dredging activities are  completed,  loaded
into trucks,  and transported to the batch plant.
PD452.001                    5-1

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The solids would be fixed at the batch plant by adding port-
land cement, Locksorb,  or  another fixing agent to hydrate
the excess water.  The mix would then be transported to cur-
ing cells.  The fixed solids would cure until they were non-
flowable.  This is expected to take about 1 day.  The  fixed
solids would be removed  from the  curing  cells  by  front end
loaders for transportation by truck to an approved disposal
site.

Lagoon.  A  24,000-yd3  lagoon  would be required to dewater
sediments from Slip No.  3.  The  assumed  shape  and location
of the proposed lagoon are shown  on Figure  5-1.   The capac-
ity of the lagoon is based on 2 ft of  freeboard and 8  ft  of
storage.  The lagoon would have a clay liner system consist-
ing of the following:

     •    A 6-inch-thick, compacted soil-cement layer  would
          be constructed to prevent removal of the clay liner
          during solids removal.

     •    A 1-ft-thick, compacted clay liner with a permeabil-
          ity less than 10 ° centimeters per second (cm/sec)
          would be  constructed  to prevent  percolation of
          PCB-contaminated water.   It would take  about 4
          years for the PCB-contaminated water to penetrate
          the 1-ft-thick clay liner.

     •    A 1-ft-thick sand or gravel layer with pipe under-
          drains would  be  constructed to collect any  PCB-
          contaminated water  that may penetrate  the  clay
          liner.

     •    A 1-ft-thick, compacted clay liner with a permea-
          bility less than 10~8 cm/sec would be constructed
          for additional protection  against percolation of
          PCB-contaminated water.

Curing Cells.  Three 1,400-yd3 curing cells would be required
to cure the fixed solids from the batch  plant.  The assumed
shape and location of the proposed curing cells are shown on
Figure 5-1.  The capacity  of  the curing cells is based on
1 ft of freeboard and 4 ft of storage.  The earth-lined cells
would have  the  same  clay liner  system as described for the
lagoons  in  Slip No. 3—Alternative 2B.  In  addition,  the
curing cells would have 2-ft-thick, 5-ft-high concrete walls
to divide the earth-lined area into three compartments.

Temporary Storage Requirements.   Dredged solids would require
temporary storage  in a  lagoon  for  dewatering.  For Slip
No. 3—Alternative 2B,  dewatering  is  expected  to take
2 months after dredging activities are completed.  When the
solids are  removed  from temporary storage,  they  would be
fixed  and  would require  an  additional  day  of temporary
PD452.001                    5-2

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storage for curing.  After curing, they would be disposed of
in a licensed chemical waste landfill.

Water Treatment.  Slurry water from dredging activities would
need to be treated before being discharged.

Laboratory tests conducted  by  Mason & Hanger  (004)  demon-
strated that the slurry water from dredging activities could
be treated by available conventional and advanced water treat-
ment processes  to  meet the discharge requirement of 1  ppb
PCBs.

Water treatment would consist of:

     •    Coagulation/sedimentation to coagulate and settle
          fine sediments that were not removed in the initial
          solids dewatering lagoon  (using  alum  and/or cati-
          onic polymer)

     •    Sand filtration to remove suspended solids

     •    Carbon filtration to remove soluble PCBs

     •    A clearwell to monitor PCB levels before the water
          is discharged

The water treatment  system would be a "package plant,"  of
factory-constructed modules, that could be easily  installed
and removed.  The package  plant  would have the capacity to
treat 1,500 gpm.  The  lagoon  would act as  an  equalization
basin to hold up to  3,000  gpm  for a 2-hour detention time.
The water treatment  plant  would operate continuously.   If
the water level  in  the lagoon drops to the  sediment/water
interface, the treated water would  be recycled.  This water
treatment plant would  be used  during the  dredging of Slip
No. 3 and the  localized  area.   In addition, rainwater  and
leachate water would need treatment on an intermittent basis
for about 3 months during dewatering.

PCB concentrations in the water  in  Slip  No. 3,  confined by
sediment dispersal  control consisting of  either  a double
silt curtain or  sheet  piling,  are not expected to exceed
1 ppb (035).  Therefore,  the in-place waters may not require
treatment.  If higher-than-allowable concentrations  of  PCBs
in solution are found after dredging, however,  treatment  of
the water confined by the sediment dispersal control device
may consist of adding one or both of the following treatment
materials directly to Slip No.  3:

     •    Cationic polymer or  alum  to coagulate and settle
          fine suspended sediments

     •    Activated carbon to remove soluble PCBs
PD452.001                    5-3

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A dredge would then remove the settled activated  carbon  and
solids confined by the sediment dispersal control device.

Major treatment equipment  and utilities  that would be re-
quired for  the  1,500-gpm water treatment  system  for Slip
No. 3—Alternative 2B include:

     •    Intake pumps, valves, and process piping

     •    Polymer (or alum) feed systems

     •    Concrete sedimentation basin

     •    Pressure filter pumps

     •    Pressure sand filters

     •    Carbon adsorption filters

     •    Turbidity meters

     •    Modular steel tank clearwell

     •    Clearwell pumps

     •    Liquid level controls, pump controls, and  control
          panel

     •    Leachate sump pumps

     •    Electrical service to all equipment

     •    Electrical lighting system

     •    Onsite water quality laboratory

Operation, Maintenance,  and  Monitoring Requirements  of the
Completed Remedy.  In  Slip No.  3—Alternative 2B, the pro-
posed action would remove the PCBs from the project site and
dispose of them in a licensed chemical waste landfill.  There-
fore, there  would  be  no onsite long-term  operation,  main-
tenance,  or  monitoring requirements after completing the
proposed remedy.

Offsite Disposal Needs, Permit Requirements, and Transporta-
tion Plans.  In Slip No. 3—Alternative 2B, about 14,200 yd3
of fixed PCB-contaminated solids, about 5,800 yd3 of contami-
nated liner material, and 2,300 yd3 of contaminated volatili-
zation control material would require disposal.  In addition,
about 39,000 yd3 of uncontaminated lagoon embankment material
would require disposal.  At this writing, CECOS in Williams-
burg, Ohio,  is the closest  chemical waste  landfill licensed
to receive  PCBs.   Under CECOS management,  available  space
PD452.001                    5-4

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was confirmed for disposal of  these  wastes.   Transportation
would be provided by CECOS.

BFI, located 13 miles from the OMC site, is a licensed hazar-
dous waste disposal facility that could be licensed to receive
PCBs.  Such  licensing  could  be accomplished by means of  a
one-time TSCA permit  for this project.  BFI  has  confirmed
that space is available  for  disposal of these wastes.  BFI
would also provide transportation to its landfill.  Construc-
tion documents  prepared  during final  design  should allow
competitive  bidding between  the operators  of  suitable
facilities.

Major Equipment.  Major construction equipment and utilities
required for Slip No. 3—Alternative 2B include:

     •    Pile driver

     •    Hydraulic and clamshell dredge

     •    Bulldozer

     •    Compactor

     •    Scarifier/mixer

     •    Dump trucks

     •    Front end loader

     •    Backhoe

     •    Dragline

     •    Batch plant

     •    Water treatment plant (see Water Treatment earlier
          in this section)

     •    Electrical service for batch plant

     •    Electrical lighting

     •    Water service for contractor's temporary facilities

Special Engineering Considerations.  For Slip No.  3—Alter-
native 2B the following  special  engineering considerations
are presented.

Engineering considerations concerning  the  dredging of Slip
No. 3 include:
PD452.001                    5-5

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     •    Type of dredge head and rate and pattern of dredg-
          ing to minimize roiling of sediments

     •    Type of sediment dispersal control to minimize possi-
          bility of contaminating the emergency drinking water
          supply intake located at the mouth of the harbor

     •    Stability of sheet piles surrounding Slip No.  3

     •    Type of  cofferdam  for  dredging of deep  contami-
          nated sand and  silt  near  former OMC outfall,  and
          means to prevent failure of existing  sheet piling
          during cofferdam installation and removal

Engineering considerations  concerning the  initial solids
dewatering lagoon include:

     •    Construction techniques necessary to obtain satis-
          factory permeabilities in the clay liner

     •    Durability of the soil-cement

     •    Determining how much of the lagoon  liner material
          must be  disposed  of in a  licensed  PCB disposal
          facility

Engineering considerations concerning the  sediment dewater-
ing process include:

     •    Determining the moisture  content of sediments to
          be removed after dewatering

     •    Controlling volatilization

Engineering considerations concerning fixation include:

     •    Moisture content of solids to be fixed

     •    Amount of fixing agent required

     •    Volume of fixing agent

     •    Volume of solids to be removed

     •    Possible  interferences  of contaminants  with  the
          fixing agent

     •    Time required for curing

     •    Cost-effectiveness of fixing with portland cement,
          Locksorb, and/or other fixing agent

Engineering considerations  concerning the water  treatment
process include:
PD452.001                    5-6

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     •    Determining  the  cost-effectiveness of  replacing
          activated  carbon  with Klensorb  for  soluble PCB
          removal  if the activated  carbon  should  become
          blinded by the oily nature of PCBs

     •    Water quality requirements for discharging  to  the
          harbor or to a sanitary sewer

Engineering considerations  concerning  disposal  of the PCB-
contaminated sediments include:

     •    Ensuring that  the sediments have  a  nonflowable
          consistency

     •    Ensuring that  moisture or solids  do  not escape
          during transport  and  disposal  of the fixed sedi-
          ments

     •    Controlling volatilization

Reliability.  Slip No. 3—Alternative  2B would remove PCB-
contaminated  sediment with  concentrations  greater than
50 ppm from Slip No. 3.  The alternative includes  dredging,
dewatering, water  treatment,  sediment solidification, and
disposal in a licensed chemical waste landfill.  This alter-
native would be effective in abating  further PCB  contamina-
tion of the Waukegan  area and  Lake  Michigan.  Slip No. 3—
Alternative 2B is considered reliable.

Costs.  The Order-of-Magnitude cost estimate for Slip No. 3—
Alternative 2B is presented in  Table  5-1.   A present-worth
analysis was used.

The cost estimates shown were prepared for guidance in pro-
ject evaluation and implementation from the information avail-
able at the time of  the  estimate.   The costs were based on
second quarter 1983 dollars.  The final costs of the project
will depend on actual  labor and  material costs, competitive
market conditions, final project scope, implementation sche-
dule, and other variable  factors.   As a result,  the final
project costs may vary from the estimates presented herein.

A description of the major elements included in the Table 5-1
line items for Slip No. 3—Alternative 2B follows:

     •    Mobilization includes the contractor costs to start
          up the job,  transfer work crews  and  equipment to
          the site,  and  provide temporary  facilities,  as
          well as insurance and  bonds.   Mobilization costs
          were estimated at 10  percent of the total  costs
          for all the  line  items except  health and  safety
          requirements and engineering, legal, and  adminis-
          tration.
PD452.001                    5-7

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                                 Table  5-1

                          DETAILED  COST ESTIMATE
                                SLIP  NO.  3
                              ALTERNATIVE 2B
                   DREDGE-DEWATER IN  LAGOON-FIX-DISPOSE
                         OMC  HAZARDOUS  WASTE  SITE
                           WAUKEGAN, ILLINOIS
                                 13-5M28.0
Description
Mobilization
Health and safety requirements
General site preparation
Sediment dispersal control
Dredging
Localized cofferdam and dewater-
ing
Dredging of deep sand and silt
Initial solids dewatering —
lagoon
Water treatment plant and water
disposal
Solids removal
Fixation
Transportation and disposal
Engineering, legal, and adminis-
tration
Subtotal
Contingency
Total
Capital
Costs
$ 600,000
330,000
290,000
60,000
60,000
390,000
20,000
1,570,000
1,260,000
60,000
1,580,000
710,000
1,180,000
8,110,000
2,430,000
$10,540,000
Present
Worth of
O&M Costs
0
0
0
0
0
$ 60,000
0
10,000
60,000
0
0
0
20,000
150,000
50,000
$200,000
Present
Worth
$ 600,000
330,000
290,000
60,000
60,000
450,000
20,000
1,580,000
1,320,000
60,000
1,580,000
710,000
1,200,000
8,260,000
2,480,000
$10,740,000
PD998.063.1
5-8

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          Health and safety requirements includes the contrac-
          tor costs  for workers'  personal  protection and
          surveillance equipment  and  materials.   They also
          would include special equipment and facilities for
          decontamination.  Health  and safety  costs were
          estimated at 5 percent  of the total costs  for  the
          same  line  items used to  determine mobilization
          costs plus the mobilization costs.

          General  site  preparation  includes the  costs  to
          remove and  replace  existing piles  and floating
          docks in Slip  No.  3;  remove existing intake and
          outlet pipes near the OMC  outfall to  Slip No.  3;
          furnish and install temporary floating docks;  con-
          struct a new large boat hoisting facility; install
          chain link fence around the lagoon, fixation cells,
          batch plant, and water  treatment  plant;  and con-
          struct a roadway to the lagoon and fixation cells.

          Sediment dispersal control  includes the  costs  to
          furnish,  install, and remove the  double  silt cur-
          tain.

          Dredging includes the costs to  dredge the  sedi-
          ments and pipe them to the initial solids dewater-
          ing basin.

          Localized cofferdam  and dewatering includes the
          costs to install and  remove a single sheet pile
          cofferdam at the localized area; partially dewater
          the cofferdam; and to remove and replace the sheet
          pile bulkhead.

          Dredging of deep sand and silt  includes  the costs
          to dredge the  contaminated  sand and silt  within
          the cofferdam.

          Initial  solids  dewatering—lagoon includes  the
          costs to install and remove lagoon embankment  and
          liner material; the costs to provide,  remove,  fix,
          and dispose of  volatilization control material;
          the costs for grading the site after lagoon removal;
          the costs for site preparation and annual lease of
          the lagoon site; and the costs  for installing  and
          monitoring the air quality  sampling  stations  and
          the groundwater monitoring wells.

          Water treatment plant and water disposal  includes
          the costs to install and remove a  1,500-gpm water
          treatment plant and the costs  for rental of the
          water treatment plant.
PD452.001                    5-9

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     •    Solids removal  includes  the  costs to remove  the
          sediments from the initial solids dewatering basin
          and transport the solids to the batch plant.

     •    Fixation includes the costs to install and  remove
          curing cell embankment,  liner  material,  and con-
          crete divider walls; mix  the  solids  with cement;
          haul fixed solids to the  curing  cells; and  remove
          fixed solids from the curing cells.

     •    Transportation and disposal includes the costs  to
          haul the fixed contaminated sediments to a licensed
          chemical waste landfill.

     •    Engineering,  legal,  and administration  includes
          the costs to  design  the remedial action alterna-
          tives, administer the construction,  acquire  ease-
          ments, supervise  consultant  and  contractor work,
          and  conduct  similar  activities.  Engineering,
          legal, and administration costs  were estimated  at
          17 percent of the total costs for all the  above
          line items.

     •    Contingency was  estimated at 30  percent  of the
          total costs for all of the above line items.

Alternative 2D;  Dredge-Dewater in Barges-Fix-Dispose

For this alternative,  a sediment dispersal control device as
described for Slip No.  3—Alternative 2B would be  installed
across the mouth of Slip No. 3 (Figure 5-1).  Sediments with
greater than 50 ppm PCBs would be removed by hydraulic dredge
and the  sediment  slurry pumped through  a  pipeline  to the
initial solids dewatering barges.  Dredging of the deep con-
taminated sand and silt would be  performed as  described for
Slip No. 3—Alternative 2B.

Solids would be dewatered in  ten barges located within the
Upper Harbor.  Volatilization would be controlled by covering
the sediments in the filled barges with organic sludge.  The
supernatant would be  continuously  decanted and routed to a
1,500-gpm water treatment plant as described for Slip No. 3—
Alternative 2B.  After  dredging  activities are completed,
rainwater and leachate water would be treated by the 1,500-gpm
water treatment plant  for the duration  of the dewatering
process.

Solids would be removed by backhoe or dragline about 2 months
after dredging activities are completed, loaded into  trucks
and transported to  the  batch plant.  The  solids  would be
fixed as described for  Slip No.  3—Alternative 2B  to  render
solids to a nonflowable form, and transported by truck to an
approved disposal site.
PD452.001                   5-10

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Barges.  Ten barges, each with a storage capacity of 2,000 yd3,
would be required to dewater sediments from Slip No. 3.  The
barges would be located within the Upper Harbor.  The assumed
shape and location  of  the barges are shown on  Figure  5-1.
Barges would be steel-deck  cargo barges  with flat bottoms.
Each barge would be equipped with submersible pumps to decant
the supernatant slurry water.

Curing Cells.  The  curing cells  for this alternative would
be the same as required for Slip No. 3—Alternative 2B.  The
assumed shape and location are shown on Figure 5-1.

Temporary Storage Requirements.  Temporary  storage  require-
ments for Slip No.  3—Alternative  2D  would  be the  same  as
for Alternative 2B, except that barges would be used in place
of a lagoon.  The barges would be moored in the Upper Harbor
until they were emptied and decontaminated.

Water Treatment.   Slurry water from dredging activities would
be treated  in  the  same  manner as for Slip  No.  3—Alterna-
tive 2B.

Operation, Maintenance, and  Monitoring  Requirements of the
Completed Remedy.   These  requirements would be  the same as
those for Slip No.  3—Alternative 2B.

Offsite Disposal Needs,  Permit Requirements, and Transporta-
tion Plans.   These items would be the same as those for Slip
No. 3—Alternative 2B,  except that there would be no disposal
of contaminated liner material or uncontaminated lagoon embank-
ment material.  However, disposal of material from the decon-
tamination of the barges would be required.

Major Equipment.   Major construction equipment and utilities
required for Slip No.  3—Alternative 2D include:

     •    Pile driver

     •    Hydraulic and clamshell dredges

     •    Barges

     •    Backhoe

     •    Dragline

     •    Batch plant

     •    Dump trucks

     •    Front end loader

     •    Water treatment plant  (see Water Treatment, earlier
          in this section)
PD452.001                   5-11

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     •    Electrical service for batch plant

     •    Electrical lighting

     •    Water service for contractor's temporary facilities

Special Engineering Considerations.  For Slip No. 3—Alterna-
tive 2D the following special engineering considerations are
presented.

Engineering considerations .concerning  the  dredging of Slip
No. 3 include:

     •    Type of dredge head and rate and pattern of dredg-
          ing to minimize roiling of sediments

     •    Type of sediment dispersal control to minimize possi-
          bility of contaminating the emergency drinking water
          supply intake located at the mouth of the harbor

     •    Stability of sheet piles surrounding Slip No. 3

     •    Type of cofferdam for dredging of deep contaminated
          sand and silt near  former  OMC outfall, and means
          to prevent failure of existing sheet piling during
          cofferdam installation and removal

Engineering considerations  concerning  the  initial solids
dewatering barges include:

     •    Method to remove sediments from barges

     •    Potential loss of contaminated sediments  from the
          barges

     •    Mooring space for barges in the harbor

     •    Decontamination of barges

Engineering considerations concerning  the  sediment  dewater-
ing process include:

     •    Determining the moisture  content of sediments to
          be removed after dewatering

     •    Controlling volatilization

Engineering considerations concerning fixation include:

     •    Moisture content of solids to be fixed

     •    Amount of fixing agent required

     •    Volume of fixing agent


PD452.001                   5-12

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     •    Volume of solids to be removed

     •    Possible  interferences  of contaminants with  the
          fixing agent

     •    Time required for curing

     •    Cost-effectiveness of fixing with portland cement,
          Locksorb, and/or other fixing agent

Engineering considerations  concerning the water  treatment
process include:

     •    Determining  the  cost-effectiveness of  replacing
          activated carbon  with Klensorb  for  soluble PCB
          removal  if  the activated  carbon should  become
          blinded by the oily nature of PCBs

     •    Water quality requirements  for  discharging  to  the
          harbor or to a sanitary sewer

Engineering considerations  concerning disposal of  the  PCB
contaminated sediments include:

     •    Ensuring  that  the sediments have  a  nonflowable
          consistency

     •    Ensuring  that  moisture  or  solids  do  not escape
          during transport  and  disposal  of the fixed sedi-
          ments

     •    Controlling volatilization

Reliability.  Slip  No. 3—Alternative 2D  would  remove PCB-
contaminated  sediments with concentrations  greater  than
50 ppm from Slip No. 3.  The alternative  includes  dredging,
dewatering, water  treatment,  sediment solidification,  and
disposal in a licensed chemical waste landfill.  This alter-
native would be effective in abating  further PCB  contamina-
tion of the Waukegan area and Lake Michigan.  Slip No. 3—Al-
ternative 2D is considered reliable.

Costs.  The Order-of-Magnitude cost estimate for Slip No. 3--
Alternative 2D is presented in Table 5-2.  This cost estimate
was developed as described for Slip No. 3—Alternative 2B.

The major elements  included in  the Table  5-2 line  items  for
Slip No. 3—Alternative 2D  are  the same  as  described for
Slip No. 3—Alternative 2B,  except as noted below:

     •    General site preparation does not include the costs
          to install a chain link fence around the lagoon.
PD452.001                   5-13

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                                 Table 5-2

                          DETAILED COST ESTIMATE
                                SLIP NO.  3
                              ALTERNATIVE 2D
                   DREDGE-DEWATER IN BARGES-FIX-DISPOSE
                         OMC HAZARDOUS WASTE SITE
                            WAUKEGAN, ILLINOIS
                                 13-5M28.0
Description
Mobilization
Health and safety requirements
General site preparation
Sediment dispersal control
Dredging
Localized cofferdam and dewater-
ing
Dredging of deep sand and silt
Initial solids dewatering —
barges
Water treatment plant and water
disposal
Solids removal
Fixation
Transportation and disposal
Engineering, legal, and adminis-
tration
Subtotal
Contingency
Total
Capital
Costs
$ 540,000
300,000
280,000
60,000
60,000
390,000
20,000
960,000
1,260,000
60,000
1,580,000
710,000
1,060,000
7,280,000
2,180,000
$ 9,460,000
Present
Worth of
O&M Costs
0
0
0
0
0
$ 60,000
0
10,000
10,000
0
0
0
10,000
90,000
30,000
$120,000
Present
Worth
$ 540,000
300,000
280,000
60,000
60,000
450,000
20,000
970,000
1,270,000
60,000
1,580,000
710,000
1,070,000
7,370,000
2,210,000
$ 9,580,000
PD998.063.2
5-14

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     •    Initial solids dewatering—barges includes the costs
          to rent  and decontaminate barges;  the  costs to
          provide, remove, fix, and dispose of volatilization
          control material; and the costs for installing and
          monitoring the air quality sampling stations.

Alternative 3:  Dredge-Dewater in Lagoon-Dispose

For this alternative, a sediment dispersal control device as
described for Slip No.  3—Alternative  2B would  be  installed
across the mouth  of  Slip  No.  3 (Figure 5-1).   Sediments in
excess of 50 ppm  PCBs would be removed by hydraulic dredge
and the  sediment  slurry pumped through a  pipeline to the
initial solids dewatering lagoon.  Dredging of the deep con-
taminated sand and silt would  be performed as described  for
Slip No. 3—Alternative 2B.

Solids would be dewatered  in a clay-lined  dewatering lagoon
constructed on OMC property.   The supernatant would  be con-
tinuously decanted and routed  to a 1,500-gpm water treatment
plant as  described for Slip No. 3—Alternative 2B.   After
dredging activities are completed, a 200-gpm water treatment
plant would treat rainwater and leachate water for the dura-
tion of the dewatering process.

After the dredging activities  are completed,  a RUG (or other
channeling device) would be used for channeling the sediments
to allow surface drainage.  The top layer of  solids would be
dried by evaporation.  The dried solids (typically the top 1
to 2 ft) would be periodically removed with a dragline.  The
solids would be loaded  into lined trucks and  transported  to
an approved disposal  site.  This  process  would  be repeated
about six times over a 2-year  period to remove the solids.

Lagoon.   The lagoon  for this alternative  would  be the same
as that required for Slip No.   3—Alternative  2B.  The assumed
shape and location of the lagoon are shown on Figure 5-1.

Temporary Storage Requirements.  Dredged solids would require
temporary storage in the lagoon for dewatering.   The  solids
would be stored until they could be removed in a nonflowable
state.  This is expected to take about 2 years.

Water Treatment.   Slurry water from dredging activities would
need to be treated before  being discharged.   This would be
accomplished with the same treatment system as described for
Slip  No.  3—Alternative 2B,  except  that  rainwater  and
leachate water would be treated using a 200-gpm  treatment
plant for about 2 years.

Operation, Maintenance, and Monitoring Requirements  of the
Completed Remedy.  These requirements  would be  the same as
those for Slip No. 3—Alternative 2B.
PD452.001                   5-15

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Offsite Disposal Needs, Permit Requirements, and Transporta-
tion Plans.   These  items would be  the same as  for Slip
No. 3—Alternative 2B, except that about 10,900 yd3 of  PCB-
contaminated solids and about 5,800 yd3 of contaminated liner
material  would require  disposal.   In addition,  about
39,000 yd3 of uncontaminated lagoon embankment material would
require disposal.

Major Equipment.  Major construction equipment and utilities
that would be required for Slip No. 3—Alternative 3 include:

     •    Pile driver

     •    Hydraulic and clamshell dredges

     •    Bulldozer

     •    Compactor

     •    Scarifier/mixer

     •    Dragline

     •    RUG  (052)

     •    Backhoe

     •    Front end loader

     •    Dump trucks

     •    Water treatment plant (see Water Treatment, earlier
          in this section)

     •    Electrical  lighting

     •    Water service for contractor's temporary facilities

Special Engineering Considerations.  For Slip No. 3—Alterna-
tive 3 the  following  special  engineering  considerations are
presented.

Engineering considerations  concerning  the dredging of  Slip
No. 3 include:

     •    Type of dredge head and rate and pattern of dredg-
          ing to minimize roiling of sediments

     •    Type  of  sediment dispersal  control  to minimize
          possibility of contaminating the emergency drinking
          water supply  intake located at the mouth of  the
          harbor
PD452.001                   5-16

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     •    Stability of sheet piles surrounding Slip No. 3

     •    Type of cofferdam for dredging of deep contaminated
          sand and silt near  former  OMC outfall, and means
          to prevent failure of existing sheet piling during
          cofferdam installation and removal

Engineering  considerations  concerning  the  initial solids
dewatering lagoon include:

     •    Construction techniques necessary to obtain satis-
          factory permeabilities in the clay liner

     •    Durability of the soil-cement

     •    Determining how much of the  lagoon  liner material
          must be disposed  of in a  licensed  PCS disposal
          facility

Engineering considerations concerning  the  sediment dewater-
ing process include:

     •    Determining the moisture content  of sediments to
          be removed after dewatering

     •    Potential for PCB volatilization during drying

Engineering  considerations  concerning the water  treatment
process include:

     •    Determining the  cost-effectiveness  of  replacing
          activated carbon with Klensorb for soluble PCB re-
          moval if the activated carbon should become blinded
          by the oily nature of PCBs

     •    Water quality requirements  for discharging to  the
          harbor or to a sanitary sewer

Engineering considerations concerning  disposal  of the  PCB-
contaminated sediments include:

     •    Ensuring that the  sediments  have a nonflowable
          consistency

     •    Ensuring that moisture  or solids do  not escape
          during transport and disposal of the sediments

     •    Controlling volatilization

Reliability.   Slip No.  3—Alternative 3 would remove  PCB-
contaminated sediment with concentrations greater than  50 ppm
from Slip No. 3.   The alternative includes dredging,  dewater-
ing, water treatment, and disposal  in a licensed  chemical
PD452.001                   5-17

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waste landfill.  Laboratory  tests  (004)  indicated that the
dredged sediments are difficult to dewater.  The time required
for dewatering is uncertain; it is estimated at 2 years with
mechanical dewatering.   After  dewatering is completed  and
the solids are removed and disposed of in a licensed chemical
waste landfill, this alternative would be  considered effec-
tive in abating  further  PCB contamination of  the  Waukegan
area and Lake Michigan.  Slip No. 3—'Alternative 3 is consid-
ered reliable.

Costs.  The Order-of-Magnitude cost estimate for Slip No.  3—
Alternative 3 is presented in Table 5-3.   This cost estimate
was developed as described for Slip No. 3—Alternative 2B.

The major elements included in Table 5-3 line items for Slip
No. 3—Alternative 3 are the same as described for Slip No. 3—
Alternative 2B, except as noted below:

     •    General site preparation does not include the costs
          to  install chain  link fence around  the  fixation
          cells and batch plant.

     •    Initial solids dewatering—lagoon does not include
          the costs to provide,  remove,  fix,  and  dispose of
          volatilization control material.

     •    Water treatment plant  and water  disposal includes
          the costs to install  and remove both a  1,500-gpm
          and a 200-gpm  water treatment  plant  and the costs
          for rental of  the water treatment plants.

     •    Solids removal includes  the costs to remove  the
          sediments from the initial solids dewatering basin
          and load into  trucks.

     •    Fixation costs would not be required.

UPPER HARBOR

Alternative 2B:  Dredqe-Dewater  in Lagoon-Fix-Dispose

This alternative is the  same as Slip  No.  3—Alternative 2B,
except that dredging of  deep contaminated  sand and silt would
not be required, and  the sediment dispersal control device
would be installed at the south  end of the Upper Harbor  (Fig-
ure 5-2) .

Lagoon.  A 118,000-yd3 lagoon would be required to dewater sedi-
ments from the Upper Harbor.  The assumed  shape and location
of the proposed lagoon are shown on Figure 5-2.  The capacity
of the  lagoon was  based on  2 ft of  freeboard and 8 ft of
storage.  The lagoon would have  a clay liner system identical
to that proposed for the Slip No. 3—Alternative 2B lagoon.
PD452.001                   5-18

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                                 Table 5-3

                          DETAILED COST ESTIMATE
                                SLIP NO. 3
                               ALTERNATIVE 3
                     DREDGE-DEWATER IN LAGOON-DISPOSE
                         OMC HAZARDOUS WASTE SITE
                            WAUKEGAN, ILLINOIS
                                 13-5M28.0

Description
Mobilization
Health and safety requirements
General site preparation
Sediment dispersal control
Dredging
Localized cofferdam and dewater-
ing
Dredging of deep sand and silt
Initial solids dewatering —
lagoon
Water treatment plant and water
disposal
Solids removal
Transportation and disposal
Engineering, legal, and adminis-
tration
Subtotal
Contingency
Total

Capital
Costs
$ 420,000
230,000
290,000
60,000
60,000

390,000
20,000
1,290,000
1,510,000
30,000
540,000
820,000
5,660,000
1,700,000
$ 7,360,000
Present
Worth of
O&M Costs
0
0
0
0
0

$ 60,000
0
40,000
80,000
0
0
30,000
210,000
60,000
$270,000

Present
Worth
$ 420,000
230,000
290,000
60,000
60,000

450,000
20,000
1,330,000
1,590,000
30,000
540,000
850,000
5,870,000
1,760,000
$ 7,630,000
PD998.063.3
5-19

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Curing Cells.  The curing  cells  for  this alternative would
be the same as those required for Slip No. 3—Alternative 2B.
The assumed shape and location are shown on Figure 5-2.

Temporary Storage Requirements.  Temporary storage requirements
would be the same as those required for Slip No. 3—Alterna-
tive 2B.

Water Treatment.  Slurry water from dredging activities would
be treated in the same manner as for Slip No. 3—Alternative 2B,
except that  rainwater  and  leachate water would be  treated
using a 200-gpm package water treatment plant on an intermit-
tent basis for about 6 months during dewatering.

Operation, Maintenance, and  Monitoring  Requirements of the
Completed Remedy.  These requirements would be the same as
those for Slip No. 3—Alternative 2B.

Offsite Disposal Needs, Permit Requirements, and Transportation
Plans.  These items would be the same as those for Slip No. 3—
Alternative 2B, except that about 46,400 yd3 of fixed PCB-con-
taminated solids, about 25,400 yd3 of contaminated liner material,
and 10,400 yd3 of contaminated volatilization control material
would require disposal.  In addition, about 99,300 yd3 of uncon-
taminated lagoon embankment material would require disposal.

Major Equipment.  Major construction equipment and utilities
required for Upper Harbor—Alternative  2B would be  the same
as those required for Slip No. 3—Alternative 2B, except that
a pile driver and clamshell dredge would not be required.

Special Engineering Considerations.  For Upper Harbor—Alter-
native 2B the  following  special engineering considerations
are presented.

Engineering  considerations  concerning the dredging of the
Upper Harbor include:

     •    Type of dredge head and rate and pattern of dredg-
          ing to minimize roiling of sediments

     •    Type of sediment dispersal control, to minimize possi-
          bility of contaminating the emergency drinking water
          supply intake located at the mouth of the harbor

     •    Stability  of  sheet piles  surrounding  the Upper
          Harbor

     •    Contaminated riprap  at the bottom  of  the sheet
          piles

All other  engineering considerations for this  alternative
would be the same as those for Slip No. 3—Alternative 2B.
PD452.001                   5-20

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Reliability.  Upper Harbor—Alternative 2B would remove PCB-
contaminated  sediments with  concentrations  greater  than
50 ppm from the Upper Harbor.  The alternative includes dredg-
ing, dewatering,  water treatment, sediment solidification,
and disposal  in a licensed chemical waste landfill.   This
alternative would be effective in abating further PCB contami-
nation of the Waukegan area and Lake Michigan.  Upper Harbor--
Alternative 2B  is considered reliable.

Costs  The Order-of-Magnitude cost estimate for Upper Harbor--
Alternative 2B  is presented in Table 5-4.  This cost estimate
was developed as described for Slip No. 3—Alternative 2B.

The major elements included in Table 5-4 line items for Upper
Harbor—Alternative 2B are  the  same as described  for  Slip
No. 3—Alternative 2B, except as noted below:

     •    General site  preparation includes  the  costs to
          install a chain link fence around the lagoon, fixa-
          tion  cells, batch plant, and water treatment plant
          and the costs to construct a roadway to the lagoon
          and curing cells.

     •    A localized cofferdam and dewatering would  not  be
          required.

     •    Dredging of deep contaminated sand  and  silt  would
          not be required.

     •    Water treatment plant and water disposal  includes
          the costs to install  and remove  both a 1,500-gpm
          and a 200-gpm water treatment plant and  the  costs
          for rental of the water treatment plants.

Alternative 3:  Dredge-Dewater in Lagoon-Dispose

This alternative  is  the  same as Slip No. 3—Alternative 3,
except that dredging of deep contaminated sand and silt would
not be required and the sediment dispersal control device
would be installed at the south end of the Upper Harbor (Fig-
ure 5-2) .

Lagoon.  The  lagoon required  for  this  alternative would be
the same as that  required  for Upper Harbor—Alternative 2B.
The assumed shape and  location  of the lagoon are  shown on
Figure 5-2.  The lagoon would have a clay liner system iden-
tical to that proposed for the Slip No. 3—Alternative 2B
lagoon.

Temporary Storage Requirements.   Dredged solids would require
temporary storage in the lagoon for dewatering.   The  solids
would be stored until  they can be removed  in  a nonflowable
state.   This is expected to take about 2 years.
PD452.001                   5-21

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                                 Table 5-4

                          DETAILED COST ESTIMATE
                               UPPER HARBOR
                              ALTERNATIVE 2B
                   DREDGE-DEWATER IN LAGOON-FIX-DISPOSE
                         OMC HAZARDOUS WASTE SITE
                            WAUKEGAN, ILLINOIS
                                 13-5M28.0
Description
Mobilization
Health and safety requirements
General site preparation
Sediment dispersal control
Dredging
Initial solids dewatering-
lagoon
Water treatment plant and water
disposal
Solids removal
Fixation
Transportation and disposal
Engineering, legal, and adminis-
tration
Subtotal
Contingency
Total
Capital
Costs
$ 1,400,000
770,000
80,000
80,000
220,000
5,250,000
1,530,000
240,000
4,250,000
2,320,000
2,740,000
18,880,000
5,660,000
$24,540,000
Present
Worth of
O&M Costs
0
0
0
0
0
$ 10,000
180,000
0
0
0
30,000
220,000
70,000
$290,000
Present
Worth
$ 1,400,000
770,000
80,000
80,000
220,000
5,260,000
1,710,000
240,000
4,250,000
2,320,000
2,770,000
19,100,000
5,730,000
$24,830,000
PD998.063.4
5-22

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Water Treatment.  Water treatment requirements for this alter-
native would be the same as for  Slip No.  3—Alternative  2B,
except that rainwater  and  leachate water would be  treated
using a  200-gpm package water treatment  plant for  about
2 years.

Operation, Maintenance, and Monitoring  Requirements of the
Completed Remedy.  These requirements would be the same as
those for Slip No. 3—Alternative 2B.

Offsite Disposal Needs, Permit Requirements,  and Transporta-
tion Plans.  These items would be the same as for Slip No.  3—
Alternative 3, except that about 35,700 yd3  of PCB-contaminated
solids and about  25,400 yd3 of  contaminated  liner material
would require disposal.  In addition, about  99,300 yd3 of uncon-
taminated lagoon embankment material would require disposal.

Major Equipment.  Major construction equipment and utilities
required for Upper Harbor—Alternative  3  would be the same
as those required for Slip No. 3—Alternative 3.

Special Engineering Considerations.  For Upper Harbor—Alter-
native 3 the  following special engineering considerations
are presented.

Engineering considerations concerning  the dredging  of  the
Upper Harbor include:

     •    Type of dredge head and rate and pattern of dredg-
          ing to minimize roiling of sediments

     •    Type of sediment dispersal control to minimize possi-
          bility of contaminating the emergency drinking water
          supply intake located at the mouth of the harbor

     •    Stability of  sheet  piles  surrounding  the Upper
          Harbor

     •    Contaminated riprap at the bottom  of  the sheet
          piles

All other  engineering  considerations for this  alternative
would be the same as those for Slip No.  3—Alternative 3.

Reliability.  Upper Harbor—Alternative 3 would remove  PCB-
contaminated  sediments  with  concentrations  greater  than
50 ppm from the Upper Harbor.   The alternative includes dredg-
ing, dewatering, water treatment, and disposal in a licensed
chemical waste  landfill.  Laboratory tests  (004)  indicated
that the dredged  sediments  are  difficult to  dewater.   The
time required for dewatering is uncertain.  After dewatering
is completed and the solids are removed and  disposed of in a
licensed chemical waste landfill, this  alternative  would be
PD452.001                   5-23

-------
effective in abating further PCB contamination of the Wauke-
gan area and Lake Michigan.   Upper Harbor—Alternative 3 is
considered reliable.

Costs.  The Order-of-Magnitude cost estimate for Upper Harbor—
Alternative 3 is presented in Table 5-5.  This cost estimate
was developed as described for Slip No. 3—Alternative 2B.

The major elements included in Table 5-5 line items for Upper
Harbor—Alternative 3 are  the  same as  described  for Slip
No. 3—Alternative 2B, except as noted below:

     •    General  site  preparation includes the  costs to
          install a chain  link  fence  around the lagoon and
          water treatment plant and the costs to construct a
          roadway to the lagoon.

     •    A localized cofferdam and dewatering  would  not  be
          required.

     •    Dredging of deep contaminated  sand and  silt would
          not be required.

     •    Initial solids dewatering—lagoon does not  include
          the costs to provide, remove,  fix, and  dispose  of
          volatilization material.

     •    Water treatment plant and water  disposal  includes
          the costs to  install  and remove  both a 1,500-gpm
          and a 200-gpm water treatment  plant and the costs
          for rental of the water treatment plants.

     •    Solids removal includes the costs to remove sediments
          from the initial solids  dewatering basin  and load
          into trucks.

     •    Fixation would not be required.

SLIP NO. 3 AND UPPER HARBOR

Alternative 6A:  Contain-Dredge-Cap

A sediment dispersal control device, consisting of  a  double
silt curtain or sheet piling, would be installed at the south
end of the Upper Harbor (Figure 5-3).  Then a cofferdam would
be constructed  near  the north end of  the  Upper Harbor to
close off Slip No. 3.  A slurry wall extending into the gla-
cial till would be constructed inside the cofferdam and around
the entire perimeter of the containment area.

Dredged  sediments  with  greater than 50  ppm PCBs  from the
Upper Harbor  would be placed  within  the contained  area.
Alternative 6A would  control  almost  100 percent of all the
PD452.001                   5-24

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                                 Table 5-5

                          DETAILED COST ESTIMATE
                               UPPER HARBOR
                               ALTERNATIVE 3
                     DREDGE-DEWATER IN LAGOON-DISPOSE
                         OMC HAZARDOUS WASTE SITE
                            WAUKEGAN, ILLINOIS
                                 13-5M28.0
Description
Mobilization
Health and safety requirements
General site preparation
Sediment dispersal control
Dredging
Initial solids dewatering-
lagoon
Water treatment plant and water
disposal
Solids removal
Transportation and disposal
Engineering, legal, and adminis-
tration
Subtotal
Contingency
Total
Capital
Costs
$ 770,000
420,000
80,000
80,000
220,000
3,830,000
1,590,000
110,000
1,780,000
1,510,000
10,390,000
3,120,000
$13,510,000
Present
Worth of
O&M Costs
0
0
0
0
0
$ 40,000
80,000
0
0
20,000
140,000
40,000
$180,000
Present
Worth
$ 770,000
420,000
80,000
80,000
220,000
3,870,000
1,670,000
110,000
1,780,000
1,530,000
10,530,000
3,160,000
$13,690,000
PD998.063.5
5-25

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PCBs now found in Slip No. 3 and Upper Harbor sediment.  Super-
natant would be continuously decanted and routed to an onsite
water treatment plant  for  suspended  solids  and PCS removal
(to I ppb PCBs),  then discharged to the harbor or to a sanitary
sewer.  After completion of dredging, a layer of filter fabric,
a 1-ft-thick  layer  of  sand with a drainage  system,  and a
3-ft-thick compacted clay  cap would  cover the  dredged  muck.
Five feet of  fill over the clay would  serve  as  a  surcharge.
Water collected from the drainage system would be treated as
described above.   Slip No. 3 would be left permanently filled.
Groundwater monitoring wells would be  installed around the
site for detection of potential PCB migration.

After completion of all dredging activities, the water treat-
ment plant would be removed and a new basin would be constructed
to replace Slip No. 3.   After settlement of the muck in Slip
No. 3 is complete,  the excess  surcharge material would be
removed and the area paved.

Containment/Encapsulation.  A slurry wall would be constructed
to completely encircle Slip No. 3 and  the northwest  portion
of the Upper Harbor.  The proposed containment area is shown
on Figure 5-3.  The existing glacial till  beneath the site
would be relied upon to act as a bottom seal.  An impervious
cap consisting of 3 ft of compacted clay covered by asphaltic
concrete paving would be used to cover the top of the filled-
in containment area.

Temporary Storage Requirements.  No  temporary  storage  would
be required.  This alternative does, however,  require  long-
term, onsite storage.

Water Treatment.   Harbor water from the containment area and
slurry water  from  dredging activities  in the  Upper  Harbor
would need to be treated  before discharge.   Treatment  would
be the same as that described for Slip No.  3—Alternative 2B,
except that  rainwater  and leachate water would be  treated
using a 200-gpm package water treatment plant for about I year
during dewatering and densification.

Operation, Maintenance, and Monitoring Requirements of the
Completed Remedy.  In Alternative 6A, PCBs are contained on-
site.  Groundwater  monitoring  wells  would  be  required to
determine whether PCBs were migrating  from the containment
area.  Should contaminant movement be  detected, an  internal
drainage system could be installed to maintain internal water
levels lower than external water levels so  that any  leakage
is into  the  containment area.   The  area would be capped.
The cap would need to be properly maintained so that it would
continue to be an impermeable barrier to surface water.

Offsite Disposal Needs, Permit Requirements, and Transporta-
tion Plans.   For Alternative 6A, no  PCB-contaminated solids
would require offsite disposal.  USEPA waivers in accordance
PD452.001                   5-26

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with 40 CFR 761 under  TSCA would be required to  leave  the
PCBs onsite.  About 46,600 yd3 of sediments containing about
310,000 Ib of PCBs would be contained in-place in the contain-
ment area.

Major Equipment.  Major construction equipment and utilities
required for Alternative 6A include:

     •    Pile driver

     •    Hydraulic dredge

     •    Slurry trench excavator

     •    Slurry mixing equipment

     •    Bulldozer

     •    Compactor

     •    Front end loader

     •    Dump trucks

     •    Paving equipment

     •    Water treatment plant  (see Water Treatment, earlier
          in this section)

     •    Electrical lighting

     •    Water services  for  contractor's  temporary  facili-
          ties

Special Engineering Considerations.  For Alternative 6A, the
following special engineering considerations are presented.

Engineering considerations concerning constructing the  cof-
ferdam and slurry wall include:

     •    Location, type, and dimensions of cofferdam sheet
          piles

     •    Type and method of placement of cofferdam fill

     •    Depth and construction  techniques  for the  slurry
          wall to ensure its integrity

     •    The effects of PCBs on slurry walls

Engineering considerations  concerning  the  dredging of  the
Upper Harbor include:
PD452.001                   5-27

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     •    Type of dredge head and rate and pattern of dredg-
          ing to minimize roiling of sediments

     •    Type of sediment dispersal control to minimize possi-
          bility of contaminating the emergency drinking water
          supply intake located at the mouth of the harbor

     •    Stability of sheet piles surrounding the Upper Harbor

     •    Contaminated riprap at the bottom of the sheet piles

Engineering considerations concerning the clay cap include:

     •    Selection of  cap material and  determination of
          correct placement methods

     •    Duration of surcharge

     •    Design of asphaltic concrete pavement for prolonged
          service as a membrane

Engineering considerations  concerning  the water  treatment
process include:

     •    Determining the  cost-effectiveness of  replacing
          activated carbon with Klensorb for soluble PCB re-
          moval if the activated carbon should become blinded
          by the oily nature of PCBs

     •    Water quality requirements for discharging to  the
          harbor or to a sanitary sewer
     •    Need for treatment of water removed from the drain-
          age layer beneath the clay cap

Reliability.  Alternative 6A would not dispose of PCB-contami-
nated solids offsite  but  would contain and cap Slip No.  3
and the northwest portion of the Upper Harbor.  There  is  no
data on long-term reliability of this alternative.  Groundwater
fluctuations may cause drying or cracking of the slurry walls
or the clay cap.  Freezing and thawing action may also cause
deterioration of the  slurry  walls  and  cap.   The underlying
glacial till may have  cracks,  fissures,  or pockets of more
permeable material  through which PCBs could migrate.   The
containment area would be monitored to permit ongoing evalua-
tion of the effectiveness and  integrity of  the  slurry  walls
and clay  cap.   The reliability of  the  containment can be
enhanced with development of additional design details:

     •    Freeze-thaw problems could be reduced by terminat-
          ing the slurry wall below the frostline.

     •    Use of a  flexible  membrane for the cap  could  be
          considered for more freedom in site grading.
PD452.001                   5-28

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     •    Should contaminant movement be detected, an inter-
          nal drainage system could be installed to maintain
          internal water  levels  lower  than external levels
          so that any leakage would be into  the  containment
          area.

Consideration of these types of  details during design would
make this alternative effective  in abating further  PCB  con-
tamination of the Waukegan area and Lake Michigan.  Alterna-
tive 6A is considered reliable.

Costs.  The  Order-of-Magnitude  cost  estimate for Alterna-
tive 6A is presented  in  Table  5-6.   This  cost estimate  was
developed as described for Slip No. 3—Alternative 2B.

The mobilization; health and safety requirements; engineering,
legal, and administration; and contingency costs included in
Table 5-6 for  Slip  No.  3 and Upper  Harbor—Alternative 6A
are the same as described for Slip No.  3—Alternative 2B.  A
description of the major  elements  included in the remaining
Table 5-6 line items follows:

     •    General site  preparation includes  the  costs  to
          remove and  replace existing piles and floating
          docks  in  Slip  No.  3,  remove existing  intake  and
          outlet pipes near OMC's Slip No. 3 outfall, furnish
          and install temporary  floating  docks,  construct a
          new large boat hoisting facility,  and install chain
          link fence around the water treatment plant.

     •    Sediment dispersal control includes the costs to
          furnish,  install, and  remove the double silt  cur-
          tain.

     •    Cofferdam includes the costs  for the  fill at  the
          base of the  sheet  piling and the  costs  for  the
          sheet piling.

     •    Slurry wall  includes  the  costs  to install  a
          soil-bentonite slurry wall.

     •    Dredging Upper Harbor includes the costs to dredge
          the sediments  and  pipe them to the containment
          area.

     •    Water treatment plant  and water disposal  includes
          the costs to install and remove both  a 1,500-gpm
          and a  200-gpm water treatment plant and the costs
          for rental of the water treatment plants.

     •    Clay cap and surcharge includes  the costs  to  pro-
          vide and install the filter fabric, drainage  sys-
          tem, clay cap,  and surcharge.
PD452.001                   5-29

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                                 Table 5-6

                          DETAILED COST ESTIMATE
                        SLIP NO.  3 AND UPPER HARBOR
                             ALTERNATIVE 6A
                            CONTAIN-DREDGE-CAP
                         OMC HAZARDOUS WASTE SITE
                            WAUKEGAN,  ILLINOIS
                                 13-5M28.0
Description
Mobilization
Health and safety requirements
General site preparation
Sediment dispersal control
Cofferdam
Slurry wall
Dredging Upper Harbor sediments
Water treatment plant and water
disposal
Clay cap and surcharge
Construct new harbor area
Monitoring (wells)
Surcharge removal and paving
Engineering, legal, and adminis-
tration
Subtotal
Contingency
Total
Capital
Costs
$ 510,000
280,000
310,000
40,000
710,000
550,000
220,000
1,560,000
340,000
1,210,000
30,000
130,000
1,000,000
6,890,000
2,070,000
$ 8,960,000
Present
Worth of
O&M Costs
0
0
0
0
0
0
0
$ 20,000
0
0
200,000
0
40,000
260,000
80,000
$340,000
Present
Worth
$ 510,000
280,000
310,000
40,000
710,000
550,000
220,000
1,580,000
340,000
1,210,000
230,000
130,000
1,040,000
7,150,000
2,150,000
$ 9,300,000
PD998.063.6
5-30

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     •    Construct new harbor includes  the  costs  to  remove
          existing  sheet  piling,  install  new  steel sheet
          piling, excavate  material and haul offsite,  and
          the costs for the land.

     •    Monitoring  (wells) includes the costs for install-
          ing and monitoring the groundwater monitoring wells.

     •    Surcharge removal and paving  includes  the cost  to
          remove and haul off the surcharge  remaining  above
          grade after settlement of the containment area and
          the cost to pave the containment area.

Alternative 6B;  Contain-Dredge Part of Upper Harbor-Cap

A sediment dispersal control device, consisting  of a  double
silt curtain or sheet piling, would be  installed across the
middle of the  Upper  Harbor  (Figure  5-4).   Then a  cofferdam
would be constructed near the east end of Slip No.  3 to close
it off.  A slurry wall extending into the glacial  till would
be constructed  inside  the cofferdam and around  the entire
perimeter of the containment area.

Dredged sediments with  greater than 50  ppm  PCBs  from the
eastern portion of Slip No. 3  and part  of  the Upper Harbor
would be placed within the contained area.   This alternative
would not address approximately 25,500 yd3  of sediments con-
taining 3,100  Ib of PCBs  with  concentrations  between  50 and
150 ppm in the Upper Harbor.  Alternative 6B, however, would
control 99 percent of all the  PCBs  now  found in Slip No. 3
and Upper Harbor sediments.   Supernatant would be  continuously
decanted and routed to  an onsite water  treatment plant for
suspended solids and PCB  removal  (to 1 ppb PCBs),  then dis-
charged to the harbor or to a sanitary sewer.  After comple-
tion of dredging, a layer of filter fabric,  a 1-ft-thick
layer of sand with a drainage  system, and  a  3-ft-thick com-
pacted clay cap would cover the dredged muck.  Five feet  of
fill over the  clay  would  serve  as  a surcharge.   Water col-
lected from the drainage system would be treated as described
above.  Slip No. 3 would be left permanently filled.  Ground-
water monitoring wells  would  be  installed  around  the  site
for detection of potential PCB migration.

After completion of all dredging activities,  the water treat-
ment plant would be  removed and a new basin would be  con-
structed to replace  Slip  No.  3.   After  settlement of the
muck in Slip No. 3 is complete, the excess  surcharge materi-
al would be removed and the  area paved.

Containment/Encapsulation.  A slurry wall would be construc-
ted to completely encircle the containment area.   The proposed
containment area is  shown on Figure 5-4.  The existing glacial
till beneath the site would  be relied upon  to act  as a bottom
PD452.001                   5-31

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seal.  An  impervious  cap consisting of  3  ft  of compacted
clay covered by asphaltic  concrete  paving  would be used to
cover the top of the filled-in containment area.

