NCD980602163_19860528_Warren County PCB Landfill_SERB C_Draft Guidelines for Permit Applications and Demonstration Test Plans for PCB Incinerators-OCR

DRAFT GUIDELINES
FOR
PERMIT APPLICATIONS AND DEMONSTRATION TEST PLANS
FOR
PCB INCINERATORS
May 28, 1986
U.S . Environmental Protection Agency
Office of Pollution Prevention and Toxics
Operations Branch (7404)
401 M Street, S.W.
Washington, D.C. 20460
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@ Printed on Recycled Paper
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TABLE OF CONTENTS
Preface .....
List of Figures
List of Tables.
Abbreviations.
Glossary.
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vii
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1.0
2.0
3.0
Introduction.
Summary of 40 CFR 761 Regulations and Guidance.
2.1 General ...... .
2.2 Approval Authority ......... .
2.3 §761.70 Incinerators ........ .
Office of Toxic Substances (OTS) Permitting Procedures.
3.1 Establish Communications with the EPA Permit
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2
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Writer ......... · . . . . . . . . 9
3.2 Apply for an R&O Permit (Optional). . . . 9
3.3 Submit Operating Permit Application and
Demonstration Test Plan to DD/EEO. . . . 13
3.4 EPA/OTS Review of Permit Application and
Demonstration Test Plan .. '. . . . . . 14
3.5 EPA/OTS Issues Demonstration Test Permit. 14
3. 6 Conduct Oemonstrat ion Test. ·. . . . . . . . 14
3.7 Submit Oemonstrati-0n Test Report to OD/EEO. . . . 15
3.8 EPA/OTS Review of the Demonstration Test Report 15
3.9 DD/EEO Issues an Operating Permit. · 15
Permit Application Foimat .....
4.1 Permit Application Cover.
4.2 Section I -Summary ... , ....
4.3 Section II -Project Organization. . .
4.4 Section III -Waste Description ...... .
4.5 Section IV -Process Engineering Description.
4.6 Section V -Monitori~g Plan .... ; ... .
4.7 Section VI -Monitoring Procedures ... · ..
4.8 Section VII -Data Reporting/Recordkeeping.
4.9 Section VIII -Inspection Procedures.
4.10 Section IX -Spill Prevention Control and
Countermeasures Plan ......... _ ..
4.11 Section X -Safety Plan ....... .
4.12 Section XI -Training Plan ....... .
4.13 Section XII -Plans for a Demonstration _
(Trial Burn) ............ ,
4.14 Section XIII -Test Data or Engineering
Performance Ca lcu lat ions. . . . . . .
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5.0
6.0
7.0
8.0
TABLE OF CONTENTS (continued)
4.15 Section XIV -Other Permits/Approvals ....
4.16 Section XV -Schedule of Pre-Operation Events
4.17 Section XVI -Quality Assurance Plan .....
4.18 Section XVII -Standard Operating Procedures.
4.19 Section XVIII -Closure Plan. . ·
Demonstration Test Plans ............ .
5.1 General .............. .
5.2 Contents of a Demonstration Test Plan
Conducting and Monitoring a Demonstration Test.
6~1 Start-up ....... .
6.2 PCB Waste Destruction ..
6.3 Shutdown ....
Demonstration Test Report
7.1 .Format and Contents
7.2 Review ...
7. 3 Approval.
References .....
Appendix A -Checklists for Completeness of Submittal ....
Appendix B -Monitoring, Sampling, and Analys1s Procedures ..
Appendix C -OTS Guidance on Frequently Asked Questions ...
Appendix D -Addresses for Headquarters and Regional Offices.
Appendix E -Annotated Bibliography ............ .
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B-1
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Figure
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List of Figures
Title
Major steps in the OTS operating permit process
Process to obtain an operating permit from OTS.
Research permitting process .... ~
Example permit application cover ...... ~ ..
Schematic of sampling and monitoring points for an
incinerator ......... .
Cover for the Demonstration Test Plan.
Demonstration Test Report cover.
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Table
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List of Tables
Title
Outline of Major Sections of 40 CFR 761 ...
Disposal Options by PCB Waste Categories
Summary of Permit Approval Authority.
Format for Permit Applications for PCB Incinerators ..
Example Summary of Monitoring Plan for a Mobile
Incinerator .................. .
Format of Demonstration Test Plan for Incinerators.
Example Summary of Anticipated Test Parameters for an
Incinerator ........ .
.PCDD and PCDF Reporting Format ....... .
Example: Proposed Schedule for. Trial Burn ·.
Format for _the Demonstration Test Report ...
Example Demonstration Test Results Summary.
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• ABBREVIATIONS
, AA: Assistant Administrator for .Pesticides and Toxic Substances.
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acm: Actual cubic meters.
acfm: Actual cubic feet per minute.
BTU: British thermal unit.
°C: Degrees Celsius.
·-1 CE: Combustion efficiency .
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CFR: Code of Federal Regulations.
CO: Carbon monoxide.
CO2 : Carbon dioxide.
CWA: Clean Water Act. See 40 CFR 129 .
• > CEMS: Continuous emissions monitoring system.
DD/EEO: Division Director, Exposure Evaluation Division.
DRE: Destruction and removal efficiency.
dscf: Dry standard cubic feet.
? dscm: Dry standard cubic meters.
DVE: Data variance estimate.
ECO: Electron capture detector.
EIMS: Electro.n impact mass spectrometry (low resolution).
EPA: U.S. Environmental Protection Agency.
ESP: Electrostatic precipitator.
°F: Degrees Fahrenheit.
FR· s· Flow rate of gas in the stack. Also termed Qs or ERs by some authors.
g: Grams.
gal.: Gallons.
GC: Gas chromatography.
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GC/ECD: Gas chromatography with electron capture detection.
GC/MS:. Gas chromatography/mass spectrometry.
7 · GPC: Gel permeation chr9matography.
gpm: Gallons per minute.
gr: Grains
h: Hours.
HCl: Hydrochloric acid .
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.1 HECD: Hall electron capture detector.
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H20: Water.
HRGC: High resolution GC, also termed capillary GC.
in.: lnch(es) .
. kg: Kilograms.
lb: Pounds.
mg: Mi 11 i grams.
min: Minutes.
MS: Mass spectrometry.
NEPA: National Environmental Policy Act.
NO· x· Oxides of nitrogen.
NPDES: National Pollutant Discharge Elimination System.
02: Oxygen.
OPTS: Office of Pesticides and Toxic Substances.
OSHA: Occupational Safety and Health Act. See 29 CFR 1910.1.
OTS: Office of Toxic Substances, a suborganization of OPTS.
PCB : Polychlorinated biphenyl(s).
PCDD: Polychlorinated dibenzo-E-dioxin.
PCDF : Polychlorinated dibenzofuran.
PGC: Packed column gas chromatography.
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, pH: Measure of acidity or alkalinity.
ppm: · Parts per mi 11 ion.
--: psi: Pou.nds per square jnch.
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QA: Quality assurance.
QC: Quality control.
RA: Regional Administrator.
RCl: Total chlorinated organics~
RCRA: Resource Conservation and Recovery Act. See 40 CFR 122-124 and
260.,.265.
sec: Seconds.
TCDD: Tetrachlorodibenzo-E-dioxin.
TCDF: Tetrachlorodibenzofuran.
_ 1 TSCA: . Toxic Substances Control Act, Pl 94-469 (1976). See 40 CFR Part 761.
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GLOSSARY
· Air: Includes ampient air and stack gases unless otherwise specified.
•' Analyte: Chemical compound or element which is the subject of an analysis.·
Aroclor: Commercial mixture of PCBs previously manufactured by Monsanto.
Authorized use: Any PCB use or servicing which can be conducted in accordance
with 40 CFR 761.30.
Combusti9n efficiency (CE): CE =·100[C02 ] + [C02+CO].
Continuous emissions monitoring system (CEMS): An emissions measurement sys-
tem which is in continuous operation except for system breakdowns~ repairs,
calibration checks, and zero and span adjustments . See 40 CFR Parts 60.2
and 60.13 and Part 60, Appendix B for additional details.
Data variance estimate (DVE): Either a numerical value such as a standard
·deviation, or a qualitative evaluation such as 11 good.11
Destruct i.on and removal efficiency (DRE): A measure of an incinerator I s
-1 performance in removing or destroying PCBs (or another compound). DRE
is expressed as percent efficiency:
. J where:
Win -Wout X 100 w. ,n
w. = Mass feed rate of PCB in the waste stream feeding the
,n incinerator, and ·
W t =,Mass emission rate of PCB present in exhaust emis-
ou sions prior to release to the atmosphere.
Demonstration Test: A test to demo~str~te system performance, commonly
called a trial burn.
Electron impact mass spectrometry (EIMS): Low resolution mass spectrometry
operated in the electron impact ionization mode.
High resolution gas chromatography (HRGC): Gas'-liquid chromatography per-
formed using a capillary column, typically 10-50 m long x 0.2 mm ID, coated
on the interior with a liquid phase.
Isomer: Any compound which has the same molecular formula, but different
positional substitutions. For example, for PCBs, 2,2 1 -dichlorobiphenyl and .
2,3-dichlorobiphenyl are isomeric; 4-chlorobiphenyl and 2,3~4-trichlorobiphenyl
are not.
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Liquid: A substance is a liquid if its melting point is less than 20°C and
. does not ·-pass the structural integrity test (> 15% free liquid
content) (Weller 1982).
Method: A series of tecf:Hliques or procedures which form a specific, well-
defined destruction, sampling, chemical analysis, or other procedure for
a specified compound(s)/matrix(ces) combfoation.
Polychlorinated biphenyl (PCB): One of 209 individual compounds having
the molecular formula C12HnC1 10_n, where n = 0-9. This definition includes
monochlorobiphenyls.
Polychlorinated dibenzo-_e-dioxin (PCDD): One of 75 individual compounds
··1 having the molecular formula C12Hi::aC1 8_ 02 , where n =-0-7. This definition
., includes monochlorodibenzo-_e-diox,ns. n ·
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Polychlorinated dibenzofuran (PCDF): One of 135 individual compounds having
the molecular formula C12HnC1 8 ~nO, where n = 0-7. This definition includes
monochlorodibenzofurans.
Packed column gas chromatography (PGC): gas-liquid chromatography performed
using a column, typically 180 cm long x 2 mm ID, packed with a liquid phase
on a granular solid support material. ·
Part per _million (ppm): One part in 106 • For gaseous mixtures, a volume/
volume (v/v) basis is typically used and:
ppm= mg/m3 x RT . MW
where RT= 22.4 liter/g-mole at 0°C and 1 atm
= 24.5 liter/g-mole at 25°C and 1 atm
and MW= molecular weight of compound, i.e., g/g-mole
For low concentration aqueous samples, a weight:volume (w/v) basis is most
commonly used ·and 1 ppm= 1 mg/liter (1 mg/kg for liquids with density 1).
For nonaqueous liquids and solid materials, a weight:weight (w/w) basis is ·
most commonly used and 1 ppm= 1 mg/kg.
Quality assurance (QA): The total integrated program for assuring the relia-
bility of monitoring and measurement data. A system for integrating the
quality planning, quality assessment, and quality improvement efforts to
meet user requirements.
Quality control (QC): The routine application of procedures for obtaining
prescribed standards of performance in the monitoring and measurement
process.
QC blank: A sample processed and analyzed to obtain background concentrations
of the analytes. j
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QC control: A sample containing a known .amount of analyte which is processed •
with sample batches .to monitor recoveries.
Residence time: -The tim~ that the flue gas spends in the destruction. zone
7 (area of combustion chamber with the temperature equal or above that re-
quired by the regulations); calculated by dividing the zone volume by the
volumetric flow rate at the exit (actual-pressure ~nd temperature
conditions). ·
Semivolatile organics: Organic compounds which are analyzed by an extraction/
gas chromatographic procedure. This excludes volatile compounds such as
chloroform which would be lost in an evaporation concentration step and non-
volatiles such as humic acids which will not elute from a gas chromatograph .
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_4 Solid: A substance is a solid if its melting point is greater than 20°C
and it passes the structural integrity test (Weller 1982).
Tetrachlorodibenzo-_e-dioxin (TCDD): One of 22 isomers with molecular fo·rmula
C12H4 Cl 402 . Often colloquially used to refer specifically to 2,3,7,8-TCDD.
Tetrachlorodibenzofuran (TCDF): One of 38 isomers with the molecular formula
C12H4 Cl 40 .
• 2 Technique: Specific destruction, laboratory, or sampling operation usually
· cdnducted as part of a method. GC/EIMS and Soxhlet extraction ar~
techniques .
Trial burn: A demonstration of a thermal destruction system.'s performance
("Demonstration Test").
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1.0 INTRODUCTION
The Code of Federa 1 Regulations, Tit 1 e 40; · Part 761 ( 40 CFR 761)
establishes rules on the disposal of PCBs and PCB items. Under these rules,
organizations or persons-wishing to dispose of PCBs are required to use ap-
proved methods and must obtain a permit. ·
This document provides guidance for persons applying to the Office
of Toxic Substances of the U.S. EPA for approval of PCB disposal by incinera-
tion (§761.70). This document presents and discusses the format, content, and
level of detail required for permit applications, demonstration test plans,
and demonstration test repbrts~
7 Note that these guidelines address only permit requirements for the
·-1 disposal of PCBs as regulated ·under TSCA. Other laws such as RCRA, CWA, and
OSHA regulations may apply to PCB disposal methods and may have different or
additional permit requirements.
Section 2.0 provides a brief summary of pertinent EPA procedural re-
quirements and guidance as well as ·a summary of pertinent Part 761 regulations.
Section 3.0 describes the EPA Office of Toxic Substances (OTS) permitting
procedures. Sections 4.0 and 5.0 provide guidance regarding preparation and
submission of permit applications and demonstration test plans, respectively.
-' Section 6.0 briefly discusses conducting a demonstration te~t. Section 7.0
provides guidance regarding preparation of a demonstration test report. Sec-
tion 8.0 lists the references for this document. Appendix A provides check-
lists for the applicant to use in determining if all pertinent areas have been
addressed prior to submittal to the Agency. Appendix Bis a summary listing
of sampling/analytical methods for PCB, PCDD, and PCDF. Appendix~ provides
guidance to the applicant in the form of answers to some frequently asked
questions. Appendix D lists the addresses for OTS Headquarters and for. the
-1 10 Regional Offices. Appendix E is an annotated bibliography of sources of
related informati~.
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2.0 SUMMARY OF 40 CFR 761 REGULATIONS AND GUIDANCE
· This section summarizes pertinent provisioh~ of Title 40 of the Code
of Federal Regulations, Part 761, (40 CFR 761) related to the disposal of PCBs.
Part 761 establishes prdhibitions of and r~quirements for the manufacture,
processing, distribution in commerce, use!_disposal, storage, and marking of
PCBs and PCB items in the United States. These ~egulations were promulgated
under authority of the Toxic Substances Control Act (TSCA, PL 94-469).
40 CFR 761 was promulgated May 31, 1979 (44 FR 31514). All references in this
document refer to the revised 40 CFR 761 as of July 1, 1985.
2.1 General
The major sections of 40 CFR 761 are outlined in Table 1. The stor-
ag~ and disposal of PCBs are addressed in 40 CFR 761, Subpart D. In Subpart D,
Section 761.60; disposal requirements are differentiated according to waste
type and PCB concentration; Table 2. summarizes the disposal requirements of
§761. 60.
This guidelin~ document is intended to provide guidance only for
approval of PCB incinerators (§761. 70) which may require approval by the .
Division Director of the Exposure Evaluation Division, Office of Toxic Sub-
stances (DD/EEO). · Disposal by chemical waste landfills (§761.75) or high .
efficiency boilers (§761.60(a)(2),(3)) is not addressed, since ·their disposal
methods are approved by the appropriate Regional Administrator (RA). Also,
storage of PCBs for disposal (§761.65) or decontamination (§761. 79) is not
· addressed.
2.2 Approval Authority
Approval authority for PCB disposal facilities is stipulated in Sec-
t ion 761. 60( i). Typically, the RA for the EPA region in which the facility
will be operated has approval authority. However, in specific situations,
the DD/EED has approval authority, in lieu of the RA. Table 3 summarizes EPA
approval authority for PCB disposal facilities. Addresses for EPA headquarters
and the regional offices are provided in Appendix D.
2.3 §761.70 Incinerators
Performance standards for PCB incinerators are described in §761.70.
To be approved, incinerators must meet specific requirements. Requirements
for destruction of liquid and nonliquid PCBs are provided in the regulation,
§761 .70(a) and §761.70(b), respectively. Paragraph 761.70(c) establishes re-
quirements for maintaining records and §761.70(d) establishes requirements
for obtaining approval of incinerators .. Each of these paragraphs is discussed
below.
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Table 1. Outline of Major Sections of 40 CFR 761a
Subpart A -
761.1
761.3
761.19
General·
Applicability
Definitions
References
Subpart B -Manufacturing, Processing, Distribution in Commerce,
and Use of PCBs and PCB Items
761.20 Prohibitions
761.30 -Authorizations
Subpart C -Marking of PCBs and PCB Items
761.4 Marking requirements
761.45 Marking formats
Subpart D -Storage and Disposal
761.60 Disposal Requirements
(a) PCBs
(b) PCB Articles
(c) PCB Containers
(d) Spills
(e) Alternative Methods
(f) Written Notice
(g) Testing Procedures for PCB Concentration
(h) Export/Import for Disposal
(i) Approval Authority for Disposal Methods
761.65 Storage for Disposal
761~70 Incineration
(a) Liquid PCBs
(b) Nonliquid PCBs
(c) Maintenance of Data and Records
(d) Approval of Incinerators
761.75 · Chemical Waste Landfills
761.79 Decontamination
Subpart E -Exemptions .
Subparts F to I -[Reserved]
Subpart J -Records and Reports
761.180 Records and Monitoring
aNote: Some subparts are outlined in greater detail than others.
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,.:.. ~ PCB waste category Mineral oil dielectric fluid Other liquids Nonliquids (soil, rags, debris) Dredged materials and municipal sewage sludge PCB transformers (drained and flushed) PCB capaci torsb PCB capacitors PCB hydraulic machines PCB contaminated elec-trical equipment (except capacitors) Other PCB artfcl es Other PCB articles· PCB containers PCB containers All other PCBs a . I -l -s CFR section 761. 60[a][2) 761. 60[a][3] 761.60[a][4] 761. 60[a]C5] . 761. 60[b][l] 761. 60[b][2] 761. 60[b][ 4) 761. 60[b][3] 761.60[b][4] 761. 60[b][5] 761. 60[b][5] 761.60[c] 761.60[c] 761. 60[a] bNot specified. cExemptions for some small capacitors. ... .. , ........ .J Table 2. Disposal Options by PCB Waste Categories (USEPA 1985) Chemical High bf sposa 1, method Drain, PCB waste efficiency Alternative Method dispose concentration Ind nerator landfill boiler method approved as solid Decon-(ppm) (§761.70) (§761. 75) (§761. 60) (§761.60(e)) by region waste lamination 50-500 X X X X 50-500 X X X X ii: 50 X X ii: 50 X X X NSa X X ii: 500 X 50-500 X X ii: 50 ,, xc,d Xe ii: 5oof X xg 50-500 Xe ii: 5oof X xd xh < 50Q xd xh ii: 50 X X ~ust also be flushed ff hydraulic fluid contains> 1,000 ppm PCBs and flushing solvent disposed of in accordance with §761.60(a). eDrained liquid must be disposed of in accordance with §761.60(a). -Hust be drained of all free-flowing liquid. The disposal of the drained electrical equipment and other PCB articles is not regulated by 40 CFR 761. All liquids must be disposed of in accordance with paragraph (a)(2) or (3) of §761.60 [in an incinerator (§761.70), chemical waste landfill f(§761.75), high efficiency boiler, or by an alternative method (§761.60(e))]. Due to a typographical error, 40 CFR 761 [July 1, 1985, p. 163] erroneously states this value as 50 ppm; ref~r to Federal Register, 44, 31514-31568 (Hay 3, 1979). iorained of any free-flowing liquid and liquid incinerated in §761.70 incinerator. Decontaminated in compliance with §761.79. . •. I
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Table 3. Summary of Permit Approval Authority
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Type facility
Mobile incinerators or portable or stationary
incinerators of identical design to be used
in more than one EPA Region
Research and development methods disposing of
> 500 lb PCB-containing material
Research and development methods disposing of
~ 500 ,lb PCB-containing material
Site-specific stationary incinerators to be
used in any.one EPA Region
Site-specific high efficiency boilers
Approval permit
authority
Assistant Administra-
tor for Pesticides and
Toxic Substances (AA)*
AAa
Regional Administra-
tors (RAs)
RAs
RAs
aDelegated authority to the Division Director of the Exposure Evaluation
Division, Office of Toxic Substances (DD/EEO) .
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include:
2.3.1 Liquid PCBs (§760.70(a))
For destruction of liquid PCBs, the incineration requirements
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A 2-sec dwell time at~ 1200°C (± 100°C) and~ 3% excess oxy-
gen or 1.5-sec dwell time at~ 1600°C (± 100°C) and~ 2% excess
oxygen in the stack gas;
A system to automatically stop the PCB feed whenever the tem-
perature or excess oxygen drops below the minimum levels spe-
·cified above;
A combustion efficiency (CE ) of at least 99.9%, where:
where [CO2]= concentration of carbon dioxide, and
[CO] = concentration of carbon monoxide;
NOTE: This equation is rewritten from the published equation,
CE = [C02 ]/[C02 ] + [CO] x 100, which appears .to be in error
mathematically. ·
Measurement and recording (at intervals no longer than 15 min)
of the rate and quantity of PCBs fed;
Continuously measuring and recording the temperature of the
incineration process (combustion chamber);
Monitoring and recording the concentrations of 02 (continuously),
CO (continuously), and CO2 (periodically ,at a frequency speci-
fied by the 0D/OTS or RA) in the stack emissions whenever PCBs
. are burned;
A system to automatically stop the PCB feed whenever the moni-
toring operations specified for 02 , CO 2 , and CO fail;
Monitoring stack emissions for 02 , CO, CO2 , NO, HCl, total
chlorinated organics (RCl), PCBs, and total particulate matter
when the incinerator is first used for the disposal of PCBs or
when the incinerator has been modified in a manner which may
affect emissions; and
Using watei scrubbers to control HCl. Al~ernative methods for
HCl control may be used if approved by the DD/EEO or RA. For
approval, EPA/OTS requires that the HC.l removal system demon-
strate a removal efficiency of 99%.
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include:
OTS policy also requires:
Demonstrating that mass air emissions .1rom the incinerator are
no greater than 0.001 g PCB/kg of the PCB introduced to obtain
a DRE of at least 99.9999% (six nines);
Measurement of the stack emissions for chlorinated dibenzo-
dioxins ,and dibenzofurans;
Particulate matter emission levels of ·~ 180 mg/dscm
(0.08 gr/dscf) when corrected to 7% oxygen; and
Total PCB concentrations in scrubber water,* fly ash (if
applicable), and bottom ash (if applicable) of~ 2 ppm.
2.3.2 Nonliguid PCBs (§761.70(b))
For destruction .of nonliquid PCBs, the incineration requirements
• Demonstrating that mass air emissions from the incinerator are
no greater than 0.001 g PCB/kg of the PCB introduced to obtain
a DRE of at least 99.9999% (six nines); and
_ A 11 requirements · for liquid PCB incinerators·, except for the ·
dwell time, temperature, and excess oxygen requirements [first
bullet in 2.3.1 above] and the automatic feed shutoff require-
ment for inadequate temperature or oxygen levels [second bullet
in 2.3.1 above].
OTS policy also requires:
Measurement of the stack emissions for chlorinated dibenzo-
. dioxins and dibenzofurans;
Particulate matter emission levels of ~ 180 mg/dscm
(0.08 gr/dscf) when corrected to 7% oxygen; and
Total PCB c~ncentrations in. scrubber water,* fly ash (if
applicable), and bottom ash (if applicable) of~ 2 ppm.
·2.3.3 Maintenance of Data and Records (§761.70(c))
Paragraph 761.70(c) establishes requirements for maintenance of data
and records for PCB incinerators. Records must be maintained according to
the prov1s1ons established in §761.180. The records required are discussed
in more detail in Section 4.0 of this report.
Federal NPDES or state or local regulations may require more stringent
control of PCBs (i.e., lower concentrations) in water discharged from
the facility.
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'2.3.4 Other Requirements
.· . Paragraph 761.70(d) establishes requirements for obtaining approval
· of PCB incinerators. These requirements include submitting an application
1 for approval, submitting.a trial burn plan (if a trial burn is required by
the approving authority), and conducting a trial burn (if required). The
required contents of a permit application-~nd of .a trial burn plan are pre-
sented and discussed in detail in Sections 4.0 and 5.0 of this document,
respectively.
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3.0 . OFFICE OF TOXIC SUBSTANCES (OTS) PERMITTING PROCEDURES
_ The Code of Federal Regulations, Title 40,~Part 761 (40 CFR 761)
specifies that the Assistant Administrator (AA) ·tor Pesticides and Toxic Sub-
stances has approval autpority for certain PCB disposal facilities [approval
authority has since been delegated to the Division Director, Exposure Evalua-
tion-Division of the Office of Toxic Substances (OD/EEO) on January 23, 1984];
Regional Administrators (RAs) have approval authority for other facilities.
Facilities for which the DD/EEO has approval authority include PCB inciner-
ators that are mobile or of identical design and intended to be used in more
than one EPA region. · Also included are certain research and development (R&D)
methods that dispose of more than a total of 500 lb PCBs or PCB-contaminated ·
material. RAs retain approval authority for site-specific facilities such as
landfills, st~tionary incinerators, high-efficiency boilers, and research and
development into PCB methods involving a total of 500 lb or less of PCB
materials.
This section describes the process used by EPA/OTS to issue an oper-
ating permit and an R&D permit to the PCB incinerator applicant. Figure 1
shows the major steps in the operating permit process. Figure 2 gives a more
detailed process diagram which includes the loops at various points in the
operating permit process when additional information is required. Figure 3
shows the process for obtaining an R&D permit from OTS.
3.1 Establish Communications With the EPA Permit Writer
The permit applicant can facilitate the permitting process by estab-
lishing good communicati-0ns with the EPA permit writer as early as possible.