Temporary Storage Requirements.  No temporary storage would
be required.  This alternative does, however, require long-
term, onsite storage.

Water Treatment.  Harbor water from the containment area and
slurry water from  dredging activities  in the Upper Harbor
would need to be treated before discharge.  Treatment would
be the same as  that described  for Slip No.  3—Alternative -
2B, except that rainwater and leachate water would be treated
using a 200-gpm package water treatment plant for about 1 year
during dewatering and densification.

Operation, Maintenance,  and  Monitoring  Requirements  of the
Completed Remedy.  In Alternative 6B,  PCBs are contained on-
site.  Groundwater  monitoring  wells would  be  required to
determine whether PCBs were  migrating  from the containment
area.  Should contaminant movement  be detected,  an internal
drainage system could be installed to maintain internal water
levels lower than external water levels  so  that any leakage
is into  the  containment  area.   The area would  be capped.
The cap would need to be properly maintained so that it would
continue to be an impermeable barrier to surface water.

Offsite Disposal Needs, Permit Requirements, and Transporta-
tion Plans.  For Alternative 6B, no PCB-contaminated  solids
would require offsite disposal.  USEPA waivers in accordance
with 40 CFR 761 under  TSCA would be required to  leave  the
PCBs onsite.  About 21,100 yd3 of sediments containing about
306,900 Ib  of  PCBs would  be contained  in-place in  the
containment area.

Major Equipment.  Major construction equipment and utilities
required  for  Alternative 6B would  be  the  same  as those
required for Alternative 6A.

Special  Engineering Considerations.   Special  engineering
considerations  for Alternative 6B would be the same as those
required for Alternative 6A.

Reliability.  Alternative 6B would not dispose of PCB-contami-
nated solids offsite but would contain and cap the western
portion of Slip No. 3.  There is no data on long-term reliabil-
ity of this alternative.  Groundwater fluctuations may cause
drying or cracking of the slurry walls or the clay cap.  Freez-
ing and thawing action may also cause deterioration of the slurry
walls and cap.  The underlying glacial till may have cracks,
fissures, or pockets of more permeable material through which
PCBs could migrate.  The containment area would be monitored
to permit ongoing evaluation of the effectiveness and integrity
PD452.001                   5-32

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of the slurry  walls  and clay cap.  The reliability  of  the
containment can be enhanced  with development of additional
design details:

     •    Freeze-thaw problems  could  be reduced by  termi-
          nating the slurry wall below the frostline.

     •    Use  of a  flexible  membrane  for the cap  could  be
          considered for more freedom in site grading.

     •    Should contaminant movement be detected, an inter-
          nal drainage system could be installed to maintain
          internal water levels  lower than  external levels
          so that any leakage would be  into  the  containment
          area.

Consideration  of these types of  details during design would
make this alternative effective  in abating further PCB  con-
tamination of  the Waukegan area and Lake Michigan.  Alterna-
tive 6B is considered reliable.

Costs.  The  Order-of-Magnitude  cost estimate for  Alterna-
tive 6B is presented in  Table  5-7.  This  cost estimate  was
developed as described for Slip No. 3—Alternative 2B.

The mobilization; health and safety  requirements;  engine-
ering, legal,  and administration;  and contingency  costs  in-
cluded in Table 5-7 for  Slip No.  3 and  Upper Harbor—Alter-
native 6B are  the same  as  described  for Slip No.  3—Alter-
native 2B.  A  description of the major elements  included  in
the remaining Table 5-7 line items follows:

     •    General site  preparation includes  the  costs  to
          remove and  replace existing piles and  floating
          docks in Slip  No.  3,  remove existing intake  and
          outlet pipes near  CMC's  Slip  No.  3 outfall, fur-
          nish and install  temporary  floating docks, con-
          struct a new  large boat hoisting  facility, and
          install chain  link fence around the water treat-
          ment plant.

     •    Sediment dispersal control  includes the  costs to
          furnish,  install, and  remove the double  silt  cur-
          tain.

     •    Cofferdam includes the  costs  for the  fill at  the
          base of the  sheet  piling and the  costs  for the
          sheet piling.

     •    Slurry wall  includes  the  costs to install  a
          soil-bentonite slurry wall.
PD452.001                   5-33

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                                 Table 5-7

                          DETAILED COST ESTIMATE
                        SLIP NO.  3 AND UPPER HARBOR
                             ALTERNATIVE 6B
                  CONTAIN-DREDGE  PART OF UPPER HARBOR-CAP
                         OMC HAZARDOUS WASTE SITE
                            WAUKEGAN, ILLINOIS
                                 13-5M28.0
Description
Mobilization
Health and safety requirements
General site preparation
Sediment dispersal control
Cofferdam
Slurry wall
Dredging Upper Harbor sediments
Water treatment plant and water
disposal
Clay cap and surcharge
Construct new harbor area
Monitoring (wells)
Surcharge removal and paving
Engineering, legal, and adminis-
tration
Subtotal
Contingency
Total
Capital
Costs
$ 330,000
180,000
290,000
40,000
160,000
290,000
90,000
1,560,000
130,000
650,000
20,000
50,000
640,000
4,430,000
1,330,000
$ 5,760,000
Present
Worth of
O&M Costs
0
0
0
0
0
0
0
$ 20,000
0
0
200,000
0
40,000
260,000
80,000
$340,000
Present
Worth
$ 330,000
180,000
290,000
40,000
160,000
290,000
90,000
1,580,000
130,000
650,000
220,000
50,000
680,000
4,690,000
1,410,000
$ 6,100,000
PD998.096.1
5-34

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     •    Dredging Upper Harbor includes the costs to dredge
          the sediments  and pipe them  to  the containment
          area.

     •    Water treatment plant and water  disposal  includes
          the costs to  install  and  remove  both a 1,500-gpm
          and a 200-gpm water treatment plant  and the  costs
          for rental of the water treatment plants.

     •    Clay cap and surcharge includes  the  costs  to  pro-
          vide and install  the  filter  fabric,  drainage  sys-
          tem, clay cap, and surcharge.

     •    Construct new harbor  includes the  costs to remove
          existing sheet  piling,  install  new  steel sheet
          piling, excavate  material  and haul  offsite,  and
          the costs for the land.

     •    Monitoring (wells) includes the costs for  install-
          ing and monitoring  the  groundwater monitoring
          wells.

     •    Surcharge removal and paving includes the  costs to
          remove and haul off the surcharge  remaining  above
          grade after settlement of the containment  area and
          to pave the containment area.

Subalternative I;  Select Excavation

This subalternative would be used only in  conjunction with
Alternatives 6A or 6B.   "Hot spots"  would be removed by clam-
shell dredging,  fixed,  and disposed of offsite.  "Hot spots"
consist of 5,700 yd3 of deep contaminated sand and silt near
the former OMC  outfall  and  silt in the western portion of
Slip No. 3 with PCS concentrations in  excess of  10,000  ppm.
Dredging of  the  deep contaminated sand and  silt  would be
performed inside a single sheet pile  cofferdam.   Subalter-
native I would remove and dispose of  offsite 92  percent of
all the PCBs now  found  in Slip No.  3  and the  Upper  Harbor
area (286,500 Ib of PCBs).  The solids  would be transported
to the  batch plant  and  fixed  by  adding portland cement,
Locksorb, or  another fixing agent  to  hydrate the  excess
water.   The mix would then  be  transported  to curing cells.
The fixed solids would be cured until they were nonflowable.
This is  expected  to  take about  1 day.  The fixed  solids
would be removed from the curing cells  by  front end  loaders
for transportation by truck to an approved disposal   site.

Curing Cells.  The curing cells  for  this  alternative would
be the same as required for Slip No.  3—Alternative   2B.  The
assumed shape and location are shown on Figures 5-3   and 5-4.
PD452.001                   5-35

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Offsite Disposal Needs, Permit Requirements, and Transporta-
tion Plans.  These items would be the same as those for Slip
No. 3—Alternative 2B, except about 7,100 yd3 of  fixed  PCB-
contaminated solids would require disposal.   For Alternative 6A
in conjunction with  Subalternative  I,  about 40,900 yd3 of
sediments containing  23,500  Ib  of PCBs would be  contained
in-place in  the  containment area.  For  Alternative 6B in
conjunction with Subalternative I, about 15,400 yd3 of sedi-
ment containing 20,400 Ib of PCBs would be contained in-place
in the containment area.

Major Equipment.  Major construction equipment and utilities
required for Subalternative I include:

     •    Pile driver

     •    Clamshell dredge

     •    Backhoe

     •    Batch plant

     •    Dump trucks

     •    Front end loader

     •    Electrical service for batch plant

     •    Electrical lighting

     •    Water service for contractor's temporary facilities

Special Engineering  Considerations.   For Subalternative I,
the  following  special engineering considerations  are  pre-
sented.

Engineering considerations concerning dredging of Slip No. 3
include:

     •    Type of  cofferdam for dredging of deep contami-
          nated sand  and  silt  near  former OMC outfall, and
          means to prevent  failure  of  existing  sheet  piling
          during cofferdam installation and removal

Engineering considerations concerning fixation include:

     •    Moisture content of solids to be  fixed

     •    Amount of fixing agent required

     •    Volume of fixing agent

     •    Volume of solids to be removed
PD452.001                   5-36

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     •    Possible interferences  of contaminants with  the
          fixing agent

     •    Time required for curing

     •    Cost effectiveness of fixing with portland cement,
          Locksorb, and/or other fixing agent

Engineering considerations concerning  disposal  of the PCB-
contaminated sediments include:

     •    Ensuring that  the  sediments have  a nonflowable
          consistency

     •    Ensuring that  moisture  or solids  do  not escape
          during transport and  disposal  of the  fixed sedi-
          ments

     •    Controlling volatilization

Reliability.  Slip No. 3 and Upper  Harbor—Subalternative  I
would remove and dispose of PCB-contaminated sediments  with
concentrations greater  than 10,000 ppm  from Slip  No.  3.
Subalternative I includes dredging, sediment solidification,
and disposal in  a  licensed chemical waste landfill.  This
Subalternative would  be  effective  in  abating further PCB
contamination of the Waukegan area  and Lake  Michigan.   Sub-
alternative I is considered reliable.

Costs.  The Order-of-Magnitude cost estimate  for  Slip No.  3
and Upper Harbor—Subalternative I is presented in Table 5-8.
This cost estimate was developed as described for Slip No.  3—
Alternative 2B.

The mobilization; health and safety requirements; engineering,
legal, and administration;  and contingency costs included in
Table 5-8 for Slip No. 3 and Upper  Harbor—Subalternative  I
are the same as described for Slip No. 3—Alternative 2B.  A
description of the major elements included in the  remaining
Table 5-8 line items follows:

     •    Localized cofferdam  and dewatering includes  the
          costs to install  and remove a single sheet pile
          cofferdam at the localized area;  partially dewater
          the cofferdam; and  remove and replace the  sheet
          pile bulkhead.

     •    Dredging of deep sand and silt includes  the costs
          to dredge the  contaminated  sand  and silt within
          the cofferdam and the "hot spots" outside the cof-
          ferdam.
PD452.001                   5-37

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                                 Table 5-8

                          DETAILED COST ESTIMATE
                       SLIP NO.  3 AND UPPER HARBOR
                             SUBALTERNATIVE I
                            SELECT EXCAVATION
                         OMC HAZARDOUS WASTE SITE
                            WAUKEGAN, ILLINOIS
                                 13-5M28.0
Description
Mobilization
Health and safety requirements
Localized cofferdam and
dewatering
Dredging of deep sand and silt
Solids removal
Fixation
Transportation and disposal
Engineering, legal, and
administration
Subtotal
Contingency
Total
Capital
Costs
$ 170,000
100,000
390,000
30,000
20,000
940,000
360,000
340,000
2,350,000
710,000
$ 3,060,000
Present
Worth of
O&M Costs
0
0
$ 60,000
0
0
0
0
10,000
70,000
20,000
$ 90,000
Present
Worth
$ 170,000
100,000
450,000
30,000
20,000
940,000
360,000
350,000
2,420,000
730,000
$ 3,150,000
PD998.063.14
5-38

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     •    Solids removal includes the costs to transport the
          solids to the batch plant.

     •    Fixation includes the costs to  install  and  remove
          curing cell  embankment,  liner  material, and con-
          crete divider walls; mix  the  solids with cement;
          haul fixed solids to the  curing cells;  and  remove
          fixed solids from the curing cells.

     •    Transportation and disposal includes the  costs  to
          haul the  contaminated material to an  approved
          chemical waste landfill.

NORTH DITCH/PARKING LOT AREA

Alternative 1:  Excavate-Dispose

A bypass would be constructed  to  divert  surface  water flow
around the highly contaminated areas  of  the Crescent Ditch
and Oval Lagoon  (Figure 5-5).  The  bypass would outfall di-
rectly into Lake Michigan.  Construction would then begin on
a structural  slurry wall  (or  other structural support sys-
tem) around the  Crescent  Ditch and a nonstructural  slurry
wall around the  Oval  Lagoon.   A nonstructural slurry wall
would be constructed  around the  deep contamination in the
Parking Lot area.  The soils would be dewatered  using well
points and pumps.  Well water  would be  routed to an onsite
water treatment plant  for  suspended solids and PCB removal
(to  1 ppb  PCBs) , then discharged  to the lake or  to a
sanitary sewer.

Soils with greater than  50 ppm PCBs would be excavated by
backhoe or front end loader and placed  in lined  trucks for
transport to an approved disposal site.    The excavated areas
would be backfilled.

North Ditch Bypass.   A gravity pipeline bypass would be con-
structed to divert surface water flow around the highly con-
taminated areas, the  Crescent  Ditch and  Oval Lagoon.  The
location of the proposed bypass is  shown on,Figure 5-5.  This
bypass would collect drainage from  the 36-inch-diameter storm
drain (that flows north at the west edge of CMC's property),
from OMC plant roof  drains,  and  from regraded areas  north
and south of the Crescent Ditch.   The bypass would discharge
to Lake Michigan.  It would be constructed south of the sheet
piling just north of the east-west portion of the North Ditch.
The Parking Lot  area would be regraded  to divert surface
water flow to catch basins.

An area approximately 15  ft deep by 25 ft wide of PCB-contami-
nated soil from the North Ditch would be excavated and disposed
of in a licensed chemical waste landfill.  Before excavation,
the existing sheet piling  (along the north side of the North
PD452.001                   5-39

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Ditch) would be fitted with extensions and driven an estimated
5 to 8 ft, penetrating into the confining clay layer.  Addi-
tional sheet piling would be driven on the south side of the
North Ditch.  The area would then be dewatered.  After exca-
vation, the area would be backfilled and the gravity pipeline
installed.

Temporary  Storage  Requirements.   North  Ditch/Parking Lot
Area—Alternative 1 would not require any temporary  storage
of solids before disposal.

Water Treatment.  Groundwater removed from  the areas to be
excavated may need to be treated before  it can be discharged
back  into  the environment.   The  water  treatment  process
would be the  same  used  in Slip No.  3—Alternative 2B.  The
groundwater would  be  pumped directly to a  200-gpm package
water treatment plant for treatment and discharge to  Lake
Michigan or to a sanitary  sewer.  The treatment  plant would
be used for about 7 months.

Operation, Maintenance,  and  Monitoring  Requirements  of the
Completed  Remedy.   In North Ditch/Parking Lot Area—Alter-
native 1,  the proposed  action removes  the  PCBs  from  the
project site  and  disposes of them  in a licensed chemical
waste landfill.  Therefore,  there are no onsite operation,
maintenance,  or monitoring requirements  after completing the
proposed remedy.

Offsite Disposal Needs,  Permit Requirements, and Transporta-
tion Plans.   These items would be the same as for Slip No. 3—
Alternative 2B, except  that  approximately  175,800 yd3 of
PCB-contaminated solids would require disposal.  In addition,
a permit to operate construction equipment under the existing
powerline would be required.

Major Equipment.  Major construction equipment and utilities
required  for  North Ditch/Parking  Lot Area—Alternative 1
include:

     •    Pile driver

     •    Backhoe

     •    Front end loader

     •    Dump trucks

     •    Construction dewatering equipment

     •     Slurry trench excavator

     •     Slurry mixing equipment
PD452.001                   5-40

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     •    Water  treatment  plant   (see  Water  Treatment,
          earlier in this section)

     •    Electrical lighting

     •    Water service for contractor's temporary facilities

Special  Engineering Considerations.   For  North  Ditch/
Parking Lot Area—Alternative 1 the  following  special  engi-
neering considerations are presented.

Engineering considerations concerning construction dewatering
(groundwater) include:

     •    Rate and  duration of well  point  pumping before
          satisfactory moisture content in soils is obtained

Engineering considerations concerning excavation include:

     •    Type of structural walls for excavation

     •    Possible contamination behind sheet piles adjacent
          to the North Ditch

     •    Controlling volatilization

Engineering  considerations  concerning the water  treatment
process include:

     •    Determining the  cost-effectiveness of  replacing
          activated carbon with Klensorb for soluble PCB re-
          moval if the activated carbon should become blinded
          by the oily nature of PCBs

     •    Water quality requirements  for discharging to  the
          lake or to a sanitary sewer

Engineering considerations  concerning disposal of the PCB-
contaminated soils include:

     •    Ensuring that the soils have a nonflowable consis-
          tency

     •    Ensuring that moisture  or  solids  do not escape
          during transport and disposal of the soils

     •    Controlling volatilization

Reliability.  North  Ditch/Parking Lot Area—Alternative  I
would  remove  PCB-contaminated solids  with  concentrations
greater than 50 ppm  from  the  North Ditch/Parking Lot area.
The alternative includes  groundwater dewatering and treat-
ment, and soil excavation and disposal in a licensed chemical
PD452.001                   5-41

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waste landfill.  This  alternative  is effective in  abating
further PCB contamination of the Waukegan area and Lake Michi-
gan.  North Ditch/Parking  Lot Area—Alternative 1  is  con-
sidered reliable.

Costs.  The  Order-of-Magnitude cost  estimates for  North
Ditch/Parking  Lot  Area—Alternative  1  are presented  in
Tables 5-9 and 5-10,  for  the North Ditch area and  Parking
Lot area,  respectively.  These estimates were developed as
described for Slip No. 3—Alternative 2B.

The mobilization; health and safety requirements;  engineering,
legal, and administration; and contingency costs included in
Table 5-9  for  North  Ditch—Alternative 1 are  the  same as
described for Slip No. 3—Alternative 2B.  A  description of
the major elements included  in the  remaining  Table  5-9 line
items follows:

     •    General site  preparation includes  the  costs to
          remove and relocate  the chain link fence and rail-
          road tracks, remove  and  replace  pavement,  reroute
          the 10-inch-diameter  sanitary  sewer, relocate the
          propane tanks, underpin  the elevated water tank,
          and install new manholes for rerouting the sewer.

     •   .Bypass North Ditch includes the costs  to install
          the pipeline around the  Crescent Ditch and  Oval
          Lagoon areas and through  the  east-west  portion of
          the North Ditch.

     •    Dewatering includes  the costs to install and remove
          well points, pipes,  and  pumps for dewatering the
          material;  install  slurry walls;  and dispose of
          contaminated material from the slurry wall excava-
          tion.

     •    Water treatment plant and  water  disposal  includes
          the costs  to  install and remove a  200-gpm water
          treatment plant and the  costs for rental  of the
          water treatment plant.

     •    Excavation and backfilling includes the costs to
          excavate contaminated material and place the
          material in trucks and the costs to backfill exca-
          vated areas with imported materials.

     •    Transportation and  disposal includes the  costs to
          haul the contaminated material to a  licensed chemi-
          cal waste landfill.

The mobilization; health and  safety requirements;  engineering,
legal, and administration; and contingency costs included in
Table 5-10  for  Parking Lot—Alternative 1 are the  same  as
PD452.001                   5-42

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                                 Table 5-9

                          DETAILED COST ESTIMATE
                               NORTH DITCH
                              ALTERNATIVE 1
                             EXCAVATE-DISPOSE
                         OMC HAZARDOUS WASTE SITE
                            WAUKEGAN, ILLINOIS
                                 13-5M28.0
Description
Mobilization
Health and safety requirements
General site preparation
Bypass North Ditch
Dewatering
Water treatment plant and water
disposal
Excavation and backfilling
Transportation and disposal
Engineering, legal, and adminis-
tration
Subtotal
Contingency
Total
Capital
Costs
$ 940,000
520,000
100,000
4,720,000
1,660,000
170,000
510,000
2,290,000
1,860,000
12,770,000
3,830,000
$16,600,000
Present
Worth of
O&M Costs
0
0
0
0
$ 20,000
20,000
0
0
10,000
50,000
20,000
$70,000
Present
Worth
$ 940,000
520,000
100,000
4,720,000
1,680,000
190,000
510,000
2,290,000
1,870,000
12,820,000
3,850,000
$16,670,000
PD998.063.7
5-43

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                                Table 5-10

                          DETAILED COST ESTIMATE
                                PARKING LOT
                               ALTERNATIVE 1
                             EXCAVATE-DISPOSE
                         OMC HAZARDOUS WASTE  SITE
                            WAUKEGAN, ILLINOIS
                                 13-5M28.0
Description
Mobilization
Health and safety requirements
General site preparation
Dewatering
Water treatment plant and water
disposal
Excavation and backfilling
Transportation and disposal
Engineering, legal, and adminis-
tration
Subtotal
Contingency
Total
Capital
Costs
$ 710,000
390,000
330,000
380,000
10,000
1,170,000
5,250,000
1,400,000
9,640,000
2,890,000
$12,530,000
Present
Worth of
O&M Costs
0
0
0
$ 10,000
10,000
0
0
10,000
30,000
10,000
$40,000
Present
Worth
$ 710,000
390,000
330,000
390,000
20,000
1,170,000
5,250,000
1,410,000
9,670,000
2,900,000
$12,570,000
PD998.063.9
5-44

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described for Slip No. 3—Alternative 2B.  A  description  of
the major elements included in the remaining Table 5-10 line
items follows:

     •    General site  preparation includes  the  costs to
          remove and  replace  pavement,  reroute a  12-inch-
          diameter high-pressure  gas  line,  and relocate  a
          light pole.

     •    Dewatering includes the costs to install and remove
          well points, pipes, and pumps required for dewater-
          ing of  the material;  install  slurry  walls;  and
          dispose of the contaminated  material from  the
          slurry wall excavation.

     •    Water treatment and water disposal includes  the
          costs for rental of the water treatment plant.

     •    Excavation and backfilling  includes the costs to
          excavate the contaminated material and place it in
          trucks and  the  costs to  backfill  the excavated
          areas with imported materials.

     •    Transportation and  disposal includes  the costs  to
          haul  the  contaminated  material  to  a licensed
          chemical waste landfill.

Alternative 3;  Excavate-Fix-Dispose

A  bypass  would be  constructed  as  described  for  North
Ditch/Parking Lot  Area—Alternative 1  (Figure  5-5).   The
excavation area would be dewatered within a slurry wall, and
the well  water  would be  treated as described  for North
Ditch/Parking Lot Area—Alternative I.   Soils with greater
than 50 ppm PCBs would be excavated with a backhoe or  front
end loader and  placed in trucks  to be  transported to the
batch plant.  The  soil  would then be  fixed  with portland
cement, Locksorb, or another fixing agent to hydrate the
excess water.  The fixed soil would then be  transported to
the curing cells.   The  fixed solids would be cured until
they were nonflowable.  The  fixed solids would be removed
from the curing cells by front end  loaders for  transport  by
truck to an approved disposal site.

North Ditch Bypass.   The  bypass  would be the same as  that
required for  North  Ditch/Parking Lot Area—Alternative  1.
The location of the proposed bypass is shown on Figure 5-5.

Curing Cells.  The curing cells  for this alternative would
be the same as those required for Slip No. 3—Alternative 2B.
The assumed shape and location are shown on Figure 5-5.
PD452.001                   5-45

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Temporary Storage Requirements.  In North Ditch/Parking  Lot
Area—Alternative 3,  excavated solids that are too wet to be
transported to  a licensed  chemical  waste landfill would
require fixation before disposal.  Fixation  is  expected to
require 1 day of temporary storage for curing.

Water Treatment.  Water treatment requirements would  be  the
same as  those  for North  Ditch/Parking  Lot  Area—Alterna-
tive I.

Operation, Maintenance, and  Monitoring  Requirements of the
Completed Remedy.  These requirements are the same  as those
for North Ditch/Parking Lot Area—Alternative 1.

Offsite Disposal Needs, Permit Requirements, and Transporta-
tion Plans.  These  items  would be the  same as those for
North  Ditch/Parking  Lot Area—Alternative 1,  except  that
approximately 219,800  yd3  of fixed PCB-contaminated  solids
would require disposal.

Major Equipment.  Major construction equipment and utilities
required  for  North Ditch/Parking  Lot Area—Alternative 3
would be  the same as  those required  for North Ditch/Parking
Lot Area—Alternative  1, except that a batch plant and electri-
cal services for the batch plant would also be required.

Special Engineering Considerations.  For North Ditch/Parking
Lot Area—Alternative  3,  special  engineering  considerations
would be  the same as those for North Ditch/Parking Lot Area--
Alternative 1,  with  the  following  additional engineering
considerations concerning  fixation:

     •    Moisture content of solids to be fixed

     •    Amount of fixing agent required

     •    Volume of fixing agent

     •    Volume of solids to be removed

     •    Possible interference  of  contaminants  with the
          fixing agent

     •    Time required for  curing

     •    Cost-effectiveness of fixing with portland  cement,
          Locksorb, and/or other fixing agent

Reliability.  North Ditch/Parking  Lot Area—Alternative 3
would  remove PCB-contaminated  soil  with concentrations
greater than 50  ppm  from  the North Ditch/Parking Lot area.
The alternative  includes  groundwater dewatering and  treat-
ment,  soil excavation,  fixation of excess water in the soil,
PD452.001                   5-46

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and solids disposal  in  a  licensed chemical waste landfill.
This alternative would  be  effective  in abating further PCB
contamination of the Waukegan area and Lake Michigan.  North
Ditch/Parking  Lot   Area—Alternative  3   is   considered
reliable.

Costs.   The  Order-of-Magnitude cost  estimates for  North
Ditch/Parking  Lot  Area—Alternative 3  are  presented  in
Tables 5-11 and  5-12 for  the North Ditch  area  and  Parking
Lot area, respectively.  These cost estimates were developed
as described for Slip No. 3—Alternative 2B.

The major elements included in the Table 5-11 line items  for
North Ditch—Alternative 3  are  the same  as  described  for
North Ditch—Alternative 1, except as noted below:

     •    Fixation includes the costs to mix the solids with
          cement, haul fixed solids to the curing cells,  and
          remove the fixed solids from the curing cells.

The description  of  the  major elements  included in the
Table 5-12 line  items  for  Parking Lot—Alternative 3 would
be the  same  as described  for  Parking Lot—Alternative 1,
except as follows:

     •    Fixation includes the costs to mix the solids with
          cement, haul fixed solids to the curing cells,  and
          remove fixed solids from the curing cells.

Alternative 4;  Contain-Cap  (Parking Lot Area Only)

A slurry  wall  extending down into the underlying glacial
till would be constructed around  the Parking Lot  to  control
movement of contaminated materials (Figure 5-6).  This alter-
native would control about  36  percent  of  all the PCBs now
found in  the North Ditch/Parking  Lot  area.  The site would
be capped with a 3-ft  compacted  clay  layer to  seal  in the
contaminated soils and reduce infiltration of surface water.
The area would be resurfaced for  parking.  This would  raise
the elevation of the site by 3 to 4 ft.  Groundwater monitor-
ing wells would be installed around the site for detection
of potential PCB migration.

Containment/Encapsulation.   A slurry wall would be constructed
to completely encircle the  contaminated  area.   The  proposed
containment area is  shown on Figure 5-6.  The existing glacial
till beneath the site would be relied upon to act as a bottom
seal.   An impervious cap of  3  ft  of  compacted clay covered
by asphaltic concrete would be used to  cover the  top of the
containment area.
PD452.001                   5-47

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                                Table 5-11

                          DETAILED COST ESTIMATE
                                NORTH DITCH
                               ALTERNATIVE 3
                           EXCAVATE-FIX-DISPOSE
                         OMC HAZARDOUS WASTE SITE
                            WAUKEGAN, ILLINOIS
                                 13-5M28.0
Description
Mobilization
Health and safety requirements
General site preparation
Bypass North Ditch
Dewatering
Water treatment plant and water
disposal
Excavation and backfilling
Fixation
Transportation and disposal
Engineering, legal, and adminis-
tration
Subtotal
Contingency
Total
Capital
Costs
$ 1,520,000
840,000
100,000
4,720,000
1,660,000
170,000
560,000
5,180,000
2,860,000
2,990,000
20,600,000
6,180,000
$26,780,000
Present
Worth of
O&M Costs
0
0
0
0
$ 10,000
10,000
0
0
0
10,000
30,000
10,000
$40,000
Present
Worth
$ 1,520,000
840,000
100,000
.4,720,000
1,670,000
180,000
560,000
5,180,000
2,860,000
3,000,000
20,630,000
6,190,000
$26,820,000
PD998.063.8
5-48

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                                Table 5-12

                          DETAILED COST ESTIMATE
                                PARKING LOT
                               ALTERNATIVE 3
                           EXCAVATE-FIX-DISPOSE
                         OMC HAZARDOUS WASTE SITE
                            WAUKEGAN, ILLINOIS
                                 13-5M28.0
Description
Mobilization
Health and safety requirements
General site preparation
Dewatering
Water treatment plant and water
disposal
Excavation and backfilling
Fixation
Transportation and disposal
Engineering, legal, and adminis-
tration
Subtotal
Contingency
Total
Capital
Costs
$ 2,040,000
1,120,000
330,000
380,000
10,000
1,280,000
11,890,000
6,560,000
4,020,000
27,630,000
8,290,000
$35,920,000
Present
Worth of
O&M Costs
0
0
0
$ 10,000
10,000
0
0
0
10,000
30,000
10,000
$40,000
Present
Worth
$ 2,040,000
1,120,000
330,000
390,000
20,000
1,280,000
11,890,000
6,560,000
4,030,000
27,660,000
8,300,000
$35,960,000
PD998.063.10
5-49

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Temporary Storage Requirements.  Parking Lot—Alternative  4
does not require temporary storage.  It does, however, require
long-term, onsite storage.

Operation, Maintenance, and Monitoring  Requirements  of the
Completed Remedy.  In Parking Lot—Alternative 4, PCBs would
be contained onsite.  Groundwater monitoring wells would be
required to determine whether  PCBs  were migrating from the
contaminant area.  Should contaminant movement be deteqted,
an internal drainage system could  be  installed to maintain
internal water  levels  lower  than external water  levels so
that any  leakage  is  into  the  containment  area.   The area
would be capped and returned to its original use as a parking
lot, which would need to be properly maintained  in order to
continue to be an impermeable barrier to surface water.

Offsite Disposal Needs, Permit Requirements, and Transporta-
tion Plans.   For Parking Lot—Alternative  4,  no PCB-con-
taminated  solids  would require  offsite disposal.   USEPA
waivers in accordance  with  40  CFR  761 under TSCA would be
required  to  leave  the  PCBs onsite.   About 105,000  yd3 of
soil containing about 277,700  Ib of PCBs would be contained
in-place on the  site at the eastern end of the Parking Lot
area.

Major Equipment.  Major construction equipment and utilities
required for Parking Lot Area—Alternative 4 include:

     •    Backhoe

     •    Front end loader

     •    Dump trucks

     •    Slurry trench excavator

     •    Slurry mixing equipment

     •    Bulldozer

     •    Compactor

     •    Paving equipment

     •    Electrical lighting

     •    Water service for contractor's temporary facilities

Special Engineering Considerations.  For Parking Lot—Alterna-
tive 4, special engineering considerations concerning contain-
ment and capping of the Parking Lot area include:
PD452.001                   5-50

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     •    Depth and construction  techniques  for the slurry
          wall to ensure its integrity

     •    The effects of PCBs on slurry walls

     •    Selection of  cap  materials and determination  of
          correct placement methods

     •    Design of asphaltic concrete pavement for prolonged
          service as a membrane

Reliability.  Parking Lot—Alternative  4  would not dispose
of PCB-contaminated soil offsite  but would  contain and cap
the Parking Lot area.   There is no data on long-term reliabil-
ity of this alternative.  The shoreline of Lake Michigan is
changing and may encroach upon the containment area.  Ground-
water fluctuations may cause drying and cracking of the slurry
walls or the clay cap.  Freezing and thawing action may also
cause deterioration of the slurry walls and cap.  The underly-
ing glacial till may  have  cracks, fissures, or pockets  of
more permeable material  through which PCBs could  migrate.
The containment  area  must  be monitored to  permit ongoing
evaluation of the effectiveness and  integrity  of  the  slurry
walls and clay cap.  The reliability  of the containment  can
be enhanced with development of additional design details:

     •    Freeze-thaw problems could be reduced by terminating
          the slurry and cap wall below the frostline.

     •    Use of a  flexible  membrane for  the  cap  could  be
          considered for more freedom in site grading.

     •    Should contaminant movement be detected, an internal
          drainage system could be installed to maintain inter-
          nal water levels lower than external levels so that
          any leakage would be into the containment area.

Consideration of these types of details during design would
make this alternative effective in abating further  PCB con-
tamination in the Waukegan area and  Lake  Michigan.  Parking
Lot—Alternative 4 is considered reliable.

Costs.   The Order-of-Magnitude   cost estimate for  Parking
Lot—Alternative 4 is presented  in Table  5-13.  This cost
estimate was developed as described for Slip No. 3—Alterna-
tive 2B.

The mobilization; health and safety requirements;  engineering,
legal,  and administration;  and contingency costs included in
Table 5-13 for Parking  Lot—Alternative 4 are the  same  as
PD452.001                   5-51

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                                Table 5-13

                          DETAILED  COST ESTIMATE
                                PARKING LOT
                               ALTERNATIVE 4
                                CONTAIN-CAP
                         OMC HAZARDOUS WASTE SITE
                            WAUKEGAN, ILLINOIS
                                 13-5M28.0

Description
Mobilization
Health and safety requirements
General site preparation
Slurry wall
Cap and regrade
Resurface parking lot
Monitoring (wells)
Engineering, legal, and adminis-
tration
Subtotal
Contingency
Total

Capital
Costs
$ 160,000
90,000
110,000
750,000
500,000
230,000
30,000
320,000
2,190,000
660,000
$ 2,850,000
Present
Worth of
O&M Costs
0
0
0
0
0
0
$240,000
40,000
280,000
80,000
$360,000

Present
Worth
$ 160,000
90,000
110,000
750,000
500,000
230,000
270,000
360,000
2,470,000
740,000
$ 3,210,000
PD998.063.il
5-52

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described for Slip No.  3—Alternative  2B.  A  description  of
the major elements included in the remaining Table 5-13 line
items follows:

     •    General site  preparation includes  the  costs to
          remove and  replace  pavement, reroute a  12-inch-
          diameter high-pressure  gas  line, and relocate  a
          light pole.

     •    Slurry wall includes the costs to install  a  soil-
          bentonite slurry wall.

     •    Cap and regrade includes the costs  to provide  and
          install the  filter  fabric,  drainage system,  and
          clay cap.

     •    Resurface parking lot  includes  the  costs to pave
          the containment area.

     •    Monitoring  (wells) includes the costs for install-
          ing and monitoring groundwater monitoring wells.

Alternative 4A: Excavate-Contain-Cap  (North Ditch Area Only)

A bypass would be constructed  to  divert  surface  water flow
around the highly contaminated areas  of  the Crescent Ditch
and Oval Lagoon (Figure 5-7).   The bypass would fall directly
into Lake Michigan.   The North Ditch soils would be dewatered
using well points and pumps.   Well water would be  routed  to
an onsite water treatment plant for suspended solids and PCB
removal  (to 1 ppb PCBs), then discharged to the lake or to a
sanitary sewer.

A slurry wall extending down  into the underlying glacial
till would then be constructed around the Crescent Ditch and
Oval Lagoon to control  movement  of contaminated materials.
The excavated  PCB-contaminated soils  from the North Ditch
and about 3  ft  of  PCB-contaminated soil from the  Crescent
Ditch area would be placed  and compacted in the Oval Lagoon
area.  Alternative 4A would control about  64  percent of  all
the PCBs now found in the North Ditch/Parking Lot area.  The
site would be  capped  with a 3-ft  compacted clay  layer to
seal in  the  contaminated  soils and reduce infiltration  of
surface water.  The area  would be resurfaced for  parking.
This would raise the elevation of the Oval Lagoon area by 20
to 25 ft.  Groundwater  monitoring wells  would be installed
around the site for detection of potential PCB migration.

North Ditch Bypass.   A gravity pipeline bypass would be con-
structed to divert surface water flow around the highly con-
taminated areas, the  Crescent  Ditch  and Oval Lagoon.  The
location of the proposed bypass is shown on Figure 5-7.  This
bypass would collect drainage from the 36-inch-diameter storm
PD452.001                   5-53

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drain (that flows north at the west edge of CMC's property),
from CMC plant  roof  drains,  and from regraded areas  north
and south of the Crescent Ditch.  The bypass would discharge
to Lake Michigan.  It would be constructed south of the sheet
piling just north of the east-west portion of the North Ditch.
The Parking Lot area would be  regraded  to divert surface
water flow to catch basins.

An area of PCB-contaminated soil approximately 15 ft deep by
25 ft wide from the North Ditch would be excavated and  dis-
posed of in the Oval Lagoon area.  Before excavation,  the
existing sheet  piling  (along the north side  of  the  North
Ditch) would be  fitted  with  extensions  and driven an esti-
mated 5 to 8 ft, penetrating into the confining  clay  layer.
Additional sheet piling would be driven on the south side of
the North Ditch.  The area would  then  be dewatered.   After
excavation, the  area would be backfilled  and the gravity
pipeline installed.

Containment/Encapsulation.  A slurry wall would be constructed
to completely encircle the contaminated area.  The proposed
containment area is shown on Figure 5-7.  The existing glacial
till beneath the site would be relied upon to act as a bottom
seal.  An impervious cap  of  3  ft  of compacted clay covered
by asphaltic concrete would be used to cover  the  top  of the
containment area.

Temporary Storage Requirements.  North Ditch—Alternative 4A
does not require temporary storage.  It does, however, require
long-term,  onsite storage.

Water Treatment.  Groundwater  removed  from the areas to be
excavated may need to be treated before it can be discharged
back into the environment.  The water treatment process would
be the same used in Slip No. 3—Alternative 2B.  The ground-
water would be  pumped  directly to a 200-gpm  package  water
treatment plant for treatment, and discharged to Lake Michigan
or to a  sanitary  sewer.   The treatment plant would be used
for about 2 months.

Operation,  Maintenance, and  Monitoring  Requirements  of the
Completed  Remedy.   In  North Ditch—Alternative 4A,   PCBs
would be  contained onsite.  Groundwater  monitoring  wells
would be required  to determine whether PCBs were migrating
from the containment area.   Should contaminant movement be
detected, an internal drainage  system could be installed to
maintain internal  water levels lower  than external  water
levels so  that  any leakage is  into  the  containment  area.
The area would be capped.  The cap would need to be properly
maintained in order to continue to be an impermeable barrier
to surface water.
PD452.001                   5-54

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Offsite Disposal Needs, Permit Requirements/ and Transporta-
tion Plans.   For  North Ditch—Alternative 4A, no  PCB-con-
taminated solids would require offsite disposal.   USEPA waivers
in accordance with 40 CFR 761 under TSCA would be required to
leave the PCBs onsite.  About  70,800  yd3  of  soil  containing
about 495,500 Ib of PCBs would be contained  in-place on  the
site.

Major Equipment.  Major construction equipment and utilities
required for North Ditch—Alternative 4A include:

     •    Pile driver

     •    Backhoe

     •    Front end loader

     •    Dump trucks

     •    Construction dewatering equipment

     •    Slurry trench excavator

     •    Slurry mixing equipment

     •    Bulldozer

     •    Compactor

     •    Paving equipment

     •    Electrical lighting

     •    Water service for contractor's temporary facilities

Special Engineering Considerations.   For North Ditch—Alter-
native 4A, the following special engineering considerations
are presented.

Engineering considerations concerning construction dewatering
(groundwater) include:

     •    Rate and  duration  of well  point  pumping before
          satisfactory moisture content in soils is obtained

Engineering considerations concerning excavation include:

     •    Possible contamination behind sheet piles adjacent
          to the North Ditch

Engineering  considerations concerning the water  treatment
process include:
PD452.001                   5-55

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     •    Determining the  cost-effectiveness  of replacing
          activated carbon with Klensorb for soluble PCS re-
          moval if the activated carbon should become blinded
          by the oily nature of PCBs

     •    Water quality requirements for discharging to  the
          lake or to a sanitary sewer

Engineering considerations concerning containment and capping
of the North Ditch area include:

     •    Depth and construction techniques for the slurry
          wall to ensure its integrity

     •    The effects of PCBs on slurry walls

     •    Selection of  cap materials and determination  of
          correct placement methods

     •    Design of asphaltic concrete pavement for prolonged
          service as a membrane

Reliability.  North Ditch—Alternative 4A would not  dispose
of PCB-contaminated soil offsite but would  contain and cap
the Crescent Ditch and  Oval  Lagoon  area.  There is no data
on long-term reliability of this alternative.   The shoreline
of Lake Michigan is changing and may encroach upon  the  con-
tainment area.   Groundwater  fluctuations may  cause  drying
and cracking of the slurry walls or  the  clay cap.   Freezing
and thawing action may also cause deterioration of the slurry
walls and cap.  The underlying glacial till may have cracks,
fissures, or pockets of more permeable material through which
PCBs could migrate.  The containment area must  be  monitored
to permit ongoing evaluation of the  effectiveness  and  inte-
grity of the slurry walls  and clay cap.  The reliability of
the containment  can  be  enhanced with development  of  addi-
tional design details:

     •    Freeze-thaw problems  could be  reduced  by  ter-
          minating  the  slurry  and  cap  wall  below the
          frostline.

     •    Use of a  flexible  membrane for the  cap  could  be
          considered for more freedom in site  grading.

     •    Should contaminant movement be detected, an inter-
          nal drainage system could be installed to maintain
          internal water levels  lower  than  external levels
          so that any leakage would  be  into the containment
          area.

Consideration of these  types of details  during  design  would
make  this  alternative  effective  in abating  further PCB
PD452.001                   5-56

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contamination of the Waukegan area and Lake Michigan.  North
Ditch—Alternative 4A is considered reliable.

Costs.  The Order-of-Magnitude cost estimate for North Ditch—
Alternative 4A is presented in Table 5-14.  This cost estimate
was developed as described for Slip No. 3—Alternative 2B.

The mobilization; health and safety requirements; engineering,
legal, and administration; and contingency costs included in
Table 5-14 for North  Ditch—Alternative  4A are the same as
described for Slip No.  3—Alternative  2B.  A description of
the major elements included in the remaining Table 5-14  line
items follows:

     •    General site  preparation includes the  costs  to
          remove and relocate the chain link fence and rail-
          road tracks,  remove and  replace  pavement,  reroute
          the 10-inch-diameter sanitary sewer,  relocate  pro-
          pane tanks, underpin the elevated water  tank,  and
          install new manholes for rerouting the sewer.

     •    Bypass includes the costs to install the pipeline
          around the  Crescent  Ditch  and Oval  Lagoon  areas
          and through  the east-west portion of the North
          Ditch.
                                                         •
     •    Slurry wall  includes  the  costs  to  install  a
          soil-bentonite slurry wall.

     •    Cap and grade includes the  costs to  provide  and
          install the  filter  fabric,  drainage  system,  and
          clay cap; to  excavate  material from  the Crescent
          Ditch area; and to place excavated material in the
          Oval Lagoon area.

     •    Resurface includes the costs to  pave  the  contain-
          ment area.

     •    Monitoring  (wells)  includes the costs for install-
          ing and monitoring the groundwater monitoring wells.

Alternative 4B;  Excavate-Contain Part of E-W Portion  of  the
North Ditch-Cap (North Ditch Area Only)

A bypass would be constructed to divert  surface water flow
around the highly contaminated areas  of  the Crescent Ditch
and Oval Lagoon (Figure 5-7).   The bypass would fall direct-
ly into Lake Michigan.  The North Ditch soils would be dewa-
tered using well  points and pumps.  Well water would be  routed
to an onsite water treatment plant for suspended solids  and
PCB removal (to 1 ppb PCBs), then discharged to the  lake or
to a sanitary sewer.
PD452.001                   5-57

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                                Table 5-14

                          DETAILED COST ESTIMATE
                                NORTH DITCH
                              ALTERNATIVE 4A
                           EXCAVATE-CONTAIN-CAP
                         OMC HAZARDOUS WASTE SITE
                            WAUKEGAN, ILLINOIS
                                 13-5M28.0
Description
Mobilization
Health and safety requirements
General site preparation
Bypass
Slurry Wall
Cap and Grade
Resurface
Monitoring (wells)
Engineering, legal, and
administration
Subtotal
Contingency
Total
Capital
Costs
$ 480,000
260,000
110,000
3,510,000
610,000
410,000
100,000
20,000
930,000
$ 6,430,000
1,930,000
$ 8,360,000
Present
Worth of
O&M Costs
0
0
0
0
0
0
0
$240,000
40,000
280,000
80,000
$360,000
Present
Worth
$ 480,000
260,000
110,000
3,510,000
610,000
410,000
100,000
260,000
970,000
6,710,000
2,010,000
$ 8,720,000
PD998.063.12
5-58

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A slurry wall extending down into the underlying glacial till
would then be constructed around the Crescent Ditch and Oval
Lagoon to  control  movement  of contaminated materials.  The
excavated  PCB-contaminated  soils  from the North Ditch  and
about 3 ft of PCB-contaminated  soil  from  the  Crescent Ditch
area would be placed and compacted in the  Oval  Lagoon area.
This alternative would not  address approximately  19,500 yd3
of soil containing 3,400 Ib of PCBs with concentrations between
50 and 5,000 ppm in the east-west portion of the North Ditch.
Alternative 4B, however, would  control  about  64 percent of'
all the PCBs now found in the North  Ditch/Parking  Lot area.
The site would be capped with a 3-ft compacted clay layer to
seal in the  contaminated soils and  reduce infiltration of
surface water.  The  area would be resurfaced for  parking.
This would raise the elevation of the Oval Lagoon  area by
about 10 ft.  Groundwater monitoring wells would be installed
around the site for detection of potential PCB migration.

North Ditch Bypass.  A gravity pipeline bypass would be con-
structed to divert surface water flow around the highly con-
taminated  areas, the  Crescent  Ditch  and Oval Lagoon.   The
location of  the proposed bypass is  shown  on  Figure 5-7.
This bypass would collect drainage from the 36-inch-diameter
storm drain  (that  flows  north  at  the  west edge of  OMC' s
property), from OMC  plant roof drains, and  from regraded
areas north  and  south of the Crescent  Ditch.   The bypass
would discharge to Lake  Michigan.   It would be constructed
south of the sheet piling  just  north of the east-west por-
tion of the North Ditch.  The Parking Lot  area  would  be re-
graded to divert surface water flow to catch basins.

An area of PCB-contaminated soil approximately 10 ft deep by
7 ft wide would be excavated from the North Ditch and disposed
of in the  Oval Lagoon  area.  The area would be dewatered.
After excavation,  the area would be backfilled and the gravity
pipeline installed.

Containment/Encapsulation.  A slurry wall would be constructed
to completely encircle the contaminated area.   The proposed con-
tainment area is shown on Figure 5-7.  The existing glacial till
beneath the site would be relied upon to act as a bottom seal.
An impervious cap of 3 ft of compacted clay covered by asphaltic
concrete would be used to cover the top of the containment area
and the east-west portion of the North Ditch (bypass area).

Temporary Storage Requirements.  North Ditch—Alternative 4B
does not require temporary storage.  It does,  however, require
long-term, onsite storage.

Water Treatment.  Groundwater removed  from the  areas to be
excavated may need to be treated before it can be discharged
back into the environment.  The water treatment process would
be the same used in Slip No. 3—Alternative 2B.   The groundwater
PD452.001                   5-59

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would be pumped directly to a 200-gpm package water treatment
plant for treatment, and discharged to Lake Michigan or to a
sanitary sewer.  The treatment plant would be used for about
2 months.

Operation/ Maintenance, and  Monitoring  Requirements of the
Completed  Remedy.   In  North Ditch—'Alternative 4B,  PCBs
would be  contained onsite.  Groundwater  monitoring wells
would be required  to  determine  whether  PCBs were migrating
from the containment  area.   Should  contaminant movement be
detected, an internal drainage  system could be  installed to
maintain internal  water levels lower than  external water
levels  so  that any leakage  is  into  the containment area.
The area would be capped.   The cap would need to be properly
maintained in order to continue to be an impermeable barrier
to surface water.

Offsite Disposal Needs, Permit Requirements, and Transporta-
tion Plans.  For North Ditch—Alternative  4B,  no  PCB-con-
taminated  solids would require  offsite disposal.   USEPA
waivers in accordance with 40  CFR 761  under TSCA  would be
required to leave the PCBs onsite.  About 51,400 yd3 of soil
containing about 492,100  Ib of  PCBs would  be contained
in-place on the  site.

Major Equipment.  Major construction equipment and utilities
required for North Ditch—Alternative 4B include:

     •    Pile driver

     •   ' Backhoe

     •    Front  end loader

     •    Dump trucks

     •    Construction dewatering equipment

     •    Slurry trench excavator

     •    Slurry mixing equipment

     •    Bulldozer

     •    Compactor

     •    Paving equipment

     •    Electrical  lighting

     •    Water  service for  contractor's temporary  facilities
PD452.001                   5-60

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Special  Engineering Considerations.   For  North  Ditch—
Alternative 4B, the following special engineering considera-
tions are presented.

Engineering considerations concerning construction dewa-
tering  (groundwater) include:

     •    Rate and  duration  of well  point  pumping before
          satisfactory moisture content in soils is obtained

Engineering considerations concerning excavation include:

     •    Possible contamination behind sheet piles adjacent
          to the North Ditch

Engineering considerations  concerning the water  treatment
process include:

     •    Determining  the  cost-effectiveness of  replacing
          activated carbon with Klensorb for soluble PCB re-
          moval if the activated carbon should become blinded
          by the oily nature of PCBs

     •    Water quality requirements  for discharging  to  the
          lake or to a sanitary sewer

Engineering considerations concerning containment and cap-
ping of the North Ditch area include:

     •    Depth and construction  techniques  for the slurry
          wall to ensure its integrity

     •    The effects of PCBs on slurry walls

     •    Selection of  cap  materials and determination  of
          correct placement methods

     •    Design of  asphaltic  concrete pavement  for  pro-
          longed service as a membrane

Reliability.  North Ditch—Alternative 4B would not dispose
of PCB-contaminated soil offsite  but would  contain and cap
the Crescent Ditch and  Oval  Lagoon  area.  There is no data
on long-term reliability of this alternative.  The shoreline
of Lake Michigan is changing and may  encroach upon the con-
tainment area.  Groundwater  fluctuations  may cause drying
and cracking of the slurry walls or  the clay cap.  Freezing
and thawing action may also cause deterioration of the slurry
walls and cap.  The underlying glacial till  may have cracks,
fissures, or pockets of more permeable material through which
PCBs could migrate.  The containment  area must  be  monitored
to permit ongoing evaluation of the  effectiveness  and  inte-
grity of the slurry walls and clay cap.  The reliability  of
PD452.001                   5-61

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the containment can be  enhanced with development of  addi-
tional design details:

     •    Freeze-thaw problems could be reduced by terminat-
          ing the slurry and cap wall below the frostline.

     •    Use of a  flexible  membrane for the cap could  be
          considered for more freedom in site grading.

     •    Should contaminant movement be detected, an inter-
          nal drainage system could be installed to maintain
          internal water levels  lower  than external levels
          so that any leakage would  be  into  the  containment
          area.

Consideration of these types of  details  during design would
make this alternative effective  in abating further  PCB con-
tamination of  the  Waukegan area and Lake Michigan.   North
Ditch—Alternative 4B is considered reliable.

Costs.  The Order-of-Magnitude cost estimate for North Ditch—
Alternative 4B is presented in Table 5-15.  This cost estimate
was developed as described for Slip No. 3—Alternative 2B.

The mobilization;  health  and safety requirements;  engine-
ering, legal, and  administration;  and  contingency costs  in-
cluded in Table 5-15 for North Ditch—Alternative 4B are the
same as  described  for Slip  No.  3—Alternative 2B.   A de-
scription of the major  elements included in the  remaining
Table 5-15 line items follows:

     •    General  site  preparation includes the  costs  to
          remove and relocate the chain link fence and rail-
          road tracks, remove and  replace  pavement,  reroute
          the 10-inch-diameter sanitary sewer, relocate pro-
          pane tanks, underpin the elevated  water tank,  and
          install new manholes for rerouting the sewer.

     •    Bypass includes  the costs  to  install the  pipeline
          around the  Crescent  Ditch  and Oval Lagoon  areas
          and through  the  east-west portion of  the North
          Ditch.

     •    Slurry wall includes  the  costs  to  install a
          soil-bentonite slurry  wall.

     •    Cap and  grade  includes the costs  to provide and
          install  the  filter fabric, drainage system, and
          clay cap; to  excavate  material from the Crescent
          Ditch area; and  to place excavated material in the
          Oval Lagoon area.
PD452.001                   5-62

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                                Table 5-15

                          DETAILED COST ESTIMATE
                                NORTH DITCH
                              ALTERNATIVE 4B
                           EXCAVATE-CONTAIN-CAP
                         OMC HAZARDOUS WASTE SITE
                            WAUKEGAN, ILLINOIS
                                 13-5M28.0
Description
Mobilization
Health and safety requirements
General site preparation
Bypass
S'lurry Wall
Cap and Grade
Resurface
Monitoring (wells)
Engineering, legal, and
administration
Subtotal
Contingency
Total
Capital
Costs
$ 220,000
120,000
110,000
1,050,000
610,000
300,000
100,000
20,000
430,000
$ 2,960,000
890,000
$ 3,850,000
Present
Worth of
O&M Costs
0
0
0
0
0
0
0
$240,000
40,000
280,000
80,000
$360,000
Present
Worth
$ 220,000
120,000
110,000
1,050,000
610,000
300,000
100,000
260,000
470,000
3,240,000
970,000
$ 4,210,000
PD998.098.1
5-63

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     •    Resurface includes the costs to pave the contain-
          ment area.

     •    Monitoring (wells) includes the costs for install-
          ing  and  monitoring  the  groundwater monitoring
          wells.

Subalternative I;   Select Excavation

This subalternative would be  used  only  in conjunction with
Alternatives 4A or  4B.   "Hot  spots" would be removed  from
the Crescent Ditch/Oval Lagoon area and disposed of offsite.
"Hot spots" consist of 5,500 yd3 of soils with PCB concentra-
tions in excess of 10,000 ppm.  Subalternative I would remove
and dispose of offsite 57 percent  of all  the  PCBs  now  found
in the North  Ditch/Parking  Lot area (440,500 Ib of  PCBs).
These soils would be excavated and then loaded into trucks
for transportation to an approved disposal site.

Offsite Disposal Needs, Permit Requirements, and Transporta-
tion Plans.  These items would be the same as for Slip No. 3—
Alternative 2B, except that about 5,500 yd3 of PCB-contaminated
solids would require disposal.  For Alternative 4A in conjunc-
tion  with Subalternative I,  about  65,300  yd3 of soil
containing 55,000 Ib of PCBs would  be contained in-place  in
the containment area.  For  Alternative  4B,  about  45,900 yd3
of sediment containing 51,600  Ib of PCBs  would  be  contained
in-place in the containment area.   A permit  to  operate con-
struction equipment under the  existing  power line would be
required.

Special Engineering Considerations.  The following special
engineering considerations  are presented.

Engineering considerations  concerning disposal  of the PCB-
contaminated soils include:

     •    Ensuring that the soils have a nonflowable consis-
          tency

     •    Ensuring  that  moisture  or solids  do  not escape
          during transport  and disposal of the soils

     •    Controlling volatilization

Reliability.  North Ditch—Subalternative I would remove and
dispose of PCB-contaminated soils with concentrations greater
than  10,000 ppm  from  the Crescent/Ditch  Oval Lagoon  area.
Subalternative I includes excavation and  then disposal in  a
licensed chemical waste landfill.   This subalternative would
be effective  in  abating further PCB contamination of the
Waukegan area  and  Lake Michigan.   Subalternative I is con-
sidered reliable.
PD452.001                   5-64

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Costs.  The Order-of-Magnitude cost estimate for North Ditch—
Subalternative I is presented in Table 5-16.  This cost esti-
mate was developed as described for Slip No. 3—Alternative 2B,

The mobilization; health and safety requirements; engineering,
legal, and administration; and contingency costs included in
Table 5-16 for North Ditch—Subalternative I are the same as
described for Slip  No.  3—Alternative 2B.   The description
of the major elements  included  in the remaining Table 5-16
line items follows:

     •    Excavation includes the costs to excavate the "hot
          spots" in Crescent Ditch and Oval Lagoon.

     •    Transportation and disposal  includes  the  costs  to
          haul the contaminated material to an approved haz-
          ardous waste landfill.
PD452.001                   5-65

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                                Table  5-16

                          DETAILED  COST ESTIMATE
                               NORTH DITCH
                             SUBALTERNATIVE I
                            SELECT  EXCAVATION
                         OMC HAZARDOUS WASTE SITE
                            WAUKEGAN,  ILLINOIS
                                 13-5M28.0
Description
Mobilization
Health and safety requirements
Excavation
Transportation and disposal
Engineering, legal, and
administration
Subtotal
Contingency
Total
Present
Capital Worth of
Costs O&M Costs
$ 40,000
20,000
150,000
280,000
80,000
570,000
170,000
$ 740,000
0
0
0
0
0
0
0
0
Present
Worth
$ 40,000
20,000
150,000
280,000
80,000
570,000
170,000
$ 740,000
PD998.063.13
5-66

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were recorded during  the  summer and maximum concentrations
occurred in the winter.   BOD and COD measurements are made
to determine the potential effect  of  oxygen-demanding mate-
rial on the aquatic environment.  Although BOD5 often varies
seasonally, this trend is not reflected  in the  limited data
available  for  the  Waukegan area.   The  results  of samples
taken at  five  stations along  the western shore  of Lake
Michigan during the months of April through  October  in 1978
and 1979 did not indicate a  seasonal  trend in COD.   Monthly
BOD5 and COD values  recorded over  a  1-year  period did not
indicate a seasonal pattern  at  three  inshore stations near
Waukegan.

Recreational and industrial activities are major  sources  of
oil and grease in surface waters.  Levels of these substances
often are higher in harbor areas due to commercial or recrea-
tional navigation and the relatively restricted flow patterns.
Sampling for oil  and  grease was done  at several stations
near the US Steel plant south of Waukegan.   The levels mea-
sured generally were  less than 1.0 mg/1 in  March and July
for the inshore stations.   Offshore, the level at one station
reached a  high of  9.0 mg/1.   Two offshore stations located
between Waukegan and  the  US  Steel plant had concentrations
of 9.0 mg/1 and 2.5 mg/1,  respectively.

The extensive recreational and commercial boating activities
in Waukegan Harbor are likely to result in periodic increases
in turbidity and  other related pollutants wherever  depths
average less than about 10 feet.  Other pollutant sources to
Lake Michigan include permitted discharges for local industry
and for the Waukegan  sewage treatment plant.   Heavy industrial
use of the lands surrounding Waukegan Harbor more than likely
results in seasonal high surface runoff-borne loads of heavy
metals and dust.  The cumulative result  of the surrounding
industrial setting, recreational boating activity, commercial
shipping, and lack of flow-through water movement is a highly
turbid harbor.   The fact  that periodic maintenance dredging
has been  conducted in the  harbor  indicates considerable
sediment deposition from numerous sources.

TERRESTRIAL BIOTA

The Waukegan Harbor area lies within the Lake Michigan Dunes
Section of the Northeastern  Morainal  Division  of Illinois.
This is the most recently glaciated area of  the state, and
many rare  species of  plants  are present in  Illinois  Beach
State Park, approximately 1.5 miles north of Waukegan harbor.
The natural communities present  in the harbor  area include
those characteristic  of and  limited to  the  shore  of Lake
Michigan (beach and foredune communities)  and those  charac-
teristic of disturbed areas  (successional communities  and
developed land).
PD525.022                    6-5

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Vegetation

The area to the east of the project site is a public beach,
the major part of which is unvegetated, lake-deposited sand.
The predominant plants  in the beach area  are  sea rocket,
winged pigweed, and cocklebur.  Sand-binding plants such  as
marram grass,  common bugseed,  and Canada wild rye help to
stabilize the  dunes and provide substrates on which various
insects and spiders live.   The more protected foredune areas
behind the strand  contain species of plants such as beach
wormwood, little bluestem grass,  silverweed, bearberry, and
trailing juniper.  Cottonwoods, dogwoods, willows, and other
shrubs and trees are present at the western edge of the beach.
Successional  communities  have developed in  the disturbed
area between  the cottonwood-willow  band  and  Seashore  Road.
Large chunks  of concrete  and  rocks  have  been piled at this
location.  Rushes,  blue vervain,  wild bergamot,  and other
weedy species  are  present in  most spots around and to  the
west of these  slabs.

Honey  locust  trees  have  become  established   (possibly
planted) in  the  area immediately north  of the concession
stand at the  north end of the  beach  parking lot.  Rushes
also are present in wet spots in  this area.   Squirrel-tail
grass and other weeds  are common  in disturbed sites around
the picnic shelter and the parking lot.

Silver maples, oaks, and conifers have been planted adjacent
to the North  Beach Park parking lot.   The  southwestern  part
of the beach has a grass cover and contains weeping willows,
cottonwoods,  and Scotch pines.  Beach Park,  located at the
west edge of the inlet, also has a grass understory and con-
tains cottonwoods and crabapples.

The areas on  the western edge of the  project  site in the
vicinity of  the  railroad track contain  weedy communities
typical of disturbed ground.  There are thickets of willows,
cottonwoods, and wild grape in the moister sites west of the
tracks.  Prairie  cord grass,  butterfly  weed,  black-eyed
susans, and other species typical of prairie communities are
present in this area.

A marsh  community  is  located  to the  north of the project
site, adjacent to the cooling ponds on the property owned by
Commonwealth  Edison.   Some of the species  of wildlife that
are present in the Waukegan Harbor  area  undoubtedly feed  or
rest in this area also.

The center of the  OMC  vacant  property contains spoil piles
covered  with  shrubby  and weedy  successional  vegetation
similar  to  that  described previously.  Various species of
coniferous and deciduous  trees have  been  planted on  the
property for  landscaping purposes.
PD525.022                    6-6

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Animals

Spiders, tiger  beetles,  antlions, grasshoppers,  termites,
digger wasps, and various  species of beetles and flies are
the typical residents of the beach and  foredune  areas.   Few
species of vertebrate animals other than gulls and shorebirds
utilize these areas.

Amphibians and Reptiles

Amphibians and reptiles are not likely  to be  present  in  the
two parks, but may be present in  the  disturbed areas  in  the
vicinity of the site.  Fowler's toad  may be  associated with
the beach community, but no individuals of this species have
been observed in Illinois Beach State Park, and it is unlikely
that they are present in the harbor area.  The American toad
and the eastern hognose  snake  probably are present in the
moist areas to the west and north of North Beach.

Mammals

Because mammals are more mobile than amphibians and reptiles,
a few species may  be present in  the  project  area at  some
time during  the year.   However,  the  relative scarcity of
vegetation and the amount of human activity  in the vicinity
would tend to cause them to avoid the area except during the
early morning and evening.   It  is likely that prairie deer
mice, eastern cottontails, and other small mammals are pres-
ent in the Waukegan Harbor area, primarily along the northern
end of North Beach.  Skunks, raccoons,  and other predators
may visit  the  area periodically.  Muskrats  currently use
lodges in the marsh on the Commonwealth Edison property,  but
these animals are  not likely to enter the beach areas in the
vicinity of the harbor.

Birds

The shore  of  Lake  Michigan serves as  a natural  migration
route and resting  area for birds.  Many species pass through
the Waukegan Harbor area during spring  and autumn migration
periods and stop to rest on  the  beach at North Beach Park,
on the breakwaters,  or  in  the  calm water area between the
breakwaters.  Other species, such as the black tern,  come to
the harbor  for  the  summer  after breeding in  inland areas.
Some species such as gulls  also over-winter  in the harbor
area.   At least 152  species  of  birds have  been observed  in
the vicinity of Waukegan Harbor.  Twenty-seven of these  are
fish-eating species, 10 of which  reside in the harbor area
during the summer  or the winter.
PD525.022                    6-7

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A breeding colony of common  terns,  which  are classified as
endangered in Illinois, is present on the Commonwealth Edison
property immediately north of the harbor area.  Approximately
40 adult black terns and 2 juveniles (a species also classi-
fied as endangered in Illinois)  were observed during a field
visit by WAPORA personnel on July 19, 1981.  The adult terns
were roosting on the north breakwater at the entrance to the
harbor and presumably were  feeding  on  fish from the harbor
area.

The gulls in the harbor area generally use North Beach  as  a
day roost.  They roost on the beach overnight and during the
early morning, and  then  move out to the lake  after  people
begin to arrive at the beach.

Because of the number  of  migrating  species and the ease of
observation of the  birds  from  the pier that extends  for a
considerable distance  into  Lake Michigan,  the harbor is a
favorite observation area for local birdwatchers, especially
during the spring and autumn migration periods.  Many species
of shorebirds have been observed  along the shoreline  to the
north of the harbor, up to Illinois Beach State Park.  North
Beach may be too disturbed to attract most of these species.

Of the three habitat types  (marshes, shores, and open water)
accessible to birds  in the  Waukegan Harbor  area,  the open
water habitat of the harbor  and Lake Michigan  is by  far the
most extensive.  The species that utilize this habitat type,
such as ducks, mergansers, and gulls, have the largest popu-
lations .

Threatened or Endangered Species—Federal Classification

The bald eagle, classified as endangered by the U.S. Depart-
ment of  the  Interior,  has  been observed in the Waukegan
Harbor area during  migration periods.   No  other species of
terrestrial biota currently  listed  as  endangered or  threat-
ened is known to be  present in  the  area at any time during
the year.

Threatened or Endangered Species—State Classification

Fifteen species of birds and at least five species of plants
classified as endangered in  Illinois are known or  likely to
be present in  the  project area.  Two species  of birds  and
one species of plant classified as threatened in  Illinois
also have been observed in the Waukegan Harbor area.

Although the range  of  the spotted turtle may  include some
parts of Illinois Beach State Park, and yellow-headed black-
birds have been  observed in the marsh to  the  east of the
Commonwealth Edison  cooling  ponds,  neither species has  been
observed  in  the  Waukegan Harbor  area.   Both  species are
classified as endangered  in Illinois.   Nineteen species of
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birds have been  included on the Blue List of  the  National
Audubon Society  for  1981.  This  is  an early  warning  list  of
species that are determined  to  be  declining,  threatened,  or
vulnerable on  the  basis of nominations  from knowledgeable
observers in all regions of the United States.

AQUATIC BIOTA

Many  researchers have studied the  chemical  and  biological
components of  the aquatic habitats  of harbors  located along
the shores of  Lake  Michigan.  Most have reported  that the
harbors often  were  severely degraded.   Harbors  and other
partially enclosed  areas are very  susceptible to  environ-
mental degradation  because  of  inputs  from adjacent popula-
tion  centers  and industrial  processes.   This  effect is
further compounded by the limited  water  exchange (dilution)
with the open  lake.

Fish

Data from 1971 studies  by Industrial  Bio-test  Laboratories,
Inc., indicate that, in general, alewife, lake trout,  rainbow
smelt, bloater,  coho salmon, brown trout, lake  whitefish,
and yellow perch were the most  abundant  species within the
Waukegan-Zion  area.   (Detailed  temporal  and  spatial varia-
tions for each of these  species  are discussed  in the  WAPORA
document (048)  .)

Benthic Macroinvertebrates

Benthic macroinvertebrates  are  defined  as  those  visible
organisms that inhabit and are  a part of the bottom  zone  of
a water body.  Benthic  macroinvertebrates are  considered  to
be important secondary producers or consumers when assessing
potential impacts because the  organisms  are  relatively im-
mobile; thus, the community composition,  abundance, and dis-
tribution of these  organisms are  a reflection of  aquatic
conditions in the recent past.  These characteristics  of the
benthic community are determined by the oxygen  content of
the waters,  sediment composition,  the degree  and  type of
pollutants (organic,  inorganic),  scouring by wave  action,
and other factors.

In the food  web, benthic macroinvertebrates are secondary
consumers of detritus, plankton, and other invertebrates,  as
well as a significant source of food for fish.   It is  through
this food source that PCBs generally are considered  to move
into fish.

The composition  of  the  macroinvertebrate  community  near
Waukegan,  as determined  in a 1974  study  by Limnetics,  Inc.,
was dominated  by aquatic worms, freshwater  shrimp,  flies,
and midges.   Snails,  clams,  sow bugs,  and water mites also
were present, but in lesser numbers.  Most of  the  organisms
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present are considered by researchers to be either  faculta-
tive (found in moderately polluted waters and having a wide
range of tolerance of  organic  pollution)  or tolerant (cap-
able of thriving under grossly polluted conditions).

Limnetics,  Inc., also calculated diversity and equitability.
Diversity is a measure of the  species richness and  the dis-
tribution among  species;  the  greater  the diversity, the
better the condition of the  aquatic population.   Equitabil-
ity is a measure of  the component  of  diversity  affected by
the distribution of  individuals  among  species.   Equal num-
bers of all species present results in an equitability value
of 1.0; values greater than 0.8 are indicative of unpolluted
conditions.  Limnetics, Inc.,  reported that for  the  shallow
locations sampled, diversity ranged from 0.000  (only one
species found) to  2.3875  and that  equitability  ranged from
0.000 to 0.9284.   It  should  be noted  that the use of these
indices is  hindered  by naturally  low diversity  in Lake
Michigan and  is  further hindered  in  this case by  severe
stress from wave action in shallow, unstable areas.

Phytoplankton

Phytoplankton occupy a unique  position  in the ecosystem of
Lake Michigan.  They represent the transition stage from the
physical and chemical aspects  to the higher-order biological
communities.  Thus the phytoplankton community can act as an
early warning indicator of changes in the chemical nature of
the aquatic ecosystem.

Several intensive studies designed to detect seasonal changes
in species composition and abundance were conducted in south-
ern Lake Michigan  in  the  1960s and 1970s.  Industrial Bio-
test Laboratories, Inc.,  sampled phytoplankton communities
at several  locations  near Waukegan and Zion in  1972,   The
following results were obtained:

     •    Diatoms were the most predominant group,  consti-
          tuting 60 percent of the biovolume.

     •    Blue-green  algae  constituted 26 percent  of the
          biovolume.

     •    Green algae had the  highest species diversity  and
          constituted 31 percent of the species present.

The inshore location nearest to Waukegan produced the highest
densities of green algae  and of  all phytoplankton;  this  was
the result  of extremely high concentrations of the diatoms
Tabellaria  floccosa and Fragilaria crotonensis.
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Zooplankton

Zooplankton represent  an important  link  in the  nutrient
cycling  and  energy flow  through an aquatic  environment.
Zooplankton graze on phytoplankton and serve as a  source of
food for many invertebrates and fish.  The following summary
is based on data  from  1971  and 1974 studies by  Industrial
Bio-test Laboratories,  Inc.,  and Limnetics,  Inc., respect-
ively.

A single seasonal maximum was  noted; populations  were  rela-
tively low from January  through  May, peaked in August, and
then declined.  Copepods  comprised  more  than 80 percent of
the total zooplankton during the winter and spring.  Rotifers
accounted for 50 percent of the total during the early summer,
Cladocera were the predominant (50 percent) organisms during
August.  The numerically predominant species included Bosmina
longirostris,  Cyclops bicuspidatus  thomasi,  Daphnia retro-
curva, Diaptomus ashlandi, and Diaptomus minutus.

Threatened and Endangered Species

No species of fish classified as endangered or threatened by
the U.S. Department of the Interior are known to inhabit the
Waukegan area.  No species  classified  as  endangered by the
State of Illinois have been collected in the Waukegan  area.
Three species of  fish classified as threatened in Illinois
(cisco, longnose sucker, and lake whitefish) were  collected
in limited numbers in the area in 1971.  Of  these,  only the
lake whitefish was reported,  in  1978 and  1979 studies, to
have occurred in  the  Waukegan-Zion area in  recent years.
These studies reported  that only limited  numbers  of lake
whitefish were present.

LAND USE

The existing land use in the City of Waukegan in the vicinity
of the project area is  largely industrial, with a  number of
commercial, open  space  and  recreational,  and other  public
land uses.  All of the land uses east of the Eastern, Joliet,
and Elgin Railroad line are water-related or water-dependent
activities that must  be located  close  to  Lake Michigan.
These activities include industrial uses that require water-
borne transportation; commercial  uses  that serve  boating,
fishing, or other recreational  activities;  and  municipal
uses, such as  the public beach,  the wastewater  treatment
plant, and the  water  filtration plant, that  derive their
functionality from the lake.

Nearly the entire  harbor is surrounded with industrial or
heavy commercial  uses,  including OMC,  Goldbond  Building
Products, Huron Cements,  and the Waukegan Port  District.
The only remaining open space around the harbor is  owned by
OMC.  Other land uses within the project area include Larsen
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Marine Services, Falcon Marine,  the  City of Waukegan Water
Filtration Plant, the North  Shore  Sanitary District (NSSD)
Wastewater Treatment Plant, and public beach and beach house
facilities along the full extent of  the  publicly owned  Lake
Michigan shoreline.

There are ten public boat  launching  ramps  at the south end
of the harbor.   A  boat hoist also is  available at Larsen
Marine adjacent  to  Slip No.  3.   Because  Waukegan Harbor is
the only protected  public  harbor on the northern  Illinois
shoreline (public access to Great Lakes  Harbor  to  the  south
is restricted to boat owners  renting moorage space from the
U.S. Navy) and  a large  number of boat launching ramps  are
available, Waukegan Harbor supports  a  large amount of rec-
reational boating activity and attracts boaters from through-
out Lake County, Illinois,  and from Kenosha County, Wisconsin.

In 1980, the City of Waukegan developed three major land use
objectives to be considered  in  the establishment of a land
use plan:

     •    To  improve  public  health  and welfare  through
          reductions in air,  noise,  and water pollution

     •    To conserve the natural resources of the area

     •    To protect existing scenic areas and to create new
          scenic areas

The City's plans to encourage recreational  and open  space
land use  along  the  Lake Michigan lakefront,  including  the
Waukegan Harbor area, are consistent with these objectives.

POPULATION

The City of Waukegan is the  most populated municipality in
Lake County.  The  official 1980 Census  figure  is 67,653.
From 1970 to  1980,  population growth in Waukegan  (3.2 per-
cent) was markedly  slower  than in Lake  County  as a whole
(15.1 percent).   Population  projections for the City  of
Waukegan  for  the year 2000 range  from 87,269 to  111,301.
Currently, all of the residential development in Waukegan  is
located outside  of  the harbor area.  This  development  trend
is expected to  continue because  no  land  in the harbor area
is zoned residential, and little land in the area is suitable
for residential development.

FJttPLOYMENT

The Waukegan Harbor area is  the  major industrial center in
the City  of Waukegan  and  is  an important  component  of  the
industrial district located along the shore  of Lake Michigan
between  North Chicago and Waukegan.  Currently,  the  15
publicly and privately owned  establishments located in the
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harbor area  employ 12 percent of  the  persons employed in
Waukegan.  The  total  number of jobs in the harbor  area  is
approximately 3,500.

Unemployment in  the City of Waukegan was high during 1980.
The unemployment rate of 9.8 percent was  higher than the
Lake  County  rate  of  6.9 percent,  the  Illinois rate  of
8.3 percent, and the  national rate  of  7.1 percent.  This
rate may reflect the  concentration of Waukegan employment in
manufacturing industries  that have experienced slow growth
during recent years.

ECONOMIC ACTIVITY

A cursory survey of the employers in the harbor area indicates
that much of the economic activity either is water-dependent
or water-related.  The  Outboard  Marine Corporation, Larsen
Marine, Falcon Marine, Waukegan Port District, Waukegan Yacht
Club,  and Waukegan Water Filtration Plant depend upon the
harbor and Lake Michigan  for  their operations.  Huron Cements
and Goldbond Building Products also depend upon a  working
harbor for their operations.

Industrial activity in  the  Waukegan Harbor area  is  expected
to remain stable with little  expansion.   The  value  of land
in the harbor area for  recreation and open space uses will
increase.  Planned industrial growth will be directed to the
west of the  harbor area.   Employment is expected to remain
concentrated in manufacturing industries.  Increases  in the
retail,  transportation  and  utilities,  and miscellaneous
services sectors also are expected.

TRANSPORTATION FACILITIES

Port Facilities

The Waukegan Harbor is  a  14-acre  interior basin  with  a 200-
ft-wide,  19-ft-deep channel.  The harbor facilities are main-
tained and operated by  the Waukegan Port District  and are
used  for both  recreational and  industrial  purposes.   The
harbor is open  from April 15  to  November  15.   The  harbor
facilities provide the  Waukegan  area with access to  world
markets.   The majority  of the harbor traffic,  however, con-
sists of pleasure  boats.  There  are more  than 200  20-ft  to
40-ft pleasure boats  moored in the  harbor.  An expansion of
the harbor is underway and will add 750 public mooring slips.

Highway Facilities

The road network near Waukegan is comprised of publicly and
privately owned  roads.    Interstate  Highway 94 is  located
approximately 6 miles west of Waukegan Harbor, and the near-
est interchange is at Grand Avenue  (Route 132) .  The City of
Waukegan has established a truck route  system with eight
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designated  truck  routes.   The  truck routes  are  heavily
traveled, but substantial additional capacity is available.

Railroad Facilities

The Chicago and North Western Transportation  Company  (C&NW)
and the  Elgin, Joliet,  and  Eastern Railroad Company  (EJ&E)
operate  freight lines in  the  western portion of the harbor
area.  In general,  operations on both sets  of  tracks are
light and therefore do not interfere with automobile 'traffic
patterns.

RECREATION AND TOURISM

Many types  of  recreation  facilities and opportunities  are
available at Waukegan Harbor.   The Illinois  Department  of
Conservation, Division of Fisheries  and Wildlife,  has esti-
mated that Waukegan Harbor and offshore areas experience the
heaviest fishing  pressure of any  area along the  Illinois
coastline of Lake Michigan.   In  addition to  fishing,  a  sub-
stantial number of people use the  Waukegan Harbor  for sail-
ing, picnicking, or sightseeing.  The beach to the north and
east of  the harbor is used for swimming,  sunbathing, volley-
ball, and public  events.   Recreational  facilities in the
harbor area in addition  to  the boat mooring and public
launching areas   include  the Waukegan  Yacht Club,  the
Warren G. Sivert Park, and the south breakwater.

The City sponsors five  festivals  each year  at  the public
beach.   In  1981, between  70,000 and 80,000 people were expec-
ted to attend  these  festivals.   Because  there are only 250
public parking spaces available  at the beach, the City has
an  informal arrangement with OMC  to use the vacant  area
across from the beach for parking  for the festivals.  Appro-
ximately 2,500 cars can be accommodated in this area.

SEWER AND UTILITY LINES

Storm and Sanitary Sewers

The North Shore  Sanitary  District  (NSSD) and the City of
Waukegan provide  storm  and sanitary sewers  in  the project
area.  The  system in  the  vicinity of the North Ditch con-
sists of a  54-inch-diameter gravity sanitary sewer,  a  48-
inch-diameter gravity combined sewer, and a 54-inch-diameter
force main.   These sewers are located parallel to each other
in  an east-west direction just  north of  the south property
line of  the NSSD  Waukegan treatment plant,  which parallels
the North Ditch.  A sanitary  sewer traverses  the  vacant lot
owned by OMC in the vicinity of  the proposed lagoon con-
struction site.   Another  sewer runs north  from the water
filtration  facilities near  the  harbor mouth  along the beach
to  the NSSD treatment plant.   This sewer was installed in
1978 to  carry  filter-backwash  solids  away  for treatment and
disposal.

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Water Lines

No water mains exist in the immediate vicinity  of  the  North
Ditch.  There is a 24-inch water main in the right-of-way of
Seahorse Drive.  Individual service  lines  extend from this
main.

Natural Gas Lines

The North Shore Gas Company provides natural gas to the proj-
ect  area.   The  system consists of  a 12-inch-diameter gas
main  located along  the  private road that extends  from the
northwest corner  of the OMC  property east and south to
Seahorse Drive.  The  main  continues along the  north-south
section of  Seahorse Drive  to  the  Waukegan  Water Filtration
Plant.  Two vault regulators are  located south  of  the  east-
west section of Seahorse Drive on the vacant OMC property.

Electrical Lines

Commonwealth Edison provides electrical service to the proj-
ect  area.   Underground  and overhead  facilities  are located
in the vicinity of  the  North Ditch.   Underground facilities
are  located in the harbor itself and on the vacant parcel of
land owned by OMC.

Telephone Lines

The  Illinois Bell Telephone Company  provides  telephone ser-
vice to the project area.  Most of the telephone  cables  are
located in  street rights-of-way.   Service  cables extend to
individual properties.

CULTURAL RESOURCES

No landmarks on the National Register of Historic Places are
located in the harbor area, and no historical or archaeologi-
cal  sites are known to exist there.

According to the Waukegan  Historical Society, five  sites of
local significance are  located in the harbor  area:  a mem-
orial shelter at Leisure Park, a memorial boardwalk, a band-
shell that was constructed through the efforts of the Wauke-
gan  Exchange Club,  a historical  marker  that  commemorates
five explorers who were present in the Waukegan area  during
the  1670s and a  beach pavilion presented to  the people  of
Waukegan in July 1940.  The bricks used in the  front pillars
of the pavilion came from the old Waukegan lighthouse, which
was razed in 1938.
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                PART 2:  IMPACTS OF NO ACTION

SLIP NO. 3

The No Action alternative will  leave  PCB concentrations in
excess of  10,000  ppm  in the localized area  of Slip No. 3
near the former OMC outfall and concentrations  in  excess  of
500 ppm in the rest of Slip No.  3 sediments.   This represents
an estimated 305,200 Ib of  PCBs  (008,  016).   PCBs in these
concentrations are regulated by 40 CFR 761 under  TSCA.  Ap-
proximately 98.4 percent of all the PCBs now found in Slip
No. 3 and the Upper Harbor are located in Slip No. 3.

Without cleanup,  Slip  No. 3 will  continue to contribute to
the estimated 22 Ib of PCBs released into Lake Michigan each
year from  Waukegan  Harbor  water  (based  on a steady state
model)   (035).  The Waukegan area  will  continue to represent
the most significant contributor  to Lake Michigan PCB con-
tamination, since it holds the largest known uncontained PCB
mass in the lake basin.  The potential for volatilization of
PCBs will continue, contributing to the estimated 12 to 40 Ib
of PCBs that  are  released from the harbor into the local
airshed each year (007, 030).

UPPER HARBOR

The No Action alternative will leave PCB concentrations between
50 and 500 ppm in the Upper Harbor sediments.  This represents
an estimated  5,000  Ib  of PCBs  (008,  016).   PCBs  in these
concentrations are regulated by 40 CFR 761 under TSCA.  Approxi-
mately 1.6 percent of  all the PCBs now found in Slip No.  3
and the Upper Harbor are located in the Upper Harbor.

Measured concentrations  of  total  PCBs in the  water  column
range from 0.6 ppb in the Upper Harbor to less than 0.01 ppb
in the Lake region directly offshore from the harbor  (035).

Without cleanup,  the  Upper Harbor  PCBs  will  continue  to
contribute to the estimated 22 Ib of PCBs released into Lake
Michigan each year  from Waukegan  Harbor  water.  The poten-
tial for volatilization of PCBs would continue, contributing
to the estimated  12 to  40 Ib of PCBs  that are  released  from
the harbor to the local airshed each year  (007, 030).

NORTH DITCH

The No Action alternative will leave an estimated 495,500 Ib
of PCBs in the  North  Ditch area  soils.   Concentrations in
excess of  10,000 ppm are in a localized area of the Crescent
Ditch and  Oval  Lagoon, and concentrations between 50 and
10,000 ppm are  in the  rest  of the North  Ditch soils  (001,
057).  PCBs in these concentrations are  regulated by  40 CFR
761 under  TSCA.
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Average water column  PCB  concentrations  in the North Ditch
were reported to be about 7 ppb with peak values during rain-
fall events of 80 to 160 ppb  (035).

Without action,  offsite  drainage entering the North  Ditch
will continue to become contaminated,  discharging  PCBs  into
Lake Michigan.   Groundwater  resources  will continue  to  be
contaminated.  It is  estimated  that 7  to 20 Ib of PCBs are
discharged annually into Lake Michigan from the  North Ditch
(032, 035).

Volatilization estimates for newly exposed contaminated sands
with levels of 1,000 ppm PCBs are 5,375 ug/m2/hr.  The vola-
tilization rate will decrease with time as the PCBs near the
surface are  volatilized  (007).   Existing air contamination
from North Ditch waters is estimated at 15 Ib/yr (004).

PARKING LOT

The No Action alternative would leave an estimated 277,700 Ib
of PCBs in the soils under the Parking Lot in concentrations
from 50 to over 5,000 ppm (001).  PCBs in these concentrations
are regulated by 40 CFR 761 under TSCA.

The groundwater is within 3 ft of the surface of the Parking
Lot area, resulting in  contamination of  this  water.   It is
estimated that the slowly moving water will begin  releasing
some 8 Ib per  day  of PCBs into  Lake Michigan in approxi-
mately 60 years  (048) .   This will  result  in  further con-
tamination of local water and soil,  which  will continue  for
decades thereafter.

Although volatilization of contaminated  soil  in  the  Parking
Lot area does not appear  to  be  occurring now  because it is
paved,  the  potential exists  if the soil is  disturbed.
Grading,  trenching, drilling, digging, or other activities
necessary  for  utility  installation,  drainage,  or other
construction projects could cause volatilization of PCBs.

IMPACTS ON FISH

The USEPA Ambient Water Quality  Criteria for  protection of
freshwater aquatic life from PCB chronic toxicity is 0.014 ppb
(088).   The lowest reported toxic concentration for freshwater
aquatic life for PCB acute toxicity is  2.0 ppb (085).  Total
reported PCB concentrations in surface  water at the OMC site
range from about 7 ppb or more in the North Ditch and 0.6 ppb
in Waukegan  Harbor to  less  than 0.01 ppb in Lake  Michigan
directly offshore from Waukegan Harbor.  About 60 percent of
the total harbor PCBs in the water column is in the dissolved
form.   The water column PCB concentrations vary over a range
of about 1.5 to 2.0 orders of magnitude  (035).
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Fish accumulate  PCBs  in their tissues by  uptake  from the
water in which they live and by ingestion  of  aquatic  organ-
isms, insects, and plants that have taken up PCBs from their
environment.  It has been demonstrated that fish  bioaccumu-
late PCBs to  factors  of 100,000 or more times  the  ambient
water concentrations of PCBs.  Available data  indicate  that
PCBs are not excreted or degraded but are stored in skin and
adipose  (fatty)  tissue.  In  USEPA  studies  on  Lake Michigan
fish,  results  ranged  from  concentrations  of  2.7 ppm to
187 ppm PCB in  fatty  tissue  for all species.    PCB  concen-
trations in excess  of  5 ppm  were present  in  all  trout  and
salmon more than 12 inches long.   Positive correlations  be-
tween size  of  the  fish, percent fat, and  age  and  the con-
centration of PCBs  dissolved in  the  water  column have also
been found.   Therefore,  larger fish with  a higher  percent
fat content, such as salmon and trout, accumulate  high  con-
centrations of  PCBs.   Bottom feeders, such as carp,  also
accumulate very  high  PCB concentrations  from  contact with
PCB-contaminated bottom sediments  (002, 021).

Bioaccumulation has been shown to  occur at positions  higher
in the  food chain.   Carnivorous predators, such  as  large-
mouth bass,  have markedly higher  PCB  concentrations  than
species lower on the food chain (002, 021).

Research has also shown that PCBs  interfere with  growth and
reproduction of  several species of fish.   PCBs in the water
column have been shown to inhibit phytoplankton  photosyn-
thesis, which  will  limit the growth of  fish  that require
phytoplankton as a  food source.   High PCB  concentration in
bottom sediments may interfere with  the development of  eggs
that are deposited  on  the bottom during spawning.   Fish fry
mortality has a direct correlation to PCB  levels in the water
column,  thereby artificially  reducing fish  populations.
PCBs may ultimately act to  diminish  natural populations of
fish species  (002,  021, 049).

IMPACTS ON ANIMALS

The No Action  alternative  would result in a  continued  in-
crease  in  the concentrations  of  PCBs  in  the  fish-eating
birds,  waterfowl,  shorebirds,  and  other species   of
terrestrial animals that  live  and feed in the  vicinity of
Waukegan Harbor  and in nearby  parts  of Lake Michigan.  The
PCB masses would remain in the area  for many  years, and the
PCB  loading  to  the lake would increase during the period
required  for  the  complete  dispersal  of   PCBs  from  the
contaminated areas  into the lake.   The  concentrations  of
PCBs would increase in the individual animals that routinely
or periodically  ingest  highly  contaminated food items.   The
individuals that reside in the area  during  a  significant
part of  the year,  such as  gulls,  terns,  and  diving ducks,
would be  most affected.  Migratory  species that  rest and
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feed in the area for a short period of time during the spring
and the autumn would be less likely to accumulate large bur-
dens of PCBs, although the body burden of an individual bird
would increase after each annual visit.  Because these birds
also might ingest PCB-contaminated food items in other parts
of their ranges, the total body burden of an individual bird
of a  relatively long-lived species could  be  sustained or
increased to a level that would affect its reproductive poten-
tial, the viability of its young, or its own health  (048).

PCBs are known to accumulate in fatty tissues, and migratory
birds develop additional fat deposits in their bodies  as  an
energy reserve  prior to migration.   When fatty  deposits
containing PCBs are metabolized, the PCBs  are released into
the bloodstream and  can  have  various toxic effects  on the
individual organisms  or  their  offspring.   Rapid releases
into  the  bloodstream could result  from  acute,  short-term
stresses such as  flight  from  a predator or severe weather
conditions or from continuous,  longer-term stresses  such  as
those associated with migration and reproduction, when large
amounts of energy are required  (048).

The  long-term  effects of  a relatively  stable  chemical
stressor such as  PCBs, especially  in a situation where the
dispersal of the  contaminant is more  than  offset by  a con-
tinual fresh input, is not yet known.  Species vary in their
tolerance to chronic "contamination stress," and  many  would
be more susceptible to toxic effects  from  manmade compounds
when  stress  from  these sources is  combined  with stresses
from other natural or  manmade  sources  such as migration or
synergistic effects  from simultaneous  accumulation of DDT.
The major long-term  effects of contaminant-induced changes
in behavior or reproduction would become evident at the popu-
lation or community level.   Little knowledge currently exists
on the ability  of species,  populations,  or communities to
resist and recover  from  such  stresses.  Because  PCBs  are
manmade compounds, few organisms have evolved that have the
capacity to break them down into harmless  constituents such
as carbon dioxide and water-soluble compounds (048) .

Skin disorders  such  as facial  edemas,  hair loss,  and  acne
have been observed  in monkeys  given  oral  doses of  PCBs.
PCBs applied directly to  the skin of rabbits produced hyper-
keratosis, erethyma, blisters, and desquamation.   PCB  expo-
sure in primates  resulted in prolonged menstrual  cycles and
increased bleeding,  indicating  endocrine  effects  (087) .
Other symptoms reported in various species include:  gastric
hyperplasia,  thymic atrophy, decreases  in red blood cells
and lymphocytes,  splenic atrophy,  an  increase  in the serum
level of triglycerides, chloresterol and phospholipids (087),
swelling of livers and jaundice, enzyme system disturbances,
growth inhibition, decrease in immunosuppression, and de-
creased in reproduction (086,  087).
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IMPACTS ON PUBLIC HEALTH AND SAFETY

The magnitude of  PCB  effects  on human health  are  not yet
known.  However, a severe accident involving PCB contamina-
tion of rice oil occurred in Kyushu, Japan, in  1968,  impli-
cating PCBs  as  a health hazard.  The  Japanese  called the
accident Yusho  (oil disease).   The oil contained PCB concen-
trations between  2,000  and  3,000 ppm, now known to be in
combination with chlorinated dibenzofurans and quaterphenyls
(049, 065).   Health  effects were documented in more than
2,000 persons.  Consumption of the contaminated oil resulted
in  skin  lesions, blindness, hearing  loss,  jaundice,  and
abdominal pain.   Uterine  ulcers, stillbirths,   and  miscar-
riages also  occurred.   Infants  born to mothers exposed  to
the contaminated rice oil exhibited  skin,  gum,  and finger-
nail discoloration,  indicating  that at least  some  of the
contaminants  had  crossed  the placental membranes.   Other
symptoms of  toxicity  noted  in humans  include:   swelling of
joints, waxy secretion from eyelid glands, general lethargy,
joint pain, weakness and vomiting, abnormal menstrual cycles,
and weight loss  (085, 086, 087,  002, 021,  049).

Occupational  exposure to  PCB mixtures has caused chloracne
and liver injuries  in workers  exposed to low  levels.   PCB
effects on  worker health from  occupational  exposure have
also been documented  (049, 002,  021).

Documented occurrences of high  levels of  PCB contamination
in humans have  almost all resulted from consumption of con-
taminated foods,  accidentally  or through  accumulation in
fatty tissues  through the food  chain.  Inhalation  of and
skin  contact with PCBs are  not considered a  significant
source of contamination for the general public, but they are
of  concern  in  occupational exposure.   The OSHA standard
(29 CFR 1910) for an  8-hour work shift exposure to PCBs in
air is  1.0  mg/1 for PCBs with  54 percent chlorine  (Aroc-
lor 1254)  and 0.5  mg/1  for PCBs with 42  percent chlorine
(Aroclor 1242).  Samples taken by the Environmental Research
Group, Inc.  (ERG) on  September  3,  1980,  for USEPA detected
Aroclor 1242  and Aroclor 1248 in Waukegan Harbor sediments.
Aroclor 1254 was below detection limits (079).

USEPA Ambient Water Quality Criteria  for carcinogenicity
protection of human health from ingestion of water and orga-
nisms is 0.00079 ppb at the 10~5 risk level.  Concentrations
that have a  risk level of 10 5 are estimated to result in an
increase of  one cancer death per 100,000  people who experi-
ence  exposure over a lifetime.  Total PCB concentrations
vary  from 0.6 ppb  in  Waukegan  Harbor to less than  0.01 ppb
in Lake Michigan directly offshore from Waukegan Harbor  (035)
There is an  emergency water supply  intake  for  Waukegan near
the mouth of  the harbor.
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SOCIOECONOMIC IMPACTS

The Lake County  Health  Department,  in conjunction with the
State of Illinois, has posted warnings of high PCB concentra-
tions in fish taken from Waukegan Harbor.  Commercial fishing
is restricted.   Economic  losses  to  Waukegan area may occur
because of the lowered recreational fishing demand and restric-
tions on  commercial fishing,  and  associated expenditures
such as  lowered  charter boat  demand,  lower pleasure boat
usage, and lower overall  recreational  and/or tourist poten-
tial for the  area.   The PCB problem also might  impact  the
desirability of  the lake, harbor, and project area as a place
to do business (002) .

Harbor maintenance  dredging of  PCB-contaminated soils  is
expensive because of the  disposal and  handling  requirements
for  dredged  sediments  with concentrations  greater  than
50 ppm.   Huron Portland  Cement and  National Gypsum are now
and will continue to be directly impacted, since they depend
on the harbor to receive raw material shipments.

A summary of the socioeconomic effects from PCB  contamination
of surface-water bodies, sediments, and soils in the Waukegan
community might  include:

     •    Loss of fish for human consumption

     •    Reduction or loss of commercial fishing

     •    Decline in property values

     •    Depressed area growth

     •    Reduction in recreational activity, such as boat-
          ing and sport fishing

     •    Reduction in commercial harbor access  due  to  lack
          of harbor dredging
     •    Expenditures for laboratory analysis of area water,
          soil,  and biota samples
     •    Occupational exposure
     •    Expenditures for medical services
     •    Expenditures for legal services

              PART 3;  IMPACTS OF ALTERNATIVES

SLIP NO.  3

Alternative 2B;  Dredge-Dewater in Lagoon-Fix-Dispose

Response Objectives

This alternative would remove  all sediments  from Slip No. 3
with PCB concentrations greater than 50 ppm.  If a 95 percent
PD525.022                   6-21

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removal efficiency were achieved,  it  would remove an esti-
mated 290,000 Ib of PCBs contained in approximately 10,900 yd3
of sediments.  This would  remove  about  93.5 percent of all
the PCBs now found in the  Slip  No.  3  and Upper Harbor area
(003) .

Mathematical modeling conducted by HydroQual, Inc.  (035),
indicates that dredging of  the  harbor sediments  to a level
of 50 ppm PCB would reduce peak water column  concentrations
by approximately one order of magnitude  (to less than 0.1 ppb)
and fish body burdens to less than 5 ppm.  Since this alter-
native would remove  approximately 93.5 percent of  all  the
PCBs now found in Slip No.  3  and  the  Upper Harbor, results
are expected to  be  similar to reductions predicted by  the
model.  Removal would also significantly diminish the exist-
ing estimated volatilization  rate of  12  to  40  Ib/yr of  PCBs
released from the harbor into the local  airshed by approxi-
mately an order of magnitude  (007).

All former land and water uses would be able to resume after
cleanup activities are completed.  No restrictions to future
uses would be expected.

Duration of Cleanup Activities

Dredging and related activities for Slip No. 3 would require
about 2 months.  An  additional  2 months would be  required
for dredging and related  activities in the localized  area
requiring dredging of deep  contaminated sand  and silt.  If
the water treatment plant were not protected against freezing
weather, the dewatering lagoon  would  not  be able  to release
slurry water to the plant during freezing conditions.   Dredg-
ing would then have to occur during nonfreezing weather.

Solids removal to the batch plant would begin about 2 months
after dredging activities are completed.  Removal and fixation
of the dewatered sediments would require 2 to 3 months.  Off-
site transportation to the disposal site would be concurrent
with the fixation process.  Total project  duration is  esti-
mated to be 10 months.

Impacts and Mitigation of Cleanup Activities

Dredging.  Roiling of bottom sediments during dredging results
in sediment suspension and dispersion.  The use of a hydraulic
dredge and the proper dredge head would minimize roiling and
sediment dispersion.  A  sediment dispersal control  system
(double silt curtain  or  steel sheet piling) would  also  be
employed to minimize migration  of suspended PCBs  out  of  the
dredging area.   To assist in controlling sediment dispersion,
water would be continually pumped from inside the slip during
construction to maintain net inflow at the slip mouth.  This
would tend to keep sediments from crossing the control barrier.
The water  could  be treated by  addition of polymer and/or
activated carbon before the sediment barrier is removed.

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A program would be established to monitor  the  effectiveness
of the  containment  measures and to  warn  of the need  for
polymer addition or shutdown of dredging.   A seiche  warning
arrangement with the National Weather  Service  would  also  be
put in  place  so  operations  could  be suspended if  a  seiche
were imminent.  The containment devices would be most likely
to fail during a seiche due to the forces created by a sudden
difference in water level between the two sides of the sheet
piling or double silt curtain.

A clamshell dredge may be required  in  the  localized  area  of
Slip No. 3 to remove the  deep contaminated sediments  (sand
and silt) below the muck at the former OMC outfall.  Spillage
of 15 to 30 percent of the  sediments in a clamshell bucket
occurs while it is being raised.   This spillage would create
a high degree of sediment suspension that would increase the
concentration of PCBs in  solution.   A sheet pile cofferdam
would be employed to support the excavation sides and contain
these dredging activities.   The  water would be treated by
the addition of powdered activated carbon to remove dissolved
PCBs before the cofferdam sediment barrier was removed.  The
water level inside the cofferdam would be  lowered  to create
net inflow as an additional control measure.

The City of Waukegan maintains an emergency water  intake  in
Waukegan Harbor.  This water  intake, while  an  integral part
of the  Waukegan  Harbor system, is  rarely used.   Project
activities would be expected to be completed while the intake
was not in use.  If, however, the  intake  was  needed during
project activities, a monitoring program,  including sampling
of raw  and finished water,  would  be established during the
project to ensure the safety  of  the supply.  A contingency
plan would also be established to stop project operations if
any contamination entered the system.

Larsen Marine Services v/ould  be  adversely affected  by any
dredging that  inhibited  or cut off access to its docks.
These impacts would be short-term and  could be minimized  by
scheduling dredging during periods that would cause the least
impact on Larsen Marine Services.

Minimal volatilization would  be  expected  to  occur during
dredging activities.  Losses would be expected to be roughly
0.3 to  0.4 Ib/day/acre from the exposed, agitated, and con-
taminated water  area  (030) .  Concentrations of  less than
2 ug/m3 would be  expected to be present  in the air as a
result  of dredging  activities (007) .  By  comparison,  the
OSHA standard for maximum worker exposure to Aroclor 1242 is
1,000 ug/m3  in the air at any time.   However,  the National
Institute of Occupational Safety  and Health (NIOSH)  recom-
mends that workers not be exposed  to more than 1  ug/m3 in
the air  during  an 8-hour period  (007) .    (See Health  and
Safety Requirements, later in this section.)
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The proposed dredging would affect terrestrial biota.  Popula-
tions of gulls and terns that  currently  reside  and feed in
the vicinity of the  harbor  would be disturbed by increased
noise and activity levels and may move to another area along
the shoreline of Lake  Michigan during the times of the day
when disturbances would  occur.  However, because  none of
these species breeds in the immediate vicinity of the harbor,
no long-term displacement of populations is anticipated (048) .

Some species of birds or other animals could come into contact
with the contaminated  sediments  and water in  the harbor and
dewataring  lagoon,  particularly during  non-working hours
(gulls)  and autumn migration periods  (waterfowl and shore-
birds)   (048).

Changes in  the harbor  water column PCB  concentrations  and
reduced PCB accumulations in fish would be the two principal
long-term beneficial impacts of dredging.

Possible short-term adverse impacts of dredging would include
the following:

     •    The area  inside  the  sediment  dispersal  control
          device used to detain roiled sediments would become
          turbid during dredging and would very likely become
          anoxic in  the  pre-dawn hours following a  day of
          dredging in organic  "muck" sediments.  Indications
          are that "disturbances"  of  polluted bottom sedi-
          ments,  especially if they have great quantities of
          reduced compounds  dissolved in the  intersticial
          waters, can  elevate  the  expression of sediment
          oxygen demand by as much as one order of magnitude.
          Diurnal rhythms of  respiration/photosynthesis in
          freshwater algae  are such that the lowest oxygen
          levels occur in  pre-dawn  hours.   Consequently,
          almost all respiring organisms inside  the silt
          curtains would be driven out  or  may  die during
          early morning hours  after dredging  (048)  .

     •    If dredging  occurs  during the  fall and spring,
          there is a good chance that spawning fish may be
          present in the harbor  during the  dredging activi-
          ties.  Chinook making fall runs may  be  able to
          swim around  or leap  over the silt  curtains into  a
          highly PCB-laden body of water  (048).

Dewatering.  Construction of a dewatering lagoon and treat-
ment facilities on OMC property or another nearby site would
remove  this  land  from other uses  for  the duration of the
project.

The lagoon would be  constructed with impermeable clay liners
and a leachate collection  system.   The groundwater beneath
PD525.022                   6-24

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the lagoon would be monitored by test wells to detect leakage
from the lagoon.

Some volatilization of  PCBs  would  occur during dewatering.
Volatilization would be minimized  during initial placement
of the dredged sediments by the decanting water layer.  This
would reduce  the estimated volatilization  rate  from 2 Ib
PCBs per day  (for  exposed  sediments  with a typical concen-
tration of 1,000 ppm) to less than 1.0  Ib  PCBs per  day  from
the less contaminated  (100 ppb) decanting  water  layer (007,
030). Other  measures  that  could  be  employed  include:
(1) placing the  less contaminated  sediments on top of  the
more contaminated  sediments  during dredging;  (2)  placing a
layer of  an organic material  (e.g.,  digested  activated
sludge,  manure)  on top  of  the  dewatering  sediments  upon
completion of dredging; or  (3)  placing  a synthetic  liner  on
top of the water in  the lagoon  during and following dredg-
ing.  These measures would be expected to  keep PCB concen-
trations in the air above the lagoon at about 2 ug/m3 (007).

Water Treatment.   All  PCB-contaminated water  (supernatant
from initial  solids  dewatering, leachate,  rainwater, and
monitoring well  water  collected from the  lagoon) would be
processed through a package water treatment plant.  The water
would be treated to  PCB levels of below 1 ppb  (the USEPA
standard).   Treatment plant effluent would be monitored  (by
grab sampling and 24-hour sampling)  to ensure that discharges
were below 1 ppb.  An  onsite  laboratory would be available
to conduct the  water quality analyses.  Effluent would be
discharged to the harbor or to  a sanitary sewer.   Water dis-
charged to the sanitary sewer system would be processed again
through the Waukegan municipal  wastewater  treatment  plant
and discharged into the Des Plaines River.