Good communication will minimize requests for additional information as well
as submission of unnecessary information. Early in the process,. the applicant
and permit writer can discuss any special circumstances and also the necessity
? for submitting optional information discussed in these guidelines. In addi-
tion, advance notice of submissions will allow the permit writer to schedule
the review in an orderly fashion.
3.2 Apply for an R&D Permit (Optional)
. The purpose of a research and deve·lopment (R&D) permit is to assist
the facility operator in bringing the destruction process from conception to
commercial -operation. R&D permits can be issued for bencn-scale operations,
for pilot-scale systems, and for full-scale commercial systems. First-time
applicants who do not have experience operating their systems, or who have
not yet used their systems to destroy PCBs, are encouraged by EPA to obtain
an R&D permit for 11 shakedown 11 of the process by conducting studies on a lim-
ited quantity of PCBs, prior to the commercial demonstration test.
An R&D permit application should consist of all of the applicable
elements described in Table 4 in Section 4.0 (except as noted). The R&D ap-
plication need not contain the detail required for an operating permit, but .
must be sufficient to demonstrate that the R&D activity will not present an
unreasonable risk of injury ·to health or the environment. The applicant
should also supply information on the specific objectives of the R&O activity.
9
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1
I , J
,,.
Establish Communications with .. EPA/OTS Permit Writer
'
Submit Complete Operatfng -Submit Complete Demonstration
Permit Application to DD/EEO · -. Test Plan to DD/EED ..
. .
EPA/OTS Review and Approval , .
·~
EPA/OTS Issues Demonstration
Test Permit
, .
, Conduct Demonstration Test
, ,
Submit Demonstration Test Report
to DD/EEO
.,
-EPA/OTS Review and Approval
DD/EEO Issues Operating Permit
Figure 1. Major . steps in the OTS operating permit process.
10
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. ll
r
I
I
I
I
Test Plan
Revised by
Applicant
Demonstration THI.
Plan Recelvec:I by
DD/EEO
Te!<t Plan Reviewed
Operating Permit Application
Received by DD/EEO
Test Plan
Requested
byDD/EED .
Has Demonstration
Test-Plan a"n
Submitted?
Application
Reviewed
Application
Acceptable
Deficiencies
Noted and
Returned to
Applicant --0---Test Plan
Complete
and
Acceptable
r---------
1
I
I
I
I
I
I ,
I L---------
,---
Test
Rescheduled
r -~ -~Acceptab~e to OTS_ j
OTS Requires
Operating. Design.
Sampling/Analysis
Deficiencies
to be Corrected
OTS Requests
Correction of
•Deficiencies
ond Anather
Demonstrati_on Test·
OTS Requests
Revised Permit
Application
Facility Corr.cts
Minor Deficiencies
and Requests New
Test Date
Operating
Permit.
Denied
---, I
I
I I I I
Operating
Permit
Denied
Test Date Set
and OTS Natified
30 Days Prior
Demonstration
Test Initiated
Demonstration
Test Completed
Demonstration
Test Results
Submitted
Results
Reviewed
byOTS
Operating
Permit Issued
----,
Additional Data/
Information Requested _____ ..
Figure 2. Process to obtain an operating permit from OTS.
11
Revised
Application
Submitted
Deficiencies
Noted and
Returned to
Applicant
OTS Recommends
Applicant Submit
R & D Permit
Application in Lieu
of Operating
Permit Application
-
7 ·
R&D
Permit
Denied
R & D Permit
Application
Received by
DD/EEO
Application
Reviewed
-~-~~-'P_i~ ... :_:~_o_n_ --<$>--
R&D
Permit
Issued
I
I.
I
I L __
Revised
Application
Submitted
Deficiencies
Noted and
Returned to
Applicant
OTS Recommends
Applicant Submit
Operating Permit
Application in
lieu of R & D
· Permit
Figure 3. Research permitting process.
12
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The R&D activity should provide process information and operat1ng experience
needed for·application for an operating permit. The R&D results should be
used for planning a full-scale demonstration such th-at there is a high prob-
ability of a succe.ssful demonstration. The R&D results may be appropriate
for inclusion in the app~ication for the operating permit.
R&D permits can be issued by the· appropriate EPA Regional Adminis-
trator for the destruction of a total of 500 lb or less of PCB-contaminated
material, or by the Division Director, Exposure Evaluation Division, Office
of Toxic Substances (DD/EED), for the destruction of more than 500 lb of PCB-
contaminated material. R&D permit applications can be submitted at any time,
even if an application for a permit to operate commercially has already been
submitted.
-~ Upon receipt of an R&D permit application, EPA will review the docu-
ment. If the application is incomplete or contains deficiencies, a notice of
deficiencies wj ll be sent to the applicant, who must then revise and resubmit
the application. In some cases, EPA/OTS may recommend that the applicant sub-
mit an operating permit application in lieu of the R&D permit application,
depending upon the circumstances involved. When a complete R&D permit appli-
cation is approved by EPA/OTS, an R&D permit is issued. ·
-According to 40 CFR 761.GO(f), before commencing R&D work, a 30-day
·3 notice must be given to EPA regional, ·state, and local officials. After ·com-
pletion of the R&D activities, a report giving the results of the activities
and test results must be submitted to EPA.
3.3 Submit Operating Permit Application and Demonstration Test Plan
to DD/EEO
The permit applican~must submit both an operating permit applica-
tion and a demonstration test plan to DD/EEO in order to receive a demonstra-
tion permit. Generally, the permit application and demonstration test plan
should be separate, complete documents.
The permit application should be submitted as early as possible.
Partial submissions are acceptable if the submission clearly indicates the
portions of the application to be submitted later,.and if the applicant and
EPA permit writer agree that a preliminary review of a partial submission will
be productive. The demonstration test plan may be submitted with or after
the permit application. In any event, both the application and demonstration
test plan must be deternined by EPA to be complete before a demonstration
permit can be issued.
Paragraph 761.70(d)(l) establishes the contents required in an ap-
plication for a permit to operate a PCB .incinerator. The suggested format
for an incinerator permit application is presented in Table 4 in Section 4.0
of this document. A complete application must address each topic in the for-
mat given in Table 4. As an aid to the applicant in determining if all re-
quirements for an application have been addressed, a checklist is provided in
Appendix A.
13
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A Demonstration Test Plan is a document prepared specifically for
the demonstration tests and provides details of how the test will be conducted.
A complete plan must include all the required information given in Table 6 in
Section 5.0 of this document. Appendix A provides a checklist to aid the ap-
7 plicant in determining whether all required items have been addressed.
3.4 EPA/OTS Review of Permit Application and Demonstration Test Plan
EPA/OTS reviews the permit application and demonstration test plan
for completeness, accuracy, clarity, and technical .viability. If either docu-
ment is unacceptable to EPA, a notice of deficiencies will be sent to the ap-
plicant. The deficiencies must be corrected in a revised application or test
plan, and the revised document(s) must be submitted to the DD/EEO. In some -1 cases, this process may need to be repeated more than once .
.. t
3.5 EPA/OTS Issues Demonstration Test Permit .
After the EPA approves the permit application and demonstration test
plan, the DD/EEO will issue a demonstration permit. A demonstration permit
is required prior to destroying any PCBs in a process demonstration . The
demonstration permit will specify a limited amount of PCB-containing material
which can be destroyed during the demonstr~tion and other conditions based on
the applicants permit application and demo nstration test plan. The time
-~ period for which the demonstration permit is valid also will be limited.
3.6 Conduct Demonstration Test
A demonstration tesi (trial burn) is scheduled at a date agreeable
' to both the applicant and EPA/OTS . It is desirable that EPA/OTS have at least
60-days' notice prior to the test; 30 days' notice is required.
J If any modifications to the test plan are required prior to the
demonstration test, EPA/OTS (permit writer) should be notified in writing at
least 14 days prior to the test. Also, if events requir~ that the plan be
significantly modified during the test demonstration, then the permit writer
should be contacted immediately to discuss the implications of any modifica-
tions. As with normal operation, any significant deviations from .or altera-
tions in the test plan .must be documented in writing to EPA/OTS (permit writer)
within 10 days after the event~ Throughou t the test demonstration, an "event
log'' should be maintained. This log should be submitted as part of the demon-
] s;ration test report.
The test should be conducted under conditions simulating normal com-
mercial operations. Operating permit requirements usually reflect the systems'
operating conditions during the demonstration test, and conditions used in
the tests become conditions ·allowed in the operating permit. Therefore, the
applicant should give very careful consideration to the design and conduct of
the demonstration test.
If the demonstration test is initiated, but cannot be completed for
some reason, EPA/OTS can exercise several options . The first option is to
deny the operating permit without further consideration, which is rarely done .
·14
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A second option is to recommend that the applicant submit an R&D permit appli-
cation in drder to have a chance to correct operating deficiencies prior to
another demonstration. The third option is to reschetlule the test, which is
usually done when minor deficiencies in the operating process cause the prob-
lem. A fourth option is 'to require that the application or test plan be re-
vised and resubmitted before issuing another demonstration permit; this option
is usually used when major design changes must be made or major operating
deficiencies must be corrected before another demonstration test can be
performed.
3.7 Submit Demonstration Test Report to DD/EED
After a ~omplete demonstration test has been performed, a report of
the results must be made and submitted to the DD/EED. ·The format and required
contents of the report are shown in Table 10 in Section 7.0 of this document .
The test report must contain all the information described in Section 7.0 of
this document.
3.8 EPA/OTS Review of the Demonstration Test Report
\ Upon receipt, EPA/OTS will review the demonstration test report
submitt~d by the applicant. If the report is incomplete or unclear, EPA will
request that the applicant submit any additional information or data needed.
If the results of the test are unacceptable, EPA may deny the operating per-
mit, request that another demonstration test plan be submitted for approval
prior to conducting another demonstration test, or require that a revised
permit application be submitted for approval. If the test results are ac-
ceptable, EPA/OTS can issue an operating permit to the applicant.
3.9 DD/EED Issues an Operating Permit
An operating permit allows the operator to commercially operate.
After acceptance of the permit application and demonstration test results,
the DD/EED will issue a final operating .permit. Generally, the final oper-
ating permit will specify the matrix(ces) which can be incinerated, an upper
limit on PCB concentration in the feed, and an effective period of up to
3 years from the date of issuance.
For a renewal approval, additional information and/or testing of
the process may be required. In order to continue the effectiveness of a
permit pending EPA action on reissuance of the permit, the operator must sub-
mit a renewal request letter to EPA at l east 90 days, but not more than 180
days, prior to the expiration date of the permit.
15
4.0 PERMIT APPLICATION FORMAT
Paragraph 761.70(d)(l) establishes the contents required in an ap-
plication for a permit to operate a PCB incinerator. The suggested format
7 for the permit applicati~n for incineration or other thermal destruction sys~
tems is presented in Table 4 .. Each major item presented in the permit format
is discussed in the following sections. A. checklist is provided in Appendix A
to aid the applicant in determining, prior to submittal, if all requirements
for an application to operate a PCB incinerator have been addressed.
. :I
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Research and development permit applications should follow the same
format as operating permit applications although less detail is generallj
required.
4.1 Permit Application Cover
Each submission must have a permit application cover. The application
cover format is presented in Figure 4. If the application or the appendices
must be bound separately (i.e., multiple volumes), number each volume of the
submis~ion in order in the upper right hand corner of the cover ("Volume m of
n)". The cover of each volume should have the full cover information. The .
principal manager is the person identified by the applicant as the primary
contact for written or verbal communications from the EPA permit writer .
4.2 Section I -Summary
The applicant is encouraged to begin the permit application with a
short summary presenting the document organizaiion and any pertinent back-
ground information.
4.3 Section II -Project Organization
Briefly describe the organization for operating the facility. Pro-
vide 'an organization chart identifying key individuals (position titles and
actual personnel, if known). The organizational chart should primarily ad-
dress those personnel directly involved in the project: The corporate struc-
ture (e.g., relationship of company officers) is only necessary if it impacts
on the chain of command for the PCB destruction facility. Personnel who
.should be identified include:
Person(s) responsible for obtaining permit;
Project manager;
Facility manager;
Operations supervisor;
Reviewing engineer;
Maintenance supervisor;
Quality assurance officer;
Safety officer;
Laboratory personnel;
Person(s) responsible for training;
Person(s) responsible for demonstration test;
Person responsible for operation of monitoring system; and
Person ·responsible for record keeping and reporting.
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Table 4. Format for Permit Applications for PCB Incinerators
..
i Permit Application Cover
ii · Table of Contents
1.· Summary
II. Project Organization
III. Waste Description
IV. Process Engineering Description
V. Monitoring Plan
VI. Monitoring Procedures
. VII. Data Reporting/Recordkeeping
VIII. Inspection Procedures
IX. Spiil Prevention Control ~nd Countermeasures Plan
X. Safety Pl an
XI. Training Plan
XIL
XIII.
. XIV.
xv.
XVI.
XVII.
XVIII.
Plans for a Demonstration (Trial Burn)a
Test Data or Engineering Performance .Calculations
Other Permits/Approvals
Schedule of Pre~operation Events
Quality Assur~nce Plan
Standard Operating Procedures
Closure Plan
aFor a research and development permit, this section would p~esent the
planned research activities.
17
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(PRELIMINARY) PERMIT APPLICATION
-PCB DESTRUCTION UNIT
[Type and location]
[Test site for mobile units]
Submission date:
Volume m of n
Submission riumber [sequential numbering, beginning with 1]
Submitted by:
[Company name and address]
[Principal manager and phone no.]
Submitted to:
Division Director, Exposure Evaluation
Division
c/o Document Control Officer (TS-790)
Office of Toxic Substances
U.S. Environmental Protection Agency
Room E-201
401 M Street S.W.
Washington, DC 20460
Figure 4. Example permit application cover.
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4.4 Section III -Waste Description
A description of the waste(s) intended to be destroyed in the unit
· should be provid~d. As a minimum provide the following information:
The type (liquid or solid) of waste to be destroyed;
The proposed total waste and PCB feed rates; and
The matrix and composition of the waste, including major and
minor constituents, and expected PCB concentration. Heating
value, viscosity, Cl, a_sll, water content, and other charac-
teristics of the waste material should be included, if appro-
priate .
4.5 S~ction IV -Process Engineering Description
The agency needs sufficient information about a PCB destruction
process to be able to evaluate the· permit application. This information will
include detailed descriptions of the facility site, PCB and PCB-item handling,
process design and operation, pollution control equipment, and anticipated
perfo.rmance. To this end, a list of parameters to be described in the plan
is presented below for guidance._ The list is not necessarily inclusive.
-• Permit applicants should provide additional ·information where appropriate.
The following process design information should be provided for
thermal destruction· systems. If .a category is not applicable, so state.
4.5.1 General
Facility location including site map;
Layout diagram and description o'f the plant or mobile unit;
Detailed engineering drawings;
Process flow diagram (schematic diagram of the system) and
description;
Intended location of the mobile unit or facility; and
Intended location of where the unit will be stored when not i n
use (if mobile unit).
4.5.2 Waste Feed System
Narrative description.of the waste feed system (e.g., equipment
and procedures for unloading, storage, and transfer of the PCB
materials, etc.). Discussion of provisions to prevent leakage;
Description of the waste preparation system if applicable
(e.g., filtration, blending, crushing, preheating, etc.);
Waste feed storage capacity and average waste feed stored at
this location (in gallons, number of days' supply, etc.);
Volume of waste expected to be handled at this facility per
month or other time period; and
Description of waste feed rate measurement method [additional
information on measurement methods is available in (Beard and
Schaum 1978)].
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4.5.3 Waste Feed Cutoff System
Describe the automatic cutoff system for PCB feed, including the
time-delay system used before shutoff. Discuss the system operation
for shut~ff when:
Combustion chamber temperature is less than allowable;
Excess 02 value is lower than allowable;
Retention time is lower than allowable;
Burner flameout occurs;
CO and CO2 concentration in exhaust gases are different from
ranges allowed in permit; and .
Other specific process conditions are different from those re-
quired by the permit (e.g., scrubber water flow rate is less
than allowable).
4.5.4 Destruction System
Detailed narrative description of the thermal de.struction unit
including engineering data (such as chamber volume), tempera-
ture, flow rates; etc.;
Engineering ~iagrams;
Design capacity of the system;
Description of how combustion chamber volume is derived;
Heating values for waste feed and auxiliary fuel;
Feed rate for waste feed and auxiliary fuel;
Exit temperature of gases;
Calculations showing the retention time at a temperature re-
quired by the regulation [additional information is available
in (Beard and Schaum 1978)];
Description of how flow rates are regulated so that the speci-
fied retention time is maintained;
Normal operating values and acceptable ranges for the essent,al
operating parameters (e.g., chamber temperature, chamber pres-
sure, volu.me flow rate, waste feed rate, retention time, 02 ,
CO, CO 2 ) being measured; and
Expected destruction· efficiency of this unit, based on design
criteria, of pilot tests.
4.5.5 Pollution Control System (PCS)
A complete description of the type of po 11 ution control system
should be provided. In addi~ion to providing diagrams of the system, •infor-
mation on the major design parameters also should be included such as:
Total exhaust gas flow rate (dscm or dscf);
Pressure drop across the system (Pascal or in. H20);
Exhaust gas temperature (°C or °F) in the stack;
Type and concentration of pollutants (control system inlet and
outlet) if avai1able; and
Design removal efficiency' (provide calculation for basis).
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Discuss the fate of associated waste streams (e.g., ESP ash,
· scrubber Tiquid): Also provide a description of the warning system, if any,
used to signal PCS malfunction.
Provide information on the normal operating values and acceptable
ranges for significant operating variables of the scrubber, fabric filter,
ESP, or other device as described below. ,Jf information is available in the
form of vendor performance specifications,. it may be substituted.
1. Scrubber
Scrubber liquid flow rate (gpm);
Pressure drop across mist eliminator (in. H20);.
-, Makeup liquid flow rate (gpm);
_J . Nozzle operating pressure (psi);
pH of scrubbing liquid;
Liquid discharge rate (gpm);
Lime or other conditioning agent feed rate;
Liquid/gas flow rate (gpm/acfm); and
Any other information on significant operating variables not
mentioned here;
2. Fabric Filter
Differential static pressure (in. H20) between clean and dirty
side;
Dew point of. gas·es;
Description of temperature protection device or fabric filter
bypass system;
Air/cloth ratio; .
Bag material (resistant to chemical and physical properties of
the stack gas);
Description of bag cleaning system;
System for ash removal; and
Any other information on significant operating variables not
mentioned here.
3. ESP
.•
.No. of fields;
No. of Transformer-Rectifier (T.R.) sets;
Total plate area;
Primary voltage;
Primary current;
ESP voltage (secondary);
ESP current (secondary);
Spark rate;
Description of rapper system;
System for ash removal;
Dust level in hopper indicator; and
Any other information on significant operating variables not
mentioned here. ·
21
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4.5.6 Summary of Process Operating Parameters
A summary should be provided which lists target values as well as
upper and lower boundaries for a 11 measured operating parameters, instrument
7 settings, and control equipment parameters. All values must be reported in
common, consistent units. The application must also describe the action to
be taken whenever a parameter deviates .outside the boundary value. These ac-
tions may include adjusting the operating conditions, stopping the PCB feed,
shutting down the process, ~tc. The time allowable for corrective action be-
fore shut-down or other action must also be specified.
4.6 Section :v -Monitoring Plan
This section of the application provides an overview of the moni-
toring to be conducted; specifics of the monitoring equipment and procedures
are presented in Section VI of the Permit Application.
The application must include a monitoring p.lan, i.e., a summary of
the strategy to be followed in monitoring the operating and emission param-
ete~s. The monitoring .objective should be to obtain results which are repre-
. sentative. In cases where representative samples are not obtainable, a worst
case result should. be obtained. In cases where problems can be anticipated
(e.g., instrument failure), contingencies should be included in the plan.
The monitoring plan should include:
Monitoring )ocations;
Parameters to be monitored;
Monitoring methods; and :
Monitoring frequency.
A schematic diagram can be used to illustrate the monitoring points;
Figure 5 is an example. The specific location of the sampling point should
be discuss~d briefly in the narrative; e.g., the liquid waste sample will be
taken from the feed line just prior to the injection nozzle. Other important
parameters of .the monitoring plan can be concisely presented in a tabular
format; Table 5 is an example monitoring plan summary.
Thermal destruction of PCBs by incineration must follow the guide-
lines established in §761.70(a). At a minimum, monitoring and recording of
co~bustion products and incineration operations shall be conducted for the
following parameters whenever the incinerator is incinerating PCBs: (i) 02 ;
(ii) CO; and tiii) CO2 • The 0~ and CO meas~rements must be continuous. (It
is recommended that a measurement value be taken at least every 15 sec and a.
value recorded at least every minute.) If these minimum requirements cannot
be met, then justification should be provided for why less frequent measure-
ment/recording times are acceptable. The CO2 measurements, defined ~s peri-
odic, must be made at least every 15 min. Operating parameters that must be
monitored include waste feed rates, combustion temperature, and residence time.
Acceptable operating ranges for these parameters must be specified in the pro-
cess engineering information, as described in Section 4.5.6, above.
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l
Waste Feed
Bulk Storage
Tank
Primary
Chamber
..
Combustion
Air
Discharge
Venturi
Scrubber
0
Scrubber
Spray
Tower
Discharge
Demister
.V.Oke-Up
Figure 5. Schematic of sampling and monitoring points for an incinerator.
23
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V,
, . ., N .Jll, I ...... .... J Table 5. Example Summary of Monitoring Plan for a Mobile Inc.inerator Parameter Method Frequency A. Oxygen Extractive Continuous Continuously Emissioni Monitor (CEM) B. Carbon monoxide Extractive CEM Continuously C. Carbon dioxide Extractive CEM Continuously D. Combustion temperature Shielded thermocouple Continuously E. Incinerator pressure Pressure transducer Continuously F. Waste feed rate Volumetric flow meter Continuously G. Residence time Gas Velocity (Annubar®) Continuously H. Combustion efficiency Automated calculation I. Venturi Pressure drop Pressure transducer J. Venturi scrubber li-quid .flow K. Spray tower liquid flow Rotameter Rotameter L. Quench water discharge Volumetric flow meter M. Scrubber liquid dis-Volumetric flow meter charge N. Quench water makeup Volumetric flow meter 0. Scrubber liquid make-Volumetric flow meter up aRefers to Figure 2. Continuously Continuously Continuously Continuously Continuously Continuously Continuously Continuously Locationa 1 1 1 2, 3. 2, 3 4 5, 6 7 8 9 10 11 12 13 Contingency Stop Operations/Repair' System (SORS) SORS SORS Second System SORS SORS SORS Manual calcul.ation SORS SORS SORS SORS SORS · SORS SORS -i
-
According to §761.70, when an incinerator is first used to ,destroy
PCBs, sampling -of the stack emissions products must be conducted and must in-
clude measur~ment of: 02 , CO, CO2 , NO , HCl, RCl, PeBs, and total particulate
matter. The measurement of these pafameters is discussed in Section 5.0
7 (Demonstration Test Plans) of this document.
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4.7 Section VI -Monitoring Procedures
This section of the permit application should provide a detailed
discussion of the monitoring methods which will be used. The discussion for
each parameter to be monitored should i~clude:
Monitor manufacturer;
Model number;
Principle of operation;
Instrument range and accuracy;
Operating temperature range of monitor, if monitor is in situ
type; ,
Description of the system for removal of the sample if the
monitor is extractive, including sample conditioning system;
Location of the sample point(s) and an explanation of why
chosen and why the point(s) is representative;
Description of the calibration procedure and frequency;
Description of the maintenance procedures and frequency;
Description of the data recording and storage system;
Description of the system for triggering automatic feed shutoff,
if applicable;
Contingency f-0r monitor failure; e.g., install and calibrate
second monitor; and
Description of routine maintenance procedures.
Evidence that the monitoring method will generate suitable data
(e.g., performance data from a non-PCB burn of the system).
4.8 Section VII -Data Reporting/Recordkeeping
The permit application shall explicitly state what data are to be
recorded (including units) and how the data records are to be maintained.
Include example calculations, units of measurements, and example record re-
porting forms. Paragraphs 761.180(b), and 761.180(c) establish the minimum
25
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I .)
data record requirements for thermal destruction units. Minimum records in-
clude _ a summary report for the previous calendar year which contains:
Date PCBs and PCB items were received and from whom;
Date PCBs and PCB items (including process wiste which has not
been demonstrated to be free of PCB contamination) were dis-
posed of or transferred;
Summary of the total weight (kg) of PCBs and PCB articles in
containers and PCBs in transformers which have been received,
transferred to other facilities, and retained at the facility;
and ·
Summary of tne total number of PCB articles or PCB equipment
not in containers which have been received, transferred to
other facilities, and retained at the facility. ,
The following information also must be maintained on site:
For periods when PCBs are being incinerated, the rate and
quantity of PCBs fed, the temperature of the combustion
process, and the 02 , CO, and CO2 emission levels;
The demonstration test (trial burn) results;
The total weight (kg) of sol i d residues generated;
The total weight (kg) of sol i d residues disposed of·in chemical
waste landfills;
The total weight (kg) of solid residues remaining on site; and
The date, time, and duration of any suspension of incineration
operations due to automatic shutoff of feed or any other reason
.for shutdown other than routine maintenance or moving to another
disposal site [pursuant to §761.70(a)(8)], ar well as an expla-
nation of the circumstances causing suspension of operation .
(Note: This information must be sent to the· RA within 30 days
of the event.)
Additional in•formation as specified by the RA or DD/EED.
4.9 Section VIII -Inspection Procedures
The permit application shall identify the routine inspection proce-
dures used to identify problems (e.g., waste feed leak) and malfunctions (e.g.,
broken bags in the baghouse) associated with the facility. The frequency of
inspections also should be addressed. Inspection procedures should be iden-
tiJied for items such as: ·
26
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4.10
Waste feed system;
Destruction system;
Waste feed cutoff system;
Pollution control system;
Process alarms; and
Fire extinguisher system
Section IX -Spill Prevention Control and Countermeasures Plan -
Describe the procedures (including system design) which will be used
to prevent spills of PCBs. Also describe the procedures which will be fol-
lowed should a spill occur. Coast Guard regulations specifying spill preven-
tion control and countermeasure plans (40 CFR 112.7) can be used as an example
-, for the type of information which should be addressed; however, the pl an pro-
.: vided in _the permit application need not be in the format or detail specified .
in 40 CFR 112. 7. . . . .
-4.11 Section X -Safety Plan
This section addresses the safety program which will be initiated
to protect workers and other humans from PCB exposure or other health hazards ..
Identify specific items (e.g., protective clothing) of the program for ensur-
ing safe routine operations. Procedures for preventing worker/population ex-
_1 posure in the case of an equipment malfunction also should be addressed; pro-
cedures for stopping waste feed, shutting down the process, and controlling
emissions in the event of a malfunction should be addressed. Provisions for
prevention and control of fires, explosions, electrical outages, etc., also
should be addressed.
4.12 Section XI -Training Plan
-1 The permit application should 'present a description of the training
' .. )
program which will be initiated to assure workers are trained in items appro-
priate to their jobs including:
Equipment operation .(in accordance with standard operating
procedures);
Emergency shut-down procedures;
Use of protective clothing;
Waste handling;
Spill prevention/control~
Fire control; and
Hazards of PCBs.
4.13 Section XII -Plans for a Demonstration (Trial Burn)
This section of the permit should briefly summarize the applicant's
plans for conducting a demonstration test; a separate detailed plan is re~
quired prior to conducting a demonstration test (see Section 5.0 of this
document). However, summary information which should be presented in this
section includes:
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Tentative date (month/year) for the test;
Tentative location for the test;
Parameters to be tested;
Type waste to be used; and
Expected .date for submittal of test demonstration plan.·
If the applicant feels a test demonstration may not be needed for
this facility, the applicant should present a rationale for 'not conducting a
demonstration. (It is .rare than a demonstration test will not be required.
One of the few reasons for not requfri ng a trial burn is that an i dent i cal
unit has been previously tested and permitted.)
4.14 Section XIII -Test Data or Engineering Performance Calculations
·-1
.1 The applicant should present a summary of any relevant test data
from R&D activities, non-PCB burns, or other sources, or any engineering
calculations which support the ability of the thermal destruction system to
destroy PCBs. Detailed test results need not be presented in this section,
but i nstead may be provided as an appendix, or referenced if alrea9y on file
with the Office of Toxic Substances.
4.15 Section XIV -Other Permits/Approvals
.1 List other permits/approvals which have been obtained or are being
sought for this unit; identify the permitting agency and the person to contact
for additional information (permit writer). Relevant permits include PCB re-
search and development permits, operating permits fssued by an RA, state or
local permits to operate, RCRA permits, NPDES permits, and DOT permits .
4.16 · Section XV -Schedule of Pre-Operation Events
Provide a proposed schedule (month and year) for complying with the
regulatory requirements associated with approval of the facility. Scheduled
items to be addressed include: beginning construction date, construction com-
pletion date, submittal of demonstration test plan, equipment shakedown period,
initiation of demonstration test, submittal of demonstration test results,
and initial operating date.
4.17 Section XVI -Quality Assurance Plan
Each permit application must include a Quality Assurance (QA) Plan.
Note that the QA Plan must address all data-generating activities (e.~., pro-
cess monitors and controllers, not just chemical laboratory analysis). This .
plan should conform to the specifications established in "Interim Guidelines
and Specifications for Preparing Quality Assurance· Project Plans" (USEPA,
1980) and must address all measurement (i.e., monito'ring) parameters·. Addi-
tional guidance in the preparation of QA project plans is available in ''Qual-
ity Assurance Program Plan for the Office of Toxic Substances" (USEPA 1983b). 1
'. The purpose of. the Quality Assurance Plan is to establish a specific
program to: (a) help assure that the monitoring data meet specific quality
object ives, and (b) routinely assess the quality of the monitoring data. Ap-
propriate QA is impera.tive. If the data (physical or chemical measurement)
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are of unknown quality~ the data are unacceptable and cannot be used to show
a facility· is operating within permit requirements. Data of poor qua l i.ty, as
long as the quality is known, .may be acceptable depending on whether or not
the parameter is critical to PCB destruction.
The Quality Assurance Pl an should address the fo 11 owing i terns:
Organization and responsibility for QA;
Quality assurance objectives for each measurement parameter
(e.g., CO, CO2 , 02 combustion temperature in terms of accuracy,
precision, completeness, !epresentativeness, and compatibility);
Monitoring procedures (brief description); '
Specific calibration procedures and frequency;
Procedures for data reduction, validation, and reporting;
Specific internal quality control 'checks and frequency;
Audit procedures and frequency;
· Preventative maintenance procedures and frequency;
Specific routine procedures to assess accuracy, precision, and
completeness;
Procedures for corrective action; and
Quality assurance reports to management.
Each of these items is discussed in "Interim Guidelines and Specifi-
cations for Preparing Quality Assurance Plans"; _the applicant is advised to
follow this document .
4.18 Section XVII -Standard Operating Procedures
A summary of the standard operati-ng procedures (SOP) should be in-
cluded in this chapter. The SOP should consist of the procedures available to
the facility operators for use in plant operations. The complete SOP should
be included as an appendix. Applicants may submit a copy of the process oper-
ating manual to satisfy this requirement.
Applicants should be required to develop a SOP and submit it to EPA
two weeks prior to the demonstration. The SOP:.
Assures that applicants have reviewed the operations in detail;
Gives EPA opportunity to review and become familiar with the
operations prior to the on-site audit; and
May be used as a tool for training new employees, which gives
some assurance that the employees have received a minimum of
training.
An SOP should be a step-by-step procedure; however, details of pro-
cedures such as the use of equipment (e.g., Modified Method 5) may be omitted
but must be referenced. Divergence from the SOP during trials or commercial
runs should be documented and significant modifications should be .submitted
to EPA. For convenience of use, lab procedures should be separate from system
operational procedures.
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The SOP should be part of the training plan. Each new employee
should-sign and date a statement indicating that the employee has read and
understood the SOP.
4.19 Section XVIII ,-Closure Plan
The closure plan for the facility should address two situations:
For mobile units, closure of the facility at each site prfor
t .o moving to a new site. Closure must address items such as
decontamination of the equipment, placarding any contaminated
equipment, and disposal of any wastes generated from decontam-
ination or cleanup activities; and
For both mobile · and stationary facilities, permanent closure
(i.e., removal from service).
The closure plan(s) should address:
Responsible personnel;
Disposal of by-product wastes on a routine basis;
Disposal of equipment; and
Financial responsibility of t he company .
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5.o · DEMONSTRATION TEST PLANS
This section pre~ents the suggested format ·for a Demonstration Test
(Trial Burn) Plan and briefly discusses the major items of information which
must be submitted in the-·plan. ·
A Demonstration Test Plan is a -0ocument prepared specifically for
the demonstration tests and provides details of how the test will be conducted.
This includes details of: when .and where the demonstration will be conducted
and by whom; process/pollution control operating parameters to be maintained
during the test; waste feed quantity and type; parameters to be monitored/
sampled; sampling/monitoring locations, frequency, and methods; sample analysis
methods; equations for calculating results;. and quality assurance procedures.
5.1 General
The minimum contents required in the trial burn plan are specified
in §761.70(d)(2) as follows:
Date of trial burn;
Quantity and type of PCBs and PCB items to be incinerated;
Parameters to be monitored and location of sampling points;
Sampling frequency and methods and schedules for sample
analyses;
Date and location of analyses; and
Name, address, and qua l i fi cations of persons who wi 11 review
analytical results and other pertinent data, and who will per-
. form a technical evaluation of the effectiveness of the trial
burn.
5.2 Contents of a Demonstration Test Plan
The Demonstration Test Plan must contain all the required informa-
tion as described in this document. Table 6 presents the format for a Demon-
stration Test Plan.· Contents of the Demonstration Test Plan, prepared accord-
ing to-the recommended format, are discussed in the following paragraphs.
Appendix A provides a checklis~ to aid the applicant in determining whether
all required items have been addressed.
5.2.1 Test Demonstration Plan Cover
A cover must be provided for the Demonstration Test Plan. Figure 6
presents the cover format to be used. If multiple volumes are submitted, pro-
.vi de a .cover for each volume and number each volume in the upper right hand
corner, "Volume!!! of.!!·"
5.2.2 Section I -Summary
The applicant should begin the plan with a short summary of the docu-
ment. The summary should indicate when, where, and by whom the test will be
conducted. A brief background discussion on the unit to be tested also is use-
ful (e.g; type ·of unit, intended use, summary of pr,evious tests or operations).
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Table 6. Format of Demonstration Test Plan for Incinerators ..
i Test Plan Cover
ii Table of Contents
I. Summary
II. Project Organization
III. Process Engineering Information (new information to application)
IV . Process Operation
V. SampHng and Monitoring Plan
VI. Sampling and Analysis Procedures
VII. Monitoring Procedures
VIII. Data Reporting
IX. Miscellaneous Tests
X. Test Schedule
XI. QA Plan (addenda to Permit QA Plan)
XII. Standard Operating Procedures (addenda to Permit SOP)
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(PRELIMINARY) DEMONSTRATION TEST PLAN
-1
.:i PCB DESTRUCTION UNIT
[Type and location]
[Test site for mobile units]
· Proposed test dates:
Submission date:
Volume m of n - -
Submission number [in sequence with permit application submissions]
--•
Submitted by:
[Company name and address]
[Principal manager and phone no.]
Submitted to:
Division Director, Exposure
Evaluation Division
c/o Document Control Officer (TS-790)
Office of Toxic Substances
U.S. Environmental Protection Agency
Room E-201
Washington, DC 20460
Figure 6. Cover for the Demonstration Test Plan.
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5.2.3 Section II -Project Organization
Provide an organizational chart and narrati~e description, as neces-
sary, to identify the key personnel for the project. Identify personnel who -
have overall authority/responsibility for conducting the demonstration test
and their relationship to key personnel having overall a_uthority/responsibil-
ity for the project. It is not necessary :to repeat detailed information on
overall project authority/responsibility that has previously been submitted
in the permit applicatiori. ,However, a consolidated organizational chart is
generally advisable so that lines of authority can be identified. Key areas
of responsibility which should be identi_fied include:
Overall project responsibility;
Facilities manager; _
Test demonstration coordinator/manager;
Operations manager;
-Sampling crew chief;.
Monitoring systems .operator;
Analytical manager/key analyst;
Quality assurance officer;
Safety -officer; end ·
Operators and laboratory technicians.
Qualifications of the key individuals who will be operating the _
system and conducting the sampling, monitoring, and analysis are to be pro-
vided with the Demonstration Test Plan.
5.2.4 Sect1on III -Process Engineering, Information
This section -provides a general overview of the process, including
· a simplified flow diagram. · Detailed information about the process should be
in the permit application and may be referenced. However, if modi fi cat ions
have been made to the system since the permit application, these modifications
should be addressed.· Similarly, if any modifications to the normal process
systems will be required during the demonstration, these should be addressed;
for example, if waste will be pumped from '55-gal. drums during the demonstra-
tion, in lieu of using a bulk feed storage tank which will be used during
normal operation,. this deviation must be noted and explained.
5.2.5 Section IV -Proc~ss -Operation Test Parameters
This section presents the operating parameters to be maintained dur-
ing the Demonstration Test. Information which should be presented includes:
Operational plan;
Process operating parameters;
Anticipated emission levels; and
PCBs or PCB items to· be fed as waste .
A brief operational plan should be provided. This plan may take
the ,form of a detailed schedule of events. In the ope rat ion al pl an explain
the operating parameters which will be maintained while bringing the unit on-
line, while conducting the demonstration and while taking the unit off-line.
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For example, will the unit be brought on line and its operation first be
demonstrated using auxiliary ·fuel? Will a non-PCB "waste feed" first be used ·
to ~emonstrate safe operation?
The process operating conditions and anticipated emissions can be
summarized in a tabular format. Table 7 is an example "test parameter sum-
mary" for an incineration system. Note that control limits (i.e. acceptable
ranges) are presented for key operating parameters.
Identify the waste feed which will be used during the demonstration
test. State the type of feed, physical state, heat content, and composition
•including anticipated PCB concentration. State the total quantity of feed to
be used during the demonstration. Explain how the waste feed used for the
demonstration compares to the waste which will normally be processed during
routine operation; i.e., the same, worst case condition, mixture of antici-
pated wastes. Explain the provisirins established for storage of the wastes
prior to and during the demonstration, if different from normal.
5.2.6 Section V -Sampling and Monitoring Plan
This section presents the sampling and monitoring plan for the demon-
stration test. The plan should be ~etailed and specific to the demonstration.
~ The plan should address all sampling and m6nitoring which will be conducted
during the demonstration; i~e., both sampling/monitoring which will be rou-
tinely conducted during normal operation and sampling/monitoring which will
be conducted only during the demonstration test. A tabular format, with nar-
rative explanation, as necessary, can be used to summarize the sampling and
monitoring plan. The sampling/monitoring pJan should include the following
elements:
A descri tion of the system or process being sampled or moni-
tored including sampling location) and breakdown of the pro-
cess into discrete sampling uni ts (stack emissions, liquid
waste, ash, etc.).·
The number of tests to be conducted and the schedule.
Generally, three tests are conducted on successive days
for incinerator~.
The objective of the sampling or monitoring for each unit (e.g.,
collect a 11 representative11 sample ; follow an EPA test protocol;
or collect a "worst case" sample). · ·
The parameters t~ be tested: Li st the compounds, phys i ca 1
measurements and media.
The sampling or monitoring methods: List the methods to be
used. Detailed description of the methods may be presented in
this section or an appendix.
The sample analysis method : List the analytical methods to be
used . Detailed description of the methods may be presented in
this section or an appendix.
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Table 7. Example Summary of Anticipated Test Parameters
for an Incinerator
;
Par_ameter
Fuel/Waste Feed
Waste feed rate (kg/hr)
PCB concentration in feed (g/kg)
Total chlorine in feed (g/kg)
PCB feed rate (kg/hr) 1
Chlorine feed rate (kg/hr)
Auxiliary fuel feed rate (kg/hr)
Total thermal duty (106 BTU/hr)
Combustion Conditioris
Combustion air flow rate (acm/min)
Residence time (sec)
Destruction temperature (°C)
Combustion gas· oxygen (%) ·
Combustion gas carbon dioxide(%)
Combustion gas carbQn monoxide .(ppm)
Combustion efficiency(%)
Emissions
Combustion gas NO (ppm)
HCl removal (%) x ·
Particulate concentration (mg/dscm)
PCB DRE(%)
Pollution Control
Scrubber water flow (gpm)
Scrubber water (pH)
Venturi water flow (gpm)
Venturi pressure drop (in. H20)
Anticipated
val ue
100
350
250
35
250
15
4.5
60
2.2
1,250
5
12
20
99.98
40
99.95
< 180
. > 99. 9999
100
8.5
75
25
Control
limits
85-115
NA
NA
NA
NA
NA
< 5.0
< 65
< 2
1,150-1,350
< 4
NA
< 100
> 99.9
NA
NA
NA
NA
> 85
8.0-10.0
60-100
> 20
] aNA (not applicable)
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Required
value
NAa
NA
NA
NA
NA
NA
NA
< 65
2
1,200 ± 100
--3
NA
NA
99.9
NA
> 99.9
< 180
> 99.9999
NA
NA
NA
NA
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The sampling or monitoring design for each unit. This may re-
quire a mathematical sampling design or simply a reference to
a standard protoco·l (e.g., EPA Reference Method 3, 40 CFR GO--
Appendix A). The frequency (e.g., every 15 min), size (e.g.,
10 m3 ), timing (e.g., any time after reaching steady-state),
number of replicates (e.g. , 10% of the samples or 2 samples,
whichever is greater, collected in triplicate), number of
surrogate-spiked samples, and total number of samples should
be listed for each sample type. The sample size is usually
dictated either by the amount of sample required to detect the
analyte or by convenience (e.g., 1 liter for water).
An estimate of sample representativeness. Thi's may be .based
on data (e.g., historical data on replicates) or scientific/
engineering judgment (e.g., a sample from an actively mixed
feed tank might be characterized as representative).
Contingencies for action if samples cannot be collected ac-
cording to the _plan (e.g.-, alternative sites or times, an
entirely new sampling plan, or repeat tests).
The .parameters ,which typically sh.ould be included in the sampling/
monitoring plan for an incinerator are discussed below .
Paragraph 761.70 states that 11 monitoring of stack emission products
shall be conducted [during a test burn] ... for the following parameters:
(a) 02 , (b) CO, (c) CO2 , (d) oxides of nitrogen (NO), (e) hydrochloric acid
(HCl). (f) total chlorinated organics (RCl), (g) PCe<s, and (h) total particu-
late matter [at a minimum]~11
Parameters which must be monitored as part of normal operation
(henc~, also during the demonstration test) include:
Rate and quantity of waste feed;
Combustion temperature;
Oxygen concentration; and
Combustion efficiency (CO2 and CO concentration).
In addition to those required by 40 CFR 761.70, and as part of the
normal operation, EPA ·has determined that the following parameters be moni-
tored for certain destruction tests:
~ Total PCB content of the waste feed in order to calculate the
DRE;
• PCDD and PCDF (tetra-through octachloro homologs, 2,3,7 :s-.
tetrachlorodibenzodioxin, and 2,3,7,8-tetrachlorobidenzofuran)
in the stack emissions; and ·
PCB, PCDD, and PCDF concentrations (see Table 8) in any solid
or liquid waste_s generated.
Appropriate operating parameters of the pollution control system
also should be monitored and the data recorded during the demonstration test
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Table 8. PCDD and PCDF Reporting Formata
PCDDs Concentrationb PCDFs Concentrationb
2,3,7,8-tetra COD 2,3,7,8-tetra CDF
Total tetra COD Tot al tetra CDF
Total penta COD Tot al penta CDF
Total hexa CDD Tot al hexa CDF
Total he_pta CDD Tot al hepta CDF
Total octa CDD Tot al octa CDF
Total PCDDs Total PCDFs
alimit of quantitation must' be S 10 ng/m3 /congener for air samples and
bS 1.0 ng/g/congener for solid and liquid wastes.
ng/m3 for air emis_sions; ng/g for solid and liquid wastes.
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(e.g.,, scrubber water flow rate and pressure drop). The parameters to be
monitoted ~hould be included in the sampling/monitoring plan.
5.2.7 Section VI -Sampling and Analysis Procedures
Specific details of the sampling and analysis procedures which will
be used during the demonstration test must be included in the Demonstration
Test ;Plan. When 11 standard methods 11 will be used, they may be referenced and
i ncl,uded as · an appendix. However, any deviations from 'standard procedures
must be noted. Any modifications to the published procedures or selection
f rom a number of options given in a procedure should be documented. Further-
more, when the standard method allows different procedural variations to be _
used, the applicant must be specific as to the procedures which will be fol-
lowed (e.g., for the measurement of 02 and CO 2 concentrations in the stack
gas by EPA Method 3, will multipoint integrated sampling or single point grab
sampling be used?).
The discussion of sampling and analysis methods should include:
Sampling equipment;
Sampling equipment calibration;
Sampling procedures;
Sample recovery, storage, and preservation;
Sample transport and custody;
Analytical equipment;
Reagents;
Reagents preparation (e.g., XAD resin preparation);
Calibration standards;
Calibration procedures; and
Sample method blanks.
Appendix B to this document provides guidance on sampling and ana-
lytical methods.
5.2.8 Section VII -Monitoring Procedures
Specific details of the monitoring procedures to be used during the
demonstration test must be included in the Demonstration Test Plan. If these
procedures have been completely described in the permit application and have
not changed, the permit application may be referenced. The following infor-
mation must be included:
Type of instrumentation;
Manufacturer, model number;
Sample conditioning system, if applicable;
Calibration standards; and
Calibration procedures .
Brief descriptions of some monitoring procedures which typically
have been used for PCB destruction systems are presented in Appendix B to this
report.
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5.2.9 Section VIII -Data Reporting
Present a summary of the data to be obtained during the demonstra-
'tion test and to be ·presented in the final test report. Example calculations
and reporting units should be presented. Include information for process data,
pollution control system operating data, waste feed, effluent waste, product
streams, and emissions.
I All chemical analytical values must be reported as concentrations,
expressed as:
Percent for 02 and CO2 ;
Part per million for trace gases in air (e.g., CO);
Micrograms per cubic meter for organics in air (e.g., PCBs);
• ·Micrograms per liter for water; and
Micrograms per gram for nonaqueous liquids or solids.
To ca1c·u1ate destruction efficiency, PCB values in stack gas and
waste feed are to be reported as "total PCB" (a sum of all 209 congeners).
A breakdown of the tota 1 . PCB value by homo 1 og or co.ngener may be useful for
certain destruction tests. PCB values in product oil, liquid waste, solid
waste,· and other streams must be. reported in micrograms per gram (µg/g) per
resolvable chromatographic peak. The analytical results may not be reported
in terms of Aroclor (or other mixture) concentrations, even if an Aroclor is
used to calibrate the instrument (as in the waste feed) unless EPA gives prior
approval.
PCDDs and PCDFs are to be reported by homo log (i.e., total octa-
chlorodibenzofurans, etc.) for the tetra-through octachloro homo logs and
summed to give total PCDD and PCDF values as a minimum. Separate values
should be reported for 2,3,7,e~TCDD and 2,3,7,8-TCDF (see Table 8, p. 38).
Any other compounds detected should be reported ·as quantitated, but
only if the sampling and analytical methods are valid for the subject compound.
5.2.10 Section IX -Miscelfaneous Tests
. )
The proper operation of the automatic waste-feed· cut-off and other
emergency systems must be demonstrated. Describe the procedures to be used
during the demonstration test to check operation of alarm and emergency sys-
tems, including:
.. Waste feed cut-off system;
Alarm systems (e.g., high temperature); and
Fire extinguisher system._
These tests must be included on the schedule (see below) .. They may
be conducted at the conclusion of testing to minimize downtime in PCB
processing.
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5.2~11 Section X -Test Schedule
Provide a detailed schedule of the proposed demonstration test
period. The schedule should be of sufficient detail to determine what activi-
ties are planned for each day. Table 9 is an example demonstration test
schedule. The schedule should be realistic in the sense of including suffi-
cient time to address problems which can ·be expetted to occur in operating a
new process.
5.2.12 Section XI--Qua l ity Assurance Plan
Each Demonstration Test Plan must include a Quality Assurance Proj-
ect Plan.· If an adequate Quality Assurance Project Plan has been submitted
with the permit application, then only addenda to the QA plan specific to ad-
ditional sampling, monitoring, and analysis for the test demonstration, need
be submitted with the Test Demonstration Plan. Those portions of the QA plan
which apply to normal operations and those which apply only to the demonstra-
tion test must be clearly identified. In any event, the QA plan, with addenda,
must address all measurement parameters (e.g., CO emissions, combustion chamber
temperature), not merely PCB sampling and analysis.
The QA plan must conform to tbe specifications established in
"Interim Guideline and Specifications for .Preparing Quality Assu.rance Project
Plans" (USEPA, 1980). A QA plan prepared according to these specifications
will address the following items:
Organization-and responsibility for QA;
QA objectives for each measurement parameter (precision, ac-
curacy, completeness, representativeness, and compatibility);
Sampling and monitoring procedures; ·
Sample .custody;
Calibration procedures and frequency;
Analytical procedures; ·
Data reduction, validation, and reporting;
Internal quality control checks and frequency;
Performance and system audits ·and frequency
Preventive .maintenance procedures and schedules
Specific routine procedures to assess data precision, accuracy,
and completeness;
Corrective action; and
QA reports to management.
Additional guidance in the preparation of QA project plans is available in
11Qual ity Assurance Program Plan for the Office of Toxic Substances" (USEPA
1983b).
For most sampling and analysis plans, a minimum of 10% or 2, which-
ever is greater, of the samples must be collected in triplicate; a minimum of
10% or 2 of the samp 1 es, whi .chever is greater, must be QC controls; and a ·
minimum of 10% or 2 of the samples, whichever is greater, must be QC blanks.
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2
3
\ Table 9. Example: Proposed Schedule for Trial Burn
Tentative
date
. xx/yy/zz AM
AM/PM
Activity
Inventory waste feed
Begin system shakedown using
auxiliary fuel
AM/PM •
AM/PM •
Continue system shakedown
Calibrate continuous emis-
sion monitoring system
AM/PM • Continue system shakedown
PM • Check emergency alarm/cut-
off systems ·
AM/PM • Continue system shakedown
AM/PM • Continue system shakedown
AM/PM • Continue system shakedowna
AM • Test crew arrives on site
PM • Test equipment set-up
AM
PM
• Be¥in_PCB destructi8n ·
Em1ss10n test No. 1
AM/PM • Emission test No. 2b
.AM/PM • Emission test No. 3b
• Shut unit down at comple-
tion of test according
to closure plan
aSystem shakedown should continue until system is able to operate without
significant downtime (e.g., a minimum ·24 h of operating time witheut
significant downtime is recommended).
bunit will be returned to auxiliary ·feed at end of each emission test; unit
wi 11 be switched to PCB waste in early AM.
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5.2.13 Section XII -Standard Operating Procedures
Provide any addenda to the Standard Operat~ng Procedures submitted
with the permit application, if necessary.
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6.0 CONDUCTING AND MONITORING A DEMONSTRATION TEST
Once the Agency has determined that the Demonstration Test Plan is
complete, a demonstration will be scheduled at a date agreeable to both the
applicant and the agency~ Before the demonstration can commence, the Agency
will issue an approval for a demonstration, i.e., a demonstration permit.
The approval will contain certain conditions, including advance 30-day noti-
fication of the demonstration to other appropriate authorities (i.e., Regional
Administrator, state and local offices), PCB-containing material(s) to be
treated, sampling, analysis, waste disposal , 'QA, site security, recordkeeping,
and reporting requirements. A copy of the demonstration permit must be on
site and adhered .to during the demonstration.
If any modifications to the test plan are required prior to the' ·
demonstration test, the Agency (permit writer) should be notified in writing
within 14 days prior to the test. Also, if events require that the plan be
significantly modified during the test demonstration, then the permit writer
should· be contacted immediately to discuss the implications of any modifica-
tions. As with normal operation, any significant deviations from or altera-
tions in the standard operating procedure must be documented in writing_ to
the Agency (permit writer) within 10 days of the event. Throughout the test
demonstration, an "event log" should be maintained. This log should be sub-
mitted as part of the demonstration test report .