Solids Removal,  Fixation,   and  Disposal.   Volatilization
would be expected  to occur during solids  removal from  the
lagoon and truck  loading for transport to  the batch plant.
The highest reported concentration in  a  Slip No.  3  sediment
sample is about  500,000 ppm (008).   The maximum  predicted
PCB concentration in the air from solids removal  operations
is predicted to  be  less than 200 ug/m3  for sediments with
concentrations of 100,000 ppm PCBs (007).  These values were
extrapolated from data  for sand assuming a 3.6-mph  wind and
an air temperature of  68°F.   The volatilization  rate from
Waukegan Harbor muck should be  less than from sand  (007).

Dewatered sediment would be  fixed  into a  nonflowable form
for offsite  transport  by truck.  A  sufficient amount  of
fixing agent would be used to prevent water loss, and covers
may be required  to prevent volatilization  during  transport.
Rules and regulations controlling the transport of hazardous
materials promulgated  by the United States  Department  of
Transportation  (USDOT), USEPA,  IDOT,  Illinois  Institute of
PD525.022                   6-25

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Natural Resources  (IINR),  and other applicable  regulatory
agencies would  be  complied with.   These  include cleanup,
safety, and spill prevention and response measures.

Offsite disposal of fixed dredged  sediments,  volatilization
material, and  liner material would require approximately
1,880 truck trips to the disposal  site using  a  10-yd3  capa-
city truck.  The established  full  truck routes  within  the
City of Waukegan have sufficient capacity to accommodate the
estimated truck  traffic,  but some  roadway  congestion and
roadway damage could occur  (048).   Some  species of terres-
trial  animals  could come into  contact with  contaminated
materials if any loss occurs  during transport,  and  the  con-
tamination  could  be passed  into other  terrestrial food
chains  (048) .

Disposal of the  materials  would be in a  licensed  chemical
waste  landfill,  and would  be  in compliance with State  and
Federal standards  for  PCB waste disposal.   PCB materials
with concentrations greater than 50 ppm must  be nonflowable
if they are to be disposed  of in a licensed chemical waste
landfill  (40 CFR 761) .   Solids  dewatering  and/or  fixation
must be complete enough  to  result  in a nonflowable consis-
tency after transport for final disposal.

Additional  Environmental  Impacts.   Implementation  of  this
alternative would also have the following impacts  (048):

     Noise.  Noise would be produced by construction, dredg-
     ing, and transportation activities.  Although  high noise
     levels could  periodically occur  in  localized areas,
     they would be of relatively short duration.  Noise im-
     pacts could temporarily  diminish  people's  enjoyment  of
     the public beach adjacent to the project area.

     Employment.  Construction  jobs created by  the project
     would  temporarily  reduce  unemployment in  the area.
     Employment  levels would  return to previous levels at
     the conclusion of the project.

     Recreation.  The noise and traffic congestion  associated
     with construction activities could have short-term nega-
     tive impacts on the public beach adjacent  to the project
     area.

     The City  of Waukegan uses the site  proposed   for  the
     dewatering lagoon as a parking area  for its public fes-
     tivals.  This  alternative  would preclude this use for
     the project duration.  The city would have to arrange
     other  transportation means (such as a shuttle system
     between the  downtown area and the  beach)  because no
     alternative parking facilities are available.
PD525.022                   6-26

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     Cultural Resources.  Cultural resources in the Waukegan
     Harbor area  would  not be adversely  affected.   It is
     possible that the cleanup of PCB-contaminated sediments
     would enhance the desirability of acquiring and retaining
     cultural resources in the harbor area.

Health and Safety Requirements.  The  PCB-contaminated  soil,
sediment, muck, dust, and water  associated  with  cleanup  ac-
tivities present  potentially  significant  health  hazards  to
workers involved  in the cleanup.  Each  specific  cleanup  ac-
tivity and associated work function would require the defini-
tion and  enforcement of  specific  safety precautions  and
levels of protection.   Ecology and Environment,  Inc., has
prepared a conceptual safety  plan  (see  Appendix).   The plan
calls for protection measures for workers who may be exposed
to PCB-contaminated materials.  Ambient air monitoring would
be performed,  and all workers  would require  appropriate
levels of protection.   Depending on  ambient air  monitoring
results, respiratory and  dermal  protection  may be required
downwind of site  cleanup  activities  and the holding lagoon.
In addition to  personal protection,  the  conceptual  safety
plan specifies  site  entry procedures, decontamination pro-
cedures, work  limitations,  and material  disposal  require-
ments.   A detailed health and safety  plan would  be  prepared
during final design of the selected response measures.

Reliability

Dredging.  Both hydraulic  and clamshell dredges  have  been
widely used in  the past  for dredging.  No new technologies
are proposed to complete the  dredging.  Dredging technology
is well developed, and  the  reliability  of the equipment  to
remove sediments  from  the slip and transport  them to the
lagoons is  high.   If a stoppage of  the  hydraulic  dredge
occurs during dredging,  it  is expected to  result  in some
temporary additional  suspension  of sediment  in  the water
column because of interruption in  hydraulic flow.   Leakage
or rupture of the hydraulic dredge discharge  pipeline  could
disperse  PCB-laden  water  and sediment over  previously
uncontaminated areas along the pipeline.  The impact of such
spills could be minimized by  prompt  cleanup of the spilled
material and of any soil or other material that was contami-
nated by the spill.   A contingency plan would be  established
for prompt cleanup.  Leakage  could either be eliminated  by
pipe joint tightening or  be controlled by  joint  caulking,
mats, collection containers, or similar means.  The collected
solids could be disposed of with the  PCB-contaminated solids,
and collected water  could  be  taken to  the  water  treatment
plant.

Dewatering Lagoon and Curing Cells.  The technology for con-
struction of lined lagoons  is well developed and feasible.
There are no  unusual construction details  for the lagoon
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construction.  Construction  could be  accomplished  using
conventionally available materials and equipment.  The  risk
of failure would be  low.   If the upper clay liner failed,
contaminated leachate could  be  collected  by the underdrain
system.  If  the lower clay liner also  failed,  contaminated
soil would have to  be excavated and disposed  of with the
other contaminated solids.

If an  exterior  lagoon dike failed, PCB-contaminated  water
and sediment could  flow  over a  large area, requiring sub-
stantial cleanup operations  and causing greatly  increased
volatilization.   The  technology for dike  design is  well
understood,  however,  so  the  probability  of dike  failure
would be extremely low.

If an  exterior  curing cell dike  failed while  a  cell was
filled with incompletely cured fixed solids, PCB-contaminated
water and  sediment  could  flow over a small area, requiring
cleanup operations and causing slightly increased volatiliza-
tion.  The technology  for dike  design is well  understood,
however, so the probability of dike failure would be extremely
low.

If detention  in  the lagoon  failed  to  lower the  moisture
content to the  extent originally anticipated,   either more
time could be allowed or  more fixing agent could be  used.
If more time were allowed, the total mass  of PCBs volatilized
would increase.  If more  fixing  agent  were used, the total
solids volume to disposed of would increase.

Water Treatment.  The water treatment system would use exist-
ing technology and  equipment shown to be  effective  in  PCB
removal.  The treatment plant would include a  clearwell for
detention of treated effluent prior to discharge.  PCB  con-
centrations  in  the  clearwell would be  monitored, and  if
adequate removal were not  achieved,  the water  could be re-
cycled through  the  plant until  discharge  standards   (less
than 1 ppb PCBs)  were met.

Fixation.  Fixation would use existing equipment in an appli-
cation similar to previous applications, but not yet estab-
lished for these high-moisture-content sediments.    Labora-
tory testing is now being  conducted to verify  that  fixation
can be  accomplished with existing available materials  and
equipment.  It is anticipated that fixation will prove to be
a technically  feasible  and reliable means  of  controlling
water loss.  If fixation  failed  to prevent  water loss,  then
solids would have to  be  dewatered mechanically as proposed
for Alternative 3,  or a waiver  from that  requirement  of
40 CFR 761 would have to be obtained from the USEPA Regional
Administrator.
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Transportation.   Transportation would be accomplished  using
dump trucks.  Failure could occur  by  loss  of material from
the truck through  leakage,  spilling over  the top, dusting,
volatilization,  or spills resulting from vehicle accidents.

The impact of leakage, dusting, and volatilization would  be
to disperse small amounts of PCBs all along the haul routes.
These types of  uncontrolled release  could be minimized by
the use of tailgate seals and covers.

The impact of spills would be to deposit a quantity  of PCB-
contaminated solids  at  one or more isolated points.  The
risk of spills over the top of the truck could  be minimized
by use of a cover.   The  risk  of  vehicle accidents is rela-
tively small, but  it  could be compensated for  by having  a
response plan and team ready during hauling.

Permit Requirements

Permit requirements are anticipated to include:

     •    USCOE Section 10  (dredging)  permit

     •    USCOE Section 404 (disposal in waterways)  permit

     •    IEPA water  quality certification  on all  USCOE
          permits

     •    Waukegan Port Authority dredging permit

     •    IEPA permit for construction  of wastewater treat-
          ment facilities

     •    NPDES  permit   (State/Federal)  for  point-source
          water discharge from the water treatment plant

     •    North Shore Sanitary District approval if water
          discharge goes to a sanitary sewer

     •    IDOT  (Division of Waterways)  permit  for work in
          public waterways

     •    IEPA  (Division of Land  and  Noise)   special waste
          hauler's permit

     •    City of Waukegan construction permits

     •    Local land use approval

     •    Certification of Authority  to haul PCB commodities
          (ICC and IICC)

     •    USEPA toxic substances  disposal approval
PD525.022                   6-29

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     •    IEPA approval if material  is  disposed in a  cur-
          rently non-PCB-approved site

See Mason & Hanger's report  (003) for further discussion  of
applicable governmental regulations.

Alternative 2D;  Dredge-Dewater in Barges-Fix-Dispose

Response Objectives

This alternative would remove all sediments  from Slip  No.  3
with PCB concentrations greater than 50 ppm.  If a 95 percent
removal efficiency were achieved, it would remove an estimated
290,000 Ib of PCBs contained in  approximately 10,900 yd3  of
sediments.  This would remove about  93.5 percent of all the
PCBs now  found in the  Slip  No.  3 and Upper Harbor area
(003) .

Mathematical modeling  conducted  by  HydroQual,  Inc.  (035),
indicates that dredging of the harbor  sediments to a level
of 50 ppm PCB would reduce peak  water column concentrations
by approximately one order of magnitude (to  less than 0.1 ppb)
and fish body burdens to less than 5 ppm.   Since this alterna-
tive would remove approximately 93.5 percent of all the PCBs
now found in  Slip  No.  3 and the Upper Harbor,  results  are
expected to be similar to reductions predicted by the model.
Removal would also significantly diminish the existing esti-
mated volatilization rate of 12 to 40 Ib/yr  of PCBs that are
released from Slip No.  3 into the local airshed by  approxi-
mately an order of magnitude (007) .

All former land and water uses would be able to resume after
cleanup activities are completed.  No restrictions to future
uses would be expected.

Duration of Cleanup Activities

Dredging and related activities for Slip No. 3 would require
about 2 months.  An  additional  2 months would  be  required
for dredging  and  related  activities in the  localized  area
requiring dredging of  deep  contaminated  sand and silt.  If
the water treatment plant were not protected against freezing
weather, the dewatering barges would not be  able to  release
slurry water to the plant during freezing conditions.  Dredg-
ing would  then have to occur during nonfreezing weather.
Use of barges  for  dewatering may also be problematic  during
freezing periods, because of ice buildup and difficulty with
sediment removal.

Solids removal to the batch plant would begin about 2 months
after dredging activities are completed.   Removal  and  fixa-
tion of the dewatered sediments would require 2 to 3 months.
PD525.022                   6-30

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Offsite transportation to the disposal site would be concur-
rent with the  fixation  process.   Total project duration is
estimated to be 9 months.

Impacts and Mitigation of Cleanup Activities

Dredging.  Roiling of bottom  sediments during dredging re-
sults in sediment  suspension  and dispersion.   The use of a
hydraulic dredge and the  proper  dredge head would minimize
roiling and sediment dispersion.  A  sediment  dispersal con-
trol system (double silt curtain or steel sheet piling) would
also be  employed   to  minimize migration of suspended  PCBs
out of the dredging area.  To assist in controlling sediment
dispersion, water  would be continually pumped  from  inside
the slip during construction  to  maintain  net  inflow at the
slip mouth.  This would tend to keep sediments from crossing
the control barrier.   The water could be treated by addition
of polymer and/or activated carbon before the sediment barrier
is removed.

A program would be established to monitor the effectiveness
of the containment measures and to warn of the need for poly-
mer addition  or shutdown  of  dredging.  A seiche warning
arrangement with the National Weather  Service would  also be
put in place  so operations could be suspended  if a  seiche
were imminent.  The containment  devices would be the  most
likely to fail during a seiche due to  the forces  created by
a sudden difference in water  level between the  two  sides of
the sheet piling or double silt curtain.

A clamshell dredge may be required in  the localized  area of
Slip No. 3 to  remove the  deep contaminated  sediments  (sand
and silt) below the muck at the former OMC outfall.   Spillage
of 15 to 30 percent of  the sediments in a clamshell bucket
occurs while it is being raised.   This spillage would create
a high degree of sediment suspension that would increase the
concentration of PCBs in  solution.   A  sheet  pile cofferdam
would be employed to  support the excavation sides and contain
these dredging  activities.  The  water  would be treated by
the addition of powdered activated carbon to remove dissolved
PCBs before the cofferdam is removed.  The water level inside
the cofferdam would be  lowered  to create net inflow as an
additional control measure.

The City of Waukegan maintains an emergency water intake in
Waukegan Harbor.  This water intake, while an  integral  part
of the Waukegan Harbor system,  is  rarely used.  Project
activities would  be  expected to  be completed  while the
intake was not  in  use.   If, however,  the  intake was needed
during project activities,  a  monitoring program,  including
sampling of raw and  finished water, would  be established
during the project to ensure  the safety of the supply.  A
PD525.022                   6-31

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contingency plan would also be  established to stop project
operations if any contamination entered the system.

Larsen Marine Services would  be adversely affected by  any
dredging that inhibited  or cut  off  access to its  docks.
These impacts would be short-term and could be minimized by
scheduling dredging  during periods  that  would cause the
least impact on Larsen Marine Services.

Minimal volatilization would  be expected  to  occur during
dredging activities.   Losses would be expected to be roughly
0.3 to 0.4 Ib/day/acre from the  exposed,  agitated,  and  con-
taminated water  area  (030) .   Concentrations  of  less  than
2 ug/m3 would be expected  to be  present in the air  as a re-
sult of dredging activities (007).   By comparison,  the  OSHA
standard for  maximum worker exposure  to  Aroclor 1242  is
1,000 ug/m3 in the air at  any  time.   However, NIOSH recom-
mends that workers not be  exposed to more than 1 ug/m3 in
the air during  an 8-hour  period (007) .    (See Health and
Safety Requirements,  later in this section.)

The proposed dredging would affect terrestrial biota.    Popu-
lations of gulls and terns that  currently reside and feed in
the vicinity of  the harbor would be  disturbed by increased
noise and activity levels  and may move to another area  along
the shoreline of Lake Michigan  during  the times  of the day
when disturbances  would  occur.  However,  because  none  of
these species breeds in the immediate vicinity of the harbor,
no long-term displacement  of populations is anticipated (048),

Some species of birds could come into contact with  the  con-
taminated sediments and water  in the harbor and dewatering
barges, particularly  during  non-working hours  (gulls)  and
autumn migration periods (waterfowl  and shorebirds) (048).

Changes in the  harbor water column  PCB concentrations  and
reduced PCB accumulations  in fish would be the two principal
long-term beneficial impacts of  dredging.

Possible short-term adverse impacts  of dredging would include
the following:

     •    The area  inside  the  sediment  dispersal  control
          device used to detain  roiled sediments would  become
          turbid during dredging and would very likely  become
          anoxic in the pre-dawn hours following a day of
          dredging in organic "muck" sediments.  Indications
          are that "disturbances"  of polluted bottom sedi-
          ments, especially if they  have great quantities of
          reduced compounds dissolved in  the  intersticial
          waters, can elevate the expression of sediment
          oxygen demand by as much as one order of magnitude.
          Diurnal rhythms  of  respiration/photosynthesis in
PD525.022                   6-32

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          freshwater algae  are  such that the lowest oxygen
          levels  occur in  pre-dawn hours.   Consequently,
          almost  all  respiring organisms inside  the silt
          curtains would  be driven out  or  may die during
          early morning hours after dredging  (048).

     •    If dredging  occurs during the  fall and spring,
          there is a good chance  that spawning fish may be
          present in the  harbor during  the  dredging  activi-
          ties.   Chinook  making fall runs  may  be able to
          swim around  or  leap over  the  silt curtains  into  a
          highly PCB-laden  body of  water  (048) .

Dewatering.  Under this alternative, barges would be used to
dewater dredged  sediments.   The barges could be  moored in
the Upper Harbor  during  the dewatering process, then towed
to  shore  for solids  removal.  No  special lining  would be
necessary, since any water  leakage  would  flow into the barges,
and become mixed  with  the supernatant.   Decant water would
be pumped to the water treatment plant.

Some volatilization of PCBs would occur during dewatering.
Volatilization would be  minimized during initial placement
of the dredged sediments  by the decanting water layer.  This
would reduce the  estimated volatilization  rate from 2 Ib
PCBs per day (for exposed sediments with an average  concen-
tration of 1,000 ppm)  to  less than  1.0  Ib PCBs  per day  from
the less contaminated  (100  ppm) decanting layer (007) .  Other
measures that  could  be employed include:   (1)  placing  the
less contaminated sediments on  top  of  the more  contaminated
sediments during dredging;  (2) placing a  layer of an organic
material  (e.g., digested  activated  sludge,  manure) on top of
the dewatering  sediments upon completion of dredging;  or
(3) placing a  synthetic  liner on top of  the water in the
barges during and following dredging.   These  measures would
be expected to keep PCB  concentrations  in the air above the
barges at about 2 ug/m3  (007).

Water Treatment.  All  PCB-contaminated water  (supernatant
from initial solids  dewatering,  leachate,  rainwater,  and
monitoring well water  collected from the lagoon)  would be
processed through a package water treatment plant.  All water
would be  treated  to  PCB  levels of  below 1  ppb (the  USEPA
standard).  Treatment  plant effluent would  be monitored (by
grab sampling and 24-hour sampling) to ensure that discharges
were below 1 ppb.  An  onsite laboratory would be available
to conduct the  water  quality analyses.   Effluent  would be
discharged to the harbor  or to a sanitary sewer.  Water dis-
charged to the  sanitary sewer system would  be processed again
through the  Waukegan municipal wastewater  treatment  plant
and discharged  into the Des Plaines River.
PD525.022                   6-33

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Solids Removal, Fixation, and Disposal.  Volatilization would
be expected to occur  during  solids  removal from the barges
and truck  loading  for transport to the  batch  plant.   The
highest reported concentration in a Slip No. 3 sediment sample
is about 500,000 ppm  (008).  The maximum predicted  PCB  con-
centration in the air from solids removal operations is pre-
dicted to be less than 200 ug/m3 for sediments with concentra-
tions of 100,000 ppm  PCBs (007).   These values were extra-
polated from data  for sand  assuming a 3.6-mph wind and  an
air temperature of 68°F.  The volatilization rate from Waukegan
Harbor muck should be less than from sand  (007) .

Dewatered  sediment would be  fixed into a  nonflowable  form
for offsite transport by truck.  A sufficient amount of fixing
agent would be used to prevent water loss, and covers may be
required to prevent volatilization  during  transport.   Rules
and regulations controlling the transport of hazardous mater-
ials promulgated by the  USDOT, USEPA,  IDOT,  IINR, and  other
applicable regulatory agencies would be complied with.  These
include cleanup, safety,  and  spill  prevention and response
measures.

Offsite disposal of fixed dredged sediments and volatilization
material would  require  approximately 1,650 truck trips  to
the disposal site using  a 10-yd3 capacity truck.  The estab-
lished full truck  routes within the City  of Waukegan  have
sufficient capacity to accommodate the estimated truck traffic,
but some roadway congestion  and roadway damage could occur
(048).  Some species  of  terrestrial animals  could come  into
contact with contaminated materials if any loss occurs during
transport, and the contamination could  be  passed  into  other
terrestrial food chains  (048).

Disposal of the fixed materials would be in a licensed chemi-
cal waste  landfill,  and would be in compliance with  State
and Federal standards for PCB waste disposal.  PCB materials
with concentrations greater than  50 ppm must be nonflowable
if they are to  be  disposed  of  in a licensed chemical waste
landfill  (40 CFR 761) .   Solids dewatering and/or  fixation
must be complete enough  to  result in a nonflowable consis-
tency after transport for final disposal.

Additional Environmental Impacts.   Implementation  of  this
alternative would also have the following  impacts (048):

     Noise.  Noise would be produced by construction, dredg-
     ing,  and transportation activities.  Although high noise
     levels could  periodically occur  in localized areas,
     they  would be of relatively  short duration.  Noise im-
     pacts could temporarily diminish  people's  enjoyment of
     the public beach adjacent to the project area.
PD525.022                   6-34

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     Employment.  Construction jobs  created  by  the project
     would temporarily  reduce unemployment  in  the area.
     Employment levels would  return to previous levels  at
     the conclusion of the project.

     Recreation.  The noise and traffic congestion associated
     with construction activities could have short-term nega-
     tive impacts on the public beach adjacent to the project
     area.

     Cultural Resources.   Cultural resources in the Waukegan
     Harbor area would  not be adversely  affected.   It is
     possible that the cleanup of PCB-contaminated sediments
     would enhance the desirability of acquiring and retaining
     cultural resources in the harbor area.

Health and Safety Requirements.  The  PCB-contaminated  soil,
sediment, muck, dust, and water associated with cleanup acti-
vities present  potentially significant health  hazards to
workers involved in the cleanup.   Each specific cleanup acti-
vity and associated work function would require the definition
and enforcement of specific safety precautions and levels of
protection.  Ecology and Environment,  Inc.,  has prepared a
conceptual safety plan  (See Appendix).   The  plan calls for
protection measures for workers who  may  be exposed to PCB-
contaminated materials.   Ambient air monitoring  would be
performed, and all workers would require  appropriate  levels
of protection.  Depending on ambient air monitoring results,
respiratory and dermal protection  may be required downwind
of site cleanup activities and the dewatering barges.   In
addition to personal protection,  the  conceptual  safety plan
specifies site entry procedures,  decontamination procedures,
work  limitations,  and material disposal  requirements.  A
detailed health and  safety plan would be prepared during
final design of the selected response measures.

Reliability

Dredging.  Both hydraulic  and clamshell dredges have  been
widely used in  the past  for  dredging.  No new technologies
are proposed to complete the  dredging.   Dredging  technology
is well developed, and the reliability of the equipment to
remove sediments from  the  slip and  transport them to the
lagoons is high.   If a  stoppage  of the  hydraulic  dredge
occurs during  dredging,  it is expected to result  in  some
temporary additional  suspension  of  sediment  in the water
column because of  interruption in  hydraulic  flow.   Leakage
or rupture of  the hydraulic dredge  discharge  pipeline  could
PD525.022                   6-35

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disperse PCB-laden water  and sediment over previously  un-
contaminated areas along  the pipeline.   The  impact of such
spills could be minimized by prompt  cleanup  of the spilled
material and of any soil or other material that was contami-
nated by the spill.  A contingency plan would be established
for prompt cleanup.  Leakage could either be eliminated by
pipe joint tightening  or  be controlled by joint  caulking,
mats, collection containers, or similar means.  The  collec-
ted solids could  be  disposed of with the  PCB-contaminated
solids, and  collected  water could be  taken  to the  water
treatment plant.

Dewatering Barges.  The technology for construction of barges
and handling slurry materials is well developed and feasible.
Conventionally available  flat-deck barges  could be used for
dewatering.  If  a barge  sank,  PCB-contaminated water and
sediment would flow back  into the harbor.  However,  such an
event is unlikely.  If it occurred,  additional dredging would
be required to re-excavate the  spilled sediment.   Some  loss
of PCBs by way  of the  spilled  supernatant would occur.   It
is estimated that  this loss would be  less than  0.1  Ib  of
PCBs if one barge sank.

If detention in the barges failed to lower the moisture con-
tent to the extent originally anticipated, either more  time
could be allowed  or  more  fixing agent could  be  used.  If
more time were  allowed, the  total mass of PCBs volatilized
would increase.   If more  fixing agent  were used,  the total
solids volume to be disposed of would increase.

Curing Cells.  The technology for construction of the curing
cells is well developed and  feasible.  There  are  no  unusual
construction details for  the curing cell construction.  Con-
struction could be accomplished using  conventionally avail-
able materials and equipment.   The risk of failure would be
low.  If the upper clay liner failed,  contaminated leachate
could be collected by  the underdrain system.   If  the lower
clay liner also  failed, contaminated soil would have to be
excavated and disposed of with  the other contaminated solids.

If an  exterior  curing cell  dike  failed  while a  cell was
filled with incompletely  cure fixed solids, PCB-contaminated
water and  sediment could  flow over  a small area,  requiring
cleanup operations and causing  slightly  increased volatili-
zation.  The technology for  dike design  is well understood,
however, so  the probability of dike failure  would be ex-
tremely low.

Water Treatment.  The water treatment system would use exist-
ing technology  and equipment shown  to be  effective  in  PCB
PD525.022                   6-36

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removal.  The treatment plant would  include  a  clearwell  for
detention of treated effluent prior  to discharge.   PCB con-
centrations in  the clearwell would  be  monitored,  and if
adequate removal were not achieved,  the  water  could be re-
cycled  through  the plant until  discharge  standards (less
than 1 ppb PCBs) were met.

Fixation.  Fixation would use existing equipment in an appli-
cation similar to previous applications, but not  yet estab-
lished for these high-moisture-content sediments.  Laboratory
testing is now being conducted  to  verify that  fixation can
be accomplished with existing available materials and equip-
ment.  It is anticipated  that  fixation  will prove  to be a
technically feasible and reliable means of controlling water
loss.  If fixation failed to prevent water loss, then solids
would have to be dewatered mechanically as proposed for Alter-
native 3, or a  waiver  from  that requirement of  40  CFR 761
would have to be obtained from the Regional Administrator.

Transportation.  Transportation would be accomplished using
dump trucks.  Failure could  occur  by loss  of material from
the truck through  leakage,  spilling  over the top, dusting,
volatilization, or spills resulting  from vehicle accidents.

The impact of leakage, dusting, and  volatilization  would be
to disperse small amounts of PCBs all along the haul routes.
These types of  uncontrolled  release  could be minimized by
the use of tailgate seals and covers.

The impact of spills would be to deposit a quantity of PCB-
contaminated solids  at  one  or more  isolated points.   The
risk of spills over the top of the truck could be minimized
by use of a cover.   The  risk of vehicle  accidents is rela-
tively small, but  it could  be  compensated for by having a
response plan and team ready during hauling.

Permit Requirements

Permit requirements are anticipated to include:

     •    USCOE Section 10 (dredging) permit

     •    USCOE Section 404  (disposal in waterways)  permit

     •    IEPA water  quality certification  on all USCOE
          permits

     •    NPDES  permit   (State/Federal)   for point-source
          water discharge from the water treatment plant

     •    Waukegan Port Authority dredging permit
PD525.022                   6-37

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     •    IEPA permit for construction of wastewater  treat-
          ment facilities

     •    North Shore Sanitary  District  approval if  water
          discharge goes to a sanitary sewer

     •    IDOT  (Division of  Waterways)  permit for work  in
          public waterways

     •    IEPA  (Division of  Land  and Noise) special  waste
          hauler's permit

     •    City of Waukegan construction permits

     •    Local land use approval

     •    Certification of Authority to haul PCB commodities
          (ICC and I1CC)

     •    USEPA toxic substances disposal approval

     •    IEPA approval  if material is disposed in a cur-
          rently non-PCB approved site

See Mason & Hanger's report  (003) for  further  discussion of
applicable governmental regulations.

Alternative 3:  Dredge-Dewater in Lagoon-Dispose

Response Objectives

This alternative would  remove all sediments from Slip No. 3
with concentrations of PCBs greater than 50 ppm.  If a 95 per-
cent removal  efficiency were achieved, it  would remove  an
estimated 290,000  Ib  of PCBs  contained  in  approximately
10,900 yd3 of sediments.  This would remove about  93.5 per-
cent of all the PCBs now found  in  the  Slip No. 3 and Upper
Harbor area (003).

Mathematical modeling conducted  by HydroQual,  Inc.  (035),
indicates that dredging  of the  harbor  sediments to a level
of 50 ppm PCB would reduce peak water  column concentrations
by approximately one order of magnitude (to less than 0.1 ppb)
and fish body burdens to less than 5 ppm.    Since this alter-
native would  remove  approximately  93.5 percent of all the
PCBs now found in  Slip  No. 3 and  the Upper Harbor, results
are expected  to be similar to reductions predicted by the
model.  Removal would also significantly diminish the exist-
ing estimated volatilization  rate of 12 to  40  Ib/yr of PCBs
released from the  harbor into the local airshed  by approxi-
mately an order of magnitude  (007).
PD525.022                   6-38

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All former land and water uses would be able to resume after
cleanup activities are completed.  No restrictions to future
uses would be expected.

Duration of Cleanup Activities

Dredging and related activities for Slip No. 3 would require
about 2 months.   An  additional 2 months would be  required
for dredging and  related activities in the  localized  area
requiring dredging of  deep  contaminated sand and silt.  If
the water treatment plant were not protected against freezing
weather, the dewatering  lagoon would not be  able  to  release
slurry water to the plant during freezing conditions.  Dredg-
ing would then have to occur during nonfreezing weather.

Because dredged solids would  not  be fixed,  they would have
to be dewatered in the lagoon  for an extended  time to  reach
an adequate nonflowable  consistency for disposal.  Even with
the  employment  of  additional  mechanical   dewatering,
retention time is expected to be from 1 to 2 years.

Offsite transportation to the disposal  site  would  begin  ap-
proximately  3  to 4 months  after  completion of  dredging.
Transportation would continue  intermittently until project
completion.  Total  project duration  is estimated to  be
3 years.

Impacts and Mitigation of Cleanup Activities

Dredging.  Roiling of bottom sediments during dredging results
in sediment suspension and dispersion.  The use of a hydraulic
dredge and the proper dredge head would minimize roiling and
sediment dispersion.   A  sediment dispersal  control  system
(double silt curtain or  steel sheet piling) would also  be
employed to minimize migration of suspended  PCBs  out of  the
dredging area.   To assist in controlling sediment dispersion,
water would be continually pumped from inside the Upper Harbor
during construction to maintain net inflow at the Upper Harbor
mouth.  This would tend  to keep sediments from crossing  the
control barrier.  The water could be treated by  addition of
polymer and/or activated carbon before  the  sediment  barrier
is removed.

A program would be established to monitor the  effectiveness
of the containment measures and to warn of the need for poly-
mer addition or shutdown of  dredging.   A seiche  warning
arrangement with the National Weather Service  would  also be
put in place so  operations  could be suspended if  a  seiche
were imminent.   The containment devices would be most likely
to fail during a seiche  due to the forces created by a sudden
difference in water level between the two sides of the sheet
piling or double silt curtain.
PD525.022                   6-39

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A clamshell dredge may be required in the  localized  area  of
Slip No. 3 to remove  the  deep contaminated sediments (sand
and silt) below the muck at the former OMC outfall.  Spillage
of 15 to 30 percent of the  sediments  in  a clamshell bucket
occurs while it is being raised.  This spillage would create
a high degree of sediment suspension that would increase the
concentration of PCBs in  solution.  A sheet pile cofferdam
would be employed to  support  the  excavation sides and con-
tain these dredging activities.   The water would  be  treated
by the addition of powdered activated carbon to remove  dis-
solved PCBs before the cofferdam sediment barrier was removed.
The water  level  inside  the cofferdam would  be  lowered to
create net inflow as an additional control measure.

The City of Waukegan maintains  an emergency water intake  in
Waukegan Harbor.  This water  intake, while an  integral  part
of the  Waukegan  Harbor system,  is  rarely used.   Project
activities would  be expected  to  be completed  while the
intake was not in use.   If, however,  the intake was needed
during project activities,  a  monitoring  program,  including
sampling of  raw  and finished water,  would be  established
during the project  to ensure  the safety.of the supply.   A
contingency plan would also be  established to  stop project
operations if any contamination entered the system.

Larsen Marine Services would  be adversely affected  by  any
dredging that  inhibited  or cut off  access to  its  docks.
These impacts would be short-term and could be  minimized  by
scheduling dredging during periods that would cause the least
impact on  Larsen Marine Services.

Minimal  volatilization would  be  expected  to  occur during
dredging activities.  Losses would be expected to be roughly
0.3 to 0.4 Ib/day/acre from the exposed,  agitated,  and  con-
taminated water  area  (030) .  Concentrations of less than
2 ug/m3  would  be  expected to be  present in the  air  as  a
result of dredging activites  (007).  By comparison, the OSHA
standard for  maximum worker  exposure  to Aroclor  1242  is
1,000 ug/m3 in the  air at  any time.   However,  NIOSH recom-
mends that workers  not  be exposed to more than I ug/m3  in
the air  during  an 8-hour period  (007) .    (See  Health  and
Safety Requirements, later in this section.)

The proposed dredging would affect terrestrial biota.  Popula-
tions of gulls and  terns  that currently  reside and feed in
the vicinity of the harbor  would be disturbed by increased
noise and activity levels and may move to  another area along
the shoreline of Lake Michigan  during  the times of the day
when disturbances  would  occur.   However,  because none of
these species breeds in the immediate vicinity of the harbor,
no long-term displacement of populations is anticipated  (048).
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Some species of birds or other animals could come into contact
with the contaminated sediments and water in the  harbor  and
dewatering  lagoon,  particularly during  non-working hours
(gulls) and autumn migration  periods  (waterfowl and shore-
birds)  (048).

Changes in  the  harbor  water column PCB  concentrations and
reduced PCB accumulations in fish would be the two principal
long-term beneficial impacts of dredging.

Possible short-term adverse impacts of dredging would include
the following:

     •    The area  inside the  sediment  dispersal control
          device used to detain roiled sediments would become
          turbid during dredging and would very likely become
          anoxic in the  pre-dawn  hours  following a day  of
          dredging in organic "muck" sediments.  Indications
          are that "disturbances"  of  polluted  bottom sedi-
          ments, especially if they have great quantities of
          reduced compounds  dissolved in the  intersticial
          waters, can  elevate the expression  of sediment
          oxygen demand by as much as one order of magnitude.
          Diurnal rhythms  of  respiration/photosynthesis  in
          freshwater algae are  such that the  lowest oxygen
          levels occur  in pre-dawn hours.   Consequently,
          almost all  respiring organisms inside  the  silt
          curtains would  be  driven out  or may die during
          early morning hours after dredging (048) .

     •    If dredging  occurs  during the  fall  and spring,
          there is a good  chance  that  spawning fish may  be
          present in the harbor during the dredging activi-
          ties.   Chinook  making fall  runs may  be able to
          swim around or leap over the silt curtains into  a
          highly PCB-laden body of water (048).

Dewatering.  Construction of a  dewatering lagoon  and treat-
ment facilities on OMC property or another nearby site would
remove  this land  from  other uses  for the duration of the
project.

The lagoon would be constructed with impermeable clay liners
and a  leachate  collection  system.   The  groundwater beneath
the lagoon would be monitored by test wells  to detect leakage
from the lagoon.

Under this alternative, volatilization would be significantly
increased during retention of  the  dredged materials in the
lagoon because mechanical dewatering would be employed.  The
RUC system  (or  other channelization techniques)  would be
used to channel the sediments for drainage of water to expose
them to air for evaporation and drying.   After the top layer
PD525.022                   6-41

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was dry,  it would  be removed and the process would be  re-
peated.  This would result in substantially more volatiliza-
tion of PCBs to the  atmosphere than  for  Alternatives  2B and
2D, since evaporation is a necessary part of  the  dewatering
process.  The highest reported concentration in a Slip No.  3
sediment  sample is about  500,000  ppm (008,  016).   The pre-
dicted PCS concentration in the air from volatilization above
these sediments would be  less  than 200 ug/m3  for sediments
with concentrations of 100,000 ppm PCBs.  The volatilization
rate is predicted to be less than 163,000 ug/m2/hr or 63 lb/
day.  Typical  PCB  concentrations range  from  about  500  to
5,000 ppm PCB.  Predicted average concentrations  in the air
from volatilization would be less than 6.6 ug/m3, assuming  a
typical PCB concentration of 1,000 ppm.  The average volatili-
zation rate from these sediments is expected to be less than
5,375 ug/m2/hr or  2  Ib/day PCB.   These values are extrapo-
lated from data for sand, assuming a 3.6-mph wind and an air
temperature of 68°F.  The volatilization rate  from  Waukegan
Harbor muck should be less than from sand (007) .

Because this alternative would require more time  for  solids
dewatering, it would restrict  land uses  on  the  OMC  property
or  another  nearby  site used for  the lagoon for  a  longer
period than Alternative 2B.  It would, however, involve less
total property use,  since it would not require  land for the
fixation process.

Water Treatment.   All  PCB-contaminated  water  (supernatant
from  initial  solids dewatering,  leachate,  rainwater,  and
monitoring well water  collected  from the lagoon) would be
processed through a package water treatment plant.  All water
would be  treated  to PCB levels of below 1  ppb (the USEPA
standard).  Treatment plant  effluent would  be monitored (by
grab sampling and 24-hour sampling) to ensure that discharges
were below  1 ppb.  An  onsite laboratory would be available
to  conduct water quality  analyses.   Effluent  would be  dis-
charged to  the  harbor  or to a sanitary  sewer.  Water dis-
charged to the sanitary sewer system would be processed again
through the Waukegan municipal wastewater  treatment  plant
and discharged into the Des Plaines River.

Solids  Removal  and Disposal.  Volatilization would be  ex-
pected  to occur  during solids  removal from the lagoon  and
truck loading  for  offsite transport.  The highest reported
concentration  in  a  Slip  No.  3 sediment  sample  is  about
500,000 ppm (008,  016).   The predicted PCB  concentration in
the air  from volatilization  above these sediments would be
less  than 200  ug/m3  for  sediments with  concentrations  of
100,000 ppm PCBs.   The  volatilization  rate  is predicted to
be  less  than  163,000 ug/m2/hr  or 63 lb/  day.  Typical  PCB
concentrations range from about 500  to  5,000  ppm  PCB.   Pre-
dicted average concentrations in the air  from volatilization
PD525.022                   6-42

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would be less than 6.6 ug/m3, assuming a typical PCS concen-
tration of 1,000 ppm.  The  average volatilization  rate  from
these sediments is expected to  be less than 5,375 ug/m2/hr
or 2 Ib/day  PCB.   These  values  are extrapolated from data
for sand, assuming a  3.5-mph wind and  an  air  temperature  of
68°F.  The volatilization rate  from Waukegan  Harbor muck
should be less  than  from sand  (007).    Since the sediments
would be dry, PCB-laden  dust particles may be dispersed in
the air  by excavation activities.  This may cause  ambient
air concentrations to exceed 1,000 ug/m3.

Additional precautions would be required during offsite trans-
portation of the non-fixed  materials.  Trucks would  have  to
employ a liner  (such as heavy-duty plastic sheeting) to pre-
vent leakage or spillage.   Cover or closure of  the  trucks
would be  required  to prevent spillage and volatilization
during transport.   Rules and regulations  controlling  the
transport of toxic materials promulgated by the USDOT,  USEPA,
IDOT, IINR,  and other applicable  regulatory agencies would
be complied with.   These  include  cleanup,  safety,  and spill
prevention and  response measures.

Offsite  disposal  of  fixed  dredged  sediments  and  liner
material would  require  approximately  16,700  truck  trips
to the disposal site using a 10-yd3 capacity  truck.  The
established  full truck routes within the City of  Waukegan
have sufficient capacity  to accommodate  the estimated truck
traffic,  but  some  roadway  congestion  and roadway  damage
could occur  (048).  Some species of  terrestrial  animals
could come into contact  with contaminated materials if  any
loss occurs during transport, and the contamination could be
passed into other terrestrial food chains  (048).

Disposal of  the materials would be in a  licensed  chemical
waste landfill, and  would be  in compliance with State  and
Federal  standards  for PCB  waste  disposal.   PCB  materials
with concentrations greater than  50 ppm must be  nonflowable
if they  are  to  be  disposed  of in a chemical waste landfill
(40 CFR 761).   Solids dewatering must  be  complete  enough  to
result in a  nonflowable  consistency  after transport to  the
final disposal  site.   If a nonflowable  consistency cannot be
obtained, fixation will be required.

Additional Environmental  Impacts.   Implementation of this
alternative would also have  the  following impacts  (048):

     Noise.   Noise would be  produced by construction, dredg-
     ing, and transportation activities.  Although high  noise
     levels  could  periodically  occur  in  localized areas,
     they would be of relatively  short duration.   Noise im-
     pacts could temporarily diminish  people's enjoyment  of
     the  public beach adjacent  to the project area.
PD525.022                   6-43

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     Employment.   Construction jobs created by  the project
     would temporarily  reduce unemployment in  the area.
     Employment levels would  return  to previous levels at
     the conclusion of the project.

     Recreation.   The noise and traffic congestion associated
     with construction activities could have short-term nega-
     tive impacts on the public beach adjacent to the project
     area.

     The City  of  Waukegan uses the site proposed  for the
     dewatering lagoon as a parking area for its public fes-
     tivals.   This alternative would  preclude this use for
     the project duration.  The  city  would  have to arrange
     other transportation means  (such as a shuttle  system
     between the  downtown  area and the  beach)  because no
     alternative parking facilities are available.

     Cultural Resources.  Cultural resources in the Waukegan
     Harbor area  would  not be adversely affected.   It is
     possible that the cleanup of PCB-contaminated sediments
     would enhance the desirability of acquiring and retaining
     cultural resources in the harbor area.

Health and Safety Requirements.  The  PCB-contaminated soil,
sediment, muck, dust, and water  associated with  cleanup ac-
tivities present  potentially  significant health hazards to
workers involved in the cleanup.  Each  specific  cleanup ac-
tivity and associated work  function would require  the defi-
nition and enforcement  of specific safety precautions  and
levels of protection.   Ecology and Environment, Inc.,  has
prepared a conceptual safety plan  (see  Appendix).  The  plan
calls for protection measures for workers who may be exposed
to PCB-contaminated materials.  Ambient air monitoring would
be performed, and all workers would require appropriate levels
of protection.  Depending on ambient air monitoring results,
respiratory and dermal  protection  may be required downwind
of site cleanup activities and the holding lagoon.  In addi-
tion  to  personal protection,  the  conceptual  safety  plan
specifies site entry procedures, decontamination procedures,
work  limitations,  and material  disposal requirements.   A
detailed  health  and  safety plan would  be  prepared during
final design of the selected response measures.

Reliability

Dredging.  Both  hydraulic and clamshell dredges have been
widely used in the past for dredging.  No  new technologies
are proposed to complete  the  dredging.   Dredging technology
is well developed, and  the  reliability of  the equipment to
remove  sediments  from the slip  and  transport them to the
lagoons is high.  If a stoppage of the  hydraulic dredge occurs
during dredging,  it  is  expected  to result in  some  temporary
PD525.022                   6-44

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additional suspension of sediment in the water column because
of interruption  in  hydraulic flow.   Leakage or rupture  of
the hydraulic dredge discharge pipeline could  disperse PCB-
laden water and sediment over previously uncontaminated areas
along the pipeline.   The impact of such spills could be mini-
mized by prompt  cleanup  of  the  spilled material and of any
soil or other material that  was  contaminated by the spill.
A contingency plan would be  established for  prompt  cleanup.
Leakage could either be eliminated by  pipe joint  tightening
or be  controlled by joint caulking, mats, collection  con-
tainers, or similar means.   The  collected solids could  be
disposed of with  the PCB-contaminated  solids,  and collected
water could be taken to the water treatment plant.

Dewatering Lagoon.  The technology for construction of lined
lagoons is well developed and feasible.  There are no unusual
construction details for the lagoon construction.   Construc-
tion could  be  accomplished using conventionally  available
materials and equipment.  The risk of  failure  would be low.
of the upper clay liner failed,  contaminated  leachate  could
be collected by  the  underdrain  system.  If the lower  clay
liner also failed, contaminated  soil would have to be  exca-
vated and disposed of with the other contaminated solids.

If an  exterior  lagoon failed, PCB-contaminated water  and
sediment could flow over  a  very  large area,  requiring sub-
stantial cleanup  operations  and  causing greatly  increased
volatilization.   The  technology  for  dike  design  is well
understood, however,  so  the probability  of  dike failure
would be extremely low.

If detention in the lagoon failed to lower the moisture con-
tent to the extent  originally anticipated, more time would
have to be  allowed.   If  more time were allowed,  the total
mass of PCBs volatilized would increase.

Water  Treatment.   The water  treatment system  would  use
existing technology and equipment shown to be effective  in
PCB removal.  The treatment plant would include a clearwell
for detention of  treated  effluent prior to  discharge.   PCB
concentrations in the  clearwell  would  be  monitored,  and  if
adequate removal  were  not  achieved,  the water could be re-
cycled through the  plant until  discharge  standards  (less
than 1 ppb PCBs)  were met.

Transportation.   Transportation would  be accomplished  using
dump trucks.  Failure  could  occur by loss  of material  from
the truck through leakage,  spilling  over  the top, dusting,
volatilization, or spills resulting from vehicle accidents.

The impact of leakage, dusting,   and volatilization would be
to disperse small amounts of PCBs all along the haul routes.
PD525.022                   6-45

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These types of  uncontrolled  release could be minimized  by
the use of tailgate seals and covers.

The impact of spills would be to deposit  a quantity  of PCB-
contaminated solids  at  one or more  isolated  points.  The
risk of spills over the top of the  truck  could  be  minimized
by use of a cover.   The risk  of  vehicle accidents  is rela-
tively small, but  it could be compensated for  by  having a
response plan and team ready during hauling.

Permit Requirements

Permit requirements are anticipated to include:

     •    USCOE Section 10 (dredging) permit

     •    USCOE Section 404 (disposal in waterways) permit

     •    IEPA  water quality certification  on all  USCOE
          permits

     •    Waukegan Port Authority dredging permit

     •    IEPA permit for  construction  of wastewater treat-
          ment facilities

     •    NPDES permit  (State/Federal) for point-source water
          discharge from the water treatment plant

     •    North Shore  Sanitary  District  approval  if water
          discharge goes to the sanitary  sewer

     •    IDOT  (Division  of  Waterways)  permit  for work  in
          public waterways

     •    IEPA  (Division  of  Land and Noise)   special waste
          hauler's permit

     •    City of Waukegan construction permits

     •    Local land use approval

     •    Certification of Authority to haul PCB commodities
          (ICC and I1CC)

     •    USEPA toxic substances disposal approval

     •    IEPA  approval  if material is disposed in  a cur-
          rently non-PCB approved site

See Mason & Hanger's  report  (003)  for further discussion of
applicable governmental regulations.
PD525.022                   6-46

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UPPER HARBOR

Alternative 2B:  Dredge-Dewater in Lagoon-Fix-Dispose

Response Objective

This alternative would  remove  all sediments from the Upper
Harbor with PCB  concentrations greater than 50 ppm.  If  a
95 percent removal efficiency were achieved, it would remove
an estimated  4,800  Ib of PCBs  contained  in approximately
35,700 yd3 of sediments.  This would remove about 1.5 percent
of all the PCBs now found in the Slip No. 3 and Upper Harbor
area (003).

Assuming that exposed sediment PCB concentrations are reduced
below 50 ppm in the harbor, peak water column concentrations
of PCBs are expected  to be reduced to  0.1 ppb and  fish  body
burdens are expected  to decline to less than 5 ppm  (035) .
(If the Upper  Harbor  were remedied without remedying Slip
No. 3,  this would not be true.)  Removal would also diminish
the existing estimated volatilization rate of 12 to 40 Ib/yr
of PCBs that  are released from the harbor  into the local
airshed by approximately an order of magnitude  (007).

All former land and water uses would be able to resume after
cleanup-activities are completed.  No restrictions to future
uses would be expected.

Duration of Cleanup Activities

Dredging and related  activities of the Upper Harbor would
require about 3 months.   (This  would be  in  addition to  the
4 months required for the dredging and related activities of
Slip No.  3.)   If the water treatment plant were not protected
against freezing weather, the dewatering lagoon would not be
able to release  slurry  water to the plant  during  freezing
conditions.  Dredging would  then  have  to  occur  during non-
freezing weather.

Solids removal to the batch plant would begin about 2 months
after dredging activities are  completed.  Removal  and fixa-
tion of the dewatered sediments would require 2 to 3 months.
Offsite transportation to the disposal site would be concur-
rent with the  fixation  process.   Total project  duration is
estimated to be 13 months.

Impacts and Mitigation of Cleanup Activities

Dredging.   Roiling of bottom sediments during dredging results
in sediment suspension and dispersion.   The use of a hydraulic
dredge and the proper dredge head would minimize roiling and
sediment dispersion.  A sediment dispersal control  system
(double silt curtain  or steel  sheet piling) would also be
PD525.022                   6-47

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employed  to minimize migration of suspended PCBs out of the
dredging area.  To assist in controlling sediment dispersion,
water would be continually pumped from inside the Upper Harbor
during construction to maintain net inflow at the Upper Harbor
mouth.  This would tend to keep  sediments  from  crossing  the
control barrier.  The water could be treated by  addition of
polymer and/or activated carbon  before  the sediment  barrier
is removed.

A program would be established to monitor  the effectiveness
of the containment measures and to warn of the need for poly-
mer addition or shutdown of dredging.   A seiche  warning  ar-
rangement with the National Weather Service would also  be
put in place  so  operations  could be suspended if a  seiche
were  imminent.  The  containment  devices would be the  most
likely to fail during a seiche due  to the  forces created by
a sudden difference in water level  between the  two sides of
the sheet piling or double silt curtain.

The City of Waukegan maintains an emergency water intake in
Waukegan Harbor.  This water intake, while an integral part
of the Waukegan Harbor system,  is  rarely used.  Project
activities would  be  expected  to be completed  while the
intake was not in use.  If, however,  the  intake was  needed
during project activities, a monitoring program, including
sampling of  raw and  finished water, would be established
during the project to  ensure  the safety of the  supply.   A
contingency plan would also be  established to stop project
operations if any contamination entered the system.

Larsen Marine Services would be  adversely affected by any
dredging that  inhibited  or cut  off access to  its docks.
These impacts would be short-term and could be  minimized by
scheduling dredging  during periods  that  would  cause  the
least impact on Larsen Marine Services.

Minimal volatilization would  be expected  to  occur  during
dredging activities.   Losses would be expected to be roughly
0.3 to 0.4 Ib/day/acre from the  exposed, agitated, and con-
taminated water  area (030) .   Concentrations  of less than
2 ug/m3 would be expected to be  present in the  air as  a  re-
sult  of dredging activities (007).  By  comparison, the OSHA
standard for  maximum worker exposure to  Aroclor 1242 is
1,000 ug/m3 in the air at  any  time.  However, NIOSH recom-
mends that workers not be  exposed to more than  1 ug/m3  in
the air during  an 8-hour period (007).   (See Health  and
Safety Requirements,  later in this  section.)

The proposed dredging would affect terrestrial biota.  Popula-
tions of gulls  and terns  that  currently reside  and feed in
the vicinity of the  harbor would be disturbed by increased
noise and activity levels and may move  to  another area along
the shoreline of Lake Michigan during the  times of the  day
PD525.022                   6-48

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when disturbances  would occur.  However,  because  none of
these species breeds in the immediate vicinity of the harbor,
no long-term displacement of populations is anticipated (048) .

Some species of birds or other animals could come into contact
with the contaminated sediments and water  in  the harbor and
dewatering  lagoon,  particularly during  non-working hours
(gulls)  and autumn  migration  periods  (waterfowl and shore-
birds)   (048^ .

Changes in  the  harbor water column PCB  concentrations and
reduced PCB accumulations in fish would be the two principal
long-term beneficial impacts of dredging.

Possible short-term adverse impacts of dredging would include
the following:

     •    The area  inside the  sediment  dispersal  control
          device used to detain roiled sediments would become
          turbid during dredging and would very likely become
          anoxic in  the pre-dawn  hours following a  day of
          dredging in organic "muck" sediments.  Indications
          are that  "disturbances"  of  polluted bottom sedi-
          ments, especially if they have great quantities of
          reduced compounds dissolved in  the  intersticial
          waters, can-elevate the expression  of  sediment
          oxygen demand by as much as one order of magnitude.
          Diurnal rhythms  of  respiration/photosynthesis  in
          freshwater algae are  such  that the lowest oxygen
          levels occur  in pre-dawn hours.  Consequently,
          almost all  respiring organisms  inside  the silt
          curtains would  be  driven out or may die during
          early morning hours after dredging  (048).