Provided that other local, state, and federal regulations allow it,
one or more pre-tests may be conducted using a .non-PCB feed to shake down the
facility. For example, if permitted, a test of an HCl scrubber on an incinera-
tor could .be conducted using a chloroform-containing feed to simulate the HCl
produced by the burning of PCBs. Furthermore, an R&D permit may be advisable
to allow the applicant to test the facility with PCBs in the field prior to a
full scale process demonstration (see Section 4.1). EPA encourages applicants
to thoroughly shake down their processes before the demonstration tests. The
EPA may approve shakedown on a limited quantity of PCBs under an R&D permit ..
Prior to the test, the facility must be prepared~ All instruments,
controls, devices, etc., must be in working order and calibrated. Sufficient
supplies of PCB waste, fuel, reagents, etc., must be on hand. The facility
should be cleaned (remove all waste, purge scrubbers, etc.) to prevent contami-
nation from previous tests or other use.
The test should be conducted under conditions simulating normal com-
mercial operations. Permit requirements usually reflect the systems' operat-
ing conditions during the demonstration test, and conditions used in the tests
become conditions allowed in the permit. Therefore, the app ,licant should give
very careful consideration to the design and conduct of the demonstration test.
Each demonstration usually consists of the following three steps:
6.1 Start-up
The i nc -i nerator is brought up to steady state with no PCBs in the
system. As soon as steady-state conditions are reached during the start-up
phase of the test, conditions should be noted and samples collected to charac-
terize background conditions. When the monitoring equipment is ready for
44
--.
7
collecting the next set of samples, the PCB waste should be introduced into
the i nc:i ner-ator.
6.2 PCB Waste Destruction
The PCB waste is introduced into the incinerator at expected normal
feed rates and expected maximum PCB concentration&. During the test, samples
should be collected and records kept of the readings of the continuous moni-
tors. Visual observation of the effluent should also be made, where appro-
priate. The test should only be as long as necessary to collect samples for
analysis. A 3-to 4-hr emission test is normal for incinerators; three test
runs are normally conducted on successive days.
For stack emission ,testing, the probe should usually be ins~rted
into the stack about 30 min after starting the PCB waste feed. This allows
sufficient time for volatilizati~n and destruction of PCBs in the combustion
chamber(s) and for sampling of representative combustion gas emissions during
PCB incineration.
6.3 Shutdown
Waste feed is terminated and the incinerator is then shut down per
normal procedures or kept running on non-PCB fuel at the discretion of the
-1 operator.
45
7.0. DEMONSTRATION TEST REPORT
After the demonstration test has been performed, a report of the
results must be prepared and submitted to the DD/EEO. The format and the
~~ required contents of the·test report are presented in this section.
-I
7.1 Format and Contents
Table 10 presents the format for the demonstration test report. The
following paragraphs briefly describe the report contents; The test report
must contain all of ·the requir~d information as described ih this document.
7.1.1 Demonstration Test Report Cover
Figure 7 is the specified format for the report cover.
If the report or the appendices must be bound separately, number
each part -0f the submission in order (Volume~ of n). The covers of each
volume should have the full cover information as descri bed above.
7.1.2 Certification Letter
This letter, signed ·by an authorized official, must certify on behalf
of the applicant that the test was carried out in accordance with the approved
test plan and the result~ of all determinations are submitted in the report.
7.1.3 Section I -Summary
The report should begin with a short summary. The summary contains
table(s) summarizing the pertinent test results; Table 11 is an example sum-
mary table for an incinerator demonstration test. A brief narrative should
summarize whether or not the facility met all performance requirements. Major
problems encountered and major deviations from the test plan should be men-
tioned.
7. 1. 4 Sect ion II -.Process Ope rat ion c
7 .1. 4.1 General
Provide a general overview of the process using simplified flow
• diagrams and a brief narrative .. Detailed information on the process should
be in the permit application and may be referenced.
7.1.4.2 Operation During the 'Test
Summarize the operating parameters of the process during the
destructi.on test. Include physical characteristics of the feed, PCB content
of ·the feed, feed rates, total feed quantity, temperatures, pressures, efflu-
ent stream flow rates and volumes, pollution control system operating param-
eters, and combustion gas composition (CO, CO2 , 02 , excess oxygen). A tabular -
_format with explanatory narrative, as necessary, is preferred. Detailed data
such as tables of 15~min temperatur~ readings and the process operator's log
should be relegated to an appendix.
46
..
-
Table 10. Format for the Demonstration Test Report
7 i Report Cover
ii Table of Contents
iii Certification Letter
I. Summary
II. Process Operation
III. Sampling and Monitoring Procedures
IV. Analytical Procedures
V. Test Results
VI. QA Summary .. VII . Visits and Audits
VIII. Closure
IX. Waste Disposal Manifests
Appendices
•
47
1"
7
DEMONSTRATION TEST REPORT
PCB DESTRUCTION UNIT
[Type and location]
[Test site for mobile units] · -l Test dates: __________ _
.1 Submission date:
Volume m of n
Submission number [in sequence with permit application and test plan submissions]
-·•
Submitted by:
[Company name and address]
[Principal manager and phone no.]
Submitted to:
Division Director, Exposure Evaluation
Division
c/o Document Control Officer (TS-790)
Office of Toxic Substances
U.S~ Environmental Protection Agency
Room E-201
401 M Street, S.W.
Washington, DC 20460
Figure 7. Demonstration•Test Report cover.
48
. .. .
Table 11. Example Demonstration Test Results Summary
Date
Time test begun
Time test ended
Operating parameters:
Waste feed rate (kg/h)
PCB concentration (g/kg)
PCB feed rate (kg/h)
Auxiliary fuel feed rate (~g/h)
Total thermal load (106 BTU/h)
Avg. calculated residence timea (sec)
Avg. combustion air flow (acm/min)
Avg. oxygen (%) ·
Avg. carbon dioxide(%)
Avg. carbon monoxide (ppm)
Combustion efficiency(%)_
Avg. scrubber water flow (gpm)
Avg. scrubber water (pH)
·Avg. venturi water flow (gpm)
Avg. venturi pressure drop (in. H20)
Particulate/HCl emissions:
Total sample time (min)
Total sample volume (dscm)
Stack gas flow rate (dscm/min) b
Particulate concentration (mg/dscm)
Chlorine (g/min)
HCl removal (%)
PCB emissions:
Total sample time (min) .
Total sample volume (dscm)
PCB feed rate (g/min)
PCB output rate (g/min)
PCB DRE(%)
PCDD/PCDF emissions:
Total sample time (min).
Total sample volume (dscm)
Total PCDD emissions (ng/dscm)
Total PCDF emissions (ng/dscm)
Test
1
~Calculated from statk gas volumetric measurements.
Corrected to 12% CO2 •
49
Test
2
Test
3
7.1.4.3 Deviations from Test Plan
Any events such as upsets, shutdowns, ·or other deviations from
· normal operations, along with the corrective actions taken must be described.
7 These deviations · should -have been previously reported to the permit writer,
verbally during the test and as a separate written incident report within 14
days of the incident. These incident reports should be presented in an ap-
pendix. This section should summarize the incidents, discuss their effect on -
the. test results, and discuss their effect on the overall ability of the
system to routinely operate within permit conditions.
Also describe non-incident-related changes such as ' site loca-
tion, amount of PCBs treated, and use of an independent laboratory for analy-
·-1 sis. The purpose or reasons for these types of changes should be explained
.i in this section.
• I
7.1.5 Section III -Sampling and Monitoring Procedures
Describe the sampling and monitori ng procedures used. Standard pro-
cedures may be referenced, but any deviations or modifications from referenced
methods must be described. Lengthy method descriptions should be placed in
the appendix .
Summarize the type, location, time, volume, and number of samples
collected. Any significant deviations from the Demonstration Test Plan must
be noted and the potential effects on the resuJts discussed.
Summarize ihe type, 1o'cation, and time period of all monitoring.
Any significant deviations from the Demonstration Test Plan must be noted and
the potential effects on the results discussed.
7.1.6 Section IV -Analytical Procedures
Describe the analytical pr6cedures used for each parameter (e.g .. ,
PCBs in water). Sta.ndard procedures may be referenced, but any deviations or
modifications from referenced methods must be described. Identify deviations
from the Demonstration Test Plan~ . Lengthy descriptions should be placed in
an appendix. · /
7.1.7 Section V -Test Results
Present concise summaries for a 11 pertinent parameters such as:
Stack emissions (NOx, HCl, RCl, particulate, PCB, .PCDD, PCDF);
Influent and effluent stream analyses;
Stack gas monitoring (CO, CO 2 , 02 ); and
Performance results (DRE, combustion .efficiency).
Discuss the test and QC results -and analysis system performance as necessary.
All results should be traceable to the original · test data. As a minimum,
" identify how the results were calculated (formulae and data used). Detailed
sample calculations should be presented in the appendix and referenced. For
50
..
--
,
7
-l
example, for calculation of the DRE, th~ equation used should be shown ~r
referenced,·
w. -w
DRE= in w. out x 100
in .
The values for W. and W used in the calculation should be clearly iden-
tified (i.e., th~'lable o~u~age number where they appear in the report) along
with the calculated result, so that the DRE calculation may be confirmed'.
Identify and discus~ any anomalies in the system operation, sampling,
monitoring, or analyses that may have significant impact on the test results.
_t Raw data and raw analytical results (e.g., chromatograms, mass mea~
surements) also should be presehted in the_appendices.
7.1.8 Section VI -Quality Assurance Summary
Summarize the QA results (blanks, replicates, audit results). Iden-
tify any serious problems (e.g., unacceptable audit results, failure to cali-
brate instrumentation) or deviations from QA protocol. A separate QA report
must be presented, authored and signed by the QA officer. The QA report
-~ should address all the QA objective~, including whether or not precision and
accuracy objectives were met, as well as results of quality control samples,
performance audit samples, and systems audits.
7.1.9 Section VII -Visits and Audits
This section should contain a list of visitors and auditors and the
affiliation, address, and phone number of those who were on site during the
-, demonstration. The list should include all visitors or auditors from state,
local, or federal agencies, their contractors, applicant management, QA per-
sonnel, and independent consultants. Where possible, the purpose of these
· visits and any significant results should be summarized. If audit reports,
engineering certifications, etc., were issued by any visitors, they should be
appended to the demonstration test report ..
7.1.i0 · Section VIII -Closure
-~ The applicant should summarize the facility closure after the demon--·• stration. Any deviations from the closure plan should be discussed. Appl ,i-
cant should provide documentation (copies of manifest) to show that all wastes
generated during the process test were properly disposed according to TSCA
and RCRA regulations. Applicant should be aware that all the waste generated
during the test should be disposed of by incineration and not landfilling,
unless compliance with the landfill restrictions can be demonstrated .
. 7.1.11 Appendices
Supporting information (e.g., detailed procedures, analytical re-
sults, sample calculations, QA report) should be presented in the appendices.
51
--
7
Include the chronological demonstration test events log and any incident
reports.
7.2 Review
The permit writer will review the rep~rt to determine if it contains
all necessary elements and if the demonstration has met the objectives of the
test.
7.3 Approval
Upon acceptance of ·the process demonstration test report and a de-
termination that the proc~ss operates within all of the pertinent requirements -l of 40 CFR 761 and the conditions of the demonstration permit, the DD/EEO shall
.1 issue a final permit to operate commercially. The operating permit will con-
tain certain conditions, including matrices to be treated, maximum PCB concen-
trations to be treated, waste disposal, site security, recordkeeping, report-
ing, and closure requirements. A permit will normally be issued for 3 years'
operation. A copy of this approval should be on site and adhered to during
all operations.
52
..
--
I
7
8.0 REFERENCES
Beard, J. H.; III, ~nd J. Schaum, ''Sampling Methods and Analytical Procedures
Manual ·for PCB Disposal:~ Interim Report, Revision O,'' Office of Solid Waste,
U.S. Environmental Protection Agency, Washington, DC {February 10, 1978).
U.S. Environmental Protection Agency, nPolychlorinated Biphenyls (PCBs) Manu-
facturing, Processing, Distribution in Commerce, and Use Prohibitions," Fed-
eral Register, 44, 31514-31568 (May 31, 1979). -
U.S. Environmental Protection Agency, "G.uidelines and Specifications for Pre-
·paring Quality Assurance Project Plans;-" Office of Monitoring Systems and . -l Quality Assurance, QAMS-005/80, December 27, 1980:
_ j
'J
U.S. Environmental Protection Agency, 40 CFR Part 761, "Procedural Amendment
of the Approval Authority for PCB Disposal Facilities and Guidance for Obtain-
ing Approval," Federal Register, 48, 13181-13186 (1983a) [has been superseded
by USEPA (1985)].
U.S . Environmental Prote.ction Agency, "Quality Assurance Program Plan for
the Office of Toxic Substance,'' Office of Pesticides and Toxic Substances,
Washington, D. C. , September 30, 1983b. ·
U.S. Environmental Protection Agency, 1985a, Code of Federal Regulations,
Title 40, Part 60 (40 CFR 60) "Standards of .Performance for New Stationary
Sources, Appendix A --Reference 'Methods 11. .
U.S. Environmental Protection Agency, 1985b, Code of Federal Regulations,
Title 40,Part 761 (40 CFR 761), "Polychlorinated Biphenyls (PCBs) Manufactur-
ing, Processing, Distribution in Commerce, and Use Prohibitions."
: Weller, P; J., J: Andis, and S. Baig, "Preliminary Study Regarding Alternative
Definitions of PCB Solid/Liquid Wastes," dated October 1981, Appendix H in
R. G. Mcinnes and R. J. Johnson, "Provision of Technical Assistance to Support
Regional Office Implementation of the PCB Regulations--East and West," Draft
Project Summary Report by GCA Corporation, New Bedford, MA, and TRW, Inc.,
Redondo Beach, CA, on EPA Contract No. 68-02-3168, Work Assignment No. 45, and
Contract No. 68-02-3174, Work Assignment No. 68, for David C. Sanchez, USEPA,
Office of Research and Development, !ERL, Research Triangle Park, NC, 1982,
186 pp. .
53
--
APPENDIX A
CHECKLISTS FOR COMPLETENESS OF SUBMITTAL
-l
A-1
j
--
APPENDIX A.1
PERMIT APPLICATION CHECKLIST FOR INCINERATORS
7
L Permit Cover
2. Summary· (Section I)
··1 3. Project Organization (Section II)
· i A. Chart
B. Text
4. · Waste Description (Section III)
A. Type
B. Total Amount/Feed Rate ·
C. Physical/Chemical
Description
5., Process Engineering (Section IV)
A. General Overview
• Description
• Flow Diagram
• Location
.. Site Maps
B. Waste Feed System
C. Waste Feed Shut Off System
D. Destruction System
E. Pollution Control System
F. · Operating Parameters
6. Monitoring Plan (Section V)
A. Parameter List ,
(see at~ached supplemental
· checklist)
B. Monitoring Frequency
C. Monitoring Plan Design
D. Meth6ds
7. Monitoring Procedures
(Section VI)
A. Appropriate Methods
B. Written Protocols
C. Apparatus
D. Data Reduction
E. Data Storage/Logging
F. Calibration
G. Maintenance
To Be
Submitted
Submitted At Later Date1
A-2
Not
Applicable
--
To B~
Submitted Not
Submitted At .Later Date 1 Applicable
7 8. Data Reporting (Section VII)
A. Format
B. ~xample Calculations c. Units
9. Inspection Procedures
(Section VIII)
A. -Waste Feed System
B .. Destruction System
C. Waste Feed Cut-Off System
D. Pollution Control System
E. Alarms
F. Fire Extinguisher Systems
10. Spill Prevention Control
(Section IX)
11. Safety Plan (Section X)
-I 12. Training Plan (Section XI)
13. Trial Burn Plans (Section XII)
14. Test Data or Engineering Per-
formance Calculations (Sec-
tion XIII)
,:; 15. Other Permits or Approvals
(Section XIV)
A. Regional R&D
B. Regional Full-Scale
C. RCRA
D. State or Local
E. DOT
16. Schedule (Section XV)
•
17. QA Plan (Section XVI)
A. Format
B. Organization and
Responsibility
C. QA Objectives
1. Precision
2. Accuracy .
3. Completeness
4. Representativeness
5. Comparability
A-3
"'
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7
·. j
_.,
D. Monitoring Procedures
E. Calibration Procedures and
Frequency ,
F. Data Reduction, Validation
and Reporting
G. Internal Quality Control
Checks
H. Audits
· 1. Performance
2. System
I. Preventive Maintenance
J. Specific Routine Procedures
Used to Assess Data Pre-
cision, Accuracy and
Completeness
K. Corrective Action
L. Quality Assurance Reports
to Management
18. Standard Operating Procedures
(Section XVII)
19. Closure Plan (Section XVIII)
A. Site-to-Site
To Be
Submitted
Submitted At •~ater Date 1
Not
Applicable
--1 B. Permanent
!I .. ;;/
1 Section of the permit should be reserved for revised submittal and the
deficiency should be noted in the application.
A-4
..
APPENDIX A.2
MONITORING PARAMETER SUPPLEMENT FOR INCiNERATORS
7 CLl ....... 0, z ~ "' ' u ~ > C 0 -...., CLl C +' ::, 0, V, ,.... "0 CT .,... ' 0 CLl CLl U) C u ~ ~ CLl 0 0 0 LL 0 .,... +,J +' +,J C CLl 0 .,.. 0, • 0, u 0 u ~ C C C U) ::, .,.. C ~ 0 .,.. .,... ::, "0 +' "' ~ ~ ~ +,J CLl "' C C 0 0 "0 "' 0:: ~ CLl CLl CLl +,J +,J 0 ~ ..0 +,J +,J al .,.. .,.. .c "' "' .,.. C +,J C C +,J Q. +,J ,.... .,.. .,.. 0 0 0 CLl Q. "' "' "' ~ I-~ ~ ~ ~ 0 u ~ 3
a. PCBs in Waste Feed
b. Feed Composition
c. Waste Feed Rate
. l d . 02
e. co
f. CO2
g. NOX ~
h. Combustion Efficiency
i . Residence Time
J j. Destruction Temperature -
k. Other
1. Other
m. Other
A-5
-
7
-~
·i
APPENDIX A.3
CHECKLIST FOR INCINERATOR DEMONSTRATION TEST PLAN
1.
2.
3.
Test Plan Cover
Summary (Section I)
Project Organization (Section II)
A. Key Personnel Identified
B.. Organization Chart
4. Process Engineering Information
(Section III; new information
from Permit Applications)
5. Process Operation Test
To Be
Submitted
Submitted At Later Date 1
.a Parameters (Section IV)
A. Operational Plan
B.-Process Operating Parameters
C. Anticipated Emission Levels
D. Waste Feed Description/
Quantity
6. Sampling and Monitoring Plan
Design (Section V) ·
A. Number of Tests
B. Parameters to be Monitored2
C. Parameters to be .Sampled2
D. Sampling/Monitoring Locations
E. Number/Frequency of Samples
F. Sampling Methods
G. Monitoring Methods
H. Analysis Method
7. Sampling/Analysis Procedures2
(Section VI)
A. Methods
B. Written Protocol
C. Equipment
D. Calibration
----
A-6
Not
Applicable
--
.. To Be
Submitted
Submitted -At·Later Date 1
Not
Applicable
7 8. Monitoring Procedures2
. i
_J
7 -•
(Section VII),
A. Written Protocol
B. Equipment
C. Calibration
9. Data Reporting (Section VIII)
A. Data tQ be Reported, Units
B. Example Calculations
10 . Miscellaneous Tests (Section IX)
A. Waste Feed Cut-Off
B. Alarm Systems
C. Fire System
11. Test Schedule (Section X)
12. Addenda to QA Plan (Sectio~ XI)
13·. Addenda to Standard Operating
Procedures (Section XII)
1 Section of the permit should be reserved for revised submittal and the
deficiency should be noted in the application.
2 See supplemental checklist.
A-7
7
.)
J
APPENDIX A.4
SAMPLING AND MONITORING PARAMETERS DEMONSTRATION TEST P1AN SUPPLEMENT FOR INCINERATORS
a. PCBs in Waste Feed
b. Feed Composition
c. Waste Feed Rate
d. 02
e. CO
f. CO2
g. NOX
h .. Combustion Efficiency
i. Residence Time
j. Destruction Temperature
k. Excess 02
1. HCl Removal Efficiency
m. Stack Gas Flow Rate
n. PCB Feed Rate
o. PCB Output Rate
p. DR_E
q. Particulate
r. RCl (volatile)
s .. RCl (semivolatile)
t. PCDDs/PCDFs
u. Semivolatile Organic
Screen
v. Pollution Control System
Operation .
w. Ash Composition
x. Wastewater
y Other
-z -....... z > ~ ....... -u > C -,:, (1,1
(1,1 ::, ,:, "-CT
(1,1 0 (1,1 ,_. ~ "-Q. .... IJ.. e C .,, 0 ' 0,
V, :::E: C ....
(1,1 (1,1 ,_.
CD CD Q. e 0 0 .,, .... .... V,
. u 0 ...J
0,
.· C .,...
"-0 .~ .,...
C
0 :::E: ....... 0,
C .... ,_.
Q. e .,,
V,
,:,
0 .c ~ (1,1 :::E:
-·
,_.
0 u 0 ~ 0 "-CL
C (1,1 ~ ~ ....
"-3
-.
------
-·
A-8
~ C
(1,1 ,:, e 0
Q. .c .... ~ C 0, ::, (1,1 0 C CT :::E: .... (1,1 . ... w C ~ 0, ~ ....... ,_. 0 u .,, "-u, .,, .... ::, "-0 ::, u ~ ,:, 0 Q. ~ .... .,, (1,1 ~ (1,1 .,, ~ "-0:: V, 0:: "-.~ .Q .,, ,_. .... .,, .,, .,,
Q. .,, ,_. ~ ~ ~ Q. C .,, .,, .,, .,, < < u Q Q Q
-·
..
--
·7
·· 1
. J
· APPENDIX B
• ll
MONITORING, SAMPLING, AND ANALYSIS PROCEDURES
J
B-1
-
' -l
I .J
1.0 MONITORING METHODS
Monitoring of gaseous .components is specifiaally required by §761.70
·for thermal destruction systems . Carbon dioxide (CO2 ) must be monitored
periodically at i nterva 1 s. of no 1 anger than 15 min. Oxygen and carbon mon-
oxide must be monitored continuously. 11 Continuously11 is not defined by the
regulation; OTS recommends an instrumental :system which completes a minimum
of one cycle of sampling and analyzing at least once every 15 sec and records
d_ata at 1 east once every minute.
Information related to continuous emission monitoring systems, in
general, ·can be found in "Continuous Air.Pol l ution Source Monitori~g Systems"
(USEPA 1979).
2.0 SAMPLING PLANS
Sampling plans are often slighted in the rush to get a test under-
way. Poor planning of the sampling can ruin an otherwise acceptable test and
is often the weakest portion of an application. The applicant and permit re-
viewer must work together to develop a detailed sampling plan which will pro-
duce the desired information. In some cases, a 11 typical 11 sample may be de-
sired, while in others a "worst case" sample may be desired. The objective
must be clearly spelled out.
PCB destruction facilities are, unfortunately, not ideal sampling
sites. Events do not always occur according to plan, especially during the
shake-down periods in which the destruction t est is generally held. The sam-
pling plan must reflect the realities of the destruction unit and make every
attempt to meet the stated objectives. In cases where a sampling plan is
compromised, the demonstration t~st report should present an explanation.
Several examples of approaches (~ot full sampling plans) to sampling
situations are presented below.
1. Stack testing generally is conducted over the duration of a test
burn (e.g., 4 h). In the EPA Method 5 protocol, the probe is traversed across
the stack in a prescribed, nonrandom manner to get a sample representative of
all of the stack gases. ·
2. The waste feed must be sampled from a pipe throughout a test
burn. Ideally, a pump would be used ·to continuously draw off a portion of
the feed to obtain an integrated sample. If use of a pump is impractic:al be-
cause of the valve design or feed stock viscosity, manual integration may be
an alternative. At measured time intervals (e.g., every 15 min) the Vctlve is
opened and a measured amount added to the sample. Thus, over the burn, a
sample is collected, which is an integration of the feed at 15-min intE!rvals.
3. An ash bin would ideally' be sampled in a random fashion, where
every part of the bin has a finite, known probability of being sampled. How-
ever, access ports are not randomly placed. A plan may specify that the sam-·
pling be randomized within the access area available (perhaps similar to the
feed samp 1 i ng).
B-2
y
--
7
. i
4. A field of waste drums is to be sampled. The drums could be
randomly sampled. If the drums are known to be from several sources and are
identifiable, the sampling design should include stratification of the sub-
sets. ·
5. The plan ~tipulates that if a bung on a drum is frozen, the
sampler is to move to the nearest drum to-·the north. If more than. half of
the bungs are frozen or if the bungs on an apparent set of drums (in one area
·or with similar markings) are all frozen, the representativeness of the sam-
pling may be compromised (these may all contain a corrosive liquid which has
frozen the drums shut) and additional efforts at opening the drums should be
employed. These would include freeing the t rozen bungs or cutting a new hole
in the drum .
3.0, EXAMPLES OF SAMPLE COLLECTION TECHNIQUES
Additional guidance on sample collection techniques is available in
"Samplers and Sampling Procedures for Hazardous Waste Streams" (USEPA 1980) and
in 11 Sampling and Analysis Methods for Hazardous Waste Combustion" (USEPA 1983).
3.1 Liquids
• 1 Liquids may be co 11 ected by grab or integrative tec:hni ques. Grab
sampling may include filling a jar from a spigot or dipper collection of water
from a lagoon. Frequency of sampling and amount to be collected during each
test must be stated in the sampling plan and recorded when the samples are
collected. Integrative sampling requires a pump on an interval timer, a slow
flow from a valve, manually timed interval sampling, or other device. Addi-
tional guidance is available (Berg 1982).
J ·3.2 Solids
Solid sampling techniques varr with the nature of the solid. Free-
flowing powders may behave like a liquid, while other solids may require spe-
'cial equipment to remove a portion. The equipment to be used (trowel, auger,
grain thief, etc.) and procedures for its use must be adequately described.
3.3 Mixed Phase Samples
Mixed phase samples represent a challenge to the sample collector.
In tanks and other static systems, a phase separation during sampling i s
preferable, provided that the total volume or weight of each phase is mea-
sured. Phases collected separately must be analyzed separately. Proportions
of each phase in the system (e.g., a holding tank) shall be measured volumet-
rically. Examples including skimming solids off liquids and drawing off oil
and water layers from a tank. Where phase separation is impractical, such as
a suspended solid, the whole must be mixed to assure that the sample is repre-
sentative. In a flowing pipe, collecting a representative sample of a solid/
oil/water mixture may be impossible, since the valve position is fixed. In
this situation the oil phase would probably contain more PCBs than the wate~
and would represent a maximum (worst case for waste, best case for feed).
The representativeness or lack thereof should be noted.
B-3
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7
3.'4. Particulate Matter in Stack Gas Emissions
EPA Method 5 (40 CFR 60) is used to colle,c;t a particulate matter
sample.
~-5 Organic Stack Gas Emissions
The modified Method 5 (MM5) train is generally used for s·anipling
organic erni ss i ans from PCB destruction systems. The configuration prE!Sented
by ASME (1984) or Stanley et al. (1982) should be followed unless an alternate
configuration is approved by the EPA. The ASME method is still in draft form,
but is available from OTS. The stack gas is withdrawn isokinetically using a
sample train. PCBs, PCDDs, PCDFs, and similar compounds are trapped on an
adsorbent tube. The sampling time and amount of gas to be sampled must be
stated. Other sampling methods .may be used if demonstrated to be satisfactory
for the objectives of the test and approved by the EPA. Note that separate
sampling trains .are recommended for collecti ng the particulate and the organic
emissions. The r~ason for recommending separate sampling trains is that PCBs
and other semivolatile organics may be lost during drying and desiccation of
the probe wash/filter catch~ as required in Method 5.
3.6 HCT Stack Gas Emissions
.1 Modified Method 5 is usually used to quantify HCl emissions; caustic
!I ...
solution is used in one or more of the impingers to collect the clorides.
3.7 NOx Stack Gas Emissions
. .
. Nitrogen oxides (NO ), in stack gases are determined according to
EPA Method 7 (40 CFR 60). Alfernate methods; such as instrumental analyzers
may be used if approved by the EPA.
3. 8 RCl
Total chlorinat~d organi~s (Rtl) must be sampled during the initial
destruction test. No specific method was mandated by the Agency in the rules.
As a result, many sampling techniques have been used to measure RCl. Strictly
speaking, RCl must measure volatile, semivolatile, and nonvolatile c.ompo-Unds
s i nee the co 11 ect i'on and ana lys.i s techniques for these three categories may
differ. It appears that the volatile halocarbons (e.g., methyl chloride) con-
stitute most of the RCl. These compounds can be sampled using the vol~tile
organic sampling train (VOST) (Bergman 1984; Hansen 1984). Semivolatile RCl
can be determined from the sample collected in the MM5 train. Analysis is by
GC/MS, GC/ECD, or GC/HECD (see Appendix C, Section 4.4.2).
4.0 SAMPLE ANALYSIS METHODS
4.1 Methods for PCBS
OTS does not specify ana lyt i ca 1 methods for PCBs; however, this .
section presents certain guidelines on methods which OTS has reason \a believ~
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wi 11 provide acceptable data. Methods for feed materials, stack gas, ash,
and scrubber water are presented. Methods other than those presented here may
be proposed by permit applicants, provided that the p'roposed methods meet the
OTS data quality objectives (e.g., analysis for all PCBs in samples with de-
tection limits adequate to meet permit requirements)., Analytical methods for
PCBs have been reviewed recently (Erickso".} 1985; Erickson and Stanley 1982;
Erickson et al. 1982, 1985a, 1985b). Applicants ·should review these guide-
1 i nes and propose complete, specific methods in their te·st pl an. Many methods,
including some of those discussed in this section, present one or more options
to the analyst. The applicant must state which option is to be used. If ,se-
lection of options is dependent on samples, or on other factors which cannot
be predicted, the selection criteria must be presented in the test plan.
PCBs are a complex set of 209 individual chemical compounds. The ·
commercial mixtures for commonly found in the feed material generally contain
from 20 to 80 of these 209 PCB congeners.· In most cases for effluent samples,
however, it can be anticipated that the PCB pattern will be qualitatively
different from that in the feed, unless the PCBs were transmitted through the
system without any chemical alteration by the destruction process. For efflu-
ent samples, the analytical method must identify and quantitate all of the
PCBs present in each sample, not just the Aroclor present in the feed.
4.1.1 Feed Materials
As long as the feed material contains PCBs which qualitatively re-
semble one of the· commercial mixtur~s, such as the Aroclors, the traditional
analytical methods which use Aroclor mixtures for GC calibration are acceptable.
These methods are discussed below.
If the PCB composition in the feed material does not resemble a com-
mercial mixture, the samples should be analyzed using the methods recommended
for the effluent samples, as discussed below.
4.1.1.1 Oils
The EPA procedure for analysis of PCBs in transformer oils and
waste oils (USEPA 1981, Bellar and Lichtenberg 1981) provides a generalized ap-
proath with respect to sample preparation and instrumental analysis. Several
cleanup techniques are provided as optional approaches in this procedure. For
the instrumental analysis, GC with halogen specific, electron capture, or mass
spectromelry detectors are all allowed, provided appropriate limits of detec-
tion can be achieved. A strong quality control program including control
samples, daily quality control check samples, blanks, standard additions,
accuracy and precision records, and instrumental and chromatographic perfor-
mance criteria is required to support a 11 data generated by the method.
The ASTM (1983) procedure for mineral insulating oils utilizes
solvent dilution and a Florisil slurry cleanup prior to PGC/ECD determination.
The procedure assumes that the composition of the PCBs present in transformer
or capacitor oils closely resembles that of the Aroclor standards. It notes
that the sensitivity of the ECO is reduced by mineral ,oil and instructs the
analyst to make the amount of oil in_ the standard and sample equivalent to
minimize the effects of the oil interference on the quantitative results.
13-5
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4.1.1.2 Soils, Sludges, and Solid Wastes
A variety of standard methods are available for these matrices.
·, Several ERA methods utilize di ch l oromethane extract ion, fo 1-
1 owed by cleanup and GC determination with different detectors. Soil and
other solid wastes may be analyzed by EPM s SW-846 methods (US EPA 1984a).
Method 8080 is the packed column GC/ECD method; 8250 is the packed column
GC/EIMS method; and 8270 is the capillary column GC/EIMS method. All three
methods have a Jtated limit of detection of 1 µg/g. Some options are pre-
. sented in these methods and the quant i tat ion procedure is not well-de if i ned
for PCBs; therefore, applicants must supply additional details on the planned
·analysis. --~
1 . ~ . The sludge method EPA 625-S (Haile and Lopez-Avila 1984) gives
. !J
optional Florisil, silica gel, and GPC cleanups and stipulates electron im-
pact mass spectrometry as the GC detector.· Quantitation is by total areas
compared to total areas of Aroclor standards.
ASTM Method 03304-74 (ASTM 1981b) ut i l i zes a hexane/welter/
acetonitrile extraction for soil samples. Several optional cleanups are
presented. Samples are analyzed by packed column GC/ECD and quantitateid using
the total areas of Aroclor standards. · ·
4.1.1.3 Capacitors and Other Solids
No standard methods exist specifically ·for these matrices.
The sample should be physically prepared by shredding or grinding and then .
extracted with an appropriate solvent (e.g., benzene or hexane), preferably
with a Soxhlet apparatus over multiple cycles. Cleanup and analysis cc1n then
follow one of the methods given above.
4.1.2 Stack Gas Samples
Stack gas samples collected by modified Method 5 trains (see Section
3.5) are extracted, cleaned up, and analyzed by gas chromatography . The fil-
ter and the sorbent cartridge (e.g., XAD-2) are generally extracted together
with a nohpolar solvent such as hexane, benzene, toluene, or petroleum ether.
The extraction is generally done in a Soxhlet extractor to give prolonged and
repeated contact with clean solvent. The ASME (1984) toluene extraction and
the EPA (Erickson 1984a) hexane extraction are acceptable examples.
GC/EIMS is recommended for the instrumental determination. An EPA
perchlorination GC/ECD method (Haile and Baladi 1977, Beard and Schaum 1978)
is inappropriate for these complex samples, since perchlorination of non-PCB
mol.ecules (e.g., biphenyl) can lead to artifacts in the analysis. An EPA
GC/EIMS method (Erickson 1984a) provides guidance on the GC/EIMS analysis and
also provides a detailed quantitation method.
The EPA procedures f6r PCB spills and incinerators (Be~rd an1i Schaum
1978) are part of a manual for PCB disposal, primarily focusing on inc·ineration
methods. Although this interim report is badly flawed and incomplete, it has
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been widely used as the guidance ~ocument by the EPA Regional Administrators
for testing-incinerators. These methods have never been updated and are cur-
rently superseded by other methods. Therefore, 0TS does not recommend their
· use by permit applicants.
•' The stack gas is sampled using the modified EPA Method 5 technique
developed by Haile and Baladi (1977). PCBs are extracted from the sorbent
materi-a l in a Soxh let extractor using both pentane and methanol . The GC/MS
analysis is taken from a tentative procedure for PCBs in water (Dudenbostel
1978). Samples may be chromatographed on columns packed with 3% Dexsil 300,
OV-1, or OV-101 and may be detected using either electron impact or chemical
ionization mass spectrometry.
Part of EPA's manual for PCB disposal,.the "Tentative Method for
Testing of Polychlorinated Biphenyls (PCBs) in Spilled Material" (Attachment A,
Beard and Schaum 1978), directs the analyst to air-dry the sample (matrix is
, not further specified), grind it, and then extract a 100-g subsample in a
Soxhlet extractor with hexane-acetone (1:1). The procedure then patches into
an unreferenced industrial effluent method, which first specifies a PGC/ECD
screen. If necessary, various cleanup techniques are specified. An aceto-
nitrile partition is used to remove fats and oils. A Florisil column cleanup
fractionates out some pesticides by eluting with 6%, 15%, and 50% ethyl ether/
petroleum ether. Two alternate silica gel microcolumn cleanups are.presented,
one of which provides for sulfur removal with mercury. As noted for the stack
gas samples, above, this old method has never been updated and is not recom-
mended by OTS for use by permit applicants.
4.1. 3 Ash
Ash and other solid effluent samples can be analyzed-by EPA's SW-846
methods (USEPA 1984a) only if the Aroclor pattern remains intact after the
incineration process. Method 8080 is the packed column GC/ECD method; 8250
is the packed column GC/EIMS method; and 8270 is the capillary column GC/EIMS
method. All . three methods have a stated limit of detection of 1 µg/g. Some
options are presented in these methods and the quantitation is not well-
defined for PCBs; therefore, applicants must supply additional details on the
planned anaJysis.
ASTM Method D3304-74 (ASTM 1981b) utilizes a hexane/water/acetonitrile
extraction for soil samples and may be adapted for use with ash samples. Sev-.
eral optional cleanups ·are presented. Samples are analyzed by packed column
GC/ECD and quantitated using the total areas of Aroclor standards. Applicants
must supply details on the planned analysis.
If the Aroclor pattern is significantly altered by the destruction
process, or if other PCBs (e.g., partially dechlorinated homologs) are observed
in the samples, then the above methods are not appropriate for the analysis.
An EPA method for by-product PCBs in commercial products and product wastes
(Erickson 1984c) may be used with GC/MS as the instrumental method. This
method presents several options, so permit applicants must stipulate which
options are to be used.
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If the app 1 i cant chooses to use GC/ECO as the i nstrumenta 1 mi~thod,
a mixture 6f 10 PCB congeners (one each for the various degrees of chlorina-
tion) may be used for the ca 1 i brat ion. This mixture, was determined by the
Dry Color Manufacturers As.sociation (OCMA) to give an average ECO response
for each homolog (DCMA 1982). No specific published method is available for ·
analysis of ash samples using the DCMA quantitation mixture. Sample prepara-
tion (extraction, cleanup, etc.) can be done according to EPA's SW-846 (USEPA
1984a) or the EPA by-product method (Erickson 1984c). Instrumental analysis
can ·be done according to EPA Method 608 (USEPA 1984b). To quantitate the
samples, the following protocol (Midwest Research Institute 1985) may be used:
a. Determine the retention windows. Note: This is an arbi-
trary demarcation and results i.n misidentification of some congeners as either
a higher or lower homolog . However, since the ECO cannot discriminate by
homologs, this is the best approach to partitioning the peaks .
( 1) Record the retention ti me for each congener in the
standard on a data sheet.
(2) For the mono-, the window extends from the retention
time of the standard, which is the first eluting PCB, to the midpoint between
the mono-and di-standards . Start the winqow sufficiently ahead of the stan-
dard elution time (e.g., 0.1 min) to allow for -retention time drift.
(3) The windows for di -through nona-are the midpoints ·
between the retention times of the standards.
(4) For the deca-, which has only one isomer, the window
is the retention time of the standard, allowing appropriate time (e.g.,
± 0.1 min) for retention time drift.
J b. Calculate a linear regression curve for each homoloo . The
minimum correlation coefficient (e.g., 0.99) should be specified in the QA
Plan. If this required correlation is not obtained, either rerun the standard
curve or perfor~ corrective acti~n as given in the QA Plan.
c. Quantitate the samples. Obtain the concentration in micro-
grams per milliliter of each peak in the sample (as injected on the gas chro~
matograph) from the regression equations calculated above. For most sa~ples,
only peaks equal to or greater than 1 µg/g need be reported. Those peaks much J less than this value do not need to be calculated. Where it appears that the
peaks will be below the cutoff, calculate the area counts necessary fo r 2 µg/g
and then visually compare these with the sample data. This shortcut can speed
up the data reduction process by eliminating unnecessary calculations.
d. Multiply the concentration obtained by the dilution factor
and divide by the original sample weight (or volume) to obtain the concentra-
tion in µg/g (or µg/ml) of the original sample.· Record this value on the data
sheet for each peak gr-eater than or equal to 2 µg/g .
e. Automated quantitation routines incorporating the above
principles may be substituted.
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4.1.4 Aqueous Samples .
Scrubber water and other aqueous samples c.an be analyzed by EPA
._ Method 608 (USEPA 1984b) or 625 (USEPA 1984d) or ASTM method D3534-80 (ASTM
1981a) only if the Arocl~r pattern remains intact after the incineration.
If the Aroclor pattern is significantly altered by the destruction
process, or if other PCBs (e.g., partially dechlorinated homologs) are observed
in the samples, then the above methods are not appropriate for the analysis.
An EPA method for by-product PCBs in water (Erickson 1984b) may be used with
GC/MS as the instrumental method. This method presents several options, so ·
permit applicants must stipulate which options are to be used.
-1 If the applicant chooses to use GC/ECD as the instrumental method,
-,l the DCMA (1982) quant i tat ion discussed above may be used, No specific pub'-
1 i shed method is available for analysis of ash samples using the DCMA quanti-
tation mixture. Sample preparation (extraction, cleanup, etc.) can be done .
according to EPA Method 608 (USEPA 1984b) or 625 (USEPA 1984d) or the EPA
by-product method (Erickson 1984b). Instrumental analysis can be done ac-
cording to EPA Method 608 (USEPA 1984b). To quantitate the samples, the
protocol presented in Section 4.1.3 may be used.
4.2 Methods for PCDDs and PCDFs
Because of their extreme toxicity, PCDDs and PCDFs are of environ-
mental concern even at very low levels. Applicants must be able to detect
PCDDs and PCDFs at levels of~ 10 ng/m3/congener as given in Table 8. There-
fore, analytical methods must not only be extremely sensitive but also generate
highly reliable results. For these reasons, only a few instrumental techiques
have been accepted for use in PCDD and PCDF analysis. Probably the most common
is high resolution gas chromatography/electron _ impact mass spectrometry
J (HRGC/EIMS), ~perated in the selected ion monitoring mode. More advanced
techniques are available and may be used for confirmation. These would
include HRGC/high resolution EIMS.
The method used must be capable of quantitating total PCDDs, total
PCDFs, total TCDD congeners, and total TCDF congeners, in addition to 2,3,7,8-
TCDD and 2,3,7,8-TCDF . While -a certain identification is not required_, any
tentative i dent i fi cat ions must be quant i tated as PCDD or PCDF compounds.
Since a false positive could adversely affect the permit approval process, it
] is advisable to employ the best possible-analytical methods .
.J
The method must employ GC/EIMS with GC/high resolution EIMS confir-
mation. EPA Priority Pollutant Method 613 (USEPA 1984c) describes analysis of
2,3,7,8-tetrachlorodibenzodioxin (2,3,7,8-TCDD) in wastewater. The analysis
of all PCDDs and PCDFs in water and solids (e.g., fly ash and the XAD-2 traps
from a Method 5 train), have been described (Stanley et al. 1982). Surrogate
[e.g., (13C) 2,3,7,8-TCDD and (13C) octachlorodibenzo-£-dioxin] must be added
to the resin cartridge before extraction to measure recoveries.
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4.3 Total Organic Chlorine (RCl)
4.3.1 Volatile RCl
v7, Volatile total-·organic chlorine, collected on a VOST train as de-
scribed above, is analyzed by thermal desorption/GC/EIMS (Bergman 1984; Hansen
1984). -
4.3.2 Semivolatile RCl
Semivolatile total organic chlorine (TOCl or RCl) or total organic
halide (TOX) has been monitored using a very short column (2.5 cm long)
PGC/HECD method (Stanley et a.1. 1982; Haile et al. 1983; Nulton et al. 1984)
or extraction and GC/EIMS method (Beard and Schaum 1978). Both employ a
Soxhlet extraction of the XAD-2 resin from the Modified Method 5 train (EPA
1977; Haile and Baladi 1977). It should be noted that these methods do not
. in fact measure total chlorinated organics, but rather semivolatile, gas
chromatographable, chlorinated organics. The GC/HECD TOX measurement was
applied to background air particulate, stack gas particulate, and ash samples
from a municipal incinerator and a cofired power plant (Haile et al. 1983a,
1983b; Nulton et al. 1984). Values ranged from 0.9 to 46,000 ng/g. In water
samples they ranged from 100 to 1,000 ng/L.
Two techniques for total chlorinated organics in water may be adapt-
able· to RCl in stack gas. Both involve concentration of the organic halides
on a sorbent trap and reduction to HCl at 950°C. In one system, the HCl gas
is detected by electrolytic conductivity (Model 610 Total Organic Halogen Ana-
lyzer, O.I. Corporation, College Station, Texas). In the other system, the
HCl gas is detected by micro-coulometry (Model DX-20 Total Organic Halide Ana-
lyzer, Dohrmann Xertex, Santa Clara, California). Both techniques have the
advantage over previously used methods in that volatile, semivolatile, and
nonvolatile organic chlorides can be detected. The extraction/Ge methods de-
tect only the semivolatile organic chlorides. Neither technique has been
validated for use in stack sampling. The instruments have been designed for
water analysis applications. No instrumental modifications appear to be nec-
·essary for stack gas application.
5.0 REFERENCES
] American Society of Mechani ca 1 Engineers, "Test Protoco 1: Samp 1 i ng for the
Determination of Ch 1 ori nated Organic Compounds · in Stack Emissions 11 (1984).
Unpublished report from Environmental Standards Workshop.
American Society for Testing arid Materials. "Standard Method for Polychlori-
nated Biphenyls (PCBs) in Water, ANSI/ASTM D 3534-80,11 in Annual Book of ASTM
Standards Part 31, Philadelphia, Pennsylvania (1981a), pp. 816-833.
American Society for Testing and Materials. "Standard Method for Analysis of
.Environmental Materials for Polychlorinated Biphenyls, ANSI/ASTM D 3304-77,11
in A~nual Book of ASTM Standards Part 31, Philadelphia, Pennsylvania (1981b),
pp. 877-885.
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7
American Society for Testing and Materi a 1 s, 11 Standard Method for Analysis of
Polychlorinated Biphenyls in Mineral Insulating Oils by Gas Chromatography,11
ANSI/ASTM D 4059-83, in Annual Book of ASTM Standards; Part 40, Philadelphia,
Pennsylvania (1983), pp. 542-550.
Beard, J. H., III, and J. Schaum, 11Sampling Methods and Analytical Procedures
Manual for PCB Disposal: Interim Report,--Revision 0,11 . Office of Solid
Waste, U.S . Environmental Protection Agency, Washington, D.C.
(February 10, 1978). -
Bellar,. T. A., and J. J . Lichtenberg, 11The Determination of Polychlorinated
Biphenyls in Transformer Fluid and Waste Oils,11 prepared for U.S. Environmen-
tal Protection Agency, EPA-600/4-81-045 (1981).
Berg, E. L., 11 Handbook for Sampling and Sample Preservation of Water and Waste-
water,11 -U.S~ Environmental Protection Agency, Report No . EPA-600/4-82-029
(September 1982), 416 pp.
Bergman, F. J. , 11Vo 1 at i 1 e Organic Samp 1 i ng Train (VOST) Deve 1 opment at MRI, 11
presented at the 4th Annual National Symposium on Recent Advances in Pollut-
ant Monitoring of Ambient Air and Stationary Sources, EMSL, USEPA, Raleigh,
North Carolina, May 1984.
-: Dry Color Manufacturers As~ociation, 11 An Analytical Procedure for the Deter-
mination of Polychlorinated Biphenyls in Dry Phthalocyanine Blue, Phthalo-
cyanine Green, and Diarylide ·Yellow Pigments,11 Arlington, Virginia (1982).
Dudenbostel, B. F. "Tentative Method of Test for Polychlorinated Biphenyls
in Water," Attachment Bin 11Sampling Methods and Analytical Procedures Manual
for PCB Disposal: Interim Report, 11 J. H. Beard, III, and J. Schaum, Office
of Solid Waste, U.S. Environinental Protection Agency, Washington, DC
· r (February 10, 1978).
Erickson, M. D., "Analytical Method: The Analysis of By-Product Chlorinated
Biphenyls in Air, Revision 2,11 U.S. Environmental Protection Agency, Office of
Toxic Substances, Washington, D.C., EPA 560/5-85-011 (1~84a).
Erickson, M. D., 11 Analytical Method: The Analysis of By-Product Chlorinated
Biphenyls in Water, Revision 2,11 U.S. Environmental Protection Agency, Office
of Toxic .Substances, Washington, D.C., EPA 560/5-85-012 (1984b).
Erickson, M. D., "Analytical Method:· The Analysis of By-Product Chlorinated
Biphenyls i n Commercial Products and Product Wastes, Revision ,2,11 U.S. Environ-
mental Protection Agency, Office of Toxic Substances, Washington, DC, EPA
560/5-85-010 (1984c). ·
Erickson, M. D., 11 Analytical Chemistry of PCBs,11 Boston: Butterworth Pub-
lishers (1985).
Erickson, M. D., and J. S. Stariley, 11 Methods of Analysis for By-Product PCBs--
Literature Review and Preliminary Recommendations,11 Interim Report No. 1, Of-
fice of Toxic Substances, U.S . Environmental Protection Agency, Washington,
D.C., EPA-560/5-82-005, October 1982, 135 pp .
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Erickson, M. D., J. S. Stanley, K. Turman, G. Radolovich, K. Bauer, J. Onstot,
D. Rose, and M. Wickham, "Analytical Methods for By-Product PCBs--Preliminary
Validation .and Interim Methods," Interim Report No. 4, Office of Toxic Sub-
.· stances, U.S. Environmental Protection Agency, Washington, D.C., EPA-560/
5-82-006 (1982), 243 pp. ·· [NTIS No. PB 83 127696].
Erickson, M .. D., J. S. Stanley, J. K. Turman, and G. Radolovich, "Analytical
Method: The Analysis of Chlorinated Biphenyls in Liquids and Solids,"·
U.S. Envi ronmen.tal Protection Agency, Office of Toxic Substances, Washington,
D.C., EPA-560/5-85-023 (February 1985a).
Erickson, M. D., J. S. Stanley, J. K. Turman, J. E. Going, D. P. Redford, and
D. T. Heggem, "Determination of By-Product PCBs in Commercial Products and -l Wastes by High Resolution GC/EIMS,11 Environ. Sci. Technol. (submitted) (1985b).
·-' Haile, C. L. and E. Baladi,. 11Methods for Determining the Total Polychlorinated
Biphenyl Emissions from Incineration and Capacitor and Transformer Filling
Plants,11 U.S. Environmental Protection Agency, EPA-600/4-77-048, NTIS No. PB-
. 276 745/7Gl (November 1977), 90 pp. ·
Haile, C. L, and V. Lopez-Avila, 11Development of Analytical Test Procedures
for the Measurement ·of Organic Priority Pol lutants--Project Summary," U.S.
E.nvi ronmenta 1 Protect ion Agency, Envi ronmenta 1 Monitoring and Support Labora-
tory, Cincinnati, Ohi.o, EPA-600/S4-84-001; (Full Report available as NTIS No.
PB 84~129 048) (1984).
Haile, C., J. Stanley, R. M. Lucas, D. Melroy, C. Nulton and W. Yauger, Jr.,
11 Comprehensive Assessment of Specific Compounds Present in Combustion
Processes. Vol. 1-Pilot Study of Combustion Emissions Variability,11 Office
of Toxic Substance, U.S. Environmental Protection Agency, Washington, D.C.,
EPA-560/5-83-004 (June 1983a).
Haile, C. L., J. S. Stanley, T. Walker, G. R. Cobb and ~-A. Boomer, "Compre-
hensive Assessment of the Specific Compounds Present in Combustion Processes,
Volume 3, National Survey of Organic Emissions from Coal Fired Utility Boiler
Plants,11 Office of Pesticides and Toxic Substances, U.S. Environmental
Protection Agency, Washington, D.C., EPA-560/5-83-006 (1983b).
Hansen, E. M., 11 Protocol for the Collection and Analysis of Volatile POHCs
·(Principal Organic Hazirdous Constituents) Using VOST (Volatile Organic Sam-
pling Train), U.S. Environmental Protection Agency, EPA-600/8-84-007 (1984).
Midwest Research Institute, 110perat i ng Procedure -Analysis of Samp 1 es for
PCBs by GC/ECD, 11 EPA Contract No. 68-02-3938, MRI Project No. 8501-A6,
December 1985.