     •    If dredging occurs  during the fall  and  spring,
          there is a  good  chance  that spawning fish may be
          present in the harbor during the dredging  activi-
          ties.   Chinook  making fall  runs may  be  able to
          swim around or leap over the silt curtains into  a
          highly PCB-laden body of water (048).

Dewatering.  Construction of a dewatering  lagoon and treat-
ment facilities on OMC property or another nearby site would
remove this land  from other  uses  for the  duration  of the
project.

The lagoon would be constructed with impermeable clay liners
and a leachate  collection  system.   The  groundwater beneath
the lagoon would be monitored by test wells to detect leakage
from the lagoon.

Some volatilization of  PCBs would  occur  during dewatering.
Volatilization would be minimized  during initial  placement
PD525.022                   6-49

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of the dredged sediments by the decanting water layer.  This
might reduce the  estimated  volatilization rate from 1.4 Ib
PCBs per day (for exposed sediments with a typical concentra-
tion of  100 ppm)  to  less  than 1 Ib PCBs per day  from  less
contaminated decanting water layer  (007, 030).  Other measures
that could be  employed  include:   (1)  placing the less con-
taminated sediments on top of the more contaminated sediments
during dredging;  (2) placing a layer  of  an  organic  material
(e.g., digested activated sludge, manure) on  top  of the  de-
watering sediments upon completion of dredging; or  (3) plac-
ing a synthetic liner on top of the water in the  lagoon dur-
ing and  following dredging.  These measures would be expected
to keep  PCB  concentrations  in the air above  the  lagoon  at
about 2 ug/m3  (007).

Water Treatment.   All PCB-contaminated  water  (supernatant
from  initial  solids dewatering,  leachate,  rainwater, and
monitoring well water collected from the lagoon) would  be
processed through a package water treatment plant.  All water
would be  treated  to PCB levels of  below 1  ppb (the USEPA
standard).  Treatment plant effluent  would  be  monitored  (by
grab sampling and 24-hour sampling) to ensure that discharges
were below 1 ppb.  An onsite  laboratory would be available
to conduct the water quality analyses.   Effluent would  be
discharged to the harbor or to a sanitary sewer.  Water dis-
charged  to the sanitary sewer system would be processed again
through  the  Waukegan municipal wastewater  treatment  plant
and discharged into the Des Plaines River.

Solids  Removal,  Fixation,  and Disposal.   Volatilization
would be  expected to occur during solids removal from the
lagoon and truck  loading  for  transport to the batch plant.
The highest reported concentration in Upper Harbor  sediments
is about 500 ppm PCBs.  The maximum predicted PCB concentra-
tion in  the  air from solids removal operations is predicted
to be less than 6.6 ug/m3.  Typical PCB  concentrations range
from about 50  to  500 ppm PCBs.   Average PCB concentrations
in the air are expected to  be  less  than  1.0 ug/m3 for sedi-
ments with  concentrations  of  100 ppm PCBs  (007) .   These
values were extrapolated from data for sand, assuming  3.6-mph
wind  and an  air temperature  of  68°F.  The volatilization
rate from Waukegan Harbor muck should be  less than  from sand
(007).

Dewatered sediment would  be fixed into  a nonflowable  form
for offsite transport by truck.  A sufficient amount of fixing
agent would be used to prevent water  loss,  and covers may be
required to prevent  volatilization  during transport.   Rules
and regulations controlling the transport of hazardous mate-
rials promulgated by the USDOT, USEPA, IDOT, IINK,  and other
applicable regulatory agencies would  be  complied  with.  These
include  cleanup,  safety,  and  spill prevention and  response
measures.
PD525.022                   6-50

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Offsite disposal of fixed dredged  sediments,  volatilization
material, and  liner material would  require approximately
8,220 truck trips to the disposal  site using  a  10-yd3  capa-
city truck.  The  established full truck routes within  the
City of  Waukegan  have sufficient  capacity  to accommodate
the estimated truck traffic, but some roadway congestion and
roadway damage could occur  (048).   Some  species of terres-
trial animals  could come into  contact with  contaminated
materials if any loss occurs during transport,  and  the  con-
tamination could be passed into other terrestrial food chains
(048) .

Disposal of the materials would be in a licensed  chemical
waste landfill, and would be in compliance with State  and
Federal  standards  for  PCB waste disposal.   PCB materials
with concentrations greater than 50 ppm must  be nonflowable
if they  are to be  disposed  of  in a chemical waste landfill
(40 CFR 761).   Solids  dewatering and/or fixation  must be
complete enough to result in a nonflowable consistency after
transport for final disposal.

Additional Environmental  Impacts.   Implementation of  this
alternative would also have the following impacts  (048):

     Noise.   Noise would be produced by construction, dredg-
     ing, and transportation activities.   Although high noise
     levels could  periodically  occur  in  localized areas,
     they would be of relatively short duration.   Noise  im-
     pacts could temporarily diminish  people's  enjoyment of
     the public beach adjacent to the project area.

     Employment.   Construction  jobs  created by  the project
     would temporarily  reduce   unemployment  in  the  area.
     Employment levels would return to previous levels  at
     the conclusion of the project.

     Recreation.   The noise and traffic congestion associated
     with construction activities could have short-term nega-
     tive impacts on the public beach adjacent to the project
     area.

     The City of  Waukegan uses the  site proposed  for the
     dewatering lagoon as a parking area for its public fes-
     tivals.   This alternative  would  preclude this use for
     the project duration.  The  city  would  have to arrange
     other transportation means (such as a shuttle  system
     between the  downtown area  and the beach)  because no
     alternative parking facilities are available.

     Cultural Resources.   Cultural resources in the Waukegan
     Harbor area would  not  be   adversely affected.   It is
     possible that the cleanup  of PCB-contaminated sediments
PD525.022                   6-51

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     ^^rould enhance the desirability of acquiring and retaining
     cultural resources in the harbor area.

Health and Safety Requirements.  The PCB-contaminated  soil,
sediment, muck, dust, and water associated with cleanup  ac-
tivities present potentially  significant  health hazards to
workers involved in the cleanup.  Each specific cleanup  ac-
tivity and associated work function would require the defini-
tion and  enforcement of  specific  safety  precautions  and
levels of protection.   Ecology and Environment, Inc.,  has
prepared a conceptual safety plan  (see Appendix).   The  plan
calls for protection measures for workers who may be exposed
to PCB-contaminated materials.  Ambient air monitoring would
be performed, and all workers would require appropriate levels
of protection.  Depending on ambient air monitoring results,
respiratory and dermal  protection  may  be  required downwind
of site cleanup activities and the dewatering  lagoons.   In
addition to personal protection, the conceptual safety  plan
specifies site entry procedures, decontamination procedures,
work limitations,  and material disposal  requirements.   A
detailed health and  safety plan would be prepared during
final design of the selected response measures.

Reliability

Dredging.  Hydraulic  dredges  have  been widely used  in  the
past for dredging.  No new technologies are proposed to com-
plete the dredging.  Dredging  technology  is  well  developed,
and the  reliability  of the equipment  to  remove sediments
from the Upper Harbor  and transport  them  to the lagoons is
high.  If a stoppage  of the  hydraulic  dredge occurs during
dredging, it  is expected  to  result in  some temporary addi-
tional suspension of sediment in the water column because of
interruption  in hydraulic  flow.  Leakage  or rupture of the
hydraulic dredge discharge pipeline could disperse PCB-laden
water and sediment over previously uncontaminated areas along
the pipeline.  The impact of such  spills  could be  minimized
by prompt cleanup of the spilled material and of any soil or
other material that was contaminated by the spill.  A contin-
gency plan would be established for prompt cleanup.  Leakage
could either  be eliminated by pipe joint tightening or  be
controlled by  joint  caulking,  mats,  collection containers,
or similar means.   The collected solids could be disposed of
with the PCB-contaminated  solids,  and  collected water  could
be taken to the water treatment plant.

Dewatering Lagoon and Curing Cells.  The  technology for con-
struction of  lined lagoons  is  well developed and feasible.
There are no  unusual construction details  for the lagoon
construction.  Construction could be accomplished using con-
ventionally available materials and equipment.  The risk of
failure would be low.   If  the  upper clay  liner failed,  con-
taminated leachate could be collected by  the underdrain system.
PD525.022                   6-52

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If the lower clay liner also failed, contaminated soil would
have to be excavated and disposed of with the other contami-
nated solids.

If an  exterior  lagoon dike failed, PCB-contaminated  water
and sediment could  flow over a large area,  requiring sub-
stantial cleanup  operations  and causing greatly  increased
volatilization.    The  technology for dike  design is  well
understood,  however,  so the probability of dike  failure
would be extremely low.

If an  exterior  curing cell dike  failed while a cell was
filled with incompletely cured fixed solids, PCB-contaminated
water and  sediment  could  flow  over a small area, requiring
cleanup operations and  causing  slightly increased  volatili-
zation.  The technology for dike  design is  well  understood,
however, so  the  probability  of dike failure  would  be ex-
tremely low.

If detention in the lagoon failed to lower the moisture con-
tent to the  extent originally anticipated,  either more time
could be allowed  or  more fixing agent  could be  used.  If
more time  were allowed,  the  total mass  of PCBs volatilized
would increase.    If more  fixing  agent were  used, the total
solids volume to disposed of would increase.

Water Treatment.   The water treatment system would use exist-
ing technology and  equipment  shown to be effective in PCB
removal.   The treatment plant would include  a  clearwell  for
detention  of treated effluent prior to  discharge.   PCB con-
centrations in the clearwell would be monitored,  and  if ade-
quate removal were not achieved, the water could be recycled
through the plant until discharge standards  (less than 1 ppb
PCBs)  were met.

Fixation.  Fixation would use existing equipment in an appli-
cation similar to previous applications, but  not yet  estab-
lished for these high-moisture-content sediments.  Laboratory
testing is now being  conducted  to verify that fixation can
be accomplished with existing available materials and equip-
ment.   It  is anticipated  that  fixation  will prove to be a
technically feasible and reliable means  of controlling water
loss.   If  fixation failed to prevent water loss,  then solids
would have to be dewatered mechanically as proposed for Alter-
native 3,  or a waiver from that requirement  of  40  CFR 761
would have to be  obtained  from  the USEPA Regional Adminis-
trator.

Transportation.   Transportation would be accomplished using
dump trucks.  Failure  could occur  by  loss  of material from
the truck  through leakage, spilling  over the top,  dusting,
volatilization,  or spills resulting from vehicle  accidents.
PD525.022                   6-53

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The impact of leakage, dusting, and volatilization would  be
to disperse small amounts of PCBs all along the haul routes.
These types of  uncontrolled release could be minimized by
the use of tailgate seals and covers.

The impact of spills would  be to deposit a quantity  of PCB-
contaminated solids  at  one or more isolated  points.  The
risk of spills over the top of the truck could be minimized
by use of a cover.   The  risk  of  vehicle accidents  is rela-
tively small, but  it could be compensated for by having  a
response plan and team ready during hauling.

Permit Requirements

Permit requirements are anticipated to include:

     •    USCOE Section 10  (dredging)  permit

     •    USCOE Section 404 (disposal in waterways)  permit

     •    IEPA  water quality certification  on all  USCOE
          permits

     •    NPDES  permit   (State/Federal)  for  point-source
          water discharge from the water treatment plant

     •    Waukegan Port Authority dredging permit

     •    IEPA permit for  construction  of wastewater treat-
          ment facilities

     •    North Shore Sanitary  District approval if water
          discharge goes to a sanitary sewer

     •    IDOT  (Division  of Waterways)  permit for work  in
          public waterways

     •    IEPA  (Division  of Land and Noise)   special waste
          hauler's permit

     •    City of Waukegan  construction permits

     •    Local land use approval

     •    Certification of Authority to haul PCS commodities
           (ICC and I1CC)

     •    USEPA toxic substances disposal approval

     •    IEPA  approval  if material is disposed in  a cur-
          rently non-PCB approved site
PD525.022                   6-54

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See Mason & Hanger's report  (003)  for  further  discussion  of
applicable governmental regulations.

Alternative 3:   Dredge-Dewater in Lagoon-Dispose

Response Objectives

This alternative would  remove  all  sediments from the Upper
Harbor with PCB  concentrations greater than 50 ppm.  Jf  a
95 percent removal efficiency were achieved, it would remove
an estimated 4,800 Ib  of PCBs  contained  in approximately
35,700 yd3 of  sediments.  This would remove about 1.5 per-
cent of all the  PCBs now  found in  the Slip No. 3 and Upper
Harbor area (003) .

Assuming that  exposed  sediment PCB concentrations are  re-
duced below 50 ppm in the harbor,  peak water column  concen-
trations of PCBs are expected  to be reduced to 0.1 ppb and
fish body burdens are expected to decline to less than 5 ppm
(035).  (If the Upper Harbor were remedied without remedying
Slip No. 3, this  would not  be true.)  Removal would also
diminish the existing estimated volatilization rate of 12 to
40 Ib/yr of PCBs that are released  from the harbor into the
local airshed by approximately an order of magnitude  (007).

All former land and water uses would be able to resume after
cleanup activities are completed.  No restrictions to future
uses would be expected.

Duration of Cleanup Activities

Dredging and related activities  for the  Upper  Harbor would
require about 3 months.   (This is in addition to the 4 months
required for the  dredging and related activities  of Slip
No. 3.)  If the water treatment plant were not protected
against freezing weather, the  dewatering lagoon could  not
release slurry water to the  plant during freezing conditions.
Dredging would then have to  occur during nonfreezing weather.

Because dredged solids  would not be fixed,  they would have
to be dewatered in the  lagoon  for  an extended  time to reach
an adequate nonflowable consistency for disposal.  Even with
the employment of  additional mechanical dewatering  (RUC),
retention time  is expected to be from 1 to 2 years.

Offsite transportation to the disposal site would begin ap-
proximately 3  to 4 months  after completion of  dredging.
Transportation  would continue  intermittently until project
completion.   Total project  duration  is  estimated to be
3  years.
PD525.022                   6-55

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Impacts and Mitigation of Cleanup Activities

Dredging.  Roiling of bottom sediments during dredging results
in sediment suspension and dispersion.  The use of a hydraulic
dredge and the proper dredge head would minimize roiling and
sediment dispersion.  A  sediment dispersal control  system
(double silt curtain  or  steel  sheet piling) would also be
employed to minimize migration of suspended PCBs out of the
dredging area.  To assist in controlling sediment dispersion,
water would be continually pumped from inside the Upper Harbor
during construction to maintain net inflow at the Upper Harbor
mouth.  This would tend to keep  sediments  from  crossing the
control barrier.  The water could be  treated by addition  of
polymer and/or activated carbon  before the  sediment  barrier
is removed.

A program would be established to monitor  the  effectiveness
of the containment measures and to warn of the need for poly-
mer addition  or shutdown of dredging.   A  seiche  warning
arrangement with the  National Weather Service  would  also  be
put in place  so  operations  could be  suspended  if  a  seiche
were  imminent.   The  containment  devices would  be  the  most
likely to fail during a seiche due  to the  forces created  by
a sudden difference in water level  between  the  two sides  of
the sheet piling or double silt curtain.

The City of Waukegan  maintains an emergency water  intake  in
Waukegan Harbor.  This water intake,  while  an  integral part
of the  Waukegan Harbor system,  is  rarely  used.   Project
activities would be  expected  to be  completed  while the
intake was not  in  use.   If,  however,  the intake was needed
during project  activities,  a monitoring program, including
sampling of  raw and  finished water,  would be established
during the project  to ensure  the safety of the  supply.   A
contingency plan would also  be established to stop project
operations if any contamination entered the system.

Larsen Marine Services would be  adversely  affected  by any
dredging that inhibited  or cut  off access to  its  docks.
These impacts would be short-term and could be minimized  by
scheduling dredging  during periods that  would cause  the
least impact on Larsen Marine Services.

Minimal volatilization would be  expected  to  occur during
dredging activities.  Losses would be expected to be roughly
0.3 to 0.4 Ib/day/acre from the  exposed, agitated,  and con-
taminated water  area (030) .  Concentrations  of less than
2 ug/m3 would be expected to be present  in the air as a
result of  dredging activities (007) .   By  comparison,  the
OSHA  standard for maximum worker exposure to Aroclor 1242 is
1,000 ug/m3 in  the  air at any  time.  However, NIOSH recom-
mends that workers  not be exposed to more  than  1  ug/m3 in
the air  during  an 8-hour  period (007) .    (See  Health  and
Safety Requirements,  later in this  section.)
PD525.022                   6-56

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The proposed dredging would affect terrestrial biota.  Popula-
tions of gulls  and  terns  that currently reside and feed in
the vicinity of the  harbor  would be disturbed by increased
noise and activity levels and may move to another area along
the shoreline of Lake Michigan  during  the  times of the day
when disturbances would occur.   However,  because  none of
these species breeds in the immediate vicinity of the harbor,
no long-term displacement of populations is anticipated (048) .

Some species of birds or other animals could come into contact
with the contaminated sediments  and water  in  the harbor and
dewatering  lagoon,  particularly during  non-working hours
(gulls)  and autumn  migration  periods  (waterfowl and shore-
birds)   (048) .

Changes in  the  harbor water column PCB  concentrations and
reduced PCB accumulations in fish would be the two principal
long-term beneficial impacts of dredging.

Possible short-term adverse impacts of dredging would include
the following:

     •    The area  inside the  sediment  dispersal  control
          device used to detain roiled sediments would become
          turbid during dredging and would very likely become
          anoxic in  the pre-dawn hours following a day of
          dredging in organic "muck" sediments.  Indications
          are that  "disturbances"  of  polluted bottom sedi-
          ments, especially if they have great quantities of
          reduced compounds  dissolved  in the  intersticial
          waters, can  elevate the  expression  of sediment
          oxygen demand by as much as one order of magnitude.
          Diurnal rhythms of  respiration/photosynthesis  in
          freshwater algae  are  such that the lowest oxygen
          levels occur  in pre-dawn hours.   Consequently,
          almost all  respiring  organisms  inside the  silt
          curtains would  be driven out or may die during
          early morning hours after dredging  (048).

     •    If dredging occurs  during the fall  and  spring,
          there is a good chance that  spawning fish may be
          present in the harbor  during the dredging activi-
          ties.   Chinook  making fall  runs may  be  able to
          swim around or leap over the silt curtains into  a
          highly PCB-laden body of water (048).

Dewatering.   Construction of a dewatering  lagoon and treat-
ment facilities on OMC property or another nearby site would
remove this land  from  other uses for the  duration  of  the
project.

The lagoon would be  constructed with impermeable clay liners
and a leachate  collection system.   The  groundwater beneath
PD525.022                   6-57

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the lagoon would be monitored by test wells to detect leakage
from the lagoon.

Under this alternative, volatilization would be significantly
increased during retention of  the  dredged materials in the
lagoon because mechanical dewatering would be employed.  The
RUG system  (or  other channelization  techniques)  would be
used to channel the sediments for drainage of water to expose
them to air for evaporation and drying.  After the top layer
was dried,  it  would be removed and  the  process repeated.
This would  result  in substantially more  volatilization  of
PCBs to the atmosphere than for Alternative 2B, since evapora-
tion is  a  necessary part of the dewatering  process.   The
highest reported concentration in  Upper  Harbor  sediments is
about 500 ppm PCS.  The maximum predicted PCB  concentration
in air above these  sediments would be less than 6.6 ug/m3,
well below 1,000 ug/m3, the OSHA standard.  The volatiliza-
tion rate  is predicted  to  be less  than 5,375 ug/m2/hr.
Typical concentrations are about 50  to 500 ppm.  Predicted
average PCB  concentrations  in  the air would  be less than
1.0 ug/m3.  The average volatilization rate  is expected to
be about 725 ug/m2/hr  or  1.4 Ib/day  of PCBs.   These values
were extrapolated from data for sand, assuming  a  wind  speed
of 3.6-mph and  an air  temperature  of  68°F.  The volatiliza-
tion rate from Waukegan Harbor muck should be less than  from
sand (007).

Because this alternative would require more time  for  solids
dewatering, it  would restrict  land uses  on the  OMC  property
or other nearby site used for the  lagoon  for a longer period
than Alternative 2B.   It would, however,  involve  less  total
property use, since it would not require  land  for the  fixa-
tion process.

Water Treatment.   All  PCB-contaminated water  (supernatant
from initial  solids dewatering, leachate,  rainwater,  and
monitoring well water  collected  from the  lagoon)  would  be
processed through a package water  treatment plant.  All water
would be treated  to PCB levels of below 1 ppb (the USEPA
standard).  Treatment  plant effluent  would be  monitored  (by
grab sampling and 24-hour sampling) to ensure that discharges
were below  1 ppb.   An  onsite  laboratory  would be available
to  conduct  water  quality analyses.   Effluent would  be
discharged  to  the harbor or to  a  sanitary sewer.   Water
discharged to the  sanitary  sewer  system  would be processed
again through  the Waukegan municipal wastewater  treatment
plant and discharged into the Des  Plaines River.

Solids Removal  and Disposal.  Volatilization would be expec-
ted to occur during solids removal from the lagoon and truck
loading for offsite transport.  The highest reported concen-
tration in Upper Harbor sediments  is  about 500 ppm PCB.  The
PD525.022                   6-58

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maximum predicted PCB concentration in air above these sedi-
ments would be  less  than  6.6  ug/m3, well  below 1,000  ug/m3,
the OSHA standard.   The volatilization rate  is predicted to
be  less  than 5,375  ug/m2/hr.   Typical  concentrations are
about 50 to  500 ppm.  Predicted average  PCB concentrations
in  the air would be  less  than 1.0 ug/m3  for sediments with
concentrations  of 100 ppm PCBs.   The  average volatilization
rate is expected to  be  about 725 ug/m2/hr or  1.4 Ib/day of
PCBs.  These values  were  extrapolated from  data for  sand,
assuming a wind speed  of  3.6-mph and  an  air temperature of
68°F.  The volatilization rate  from  Waukegan Harbor muck
should be less  than  from  sand  (007).   Increased concentra-
tions of PCBs may result  in the  air  from PCB-contaminated
dust produced by excavation activities,  since these solids
will be dry and  dusty.

Additional precautions  would be  required during  offsite
transportation  of the non-fixed  materials.   Trucks would
have to employ  a  liner  (such as heavy-duty plastic sheeting)
to  prevent leakage  or spillage.  Cover or  closure of the
trucks would be required  to prevent  spillage  and volatili-
zation during transport.  Rules and regulations  controlling
the transport of toxic  materials promulgated by the USDOT,
USEPA, IDOT,  IINR, and  other  applicable regulatory agencies
would be complied with.   These  include cleanup,  safety,  and
spill prevention and response measures.

Offsite disposal of  fixed dredged sediments  and liner material
would require approximately 6,110 truck  trips to  the  dis-
posal site using a  10-yd3  capacity truck.  The established
full truck routes within the City of Waukegan  have sufficient
capacity to  accommodate the estimated truck traffic, but
some roadway congestion and roadway damage could occur (048).
Some species of terrestrial  animals could come into  contact
with contaminated materials if  any loss occurs during trans-
port, and the contamination  could be  passed  into other ter-
restrial food chains (048).

Disposal of the materials would be in a  licensed  chemical
waste landfill,  and  would be in  compliance  with State and
Federal standards  for  PCB waste  disposal.   PCB materials
with concentrations  greater than  50 ppm must be  nonflowable
if  they are to  be disposed  of in a chemical waste landfill
(40 CFR 761).   Solids dewatering  must be  complete  enough to
result in a nonflowable consistency after transport to the
final disposal  site.  If a nonflowable consistency cannot be
obtained,  fixation will be required.

Additional Environmental  Impacts.  Implementation of  this
alternative would also have the following impacts  (048):

     Noise.   Noise would be produced by construction, dredg-
     ing,  and transportation activities.   Although high noise
PD525.022                   6-59

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     levels could  periodically  occur in  localized  areas,
     they would be of relatively short duration.  Noise im-
     pacts could temporarily diminish people's enjoyment  of
     the public beach adjacent to the project area.

     Employment.  Construction jobs  created  by  the  project
     would temporarily  reduce unemployment  in  the  area.
     Employment levels would  return  to  previous levels at
     the conclusion of the project.

     Recreation.  The noise and traffic  congestion associated
     with construction activities could  have short-term nega-
     tive impacts on the public beach adjacent to the project
     area.

     The City  of  Waukegan uses the  site  proposed for the
     dewatering lagoon as a parking area for its public fes-
     tivals.   This alternative would preclude this  use for
     the project duration.  The  city would  have to  arrange
     other transportation  means  (such as a  shuttle system
     between  the  downtown  area and  the  beach)  because no
     alternative parking facilities are  available.

     Cultural Resources.  Cultural resources in the  Waukegan
     Harbor area  would  not be adversely  affected.   It is
     possible that the cleanup of PCB-contaminated sediments
     would enhance the desirability of acquiring and retaining
     cultural resources in the harbor area.

Health and Safety  Requirements.  The PCB-contaminated  soil,
sediment, muck, dust, and water associated with  cleanup ac-
tivities present  potentially  significant health hazards to
workers involved in the cleanup.  Each specific  cleanup ac-
tivity and associated work function would require the defini-
tion and  enforcement of  specific  safety precautions  and
levels of  protection.   Ecology and  Environment, Inc.,  has
prepared a conceptual safety plan  (see Appendix).   The  plan
calls for protection measures for workers who may be exposed
to PCB-contaminated materials.  Ambient  air monitoring would
be performed, and all workers would  require appropriate levels
of protection.  Depending on ambient air monitoring results,
respiratory and dermal  protection  may be required downwind
of site cleanup activities and the holding lagoon.  In addi-
tion to personal protection, the conceptual safety plan speci-
fies site entry procedures, decontamination procedures, work
limitations,  and material disposal requirements.  A detailed
health and safety plan would be prepared during  final design
of the selected response measures.

Reliability

Dredging.  Hydraulic  dredges  have been  widely used in  the
past for  dredging.  No new  technologies are proposed  to
PD525.022                   6-60

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complete the dredging.  Dredging technology is well developed,
and the  reliability  of the equipment  to  remove sediments
from the Upper Harbor  and  transport  them  to the lagoons is
high.  If a  stoppage  of the hydraulic dredge occurs during
dredging, it is expected to result in some temporary addi-
tional suspension of sediment in the water column because of
interruption in hydraulic  flow.   Leakage  or rupture of the
hydraulic dredge discharge pipeline could disperse PCB-laden
water and sediment over previously uncontaminated areas along
the pipeline.  The impact  of  such  spills  could  be  minimized
by prompt cleanup of the spilled material and of any soil or
other material that was contaminated by the spill.  A con-
tingency plan would be established for prompt cleanup.  Leak-
age could either be eliminated  by pipe joint tightening or
be controlled by joint caulking, mats, collection containers,
or similar means.  The collected solids could be disposed of
with the PCB-contaminated  solids,  and  collected  water  could
be taken to the water treatment plant.

Dewatering Lagoon.   The technology for construction of lined
lagoons is well developed and feasible.  There are no unusual
construction details for the lagoon construction.  Construc-
tion could be  accomplished using  conventionally available
materials and equipment.  The risk of  failure would  be  low.
If the upper clay liner failed,  contaminated  leachate  could
be collected by  the underdrain  system.  If the  lower  clay
liner also failed,  contaminated soil would have  to be excava-
ted and disposed of with the other contaminated  solids.

If an  exterior  lagoon  failed,  PCB-contaminated  water and
sediment could flow over a  very large area, requiring sub-
stantial cleanup operations and causing greatly increased
volatilization.   The  technology for  dike  design is v/ell
understood,   however,  so the  probability  of dike  failure
would be extremely low.

If detention in the lagoon failed to lower the moisture con-
tent to the  extent originally anticipated,  more time would
have to be allowed.   If more time were allowed, the  total
mass of PCBs volatilized would increase.

Water Treatment.   The water treatment system would use exist-
ing technology and equipment  shown to be effective  in  PCB
removal.   The treatment plant would  include a clearwell  for
detention of treated effluent prior to discharge.  PCB  con-
centrations   in the  clearwell would  be monitored,  and  if
adequate removal were not  achieved,  the water could be re-
cycled through the  plant until  discharge  standards (less
than 1 ppb PCBs)  were met.

Transportation.   Transportation would  be  accomplished  using
dump trucks.   Failure could occur  by  loss  of  material from
PD525.022                   6-61

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the truck through leakage,  spilling  over  the top,  dusting,
volatilization, or spills resulting from vehicle accidents.

The impact of leakage, dusting, and volatilization would  be
to disperse small amounts of PCBs all along the haul routes.
These types of  uncontrolled release  could be minimized by
the use of tailgate seals and covers.

The impact of spills would be to deposit  a quantity of PCB-
contaminated solids  at  one or more  isolated points.   The
risk of spills over the top of the truck  could  be minimized
by use of a cover.   The  risk of  vehicle accidents  is rela-
tively small, but it  could be compensated for by having  a
response plan and team ready during hauling.

Permit Requirements

Permit requirements are anticipated to include:

     •    USCOE Section 10  (dredging) permit

     •    USCOE Section 404  (disposal in waterway)  permit

     •    IEPA  water  quality certification  on all  USCOE
          permits

     •    Waukegan Port Authority dredging permit

     •    IEPA permit for  construction  of wastewater  treat-
          ment facilities

     •    NPDES  permit   (State/Federal)  for  point-source
          water discharge  from the water treatment plant

     •    North  Shore Sanitary  District approval if  water
          discharge goes to a sanitary sewer

     •    IDOT  (Division  of Waterways)  permit  for work  in
          public waterways

     •    IEPA  (Division  of Land and Noise)   special  waste
          hauler's permit

     •    City of Waukegan construction permits

     •    Local land use approval

     •    Certification of Authority to haul PCB commodities
           (ICC and I1CC)

     •    USEPA toxic substances disposal approval

     •    IEPA  approval  if material  is disposed in a cur-
          rently non-PCB-approved site
PD525.022                   6-62

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See Mason & Hanger's report  (003) for  further  discussion  of
applicable governmental regulations.

SLIP NO. 3 AND UPPER HARBOR

Alternative 6A;  Contain-Dredge-Cap

Response Objectives

Under this alternative, a cofferdam would be constructed near
the north end  of  the  Upper Harbor to close off  Slip  No.  3
and the northwest portion of the Upper Harbor.  A slurry cut-
off wall would be constructed inside the cofferdam and around
the perimeter of the enclosed area to contain PCBs in-place.
The cutoff wall would extend into the glacial till to minimize
uncontrolled dispersion of PCBs into the groundwater.

A sediment dispersal control device, consisting of a double silt
curtain or sheet piling, would be installed at the south end
of the Upper Harbor.  Sediments with PCB concentrations greater
than 50 ppm would then be dredged from the rest of the Upper
Harbor and placed within the containment area.  This alternative
would control almost 100 percent of all the PCBs now found in
Slip No. 3 and the Upper Harbor area.  If a 95 percent removal
efficiency were achieved,  this  would transfer an estimated
4,400 Ib of  PCBs  contained in approximately 33,500 yd3 of
sediments from the Upper Harbor to the containment area.

Dredged sediments would be  dewatered,  with the supernatant
processed through  a package water treatment  plant  to PCB
levels below 1 ppb.  The contained area would be capped with
impermeable materials to seal in the contaminated materials.

Based on Mason & Hanger's equation for calculation of disper-
sion of PCBs (001), migration_through a 2-ft slurry wall with
an overall permeability of  10~7 cm/sec would be  expected  to
take 2 years, dispersing about 0.001 Ib/yr PCBs.  If the slurry
wall were cracked by the fluctuating water table, freezing,  or
other natural phenomena, PCBs could escape at a higher rate.
Groundwater monitoring wells would be constructed to provide
continuous checks on the efficiency of the slurry wall.  The
State would be required to provide maintenance under PL 96-510.

Using Mason  &  Hanger's  equation (001),  migration through  a
1-ft-thick layer of glacial till with an overall permeability
of 10"7 cm/sec would be expected to  take  1 year,  dispersing
about 0.008 Ib/yr PCBs.  If sandy zones were encountered  in
the glacial till,  PCBs could escape at a higher rate.  Ground-
water monitoring wells would be constructed to provide contin-
uous checks on the efficiency of the glacial till.  The State
would be required to provide maintenance under PL 96-510.

The site would be capped with impermeable materials to  seal
in the contaminated soils.   Capping would reduce percolation
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into the  contaminated  area.   Future construction projects
that would cause disturbance  to  the surface and underlying
soils (trenching, drilling, digging, etc.) would not be al-
lowed,  to minimize deterioration of the impermeable barriers.

Containment and capping would reduce the environmental hazards
now posed by PCB contamination in the harbor.   All  contami-
nated sediments  in  Slip  No.  3 and the enclosed portion of
the Upper Harbor would be contained in-place, and 95 percent
removal efficiency of PCBs would be achieved in the rest  of
the Upper Harbor.   The  reliability  of the slurry wall and
capping technologies and  the  glacial  till is discussed in
the Reliability section below.

Containment of Slip No. 3 and the Upper Harbor in this manner
would require a USEPA waiver from the requirements of 40 CFR 761
of TSCA, since PCBs would remain in proximity to Lake Michigan
and in an area with a high groundwater table (058).

This alternative would have greater land use impacts than Slip
No. 3 and the Upper  Harbor alternatives.   Slip  No.  3  and a
portion of the Upper Harbor would no longer  exist and would
be converted into a parking lot.   Future uses of the new area
(and possibly use of some adjacent areas)  would be restricted
because soil-disturbing construction activities could not be
allowed.  A  new  basin  would be constructed  on  vacant OMC
property to  the  east of  Slip  No.  3.  Larsen  Marine  Services
would have to be relocated adjacent to the new basin.

Duration of Cleanup Activities

Cofferdam and slurry wall construction at the north end of the
Upper Harbor would  require about 3 months.  An additional
month would  be  required  for dredging in the Upper  Harbor.
If the water treatment plant were not protected against freez-
ing weather, the containment  area would not  be  able to re-
lease slurry water to the  plant during  freezing conditions.
Dredging would then have to occur during nonfreezing weather.

Surcharging would extend 6 to 12 months after dredging activities
are completed.  Removal of the surcharge and capping of the de-
watered sediments would require about 1 month.  Construction of
the new boat basin would require about 4 months, concurrent with
surcharging.  Total project duration is estimated to be 11 to
17 months.

Impacts and Mitigation of Cleanup Activities

Dredging.  Roiling of bottom sediments during dredging results
in sediment  suspension and dispersion.  The use of a hydraulic
dredge and the proper dredge head would minimize roiling and
sediment  dispersion.   A  sediment dispersal  control system
(double silt curtain or  steel sheet piling) would  also be
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employed to minimize migration of  suspended PCBs  out  of  the
dredging area.  To assist in controlling sediment dispersion,
water would be continually pumped  from  inside  the contained
area during construction to maintain net inflow at the south
end of the Upper Harbor.  This would tend  to keep sediments
from crossing the control barrier.  The water could be treated
by addition of polymer and/or activated carbon before the
sediment barrier is removed.

A program would be established to  monitor  the  effectiveness
of the containment measures and to warn of the need for polymer
addition or shutdown of dredging.  A seiche warning arrange-
ment with the National Weather Service  would also be  put in
place so operations could be suspended  if  a seiche were  im-
minent.  The containment devices would be the most likely to
fail during a seiche due  to  the  forces  created by a sudden
difference in water level between the two sides of the sheet
piling or double silt curtain.

The City of Waukegan maintains an  emergency water intake in
Waukegan Harbor.   This water intake, while an  integral part
of the  Waukegan  Harbor system,  is rarely used.   Project
activities would be expected to  be completed  while the in-
take was not  in  use.   If, however,  the intake was needed
during project activities,  a  monitoring program,  including
sampling of raw  and finished water, would be  established
during the project to  ensure  the safety of the supply.   A
contingency plan would also  be  established to  stop project
operations if any contamination entered the system.

Larsen Marine Services would be  seriously  affected by this
alternative.  Cofferdam construction would permanently cut
off access to its dock.  To prevent  further spread of PCBs,
the new boat  basin should not be  opened until the Upper
Harbor dredging  is  complete.   It  is estimated that  there
would be a  4-month  period during which neither Slip  No.  3
nor the new boat basin would be  available  for  Larsen  Marine
Services'  operations.   Temporary facilities would have to be
provided,  most probably on the east side of the Upper Harbor
south of the proposed boat basin.  In addition, a number of
Larsen Marine Services  docks  and service  facilities  would
have to be relocated.   The overall short-term impact on Larsen
Marine Services would be  greater for this  alternative than
for Alternatives 2B, 2D,  and 3.   This  could  be partially
offset by the long-term advantages that may accrue to Larsen
Marine Services,  since the new boat basin  geometry could  be
designed to improve water accessibility.

Minimal volatilization would  be expected  to  occur during
dredging activities.   Losses would be expected to be roughly
0.3 to 0.4 Ib/day/acre from the exposed, agitated, and con-
taminated water  area  (030) .   Concentrations of  less  than
2 ug/m3 would be expected  to be present in the air as  a
result of dredging  activities (007).   By  comparison,  the
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OSHA standard for maximum worker exposure to Aroclor 1242 is
1,000 ug/m3 in the air at  any  time.   However,  NIOSH recom-
mends that workers not be  exposed to more than 1 ug/m3  in
the air  during  an 8-hour  period  (007) .   (See Health  and
Safety Requirements,  later in this section.)

The proposed dredging would affect terrestrial biota.  Popula-
tions of gulls and terns that  currently  reside and feed in
the vicinity of the harbor would  be  disturbed by increased
noise and activity levels and may move to another area along
the shoreline of  Lake Michigan  during  the  times  of the day
when disturbances would  occur.  However, because  none of
these species breeds in the immediate vicinity of the harbor,
no long-term displacement of populations is anticipated  (048) .

Some species of birds or other animals could come into contact
with the contaminated sediments and water in  the harbor  and
dewatering lagoon,  particularly during  non-working hours
(gulls)   and autumn migration  periods  (waterfowl  and shore-
birds)  (048) .

Changes  in the  harbor water column PCB  concentrations  and
reduced PCB accumulations  in fish would be the two principal
long-term beneficial impacts of dredging.

Possible short-term adverse impacts of dredging would include
the following:

     •    The area  inside  the  sediment  dispersal  control
          device used to detain roiled sediments would become
          turbid during dredging and would very likely become
          anoxic  in the  pre-dawn  hours following a  day  of
          dredging in organic "muck" sediments.  Indications
          are that "disturbances"  of  polluted bottom sedi-
          ments, especially if they have great quantities of
          reduced compounds  dissolved in the  intersticial
          waters, can  elevate the expression  of sediment
          oxygen demand by as much as one order of magnitude.
          Diurnal rhythms  of  respiration/photosynthesis in
          freshwater algae are  such  that the lowest oxygen
          levels  occur  in pre-dawn  hours.   Consequently,
          almost  all  respiring organisms inside  the silt
          curtains would be  driven out  or may die during
          early morning hours after dredging  (048) .

     •    If dredging  occurs  during the  fall  and  spring,
          there is a  good  chance  that spawning fish may be
          present in the harbor during the dredging activi-
          ties.   Chinook making fall runs may be  able to
          swim around or leap over the silt  curtains  into  a
          highly PCB-laden body of water  (048) .

Dewatering.  Some volatilization of PCBs would occur during
dewatering of  the dredged sediments.   PCB volatilization
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would be minimized during  initial  placement of the dredged
sediments  by  the decanting  water layer.   The estimated
volatilization rate from exposed Upper Harbor sediments with
a typical  concentration  of 100  ppm PCBs  would be less than
1 Ib of PCBs per day.  Volatilization from the less contami-
nated  decanting  water  layer would  also be  less  than
1.0 Ib/day  (007,  030).

After completion of  dredging,  water removal  and  treatment
would continue until settlement of the top of the  dredged
sediments  slowed to  a  negligible rate.   The contained area
would then be covered by filter  fabric, a granular  drainage
blanket with drain pipes,  and a  compacted clay cap  and sur-
charge.  This would  eliminate  the  volatilization potential
from the containment area.   Water  removed from the  drainage
system would have to be  treated to remove PCBs until  sur-
charge removal.   The drainage pipes would then be permanently
plugged.

Water Treatment.   All  PCB-contaminated waters from the de-
watering process would be  processed through a package water
treatment  plant.   All  water  would  be  treated to  PCB levels
of below 1 ppb (the USEPA  standard).  Treatment plant efflu-
ent would  be monitored  (by grab sampling and 24-hour samp-
ling)  to ensure that discharges were below 1 ppb.  An onsite
laboratory would be  available  to conduct  the water quality
analyses.  Effluent would  be discharged  into Lake Michigan
or to a  sanitary sewer.  Water  discharged into the  sanitary
sewer system would be  processed again  through the Waukegan
municipal wastewater treatment plant and discharged into the
Des Plaines River.

Borrow Materials.  Cofferdam, drain, cap, and surcharge con-
struction  would require  filling  with  clean  material.   This
would require  soils  removal from  an  offsite borrow pit,
causing  topographic  and  other  minor local  impacts  to  the
borrow area.

Additional Environmental  Impacts.   Implementation of this
alternative would also  have the following impacts (048):

     Noise.  Noise  would be produced by construction,  dredg-
     ing, and transportation activities.   Although high noise
     levels could periodically  occur in  localized  areas,
     they would be of  relatively short duration.  Noise  im-
     pacts could temporarily diminish people's enjoyment  of
     the public beach adjacent to the project area.

     Employment.   Construction  jobs created  by the  project
     would temporarily  reduce  unemployment  in the area.
     Employment levels would return  to previous  levels  at
     the conclusion of  the project.
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     Recreation.  The noise and traffic congestion associated
     with construction activities could have short-term nega-
     tive impacts on the public beach adjacent to the project
     area.

     Cultural Resources.  Cultural resources in the Waukegan
     Harbor area would  not be adversely affected.   It is
     possible that the cleanup of PCB-contaminated sediments
     would enhance the desirability of acquiring and retaining
     cultural resources in the harbor area.

Health and Safety Requirements.  The  PCB-contaminated  soil,
sediment, muck, dust, and water associated with  cleanup  ac-
tivities present potentially  significant health  hazards to
workers involved in the cleanup.  Each specific  cleanup  ac-
tivity and associated work function would require the defini-
tion and  enforcement of  specific  safety precautions  and
levels of  protection.   Ecology and Environment,  Inc.,  has
prepared a conceptual safety plan (Appendix).   The plan calls
for protection  measures  for  workers who may be  exposed  to
PCB-contaminated materials.  Ambient air monitoring would be
performed, and  all workers would require appropriate  levels
of protection.  Depending on ambient air monitoring results,
respiratory and  dermal  protection may be required downwind
of site cleanup activities.  In addition to personal protec-
tion, the  conceptual  safety  plan  specifies site  entry pro-
cedures, decontamination  procedures,  work  limitations, and
material disposal requirements.  A detailed health and safety
plan would be prepared  during final design of the selected
response measures.

Reliability

Slurry Walls.  Slurry walls are a relatively new  construction
technique, in general use for about 20 years.   The technology
of construction is well developed, but long-term  performance
data on the use of slurry walls as  a  seepage  cutoff  are not
available.  While it is generally expected that  slurry walls
would be relatively impervious, it is possible that "windows"
of more permeable material could develop during  slurry wall
construction.  Trench backfill is done below  the surface of
the slurry, so  that  visual inspection of the  backfill  as it
reaches its  final  position is not possible.   In addition,
the upper part of the completed slurry wall could be cracked
by  freezing,  groundwater  fluctuations,  or other natural
phenomena.  The  literature on the  effect of PCBs on slurry
wall permeability is  limited.  It is  anticipated that  there
would be  no  significant effects, since  clay  is  generally
accepted  as  a  liner for  licensed  PCB  disposal sites.
However,  the  types  of  slurry wall  available should  be
reviewed  during design.   If  the slurry wall failed  to
achieve the  overall  average  permeability desired, movement
of  PCB-contaminated  groundwater could  occur  more rapidly
PD525.022                   6-68

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than anticipated.  On the other hand, slurry walls have been
used for  groundwater  control on many projects  and have a
good performance  record.  The  containment area would  be
monitored to permit ongoing  evaluation  of  the  effectiveness
and  integrity  of  the  slurry walls  and clay  cap.  The
reliability  of  the containment could  be  enhanced  with
development of additional design details:

     •    Freeze-thaw problems could be reduced by terminating
          the slurry wall below the frostline.

     •    Use of a  flexible  membrane for the cap  could be
          considered for more freedom in site grading.

     •    Should contaminant movement be detected, an inter-
          nal drainage system could be installed to maintain
          internal water  levels  lower  than external levels
          so that any leakage would  be  into  the containment
          area.

Consideration of these types of  details  during  design would
make this alternative effective  in abating further PCB  con-
tamination of the Waukegan area and Lake Michigan.  The type
of slurry wall  material  should  also be evaluated  during
design.  Overall, the reliability of slurry  walls  to reduce
the movement of  PCB-contaminated groundwater is considered
good.

Glacial Till.  The glacial till  covering the bedrock in the
Waukegan area is unsorted, glacier-deposited  sediment,  con-
sisting of silt, clay, and lenses of sand, in which pebbles,
cobbles, and boulders  are embedded.   The thickness  of  the
glacial till typically ranges from 50 to more than 100 ft.

Because of the  relatively low permeability of  the  glacial
till, dissolved substances would be unlikely to migrate more
than 20 to 30 ft, unless they reached a sandy zone of higher
permeability.  These zones could permit  deeper  migration of
dissolved substances  (058).   Diffusion  (the natural  force
acting to minimize concentration differences) may  also  dis-
perse dissolved PCBs in the glacial till pore water.

Because of the  limited information  available  at the time
they prepared their report, Mason & Hanger did not recommend
any alternatives that  depended on the  underlying glacial
till to contain  the more concentrated  PCB materials (001).
Mason & Hanger recommended additional  studies  be performed
to determine the reliability of the glacial till.

PCBs are heavier than water.  The PCBs could gravitate  down
through the glacial till as evidenced by the PCB penetration
into the  glacial till  immediately adjacent  to  former OMC
PD525.022                   6-69

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discharge points  in  Slip No. 3  (001) .   PCB concentration
decreases rapidly with depth into the glacial till, dropping
off to a few ppm after 5 ft of depth in Slip No. 3 (008) .

Dredging.  Hydraulic  dredges  have  been widely used in the
past for dredging.  No new technologies are proposed to com-
plete the dredging.   Dredging technology  is well  developed,
and the  reliability  of the equipment  to  remove sediments
from the Upper Harbor and transport  them  to the containment
area is high.  If a stoppage of the  hydraulic dredge occurs
during dredging, it is expected to result in  some  temporary
additional suspension of sediment in the water column due to
interruption in hydraulic flow.  Leakage  or rupture of the
hydraulic dredge discharge pipeline could disperse PCB-laden
water and sediment over previously uncontaminated areas along
he pipeline.  The impact of  such  spills could be  minimized
by prompt cleanup of  the spilled material and of any soil or
other material that was  contaminated by the spill.  A con-
tingency plan would be established for prompt cleanup.   Leak-
age could either be eliminated by  pipe joint tightening or
be controlled by joint caulking,  mats, collection containers,
or similar means.  The collected solids could be disposed of
in the containment area, and  collected water  could be  taken
to the water treatment plant.

Water Treatment.  The water treatment  system would use exist-
ing technology  and equipment  shown to be effective in PCB
removal.  The treatment  plant would  include  a clearwell  for
detention of treated  effluent prior  to discharge.   PCB con-
centrations  in  the clearwell would  be monitored, and if
adequate removal were not achieved,  the water could be re-
cycled through  the plant until discharge standards (less
than 1 ppb PCBs) were met.

Capping.  The use  of  compacted clay  as liners and caps for
chemical waste landfills is a well-developed technology.   The
use of asphaltic  concrete as  a runoff-accelerating membrane
is also well developed.  The  clay  cap could develop cracks
due to moisture content variations,  settlement,  freezing, or
other natural phenomena.  The asphaltic concrete  cap would
be used  to help  reduce  the  possibility  of soil  moisture
changes, thus reducing the possibility of developing cracks
in the clay  cap.   It  is  anticipated  that  the  asphaltic con-
crete membrane  would  require periodic maintenance to  seal
cracks that will inevitably develop  as the pavement ages.

The impact of cracking of the cap  system would  be to allow
additional surface water to  infiltrate the  ground,  and pos-
sibly to permit minor amounts of  volatilized PCBs to leave
the containment  area.  If  infiltration increased, it could
provide hydraulic head inside the  contained area  that  would
increase  the flow of PCB-contaminated  groundwater from
inside the contained  area  to  the  surrounding or underlying
PD525.022                   6-70

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soil.  This  would result in  further  PCB contamination of
adjacent and underlying soil.  The amount of any such uncon-
trolled release would be expected to  be  very  small.    Over-
all, the reliability of the cap would be considered good.

Permit Requirements

Permit requirements are anticipated to include:

     •    USCOE Section 10  (dredging) permit

     •    USCOE Section 404  (disposal in waterways) permit

     •    IEPA water  quality  certification  on all  USCOE
          permits

     •    Waukegan Port Authority dredging permit

     •    IEPA permit for construction of wastewater  treat-
          ment facilities

     •    NPDES  permit   (State/Federal)  for  point-source
          water discharge from the water treatment plant

     •    North Shore Sanitary District  approval  if  water
          discharge goes to a sanitary sewer

     •    IDOT  (Division of Waterways)  permit for work  in
          public waterways

     •    City of Waukegan construction permits

     •    Local land use approval

     •    USEPA toxic substances disposal approval

     •    IEPA approval if  material  is  disposed in a  cur-
          rently non-PC3-approved site

See Mason & Hanger's report  (003) for further  discussion  of
applicable governmental regulations.

Alternative 6B;  Contain-Dredge Part of Upper Harbor-Cap

Response Objectives

Under this alternative,  a cofferdam would be  constructed  to
separate Slip No. 3 from the  Upper Harbor.  A  slurry  cutoff
wall would be  constructed  inside the cofferdam and around
the perimeter  of  the  slip to  contain PCBs  in-place.   The
cutoff wall would extend into the glacial  till to minimize
uncontrolled dispersion of PCBs into the  groundwater.
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A sediment dispersal control device, consisting of a  double
silt curtain or  sheet  piling,  would be installed near  the
middle of  the  Upper Harbor.  Approximately  13,100 yd3  of
sediments with PCB concentrations greater than 50 ppm would
then be dredged  from the north part of the Upper Harbor and
placed within the containment area.   If a 95 percent removal
efficiency were  achieved,  this would  transfer an estimated
3,600 Ib of PCBs to the containment area.  This alternative
would control 99 percent of all  the PCBs  now found  in Slip
No. 3 and  the  Upper Harbor area.  Because of the  limited
containment area,  a smaller volume of sediments would  be
dredged from the Upper Harbor than under the  other alterna-
tives.  This alternative would not remove approximately 25,500
yd3 of sediments containing 3,100 Ib of PCBs with concentra-
tions between 50 and 150 ppm in  the Upper Harbor.  However,
these PCBs represent less  than 1 percent of  the PCBs now
found in Slip No. 3 and the Upper Harbor area.

Dredged sediments would be  dewatered,  with  the supernatant
processed  through  a package water treatment  plant  to PCB
levels below 1 ppb.  The contained area would be capped with
impermeable materials to seal in the contaminated materials.

Using Mason & Hanger's equation for dispersion of PCBs  (001),
migration  through a 2-ft slurry  wall with an  overall  perme-
ability of 10 7  cm/sec would be  expected to  take 2 years,
dispersing about 0.0006 Ib/yr PCBs.   If the slurry wall were
cracked by the  fluctuating  water table,  freezing,  or other
natural phenomena, PCBs could escape at a higher rate.  Ground-
water monitoring wells would be  constructed  to provide  con-
tinuous checks  on  the  efficiency of the slurry wall.   The
State would be required to provide maintenance under PL 96-510.

Using Mason & Hanger's equation  (001),  migration through a
1-ft-thick layer of glacial till with an overall permeability
of 10 7 cm/sec would be expected  to take  1 year, dispersing
about 0.003 Ib/yr PCBs.  If sandy zones were  encountered in
the glacial till, PCBs could escape at a higher rate.  Ground-
water monitoring wells would be constructed to provide contin-
uous checks on the efficiency of the glacial  till.   The State
would be required to provide maintenance under PL 96-510.