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• Nulton, C. P., C. L. Haile and D. P. Redford, "Determination of Total Organic
Halogen in :Environmental Extracts by Gas Chromatography with Ha 11 Detection, 11
Anal. Chem. 56:598-599 (1984).
Stanley, J., C. Haile, A •. Small, and E. Olson, "Sampling and Analysis Proce-
dures for Assessing Organic Emissions from Stationary Combustion Sources for
Exposure Evaluation Division Studies. Methods Manual," 'U.S. Environmental
Protection Agency, EPA-560/5-82-014 (1982).
U.S. Environmental Protection Agency, 1140 CFR Part 60 -Standards of Performance
for New Stationary Sources," Fed. Regist., 42, 41754-41789 (August 18, 1977).
U.S. Environmental Protection Agency, "Continuous Air Pollution Source Moni-
·1 toring Systems," EPA-625/6-79-005 (June 1979). ·
' . I,
U.S. Environmental Protection Agency, "Samplers and Sampling Procedures for
Hazardous Waste Streams," Report No. EPA-600/2-80-018 (January 1980).
U.S. Environmental Protection Agency, "The Analysis of Polychlorinated Biphenyls
in Transformer Fluid and Waste Oils, 11 Office of Research and Development, Envi-·
ronmental Monitoring and Support Laboratory, Cincinnati, Ohio (February 1981).
U.S. Environmental Protection Agency, "Sampling and Analysis Methods for Haz-
-~ ardous Waste Combustion (First Edition)," prepared by A. D. Little, Inc.
(December 1983).
•
U.S. Environmental Protection Agency, "Test Methods for Evaluating Solid Waste-
Physical/Chemical Methods, SW-846, 2nd Edition, Revised," Office of Solid Waste
and Emergency Response, Washington, DC (April 1984a). ·
U.S. Envi ronmenta 1 Protect ion Agency, 11 0rganoch l ori ne Pesticides and PCBs--
Method 608,11 Fed. Regist., 49(209), 89-104 (October 26, 1984b).
U.S. Environmental Protection Agency, 11 2,3,7,8-Tetrachlorodibenzo-£-dioxin -
Method 613,11 Fed. Regist., 49, 136-141 (October 26, 1984c).
U.S. Environmental Pratection Agency, "Base/Neutrals, Acids, and Pesticides--
Method 625,11 Fed. Regist., 49, 153-174 (October 26, 1984d) .
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APPENDIX C
OTS GUIDANCE ON FREQUENTLY ASKED QUESTIONS
June ,1986
C-1
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PREFACE
This Appendix presents answers to frequently asked questions related
~, to permitting of incinerator facil lti es. The answers represent OTS guidance,
as of June 1986 .
. J
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. I
Conditions Which May Be Included in Permits
.· Question 1: Is 11 blend-down11 of PCB fluids authorized?
Answer: Blending and/or spiking is allowed only for the purpose of achiev-
ing a particular treatment concentration during process demonstra-
tions. However, during commercial operation no material which ex-
ceeds the concentration level demonstrated and authorized by the
permit, may be diluted or blended.
Demonstration Test Protocol
Question 2: Are applicants required to test stack gases, ash (including bot-
tom ash), and scrubber water for PCBs, dioxins and furans during
incinerator demonstrations?
Answer: Demonstration tests of incinerators must include sampling of stack
gases and ash, including bottom ash, for PCBs, dioxins and furans.
EPA reserves the right to request similar testing of scrubber water,
if available information and data indicate that such testing is
needed.
Question 3: What are the testing requirements for dioxins and furans during
process 'demonstrations?
Answer: For incineration, OTS requires stack testing for chl~rinated dibenzo-
dioxins and chlorinated dibenzofurans. The analytical detection
· J limits should be no greater than 10 ng/resolvable isomer peak. Test-
ing should be conducted fop individual 2,3,7,8 tetrachloro isomers
for both dibenzodioxins (2,3,7,8-TCDD) and dibenzofurans (2,3,7,8-
TCDF), total . tetrachloro homologs of both dibenzodioxins (TCDD) and
dibenzofurans (TCDF) and total chlorinated dibenzodioxins (PCDD)
and chlorinated dibenzofurans (PCDF).
Question 4: How many successful test runs are required during an incineration
Answer:
trial burn? ·
For -thermal treatment processes, a minimum of three 4-hour test runs
are required. However, more than three test runs may be required
if the operator desires to demonstrate performance under more than
one operating condition. For example, the operator may desire to
demonstrate compliance under two distinct operating conditions a~
follows: (a) multiple waste feed systems (e.g._, solids and liquids);
and (b) liquid waste feed stream only at a higher feed rate than
when solids also are fed.
C-3
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7
Question 5: What are the m1n1mum requirements for decontaminating an incin-•
Answer:
~rator following a PCB burn?
As a minimum, the following decontamination steps should be taken:
(1) if applicable, the waste feed tank should be flushed with a
non-PCB fluid (e.g., diesel fuel) and the flushing liquid inciner-
ated; and (2) the incinerator should burn a volume of non-PCB fluid
equivalent to one-half the total volume of the incinerator combus-
tion chamber(s).
Question 6: What PCB standards are recommended for analytical testing?
Answer:. The PCB standard chosen depends on the PCB composition in the sam--1 ples and the purpose of the data.
-ti
a. If a waste feed sample is being assayed for initial PCB con-
centration, and if it consists of an identifiable Aroclor (or
other commercial mixture) or combination of Aroclors, the in-
strument may be calibrated using the appropriate Aroc l or or
combination of Aroclors. The standard concentrations must be
within ~he working range of the instrument and must bracket
the concentration of the sample dilutions.
b. If the sample does not contain a PCB mixture similar to the
Aroclors or other commercial mixtures, the applicant must
demonstrate that all PCBs are being measured. The stack gas
and other effluent samples from an incinerator are in this
category. For the stack gas samples, the requtred limit of
detection to. demonstrate 99.9999% destruction efficiency de-
pends on the feed concentration.·
The PCB elution window is defined by the retention times on a
gas chromatograph between 2-chlorobiphenyl and decachlorobi-
phenyl. The calibration mixture is generally a solution con-
taining one each of the 10 PCB homologs (i.e., mono-, di-,
tri-, ... decachlorobiphenyl; e.g., the 11 DCMA11 solution avail-
able from chromatography supply companies).
As with the Aroclor calibration, the standard concentrations
must be within the working range of the instrument and must
bracket the concentration of the samples.
Any peaks within the PCB retention window must be calculated
as PCBs unless the analyst can demonstrate through use of ·
blanks, confirmatory techniques, or other methods that the
peak(s) in question is not a PCB.
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Preparations for a Demonstration
Question 7: Is an R&D program, or some other demonstration of the ability to
operate, required prior to scheduling an official test demonstra-
tion?
Answer: For previously unpermitted facilities OTS recommends either a pre-
liminary R&D program with PCBs or use of a PCB substitute for shake-
down of the unit. An R&D permit will not be issued for more than
three total batches. It should be stressed that once the applicant
proceeds with a demonstration·test, if the demonstration schedule
is not adhered to, OTS will reserve the right to rescind the permit
-1 while on-site or leave the demonstration before it is completed .
_J Another demonstration cannot be rescheduled for a minimum period of
three months.
.;
Question 8: Will applicant preparedness be screened prior to demonstration?
Answer: OTS will work with applicants to ensure that the process is ready
prior to the demonstration. This may include evidence of success-
ful operations under similar conditions. For facilities where im-
mediate on-site analyses of product is required as part of the
demonstration, successful analysis of QA samples may be required
before-the demonstration as a method of screening out unprepared
applicants.
Test Demonstrations
Question 9:. What criteria will be used to make an on-site determination to
discontinue a demonstration?
· Answer: For incinerators, a maximum of two interruptions will be allowed
during a stack sampling run. Additional interruptions automatically
invalidate the run 1 s results. Inability to complete an acceptable
run on the first day is cause for departure by EPA representatives.
If the demonstr~tion schedule is not adhered tQ, OTS will reserve
the right to rescind the permit while on-site or leave the demon-
stration befo~e it is completed. Another demonstration cannot be
rescheduled for a minimum period of three months.
C-5
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APPENDIX D
_. I
ADDRESSES FOR HEADQUARTERS AND REGIONAL OFFICES
D-1
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Addresses follow for U.S. EPA Headquarters and Regions. Headquarters will
supply .the ~ames of Regional PCB Coordinators upon request.
Headquarters
Director of the Office of Toxic Substances (TS-792)
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Region 1
(Connecticut, Maine, Massachusetts,.
New Hampshire, Rhode Island, Vermont)
l -• Regional Administrator
Environmental Protection Agency
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Region 2 _
(New Jersey, New York)
Regional Administrator
• .a Environmental Protection Agency,
26 Federal Plaza
New York, N~w York 10278
Re ion 3
Delaware, District of Columbia,
Maryland, Pennsylvania, Virginia,
West Virginia).
Regional Administrator
Environmental Protection Agency
841 Chestnut Street
-Philadelphia,•Pennsylvania 19107
Re ion 4
Alabama, Florida, Georgia, Kentucky,
Mississippi, North Carolina, South
Carolina, Tennessee)
Regional Administrator
Environmental Protection Agency
345 Courtland Street; N.E.
Atlanta, Georgia 30365
D-2
--
Re ion 5 ·
Illinois, ',Indiana, Michigan, Minnesota
Ohto,_Wisconsin)
· 1 l . i
Regional Administrator
Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois 60604
Re ion 6
Arkansas, Louisiana, New Mexico,
Oklahoma, Texas)
Regional Administrator .
Environmental Protection Agency
First International Building
1201 Elm Street
Dallas, Texas 75270
Region 7
(Iowa, Kansas, Missouri, Nebraska)
Regional Administrator
-• Environmental Protection Agency
726 Minnesota Avenue
Kansas City, Kansas 66101
Region 8
(Colorado, Montana, North Dakota,
South Dakota, Utah, Wyoming)
·; Regional Administrator
Environmental Protection Agency
One Denver Place
999 18th Street,, Suite 1300
Denver, Colorado 80202-2413
Region 9
(Arizona, California, Hawaii, Nevada)
Regional Administrator
Environmental Protection Agency
215 Fremont Street
San Francisco, California 94105
Region 10
(Alaska, Idaho, Oregon, Washington)
Regional Administrator
Environmental Protection Agency
1200 6th Avenue
Seattle, Washington 98101
D-3
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"' . .:.1
APPENDIX E
ANNOTATED BIBLIOGRAPHY
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7
' . I
. '
J
D. G. Ackerman, L. L. Scinto, P. S. Bakshi , R. G. Delumyea, R. J. Johnson,
G. Richard, .. and A.· M. Takata, "Guidelines for the Disposal of PCBs and PCB
ttems by Therma 1 Destruction, 11 Report by TRW, Inc. , .. Redondo Beach, CA, to
· Da~id C. Sanchez, USEPA, IERL, Research Triangle Park, NC, EPA-600/2-81-022,
February 1981, 317 pp.
Guidance -Thermal
This report is a resource and guidelines document intended to aid U.S.
Environmental Protection Agency Regional Offices in interpreting and applying
the PCB Disposal Regulations to thermal. destruction of PCBs ..
As background material, this document describes fundamental processes of
combustion, thermal destruction systems, sampling and analysis methodology,
and flame chemistry relative to PCB incineration. Administrative considera-
tions, including poblic involvement, are discussed. Detailed guidelines on
evaluation of Annex I incinerators, high efficiency boilers, and the several
stages of the approval process are presented and discussed. [authors• abstract]
---------------------------------------------------------------·--------------
D. G. Ackerman, L. L. Scin'to, P. S. Bakshi, R. G. Delumyea, R. J. Johnson, G.
Richard, A. M. Takata, and .E. M. Sworzyn, "Destruct ion and Di sposa 1 of PCBs
by Thermal and Non-Thermal Methods," Noyes ·Data Corporation, Park Ridge, NJ,
1983, 417 pp.
~ Guidance -Thermal and Non-Thermal
This is a verbatim combination of two EPA reports:
1. Sworzyn and Ackerman (1982) · [EPA-600/2-82-069], and
.. 2. Ac.kerman et al., (1981) [EPA-600/2-81-022] .
American Society of Mechani ca 1 Engineers, "Test ·Protocol: Sampling for the
Determination of Chlorinated Organic Compounds in Stack Emissions," 1984,
24 pp. Unpublished .report from Environmental Standards Workshop.
Sampling Methods
A ·sampling train using XAD-2 resin as the adsorbent is designed so that
only the total amount of each chlorinated organic compound in the stack gases
sampled may be determined; that is, sampling to determine the partitioning of
the chlorinated organic compounds between the solid and 'gaseous phases is not
attempted. All of the compounds of interest are assumed to be collected by
the resin. Since this assumption has not been validated in the presence of
HCl, high organic 1 oad, and other components present, appropriate qua 1 i ty
control steps are .recommended until the method has been validated. The
sampling method is intended for use with analysis by gas chromatography/mass
spectroscopy.
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American Society of Mechanical Engineers, 11 Analytical Protocol: Analytical
Procedures '-to Assay Stack Effluent Samples and Residu_al Combustion Products
for Polychlorinated Dibenzo-p-dioxins (PCDD) and Polychlorinated Dibenzofurans
· (PCDF),11 1984, 26 pp. Unpublished report from Environmental Standards Workshop.
Analyti~al Methods
The title methoqs, which are also applicable to residual combustion
products such as bottom and precipitator ash, entail addition of isotopically
labeled internal standards to all samples in known quantities, extraction of
the sample with appropriate organic solvents, preliminary fractionation and
cleanup of the extracts using a sequence of liquid chromatography columns,
and analysis of -the extract for PCDD and PCDF using gas chromatography/mass
spectrometry. Performance criteria are specified which the analytical data
must satisfy for quality assurance purposes. The method is designed to indi-
cate the total concentration of each group of isomers, that is, the total of
each group of tetra-, penta-, hexa-, hepta-~ and octachlorinated diebenzo-2-
dioxins and dibenzofurans. However, the method does allow quantitation of
2,3,7,8-tetrachlorodibenzo-2-dioxin (TCDD) and 2,3~7,8-tetrachlorodibenzofuran
(TCDF). The method is intended to be applicable for determining PCDD/PCDF in
combustion products at the parts-per-tri 11 ion to parts-per-mi 11 ion 1 eve 1.
[adapted from the introduction]
Anonymous, 110cean Incineration of Hazardous Waste--Permit Writer's Manual,11
undated, 226 pp.
Guidance
The incineration of hazardous and other wastes by ocean-going vessels on
the high seas (hereafter "ocean incineration') offers an attractive alternative
to land-based disposal, provided that adequate environmental and other safe-
guards are taken. National and 1nternational regulations and guidelines for
ocean incineration have been developed and are recognized by most major indus-
trialized countries. Both international and United States regul~tions require
a permit for ocean i-ncineration. This Manual summarizes existing administra-
tive procedures of the U.S. Environmental Protection .Agency (hereafter "EPA")
for issuance of such permits and provides technical guidance for evaluating
permit aP,plications and for drafting permits. Such guidance relies heavily
on documents developed by EPA for permitting land-based hazardous waste incin-
eration facilities under its RCRA program. [author's introduction]
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J. H. Beard, III, and J. Schaum, "Sampling Methods and Analytical Procedures
Manua r for--PCB Disposal: Interim Report, 11 Draft Report by Office of Solid
_Waste, U.S. Environmental Protection Agency , Washington, DC, February 10, 1978.
7 Guidance/Sampling/Ana lyt.i cal Methods
This manual is a compendium of sampli~g methods and analytical procedures
which may be referred to and used by the PCB disposal facility owner/operators
to assist them with any sampling and analyti cal testing which may be required
under 40 CFR Part 761, Polychlorinated Biphenyls. However, due to the short
time period in which this manual was prepared, the U.S. Envfronmental Protec-
tion Agency is issuing this manual as an interim document. (The U.S. EPA be-
lieves that a sampling methods and analytital procedures manuil has to be
1 avai1able to PCB disposal facility owner/operators at the time the regulation
_J is finally promulgated to successfully impl ement the site approval process
under 40 CFR Part 761, Polychlorinated Biphenyls.) A final version of this
manual is expected to be issued, after undergoing further review within the
U.S. EPA, by early spring of 1978. [authors' preface]
Department of Health, Education, and Welfare, Public Health Service, Center .
for Disease Cc>ntrol, National Institute for Occupational Safety and Health,
r a ''Criteria for a Recommended Standard ... Occupational Exposure to Polychlorinated
. r.. '
Biphenyls (PCBs),11 September 1977, 224 pp. (available from U.S. Government ·
Printing Office, Washington, DC).
Worker Safety and Health
The National Institute for Occupational Safety and Health (NIOSH) recom-
mends that employee exposure to polychlorinated biphenyls (PCBs) in the work-
place be controlled by adherence to the following sections. The standard is
designed to protect the health and provide for the safety of employees for up
to a 10-hour workday, 40-hour workweek, over a normal working lifetime. The
standard is measurable by techniques that are valid, reproducible, and avail-
•ab le to industry and governmental agencies. . Compliance with the standard
should substantially reduce any risk of reproductive or tumorigenic effects
of PCBs and prevent other adverse effects of exposure in the workplace. Em-
ployees should regard the recommended workplace env.ironmental limit as the
upper boundary for exposure and make every effort to keep exposure as .low as
possible .
Evidence indicates adverse reproductive and tumorigenic effects in exper-
imental animals exposed to certain commercial PCB preparations. Currently
available information is not adequate to demonstrate that other commercial
PCB preparations do not have these effects. Should sufficent information be-
come available to indicate that the standard offers greater or lesser protec-
tion from some chlorobiphenyl isomers or commercial preparations than is needed,
it will be considered for revision. [from Recommendations secti-0n of report]
E-4
' R. L Durfee, G. Contos, F. D. Whitmore, J. D. Barden, E. E. Hackman, III,
and R. ·-A. Westin, 11 PCBs in the United States -Industria·l Use and Environmental
Distributions,11 U.S. Environmental Protection Agency,, Office of Toxic Sub-
. stances, Washington, DC, Report No. EPA 560/676-005 [NTIS No. PB-252012], 1976,
~7 · 488 pp.
Review of Disposal and Destruction Methods '
This document present~ the current state of knowledge about the produc-
tion, usage, and distribution of polychlorinated biphenyls (PCBs) in the
United States. The information presented is derived from detailed studies on
the production and first ti er user industries, the past and present genera-
tion and disposition of PCB-containing wastes, environmental transport and
1 cumulative loads, potential alternatives to PCBs usage, inadvertent losses to
• d and potential formation in the environment, and current regulatory authorities
for PCBs control. These results indicated that, although PCBs ·content of .in-
dustrial wastes can be reduced through various approaches (treatment, substi-
tution, etc.), there exists a potentially severe future hazard in the form of
large amounts of PCBs currently contained in land disposal sites. Further
definition of this and other aspects of the PCBs problem, and determination
of ways to minimize the hazard, are-recommended. [author's abstract]
; :a
. . -----------------·------------------------------------------------------------
Environmental Prote~tion Agency, 1140 CFR Part 761, Pqlychlorinated Biphenyls
(PCBs) Manufacturing~ Processing, Distribution in Commerce, and Use Prohibi-
tions,11 Federal Register, 44, 31514-31568, May 31, 1979.
TSCA Rules
This final rule implements prov1s1-0ns of the Toxic Substances Control
j · Act (TSCA) prohibiting the manufacture, processing, distribution in commerce,
and use of polychlorinated biphenyls (PCBs). Specifically, this rule:
(1) Prohibits all manufacturing of PCBs after July 2, 1~79, unless spe-
cifically exempted by the Environmental Protection Agency (EPA); ·
(2) Prohibits the processing, distribution in commerce, and use of PCBs
except in a totally ~nclosed m~nner after July 2, 1979;
(3) Authorizes certain processing, distribution in commerce, and use of
PCBs in a non-totally enclosed manner (which would otherwise be subject to
the prohibition described above); · ·
(4) Prohibits all processing and distribution in commerce of PCBs after
July 1, 1979, unless specifically exempted by EPA. [author's summary]
'
E-5
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Environmental Protection Agency, "Region V Strategy for Permitting PCB Dis-l
posal Sites,11 Process Evaluation Unit, Technical, Permits and Compliance Sec-
tion, Waste Management Branch, Waste Management Division, Region V, U.S. En-
, vironmental Protection Agency, Chicago, IL, undated, 68 pp.
Guidance
This document describes the permitting experiments by repeating the appli-
cable CRF Sections and providing examples of approval and consent letters.
Participant programs (public hearings) procedures and a checklist for evaluat-
ing applications are appended.
----·------------------------------------------------------------------------
. ! Environmental Protection Agency, 11 40 CFR Part 761, Polychlorinated Biphenyls
•
(PCBs) Manufacturing, Processing, Distribution in Commerce and Use Prohibitions;
· Recodification,11 Federal Register, 47, 19526-19527, May 6, 1982.
TSCA Rules
This action recodifies 40 CFR Part 761 which deals with polychlorinated
biphenyls (PCBs). The recodification proviges for a more orderly organization
of the material . No substantive changes are involved. [author's summary]
Environmental Protection Agency, 1140 CFR Part 761--Polychlorinated Biphenyls
(PCBs).,.-Procedural Amendment of the Approva l Authority for PCB Disposal Facili-
ties and Guidance for Obtaining Approval," Federal Register, 48, 13181-13186
(1983).
TSCA Rules
This procedural rule change gives the Assistant Administrator for Pesti-
cides and Toxic Substances (Assistant Administrator) authority to approve cer-
tain PCB disposal facilities which have previously been subject to approval
by each Regional Administrator. The Assistant Administrator will be the ap-
proval authority for facilities which are operated in more than one region.
The Regional Administrators will continue to have the authority to approve
all unique, site-specific facilities such as landfills, stationary incinera-
tors, and research and development into PCB disposal methods. This amendment
does not change any standards for approving Pea disposal activities and should
provide better responsiveness to the needs of the public and industry. In
addition, EPA is providing supplemental guidance to assist persons applying
for approval of PCB disposal technologies that are alternatives to incinera-
tors and high efficiency boilers. [author's .summary]
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: :I
M. D. Erickson, Analytical Chemistry of PCBs, Butterworth Publishers,·
Stoneham, Massachusetts, 1985, 528 pp.
Sampling and Analytical Methods
I The book defines and discusses sampling, extraction, cleanup, determina-
tion by chromatographic and nonchromatographic methods, data reduction, and
quality ·assurance as six discrete steps in the analysis of PCBs. The final
chapter provides a discussion on collaborative testingJ The comprehensi~e
bibliography includes more than 1200 references. Five appendices detail PCB
nomenclature, physical properties, compositions of commercial mixtures, mass
spectra characteristics, and PGC/ECD chromatograms. The book includes exten-
sive critical reviews of the primary literature .
-------------------------------------------------------~---------------------
M. D. Erickson and J. S. Stanley, "Methods of Analysis for By-Product PCBs--
Literature 'Review and Preliminary Recommendations, 11 Report by Midwest Research
Institute, Kansas City, MO, to David P. Redford, U.S. Environmental Protection
Agency, Office of Toxic Substances, Field Studies Branch, Washington, DC,
EPA-560/5-82-005, 1982, 135 pp. .
.Sampling and Analytical Methods
A review of the literature on polychlorinated biphenyl (PCB) analysis and
recommendations for methods to determine by-product PCBs in commercial prod-
ucts and other matrices are presented. This report was prepared to assist EPA
in formulating a rule regulating by-product PCBs. The published literature on
PCB analysis is criti~ally reviewed. Several hundred references are cited in
a bibliography. The review is subdivided into extraction, cleanup, determina-
tion, data reduction, confirmation, screening, quality assurance, and by-
! prod~ct analysis sections. The determination section includes TLC, HPLC, GC
(PGC and CGC), GC detectors (ECO, FID, HECD, EIMS, and other MS), and non-
chromatographic analytical methods (NMR, IR, electrochemistry, NAA, and RIA).
Techniques applicable to analysis of commercial products, air, and water for
by-product PCBs are discussed. The final section of .this report presents a
. recommended overall primary analytical scheme. [authors• abstract]
M. D. Erickson, J. S_. Stanley, G. Radolovich, · K. Turman, K. Bauer, J. Onstot,
D. Rose, and M. Wickham, "Analytical Methods for By-Product PCBs--Initial Vali-
dation and Interim Protocols," Report by Midwest Rese 9rch Institute, Kansas City,
MO, to David P. Redford, U.S. Environmental Protection Agency, Office of Toxic
Substances, Field Studies Branch, Washington, DC, EPA-560/5-82-006, 1982, 243 pp.
Sampling and Analytical Methods
This document presents proposed analytical methods for analysis of by-
product PCBs in commercial products, product waste streams, wastewaters, and
air. The anaiytical method for commercial products and product waste streams
consists of a flexible approach for extraction and cleanup of particular ma-
trices_. The 13C-labeled PCB surrogates are .added as part of a strong quality
E-7
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assurance program to determine levels of recovery. The wastewater method is
based on EPA Methods 608 and 625 with revisions to include use of the 13C-
labeled PCB surrogates. The air method is a revisio~of a proposed EPA method
· for the collection and analysis of PCBs in.air and flue gas emissions. Capil-
lary or packed column gas chromatography/electron impact ionization mass spec-
trometry is proposed as the primary instrumental method. Response factors
and retention times of 77 PCB congeners relative to tetrachlorobiphenyl-d6 are presented in addition to statistical analysis to project validity of the
data ~nd extrapolation of relative response factors to all 209 possible con-
geners. Preliminary studies using the 13C:-labeled surrogates to validate
specific cleanup procedures and to analyze several commercial products and
product wastes indicate that the proposed analytical methods are both feasible
and practical. [authors• abstract]
L. Fradkin and S. Barisas, 11 Technologies for Treatment, Reuse, and Disposal
of Polychlorinated Biphenyl Wastes,11 Report by Argonne National Laboratory for
U.S. Department of Energy, ANL/EES-TM-168, 1982, 47 pp. (NTIS No. DE82013715).
Review of Disposal and Destruction Methods
Several technologies being developed by private industry· and government
~• to meet U.S. Environmental Protection Agency regulations for PCBs were assessed
. to assist in the selection of the best process for a particular application.
Methods evaluated include a sodium naphthalide system, a sodium-amine method,
the NaPEG® process, plasma-arc technology, ultraviolet-ozone treatment,
catalyzed wet oxidation, hydrothermal dechlorination, light-activated reduc-
tion, and EPAC filters as well as the approved methods of land disposal and
incineration.
-} ------------------------------------------------------------------------------
C. L. Haile and E. Baladi, 11Methods for Determining the Polychlorinated Bi-
phenyl Emissions from Incineration and Capacitor and Transformer Filling
Plants,11 Report: by Midwest Research Institute, Kansas City, MO, to Environ-
mental Monitoring and Support Laboratory, Office of_ Research and Development,
U.S. Environmental Protection Agency, Research Triangle Park, NC, EPA-600/4-
77-048, 1977, 90 pp. (NTIS No. PB-276 745/7Gl).
Sampling and Analytical Methods
Described are methods to measure the polychlorinated biphenyl (PCB) emis-
sions from the stacks 1 of municipal waste, industrial waste, and sewage sludge
incinerators and from capacitor and transformer filling plants. The PCB emis-
sions from the incineration plants are collected by impingement in water and
adsorption on Florisil. The samples are extracted with hexane, concentrated
through evaporation of the solvent, perchlorinated, and the polychlorinated
biphenyl content measured as the decachlorinated isomer using a gas chromato-
graph equipped with a flame ionization detector. The PCB emissions ·from the
capacitor and transformer filling plants are coliected directly on Florisil,
extracted with hexane, and quantified against the appropriate Aroclor using a
gas chromatograph. ·
E-8
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I The methods were developed from laboratory studies and field tested at
l
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nine incineration plants and two transformer filling plants.
[authors' abstract]
-----------------------------------------------------------------------------. .
J . C. Harris, 0. J. Larsen, C. E. Rechsteiner, and. K. E.. Thrun, "Sampling and
Analysis Methods for Hazardous Waste Incineration (First Edition),11 Report by
Arthur 0. Little, Inc., Cambridge, MA, to Larry 0. Johnson, Technical Support
Staff, U.S. Environmental Protection Agency, !ERL, Research Triangle Park, NC,
EPA Contract NO. 68-02-3111, Technical Directive No. 124, February 1982, 400 pp.
Guidance -RCRA
. As part of the Resource Conservation and Recovery Act, the U.S . Environ-
.mental Protection Agency has proposed regulations for the owners/operators of
facilities which treat hazardous wastes by incineration to ensure that these
intinerators are operated in an environmentally responsible manner. In sup-
port of these regulations, this document has been prepared as a reference
document which describes the sampling and analysis methodologies appropriate
to the measurement of the principal organic hazardous constituents in both
influent and effluent streams at these facilities. The sampling and analysis
methods for -these principal organic hazardous constituents (POHCs) are de-
scribed in the text. Also included are concise summary sheets for all of the
recommended methods, stating the method name and number, the types of samples ·
and specific analytes to which ~he method applies, a brief description of the
method, instrument and operating conditions, and a reference to a more de-
tailed description of the procedure. Technician-level protocols are thus in-
corporated by reference rather than reproduced in this document. In addition
to -specific methods for the sampling and analysis activities at these facili-
·ties, information concerning general strategies and guidelines for reporting
and documentation are discussed:
Appendix A provides basic-information (structure, CAS Registry Number,
molecular weight, melting point, boiling point, and heat of combustion, when
available) for all compounds listed in Appendix VIII of the May 20, 1981,
Federal Register. Additional appendices list specific Appendix VIII compounds
with the appropriate sampling and analysis methods. Mass spectral analytical
· ions for compounds -analyzed by GC/MS are tabulated in Appendix E. [authors'
abstract] [revision of Rechsteiner et al.] ,
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T. J. Hennings, P. A. Painter, L. L. Scinto, and A. M. Takata, 11 Preliminary
Operations ··Plan and Guidelines for the At-sea ·incineration of Liquid PCB
Wastes,." Report by TRW, Inc., Redondo Beach, Californ~a, for the U.S. Environ-
mental Protection Agency, Office of Research and Development, Industrial
Environmental Research Laboratory, Research Triangle Park, EPA-600/2-82-068,
1982, 121 pp. (NTIS No. PB83-181834).
Guidance
The report is a preliminary operations plan and guidelines report for
the disposal of PCB wastes by at-sea incineration. An inventory of government~
owned PCB wastes suitable for at-sea incineration and operating plans and a
schedule for an EPA-coordinated disposal project were developed. Of the ap-
proximately 1.3 million gal. of government-owned ·1iquid PCB wastes identified,
425,000 gal. were considered to be immediately a~ailable for at-sea incinera-
tion. The operations plan addresses both land-based and at-sea operations.
Land-based oper~tions include waste collection and preparation, transportatibn
to a processing facility, processing of wastes and containers, interim storage
of bulk liquids, transportation to a ship loading site on the Gulf of Mexico,
and ship loading. Incineration site selection, permit requirements, incinera-
tion procedures, and cargo tank detontamination are addressed for at-sea
operations. The preliminary schedule for the disposal project shows 10 months
from the decision to proceed with the project to completion of disposal opera-
. tions. [adapted from authors' project summary]
------.------·-------------. --------------------------------------------------
R. G. Mclnnes, 11 Technical Assistance in Support of Permitting Activities for
the Thernial Destruction of PCBs," USEPA, Office of Research and Development,
!ERL, Research Triangle Park,. NC, EPA 6.00/2-81-240, 1982, 70 pp. (NTIS No.
PB82 231 325). '
Guidance -Thermal
This report descri t;>es phas_ed efforts to identify, eva 1 uate, and provide
technical _ permitting assistance to utility boiler owners considering thermally
destroying PCB-contaminated mineral oil. I dent i fi cat ion initially concentrated
on identifying ideal PCB destruction sites using size, age, location, and fuel
use criteria to evaluate available boilers. This effort then extended to di-
rectly contacting USEPA Regional Offices to identify utility boiler owners who
had expressed an interest in the PCB disposal program. Regular bimonthly
-contacts were initiated with the Regional Of fices and the status of all re-
gional PCB activities was tracked. This con t act produced three potential PCB
burn sites operated by: (1) Consolidated Edison of New York, (2) Northeast
Utili·ties, and (3) Pennsylvania Power and Light. · Test plans were received ·
from the first two and .were reviewed and found acceptable; these facilities,
however, subsequently withdrew their involvement with the PCB destruction
verification burn program due to local community opposition. The Pennsylvania
Power and Light Company site remains under active consideration. By the end
of the technical performance period of this work assignment, a candidate site
had not been identified or approved for testing. Appendices to this report
detail the utility boi 1 er site select ion methodology, the status of PCB
E-10
•
7
activities in EPA Regional Offices as of May 1, 1981, and the test plan
evaluation~ for the Consolidated Edison and Northeast Utilities facilities.
The project also required that state and local governments be provided
information needed to airl permitting of a PCB. verification burn. Under this
-phase of the project a PCB 11white paper11 was prepared which summarized back-
ground technical information used in writing the PCB regulation (40 CFR 761).
A second paper was prepared summarizing comments delivered at a public meeting
entitled 11What Should We Be Doing About PCBs?11 Both of these papers are pro-
vided as appendices to the report. [author's project summary]
---------------.-------------------------------------------------------------
-l R. G. Mclnnes and R. J. Johnson, 11 Provision of Technical Assistance to Support
_i Regional Office Implementation of the PCB Regulations--East and West,11 Draft
Project Summary Report by GCA Corporation, New Bedford, MA, and TRW, Inc. ,
Redondo Beach, CA, on EPA Contract No. 68-02-3168, Work Assignment No. 45,
and Contract No. 68-02-3174, Work Assignment No. 68, for David C. Sanchez,
USEPA, Office of Research and Development, IERL, Research Triangle Park, NC,
1982, 186 pp.
•· I
Guidance -Thermal
To assist EPA headquarters, laboratory and regional office personnel with
the implementation of the PCB regulations, GCA/Technology Division and TRW,
Inc., Environmental Division, were retained. _GCA was assigned to provide tech-
nical assistance to the Eastern EPA Regions (I-V), and TRW performed the iden-
tical function in the West (Regions VI-X). These contracts had a twofold direc-
tion: to establish a regular bimonthly liaison with the EPA regional offices
and to provide technical and coordinative assistance to these offices on an
as-needed basis. The bimonthly contact resulted in a regular bimonthly news-
letter which was mailed to-the EPA personnel in all 10 -regions who are directly
involved with the implementation of the PCB regulations. The technical assis-
tance effort produced -a series of individual facility evaluations as well as
a separate study regarding alternative definitions of PCB solid/ liquid wastes.
This project report documents the work efforts .conducted by GCA/Technology
Division and TRW Environmental Division in providing,technical assistance to
support regional office implementation of the PCB regulations. The salient
points of the two project tasks are discussed in the body of the report and a
copy of the latest bimonthly report and all facility evaluations is included
in the appendices. This report covers the period of April 28 to December 15,
1981, and work was completed as of December 31, 1981. [from authors' introduc-
tion]
E-11
-
Navy, 11 PCB Compliance, Assessment, and Spill Control Guide,11 Naval Energy and
Environmental Support Activity, Fort Hueneme, CA, Report No . NEESA-20.2-028A
-[NTIS No. -AD-A121 329/7] August 1982, 105 pp . '
7 Guidance
Polychlorinated biphenyls (PCB) are toxic belonging to the well-known
chlorinated hydrocarbon family. Because of their low flammability and high
stability, PCBs have been extensively used as coolants and insulators in elec-
trical equipment. However, due to the known environmental and health problems
occurring from improper use and handling, the Environmental Protection Agency
has promulgated stringent regulatory controls concerning use, storage, trans-
port and disposal of PCBs leading to a total ban on use of PCBs . This guide
-1 was designed to assist Navy activities in complying with these complex and
_J intricate_ regulations. [author's abstract]
C. Rechsteiner, J. C. Harris, K. E. Thrun, D. J. Sorlin, and V. Grady,
11 Sampling and Analysis Methods for Hazardous Waste Incineration,11 Draft
Report by Arthur D. Little, Inc., Cambridge, MA, to Larry D. Johnson, Process
Measurements Branch, U.S. Environmental Protection Agency, !ERL, Research
Triangle Park, NC, EPA Contract No. 68-02-3111, Technical Directive No. 124,
:~ July 1981, 324 pp.
Guidance-:-RCRA
As part of the Resource Conservation and Recovery Act; the U.S. Environ-
mental Protection Agency has proposed regulations for the owners/operators of
'facilities which treat hazardous wastes by incineration to ensure that these
incinerators are operated in an environmentally responsible manner. In sup-
J port of these regulations, this document has been prepared as a reference
document which describes the sampling and analysis methodologies appropriate
to the measurem~nt of the priority organic hazardous constituents in influent
and effluent streams at these facilities. In addition to specific m~thods for
the sampling and analysis activities at these facilities, strategic informa~
tion concerning such activities and guidelines for reporting and documentation
are discussed. [authors' summary] [Revised to Harris et al.]
J. Stanley, C. Haile, A. Small, and E. Olso n, 11 Sampling and Analysis Procedures
for Assessing Organic Emissions from Stationary Combustion Sources for EEO
Studies. Methods Manual,11 Report by Midwest Research Insitute, Kansas City,
MO, to Exposure Evaluation Division, Office of Pesticides and Toxic Substances,
Washington, DC, EPA-560/5-82-014, 1981, 34 pp .
Sampling and Analytical Methods
The sampling and analysis methods described in this report were specific-
ally designed for use in an ongoing nationwide survey of emissions of organic
pollutants from stationary combust,on sources. The primary focus of this
E-12
I •
l
t' ·. survey is on polynuclear aromatic hydrocarbons (PAHs) and polychlorinated
aromatic hygrocarbons including polychlorinated biphenyls (PCBs), polychlori-
nated dibenzo-£-dioxins (PCDDs), and polychlorinated:dibenzofurans (PCDFs).
To date, these procedures have been used by Midwest Research Institute (MRI)
to survey emissions fro~ coal-fired utility boilers, a co-fired (coal +
refuse-derived fuel) uti1ity boiler, and a municipal refuse incinerator ..
This document was prepared by MRI as a guideline for laboratories who may
participate in this study, and for other researchers who wish to use these
methods. [authors' abstract]
------------------------------------------------------------------------------. . .
-' G. Vogel, K. Brooks, I. Frankel, S. Haus, and W. Jacobsen, "Guidance Manual
,·. for Evaluating Permit Applications for the Operation of Incinerator Units,"
Report by The Mitre Corporation, Mclean, VA, to U.S. Environmental Protection '. I
J
.Agency, Contract No. 68-01-6092, December 31, 1980, 221 pp. . .
Guidance -RCRA
An EPA or state permit writer is offered guidance for evaluating permit
applications submitted by owners or operators of incinerator facilities as
required under mandate of the Resource Conservation and Recovery Act of 1976.
The subject areas requiring evaluation are identified and information that
should be contained in an application to ensure a thorough evaluation is
list~d. Data typical of current, acceptable incineration practices and ex-
amples of computations are offered to assist the permit writer.
,[~uthors' abstract]
. . -----------------------------------------------------------------------------
J. V. Zbozinek, T. J. Chang, J. R. Marsh, P. K. McCormick, and J. E. Mccourt,
"PCB Disposal Manual ,11 Report by SCS Engineers, Inc., Long ·eeach, California,
for the Electric Power Research Institute, Palo Alto, California, CS-4098,
1985.
Review of Disposal and Destruction Methods
The objective of this report is to present an update of the information
presented in FP-1207, Volume 1, published in 1979. There have been signifi-
cant changes both to the regulations and the technology in the intervening
period. This report emphasizes tho.se areas which were subject to the greatest
change; as well as new areas that were not considered when 'the previous volume
was published. Among the various areas of PCB di.sposal which ar:e addressed
in this report are PCB materials and /their distribution in the utility indus-
try, regulations, thermal destruction technology, land disposal, treatment
technologies, disposal capacity and demand, and a PCB management program. It
is intended that this manual provide sufficient-detail to be useful in utility ·
decision processes, even with the realization that regulations are once again
in a state of change, as are the available processes and disposal capacities.
[authors' abstract]
E-13
JJf289?3
QUALITY ASSURANCE AND QUALITY CONTROL PROCEDG~ES FOR
DEMONSTRATING PCB DESTRUCTION IN FILING
F'OR A PCB DISPOSAL PERMIT
I~JTROOUCTION
The applicant shall provide information on the overall
company organization and the organization of the actual group
carrying out the processing or PCB _d~struction _. Include a table
or chart showing the project organization and the line of
authority. This table or chart should list all the key
individuals, including those who are responsible •for ensuring the
collection of valid measurement data and routine assessment of
measurement syst ems for precision and accuracy.
A general description of the project shall also be
included. This should contain; the experimental design, flow
diagrams if ava i lable, tables, charts, and dates anticipated for
start and completion.
A demonstration of destruction of PCBs by a chemical process
will require specific quality assurance and quality control
(QA/OC) measures.
As a minimum these measures are a Quality Assurance· Plan
signed by process officials and containing:
(l) documents demonstrating the capability and capacity
t~ ~,1troy PCBs in the materials to be processed by the
potential pemitee to levels at or above the requested
permit level;
(2} chemical reactions and process conditions (for
example; temperature changes, viscosity changes,
s t·irring) changing the kinds of products, amounts of
products, or rates of reaction resulting fran the
destruction of PCBs in the medium for which the permic
~5"
is c-equested;
(3) procedures_ for selecting the poc-tions of · the
process-ed material specimens to be chemically analyzed
to demons-trate PCB destruction and chain of custody of
the specimens;
(4) treatment of the material to be chemically
analyzed;
(5) the chemical analysis procedures used including
references, specimens and instrument settings;
(6) calculations employed to transform instrument
readings into raw data and raw data into reported data1
(7) method of verifying reported results;
(8) certification that there are no PCBs below EPA
required levels in any waste materials.
Detailed Descriptions
(l) Preliminary laboratory testing on -the material to b•
treated (e.g. mineral oil dielectric fluid) should be done
before applying for a permit. The potential permittee must
provide--aecessary documentation to demonstrate that, !or t~e
mediwa to be treated the process has the capability and
capacity to destroy PCBs. Part of the demonstration would
be:
(a) how any specimens analyzed in such a demonstra':~on
were sampled fran the larger amount to be treated . ~~
example might be: a 100 milliliter specimen >1a s
withdrawn by a volumetr-ic pipette fran each of -:~r ••
different randomly selected fifty-five gallon drums.
The .three specimens were emptied, in turn, into a brown
glasi one liter bottle with a teflon lined c~p;
(b) ~rea-tment of the material, collected in (a) above,
prior to chemical analysis;
(c) analytical procedures·· for quantifying PCBs in the
material collected in (a) and located in (6);
(d) results of the chemical analyses before and after
the destruction process.
(2) Relevant chemical reactions to be reported are all
reactions of PCBs with the ingredients in the process. Anv
confidential business information (CBI) must be submitted
through established procedures. A version eliminating CBI is
more easily and expeditiously handled in permit review. rn
addition to chemical reactants and products, the applicant
must detail all changes in operating conditions which effect
the destruction of PCBs, such as temperature or impurities
which canpete for the process active ingredients. Products
of reaction of the process active ingredient with the medium
to be processed and impurities in that ~ediurn shall be
stated.
(3) For the actual full scale or large capacity destruction
demnst,t.r.ation, there must be a written description of how the
mediWI to be processed is sampled to obtain specimens for
analysis. To demonstrate destruction, a representative
sample ts necessary. One· way of obtaining a representative
sample, when only limited sampling sites are available, 1s ~Y
randanly (over time) collecting subsamples and then
compositing the subsamples to a single composited sample.
~he sampling must take place fran the material as it 1s
returned to the customer for storage or use. Mid-process
specimens, while helpful, do not demonstrate destruction.
(4) Details of the handling, physical and chemical treatment
of a specimen to be chemically analyzed for PCBs must
include, but are not limited to, reagents added, source of
collection vessels, preparation of collection vessels, any
extractions or separations of a treated specimen.
Examination of all separated parts for PCBs is necessary.
For example, if a separating funnel is used and there are two
layers, if one layer is assumed to contain PCBs and the other
layer is discarded, then the discarded layer must be examined
and proven free of PCBs. If a process is •quenched• with
sulfuric acid, detailed descriptions are required to
demonstrate that the sulfuric acid used is in the same
proportion in quenching the specimen to be analyzed as in
quenching the large volu~e of the medium processed. This
description is necessary because of the degradation of less
highly chlorinated PCB congeners by sulfuric acid.
(5) Details of the chemical analysis must include the method
used and reference of that method to any published method
which has been demonstrated to detect chlorinated biphenyl
congeners with a known precision and accura~y. EPA will
provide methodology guidance for chemical analysis of PCB
destruction. in a separate document.
It is ~•sible to use screening techniques employing
very sensitive but not specific chemical analyses to
determine quantities of potential chlorinated bi phenyl
congeners. EPA will identify and confirm PCBs by the
techniques described in •Analytical Methods for By-Product
PCBs -Preliminary Validation and Interim Methods•. Quallt,
assurance and quality control for analytical methodology
includes but is not restricted to:
(a) a table of instrumental settings and other
parameters required to c-eproducibly measure PCBs. E'or a
gas chrQmatographic technique some requirementg include
type oe column material, column packing/coating, column
length, gas composition, gas flow rate, inject ion
volume, attenuation, type of detector, column
temperature, detector temperature, and brand and mone l
number of ins~rument(s);
(b) _precision and accuracy determination procedures and
results, including frequency of calibration, replicated
analyses, standard reinforced specimens, PCB standards,
and blanks. Standards must cover the range from
rnonochloro biphenyl through decachloro biphenyl and it
is suggested that at least one congener fran each
hanolog be used in a standard •cocktail•. The level of
this cocktail should be s·uch that. PCBs can be quantified
at the Level of Quantitation as defined by the (Closed -
and Controlled Rule 4 7 FR 46980). Any meaisurable
indication of a canpound in the r4nge betw•!en and
including monochlorobiphenyl and decachlor<:>biphenyl is
considered PCBs unless confirmed by mass spectral
analysis.
(c) traceability of standards;
(d) participation in audit programs when available;
(e) conficnation of split specimens with an independent
lAboratory1
(f) copies of instrument charts or tracings, such as
chromatograms with all information necessary for
interp~etation and reference a9 in part S(a).
(6) All focmulas, calculations, and equations used in
converting instrument readings or printouts to refined data
or results must be documented. Include procedures used to
confirm-correct calculations and transcription.
(7) Any other checks employed to verify results but not
given in l-6 above.
(8) A statement, signed by the ~~sponsible official seeking
the permit, that:
All •clean• materials have been documented and
demonstrated to have no PCBs above EPA required levels,
additionally all waste materials have either been
documented and demonstrated to have no PCBs, or the
plans for disposal of these wastes are attached. Wastes
include, but are not limited to, quenching water,
T
unprocessed material leaked or spilled during connect ion
to or release fran the process, any polymers formed, anq
the residue resulting fran the destruction of PCBs.
~ ~ ,,,.
:..;; -:
~,,., ..
FR (48) /62/ Wednes~ay, March 30, 1983
40 CFR Part 761
[OPTS-62028; TSH-FRL 2242-2)
Polychlorinated Blphenyta (PCBa);
Procedural Amendment of the
Approval Authority for PCB Dlspoeal
FactDtJes-and Guidance for Obtalnbtg Approval
AGENCY: Envirorunental Prote,.tion
Agency (EPA).
ACTION: Procedural Rule Amendment
and Statement of Policy.
SUMMAR~ Thia procedural rule change
gives the Assistant Admipistrator for
Pesticides and Toxic Substances
(Assistant Administrator) authority to.
approve certain PCB disposal facilities
which previously have required
approval from each Regional
Administrator. The Assistant
Administrator will be the approval
authority for facilities which will be
13181
FR (48) /62/ Wednesday, March 30,-1983 13182
operated in more than one region. The
Regional Administrators will continue to
have the authority to approve all unique,
site-specific facilities such as landfills
and stationary incinerators. The
Regional Administrators also will
continue to have the authority to
approve all research and development .
(R and DJ on PCB disposal methods
involving less tlian 500 pounds of
material, regardless of whether the
disposal facility will be operated.in
more than one region. This amendment
should provide better responsiveness to
the needs of the public and industry. It
does not change any standards for
approving PCB disposal activities. In ·
addition. EPA is p~viding supplemental
guidance to assist persons applying for
approval of PCB disposal technologies
that are alternatives to incinerators and
high efficienc·y boilers.
EFFECTIVE DATE: These amendments·
shall be effective on April 29, 1983.
FOR FURTHER INFORMATION CONTACT:
Jack P. McCarthy, Director, Industry
Assistance Office (TS-799), Office of
Toxic Substances, Environmental.
Protection Agency, Rm. E-509, 401 M SL,
SW., Washington, D.C~ 20460, Toll free:
(800-424-9065), In Washington, D.C.: ·
(554-1404}. Outside the USA:
(Operator-202-554-1404}.
SUPPLEMENTARY INFORMATION:
L Recodification of 40 CFR Part 761
Title 40 of the Code of Federal
Regulations, Part 761, which regulates
polychlorinated biphenyls (PCBs), has
been reorganized and recodified. Notice
.--:f the reorganization and recodification-
c:1ppears in the Federal Register of May n. ::.982 (47 FR 19527). This rule
amendment uses the following new
designations: ·
Old deeignation New designa1lon
Subl>vt B, § 781 .10-----l ~ 0, § 761.80. Sub!><wt o. § 161.31 ....... ,., _____ Subpart e. § 761..30.
Subpart E. §781.40 Subpart o. §781.70. Sub!)art E. § 76f.41 ____ &11,part 0, § 781.7.5.
Subpart E. §761.42 · Subpart o. §761.65.
II. Background
Section 6(e)(l)(A} of the Toxic
Substances Control Act (TSCA) requires
that EPA promulgate rules for the
disposal of polychlorinated biphenyls
(PCBs ). The rules implementing section
6(e)(1)(A) were published in the Federal
Register of May 31, 1979 (44 FR 31514}
and recodified in the Federal Register of
May 6, 1982 (47 FR 19527). (See Unit 1 of
this preamble.) Those rules. among other
thing8, generally require that various
types of PCBs and PCB Articles be
disposed of in landfills or destroyed in
incinerators, or in high efficiency boilers
approved by EPA Regional
Administrators in accordance with
standards set forth in the rules. (See 40
CFR 761.60, 761.70, 761.75). The rules
also provide that persons may obtain·
approval from the Regional .
Administrators for alternative methods
of destroying PCBs if the alternative
methods can achieve a level of
performance equivalent to EPA
approved incinerators or high efficiency
boilers. (See 40 CFR 761.00(e)).
Regional Administrators were given ·.
sole authority to apprpve PCB disposal
facilities. At that time site-specific
technologies, such as incinerators,
boilers. or landfills, were the only .
available meansnf-dillposing of PCBsor
destroying them. During the past.year, in
particular, EPA has been receiving
applications for mobile and other types
of destruction technologies that require
approval in more than one region.
To improve management of permit
procedures for PCB disposal.activities,
the.Administrator has decided to ·
transfer the review and approval
authority of mobile &nd other PCB
disposal techniques that are used in
more than one region to the Office of
Pesticides and Toxic Substances in
Washington D.C. This transfer of
approval authority should provide better
responsiveness to the needs of the -
public and industry. The purpose of this
amendment is to reduce the resource
burden on EPA and affected-parties by·
eliminating duplication of effort in the
regional offices and to unify the
Agency's approach to PCB disposal.
This procedural rule amendment does
not change the· Agency standards for
approval of PCB disposal methods. It
merely substitutes the Assistant
Administrator for Pesticides and Toxic
Substances for the Regional ·
Administrators as an approval authority
for certain facilities. Since this
proced~al amendment makes no , ·
substantive change to the existing PCB
rule, no comment period is required or
necessary for this rulemaking. The
notice and comment procedures under 5
U.S.C. 553 are not appHcable to
procedural rules. Therefore, this _
amendment becomes effective on April
29, 1983.. .
The preamble to this rule also
presents general notice of supplemental
guidance for judging whether an
alternative PCB destruction method
should be approved under 40 CFR
76i.60(e). This guidance has been
generally used by regional
administrators in the past and_is
presented to assist applicants in
submitting useful information.