The site would  be  capped with  impermeable materials to  seal
in the contaminated soils.  Capping would reduce percolation
into  the  contaminated  area.  Future construction projects
that would cause disturbance  to  the surface and underlying
soils  (trenching, drilling, digging, etc.) would not  be al-
lowed, to minimize deterioration of the impermeable barriers.

Containment and  capping would  reduce the  environmental  haz-
ards now posed by PCB contamination in the harbor.   All con-
taminated  sediments  in the western portion  of Slip No. 3
would be contained in-place, and 95 percent removal efficiency
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of PCBs would  be achieved in the  eastern  portion of Slip
No. 3 and  the  northern portion of  the  Upper Harbor.  The
reliability of the slurry wall and  capping technologies  and
the glacial  till is discussed in  the Reliability section
below.

Containment of  Slip  No. 3 in this  manner  would require a
USEPA waiver from  the  requirements of 40  CFR 761 of TSCA,
since PCBs would remain in proximity to Lake Michigan and in
an area with a high groundwater table (058) .

This alternative would have  greater land  use impacts  than
Slip No. 3—Alternatives 2B,  2D,  and 3.   Slip No. 3 would no
longer  exist and would be converted  into a parking lot.
Future uses of the new area over the  slip  (and  possibly  use
of some adjacent areas) would be restricted because soil-
disturbing construction activities  could not be allowed.  A
new basin would be constructed on vacant OMC property to the
east of Slip No. 3.  Larsen Marine  Services would have to be
relocated adjacent to  the new basin.

Duration of Cleanup Activities

Cofferdam and slurry wall construction at  the mouth  of  Slip
No. 3 would  require  about 2 months.  An  additional  month
would be required  for  dredging in  the Upper Harbor.   If  the
water treatment  plant  were  not protected  against  freezing
weather, the containment  area  would not  be able to  release
slurry water to the plant during freezing  conditions.  Dredg-
ing would then have to occur during nonfreezing weather.

Surcharging would extend 6 to 12  months after dredging acti-
vities are completed.   Removal of  the surcharge and  capping
of the dewatered sediments would require about  1 month.  Con-
struction of the new boat basin would require about  4 months,
concurrent with surcharging.   Total project duration is esti-
mated to be 10  to 16 months.

Impacts and Mitigation of Cleanup Activities

Dredging.   Roiling of bottom sediments during dredging results
in sediment suspension and dispersion.  The use of a hydraulic
dredge and the  proper dredge head would minimize roiling and
sediment dispersion.   A sediment dispersal control  system
(double silt curtain or steel  sheet piling) would also  be
employed to minimize migration of suspended PCBs out of  the
dredging area.   To assist in controlling sediment dispersion,
water would be  continually pumped from inside the contained
area during construction to maintain  net inflow at the  slip
mouth.  This would tend to keep sediments  from  crossing  the
control barrier.  The  water could be  treated by addition of
polymer and/or  activated carbon before the sediment  barrier
is removed.
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A program would be established to monitor  the  effectiveness
of the containment measures and to warn of the need for poly-
mer addition  or shutdown of  dredging.   A seiche  warning
arrangement with the National Weather Service  would also be
put in place  so operations  could be suspended if  a seiche
were imminent.  The  containment  devices  would be  the  most
likely to fail during a seiche due to the  forces created by
a sudden difference  in water  level between the two sides of
the sheet piling or double silt curtain.

The City of Waukegan maintains an emergency water  intake in
Waukegan Harbor.  This water  intake, while an  integral part
of the Waukegan Harbor system,  is  rarely used.   Project
activities would  be  expected  to be completed while  the
intake was not  in use.  If,  however,  the intake  was  needed
during project  activities,  a  monitoring  program,   including
sampling of  raw and  finished water, would be established
during the project to  ensure the safety of the supply.  A
contingency plan would also  be  established to stop project
operations if any contamination entered the system.

Larsen Marine Services would  be  seriously affected by this
alternative.  Cofferdam construction  would permanently cut
off access to its dock.  To prevent further spread of  PCBs,
the new  boat basin  should not be  opened until the Upper
Harbor dredging  is  complete.   It is  estimated that  there
would be a  4-month period during which neither Slip No. 3
nor the  new  boat  basin  would  be  available  for   Larsen
Marine Services'  operations.  Temporary  facilities  would
have to be provided, most probably  on  the east side  of the
Upper Harbor  south of the proposed boat basin.  In addition,
a number of Larsen Marine Services docks and service facili-
ties would  have to be relocated.   The  overall short-term
impact on Larsen Marine Services would  be greater for this
alternative than for Alternatives 2B,  2D, and 3.    This could
be partially  offset  by the long-term  advantages  that may
accrue to Larsen Marine Services,  since  the new boat basin
geometry could be designed to improve water accessibility.

Minimal volatilization would be expected  to  occur during
dredging activities.   Losses would be expected to  be roughly
0.3 to 0.4 Ib/day/acre from  the  exposed,  agitated, and con-
taminated water area (030) .  Concentrations  of  less   than
2 ug/m3 would be  expected to be present in the air as  a
result of  dredging  activities  (007) .  By comparison,  the
OSHA standard for maximum worker exposure to Aroclor 1242 is
1,000 ug/m3 in  the air at  any time.   However, NIOSH recom-
mends that workers not be exposed to more than 1  ug/m3  in
the air  during  an 8-hour period (007) .    (See Health  and
Safety Requirements,  later in this section.)

The proposed  dredging would affect terrestrial biota.   Popula-
tions of gulls  and terns  that currently reside and feed in
PD525.022                   6-74

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the vicinity of  the  harbor would be disturbed by increased
noise and activity levels and may move to another area along
the shoreline of  Lake  Michigan  during the times of the day
when disturbances  would occur.   However, because  none of
these species breeds in the immediate vicinity of the harbor,
no long-term displacement of populations is anticipated (048) .

Some species of birds or other animals could come into contact
with the contaminated sediments  and water in  the harbor and
dewatering  lagoon,  particularly during  non-working hours
(gulls) and autumn migration  periods  (waterfowl and shore-
birds)   (048) .

Changes in  the  harbor  water column PCB  concentrations and
reduced PCB accumulations in fish would be the two principal
long-term beneficial impacts of dredging.

Possible short-term adverse impacts of dredging would include
the following:

     •    The area  inside the  sediment  dispersal  control
          device used to detain roiled sediments would become
          turbid during dredging and would very likely become
          anoxic in  the  pre-dawn hours  following a day of
          dredging in organic "muck" sediments.  Indications
          are that "disturbances"  of  polluted bottom sedi-
          ments, especially if they have great quantities of
          reduced compounds  dissolved in the  intersticial
          waters, can  elevate the expression  of sediment
          oxygen demand by as much as one order of magnitude.
          Diurnal rhythms  of  respiration/photosynthesis  in
          freshwater algae are  such that the  lowest oxygen
          levels  occur  in pre-dawn hours.   Consequently,
          almost  all  respiring  organisms inside  the  silt
          curtains would  be  driven out  or may die during
          early morning hours after dredging  (048).

     •    If dredging  occurs  during the  fall  and  spring,
          there is a good  chance  that  spawning fish may  be
          present in the harbor  during the dredging activi-
          ties.   Chinook  making fall  runs may  be  able to
          swim around or leap over the silt curtains into  a
          highly PCB-laden body of water (048).

Dewatering.  Some volatilization of PCBs would  occur during
dewatering  of  the dredged sediments.  PCB  volatilization
would be minimized during  initial  placement  of the dredged
sediments by  the decanting  water layer.  The  estimated
volatilization rate from exposed Upper Harbor sediments with
a typical concentration of 500  ppm PCBs  would be less  than
1 Ib of PCBs per day.  The volatilization rate from the less
contaminated decanting water  layer would also  be less  than
1 Ib/day (007, 030).
PD525.022                   6-75

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After completion  of  dredging,  water removal and  treatment
would continue until  settlement  of the top of the  dredged
sediments slowed  to a  negligible  rate.   The contained area
would then be covered by filter fabric, a  granular  drainage
blanket with drain pipes, and a compacted  clay cap  and  sur-
charged.  This would eliminate the  volatilization potential
from the containment area.  Water  removed  from the  drainage
system would have to  be  treated  to remove PCBs until sur-
charge removal.  The drainage pipes would then be permanently
plugged.

Water Treatment.  All  PCB-contaminated waters  from  the  de-
watering process would be processed through a package water
treatment plant.  All  water would be  treated to  PCB levels
of below 1 ppb (the USEPA standard).  Treatment plant efflu-
ent would be monitored (by  grab  sampling and 24-hour samp-
ling) to ensure that discharges were below 1 ppb.  An onsite
laboratory would  be available to  conduct the water  quality
analyses.  Effluent would be discharged into Lake Michigan
or to a  sanitary  sewer.  Water discharged  into the  sanitary
sewer system would be  processed  again through  the Waukegan
municipal wastewater treatment plant and discharged into the
Des Plaines River.

Borrow Materials.  Cofferdam, drain, cap, and surcharge con-
struction would require  filling with  clean material.  This
would require  soils  removal from an  offsite borrow  pit,
causing  topographic  and  other  minor  local  impacts  to the
borrow area.

Additional Environmental  Impacts.  Implementation  of this
alternative would also have the following impacts (048):

     Noise.  Noise would be produced by construction, dredg-
     ing, and transportation activities.  Although high noise
     levels  could periodically  occur  in  localized  areas,
     they would be of  relatively  short duration.  Noise im-
     pacts could  temporarily diminish  people's enjoyment  of
     the public beach adjacent to the project area.

     Employment.  Construction jobs created by the  project
     would  temporarily reduce  unemployment  in the  area.
     Employment levels would return to previous  levels  at
     the conclusion of the project.

     Recreation.  The noise and traffic congestion  associated
     with construction activities could have short-term nega-
     tive impacts on the public beach adjacent to the project
     area.

     Cultural Resources.  Cultural  resources in the Waukegan
     Harbor  area  would not be adversely  affected.   It  is
     possible that the cleanup of PCB-contaminated  sediments
PD525.022                   6-76

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     would enhance the desirability of acquiring and retaining
     cultural resources in the harbor area.

Health and Safety Requirements.   The  PCB-contaminated  soil,
sediment, muck, dust, and water  associated with  cleanup  ac-
tivities present potentially  significant  health  hazards to
workers involved in the cleanup.   Each  specific  cleanup  ac-
tivity and associated work function would require the defini-
tion and  enforcement of  specific safety precautions  and
levels of protection.   Ecology and Environment,  Inc.,  has
prepared a conceptual safety  plan (see  Appendix).   The  plan
calls for protection measures for workers who may be exposed
to PCB-contaminated materials.  Ambient air monitoring would
be performed, and all workers would require appropriate levels
of protection.  Depending on ambient air monitoring results,
respiratory and dermal  protection may be  required downwind
of site cleanup activities.   In addition to personal protec-
tion, the conceptual  safety plan specifies site  entry pro-
cedures, decontamination  procedures,  work limitations,  and
material disposal requirements.  A detailed health and safety
plan would be prepared  during final  design of the selected
response measures.

Reliability

Slurry Walls.  Slurry walls are a relatively new construction
technique, in general use for about 20 years.  The technology
of construction is well developed, but long-term performance
data on the use of slurry walls  as a  seepage  cutoff  are  not
available.  While it is generally expected that slurry walls
would be relatively impervious, it is possible that "windows"'
of more permeable material could  develop during  slurry  wall
construction.  Trench backfill is  done  below  the surface of
the slurry,  so that visual inspection of the  backfill as it
reaches its  final position  is not possible.  In addition,
the upper part of the completed slurry wall could be cracked
by freezing,  groundwater fluctuations, or other natural pheno-
mena.  The literature on  the  effect of  PCBs on  slurry wall
permeability is limited.  It is anticipated that  there would
be no significant effects, since  clay is generally  accepted
as a liner for  licensed PCB disposal sites.  However,  the
types of  slurry  wall available  should  be  reviewed during
design.  If the  slurry  wall  failed to achieve the  overall
average permeability  desired,  movement  of PCB-contaminated
groundwater could occur more  rapidly  than anticipated.   On
the other hand, slurry walls have been  used for  groundwater
control on many projects and have a good performance record.
The containment area  would  be monitored to permit  ongoing
evaluation of the effectiveness  and integrity of the slurry
walls and clay  cap.   The reliability of  the containment
could be  enhanced  with development  of additional  design
details:
PD525.022                   6-77

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     •    Freeze-thaw problems could be reduced by terminat-
          ing the slurry wall below the frostline.

     •    Use of a  flexible  membrane  for the cap could  be
          considered for more freedom in site grading.

     •    Should contaminant movement be detected, an inter-
          nal drainage system could be installed to maintain
          internal water levels  lower  than external levels
          so that any leakage would be  into  the  containment
          area.

Consideration of these types of  details  during design would
make this alternative effective  in abating further  PCB con-
tamination of the Waukegan area and Lake Michigan.  The type
of slurry wall material should  also  be evaluated  during
design.  Overall, the reliability of slurry  walls to  reduce
the movement of  PCB-contaminated groundwater is  considered
good.

Glacial Till.  The glacial till  covering the bedrock  in  the
Waukegan area  is unsorted, glacier-deposited sediment, con-
sisting of silt, clay, and lenses of sand, in which pebbles,
cobbles, and boulders  are  embedded.   The thickness of the
glacial till typically ranges from 50 to more than 100 ft.

Because of  the relatively  low permeability  of the  glacial
till, dissolved substances would be unlikely to migrate more
than 20 to 30 ft, unless they reached a sandy zone of higher
permeability.  These zones could permit  deeper migration of
dissolved substances  (058).   Diffusion  (the natural  force
acting to minimize concentration differences) may also dis-
perse dissolved PCBs in the glacial till pore water.

Because of  the limited information available  at the time
they prepared their report, Mason & Hanger did not recommend
any  alternatives  that depended  on the  underlying glacial
till to contain  the  more  concentrated PCB materials  (001).
Mason  & Hanger  recommended  additional  studies  be performed
to determine the reliability of  the glacial till.

PCBs are heavier than water.  The PCBs  could gravitate down
through the glacial till as evidenced by the PCB penetration
into the  glacial till immediately adjacent  to  former CMC
discharge points  in Slip No. 3  (001).   PCB concentration
decreases rapidly with depth into the glacial till, dropping
off to a few ppm after 5 ft of depth in Slip No.  3  (008).

Dredging.  Hydraulic  dredges  have  been widely used in the
past for dredging.  No new technologies are proposed to com-
plete  the dredging.  Dredging technology  is  well developed,
and  the  reliability of the  equipment  to remove sediments
PD525.022                   6-78

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from the Upper Harbor and transport them  to  the  containment
area is high.  If a stoppage of the hydraulic dredge  occurs
during dredging, it is expected to result in some  temporary
additional suspension of sediment in the water column due to
interruption in hydraulic flow.   Leakage  or  rupture of the
hydraulic dredge discharge pipeline could disperse PCB-laden
water and sediment over previously uncontaminated areas along
he pipeline.  The impact of  such  spills could be minimized
by prompt cleanup of the spilled material and of any soil or
other material that was contaminated  by the  spill.  A con-
tingency plan would be established for prompt cleanup.  Leak-
age could either be eliminated by pipe  joint tightening or
be controlled by joint caulking,  mats, collection containers,
or similar means.   The collected solids could be disposed of
in the containment area, and collected  water could be  taken
to the water treatment plant.

Water Treatment.  The water treatment system would use exist-
ing technology and equipment  shown to be effective in  PCB
removal.  The treatment plant would include  a clearwell  for
detention of treated effluent prior to  discharge.   PCB  con-
centrations  in  the  clearwell would be  monitored,  and  if
adequate removal were not achieved, the water could be re-
cycled through  the  plant until discharge standards  (less
than 1 ppb PCBs)  were met.

Capping.  The use of  compacted clay as  liners and caps for
chemical waste landfills is a well-developed technology.  The
use of asphaltic concrete as a runoff-accelerating membrane
is also well developed.  The clay cap could  develop cracks
due to moisture content variations, settlement,  freezing, or
other natural phenomena.  The asphaltic concrete cap would
be used  to  help reduce the  possibility of  soil moisture
changes, thus reducing the possibility  of developing  cracks
in the clay cap.  It is anticipated that  the asphaltic  con-
crete membrane would  require  periodic maintenance  to  seal
cracks that will inevitably develop as the pavement ages.

The impact of cracking of the cap system would  be to allow
additional surface water to infiltrate  the ground,  and  pos-
sibly to permit minor amounts of  volatilized PCBs  to leave
the containment area.   If  infiltration  increased,  it could
provide hydraulic head inside the contained  area that would
increase the flow of PCB-contaminated groundxvater from inside
the contained area to  the  surrounding or underlying  soil.
This would result in  further PCB  contamination  of adjacent
and underlying soil.  The  amount  of  any  such uncontrolled
release would be expected to be  very  small.    Overall,  the
reliability of the cap would be  considered good.
PD525.022                   6-79

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Permit Requirements

Permit requirements are anticipated to include:

     •    USCOE Section 10 (dredging)  permit

     •    USCOE Section 404 (disposal in waterways) permit

     •    IEPA water  quality  certification  on all  USCOE
          permits

     •    Waukegan Port Authority dredging permit

     •    IEPA permit for construction of wastewater treat-
          ment facilities

     •    NPDES  permit   (State/Federal)  for  point-source
          water discharge from the water treatment plant

     •    North Shore Sanitary  District approval  if  water
          discharge goes to a sanitary sewer

     •    IDOT  (Division  of Waterways)  permit for work  in
          public waterways

     •   • City of Waukegan construction permits

     •    Local land use approval

     •    USEPA toxic substances disposal approval

     •    IEPA approval  if material  is disposed in  a cur-
          rently non-PCB-approved site

See Mason & Hanger's report (003) for  further discussion of
applicable governmental regulations.

Subalternative I;  Select Excavation

Response Objectives

This alternative  would  be used  only  in conjunction  with
Alternative 6A  or  6B.   The deep contaminated sediments  in
the  localized  area of  Slip  No. 3  (near  the  former  OMC
outfall) would be  removed by  clamshell  dredging,  fixed,  and
disposed  of offsite.   No dewatering  of these  dredged
sediments would occur.   Containment,  dredging  of Upper
Harbor sediments,  and capping would then occur as  described
under Alternative  6A or 6B.

Because sediments with the greatest PCB concentrations would
be removed  (about  286,500  Ib  of PCBs  in 2,000 yd3 of sedi-
ments and  3,700  yd3  of deep  contaminated  sand and  silt),
PD525.022                   6-80

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this variation would  reduce  the potential impacts of  pos-
sible PCB migration or  escape through the slurry wall  and
the glacial till  (see discussion under Alternatives 6A and
6B).  Subalternative I would  remove  and dispose of offsite
approximately 92.4 percent of all the PCBs now found in Slip
No. 3 and the Upper Harbor area.

Duration of Cleanup Activities

The dredging  of  deep  contaminated sediments in  Slip No.  3
would add about 2 months to the cleanup activities of Alter-
native 6A or  6B.  Total project  duration  is  therefore  esti-
mated to be 13 to 19 months for  6A and  Subalternative  I  and
12 to 18 months for 6B and Subalternative I.

Impacts and Mitigation of Cleanup Activities

Clamshell Dredging.   Spillage of 15 to  30  percent  of  the
sediments in  a  clamshell  bucket occurs while  it is being
raised.  This  spillage  creates a high  degree  of sediment
suspension that increases the concentration of PCBs in solu-
tion.  A sheet pile cofferdam would  be employed to support
the excavation sides and contain  these  dredging  activities.
The water would be treated by the addition of powdered acti-
vated carbon  to  remove dissolved PCBs  before the cofferdam
sediment barrier was  removed.  The water level  inside  the
cofferdam would be lowered to create net  inflow  as  an  addi-
tional control measure.  After  excavation of the localized
area was complete, the  cofferdam would be removed and  the
remaining portion of the western  200 ft of  Slip  No. 3  would
be dredged with a clamshell.

Minimal volatilization would  be expected to  occur during
these dredging activities.  Losses would  be expected  to be
roughly 0.3 to  0.4 Ib/day/acre  from  the exposed, agitated,
and contaminated water area  (030).   Concentrations  of  less
than 1 ug/m3  are  expected  to be  present  in the air as  a
result of dredging  activities  (007).   By comparison,  the
OSHA standard for maximum worker exposure to Aroclor 1242 is
1,000 ug/m3  in the air at  any time.   However,  NIOSH recom-
mends that workers not be  exposed to more than  1 ug/m3  in
the air during an 8-hour period  (007).

Solids Removal, Fixation,  and Disposal.   Volatilization is
expected to occur during truck loading of dredged  sediments
for transport to the batch plant.  The highest reported con-
centration in Slip No. 3 sediments is about 100,000 ppm PCB.
The maximum  predicted PCB concentration  in the air from
solids removal  operations  is predicted  to be  less  than
200 ug/m3 (007).  These values  were  extrapolated from  data
for sand assuming a 3.6-mph wind  and an air temperature of
68°F.  The volatilization  rate from Waukegan  Harbor  muck
should be less than from sand (007).
PD525.022                   6-81

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Dewatered sediment would  be  fixed into a nonflowable  form
for offsite transport by truck.  A sufficient amount of fix-
ing agent would be used  to prevent water loss, and  covers
may be required to prevent volatilization during  transport.
Rules and  regulations  controlling the transport  of toxic
materials promulgated by  the  USDOT,  USEPA,  IDOT,  IINR, and
other applicable regulatory agencies would be complied with.
These include  cleanup,  safety,  and  spill prevention  and
response measures.

Offsite disposal  of  fixed dredged sediments would  require
approximately 710 truck trips  to  the disposal  site using  a
10-yd3 capacity truck.   The  established full  truck  routes
within the  City  of Waukegan  have sufficient  capacity  to
accommodate the estimated truck traffic, but  some  roadway
congestion  and  roadway damage  could occur  (048).   Some
species of  terrestrial animals  could come into contact with
contaminated materials if any  loss occurs during  transport,
and the contamination could be passed into other terrestrial
food chains (048)  .

Disposal of the materials would be  in a  licensed  chemical
waste landfill, and  would be in compliance with  State  and
Federal standards for PCB waste disposal.

Reliability

Clamshell Dredging.  Clamshell dredges have been widely used
in the past for dredging.  No  new technologies are  proposed
to complete the dredging.  Dredging  technology is well devel-
oped, and the reliability of the equipment to remove sediments
from the slip and transport them to  the batch plant would  be
high.

Glacial Till.  The glacial till covering  the bedrock in the
Waukegan area is  unsorted, glacier-deposited sediment,  con-
sisting of  silt,  clay, and lenses of  sand, in which pebbles,
cobbles, and boulders  are embedded.   The thickness  of  the
glacial till typically  ranges from 50 to more  than  100  ft
(058) .

Because of  the  relatively low permeability of the  glacial
till, dissolved substances would be  unlikely to migrate more
than 20 to  30 ft, unless  they reached a sandy  zone of higher
permeability.  These zones could  permit  deeper migration  of
dissolved  substances  (058).   Diffusion  (the natural  force
acting  to   minimize  concentration differences) may also
disperse dissolved PCBs in the glacial till pore water.

Because of  the  limited information  available  at  the time
they prepared their report, Mason &  Hanger did not recommend
any  alternatives  that depended on  the underlying glacial
till to contain the  more concentrated PCB materials  (001).
PD525.022                   6-82

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Mason & Hanger  recommended additional studies be performed
to determine the reliability of the glacial till.

PCBs are heavier than water.  The  PCBs  could  gravitate  down
through the glacial till as evidenced by the PCB penetration
into the glacial  till immediately adjacent to  former OMC
discharge points in  Slip No.  3  (001, 008,  016).   The PCB
concentration decreases  rapidly with  depth  into  the  glacial
till, dropping off to a  few ppm after 5  ft  of depth  in  Slip
No. 3 (008).  Removing the very high  concentrations  of  PCBs
near the OMC  outfall  in Slip No.  3 would  remove the area
where the PCBs  have been known  to  migrate into the glacial
till.

Curing Cells.  The technology for construction of lined cur-
ing cells is well developed and feasible.   There are  no  un-
usual construction details for the curing cell construction.
Construction could be accomplished using conventionally avail-
able materials and equipment.  The risk  of  failure would be
low.  If the upper clay  liner failed, contaminated leachate
could be collected by the  underdrain  system.   If the lower
clay liner also failed,  contaminated  soil  would  have to be
excavated and disposed of with the other contaminated solids.

If an exterior  curing cell dike failed  while a cell was
filled with incompletely cured fixed  solids, PCB-contaminated
water and sediment could flow over a  small area, requiring
cleanup operations and causing slightly increased volatiliza-
tion.  The technology for  dike  design is well understood,
however, so  the  probability of dike  failure  would be ex-
tremely low.

Fixation.   Fixation would use existing equipment in an appli-
cation similar to previous applications, but not yet  estab-
lished for these high-moisture-content sediments.  Laboratory
testing is now being conducted to  verify that fixation can
be accomplished with existing available materials and equip-
ment.  It is  anticipated that  fixation  will prove to be  a
technically feasible and reliable means of controlling water
loss.  If fixation failed to prevent  water loss,  then solids
would have  to be  dewatered mechanically,  as  proposed for
Alternative 3, or a waiver from that  requirement of 40 CFR 761
would have to be obtained  from  the USEPA Regional Adminis-
trator.

Transportation.   Transportation would be accomplished using
dump trucks.  Failure could occur  by  loss  of  material from
the truck through leakage,  spilling over the  top,  dusting,
volatilization,  or spills resulting from vehicle accidents.

The impact of leakage, dusting, and volatilization would be
to disperse small amounts of PCBs all along the haul  routes.
PD525.022                   6-83

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These types of uncontrolled  release  could be minimized by
the use of tailgate seals and covers.

The impact of spills would be to deposit a quantity of PCB-
contaminated solids at  one or more  isolated  points.   The
risk of spills over the top of the truck could be minimized
by use of a cover.  The  risk  of  vehicle accidents is  rela-
tively small, but  it could be compensated for by having  a
response plan and team ready during hauling.

Permit Requirements

The following permits would be required in addition to those
listed under Alternatives 6A and 6B.

     •    IEPA (Division  of  Land and Noise)   special  waste
          hauler's permit

     •    Certification of Authority to haul PCB commodities
          (ICC and IICC)

NORTH DITCH/PARKING LOT AREA

Alternative 1:  Excavate-Dispose

Response Objectives

This alternative would remove all  soils with  concentrations
of PCBs greater than 50 ppm from the North Ditch/Parking Lot
area.  If a 98 percent removal efficiency were achieved,  it
would remove an estimated  757,700 Ib of PCBs in approximately
175,800 yd3 of soil  (003).  This alternative  would  signifi-
cantly reduce the  discharge of PCBs  into Lake Michigan, the
potential for future groundwater contamination, and the vola-
tilization of PCBs into the airshed.

All former land and water  uses would be able to resume after
cleanup activities are completed.  No restrictions to future
uses would be expected.

Duration of Cleanup Activities

Construction of the structural and nonstructural slurry walls
at the Crescent Ditch, Oval Lagoon, and the Parking Lot area
is expected to take a total of 2 to  3 months.   Installation
of the  groundwater pumping system and  initial  groundwater
lowering  is  expected  to take 1  to 2 months.   Excavation,
transportation, and backfilling  is expected to take a total
of about  5  months.  If the water  treatment plant was not
protected against  freezing weather, dewatering effluent could
not be  released  to the  plant during freezing conditions.
Construction below the  water  table would then have to take
PD525.022                   6-84

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place during nonfreezing weather.   The  overall  duration for
this alternative is estimated to be 9 months.

Impacts and Mitigation of Cleanup Activities

Excavation.  Soils  with PCB  concentrations  in excess  of
50 ppm would be excavated by backhoe or front end loader and
loaded onto trucks for offsite disposal.  Excavation of con-
taminated  soils would  also  be required for construction of
the North  Ditch bypass  and  installation of the well points
to control surface water and groundwater.

Volatilization that would occur during these activities could
be minimized by employing the following mitigation measures:

     •    Keeping the area exposed by excavation as small as
          possible.

     •    Performing the work in as short a time as possible,
          by using more or larger equipment.

     •    Covering the exposed material  not  at the working
          face with organic materials  (such as digested acti-
          vated sludge, manure, paper  mill sludge)  or with
          synthetic liners.

     •    Performing the work in the winter,  since  the  rate
          of volatilization during cold weather is less than
          during warm weather.

The highest reported concentration  in  the  North Ditch  soils
is about 100,000 ppm (001).  The predicted PCB concentration
in air during excavation would be about 200 ug/m3.  The vola-
tilization rate is predicted  to  be about 163,000 ug/m2/hr.
Typical concentrations  range  from 50  to  5,000 ppm.   Pre-
dicted average PCB concentrations  in the  air would be less
than 6.6 ug/m3.  The average volatilization rate is expected
to be less than 5,375 ug/m2/hr for soils with concentrations
of 1,000 ppm PCBs.   The highest reported  concentration  in
Parking Lot area soils  is  less  than 10,000 ppm (001).   The
predicted PCB  concentration in  air during excavation would
be less than  43 ug/m3, well  below 1,000 ug/m3, the OSHA
standard.   The volatilization rate  is  predicted to be less
than 35,000 ug/m2/hr.  Typical concentrations range  from  50
to 5,000.   Predicted average  PCB  concentrations in the air
would be about  6.6 ug/m3.   The  average volatilization rate
is expected to be  about  5,375 ug/m2/hr.   These values were
extrapolated from data for sand assuming a 3.6-mph wind  and
an air temperature of  68°F  (007).   The  volatilization  rates
from the sandy soils of the North Ditch/Parking Lot area are
expected to be  approximated by  these  predictions.   By com-
parison, the OSHA  standard  for  maximum worker  exposure  to
Aroclor 1242 is 1,000  ug/m3 in  the air at any  time.   How-
PD525.022                   6-85

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ever, NIOSH recommends that workers  not  be exposed to more
than 1 ug/m3 in the air during an 8-hour period (007) .  (See
Health and Safety Requirements, later in this section.)

Animals could  be disturbed or affected  by construction
activities that  would  alter or remove their habitats and
affect their normal daily and seasonal activities.  However,
such changes would be expected  to  affect  relatively  few
species and individuals and would be far .outweighed by the
benefits  to  be gained from  removal of  the contaminated
material.   Shorebirds, gulls,  and possibly other species
could be attracted to the excavated areas  (048).

Water Treatment.   The  groundwater  removed by pumping  from
the  well  points would be  fully contained  and processed
through a package water  treatment plant.  Secondary solids
discharged from  the water  treatment  plant would  be treated
with other area  solids.  All water would be treated to PCB
levels of below 1 ppb  (the USEPA standard).  Treatment plant
effluent would be  monitored  (by grab sampling and  24-hour
sampling)  to ensure  that discharges were below 1 ppb.  An
onsite laboratory would  be available to conduct  the  water
quality analyses.  Effluent would  be discharged  into  Lake
Michigan  or  a  sanitary  sewer.   Water discharged  to the
sanitary  sewer system  would be processed again through the
Waukegan municipal wastewater treatment plant and discharged
into the Des Plaines River.

Backfill  of  Excavated Areas.    The  backfill of excavated
areas would  require  soils removal from  an offsite borrow
pit, causing topographic  and  other  minor local impacts to
the borrow area.

Solids Removal and Disposal.  Excavated  soil would be trans-
ported by truck to an offsite  disposal  site.   The trucks
would have to be lined to prevent leakage.  Cover or closure
of the trucks would prevent spillage and volatilization dur-
ing transport.   Rules and regulations controlling the trans-
port of toxic  materials  promulgated by  the USDOT,  USEPA,
IDOT, IINR,  and  other  applicable  regulatory agencies would
be complied with.  These  include cleanup,  safety,  and spill
prevention and response measures.

Offsite disposal of excavated soil would require approximately
17,580 truck trips to the disposal site  using a 10-yd3 capacity
truck.  The established full truck routes within the City  of
Waukegan  have sufficient capacity to accommodate the estimated
truck traffic,  but some roadway congestion  and roadway damage
could occur  (048).  Some species of  terrestrial animals could
come into contact  with contaminated materials if any loss
occurs during transport, and the contamination could be passed
into other terrestrial food chains  (048)  .
PD525.022                   6-86

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Disposal of the excavated soil would be in a licensed chemi-
cal waste  landfill,  and  would be in compliance with  State
and Federal standards for PCB waste disposal.  PCB materials
with concentrations greater than  50 ppm must be nonflowable
if they are to be  disposed  of in a chemical waste landfill
(40 CFR 761).   This alternative assumes that the contaminated
soils can  be  excavated  in a nonflowable state, since  they
are mostly sand.

Additional Environmental  Impacts.   Implementation of  this
alternative would also have the following impacts (048):

     Noise.   Noise would  be   produced  by  construction,
     excavation,  and  transportation activities.  Although
     high noise levels could periodically occur in localized
     areas, they  would be  of relatively short duration.
     Noise impacts could  temporarily  diminish  people's en-
     joyment  of the  public beach adjacent  to  the project
     area.

     Employment.   Construction  jobs created by the  project
     would temporarily  reduce  unemployment  in the  area.
     Employment levels would  return to previous  levels  at
     the conclusion of the project.

     Recreation.   The noise and traffic congestion associated
     with construction activities could have short-term nega-
     tive impacts on the public beach adjacent to the project
     area.

     Cultural Resources.   Cultural resources in the Waukegan
     Harbor area would  not be  adversely  affected.   It is
     possible that the cleanup of PCB-contaminated sediments
     would  enhance the  desirability  of acquiring  and
     retaining cultural resources in the harbor area.

Health and Safety Requirements.   The PCB-contaminated  soil,
sediment,  muck,  dust,  and  water associated with cleanup
activities present potentially significant health hazards to
workers  involved  in the  cleanup.   Each specific cleanup
activity  and  associated  work  function  would require  the
definition and enforcement  of specific safety precautions
and levels of protection.   Ecology and Environment,  Inc.,
has prepared  a conceptual  safety plan  (see  Appendix).   The
plan calls for protection  measures for workers who may  be
exposed to PCB-contaminated materials.  Ambient air monitoring
would be performed, and all workers would require appropriate
levels of  protection.  Depending on ambient air monitoring
results, respiratory and dermal  protection  may be required
downwind of site  cleanup activities.   In addition to  per-
sonal protection, the conceptual  safety plan specifies site
entry procedures,  decontamination procedures,  work  limita-
tions, and material disposal requirements.  A detailed health
PD525.022                   6-87

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and safety plan would be prepared during final design of the
selected response measures.

Reliability

Excavation.  Excavation would be accomplished using backhoes
and front  end loaders.  Conventionally  available  devices
based on well-developed technology are feasible for the pro-
posed use.  Failure could  occur  by  loss  of material during
excavation as a result of power loss, accident, or spilling.
Where material falls back into the working excavation, there
would be essentially no impacts.   The impact of spills would
be to deposit  a  quantity of  PCB-contaminated solids at one
or more points on the site.  The impact of such spills could
be minimized by  prompt  cleanup of the spilled material and
of any soil or other material that  was  contaminated by the
spill.

Water Treatment.   The water  treatment  system  would use
existing technology and equipment shown  to be effective in
PCB removal.  The treatment plant would  include a  clearwell
for detention of  treated effluent prior  to discharge.  PCB
concentrations in the  clearwell  would be monitored, and if
adequate  removal  were not achieved,  the  water could be
recycled through  the plant until discharge standards  (less
than 1 ppb PCBs)  were met.

Transportation.  Transportation would be  accomplished using
dump trucks.  Failure  could  occur by loss of material from
the truck  through leakage, spilling over the top,  dusting,
volatilization, or spills resulting from vehicle accidents.

The impact of leakage, dusting,  and  volatilization  would  be
to disperse small amounts of PCBs all along the haul routes.
These types of uncontrolled  release could be minimized by
the use of tailgate seals and covers.

The impact of spills would be to  deposit  a quantity of PCB-
contaminated  solids  at one or more  isolated points.  The
risk of spills over the top of the  truck  could  be  minimized
by use of  a cover.   The risk of  vehicle accidents is rela-
tively small, but it  could be compensated for by  having  a
response plan and team ready during hauling.

Permit Requirements

Permit requirements are anticipated to include:

     •    Well water removal permit  (State)

     •    IEPA permit  for  construction of wastewater treat-
          ment facilities
PD525.022                   6-88

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     •    USCOE Section 404  (disposal in waterways) permit

     •    IEPA water  quality certification  on all  USCOE
          permits

     •    NPDES  permit  (State/Federal)  for  point-source
          water discharge from the water treatment plant

     •    North Shore  Sanitary  District approval  if  water
          discharge goes to a sanitary sewer

     •    IEPA  (Division  of  Land and Noise)  special  waste
          hauler's permit

     •    City of Waukegan construction permits

     •    Local land use approval

     •    Certification of Authority to haul PCB commodities
          (ICC and IICC)

     •    USEPA toxic substances disposal approval

     •    IEPA approval  if material  is disposed in a  cur-
          rently non-PCB-approved site

See Mason & Hanger's report  (003) for  further  discussion  of
applicable governmental regulations.

Alternative 3;  Excavate-Fix-Dispose

Response Objectives

This alternative would remove all soils with  PCB  concentra-
tions greater than 50 ppm  from  the  North  Ditch/Parking Lot
area.  If a 98 percent removal efficiency were achieved,  it
would remove  an  estimated 757,700 Ib of  PCBs  in approxi-
mately 175,800 yd3 of  soil  (003).   This  alternative will
significantly reduce the discharge of  PCBs  into Lake  Michi-
gan, the potential for future groundwater contamination, and
the volatilization of PCBs into the airshed.

All former land and water uses would be able to resume after
cleanup activities are completed.  No restrictions to future
uses would be expected.

Duration of Cleanup Activities

Construction of  the  structural  and  nonstructural  slurry
walls at the Crescent  Ditch,  Oval Lagoon, and  Parking  Lot
area is expected to take a total of 2 to 3 months.  Installa-
tion of the groundwater  pumping  system and  initial ground-
water lowering is expected to take 1 to 2  months.   Excavation
PD525.022                   6-89

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is expected to take about 5 months.  Fixing, transportation,
and backfilling  could  occur concurrently with excavation.
If the water treatment plant was not protected against freez-
ing weather, dewatering  effluent  could not be released  to
the plant  during freezing conditions.  Construction  below
the water table would then have to take place during nonfreez-
ing weather.  The  overal duration for this alternative  is
estimated to be 9 months.

Impacts and Mitigation of Cleanup Activities

Excavation.  Soils  with PCB  concentrations in excess of
50 ppm would be excavated by backhoe or front end loader and
loaded onto trucks for offsite disposal.  Excavation of con-
taminated  soils  would  also  be required for construction of
the North  Ditch  bypass  and  installation of the well points
to control surface water and groundwater.

Volatilization that  would  occur  during these activities
could be  minimized by employing  the  following mitigation
measures:

     •    Keeping the area exposed by excavation as small as
          possible.

     •    Performing  the work  in as  short  a  time  as
          possible, by using more or larger equipment.

     •    Covering the exposed  material not at the working
           face with  organic  materials  (such as  digested
          activated  sludge,  manure,  paper mill sludge)  or
          with synthetic liners.

     •    Performing the work in  the winter,  since  the  rate
          of volatilization during cold weather is less than
          during warm weather.

The highest reported concentration in  the  North Ditch soils
is about 100,000 ppm (001).  The predicted PCB concentration
in air during excavation would be about 200 ug/m3.  The vola-
tilization rate  is  predicted to be about 163,000 ug/m2/hr.
Typical concentrations  range from 500  to  5,000 ppm.   Pre-
dicted average PCB concentrations  in  the air would be less
than 6.6 ug/m3.  The average volatilization rate is expected
to be less than  5,375 ug/m2/hr for soils with concentrations
of  1,000  ppm  PCBs.   The highest  reported  concentration  in
Parking Lot area soils  is  less  than 10,000 ppm (001).  The
predicted  PCB  concentration in  air during excavation would
be  less  than  43 ug/m3,  well  below 1,000 ug/m3,   the  OSHA
standard.  The volatilization rate  is predicted  to be less
than 35,000 ug/m2/hr.  Typical  concentrations  range  from 50
to  5,000.  Predicted average PCB  concentrations  in the air
would be  about  6.6  ug/m3.   The  average volatilization rate
PD525.022                   6-90

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is expected to be  about  5,375 ug/m2/hr.   These values were
extrapolated from data for  sand  assuming  a  3.6-mph  wind  and
an air temperature of 68°F  (007).  The volatilization rates
from the sandy soils of the North Ditch/Parking Lot area are
expected  to  be  approximated  by  these  predictions.   By
compairson, the OSHA standard for maximum worker exposure to
Aroclor 1242 is  1,000 ug/m3 in  the air at  any  time.   How-
ever, NIOSH recommends that workers  not  be exposed to more
than 1 ug/m3 in the air during an 8-hour period (007).   (See
Health and Safety Requirements,  later in this section.)

Animals could  be disturbed or  affected  by construction
activities that  would  alter or  remove their habitats and
affect their normal daily and seasonal activities.  However,
such changes would be expected  to affect  relatively few
species and individuals and would be  far outweighed by the
benefits  to  be gained from removal of  the contaminated
material.   Shorebirds, gulls, and possibly other species
could be attracted to the excavated areas (048).

Water Treatment.  The  groundwater removed by pumping from
the  well  points  would be  fully  contained  and processed
through a package water  treatment plant.   Secondary  solids
discharged from the water  treatment  plant would be treated
with other area solids.  All  water would be treated to PCB
levels of below 1 ppb (the USEPA  standard).  Treatment plant
effluent would be monitored (by grab sampling  and  24-hour
sampling)  to ensure  that discharges were below 1 ppb.   An
onsite laboratory would  be  available to  conduct  the  water
quality analyses.  Effluent would be discharged  into Lake
Michigan  or  a  sanitary  sewer.   Water discharged  to the
sanitary sewer system would be  processed again through the
Waukegan municipal wastewater treatment plant and discharged
into the Des Plaines River.

Backfill of  Excavated Areas.   The  backfill of excavated
areas would require  soils  removal from  an  offsite borrow
pit, causing topographic and  other minor local impacts  to
the borrow area.

Solids Removal,  Fixation,  and  Disposal.   Excavated  soil
would be fixed into a nonflowable form for offsite transport
by truck.   A sufficient amount of fixing agent would be used
to  prevent water  loss  during  transport.   Rules  and
regulations controlling  the transport of  toxic materials
promulgated by  the USDOT,  USEPA, IDOT,  IINK,  and  other
applicable regulatory  agencies  would  be complied  with.
These include  cleanup,  safety,  and  spill prevention  and
response measures.

Offsite disposal of  excavated soil would require  approxi-
mately 21,980 truck trips to the disposal site using a 10-yd3
capacity truck.  The  established full truck routes  within
PD525.022                   6-91

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the City of Waukegan have sufficient capacity to accommodate
the estimated truck traffic, but some roadway congestion and
roadway damage could occur  (048).   Some  species of terres-
trial animals  could come into  contact with  contaminated
materials if any loss occurs during  transport,  and  the  con-
tamination could be passed into other terrestrial food chains
(048).

Disposal of  the  fixed materials  would be in  a licensed
chemical waste landfill,  and would be in  compliance with
State and Federal  standards for PCB waste  disposal.  PCS
materials with concentrations  greater  than 50 ppm  must  be
nonflowable  if they are  to be  disposed  of in  a  chemical
waste landfill (40  CFR 761).  This alternative  assumes  that
the  contaminated soils  can be  excavated  in  a nonflowable
state,  since they are mostly sand.

Additional Environmental  Impacts.   Implementation  of this
alternative would also have the following impacts (048):

     Noise.    Noise  would  be produced  by construction,
     excavation,  and  transportation activities.  Although
     high noise levels could periodically occur in  localized
     areas,   they would be  of  relatively short  duration.
     Noise impacts  could  temporarily diminish people's  en-
     joyment of  the public beach adjacent to the project
     area.

     Employment.   Construction  jobs  created  by the project
     would temporarily  reduce  unemployment  in the  area.
     Employment levels would  return to previous  levels  at
     the conclusion of the project.

     Recreation.   The noise and traffic congestion associated
     with construction activities could have short-term nega-
     tive impacts on the public beach adjacent to the project
     area.

     Cultural Resources.   Cultural resources in the Waukegan
     Harbor  area would  not be  adversely  affected.   It  is
     possible that  the cleanup  of PCB-contaminated  sediments
     would enhance  the desirability of acquiring and retaining
     cultural resources in the  harbor area.

Health and Safety Requirements.  The PCB-contaminated soil,
sediment, muck,  dust,  and  water associated with  cleanup
activities present  potentially  significant health hazards  to
workers  involved  in the  cleanup.   Each specific  cleanup
activity  and associated  work  function  would require the
definition and enforcement  of  specific safety  precautions
and  levels of  protection.   Ecology and Environment,  Inc.,
has prepared a conceptual  safety plan  (Appendix).   The  plan
calls for protection measures for workers who may be exposed
PD525.022                   6-92

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to PCB-contaminated materials.  Ambient air monitoring would
be performed,  and all  workers  would require  appropriate
levels of protection.   Depending  on ambient air monitoring
results, respiratory  and  dermal protection may be required
downwind of  site  cleanup  activities.   In addition to  per-
sonal protection, the conceptual  safety  plan  specifies site
entry procedures, decontamination procedures,  work limita-
tions, and material disposal requirements.  A detailed health
and safety plan would be prepared during final design of the
selected response measures.

Reliability

Excavation.  Excavation would be accomplished using backhoes
and front  end loaders.   Conventionally  available devices
based on well-developed technology are feasible for the pro-
posed use.  Failure could  occur by loss  of material during
excavation as a result of power loss, accident, or spilling.
Where material falls back into the working excavation, there
would be essentially no impacts.  The impact of spills would
be to deposit a quantity  of PCB-contaminated  solids  at one
or more points on the site.  The impact of such spills could
be minimized by prompt  cleanup  of the spilled material and
of any soil or other material contaminated by the spill.

Water Treatment.   The water  treatment  system  v/ould  use
existing technology and equipment shown  to be effective in
PCB removal.  The treatment plant would  include a clearwell
for detention of  treated  effluent prior  to discharge.  PCB
concentrations in the clearwell would be monitored,  and if
adequate removal were not  achieved,  the  water could be re-
cycled through  the  plant until discharge  standards   (less
than I ppb PCBs) were met.

Fixation.  Fixation would use existing equipment in an appli-
cation similar to previous  applications, but not  yet  estab-
lished for  these  high-moisture-content  soils.  Laboratory
testing is now being  conducted  to verify that fixation can
be accomplished with existing available materials and equip-
ment.   It is  anticipated  that fixation  will prove to  be  a
technically feasible and reliable means of controlling water
loss.   If fixation failed to prevent water loss, then solids
would have  to  be  dewatered mechanically,  as  proposed for
Slip No.  3—Alternative 3, or a waiver from that requirement
of 40 CFR 761 would have  to be  obtained  from  the  USEPA Re-
gional Administrator.

Curing Cells.  The technology for construction of lined cur-
ing cells is well developed and feasible.  There  are  no un-
usual construction details for the curing cell construction.
Construction could be accomplished using conventionally avail-
able materials and equipment.  The risk of failure v/ould  be
low.   If the upper clay liner failed, contaminated leachate
PD525.022                   6-93

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could be collected by  the  underdrain  system.   If the lower
clay liner also failed, contaminated  soil  would  have to be
excavated and disposed of with the other contaminated solids.

If a dike failed while a cell  was filled with incompletely
cured fixed  solids,  PCB-contaminated material could flow
over a small area, requiring cleanup  operations  and  causing
slightly increased volatilization.  The  technology for  dike
design is well  understood,  however,  so the probability  of
dike failure would be extremely low.

Transportation.   Transportation would be accomplished using
dump trucks.  Failure  could  occur by  loss  of material from
the truck through leakage,  spilling over the top, dusting,
volatilization,  or spills resulting from vehicle accidents.

The impact of leakage, dusting, and volatilization would be
to disperse small amounts of PCBs all along the haul routes.
These types of  uncontrolled  release  could be minimized  by
the use of tailgate seals and covers.

The impact of spills would be  to  deposit a quantity  of  PCB-
contaminated solids  at one or more isolated points.  The
risk of spills  over the top  of the truck could be minimized
by use of a  cover.   The  risk of  vehicle accidents is rela-
tively small, but it  could be compensated for by having a
response plan and team ready during hauling.

Permit Requirements

Permit requirements are anticipated to include:

     •    Well water removal permit (State)

     •    USCOE Section 404  (disposal in waterways)  permit

     •    IEPA  permit  for  construction  of  wastewater treat-
          ment  facilities

     •    IEPA  water quality  certification  on  all  USCOE
          permits

     •    NPDES  permit  (State/Federal)  for  point-source
          water discharge  from the water treatment plant

     •    North Shore  Sanitary District approval if water
          discharge goes to  a  sanitary sewer

     •    IEPA  (Division of  Land and Noise)  special waste
          hauler's permit

     •    City  of Waukegan construction permits
PD525.022                   6-94

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     •    Local land use approval

     •    Certification of Authority to haul PCB commodities
          (ICC and I1CC)

     •    USEPA toxic substances disposal approval

     •    IEPA approval if  material is disposed in  a  cur-
          rently non-PCB-approved site

See Mason & Hanger's report  (003) for  further  discussion of
applicable governmental regulations.

Alternative 4:  Contain-Cap  (Parking Lot Area Only)

Response Objectives

This alternative would use a slurry wall around the perimeter
of the  soil  with PCB concentrations  greater than 50 ppm.
The containment wall would extend down to the  existing gla-
cial till beneath the local  sands  (35  ft deep).   This  would
minimize uncontrolled dispersion of PCBs through the soil or
the groundwater.  Based on Mason &  Hanger's equation for
dispersion of PCBs  (001) ,  if a wall with an overall per-
meability of 10 7 cm/sec were used,  migration through a  2-ft
slurry wall would be  expected to take 2 years,  dispersing
about 0.002 lb/ year PCBs.   If  the  slurry wall were  cracked
by the  fluctuating water  table,  freezing,  or other natural
phenomena, PCBs would escape  at a higher rate.   Groundwater
monitoring wells would be constructed  to provide  continuous
checks on the  efficiency  of the slurry walls.   The State
would be required to provide maintenance under PL 96-510.

Using Mason & Hanger's  equation (001),  migration through a
1-ft-thick layer of glacial till with an overall permeability
of 10 7 cm/sec would be expected to  take 1  year,  dispersing
about 0.02 Ib/yr PCBs.  If  sandy  zones were encountered in
the glacial  till,  PCBs could escape  at  a   higher  rate.
Groundwater monitoring wells would be constructed to provide
continuous checks on  the  efficiency of the glacial till.
The State would  be  required to provide maintenance under
PL 96-510.

The site would be capped with impermeable materials  to seal
in the  contaminated  soils,  and would be resurfaced for
future parking.  Capping would  reduce  percolation into the
contaminated area.   Future construction projects that  would
cause disturbance to the surface and underlying soils  (trench-
ing,  drilling, digging,  etc.) would not be allowed, to mini-
mize deterioration of the impermeable barriers.

This alternative would reduce the environmental  hazards  now
posed by PCB contamination.   The reliability of  the slurry
wall,  the underlying glacial till,  and capping is  discussed
PD525.022                   6-95

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in the reliability section below.  Because of its proximity
to Lake Michigan, the Parking Lot area could experience erosion
as a result of storm events.  However,  a  one-time  event is
not likely to impact the area, and mitigative measures could
be taken to prevent cumulative impacts from multiple events.

Containment of the Parking Lot in this manner would  require
a USEPA waiver from the requirements of 40 CFR 761 of  TSCA,
since PCBs would remain in proximity to Lake Michigan and in
an area with a high groundwater table (058).

This alternative would  have  greater land use impacts  than
Alternatives 1 and 3.   Future new uses of the Parking  Lot
area and possibly of some adjacent areas would be restricted
because soil-disturbing construction activities could not be
allowed.

Duration of Cleanup Activities

Construction of  the  slurry wall  is expected to take  about
1 month, with construction of the clay cap and paving taking
about 2 months.  The overall  duration for this alternative
is estimated to be 4 months.

Impacts and Mitigation of Cleanup Activities

Excavation.  Excavation would be  required for construction
of the slurry wall and installation of the monitoring wells.
Volatilization from excavation of soils with average contami-
nant levels of 10,000 ppm is estimated to result in air con-
centrations of 43 ug/m3 (007)  .  By comparison, the OSHA stan-
dard  for  maximum  worker exposure  to Aroclcr  1242  is
1,000 ug/m3 in the air  at any time.   However,  NIOSH recom-
mends that workers not  be  exposed to more than 1 ug/m3  in
the air during  an 8-hour period  (007) .   (See Health  and
Safety Requirements, later in this section).

Health and Safety Requirements.   The  PCB-contaminated  soil,
sediment,  muck,  dust,  and water  associated with cleanup
activities present potentially significant health hazards to
workers involved in the cleanup.   Each  specific cleanup
activity and  associated work function  would require  the
definition and  enforcement  of specific safety precautions
and levels of  protection.   Ecology and Environment,  Inc.,
has prepared a conceptual safety  plan  (Appendix).  The  plan
calls for protection measures for workers who may be exposed
to PCB-contaminated materials.  Ambient air monitoring would
be performed,  and all  workers  would require  appropriate
levels of protection.   Depending  on ambient air monitoring
results, respiratory and dermal protection may be required
downwind of  site cleanup  activities.  In addition to  per-
sonal protection, the conceptual  safety plan  specifies  site
PD525.022                   6-96

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entry procedures, decontamination  procedures,  work limita-
tions, and material disposal requirements.  A detailed health
and safety plan would be prepared during final design of the
selected response measures.

Additional Environmental  Impacts.   Implementation of  this
alternative would also have the following impacts  (048):

     Noise.  Noise would be produced by  construction,  exca-
     vation, and  transportation  activities.   Although high
     noise levels could periodically occur in localized areas,
     they would be of relatively short duration.   Noise  im-
     pacts could temporarily diminish people's enjoyment  of
     the public beach adjacent to the project area.

     Employment.  Construction jobs  created  by the project
     would  temporarily  reduce unemployment  in the  area.
     Employment levels would  return  to previous  levels  at
     the conclusion of the project.

     Cultural Resources.  Cultural resources in the Waukegan
     Harbor area  would  not be adversely  affected.   It is
     possible that the cleanup of PCB-contaminated sediments
     would enhance the desirability of acquiring and retaining
     cultural resources in the harbor area.

Reliability

Slurry Walls.  Slurry walls are a relatively new construction
technique, in general use for about 20 years.  The technology
of construction is well developed,  but long-term performance
data on the use of slurry walls as a seepage  cutoff  are  not
available.  While it is generally expected that slurry walls
would be relatively impervious, it is possible that "windows"
of more permeable material could develop  during  slurry wall
construction.  Trench backfill is  done below  the  surface  of
the slurry, so that visual inspection of  the backfill  as  it
reaches its  final  position is not possible.   In  addition,
the upper part of the completed slurry wall could be cracked
by freezing, groundwater fluctuations,  or other natural pheno-
mena.  The literature on the effect  of  PCBs  on slurry wall
permeability is limited.  It is anticipated that there would
be no significant effects, since clay is  generally accepted
as a  liner  for  licensed PCB disposal sites.   However,  the
types of  slurry wall available should be reviewed during
design.  If the  slurry  wall failed to achieve the overall
average permeability desired,  movement  of PCB-contaminated
groundwater could occur more  rapidly than anticipated.  On
the other hand, slurry walls have  been used  for  groundwater
control on many projects and have a good performance record.
The containment area would be  monitored to permit ongoing
evaluation of the effectiveness and  integrity  of  the  slurry
PD525.022                   6-97

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walls and clay cap.  The reliability of the containment could
be enhanced with development of additional design details:

     •    Freeze-thaw problems could be reduced by terminating
          the slurry and cap wall below the frostline.

     •    Use of a  flexible  membrane for the cap could be
          considered for more freedom in site grading.

     •    Should  contaminant movement  be  detected,  an
          internal  drainage  system could be  installed to
          maintain internal water levels lower than external
          levels so  that any  leakage  would be  into the
          containment area.

Consideration of these types of details during design would
make this alternative effective in  abating  further  PCB con-
tamination in the Waukegan area and Lake Michigan.  The type
of  slurry  wall material should  also be evaluated  during
design.  Overall, the reliability of slurry walls to reduce
the movement of  PCB-contaminated  groundwater  is  considered
good.

Glacial Till.  The  glacial till covering the bedrock in the
Waukegan area is unsorted, glacier-deposited sediment,  con-
sisting of silt, clay, and lenses of sand, in which pebbles,
cobbles, and boulders are  embedded.  The thickness  of the
glacial till typically ranges from  50 to more than 100 ft.

Because of the  relatively  low permeability of the  glacial
till, dissolved substances would be unlikely to migrate more
than 20 to 30 ft, unless they reached a sandy zone of higher
permeability.  These zones could  permit  deeper migration  of
dissolved  substances  (058).   Diffusion  (the natural  force
acting  to  minimize  concentration  differences)   may  also
disperse the PCB oil in the glacial till pore water.

Because of  the limited  information  available at the time
they prepared their report, Mason & Hanger did not recommend
any  alternatives  that depended on  the  underlying glacial
till to contain  the more concentrated  PCB materials  (001).
Mason  & Hanger  recommended additional  studies  be performed
to determine the reliability of the glacial till.

PCBs are heavier than water.   The PCBs  could gravitate down
through the glacial till as evidenced by the PCB penetration
into the  glacial till immediately  adjacent  to  former CMC
discharge points in  the  Crescent  Ditch (001).   Penetration
of PCBs has  occurred at  that location  with a concentration
of 240 ppm  found at a depth  of about 5 ft into the glacial
till (001).
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Capping.  The use  of  compacted clay as liners and caps for
chemical waste  landfills is  a well-developed technology.
The use of asphaltic  concrete as  a  runoff-accelerating mem-
brane is also well developed.  The clay cap  could  develop
cracks due to moisture content variations, settlement,  freez-
ing, or other natural phenomena.  The asphaltic concrete cap
would be used to help reduce  the possibility of soil moisture
changes, thus reducing the possibility  of  developing cracks
in the clay cap.   It  is  anticipated that  the  asphaltic con-
crete membrane  would  require periodic maintenance  to  seal
cracks that will inevitably develop as the pavement ages.

The impact of cracking of  the cap system  would be to allow
additional surface water to  infiltrate  the ground,  and pos-
sibly to permit minor amounts of  volatilized  PCBs to leave
the containment area.   If  infiltration increased, it could
provide hydraulic head inside the contained area  that  would
increase the flow of PCB-contaminated groundwater from  inside
the contained area  to the  surrounding or  underlying  soil.
This would result  in  further PCB  contamination of adjacent
and underlying  soil.  The  amount  of any  such  uncontrolled
release would be expected  to be very small.    Overall, the
reliability of the cap would  be considered good.

Permit Requirements

Permit requirements are anticipated to include:

     •    City of Waukegan construction permits

     •    Local land use approval

     •    USEPA toxic substances disposal approval

     •    IEPA  approval  if material is disposed  of in a
          currently non-PCB-approved site

See Mason & Hanger's  report  (003)  for  further  discussion  of
applicable government regulations.

Alternative 4A:   Excavate-Contain-Cap  (North Ditch Area Only)

Response Objectives

Under this alternative,  a drainage bypass of the North Ditch
would be constructed, and  soils with PCB  contamination in
excess of 50 ppm would  be  excavated from the  North  Ditch.
The Crescent Ditch area  would also  be  excavated to  a depth
of 3 ft.  The soils would be dewatered using well points and
pumps.  A slurry wall would be  constructed around the  peri-
meter of the Crescent Ditch/Oval Lagoon area.   This  containment
wall would extend down to  the existing  glacial till  beneath
the local sands  (35  ft) .  Excavated soils from the North
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Ditch and Crescent Ditch areas would be placed on top of the
Oval Lagoon area.  The Crescent Ditch/Oval Lagoon containment
area would then be capped with 3 ft of impermeable materials
to seal in the contaminated soils.

The slurry wall  would minimize uncontrolled dispersion  of
PCBs from the  Crescent  Ditch/Oval  Lagoon area through  the
soil or groundwater.  Based on Mason & Hanger's equation, if
a wall with an overall permeability of 10 'cm/sec were used,
migration through a 2-ft  slurry wall  is  expected to take 2
years, dispersing about 0.001 Ib/yr PCBs.   If  the slurry
wall were cracked by  the  fluctuating water  table,  freezing,
or other  natural phenomena,  PCBs would  escape  at a  much
higher  rate.   Groundwater  monitoring  wells  would  be
constructed to provide  continuous  checks  on the efficiency
of the  slurry.  The  State would  be required  to provide
maintenance under PL 96-510.

Using Mason &  Hanger's  equation  (001),  migration through a
1-ft-thick layer of glacial till with an overall permeability
of 10 7 cm/sec would be expected to take  1  year,  dispersing
about 0.001 Ib/yr PCBs.   If sandy zones were encountered in
the glacial till, PCBs could escape at a higher rate.  Ground-
water monitoring wells would be constructed to provide contin-
uous checks on the efficiency of the glacial till.  The State
would be required to provide maintenance under PL 96-510.

Capping of the containment area would prevent  percolation
into the  contaminated area.   Future construction  projects
that would cause disturbance  to  the surface and underlying
soils  (trenching,  drilling,  digging, etc.)  would not  be
allowed,  to minimize  deterioration  of the impermeable bar-
riers .

This alternative would  reduce  the  environmental  hazards  now
posed by  the  PCB contamination in  the  North Ditch  area.
Approximately  98 percent  of North Ditch  soils with PCB  con-
tamination in  excess  of 50 ppm would be  removed,  and all
contaminated soils  in the Crescent Ditch/Oval Lagoon area
would be  contained  in-place.  The reliability of the  slurry
wall and  capping technologies  and  the glacial till is dis-
cussed in the  Reliability Section below.

Containment of the  North  Ditch in  this manner would require
a USEPA waiver from the requirements  of  40 CFR 761 of TSCA
since PCBs would remain in proximity to Lake Michigan and in
an area with a high groundwater table (058) .

This alternative would  have  greater land use impacts than
Alternatives 1 and  3.   The Crescent Ditch  area  would  remain
at the existing  ground  elevation,  and would be  converted to
a parking lot.   Future  new uses would be  restricted because
soil-disturbing  construction activities could not be  allowed.
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Landfilling of the Oval  Lagoon  area with contaminated soil
and capping materials would elevate  it  about 20 to 25 feet
above the  existing  ground level.  No future uses of this
area would be possible.

Duration of Cleanup Activities

Construction of the drainage  bypass  and the slurry wall is
expected to take about 1 to 2 months.  Excavation activities
are expected to take a total of 1 to 2 months, and construc-
tion of  the  clay  cap  and paving another 2  months.   If  the
water treatment plant  were not protected against  freezing
weather, dewatering effluent  could not  be  released  to  the
plant during  freezing conditions.   Excavation below the
water table would then have to take place during nonfreezing
weather.   The  overall duration  for this alternative is
estimated to be 4 to 6 months.

Impacts and Mitigation of Cleanup Activities

Excavation.  Contaminated  soils would be excavated  from the
North Ditch and Crescent Ditch areas by backhoe or front end
loader and transported to  the Oval  Lagoon containment area.
Excavation of contaminated soils would  also be  required  for
construction of the North  Ditch  bypass  and  installation of
the well points to control surface and groundwater.

An average volatilization  rate that can be expected from
exposed sand during excavation activities is 5,375 ug/m2/hr,
assuming average PCB concentrations  in  the  exposed sand to
be 1,000 ppm.  Volatilization that would occur  during these
activities could  be  minimized by  employing the following
mitigation measures:

     •    Keeping the area exposed by excavation as small as
          possible.

     •    Performing the work in as short a time as possible,
          by using more or larger equipment.

     •    Covering the exposed material not at the working
          face with  organic materials  (such as  digested
          activated sludge, manure,  paper  mill sludge)   or
          with synthetic liners.

     •    Performing the work in the winter,  since  the  rate
          of volatilization during cold  weather is less  than
          during warm weather.

The highest reported concentration in the North Ditch soils
is about 100,000 ppm (001).  The predicted PCB concentration
in air during excavation would be about  200  ug/m3.  The  vola-
tilization rate is predicted  to  be about 163,000 ug/m2/hr.
PD525.022                   6-101

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Typical concentrations range  from 500 to 5,000 ppm.   Pre-
dicted average PCB concentrations  in  the  air would be less
than 6.6 ug/m3.   The average volatilization rate is expected
to be less than 5,375 ug/m2/hr for soils with concentrations
of 1,000 ppm PCBs.  These values were extrapolated from data
for sand, assuming a 3.6-mph wind  and an  air  temperature  of
68°F  (007).  The  volatilization  rates  from the sandy soils
of the North Ditch area are expected to be closely approximated
by these predictions.  By comparison, the OSHA standard  for
maximum worker exposure  to  Aroclor 1242  is 1,000  ug/m3  in
the air at any time.   NIOSH recommends  that workers not be
exposed to more  than  1 ug/m3 in the  air  during an 8-hour
period  (007) .  (See Health and Safety Requirements, later in
this section.)

Animals could  be disturbed  or affected  by construction
activities that  would  alter or remove  their habitats and
affect their normal daily and seasonal activities.  However,
such  changes  would  be expected  to affect relatively  few
species and individuals  and  would be  far outweighed by the
benefits  to  be  gained  from removal of  the contaminated
material.  Shorebirds,  gulls,  and possibly  other species
could be attracted to the excavated areas  (048).

Water Treatment.  The  groundwater removed by  pumping  from
the well  points  would be  fully contained  and processed
through a package water  treatment plant.   Secondary solids
discharged from  the water  treatment  plant would be treated
with other area  solids.  All water would be treated to PCB
levels of below 1 ppb  (the USEPA standard).  Treatment plant
effluent would be monitored (by grab sampling  and 24-hour
sampling)  to ensure  that discharges  were below 1  ppb.   An
onsite  laboratory would  be available to  conduct  the  water
quality analyses.  Effluent  would be discharged  into  Lake
Michigan  or  a sanitary  sewer.   Water discharged  to the
sanitary sewer system  would  be processed again through the
Waukegan municipal wastewater treatment plant and discharged
into the Des Plaines River.

Backfill  of  Excavated Areas.   The backfill  of excavated
areas would  require  soils  removal from  an offsite borrow
pit,  causing  topographic and other minor local impacts  to
the borrow area.

Health and Safety Requirements.   The  PCB-contaminated soil,
sediment, muck,  dust,  and  water  associated with  cleanup
activities present potentially significant health hazards to
workers involved in  the cleanup.   Each  specific  cleanup
activity  and  associated work  function  would  require  the
definition and enforcement of specific safety  precautions
and levels of  protection.   Ecology and Environment,  Inc.,
has prepared a conceptual  safety plan  (Appendix).   The plan
calls for protection measures for workers who may be exposed
PD525.022                   6-102

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to PCB-contaminated materials.  Ambient air monitoring would
be performed,  and all workers  would require  appropriate
levels of protection.  Depending  on ambient air monitoring
results,  respiratory and dermal protection  may be required
downwind of site cleanup activities.  In addition to personal
protection,  the conceptual safety plan specifies  site  entry
procedures,  decontamination  procedures,  work  limitations,
and material disposal requirements.  A  detailed health and
safety plan would be prepared during final  design  of the
selected response measures.

Additional Environmental  Impacts.   Implementation of  this
alternative would also have the following impacts (048):

     Noise.   Noise would be produced by  construction,  exca-
     vation, and  transportation activities.   Although high
     noise levels could periodically occur in localized areas,
     they would be of relatively short duration.  Noise  im-
     pacts could temporarily  diminish people's  enjoyment of
     the public beach adjacent to the project area.

     Employment.  Construction jobs  created  by the  project
     would temporarily  reduce unemployment  in the  area.
     Employment levels would  return to previous  levels  at
     the conclusion of the project.

     Cultural Resources.   Cultural resources in the Waukegan
     Harbor area  would  not be adversely  affected.   It is
     possible that the cleanup of PCB-contaminated sediments
     would enhance the desirability of acquiring and retaining
     cultural resources in the harbor area.

Reliability

Excavation.   Excavation would be accomplished using backhoes
and  front  end  loaders.   Conventionally  available devices
based on well-developed technology are feasible for the pro-
posed use.  Failure  could  occur by  loss  of material during
excavation as a result of power loss, accident, or spilling.
Where material falls back into the working excavation, there
would be essentially no impacts.  The impact of spills would
be to deposit a quantity of  PCB-contaminated solids at one
or more points on the site.  The impact of such spills could
be minimized by prompt cleanup  of  the  spilled material and
of any soil or  other material that was  contaminated by the
spill.

Water Treatment.  The water treatment system would use exist-
ing technology  and  equipment  shown to be effective  in  PCB
removal.   The treatment plant would  include  a  clearwell  for
detention of treated effluent prior to discharge.  PCB concen-
trations in the clearwell would be monitored, and if adequate
removal were  not achieved, the  water could  be recycled
PD525.022                   6-103

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through the plant until discharge standards (less than 1 ppb
PCBs) were met.

Slurry Walls.  Slurry walls are a relatively new construction
technique, in general use for about 20 years.   The technology
of construction is well developed, but long-term performance
data on the use of slurry walls as a  seepage cutoff  are  not
available.  While it is generally expected that slurry walls
would be relatively impervious, it is possible that "windows"
of more permeable material could  develop  during  slurry wall
construction.  Trench backfill is done below the  surface  of
the slurry, so that visual inspection of  the backfill as  it
reaches its  final position  is not possible.  In  addition,
the upper part of the completed slurry wall could be cracked
by freezing, groundwater fluctuations, or other natural phe-
nomena.  The literature on the effect of PCBs on slurry wall
permeability is limited.  It is anticipated that there would
be no  significant effects, since  clay is  generally  accepted
as a  liner  for licensed PCB disposal sites.  However, the
types  of  slurry  wall available should be reviewed during
design.  If  the  slurry  wall  failed to achieve the  overall
average permeability desired,  movement  of PCB-contaminated
groundwater could occur more  rapidly  than anticipated.   On
the other hand,  slurry walls  have been used for  groundwater
control on many projects and have a good performance record.
The containment  area would  be monitored  to permit  ongoing
evaluation of the effectiveness and integrity of  the  slurry
walls and clay cap.   The reliability of the containment could
be enhanced with development of additional design details:

     •    Freeze-thaw problems could be reduced by terminating
          the slurry and cap wall below the frostline.

     •    Use of  a  flexible  membrane  for the cap could  be
          considered for more freedom in  site grading.

     •    Should  contaminant  movement  be  detected, an
          internal drainage  system could be  installed  to
          maintain internal water levels  lower than external
          levels  so  that any  leakage would be  into the
          containment area.

Consideration of these types of details during design would
make this alternative effective in abating  further  PCB con-
tamination of the Waukegan area and Lake Michigan.  The type
of  slurry  wall material  should  also  be  evaluated  during
design.  Overall, the reliability of  slurry walls  to reduce
the movement of  PCB-contaminated  groundwater  is considered
good.

Glacial Till.  The glacial till covering  the bedrock in  the
Waukegan area  is  unsorted, glacier-deposited  sediment,  con-
sisting of silt, clay,  and lenses of sand, in which pebbles,
PD525.022                   6-104

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cobbles, and boulders  are  embedded.   The thickness of  the
glacial till typically ranges from 50 to more than 100 ft.

Because of  the  relatively  low permeability of  the  glacial
till, dissolved substances would be unlikely to migrate more
than 20 to 30 ft, unless they reached a sandy zone of higher
permeability.  These zones could permit  deeper  migration  of
dissolved substances  (058).   Diffusion  (the natural  force
acting to minimize concentration differences) may  also  dis-
perse the PCB oil in the glacial till pore water.

Because of  the  limited information available at the  time
they prepared their report, Mason & Hanger did not recommend
any  alternatives  that  depended on the  underlying glacial
till to contain  the more  concentrated PCB materials  (001).
Mason & Hanger  recommended additional studies  be performed
to determine the reliability of the glacial till.

PCBs are heavier than water.  The PCBs  could gravitate  down
through the glacial till as evidenced by the PCB penetration
into the glacial till  immediately adjacent to  former OMC
discharge points in the Crescent  Ditch (001).   Penetration
of PCBs has  occurred at that location with a concentration
of 240 ppm found at a depth  of  about  5  ft into  the glacial
till (001) .

Capping.  The use of compacted  clay as  liners  and caps for
chemical waste  landfills  is  a  well-developed  technology.
The use of asphaltic concrete as a runoff-accelerating  mem-
brane is also well  developed.  The  clay cap could  develop
cracks  due  to  moisture  content variations,  settlement,
freezing,  or other  natural phenomena.  The asphaltic  con-
crete cap would  be used to help reduce the possibility of
soil moisture  changes,  thus  reducing the possibility  of
developing cracks in the clay cap.   It  is anticipated that
the asphaltic concrete  membrane would require periodic main-
tenance to seal  cracks that  will  inevitably  develop as the
pavement ages.

The impact of cracking of  the cap system would  be to  allow
additional surface water to  infiltrate  the ground,  and  pos-
sibly to permit minor amounts of volatilized  PCBs to  leave
the containment  area.  If  infiltration  increased,  it  could
provide hydraulic head inside the contained area that would
increase the flow of PCB-contaminated groundwater from in-
side the contained  area  to  the surrounding  or  underlying
soil.  This  would  result  in  further  PCB  contamination of
adjacent and underlying soil.   The  amount of any such  un-
controlled release would be expected to be very small.  Over-
all, the reliability of the cap would be considered good.
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Permit Requirements

Permit requirements are anticipated to include:

     •    Well water removal permit (State)

     •    IEPA permit for construction of wastewater  treat-
          ment facilities

     •    USCOE Section 404 (disposal in waterways)  permit

     •    IEPA water  quality certification  on all USCOE
          permits

     •    NPDES  permit   (State/Federal)  for  point-source
          water discharge from the water treatment plant

     •    North  Shore Sanitary  District approval if  water
          discharge goes to a sanitary sewer

     •    City of Waukegan construction permits

     •    Local land use approval

     •    IEPA  (Division of  Land and Noise)  special  waste
          hauler's permit

     •    USEPA toxic substances disposal approval

     •    IEPA approval  if  material is disposed in a cur-
          rently non-PCB-approved site

     •    Certification of Authority to haul PCB commodities
          (ICC and I1CC)

See Mason & Hanger's report  (003)  for  further discussion  of
applicable governmental regulations.

Alternative 4B:  Excavate-Contain Part of E-W Portion of the
North Ditch-Cap  (North Ditch Area Only)

Response Objectives

Under this alternative,  the  east-west  portion of the North
Ditch would be excavated only to  the  extent necessary to
install a pipeline bypass within the ditch area.  This would
require excavation to a  depth of  10 ft  and  a width  of 7  ft,
removing approximately  5,500  yd3  of soil.   In  comparison,
excavation under the other North Ditch alternatives would be
to a depth of  15 ft and  a width  of  25  ft, removing  approxi-
mately  25,000  yd3  of  soil.  Construction of a structural
support system (sheet piling) would not be  necessary under
this alternative because of the limited excavation involved.
PD525.022                   6-106

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The soil, however, would be dewatered  using well  points  and
pumps before excavation.  After the bypass is installed, the
excavated area would be backfilled and capped with impermeable
materials.

The Crescent Ditch area would  be  excavated to a depth of 3
ft.  All excavated soils would be dewatered using well points
and pumps.  A  slurry wall  would be constructed around  the
perimeter of  the Crescent Ditch/Oval  Lagoon area.   This
containment wall would  extend  down  to  the existing glacial
till beneath the local sands  (35  ft).  Excavated  soils  from
the North Ditch  and  Crescent Ditch  areas  would  be placed on
top of the Oval Lagoon area.   The Crescent Ditch/Oval Lagoon
containment area would  then  be capped with 3 ft  of  imper-
meable materials to  seal in the contaminated soils.

The slurry  wall  would minimize uncontrolled dispersion  of
PCBs from the  Crescent  Ditch/Oval Lagoon area  through  the
soil or  groundwater.   Using  Mason & Hanger's equation  for
dispersion of  PCBs  (001) ,  if a wall with an  overall per-
meability of 10  7cm/sec were used,  migration  through  a  2-ft
slurry wall is expected to take 2 years,  dispersing  about
0.001 Ib/yr PCBs.  If  the  slurry  wall were cracked by  the
fluctuating water table, freezing,  or  other natural pheno-
mena, PCBs would escape at a much higher  rate.  Groundwater
monitoring wells would be constructed  to  provide  continuous
checks on the efficiency of the slurry.   The  State would be
required to provide maintenance under PL  96-510.

Using Mason &  Hanger's  equation  (001),  migration  through a
1-ft-thick layer of glacial till with an overall permeability
of 10 7 cm/sec would be expected  to take  1  year,  dispersing
about 0.001 Ib/yr PCBs.  If sandy zones were  encountered in
the glacial  till,  PCBs  could  escape  at  a higher rate.
Groundwater monitoring wells  would be constructed to provide
continuous checks on the efficiency of the  glacial  till.
The State would  be  required  to provide  maintenance  under
PL 96-510.

Capping of the North Ditch and the containment area  would
prevent percolation into the  contaminated area.   Future con-
struction projects that would cause disturbance to the  sur-
face and  underlying  soils  (trenching,  drilling,  digging,
etc.)  would not be allowed, to minimize deterioration of the
impermeable barriers.

This alternative would reduce the environmental hazards  now
posed by  the  PCB contamination in  the North Ditch  area.
Contaminated soils in  the  Crescent Ditch/Oval Lagoon area
would be contained in-place; the  reliability  of the slurry
wall and capping technologies and the  glacial  till is dis-
cussed in the  Reliability  section, below.   Approximately
19,400 yd3 of soil containing  about 3,400 Ib  of PCBs would
PD525.022                   6-107

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not be removed from the North Ditch.  The hydrologic  system
is currently  not  well enough understood to  determine the
extent of past or future  PCB contamination by  groundwater
movement from the North Ditch.   However,  the potential for
future groundwater contamination would be higher under this
alternative than  under  the other North Ditch  alternatives
because of the remaining contaminated soils.   While  capping
would prevent direct percolation into the contaminated area,
some dispersion of PCBs through  the groundwater could occur
because no containment wall would be present (080).  However,
the PCBs represent less than  1  percent of  all  the  PCBs now
found in the North Ditch/Parking Lot area.

This alternative  would not remove  approximately 19,400 yd3
of soil  containing  approximately 3,400 Ib of  PCBs in the
North Ditch area.

This alternative  would  have greater land use  impacts than
Alternatives 1 and 3.  The Crescent Ditch area  would  remain
at the existing ground elevation, and would  be  converted  to
a parking lot.  Future new uses  would be restricted  because
soil-disturbing construction activities could not be  allowed.
Landfilling of the Oval Lagoon  area with contaminated soil
and capping materials would  elevate it  about 10 feet above
the existing ground level.  No future uses of this area would
be possible.

Duration of Cleanup Activities

Construction of the drainage bypass is expected to take about
1 to 2 months.  Excavation activities are expected to take  a
total of 1 to 2 months, and construction of the clay  cap and
paving another 2  months.   If the water treatment plant were
not protected against freezing  weather,  dewatering effluent
could not be released to the plant during freezing conditions.
Excavation below  the  water table would  then  have  to take
place during nonfreezing weather.   The overall  duration for
this alternative  is estimated to be 4 to 6 months.

Impacts and Mitigation of Cleanup Activities

Excavation.  Contaminated  soils  would be excavated from the
North Ditch and Crescent Ditch areas by backhoe or front end
loader and transported to  the Oval  Lagoon  containment area.
Excavation of contaminated soils would also  be  required for
construction of the North  Ditch bypass  and installation of
the well points to control surface and groundwater.

An average  volatilization  rate   that can be  expected  from
exposed sand during excavation activities is 5,375 ug/m2/hr,
assuming average  PCB  concentrations in  the exposed sand to
be 1,000 ppm.  Volatilization that  would occur during these
PD525.022                   6-108

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activities could  be  minimized by  employing  the following
mitigation measures:

     •    Keeping the area exposed by excavation as small as
          possible.

     •    Performing the work in as short a time as possible,
          by using more or larger equipment.

     •    Covering the exposed material  not  at the working
          face with organic materials (such as digested acti-
          vated sludge, manure,  paper mill  sludge)  or with
          synthetic liners.

     •    Performing the work in the winter,  since  the  rate
          of volatilization during cold weather is less than
          during warm weather.

The highest reported concentration in the North Ditch soils
is about 100,000 ppm (001).  The predicted PCB concentration
in air during excavation would be about 200 ug/m3.  The vola-
tilization rate is predicted  to  be about 163,000 ug/m2/hr.
Typical concentrations range  from  500 to 5,000 ppm.   Pre-
dicted average PCB concentrations  in  the  air would be less
than 6.6 ug/m3.  The average volatilization rate is expected
to be less than 5,375 ug/m2/hr for soils with concentrations
of 1,000 ppm PCBs.  These values were extrapolated from data
for sand, assuming a 3.6-mph wind and an air  temperature  of
68°F  (007).  The  volatilization  rates  from  the sandy soils
of the North Ditch area are expected to be closely  approxi-
mated by these predictions.  By comparison,  the OSHA  standard
for maximum worker exposure to Aroclor  1242  is 1,000 ug/m3
in the air at  any time.   NIOSH  recommends  that workers not
be exposed to more than 1 ug/m3  in the air during  an  8-hour
period (007).   (See Health and Safety Requirements, later in
this section.)

Animals could  be disturbed  or  affected by  construction
activities that would  alter or remove their  habitats and
affect their normal daily and seasonal activities.  However,
such changes would  be  expected  to  affect relatively  few
species and individuals and would  be  far outweighed by the
benefits to be gained from  removal  of  the  contaminated
material.   Shorebirds, gulls,  and possibly  other species
coulc be attracted to the excavated areas (048) .

Water Treatment.  The  groundwater  removed by pumping from
the well  points  would be  fully contained  and processed
through a package water  treatment  plant.   Secondary  solids
discharged from the water  treatment plant would be treated
with other area solids.  All  water would be  treated to PCB
levels of below 1 ppb (the USEPA standard).   Treatment plant
effluent would be monitored  (by grab sampling and  24-hour
PD525.022                   6-109

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sampling) to ensure  that  discharges were below  1 ppb.   An
onsite laboratory would be  available to conduct the  water
quality  analyses.  Effluent  would be discharged into  Lake
Michigan or  a  sanitary sewer.   Water discharged  to  the
sanitary sewer system would  be  processed again through the
Waukegan municipal wastewater treatment plant and discharged
into the Des Plaines River.

Backfill of Excavated Areas.  The backfill of excavated areas
would require soils removal from an offsite borrow pit, causing
topographic and other minor local impacts to the borrow area.

Additional Environmental  Impacts.   Implementation of  this
alternative would also have the following impacts (048):

     Noise.  Noise would be  produced  by  construction,  exca-
     vation, and  transportation activities.   Although high
     noise levels could periodically occur in localized areas,
     they would be of relatively  short duration.  Noise  im-
     pacts could  temporarily diminish people's  enjoyment of
     the public beach adjacent  to the project area.

     Employment.  Construction  jobs  created  by the project
     would  temporarily  reduce  unemployment  in  the area.
     Employment levels would return to previous levels  at
     the conclusion of the project.

     Cultural Resources.  Cultural resources in  the Waukegan
     Harbor area  would  not be  adversely  affected.   It  is
     possible that the cleanup  of PCB-contaminated sediments
     would enhance the desirability of acquiring and retaining
     cultural resources in the  harbor area.

Health and Safety Requirements.   The  PCB-contaminated soil,
sediment, muck, dust, and water associated with  cleanup  acti-
vities present  potentially  significant  health hazards  to
workers  involved  in the cleanup.  Each specific  cleanup  acti-
vity and associated work function would  require the defini-
tion and enforcement of specific safety precautions and  levels
of protection.  Ecology and  Environment,  Inc.,  has  prepared
a  conceptual  safety  plan (Appendix).  The  plan calls for
protection measures  for workers who may be exposed to PCB-
contaminated materials.   Ambient air monitoring would  be
performed, and all workers would  require  appropriate  levels
of protection.  Depending on ambient air monitoring results,
respiratory and dermal  protection may be required downwind
of site  cleanup activities.  In addition to personal protec-
tion,  the  conceptual  safety plan specifies site entry pro-
cedures, decontamination  procedures,  work limitations,  and
material disposal requirements.  A detailed health and safety
plan would  be  prepared  during final design of  the selected
response measures.
PD525.022                    6-110

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Reliability

Excavation.  Excavation would be accomplished using backhoes
and  front  end loaders.  Conventionally  available devices
based on well-developed technology are feasible for the pro-
posed use.  Failure could occur  by  loss  of material during
excavation as a result of power loss, accident, or spilling.
Where material falls back into the working excavation, there
would be essentially no impacts.  The impact of spills would
be to deposit a quantity of PCB-contaminated solids at one
or more points on the site.  The impact of such spills could
be minimized by prompt cleanup  of  the spilled material and
of any  soil or  other  material  that  was contaminated by the
spill.

Water Treatment.  The water treatment system would use exist-
ing  technology  and  equipment  shown  to be effective in  PCS
removal.  The treatment plant would  include  a  clearwell  for
detention of treated effluent prior to discharge.  PCB concen-
trations in the clearwell would be monitored, and if adequate
removal were not achieved,  the water could be recycled through
the  plant until discharge  standards  (less than 1 ppb PCBs)
were met.

Slurry Walls.   Slurry walls are a relatively new construction
technique, in general use for about 20 years.  The technology
of construction is well developed, but long-term performance
data on the use of  slurry walls  as a  seepage  cutoff are  not
available.  While it is generally expected that slurry walls
would be relatively impervious, it is possible that "windows"
of more permeable material  could develop  during  slurry wall
construction.   Trench backfill is done below the  surface  of
the  slurry, so that visual  inspection of  the backfill  as  it
reaches its final position  is  not possible.   In  addition,
the upper part of the completed slurry wall could be cracked
by freezing, groundwater fluctuations, or other natural phe-
nomena.  The literature on the effect of PCBs on slurry wall
permeability is limited.   It is anticipated that there would
be no significant effects,  since clay  is  generally  accepted
as a  liner  for  licensed  PCB disposal sites.   However,  the
types of  slurry  wall  available  should be reviewed during
design.  If the slurry wall failed to achieve the  overall
average permeability  desired,  movement of PCB-contaminated
groundwater could occur more rapidly  than anticipated.   On
the other hand, slurry walls have been used  for  groundwater
control on many projects and have a good performance record.
The  containment area  would  be  monitored to permit  ongoing
evaluation of the effectiveness and integrity  of  the  slurry
walls and  clay  cap.  The  reliability of the  containment
could be  enhanced  with development  of additional  design
details:
PD525.022                   6-111

-------
     •    Freeze-thaw problems could be reduced by terminating
          the slurry and cap wall below the frostline.

     •    Use of a  flexible  membrane  for the cap could  be
          considered for more freedom in site grading.

     •    Should contaminant movement be detected, an inter-
          nal drainage system could be installed to maintain
          internal water levels  lower  than external levels
          so that any leakage would be into the  containment
          area.

Consideration of these types of details during design would
make this alternative effective in abating further  PCS  con-
tamination of the Waukegan area and Lake Michigan.  The type
of slurry wall material should  also  be evaluated  during
design.  Overall, the reliability of slurry walls to  reduce
the movement of  PCB-contaminated  groundwater  is  considered
good.

Glacial Till.  The glacial till covering the bedrock  in  the
Waukegan area is unsorted, glacier-deposited sediment,  con-
sisting of silt, clay, and lenses of sand,  in which pebbles,
cobbles, and boulders are  embedded.   The  thickness of  the
glacial till typically ranges from 50 to more than 100 ft.

Because of the  relatively  low permeability of the  glacial
till, dissolved substances would be unlikely to migrate more
than 20 to 30 ft, unless they reached a sandy zone of higher
permeability.  These zones could  permit deeper migration of
dissolved substances  (058).   Diffusion (the natural  force
acting to minimize concentration  differences) may also  dis-
perse the PCB oil in the glacial till pore water.

Because of  the limited  information available at the time
they prepared their report, Mason & Hanger did not recommend
any  alternatives  that  depended on the  underlying glacial
till to contain  the more  concentrated  PCB  materials  (001) .
Mason & Hanger  recommended additional  studies  be performed
to determine the reliability of the glacial till.

PCBs are heavier than water.  The PCBs could gravitate  down
through the glacial till as evidenced by the PCB penetration
into the  glacial till immediately adjacent to  former OMC
discharge points in the Crescent  Ditch (001).   Penetration
of PCBs has  occurred  at that location with a concentration
of 240 ppm found at a depth  of  about  5 ft  into  the glacial
till (001).

Capping.  The use of compacted  clay as  liners  and caps  for
chemical waste  landfills  is  a  well-developed  technology.
PD525.022                   6-112

-------
The use of asphaltic concrete as  a  runoff-accelerating  mem-
brane is also well  developed.   The clay cap could  develop
cracks due to moisture content variations, settlement, freez-
ing, or other natural phenomena.  The asphaltic concrete cap
would be used to help reduce the possibility of soil moisture
changes, thus reducing the possibility of developing  cracks
in the clay cap.  It is anticipated that  the asphaltic  con-
crete membrane would  require  periodic maintenance  to seal
cracks that will inevitably develop as the pavement ages.

The impact of cracking of  the cap system  would be to allow
additional surface water to infiltrate the ground,  and  pos-
sibly to permit minor amounts of  volatilized  PCBs to leave
the containment area.  If  infiltration  increased, it could
provide hydraulic head inside the contained area  that would
increase the flow of  PCB-contaminated groundwater from  in-
side the contained  area  to the surrounding  or underlying
soil.  This would  result  in further  PCB  contamination  of
adjacent and underlying soil.   The  amount of any such  un-
controlled release would be expected to be very small.  Over-
all, the reliability of the cap would be considered good.

Permit Requirements

Permit requirements are anticipated to include:

     •    Well water removal permit (State)

     •    IEPA permit for  construction of wastewater  treat-
          ment facilities

     •    USCOE Section 404 (disposal in waterways)  permit

     •    IEPA water quality certification on all USCOE  per-
          mits

     •    NPDES permit (State/Federal) for point-source  water
          discharge from the water treatment plant

     •    North Shore Sanitary  District  approval if water
          discharge goes to a sanitary sewer

     •    City of Waukegan construction permits

     •    Local land use approval

     •    IEPA (Division of Land  and Noise)  special waste
          hauler's permit

     •    USEPA toxic substances disposal approval
PD525.022                   6-113

-------
     •    IEPA approval if material  is disposed in a  cur-
          rently non-PCB-approved site

     •    Certification of Authority to haul PCB commodities
          (ICC and I1CC)

See Mason & Hanger's report  (003) for  further discussion of
applicable governmental regulations.
Subalternative I;  Select Excavation

Response Objectives

This subalternative would be  used  only  in conjunction with
Alternative 4A and 4B.   The most  highly contaminated areas
in the Crescent  Ditch/Oval  Lagoon  area  would be  excavated
and disposed  of  offsite.  Excavation, containment,  onsite
disposal, and capping for the rest  of the North Ditch area
would occur as described under Alternative 4A or 4B.

Because soils with the greatest PCB concentrations  would  be
removed  (about 440,500  Ib of  PCBs  in 5,500 yd3 of  soils),
this variation would  reduce the impacts  of possible  PCB
migration or  escape through the slurry wall and the glacial
till.  The reliability of the slurry  wall  and capping  tech-
nologies and the glacial till is discussed in the Reliability
Sections of Alternatives 4A and 4B.   Subalternative I  would
remove and dispose of offsite approximately 57 percent of
all the PCBs now found in the North Ditch/Parking Lot area.

With this  subalternative,  the Oval  Lagoon area would be
landfilled and  capped to about  10 to  15 ft above the
existing ground level.

Duration of Cleanup Activities

The excavation and offsite  disposal  of  the highly contami-
nated "hot spots" would add about 1  month to  the cleanup
activities of Alternative 4A or 4B.   Total project  duration
with this  variation  is   therefore estimated  to  be  5 to 7
months.

Impacts and Mitigation of Cleanup Activities

Excavation.   The highly  contaminated  soils have PCB concen-
trations greater  than  100,000 ppm  (001).   Volatilization
during excavation and loading of these soils is estimated to
be in the  range  of  163,000  ug/m2/hr.  Concentration in the
air above  the most contaminated soils  is  estimated to be
about 200 ug/m3.
PD525.022                   6-114

-------
Solids Removal and Disposal.  Excavated soil would be trans-
ported by  truck  to an offsite disposal  site.   The trucks
would have to be lined to prevent leakage.  Cover or closure
of the trucks would prevent spillage and volatilization dur-
ing transport.  Rules and regulations controlling the trans-
port of  toxic materials  promulgated by  the  USDOT,  USEPA,
IDOT, IINR, and other  applicable  regulatory  agencies would
be complied with.  These include  cleanup,  safety, and  spill
prevention and response measures.

Offsite disposal of excavated soil would require approximately
550 truck trips to the disposal site using a 10-yd3 capacity
truck.  The established full truck routes within the City of
Waukegan have sufficient capacity to accommodate the estimated
truck traffic, but some roadway congestion and roadway damage
could occur (048).  Some species of terrestrial animals could
come into  contact  with contaminated materials if any  loss
occurs during transport,  and the contamination could be passed
into other terrestrial food chains  (048) .

Disposal of the excavated soil would be in a licensed chemi-
cal waste  landfill,  and  would be  in compliance with State
and Federal standards for PCB waste disposal.  PCB materials
with concentrations greater than  50 ppm must be nonflowable
if they are to be  disposed  of in  a  chemical  waste landfill
(40 CFR 761).   This alternative assumes that the contaminated
soils can  be  excavated in  a nonflowable state, since  they
are mostly sand.

Reliability

Glacial Till.   The glacial  till covering the bedrock in  the
Waukegan area is unsorted,  glacier-deposited sediment, con-
sisting of silt,  clay, and lenses of sand, in which pebbles,
cobbles, and  boulders  are  embedded.   The thickness of the
glacial till typically ranges from 50 to more than 100 ft.

Because of the relatively  low permeability of the glacial
till, dissolved substances would be unlikely to migrate more
than 20 to 30 ft, unless they reached a sandy zone of higher
permeability.   These zones  could  permit deeper migration  of
dissolved  substances  (058) .   Diffusion (the natural force
acting  to  minimize  concentration differences)  may  also
disperse dissolved PCBs in the glacial till pore water.

Because of the  limited information available at  the time
they prepared their report, Mason & Hanger did not recommend
any alternatives  that  depended on  the  underlying glacial
till to contain the  more concentrated  PCB  materials  (001).
Mason & Hanger recommended  additional  studies  be  performed
to determine the reliability of the glacial till.
PD525.022                   6-115

-------
PCBs are heavier than water.  The PCBs could gravitate  down
through the glacial till as evidenced by the PCB penetration
into the glacial  till immediately adjacent to  former OMC
discharge points in  the  Crescent  Ditch (001).   Penetration
of PCBs has occurred  at  that  location  with a  concentration
of  240 ppm  PCB found at  a depth of 4 ft 9 in into  the
glacial till (001) .

Removing the very high concentrations  of  PCBs  near the OMC
outfalls would  remove the area where  the PCBs have  been
known to migrate into the glacial till.

Transportation.  Transportation would  be  accomplished using
dump trucks.  Failure could occur by  loss of  material from
the truck through  leakage,  spilling over  the  top, dusting,
volatilization, or spills resulting from vehicle accidents.

The impact of leakage, dusting, and volatilization would be
to dispense small amounts of PCBs all along the haul  routes.
These types of  uncontrolled release  could be minimized by
the use of tailgate seals and covers.

The impact of spills  would be to  deposit  a  quantity  of PCB-
contaminated solids  at  one or more isolated  points.  The
risk of spills over the top of the truck  could  be minimized
by use of a cover.   The  risk  of  vehicle accidents is rela-
tively small, but  it  could be compensated for  by  having a
response plan and team ready during hauling.

Permit Requirements

Permit requirements are anticipated to include:

     •    Well water  removal permit (State)

     •    IEPA permit for  construction of wastewater treat-
          ment facilities

     •    USCOE Section 404 (disposal  in waterways) permit

     •    IEPA  water quality certification on all  USCOE
          permits

     •    NPDES  permit  (State/Federal)  for point-source
          water discharge  from the water treatment plant

     •    North Shore Sanitary  District approval  if water
          discharge goes to a sanitary sewer

     •    IEPA  (Division  of Land and  Noise) special waste
          hauler's permit

     •    City of Waukegan construction permits
PD525.022                   6-116

-------
     •    Local land use approval

     •    Certification of Authority to haul PCB commodities
          (ICC and I1CC)

     •    USEPA toxic substances disposal approval

     •    IEPA approval if material  is disposed in a  cur-
          rently non-PCB-approved site

See Mason & Hanger's report  (003) for  further  discussion  of
applicable governmental regulations.
PD525.022                   6-117

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     Section 7
     ALTERNATIVES SUGGESTED FOR PUBLIC COMMENT
The preliminary, initial, and detailed development and evalua-
tion of alternatives were presented in the previous sections
of this report.  The development  and  evaluation  process  was
used to determine  the  remedial  action alternative for each
area that was cost-effective  (i.e., "the lowest cost alterna-
tive that is technologically  feasible and reliable and which
effectively mitigates  and minimizes  damage  to and provides
adequate protection of public health, welfare, or the en-
vironment"—Section 300.68(j) of the NCP).

The alternatives that  were retained from the  screening, pro-
cesses of Tasks  1  through  3  to the detailed  evaluation  of
Task 5 were considered technologically feasible and reliable
and would effectively  mitigate  and minimize damage to, and
provide adequate protection of, public health, welfare,  and
the environment.  The  economic evaluation (Section 5)  defined
the alternatives with  the least cost.  A summary  of the  de-
tailed cost estimates  and the pounds  of PCBs controlled is
presented in  Tables  7-1 and  7-2.  The  cumulative project
costs versus  the  cumulative  pounds of PCBs controlled are
shown on Figure 7-1.

The relative advantages and disadvantages of each alternative
are presented in Tables  7-3  through  7-6.  Alternatives for
each area were ranked  together  (e.g., Slip No. 3 Alternatives,
etc.).  The relative ranking of  (0)  was used as the  base
value.  If one alternative was  more favorable than another,
it was assigned a  relative ranking of (+).   Less favorable
alternatives were assigned the relative ranking of (-).

Section 104(c)[4] of CERCLA requires that the  need for pro-
tection of the public  health and welfare and the environment
at the OMC site be balanced against the amount of money avail-
able in the fund to respond to other sites,  which also present
a threat to public health and welfare and the environment.
Accordingly,  the lead  agency must consider the need to respond
to other releases  in determining  the  appropriate extent  of
remedy for fund-financed response at the OMC site.

Based on this  feasibility study,  the five  cleanup actions
listed below  comprise  USEPA's recommended  cleanup plan for
the OMC site.

     •    Slip No. 3 and Upper Harbor;  Subalternative I.  This
          subalternative would be used only in conjunction with
          Alternative  6B, PCB-contaminated  sediment,  sand,
          and silt would be dredged from the  localized area
          near the former OMC outfall.  This material  contains
          the greatest PCB concentrations in  the  harbor  and
          represents 92 percent of all the PCBs now found in
          Slip No. 3 and the Upper Harbor.   This alternative

PD998.059                    7-1

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-------
                                       Table  7-3

                                   RANKING PROCEDURE
                                      SLIP NO.  3
                               OMC HAZARDOUS  WASTE SITE
                                  WAUKEGAN, ILLINOIS
                                       13-5M28.0
                                                    Ranking Numbers
Alternatives
Criteria
Capital cost
Life cycle cost
Long-term environmental impact
Short-term environmental impact
Implementation time
Constructibility
Reliability
Health risks
Safety requirements
Land reuse
Complexity of operation
2B 2D 3 6A
0
0
+ + + -
0
+ + - 0
- - 0
+ + + -
0000
0
+ + + 0
0
6B
+
+
-
0
0
0
-
0
0
0
0
6AI
0
0
0
-
0
0
0
0
-
0
-
6BI
0
0
-
-
0
0
-
0
-
0
-
Note:  - is least favorable; + is most favorable.
       2B: Dredge-Dewater in Lagoon-Fix-Dispose
       2D: Dredge-Dewater in Barges-Fix-Dispose
        3: Dredge-Dewater in Lagoon-Dispose
       6A: Contain-Dredge-Cap
       6B: Contain-Dredge Part of Upper Harbor-Cap
      6AI: Select Excavation-Contain-Dredge-Cap
      6BI: Select Excavation-Contain-Dredge Part of Upper Harbor-Cap
 PD998.060.
7-4

-------
                                   Table 7-4

                               RANKING PROCEDURE
                                 UPPER HARBOR
                           OMC HAZARDOUS WASTE SITE
                              WAUKEGAN, ILLINOIS
                                   13-5M28.0
                                                   Ranking Numbers
Alternatives
Criteria
Capital cost
Life cycle cost
Long-term environmental impact
Short-term environmental impact
Implementation time
Constructibility
Reliability
Health risks
Safety requirements
Land reuse
Complexity of operation
2B 3
-
-
+ 0
0 +
+
+
-
0 0
0 0
+
0
6A
0
0
-
0
0
0
-
0
0
0
0
6B
+
-
-
0
0
0
-
0
0
0
0
6AI
0
0
0
-
0
0
0
0
-
0
__
6BI
0
0
-
-
0
0
-
0
-
0
_
Note:  - is least favorable; + is most favorable.
       2B:  Dredge-Dewater in Lagoon-Fix-Dispose
        3:  Dredge-Dewater in Lagoon-Dispose
       6A:  Contain-Dredge-Cap
       6B:  Contain-Dredge Part of Upper Harbor-Cap
      6AI:  Select Excavation-Contain-Dredge-Cap
      6BI:  Select Excavation-Contain-Dredge Part of Upper Harbor-Cap
PD998.061.
7-5

-------
                                   Table 7-5

                               RANKING PROCEDURE
                                  NORTH DITCH
                           OMC HAZARDOUS WASTE SITE
                              WAUKEGAN, ILLINOIS
                                   13-5M28.0
                                                   Ranking Numbers
            Criteria
Capital cost

Life cycle cost

Long-term environmental impact

Short-term environmental impact

Implementation time

Construetibility

Reliability

Health risks

Safety requirements

Land reuse

Complexity of operation
                                                    Alternatives
              4A
_4B     4AI

 0      0

 0      0

        0

 0      0
4BI

 0

 0
-
0
0
0
0
-
0
0
0
0
0
0
-
0
0
-
0
-
0
0
Note:  - is least favorable; + is most favorable.
       1:  Excavate-Dispose
       3:  Excavate-Fix-Dispose
      4A:  Excavate-Contain-Cap
      4B:  Excavate-Contain Part of E-W Portion of the North Ditch-Cap
     4AI:  Select Excavation-Excavate-Contain-Cap
     4BI:  Select Excavation-Excavate-Contain Part of E-W Portion of the
           North Ditch-Cap
PD998.062.
7-6

-------
                                  Table 7-6

                              RANKING PROCEDURE
                                 PARKING LOT
                          OMC HAZARDOUS WASTE SITE
                             WAUKEGAN, ILLINOIS
                                  13-5M28.0
                                                   Ranking Numbers
                                                    Alternatives
                      Criteria                     1
        Capital cost                                             +

        Life cycle cost                                          +

        Long-term environmental impact             +      +      0

        Short-term environmental impact                          +

        Implementation time                        +      +      -

        Constructibility                           00+

        Reliability                                +      +      0

        Health risks                               000

        Safety requirements                        -      -      0

        Land reuse                                 +      +      0

        Complexity of operation                    -      -      0
        Note:  - is least favorable; + is most favorable.
               1:   Excavate-Dispose
               3:   Excavate-Fix-Dispose
               4:   Contain-Cap
PD998.062.                             7-7

-------
          would remove, fix,  and dispose of  an  estimated
          5,700 yd3 of PCB-contaminated material containing
          about 286,500 Ib of PCBs.  The material  would be
          disposed of offsite in a  licensed  chemical  waste
          landfill.  The estimated  Order-of-Magnitude cost
          is $3,150,000.

     •    Slip No. 3  and  Upper  Harbor:  Alternative 6B.  A
          cofferdam with a slurry wall would be constructed
          around the perimeter  of  Slip  No.  3, part of  the
          Upper Harbor sediments would be dredged  into the
          contained area,  and then the  containment  area would
          be capped.   The estimated Order-of-Magnitude  cost
          is $6,100,000.

          The emerging technology,  such as  the  Pollution
          Sciences extraction or bacterial  destruction tech-
          nique, should be reevaluated before  placement of
          the cap to determine their cost effectiveness.

     •    North Ditch Area:   Subalternative I.  This subalter-
          native would be  used only in  conjunction  with Alter-
          native 4B.   PCB-contaminated  soil would be excavated
          from the localized  areas in the Crescent  Ditch and
          Oval Lagoon.  This  material contains the  greatest
          PCB concentrations  in the North Ditch area and
          represents 57 percent of all  the  PCBs now found in
          the North Ditch/Parking Lot area.   This alternative
          would remove and dispose of an estimated  5,500 yd3
          of PCB-contaminated soil containing about 440,500
          Ib of PCBs.  The soil would be disposed of offsite
          in a licensed chemical waste  landfill.   The estimated
          Order-of-Magnitude  cost is $740,000.