III. Approval Authorities for PCB
Disposal Activities
The following paragraphs specify the
approval authority for various disposal
activities. However, at the discretion of
the Assistant Administrator, an
application for approval may be
assigned to another office if the
application appears more suited for
review in an office other than the one
suggested below.
-A. Landfills
Landfills for PCB materials will
continue to be approved by the Regio~al
Administrators. •' B. Stationary and Mobile Incinerators
The operation of stationary
incinerators will be approved by the
Regional Administrators. Mobile
incinerators and stationary incinerators
of identical design that are intended to
be used in more than one region will be
approved by the Assistant
. Administrator, except for research and
development involving less that 500 ·
pounds of PCB material (see Part D of
this unit). The Assistant Administrator
. may issue an approval that will be
effective in all ten EPA regions.
C. Alternate Methods
The existing PCB regulations provide
for the approval of methods which are
alterntives to incineration. Alternate
methods that are stationary and unique
(site-specific design) will be approved
by theappropnate Regional
Administrator. Altemate'methods that
are mobil e or will be used in more than
one region will-be approved by the
Assistant Administrator, except for
research and development involving less
than 500 pounds of PCB ro11.t,?:ial {see
Part D of this unit). The A1111istant •.
Administrator may issue an approval
which is effective in all ten EPA regions.
D. Research and Development
The EPA Regional Administrators will
be the approval authority for R and If
into PCB disposal methods, regardles~ ·of
the type of method, that: use 500 pounds
total or less of PCB-contaminated
material. Disposal of more than 500 .·
pounds of total PCB or PCB-
contaminated material for Rand D
purposes will be reviewed and approved
by either the Assitant Administrator or
an appropriate Regional Administrator
based .on the principles set out in A; B, ·
C, and E of this unit ufthe preamble.
EPA notes that Rand Don PCB disposal
is regulated using the disposal sections
FR (48) /62/ Wednesday. March 30. 1983 13183
of the PCB rule. See unit V of this ·
preamble, "Research and Development"
. for a more complete explanation.
E. Others
Req_uests for approval of disposal
facilities that are not covered under A.
B, C. or·D above should be sent to the
Assistant Administrator. If an applicant
is unsure about where to submit a
request. it should be sent to the
Assistant Administrator. The Assistant
Administrator will assign the .review •
and approval authority for these
disposal facilities to the Office of
Pesticides and Toxic Substances or the
appropriate Regional Administrator.
IV. Supplemental Guidance , ,
Section 40 CFR 761.70 of the PCB rule
provides criteria and procedures for the
approval of incinerators. 40 CFR ·
761.60{a)(2)(ili) provides criteria for the
approval of high efficiency boilers. ·
Thermal destruction technologies which
do not comply exactly with the
provisions of 40 CFR 761.70 may be
approved under the waiver provision of
that section (40 CFR 76L70(d)(5)). In
addition. destruction technologies may
also be approved under the alternative
technologies section of the ·PCB _
regulation (40 CFR 761.00(e)).
Sec_tion 40 CFR 761.00{e) does not .
provide specific guidance concerning the
types of information that EPA requires
to review alternative disposal methods.
Therefore, .EPA is taking this
opportunity to provide this guidance.
The following guidance is applicable
to most alternate PCB disposal
activities, including R and D. but may be
modified as appropriate to the specific
activity at the discretion of th-e Regional
Administrators or the Assistant
Administrator. Although not noted here,
site-specific considerations may also be
involved in any PCB disposal facility
approval.
· 1. The owner or operator of any
alternate method should submit an
application which contains the fallowing
(if applicable):
(i) Name, address and phone nll.Dlber
of the unit's principal manager.
(ii) The location of the facility where
the unit will b'e tested and the location
where the unit will be stored and
serviced when not engaged in testing.
(iii) A detailed description of the unit
including general plans and design
drawings.
' (iv) An engineering report or other
information on the anticipated
performance of the unit.
(v) A sampling plan and quality
assurance plan, including sampling and
monitoring equipment and available
facilities. 1
(vi) Waste volumes expected to be
handled. process design capacity,
process control, reagent-to-waste feed
. ratios. and safety features.
(vii) Any local, State or Federal
permits or approvals;
(viii) Schedules and plans for
complying with the approval
requirements.
(ix) A contingency plan which
describes steps taken in case of process
failure, spill or overflow.
(x) Environmental impact. including ..
process emissions, toxicity and disposal
of process products, site relationships,
and steps taken to protect the health of
operators.
2. Following receipt of the application.
EPA may determine that a proce,s
·demonstration is required and will
notify the person who submitted the
report. The Assistant Administrator or
Regional Administrator may require the
submission of any other information that
the EPA finds to be reasonably
necessary to determine the need for a
process demonstration. Such other·
information shall be restricted to the
types of information requited in the
initial application. All pages containing
proprietary information should be
labeled "CONFIDENTIAL" Documents
marked accordingly must be treated by
the EPA as Confidential Business
Information, unless a determination to
deny the claim of confidentiality has
been made by the General Counsel. In
addition, a non-<:onfidential version of
the submission is required so that a
copy of the application is available, if
needed, for public review.
The following information should be
submitted by persons who are asked to
demonstrate their process for the
Agency. EPA may request any
additional testing nr snalysis _which will
help the reviewini:; officials determine
the safety and efh.:.-i,mcy of the process.
(i) The time, date, and location of the
process demonstration.
(ii) The quantity and type of PCBs and
PCB Items to be processed.
(iii) The parameters to be monitored ·
and lo~ation of sampling points.
(iv) A sampling plan and quality
assurance plan, including sampling
frequency and methods and schedules
for sample analysis.
(v) The name, address and
qualifications of persons who will
review the analytical results and other
pertinent data, and who will perform a
technical evaluation of the effectiveness
of the process demonstration.
3. At least thirty (30) days prior to
conducting the process demonstration,
the owner or operator of the process
should give written notice of the
demonstration to the state and local
goxerrunents within whose jurisdiction
the demonstratiorris to take place.
4. Following receipt of the process .
demonstration plan. the Assistant
Administrator or Regional
· Administrator will approve the plan,
require additions or modifications to the
plan, or disapprove the plan~ If the plan
is disapproved, the EPA will notify the
person who submitted the plan of such
disapproval, together with the reasons·
why it is disapproved. That person may,
thereafter, submit a new plan in
accordance with paragraph t. above. If
the new plan is approved (with any
additions or modifications which EPA
may prescrib-e), the EPA will notify the
person who submitted the plan of the
approval. Thereafter, the process
demonstration, if decessacy, shall take
place at a date, time, and location to be
agreed upon between the EPA and the
person(!') who submitted the plan. The
demonsttation must satisfy all_
applicable requirements of 40 CFR Part
761, and supply any other pertinent data
that aids EPA in reviewing these
processes.
5. The Assistant Administrator or
Regional Administrator will grant or
deny approval for full scale operation
based on a comprehensive review of the
application package, demonstration
results, and other submitted information.
Approvals for operation will contain
special conditions, if EPA finds them
necessary to provide sufficient
protection to human health or the
environment. '·
6. Requests for approval must be sent
to the Assistant Administrator for
Pestici..:.-::111nd Toxic Substances or the
apprornat!:! Regional Administrator. The
proper -,i};:ial can be determined under
40 CFR iol.60(e), and 761.70 (a} and (b)
or under A. B, C. D, and E in unit II of
this preamble. Addresses for these
officials are listed astollows:
Document Control.Officer (TS-793),
Office of Toxic Substances,
Environmental Protection Agency,
Room E-401, 401 M Street, SW.,
Washington, D.C. 20460
Region1
(Connecticut, Maine, Massachusetts,
New Hampshire, Rhode Island.
Vermont)
Regional Administrator, Region 1,
Environmental Protection Agency,
John-F. Kennedy Federal Building,
Boston, Massachusetts 02203
Region 2
(New Jersey, New York)
Regional Administrator, Region z.
Environmental Protection Agency, 26
FR (48) /62/ Wednesdat.'_.~March 30, 1983 13184
Federal Plaza, New.York, New York
10278
Regions
(Delaware, District of Columbia,
Maryland Pennsylvania, Virginia, West
•Virginia)
Regional Administrator, Region 3,
Environmental Protection Agency;6th
and Walnut Streets, Philadelphia,
Pennsylvania 19106
Region 4
(Alabama, Florida, Georgia, Kentucky,
Mississippi, North Carolina, South
Caroli1:1a, Tennessee)
Regional Administrator, Region 4,
-_-Envirolmlental Protection Agency, 345
Courtland Street, NE., Atlanta, ·
Georgia 30365
Region 5
(IJlinois, lhdiana, Michigan, Minne.,;ota, ·
Ohio, Wisconsin)
Regional Administrator, Region 5,
Environmental Protection Agency, 230
South Dearborn Street; Chicago,
Illinois 60604
Region 6
(Arkansas, Louisiana, New Mexico,
Oklahoma, Texas)
Regional Administrator, Region 6,
Environmental Protection Agency,
First International Building, 1201 Elm
StreetL Dall~s, Texas 75270
Region 7
(Iowa, "Kapsas, Missouri, Nebraska)
Regional Administrator, Region 7, ·
Environmental Protection Agency, 324
East 11th Street, Kansas City,
Missouri 64106
Region 8
(Colorado, Montcinii, North Dakota,
South Dakota, Utah, Wyoming)
Regional Administrator, Region 8,
Environmental Protection Agency,
1860 Lincoln Street, Denver, Colorado
80295
Region 9
(Arizona, California, Hawaii, Nevada)
Regional Administrator, Region 9,
Environmental Protection Agency, 215
Fremont Street, San Francisco,
California 94105
Region 10
(Alaska, Idaho, Oregon, Washington)
Regional Administrator, Region 10,
Environm~ntal Protection Agency,
1200 6th Avenue, Seattle, Washington
98101 .
_ V. Research and Development
Research is_ an investigation to
discover or revise facts or theories. The
present PCB rule authorizes the use of
PCBs for R and D activities if the PCBs
are packaged in 5.0 ml containers and
used for scientific experimentation or
analysis (40 CFR 761.30U)), Therefore, R
and D on disposal methods using PCBs
in any other-form constitutes disposal ·
. and is regulated using the disposal ·
section of the PCB rule (40 CFR 761.60),
In s.ome cases, companies have •
conducted R and D on PCB disposal
without the appropriate EPA region's
awareness of their activities. Failure to
obtain prior approval from EPA is a
violation of the. PCB disposal
regulations. Persons already engaged in
PCB disposal research that is not
permitted pursuant to 40 CFR 761.30U)
and not approved by the appropriate
EPA Regional Administrator must cease _
that research and obtain approval from
the Regional Administrator before
recommencing their research.
EPA recognizes that R and D for new-
methods of PCB disposal is desirable. To
obtain approval to use PCB materials in
quantities sufficient to develop new ·
disposal methods (i.e. over 5.0 ml PCBs ),
researchers must apply to EPA and
receive a letter of authorization before
beginning their research. To the extent
possible, all applications ehould contain
the types of information required in unit.
Ill of this preamble and 40 CFR 761.70 of
the PCB rule for approval of PCB -
disposal facilities.
VI. TSCA and RCRA Permits
PCB dispri.;~,, facility permits are
granted unl~-~r the authority of the Toxic
Substances ,..,0ntrol Act (TSCA). The
majority of the hazardous waste
disposal permits are granted under the
R~source Conservation and Recovery
Act (RCRA). Although ma:ny facilities
are cap,able of destroying wastes
controlled under each of these statutes,
the regulations presently require two
individual permits. EPA anticipates
· integrating, these regulations and is
currently making an internal effort to
assure ·that hazardous and toxic waste
disposal ·permits contain the same
essential conditions.
The TSCA rules-for waste PCBs have
been. in place since 1978 and they are
well understood by the regulated
community. As of this writing, the RCRA
rules are the subject of pending
litigation. In addition, the RCRA rules
are undergoing comprehensive
regulatory impact analyses that may
result in a number of regulatory
amendments. Efforts to integrate the
ruleo will resume after the major RCRA
litigation issues are resolved and the
RCRA regulatory impact analyses are
completed.
VII. Executive Order 12291, Papenvork
Redu<;_tion Act. and Regulatory
· Flexibility Act ·
Under Executive Order 12291, issued
February 17, 1981, EPA has determined
that this .amendment to the PCB rule is
not -a "major rule" as the term is defined
in section l(b) of the Executive Order.
Therefore; ao Regulatory Impact
Analysis has been prepared for this
amendment This final rule amendment
was sub~tted to the Office of
Management and Budget (0MB) prior to
pul>lication in the F~eral Register.
EPA has aeterminect that the
· application requirements for the
approval of PCB disposal activities
constitute a "collection of information,"
as defined in the Paperwork Reduction
Act (PRA) of 1980, 44 ti.S.C. 3501. These
requirements are set out in 40 CFR ·
761.60, 761.70, and 761.75 of the PCB rule.
These sections of the PCB rule require
the submission of information to EPA
that is necessary to determine the
capabilities and risks associated with
PCB disposal activities. This information
is necessary to insure proper disposal, of
PCBs without posing an ~easonable
risk to human health or the environment.
Information collection requirements
contained in this regulation have been
approved by the Office of Management
and Budget (0MB) under the provisions
of the Paperwork Reduction Act of 1980,
44 U.S.C. 3501 et seq. and have been
assigned 0MB control number 2070-
0011.
The Regulatory Flexibility Act does
not apply to rules that do not undergo
"notice and comment" under-section
553(b) of the Administrative Procedure
Act, or -any other law.
VIII. Statutory Authority
Under section 6(e) of TSCA (15 U.S.C.
2605), the Administrator must
promulgate rules to prescribe methods
for the disposal of PCBs, The
Administrator also has the authority to
amend or modify the existing PCB
disposal rules (40 CFR Part 761),
published in the Federal Register of May
31, 1979 (44 FR 31514), and issue
procedural rules and policy statements
regarding the disposal regulations ..
List of Subjects in 40 CFR Part 761
Hazardous materials, Labeling,
Polychlorinated biphenyls, Reporting
and recordkeeping requirements,
Environmental protection.
FR (48) /.62/ Wednesday, March 30. 1983 13185
Dated: March 21, 1983.
John W. Hernandez. Jr.,
Acting Administrator.
Therefore, 40 CFR Part 761 is
amended as follows:
PART 761-POLYCHLORINATED
BIPHENYLS (PCBs) MANUFACTURtNG,
PROCESSING, DISTRIBUTION IN
COMMERCE, AND USE PROHIBITIONS
1. In§ 761.60 paragraph (e) is revised ·
and paragraphs (i) (1) and (2) are added
to read as follows:
Subpart D-Storage and Disposal
§ 781.60 Dlapoul requlrementa. . . .. * .. •
(e) Any person who is required to .
incinerate any PCBs and PCB Items
under this st~!ipart and who can
demonstrate that an alternative method
of destroying PCBs and PCB Items exists
and that this alternative method can
achieve a level of performance
equivalent to § 761.70 incinerators or
high efficiency boilers as provided in ·
paragraph (a)(2)(iv) and {a)(3)(iv) of this
section, may submit a .written request to
either the Regional Administrator or the
Assistant Administrator for Pesticides
and Toxic Substances for an exemption
from the incineration requirements 0£
§ 761.70 or § 761.60. Requests for
approval of alternate methods that will
be operated in more than one region
must be submitted to the Assistant
Administrator for Pesticides and Toxic
Substances except for research and ·
developmer..• involving less than 500
pounds of P'--""3 material (see paragraph
(i)(2)). Reqvea~~ for approval of alternate
methods tha~ .vill be operated in only
one region must be submitted to the
appropriate Regional Administrator. The
applicant must show that his method of
destroying PCBs will not present an
unreasonable risk of injury to health or
the environment. On the· basis of such
information and any·available
information. the Regional Administrator
or Assistant Administratodor
Pesticides and Toxic Substances ma~ in
his discretion, approve the use of the
alternate method if he· finds that the
alternate disposal method provides PCB
destruction equivalent to disposal in a
§ 761.70 incinerator or a § 761.60 high
efficiency boiler and will not present an
unreasonable risk of injury to health or
the environment. Anf approval must be
stated in writing and may contain such
conditions.and provisions as the
Regional Administrator or. Assistant
Administrator for Pesticides and Toxic·
Substances deems appropriate-. The
person to whom such waiver is issued.
must comply with all limitations
contained in such determination.
* * • * •
(i) Approval authority for disposal
methods. (1) The officials (the Assistant
Administrator for Pesticides and Toxic
Substances and the Regional.
Administrators) designated in§§ 761.60
(e) and 761.70 (a) and (b) to receive
requests for approval of PCB disposal
activities are the primary approval
authorities for these activities.
Notwithstanding, the Assistant
Administrator for Pesticides and Toxic
Substances may, at his/her discretion,
assign the authority to review and ·
approve any aspect of a disposal system
to the Office of-Pesticides and Toxic
Substances or to a Regional
Administrator.
(2) Except for activity authorized
under § 761.30(j), research and
development (R and D) into PCB
disposal methods using a total of less
than 500 pounds of PCB material -·
(regardlesa of PCB concentration) will
be reviewed and approved by the
appropriate EPA Regional Administrator
and research and development using 500
pounds or more of PCB material
(regardless of PCB concentration) will
be reviewed by the approval authorities
set out in§§ 761.BO(e) and 761.70 (a) and·
(b).
. 2. In§ 761.60 by revising-the
· introductory text of paragraphs (a) and
(a)(8), paragraphs (a)(7) and (9), the ·
introductory text of paragraphs (b], (d)
and (d)(l), paragraph (d)(2) (i) and (iii),
the introductory text.of paragraph ·
(d)(2)(ii), and paragraph (d) (3), (4), (5)
and (7) to read as follows:
§ 781;70 lnctneratlon.
(a) Liquid PCBs. An incinerator used
for inciner:! ting PCBs shall be approved
by an EPA Regional Administrator or
the Assist. :t Administrator for
Pesticides and Toxic Substances
pursuant to paragraph (d) of this se.!'.:tion.
Requests for approval of incineratonJ to
be used i{l more. than one region must be
submitted to the Assistant
Administrator for Pesticides and Toxic
Substances, except for research and
development involving· less than· 500 .
pounds of PCB material (see section
761.60(l)(2)). R,equests for approval of
incinerators to be used in only one
region must:be submitted to the
appropriate Regional Administrator. The
incinerator shall meet all of the
requirements specified in paragraph (a)
(1) through (9) of this section, unless a
waiver from theseTequirements is
-obtained pursuant to paragraph (d](5) of -
this section. In addition·, the incinerator
shall meet any t>ther requirements.which •
may be prescribed pursuant to
paragraph (d)(4) of this section.
• • * • *
(7) At a minimum monitoring and
recording of combustion products and
incineration operations shall be
conducted for the follQwing parameters
whenever the incinerator is incinerating
PCBs: (i) 01: (ii} CO: and (iii) co •. The
monitoring for 01 and CO shall be
continuous. The monitoring for CO1
shall be periodic, at a frequency
'specified by the Regional Administrator
or Assistant Administrator for
Pesticides and Toxic .Substances.
. (8) The flow of PCBs to the incinerator
shall stop automatically when any one
or inore of.the followipg conditions
occur, unless a conthfgency plan is
submitted by the incinerator owner or
operator and approved by the Regional
Administrator or Assistant
Administrator for Pesticides and Toxic
Substances. The contingency plan
indicates what alternative measures the
incinerator owner or operator would
take if any of the following_ conditions
occur: .. * * •
(9) Water scrubbers shall be used for
HCl control during PCB incineration and
shall meet any performance
requirements specified by the
appropriate EPA Regional Administrator
or the Assistant Administrator for
Pesticides and Toxic Substances.
Scrubber effluent shall be monitored
and shall comply with applicable
effluent or pretreatment standards, and
any other State and Federal laws and
regulations. An alternate method of HCl
control may be used if the alternate
method has been approved by the
Regional Administrator or the Assistant
Administrator for Pesticides and Toxic
Substances. (The HCl neutralizing
capability of cement kilns is considered
to be an alternate method.)
(b) Nonliquid PCBs. An incinerator
used for incinerating nonliquid PCBs,
PCB Articles, PCB Equipment. or PCB
Containers shall be approved by the •
appropriate EPA Regional Administrator
or the Assistant Administrator for
Pesticides and Toxic Substances
pursuant to paragraph (d) of this section.
Requests for approval of incinerators to
be used in more than one region must be
· submitted to the Assistant
Administrator for Pesticides and Toxic
Substances, except for research and
development involving less than 500
pounds. of PCB material (see section
761.BO(i)(Z)). Requests for approval of
·incinerators to be-used in only one
region must be submitted to the
appropnate Regional Adminiatrator. The
FR (48) /62/ Wednesday. March 30. 1983 13186
incinerator shall meet all of the·
requirements specified in paragraph (b)
(1) and (2) of this section unless a
waiver from these requirements is
obtained pursuant to paragraph (d)(S) of.
this section. In addition. the incinerator
shall meet any other requirements that·
· M/lY be prescribed pursuant to
paragraph (d)(4) of this se<;tion.
• • • . . .
( d) Approval of incinerators. Prior to
the incineration of PCBs and PCB Items
the owner or oper~tor of an incinerator·
shall receive the written approval of the
Agency Regional Administrator for the
region in which the incinerator is ·
located. or the AsaillitaRt Administrator
for Pesticides and Toxie Substances.
Approval from the Assistant
Administrator for Pesticides and Toxic
Substances may be effective in all ten
EPA regions. Such approval shall be
obtained in the following manner: -
(1) Application. The owner or .
operator shall submit to tJie Regional
Administrator or the Assistant
Administrator an application which
contains:
* • * *
(2) Trial burn. (i) Following receipt of
the application described in paragraph
(d)(l) of this section. the Regional
Administrator or the Assistant
Administratorfor Pesticides and Toxic
Substances shall determine if a trial ·
burn is required and notify the person
who submitted the report whether a trial·
burn of PCBs and PCB Items must be
conducted. The Regional Administrator
or the Assistant Administrator for
Pesticides and Toxic Substances may
require the submission of any other
information that the Regional
· Administrator or-the,Assistant
Administrator for Pesticides and Toxic
Substances finds to be reasonably
necessary to determine the need for a
trial burn. Such other information shall
be restricted to the types of information
required in paragraph (d)(l) (i) through
(vii} of this section.
(ii) If the Regional Administrator or
the Assistant Administrator for
Pesticides and Toxic Substances
determines that a trial bnrn must be
held, the person who submitted the
report described in paragraph (d}(l) of
this section shall submit to the Regional
Administrator or the Assistant
Administrator for Pesticides and Toxic.
3ubstances a detailed.plan for
•::onducting and monitoring the trial
burn. At a minimwil. the plan must
include: ..
(iii} Following receipt of the plan
:iescribed in paragraph (d}(2)(ii) of this
,ectian. the Regional Administrator or.
the Assistant Administrator for
Pesticides and Toxic Substances will
approve the plan, require additions or
modifications to the plan. or disapprove
. the plan. If the plan is disapproved. the
Regional Administrator or the Assistant
Administrator for Pesticides and Toxic
Substances will notify the person who
submitted the plan of such disapproval,
together with the reaso~s why it is ·
, disapproved. That person may
thereafter submit a new plan in
accordance with paragraph (d](2)(ii) of
this section. If the plan is approved
(with ariy additions or modifications
which the Regional Administrator or the
Assistant Administrator for Pesticides
and Toxic Substances may prescribe),
thi! Regional Administrator or the
. Assistant Administrator for Pesticides
and Toxic Substances will notify the
person who submitted the plan of the
approval. Thereafter, the trial bum shall
take place at a dat~ and time to be ,
agreed upon between the Regional
Administrator or the Assistant
Administrator for Pesticides and Toxic
-Substances and the person who
submitted the plan.
(3) Other information. In addition to
the information contained in the report,
and plan described in paragraph (d)(l)
and (2) of this section, the Regional
Administrator or the Assistant
Administrator for Pesticides and Toxic
Substances may require the owner or
operator to submit any other
information that the.Regional
Administrator or the Assistant
Administrator for Pesticides and Toxic
Substances finds to be reasonably
necessary l,:; determine whether an
incinerate!' 11hall _be approved.
Note.-Th,. Regional Administrator will
have_avliilable for review and inspection an·
Agency manual containing information on
sa..:pling methods and analytical procedures
for tbparameten, required in§ 781.70(a) (3),
(4), (6), and (7) plua any other parameters he/
she ,-:iay determine to be appropriate. Owners
or operators are encouraged to review this
manual prior to submitting any report
required in § 761.70.
(4) Coclents of Approval. [i) Except as
provided in paragraph (d}(5) of this
section, the. Regional Administrator or
the Anistant Administrator for
Pesticides and Toxic Substances may
not approve an incinerator for the
disposal of PCBs and PCB Items unless
he finds that the incinerator meets all of
the requirements of paragraphs (a) and/
or (b) of this section.
(ii) In addition to the requirements of -
paragraphs (a) and/or (b) of this section.
the Regional Administrator or the
Aasistant Administrator for Pesticides
and Toxic Substances may include in an
approval any other requirements that
the Regional Administrator or the
Assistant Administrator for Pesticides
and Toxic Substances finds are
necessary to ensure that operation of
the incinerator does not present an
unreasonable risk of injury to health or
· the environment from PCBs. Such
requirements may include a fixed period
of time for which the approval is valid. .
(5) Waivers. An owner or operator of
the incinerator may submit evidence to
the Regional Administrator or the
Assistant Administrator for Pesticides
and Toxic Substances that operation of
the incinerator will not present an
unreasonable risk of injury to health or
the enviroment from PCBs, when one or
more of the requirements of paragraphs
(a) and/or (b) of thiMection are not met.
On the basis of such evidence and any ·
other available information. the
Regional Administrator or the Assistant
Administrator for Pesticides and Toxic
Substances may in his/her discretion
find that any requirement of paragraphs
(a) and (b) of this section is not
necessary to protect against such a risk.
and may waive the requirements in any .
approval for that incinerator. Any
finding and waiver under this paragraph
must be stated in writing and included
as part of the approval
• . *
'(7) Final Approval._Approval of an
incinerator will be in writing and signed
by the Regional Administrator or the
Assistant Administrator for Pesticides
and Toxic Substances. The.appro~al
will state all requirements applicable to
the approved incine~tor. ·
.• • • • •
(PR Doc. ss-tZeZ Fll,,,i,__ Mii amj
B1WNG com 1M0-60-M