     •    North Ditch Area;   Alternative 4B.   PCB-contaminated
          soil would be contained and capped in the Crescent
          Ditch/Oval Lagoon area.  A pipeline to bypass  the
          east-west portion of the North Ditch would also be
          constructed  (with partial excavation of PCB-contami-
          nated soil to install the pipe).   The PCB-contami-
          nated soil  from  the bypass excavation would be
          placed in the Crescent Ditch/Oval Lagoon  area before
          capping the area.  The estimated Order-of-Magnitude
          cost is $4,210,000.

     •    Parking Lot Area;  Alternative 4.   PCB-contaminated
          soil would be contained and capped  in the Parking
          Lot area.   The  estimated  Order-of-Magnitude cost
          is $3,210,000.

The total estimated Order-of-Magnitude  cost to implement the
above alternatives is $17,410,000.
PD998.059                    7-8

-------
Public comments will  be  received during the 30-day  public
comment period.  The  USEPA Record of Decision  issued at  the
end of the public comment period will determine specifically
the alternatives to be  implemented,  with modifications,  if
any, resulting from public comment.

A conceptual design will be prepared for the remedial action
alternative(s) selected by USEPA.

The following individuals participated in the preparation of
this feasibility study:

          U.S. Environmental Protection Agency

          Mr. Jack Braun
          Environmental Scientist
          U.S. EPA/Remedial Response
          Section 2 5HR-13th Floor
          230 S. Dearborn
          Chicago,  Illinois  60604
          (312) 886-6214

          CH2M HILL

          Mr. Stewart L. Davis
          Project Manager
          CH2M HILL
          2020 S.W. Fourth Avenue
          Portland, Oregon  97201
          (503) 224-9190
PD998.059                    7-9

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                                       u. o o o$ a
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                                                 §
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                                                 to
                                                 
-------
     Section 8
• •  BIBLIOGRAPHY

001  An Engineering Study for the Removal and Disposition of
     PCB Contamination in the Waukegan Harbor and North Ditch
     at Waukegan, Illinois, Final Report.  Prepared for USEPA
     Region V, Chicago, Illinois.  Lexington, Kentucky: Mason
     & Hanger—Silas Mason Co., Inc.  January 1981.

     The purpose of the report was to perform an engineering
     study to recommend a  solution  for removing,  fixing,  or
     otherwise treating the PCB-contaminated soils and sedi-
     ments located  in  and near Waukegan Harbor,  Illinois.
     The study  recommends  removal,  storage, and  treatment
     alternatives and gives estimates of associated costs.

     This report reviews  previous studies  (before January
     1981)  conducted to define  the  PCB  problem of Waukegan
     Harbor.   It also  provides  a  summary of existing field
     and  laboratory  data and  applicable  governmental
     regulations.

002  Draft—Environmental  Impact  Statement  on  the Waukegan
     PCB Abatement  Project.   Prepared for USEPA  Region  V,
     Office of Superfund, Chicago, Illinois.  Chicago, Illi-
     nois:   WAPORA, Inc.  December 11, 1981.

     The document defines the PCB problem at Waukegan Harbor,
     reviews alternative  courses  of action  to  remove the
     PCBs,  and  gives  an environmental analysis of the im-
     pacts of each action.

     The conclusion arrived at  is that any  adverse environ-
     mental impacts resulting  from  an abatement action  in
     the harbor are outweighed  by the public health  bene-
     fits.   Not a public document.

003  An Engineering Study for the Removal and Disposition of
     PCB Contamination  in  the Waukegan  Harbor,  and  North
     Ditch at Waukeqan,  Illinois.   Prepared for USEPA Re-
     gion V,  Chicago,  Illinois.   Lexington,  Kentucky:  Mason
     & Hanger—Silas Mason Co., Inc.  January 1981.

     The purpose of the report was to perform an engineering
     study to recommend a  solution  for removing,  fixing,  or
     otherwise treating the PCB-contaminated soils and sedi-
     ments located in  and  near  Waukegan  Harbor.   The study
     recommends removal, storage, and treatment alternatives
     and gives estimates of associated costs.

     This report gives a review of  previous  studies  (before
     January 1981)  conducted  to define  the  PCB problem  of
     Waukegan Harbor.   The report also provides a summary of
     existing field and laboratory data  and  applicable govern-
     mental regulations.

PD998.057                    8-1

-------
004  An Engineering Study for the Removal and Disposition of
     PCS Contamination in Waukegan Harbor and North Ditch at
     Waukegan, Illinois.  Prepared for USEPA Region V, Chi-
     cago, Illinois.  Lexington,  Kentucky:   Mason & Hanger—
     Silas Mason Co., Inc.  January 1981.

     The appendices  consisted of  summaries  of  samples col-
     lected in Waukegan Harbor to define contamination limits,
     a discussion on environmental considerations  resulting
     from failure to remove PCS,  and a report on the  dredge
     spoil treatment parameters developed  from bench scale
     laboratory treatment tests.

005  Dawson,  G.W.,  and  J.L.  Goodier.   Evaluation of Alter-
     natives   for  Removal/Destruction of PCS  Contaminated
     Sediments in Waukeqan Harbor.  Prepared for USEPA, Cin-
     cinnati, Ohio.  Richland, Washington:   Battelle, Pacific
     Northwest Laboratories.

     The purpose of this report was to evaluate alternatives
     for the removal and/or destruction  of  PCB-contaminated
     sediments in Waukegan Harbor and the North  Ditch.   The
     report contains a  site  description, a preliminary as-
     sessment and evaluation of alternatives, and evaluation
     recommendations.   The  alternatives  addressed  were in-
     place destruction, in-place  fixation or immobilization,
     and removal and disposal of  contaminants.

006  Karnauskas, Robert J.  Subsurface  Investigation,  North
     Ditch Area Outboard Marine Corporation, Waukegan, Illi-
     nois .  Prepared for  USEPA Region V, Chicago,  Illinois.
     Madison, Wisconsin:  Warzyn  Engineering, Inc.   July 29,
     1980.

     The purpose of this  report  was  to present the results
     of the  subsurface  exploration performed in the  North
     Ditch area.   The  report consisted of  a discussion  of
     the drilling,  sampling, and  testing procedures.  Thirty-
     nine  soil  borings  were drilled to  the till layer at
     depths of 25 to 35 feet.  Soil  boring  logs, the  boring
     logs  for  the  monitoring wells,  and corings were in-
     cluded in the  report.

007  Volatilization  of  PCBs  During Planned Waukegan Harbor
     Cleanup  Operations,  Literature  Review.  Prepared  for
     USEPA Region V, Chicago, Illinois.  Lexington, Kentucky:
     Mason & Hanger—Silas Mason Co., Inc.   May 1981.

     The purpose of the report was to define the PCB vola-
     tilization problem as it applies to the proposed dredg-
     ing,  dewatering, and final  excavation of  the  PCB con-
     taminated  sediments  and soils at Waukegan, Illinois.
     The report contains  a  literature  review of  PCBs,  esti-
     mates of PCB  volatilization  during Waukegan  Harbor
PD998.057                    8-2

-------
     cleanup, and  recommendations  for appropriate control
     measures.

008  An Engineering Study for the Removal and Disposition of
     PCS Contamination in the Waukegan Harbor and North Ditch
     at Waukegan Harbor, Addendum to Final Report.  Prepared
     for USEPA Region V, Chicago, Illinois.  Lexington, Ken-
     tucky:  Mason & Hanger—Silas Mason Co., Inc.  May 1981.

     This addendum presents the results of the soil analysis
     work performed on  the core  borings  collected from the
     North Ditch in  June  1980  and from Waukegan Harbor  in
     November 1980  and  March 1981.  Drawings  showing  the
     location of the subsurface borings and  the boring logs
     are also included.

009  Hydrogeologic Investigation, Outboard Marine Corporation,
     Waukegan,  Illinois.   Prepared  for USEPA Region V and
     JRB and Associates.  Madison, Wisconsin:  Warzyn  Engi-
     neering, Inc.   September 20, 1979.

     This document contains the results of the hydrogeologic
     investigation performed at the Waukegan Harbor site  of
     PCB contamination.   The investigation included 15 soil
     borings, collection  and  field classification of  soil
     samples, groundwater  monitoring  wells,  boildown  per-
     meability tests, water level measurements, and survey-
     ing.  A site  topography map, a water table  map,  and
     geologic cross sections are presented.

010  OMC Technical and Witnessing Case Support Hydrological
     Study of Ground Water, Final Report.   Prepared for USEPA,
     Office of Water Enforcement, Washington, D.C.  McLean,
     Virginia:   JRB Associates, Inc.  February 10, 1981.

     The purposes of this report were to document the  source
     of groundwater contamination  and  to  determine whether
     PCBs have been released into Lake Michigan.   The  report
     describes drilling,  sampling,  and testing procedures
     and presents an interpretation of the groundwater hydro-
     logy.  Cross  sections showing  the  groundwater flow
     direction are also  included.

Oil  Sediment and  Shore Sample  Collection, Waukegan  Harbor
     Slip #3.  Prepared  for USEPA Region V, Chicago,  Illinois,
     and Mason & Hanger—Silas  Mason Co., Inc.    Madison,
     Wisconsin:   Warzyn  Engineering, Inc.   May 26, 1981.

     This report describes  soil  sampling  and testing  per-
     formed during March 16  through March 25,  1982, at the
     Waukegan Harbor Slip No. 3.  The purpose of the  sampling
     program was to obtain soil  samples at specified depths
     for PCBs and to test particular engineering properties
     of the organic clayey silt  (muck).
PD998.057                    8-3

-------
012  Specifications for  Dredging  and Water  Treatment  for
     Removal of  PCB Contamination.  Lexington,  Kentucky:
     Mason & Hanger—Silas Mason Co., Inc.   August 31,  1981.

     Specifications contained  in  this  document  relate  to
     dredging and water  treatment  for removal  of PCBs  from
     Waukegan Harbor.   Sections contained herein are:

     •    Site Work   (describes general, character of soil
          materials to be encountered)

     •    Temporary Facility  Controls  (utilities  such  as
          water,  telephone, sewage, and  enclosures)

     •    Maintenance and  Operation (associated  with  the
          removal of PCB-contaminated material,  storage of
          contaminated material in  a lagoon, and treatment
          of slurry water and rainwater)

     •    Equipment (package water treatment system)

013  Plan for Removal and Disposal of PCB Contaminated Soils
     and Sediments at Waukegan, Illinois.  Prepared for USEPA
     Region V, Chicago,  Illinois.   Lexington,  Kentucky:
     Mason & Hanger—Silas Mason Co., Inc.   September 1980.
                                                   »
     This document presents background  information, an exca-
     vation plan  for  the North Ditch,  and a dredging plan
     for Waukegan Harbor, a treatment plan for  settling  and
     dewatering of  dredged  sediments, and  a  disposal plan.
     The document contains typical  cross sections  and costs
     for the work.

014  Final Estimate  for  Dredging  and Water  Treatment  for
     Removal of PCB Contamination in Waukegan Harbor, Wauke-
     qan, Illinois.  Lexington, Kentucky:  Mason & Hanger—
     Silas Mason Co., Inc.  September 4,  1981.

     This report  gives a detailed  breakdown  of costs.   The
     Most Probable Construction Cost is  also given for dredg-
     ing and water  treatment  to remove  PCBs from  Waukegan
     Harbor  as  described in  drawings  dated September  1,
     1981, and specifications dated August 31,  1981.

015  North Ditch  Bypass, Outboard Marine Corporation Dis-
     posal of  Excess  Excavated Material and Pumpage from
     Trench Dewatering.  Chicago,  Illinois:  USEPA Region V.
     January 7, 1980.

     This paper describes  requirements  for the disposal of
     excess excavated materials resulting  from construction
     of  the  North Ditch bypass and  the  amount of pumpage
     required  for dewatering  for the construction of the
     North Ditch bypass.
PD998.057                    8-4

-------
016  An Engineering Study for the Removal and Disposition of
     PCB Contamination  in the Waukegan  Harbor and North
     Ditch at  Waukegan,  Harbor—Second Addendum  to  Final
     Report.    Prepared  for  USEPA  Region V,  Chicago,
     Illinois.  Lexington, Kentucky:  Mason  &  Hanger—Silas
     Mason Co., Inc.  March 1982.

     This second addendum incorporates  the  results of the
     analysis work performed on the  additional core borings
     collected from Waukegan Harbor  in September  1980.   The
     samples were collected to further define  the PCB con-
     tamination.   The report presents revised  quantities of
     contaminated muck, sand,  and clay.

017  Work Plan for  Engineering Design of  the Bypass  of  the
     North Ditch at  Outboard  Marine Corporation,  Waukegan,
     Illinois.  Prepared  for USEPA,  Cincinnati, Ohio.  West
     Chester, Pennsylvania:  Roy F. Weston,  Inc.,  Environmen-
     tal Consultants/Designers.  August 28,  1981.

     This document  presents a  work plan  and project  costs
     for the  "Design of  the  North Ditch Bypass  Outboard
     Marine Corporation, Waukegan, Illinois."

018  Final Estimate  for  Lagoon and Treatment Facility for
     Removal of PCB Contamination in Waukegan Harbor,  Wauke-
     gan, Illinois.  Lexington, Kentucky:  Mason  & Hanger—
     Silas Mason Co., Inc.  July 1, 1981.

     This report gives a  detailed breakdown  of costs  and an
     estimate of most  probable construction cost  for the
     proposed lagoon and  associated  water treatment facili-
     ties as described in drawings dated June  12,  1981,  and
     specifications dated June 15, 1981.

019  Draft Work Plan Feasibility Study Motco Site, LaMarque,
and  Texas.   Prepared for USEPA Region IV.   Montgomery,  Ala-
020  bama:   CH2M HILL.   February 11, 1983.

     Example Work Plan (2 copies).  Not a public document.

021  The PCB  Contamination  Problem in Waukegan,  Illinois.
     Chicago, Illinois:  USEPA Region V.   January 21,  1981.

     This report describes the extent of  current (up  to  1981)
     knowledge of PCB  contamination  at the  Waukegan  Harbor
     site.   It discusses  the various engineering  options
     which have been examined  for cleaning up  or mitigating
     the contamination and identifies a  set  of "preferred"
     options.  The  report summarizes the possible funding
     sources and concludes that  it  will  be  the constraints
     of the funding mechanisms that  shape the  final  execu-
     tion of the project.
PD998.057                    8-5

-------
022  Capper, Chris.  Authorization to Proceed with Remedial
     Planning and Implementation at the OMC Hazardous Waste
     Site on Waukegan, Illinois.  Office of Solid Waste and
     Emergency Response.

     The purpose of the memorandum was to request authorization
     to undertake remedial planning and implementation actions
     at the  OMC  facility.   The memorandum consisted  of a
     background description and the following recommendations:

     •    The existing complaint be  amended  to ask for an
          injunctive  relief  pursuant to  Section 106 and
          reimbursement under Section 107 for USEPA monies.

     •    The USEPA begin settlement negotiations.

     •    The USEPA provide  authorization to proceed with
          the proposed remedial action.

°23  Maps;  (1) Top of Muck Layer;  (2) Bottom of Muck  Layer;
      (3) Thickness of Muck Sediments;  (4) Core Boring Loca-
     tions 1976-1980.   Lexington, Kentucky:   Mason & Hanger—
     Silas Mason Co.,  Inc.

     Maps of harbor.

024  Miscellaneous Maps from USEPA Files.

     Contents of Folder

      •   Figure 7, Extent of PCB Contamination in Waukegan
          Harbor by Concentration

      •   Plot Plan

      •   Conceptual Design of Lagoon Cross Sections

      •   Sounding, November 1980

      •   Xerox of U.S. Geological Survey Map of Waukegan (5
          copies)

      •   State of Illinois, Department of Registration,
          Geological Survey Division, Urbana, Illinois, Map
          of Waukegan

      •   Lagoon Plan and Section

      •   Cofferdam Plan and Elevation

      •   Silt Curtain Plan and Elevations

      •   Location Map

      •   Miscellaneous Map of Waukegan

PD998.057                    8-6

-------
025  Bedard, Judith A.  Additional Support Information, Wauke-
     gan Harbor  Litigation.   Prepared for USEPA  Region  V,
     Chicago, Illinois.   White  Plains,  New York:   Malcolm
     Pirnie.  July 7, 1982.

     This document presents  a brief history  of  the Upper
     Hudson River PCB problem and  project description, key
     design criteria, and cost/benefit analysis for the fol-
     lowing PCB-related projects:

     •    The Fort Edward Terminal Channel Excavation and
          Remnant Pool Deposit  Mitigation completed by the
          NYSDEC in 1978

     •    The Hudson River PCB Reclamation Project

     In addition, dredging production rates  are  presented
     for the alternative dredging  schemes developed as part
     of the Hudson River PCB Reclamation Project.

026  Harris, Rosalind Mason.  Waukegan Harbor PCB Fish Levels,
     Prepared for USEPA Region V,  Chicago, Illinois.   White
     Plains, New York:  Malcolm Pirnie.  July 9, 1982.

     This document summarizes existing data and  information
     on the  extent  of fish PCB  contamination in Waukegan
     Harbor and Lake Michigan.   The results of in-situ live
     carp bioconcentration and depuration studies were under-
     taken in Waukegan  Harbor,  and laboratory studies are
     also discussed.   Finally, estimates of the value of the
     commercial and  recreational fishery in  the Waukegan
     area are discussed in relation to present PCB levels of
     commercially and recreationally important species.

027  Roberts, S.A.  Waukegan  Harbor Slip  No.  3—PCB Loading
     Rates.   Prepared for USEPA Region V, Chicago, Illinois.
     White Plains, New York:  Malcolm Pirnie.   July 21, 1982.

     This document presents potential PCB loading rates  of
     groundwater discharging through Slip No.  3 for two scen-
     arios :

     •    Slip No. 3 filled with clean sand

     •    Slip No. 3  filled with dredge material from ad-
          joining areas of the harbor

     The loading rates determined were 0.0005 pound per  day
     for clean sand  and  0.00003 pound per day for  dredged
     material.

028  Mulligan, J.B.   Waukegan Harbor PCB  Problem.   Prepared
     for USEPA Region V,  Chicago,  Illinois.   White  Plains,
     New York:  Malcolm Pirnie.   August  4, 1982.
PD998.057                    8-7

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     This document presents preliminary cost estimates for a
     number of alternative methods of reducing the potential
     for environmental danger from PCB contamination  in the
     Waukegan Harbor area.  Alternatives for the harbor and
     for the North Ditch and Parking Lot area are described,
     and associated costs have been developed.

029  Brownell, R.P.  Waukegan  Harbor.   Prepared for  USEPA
     Region V, Chicago, Illinois.  White Plains,  New York:
     Malcolm Pirnie.  August 5, 1982.

     This document lists the alternatives evaluated and recom-
     mends  elimination  of further  evaluation  on  the No
     Action alternative and on the Incineration alternative.

030  Volatilization.  Prepared for USEPA Region V, Chicago,
     Illinois.  White  Plains,  New York:   Malcolm Pirnie.
     August 5, 1982.

     This document calculates volatilization of PCBs in terms
     of solubility in the water  column based on literature
     and on Waukegan area data  reported by M.  T.  Kontaxis.
     It also presents two methods for estimating PCB loss.

031  Shahabian, H.L.  Waukegan  Harbor  Siltation.   Prepared
     for USEPA Region V,  Chicago,  Illinois.   White Plains,
     New York:  Malcolm Pirnie.  August 5,  1982.

     This document  presents  a  review of available reports
     and data related to sedimentation/siltation of Waukegan
     Harbor.  It estimates the  amount  of solids that could
     reach Slip No. 3 and discusses  the  fluctuation  of lake
     water levels.

032  Mann, M.I.,  and  S.A.  Roberts.  Waukegan North  Ditch.
     Prepared for USEPA Region V,  Chicago,  Illinois.  White
     Plains, New York:  Malcolm Pirnie.  August 6, 1982.

     This document presents a discussion of the following:

     •    Do previous estimates  for  surface  water  discharge
          from the  North  Ditch to the  lake  consider only
          sediment transport or  do they include a  soluble
          component as well?

     •    Do soluble PCBs absorb and then settle?

     •    What is the estimated  effect of  filling  the North
          Ditch?

033  Waukegan EPA Folder.  USEPA Region V,  Chicago, Illinois.

     This  folder  contains a  duplicate copy  of document
     No. 05-5M28.0/040—Preliminary  Screening  Assessment
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     Site Selection  and  Evaluation for a  Hazardous  Waste
     Disposal Site—C 9400, a  draft list  of appendices  to
     the EIS, a draft of the Summary to the EIS,  additional
     information for  Sections  1.2.4,  3.1.9, and  4.1.8  of
     Appendix C, and graphs on inhibition  of phytoplankton
     versus water column PCS concentrations.

034  Final Site  Selection  and  Evaluation  for  a Hazardous
     Waste Disposal  Site—C 9400.   Prepared for Mason and
     Hanger—Silas Mason Company,  Inc., and USEPA  Region V,
     Chicago, Illinois.  Madison,  Wisconsin:   Warzyn Engi-
     neering, Inc.   December 23, 1980.

     The purpose of the work was to perform final evaluations
     of potential alternatives  for PCB-contaminated  dredge
     material disposal.   The   sites considered  included:
     Browning-Ferris Industries  (BFI)  landfill near  Zion,
     Illinois,   the  Clermont   Environmental  Reclamation
     (CECOS)  landfill site near Williamsburg,  Ohio,  and  the
     Outboard Marine Corporation  (OMC)  property.   The sites
     were evaluated  with  respect  to their environmental,
     socioeconomic, engineering, and transportation  charac-
     teristics  and the costs associated with the development
     and use of each site for  PCB-contaminated dredge material.

035  Thomann, R.V., and M.T. Kontaxis.   Mathematical  Model-
     ing Estimate of Environmental  Exposure Due  to PCB-Con-
     taminated  Harbor Sediments of Waukegan Harbor and North
     Ditch.   Prepared for USEPA, Cincinnati, Ohio.   Mahwah,
     New Jersey:  HydroQual, Inc.  February 1981.

     This report presents the  results of a  study on estimating
     environmental exposure due to PCB-contaminated sediments
     of the Waukegan Harbor area to provide EPA with  technical
     support for the litigation between USEPA and OMC.

     A mathematical  model  of  the  harbor was  prepared and
     indicated  that, at the time of the report (1981), about
     10 kg/yr of PCS was  reaching  Lake Michigan  from the
     harbor.

036  Thomann, R.V., and M.T. Kontaxis.   Mathematical  Model-
     ing Estimate of Environmental  Exposure Due to PCB-Con-
     taminated  Harbor Sediments of Waukegan Harbor and North
     Ditch.   Prepared for USEPA, Cincinnati, Ohio.   Mahwah,
     New Jersey:  HydroQual, Inc.  February 1981,

     This report presents the  results of a  study on estimat-
     ing environmental exposure due to  PCB-contaminated  sedi-
     ments of the Waukegan Harbor  area  to  provide  EPA with
     technical  support for the litigation  between  USEPA  and
     OMC.
PD998.057                    8-9

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     A mathematical model  of the harbor was  prepared and
     indicated that,  in  1981,  about 10 kg/yr  of PCB was
     reaching Lake Michigan from the harbor.

037  Feasibility Report,  Dredging of PCB-Contaminated River
     Bed Materials, Upper Hudson River, New York, Volume 2--
     Engineering Studies.  Prepared for New York State  De-
     partment of  Environmental Conservation,  Albany,  New
     York.  White Plains, New York:   Malcolm Pirnie.   1978.

     This document evaluates the feasibility and cost of dredg-
     ing PCB-contaminated bed materials from the Upper Hudson
     River, between the  Federal  Dam at Troy and Lock 7  at
     Fort Edward.  This document consisted of an introduction;
     descriptions of existing conditions,  dredging technology,
     disposal sites, return flow treatment, alternative systems
     for total PCB removal, and alternatives for partial PCB
     removal; and the findings, conclusions,  and recommenda-
     tions of the study.

038  Outboard Marine  Corporation,  Waukegan Harbor Boring,
     Waukegan, Illinois—C 9791.  Prepared for Mason  &  Han-
     ger—Silas Mason  Company, Inc.,  and  USEPA Region V,
     Chicago, Illinois.  Madison, Wisconsin:   Warzyn Engi-
     neering, Inc.  August 5, 1980.

     This document presents the results for soil samples col-
     lected on July 1 and  2, 1980,  at  Waukegan Harbor.   The
     purpose of  the work was to collect bottom  sediments,
     underlying cohesive soils, and harbor water for  chemi-
     cal analysis and determination of engineering properties.
     The report  consisted  of an introduction; descriptions
     of chain of custody, sample collection,  field procedures,
     sediment and soil properties,  six soil boring logs, and
     laboratory test results.

039  Sand  Sample  Collection, Waukegan Harbor  Slip No.  3,
     Waukegan, Illinois—C 9560.  Prepared for Mason  &  Han-
     ger—Silas Mason  Company, Inc.,  and  USEPA Region V,
     Chicago, Illinois.  Madison, Wisconsin:   Warzyn Engi-
     neering, Inc.  January 6, 1981.

     This document presents the results for sediment samples
     collected between November 19 and 22, 1980, at Waukegan
     Harbor  Slip  No.  3.   The  purpose  of  the work was  to
     obtain soil samples for PCB analysis and to test parti-
     cular engineering properties of the  sediment.   The re-
     port  consisted of  an introduction,  descriptions  of
     chain of custody, sample  collection,  field and sample
     preparation procedures,  laboratory  test results,  and
     six soil boring logs.

040  Preliminary Screening Assessment,  Site  Selection,  and
     Evaluation for a Hazardous Waste Disposal Site—C  9400.
PD998.057                   8-10

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     Prepared for Mason & Hanger—Silas Mason Company, Inc.,
     and USEPA Region V, Chicago, Illinois.  Madison, Wiscon-
     sin:  Warzyn Engineering, Inc.  October 29, 1980.

     The purpose of the work is to screen specific sites for
     potential PBC-contaminated  dredge material  disposal,
     based  on  selected physical/environmental  and socio-
     economic criteria.  This report presents the results of
     preliminary screening of hazardous waste disposal sites.

041  An Estimate of Sediment Movement in North Ditch, Wauke-
     gan, Illinois.  Prepared  for  USEPA Region V, Chicago,
     Illinois.   Champaign, Illinois:  United States  Depart-
     ment of the Interior, Geological Survey.  1980.

     Stage-discharge and  sediment-discharge  to stream-dis-
     charge relations  have been  developed for  North Ditch,
     Waukegan,  Illinois.  Indirect methods were used  to  ob-
     tain a stream-discharge rating curve, and discharge and
     stage measurements were used  to  adjust  that relation.
     Transport curves  for discharge  of both  measured sedi-
     ment and bed material were developed from measured sedi-
     ment concentrations and by  calculation  from three in-
     direct methods.  The stream-discharge and sediment-dis-
     charge relations were used with stage record to estimate
     daily sediment load in the  ditch  for the  study period
     March 13 to September 30, 1979.

042  Sediment and Shore Sample Collection, Waukegan Harbor
     Slip No. 3, Waukegan,  Illinois—C 9729.   Prepared for
     Mason & Hanger--Silas Mason Company, Inc., and  USEPA
     Region V,   Chicago,   Illinois.   Madison,  Wisconsin:
     Warzyn Engineering, Inc.   May 26,  1981.

     This document  presents  the  results  for  soil samples
     collected between March 16 and 25, 1981, at the Waukegan
     Harbor Slip No. 3.  The purpose of the work was  to  ob-
     tain soil samples at specified  depths  for polychlori-
     nated biphenyl  (PCB) analysis and to test particular
     engineering properties  of the organic clayey silt (muds).
     The report consisted of  an  introduction,  descriptions
     of chain of custody, sample collection, field  proce-
     dures,  laboratory test  results, and six  boring logs.

043  Zar, Howard, Great Lakes  Enforcement Coordinator.  A
     Draft Status Report on the  Presence  of Polychlorinated
     Biphenyl Compounds (PCBs)  in the Fishes of Lake  Michi-
     gan;  With Special  Reference to  the  Waukegan Harbor
     Area.  Prepared for USEPA Region V,  Chicago,  Illinois.
     1981.

     The purpose of this document is to document PCB impacts
     on selected fish and human populations of the Lake Michi-
     gan basin.   It consisted of  an introduction;  discussions
PD998.057                   8-11

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     on background information,  trend analysis approach,  and
     sources of variability in  the  data;  interpretation  of
     trend analysis;  discussion  of trends, and public health
     concerns and fish flesh consumption guidelines;  and  the
     conclusions of the report.

044  Screening of Alternatives to Abate PCB Contamination in
     Waukegan Harbor and Environmental Assessment of Lagoon
     Construction.  Prepared  for USEPA Region V, Chicago,
     Illinois.

     This document consists of an introduction, a description
     and screening of alternatives,  and environmental conse-
     quences of alternatives.

045  Maps of North Shore  Gas  Company Lines—4512-153A and
     4512-221A.  Prepared for USEPA Region V, Chicago,  Illi-
     nois.  North Shore Gas Company.  1974.

     Maps of North Shore Gas Company lines.

046  Kontaxis,  Michael  T.   Report.   Prepared  for  WAPORA,
     Inc., Chicago, Illinois, and USEPA Region V,  Chicago,
     Illinois.   Mahwah, New Jersey:   HydroQual,  Inc.  Octo-
     ber 21, 1981.
                                           •
     This document presented available PCB data for the water
     column and bed sediments in Waukegan Harbor, North Ditch,
     and the near shore area of Lake Michigan.  It also dis-
     cussed the  following  alternatives:   No  Action,  diver-
     sion  of  water,   harbor  dredging,  operation  of the
     dewatering lagoon, and excavation of contaminated soils
     from North Ditch.

047  Nawrocki, Michael  A.  Demonstration  of  the Separation
     and Disposal  of  Concentrated Sediments.   Washington,
     D.C.:  USEPA, Office of Research and Development.   June
     1974.

     A pilot  scale  field study was  conducted  on a system
     designed to remove and process sediments from pond bot-
     toms.  Sediment removal was accomplished with a Mud Cat
     dredge, which minimizes  turbidity  while  dredging.   The
     500-gpm sediment processing system consisted of elevated
     clarifier bins  (type  used  for concrete batch plants)
     arranged in series, a bank of hydrocyclones, a cartridge
     filter unit, and Uni-Flow bag type fabric filters.  The
     most efficient components of the sediment removal system
     were the elevated bins and Uni-Flow  filters.  The hydro-
     cyclones were good at removing sand  size particles.
PD998.057                   8-12

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048  Draft Environmental  Impact  Statement  on Waukegan PCB
     Abatement Project with Comments and Corrections.  Pre-
     pared for USEPA Region V, Chicago, Illinois.  Chicago,
     Illinois:  WAPORA, Inc.   December 11,  1981.

     This is  one  of  2 copies  of the DEIS.   This  copy in-
     cludes the handwritten revisions  to  the draft of the
     DEIS.  The DEIS discusses the environmental  impacts  of
     the  PCB  contamination  and  the  impacts  that  cleanup
     efforts might have.  See  document ID No. 05-5M28.0/002.

049  Miscellaneous articles  on PCBs from a literature search.
     USEPA Region V,  Chicago,  Illinois.

     Miscellaneous articles  on PCBs from a literature search.

050  Draft Environmental Assessment for Alternatives to Abate
     PCB Contamination in Waukeqan Harbor.   Chicago,  Illinois:
     USEPA Region V.   Not yet  published (draft).

     Environmental assessment  of initial PCB cleanup  action
     in Waukegan Harbor.  A finding of no significant impact
     (FNSI)  for remedying existing PCB contamination  of the
     bottom sediments of Waukegan Harbor, Illinois, was the
     result of this study.  Not a public document.

051  OMC—North Ditch Bypass.   Weston.   1982.

     This report presents five alternative plans for provid-
     ing runoff and  drainage  collection  and  diversion away
     from the contaminated areas of North Ditch.  Associated
     incremental costs are projected for each alternative.

052  Guidelines for  Dewatering/Densifying  Confined Dredge
     Material.  Washington,  B.C.:  Department of  the Army,
     Corps of Engineers.  December 1978.

     This document provides information  about design, con-
     struction, operation,  and management of  containment
     areas for dredged  material  to be  dewatered and densi-
     fied.  The manual  helps  the design  engineer  in deter-
     mining what  is   technically feasible,   operationally
     practical and cost-effective for dewatering.

053  Hammer,  D.P.  Evaluation of Underdrainage Techniques
     for the Densification of  Fine-Grained Dredged Material.
     Vicksburg, Mississippi:   Office,  Chief  of Engineers,
     U.S. Army.  March 1981.

     The results of a large-scale field experiment to evaluate
     dewatering/densifying of  fine-grained dredged material
     with under-drainage techniques is presented.   The under-
     drainage systems evaluated were:   gravity,  partial vacuum,
     seepage consolidation,  and seepage consolidation with a
PD998.057                   8-13

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     partial vacuum.  Of the techniques evaluated, the par-
     tial vacuum in the  under-drainage  layer was the most
     effective.

054  Sax, Newton Irving.   Dangerous Properties of Industrial
     Materials,  Fifth Edition.   New York, New  York:   Van
     Nostrand Reinhold Co.   1979.

     This book provides  a single source for quick, up-to-date,
     concise, hazardous-analysis information for nearly 15,000
     common industrial materials.

055  Richmond, Gene L.   "Sediment Resuspension During Clam-
     shell Dredging."  Dredged  Material  Research.  D-83-1:
     2-5.  January 1983,

     This field  study compared the  sediment resuspension
     characteristics of a standard open clamshell and a spe-
     cially designed watertight clamshell dredge.  The data
     indicate that operating a  watertight  clamshell  in the
     upper water column  is  advantageous  over an open clam-
     shell in that  loss  is less as  the  loaded  watertight
     clamshell moves through the water.  However, turbidity
     in the  lower 5 ft of  the  water column  is higher with
     operation of a watertight clamshell due to penetration,
     digging, and withdrawal.

056  Radecca, Inc.,  Information on  Locksorb and Klensorb
     Materials.   Austin,  Texas:  Radecca, Inc.  July 1982.

     Manufacturer's  information  on a  fixation  agent,
     Locksorb, and a water treatment agent, Klensorb.

057  Sworzyn, E.M., and  D.G. Ackerman.   Interim Guidelines
     for the Disposal/Destruction of PCBs  and PCB items  by
     Non-thermal Methods.   Research Triangle Park,  N.C.:
     USEPA.  July 1982.

     This interim  report describes  and  evaluates various
     chemical, physical  and biological PCB  removal  and/or
     destruction  techniques.    Many techniques  are  not
     commercially available but show potential  for greater
     than 90 percent  PCB destruction with minimal environ-
     mental impacts and  low-to-moderate economic costs.

058  Larsen, Jean I.  Geology  for  Planning on Lake County,
     Illinois.  Prepared for State  of  Illinois.  Urbana,
     Illinois:  Illinois State  Geological Survey.  1973.

     This report summarizes geological studies conducted for
     Lake County  Illinois.   The following topics were ad-
     dressed:  basic  geology,  groundwater geology,  mineral
     resources, and engineering geology.
PD998.057                   8-14

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 059  Wet  Oxidation Waste  Disposal.   Hinsdale,  Illinois:
     Midwest  Recovery  Company.

     Manufacturer's brochure  on wet air  oxidation.

(060)  (Number  not  used.)

 061  Dehydro  Sludge  Dewatering System.  Richmond, Virginia:
     Infilco  Degremont,  Inc.   1981.

     Manufacturer's  brochure  on a vacuum  sludge  dewatering
     bed.

 062  Process  Design  Manual for  Sludge Treatment and  Dis-
     posal.   Prepared  for  USEPA,  Technology  Transfer.   Gaines-
     ville, Florida:   Black,  Crow,  and Eidness.   1974.

     This  document summarizes state-of-the-art sludge  pro-
     cessing  technology.

 063  Technical  and Cost  Proposal  for Development  and Testing
     of PCB-Silt  Decontamination  Process.  Prepared for USEPA,
     Chicago,   Illinois.   Philadelphia,  Pennsylvania:
     Franklin Research Center.  April 12,  1983.

     The data contained  in this  proposal are proprietary to
     the Franklin Institute.   The methods discussed concern
     extraction of PCBs  from harbor  sediments using a  sol-
     vent.  This  technique has not  been  developed outside of
     laboratory conditions.

 064  The  Zone  II  REM/FIT  Management  Plan.   Prepared  for
     USEPA.   Corvallis,  Oregon:   CH2M HILL  and Ecology
     Environmental,  Inc.   April  1983.

     This  document describes  the  organization and procedures
     CH2M  HILL  and Ecology and Environment,  Inc., have  estab-
     lished to  implement the REM/FIT  contract with EPA to
     provide  site investigation,  remedial planning,  program
     management and  support services  for  remedial response
     activities.

 065  Miller,  Stanton.   "The PCB  Imbroglio."   Environmental
     Science  Technology.   17-1:11A-14A.   1983.

     This  article reviews  the controversy over the impacts
     on human health caused by PCBs.   It  concludes that more
     work  needs to be done to understand the implications
     for human  and environmental  exposures to PCBs.

 066  Deposition of Julia B. Graf.   The United States of America,
     Plaintiff, vs. Outboard  Marine  Corporation and Monsanto
     Company, Defendants.   Called by Outboard Marine Corpora-
     tion  in  Chicago,  Illinois.   February 16,  1981.
 PD998.057                    8-15

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067  Deposition of R.  Emmet Kelly (Monsanto Plant Physician).
     United States of America, Plantiff,  vs. Outboard Marine
     Corporation and Monsanto Company,  Defendants.   Taken on
     behalf of Plaintiff at Saint Louis,  Missouri.   March 26-27,
     1981.

068  Deposition of Alfred F. Hanson.  The  United States of
     America, Plaintiff, vs. Outboard Marine Corporation and
     Monsanto Company, Defendants.  Called by the Plaintiff .
     at Chicago, Illinois.   June 11 and 12, 1981.

069  Deposition of Robert K. Ringer.  The  United States of
     America, Plaintiff, vs. Outboard Marine Corporation and
     Monsanto Company, Defendants.  Called by Monsanto Company,
     at Chicago, Illinois.   July 22, 1981 and July 23, 1981.

070  Deposition of Harold E.B. Humphrey.    The United  States
     of America, Plaintiff, vs. Outboard Marine  Corporation
     and Monsanto Company,  Defendants.   Called  by  Monsanto
     Company at Chicago,  Illinois,  and Lansing, Michigan.
     August 12-13, 1981, and October 2, 1981.

071  Deposition of Robert V. Thomann.  The United States  of
     America, Plaintiff, vs. Outboard Marine Corporation and
     Monsanto Company, Defendants.  Called by Outboard Marine
     Corporation,  at  Chicago,  Illinois.   September 17  and
     18, 1981; November 12 and 13, 1981;  and October 26, 1982.

072  Deposition of Wayland  R.  Swain.  The  United States of
     America, Plaintiff, vs. Outboard Marine Corporation and
     Monsanto Company, Defendants.  Called by the Defendants
     at Chicago, Illinois.  October 28-29, 1981.

073  Deposition of Thomas H.  Milby.   The United States  of
     America, Plantiff, vs. Outboard Marine  Corporation  and
     Monsanto Company, Defendants.  Called by the Plaintiff,
     at San Francisco, California.  May  27 to 28, 1982,  and
     August 4, 1982.

074  Deposition of Richard  P.  Brownell.   The United States
     of America, Plaintiff, vs. Outboard Marine  Corporation
     and Monsanto Company,  Defendants.   Called  by Outboard
     Marine Corporation,  at Chicago, Illinois.   August  10
     and 11,  1982;  August  31  and September 1,   1982;  and
     September 13 and 14, 1982.

075  Deposition of Dr. David Stalling.   The United States of
     America, Plaintiff, vs. Outboard Marine Corporation and
     Monsanto Company, Defendants.  Called by Monsanto Company,
     at Chicago, Illinois.  September 9,  1982.

076  Deposition of John Norden.  The United States of America,
     Plaintiff, vs.  Outboard Marine Corporation and Monsanto
PD998.057                   8-16

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     Company, Defendants.  Called by Outboard Marine Corpora-
     tion, at Chicago, Illinois.  June 10,  1982.

077  Deposition of Dr. William R. Gaffey.   The United States
     of America, Plaintiff, vs. Outboard Marine Corporation
     and Monsanto Company, Defendants.  Called by the Plain-
     tiff at Chicago, Illinois.  June 3,  1982.

078  Deposition of John C. Henningson.  The United States of
     America, Plaintiff, vs.  Outboard Marine Corporation and
     Monsanto Company, Defendants.  Called by Outboard Marine
     Corporation at Chicago,  Illinois.  August 12, 1982.

079  Deposition of Russell W.  Cook,  Jr. ,  United States  of
     America, Plaintiff, vs.  Outboard Marine Corporation and
     Monsanto Company, Defendants.  Called by Outboard Marine
     Corporation, at Chicago, Illinois.   June 8-9, 1982.

080  Deposition of Dr. Douglas Cherkauer.   The United States
     of America, Plaintiff, vs. Outboard Marine Corporation
     and Monsanto, Defendants.  Called by Monsanto  Company,
     at Chicago, Illinois.  June  17,  1982, and November 18,
     1982.

081  Notice of Filing - Defendant Monsanto Company's  Second
     Set of Requests for Admission to Plaintiff United States
     of America and response.  Includes  amendments 1, 2, and
     3 and Responses.  The United States of America, Plaintiff,
     vs. Outboard Marine  Corporation  and  Monsanto Company,
     Defendants.  June 8, 1982.

082  Notice of Filing - Defendant Monsanto Company's Amended
     Requests for Admission to  Plaintiff,  United  States of
     America.  The United States  of America,  Plaintiff,  vs.
     Outboard Marine Corporation and Monsanto Company, Defen-
     dants.  April 26, 1982.

083  Notice of Filing -  Defendant Monsanto  Company's Third
     Set of Requests for Admission to Plaintiff,  United States
     of America.  The United  States  of  America,  Plaintiff,
     vs. Outboard iMarine  Corporation  and  Monsanto Company,
     Defendants.  June 17, 1982.

084  Notice of Filing - Defendant Monsanto Company's  Fourth
     Set of Requests for Admission to Plaintiff,  United States
     of America and Response.  The United States  of America,
     Plaintiff,  vs.  Outboard  Marine  Corporation and Monsanto
     Company, Defendants.  January 6, 1983.

085  Draft Remedial Action Master Plan Lemon  Lane Landfill.
     Milxvaukee,  Wisconsin:  CH2M HILL.  June 6, 1983.

     This document is a Remedial  Action Plan  for  the Lemon
     Lane Landfill site.  The  major  concern  at the  site is
PD998.057                   8-17

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     disposal of PCB oils in capacitors.   Not a public docu-
     ment.

086  Nemerow, N.L.   Industrial  Water Pollution.  Addison-
     Wesley Publishing Company.   1978.

     Book on industrial water pollution.

087  James, R.;  M.  Cranmer;  and  R.  Harbison.  Technical
     Review  of  the  Health  Effects of  PCBs.   Ecology and
     Environment,  Inc., 1981.

     Review of health effects of PCBs.

088  USEPA Water Quality Criteria Documents.   Summary of
     Federal Register, Volume 45, No. 231, November 28,  1980
PD998.057                   8-18

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     Appendix
     CONCEPTUAL SITE HEALTH AND SAFETY PLAN
INTRODUCTION

The conceptual  site  health  and safety plan is  intended  to
outline, in general terms, the various requirements to allow
remedial site activities at the OMC site  in Waukegan,  Illi-
nois.  Remedial site activities may include cleanup  activi-
ties such as hydraulic and/or mechanical dredging, excavation
and dewatering  of  soil,  trenching, and waste  hauling via
trucks and/or barges.

The waste characteristics include  liquid,  solid,  and sludge
materials of  a  toxic nature.  PCBs from  hydraulic fluids
used in an  aluminum  die-casting  facility  are  the source of
the wastes  that have contaminated Waukegan Harbor and  the
North Ditch/Parking Lot areas.

HAZARD EVALUATION

The cleanup activities  may include hydraulic,  pneumatic,
and/or mechanical  dredging  of harbor  sediments including
those in Slip No.  3;  dewatering and subsequent excavation of
soils of the  North Ditch; and excavation of  contaminated
soils from  the  Parking  Lot  area.   The last two  items  will
require the collection and  diversion  of  stormwater runoff.
Dewatering  may  involve  the construction  of a  dewatering
lagoon.

The health hazards associated with the above cleanup activi-
ties are both chemical and  physical in nature  and include:
respiratory and dermal hazards, noise, and hazards associated
with the construction, excavation, and trenching.

Volatilization of PCBs and  increased dust levels  containing
PCBs during dredging and excavation operations will temporar-
ily increase  PCB  concentrations  in the air.  These  levels
may exceed  the  OSHA  standards and NIOSH  recommendations of
1.0 mg/m3 and  1.0  ug/m3, respectively.   Both  volatilized
PCBs and PCB-laden dust, as well as high  PCB concentrations
in the excavated materials  (soil, sludge, and water)  will
require dermal protection.  Noise and other physical hazards
will be produced by construction activities.  Both State and
Federal OSHA safety  and health standards  that  apply to the
construction industry  (such  as 29 CFR 1926/1910)  must be
enforced.

As stated above, the OSHA permissible  exposure  limit  is  1.0
mg/m3.  The NIOSH recommended  level is 1.0  ug/m3  for a 10-
hour time-weighted average,  due  to PCB  designation as  a
PD998.003.1                  A-l

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suspected carcinogen.  The immediately dangerous to  life or
health concentration is 5 mg/m3.

PCBs are colorless to dark brown liquids that possess a mild
hydrocarbon odor.  However, this compound  will  most likely
be bound  to  the soil and  sediment  components  of Waukegan
Harbor and surrounding CMC facility areas and environment.

The major routes of entry  into the  body  are  inhalation, in-
gestion, and skin or eye contact.   The target organs are the
skin, eyes, liver, and kidneys.  Major symptoms of PCB expo-
sure include eye irritation,  dermatitis  (notably chloracne),
hepatic degeneration, fatigue, dark urine,  and jaundice.

General first aid procedures  include:

     •    If PCBs  get  into the eyes, immediately wash  the
          eyes for at least 15 minutes with  copious  amounts
          of water, occasionally lifting the lower and upper
          lids.  Medical attention  should  be sought  immedi-
          ately.  Contact  lenses are not to  be  worn  by  per-
          sonnel during any onsite activities.

     •    Any contact with the skin will require the prompt
          washing  of  the contaminated areas with  soap or
          mild detergent  and  water.  If liquids  or soils
          potentially  contaminated  with  PCBs  penetrate
          through  clothing, the clothing should be  immedi-
          ately  removed  and  the skin should be washed as
          described  above.   Any signs of  skin irritation
          warrant'prompt medical attention.

     •    If a worker breaths in significant amounts of PCB-
          contaminated air, the exposed individual should be
          moved  to an uncontaminated area  at once.   Medical
          attention should be sought promptly.  If breathing
          has stopped, artificial respiration should be per-
          formed.

     •    If ingested,  seek  medical attention immediately,
          induce vomiting  with  syrup of  Ipecac or physical
          means.  Do not make an unconscious person  vomit.

Those personnel  who will come into  direct  contact with  PCB-
contaminated soils, sludges,  and liquids are at the  greatest
risk and must be protected and monitored accordingly.  Those
personnel who  will work close to  defined  PCB-contaminated
areas,  (i.e.,  heavy  equipment operators)  will  also be at
high risk and must be properly protected and monitored.

The  greatest  potential  health hazards within  the  project
area are as follows:
PD998.003.2                  A-2

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     •    The massive amount of contaminated sediment dredged
          from Slip No. 3 and associated dusts

     •    The contaminated sediments, sands, and  clays  near
          the abandoned OMC outfalls

     •    The contaminated soils  of  the Crescent Ditch and
          Oval Lagoon  located  on the western  end of  the
          North Ditch

     •    The contaminated  soil areas  designated as "hot
          spots" located in the parking lot

     •    The contaminated water  and dredged soils  in  and
          around the dewatering basins,  if used, and general
          construction and dredging activities onsite

The variously contaminated soils,  sediments,  mucks,  dusts,
and water adjacent to and associated with the aforementioned
areas and activities present potentially  significant health
hazards to the personnel involved in this cleanup.  Therefore,
all personnel who will  come  into  direct contact with these
contaminated materials  must  be provided  with  the maximum
allowable protection including  self-contained breathing  ap-
paratus  (SCBA) and sufficient dermal protection.   Personnel
monitoring and subsequent analysis will be required in order
to document a lowering of this  protection level.   Dependent
upon ambient  air  monitoring  results, specific  respiratory
and dermal protection may be required downwind  of any site
cleanup activities and holding basins.

Each specific cleanup activity  and associated work function
will require  the  definition and  enforcement of  specific
safety precautions and levels of protection.  This conceptual
safety plan will  require updating as the final abatement
alternatives are better defined.  Once work has begun onsite,
daily safety meetings are to be held so as to specifically
define individual work responsibilities in relation to recog-
nized hazard  potentials.  Therefore,  various modifications
to the site safety plan may be required.

SITE SAFETY WORK PLAN

The site perimeter  shall be  established  and the  zones of
contamination identified.  Prior to cleanup activities, con-
tamination will be  limited to  sediments,  water,  and soil.
During construction, new areas  may be identified,  including
the worksite air.
PD998.003.3                  A-3

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Personal Protection

Level of protection  may include Level B  and  C protection
equipment.   Those  in direct contact with  the contaminant
shall wear Butyl splash protection  aprons;  along with neo-
prene/viton gloves  over surgeon  gloves;  disposable  PVC-
coated, or better,  coveralls over chemically resistant cover-
alls; and disposable booties over  steel  toe/shank neoprene
boots.

Those workers in areas of PCB levels in the air of 1.0 mg/m3*
or greater  shall wear supplied air  respirators  with full
facepiece helmet or  hood,  or SCBA's with  full facepiece,
operating in  the positive  pressure mode.   Those  in areas
less than 1.0 mg/m3, shall wear full face air-purifying respi-
rators with high efficiency organic  vapor/dust canisters  or
cartridges  (respiratory equipment must be NIOSH approved).

Surveillance equipment  and  other  safety  equipment will in-
clude air  sampling pumps  with  florisil  collection tubes,
total dust  particulate  counter  or Hi-volume  sampler,  wind
speed and  direction device, air  escape  mask,  first aid
kit(s), portable emergency eye/face wash, showers and change
room.

Decontamination Procedures

Disposables shall be removed at the hotline.  All nondispos-
ables shall be washed in the following series:  1) detergent
and water  solution;  2)  clean water  rinse.   Nondisposable
work clothing  shall  be  changed  daily and checked  for con-
tamination.  Any contaminated  clothing underneath  dispos-
ables shall be properly discarded.  Wash tubs and/or basins,
brushes, decon solution, pressurized sprayers, plastic sheet-
ing  for  equipment  drop, plastic bags, drums,  labels, and
those items necessary  to  comply with Federal  Industry  and
Construction Regulations shall be provided.

Site Entry Procedures

Site should be entered  from an  upwind hotline in the level
of protection required for the associated task.  Strict con-
tamination  avoidance techniques will be  practiced by all
personnel onsite.
*Note:  NIOSH currently recommends an "action level" of
 1 microgram/cubic meter in ambient air for requiring the
 use of  supplied air/SCBA.  The above-referenced "action
 levels"  refer  to  current OSHA standards for  exposure  to
 chlorodiphenyl  (42% chlorine).
PD998.003.4                  A-4

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Work Limitations (Time of Day, Etc.)

In daylight hours,  heat  stress must be carefully watched,
and appropriate  alteration of work activities should  be
incorporated,  i.e., work shifts,  time-of-day shifts.

Investigation-Derived Material Disposal

All disposable clothing  and  materials  that are potentially
contaminated must be properly  bagged and  labelled and dis-
posed of properly.   All  contaminated sediments,  soils, and
liquids that leave the site must meet all Federal D.O.T. and
State of Illinois Regulations.  All onsite equipment such as
heavy excavation and dredging equipment must  be properly
decontaminated prior to leaving the designated hot zones.

SUMMARY

This is a conceptual site  safety plan, and  does  not  include
the detailed  information that would be incorporated in a
final site safety plan for the OMC  site.   Additional informa-
tion should be  developed when final remedial  alternatives
are better defined.  Additional information  to be developed
includes:

     •    Local resources for emergency situations

     •    Emergency routes (hospital, etc.)

     •    Delineated responsibilities

     •    Provisions for contingencies

     •    Site layout and zones of  contamination

     •    Detailed  level  of  protection per  specific site
          activity

     •    Detailed access and egress points

     •    Detailed air monitoring activities
PD998.003.5                  A-5

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