NCD980602163_19860821_Warren County PCB Landfill_SERB C_Draft Guielines for Permit Applications and Demosntration Test Plans for PCB Disposal by Non-Thermal Alternatuve Methods-OCR

DRAFT GUIDELINES
FOR
-PERMIT APPLICATIONS AND DEMONSTRATION 'l'EST PLANS
FOR
PCB DISPOSAL BY NON-THERMAL ALTERNATIVE METHODS
AUGUST 21, 1986
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics
Operations Branch (7404)
401 M Street, S.W.
Washington, D.c·. 20460
TABLE OF CONTENTS
Preface . . . .
List of Figures
List of Tables.
Abbreviations .
Glossary ..... .
1.0 Introduction.
2.0 Summary of 40 CFR 761 Regulations and Guidance.
2.1 General .............. .
2.2 Approval Authority ......... .
2.3 §761.60(e) Alternative Methods of Disposal .
3.0 Office of Toxic Substances (OTS) Permitting Procedures.
· 3.1 Establish Communications with the EPA Permit
Writer ............ .
3.2 Apply for an R&D Permit (Optional). . .
3.3 · Submit Operating Permit Application and Demon-
stration Test. Plan to DD/EEO ........ .
3.4 EPA/OTS Review of Permit Application and Demon-
stration Test Plan .......... : .
3.5 EPA/OTS Issues Demonstration Test Permit ... .
3.6 Conduct Demonstration Test .......... .
3.7 Submit Demonstration Test Report to DD/EEO .. .
3.8 EPA/OTS Review of the Demonstration Test Report
3.9 DD/EEO Issues and Operating Permit.
4.0 Permit Application Format .....
4.1
. 4.2
4. 3 :
4.4
·4.5
4.6
4.7
4.8
4.9
4.10
4.11
4.12
4.13
4.14
4.15
4.16
Permit Application Cover
Section· I -Summary ...
Section II -Project Organization.
Section III -Wast~ Description. . . .
Section IV -Process Engineering Description
Section V -Sampling and Monitoring Plan
Section VI -Sampling Procedures ....
Section VII -Sample Analysis Procedures
Section VIII -Monitoring Procedures ..
Section IX -Waste Handling and Disposal
Section X -Data Reporting/Recordkeepin_g
Section XI -Inspection Procedures .. I .
Section XII -Spill Prevention Control and
Countermeasures Pl an . . . . . . . .
Section XIII -Safety Plan ..... .
Section XIV _-Training Plan ..... .
Section XV -Demonstration Test Plans.
i;;
Page
ii
" V ...
vi
vii
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4.17.,
. 4.18
4.19
4.20
A.21
4.22
TABLE OF CONTENTS -(concluded) ;
Section XVI -Test Data or Engineering
Performance Calculations ..... .
Section XVII -Other Permits/Approvals
Section XVIII -Schedule of Pre-Operation
Events . .. . . . ·. . . . . ·. . . . . . .
Section XIX -Quality Assurance Plan ....
Section XX -Standard Operating Procedures
Section XXI -Closure Plan
5.0 Demonstration Test Plans ...... .
5.1 General ......... .
5.2 Contents of a Demonstration Test Plan
6.0 · Conducting a Demonstration Test
6.1 Start-up ...... .
6.2 PCB Waste Destruction
6.3 Shutdown ....
7.0 Demonstration Test Report
7.1 Format and Contents
7,2 Review ..
7. 3 Approval.
8.0 References ..
Appendix A -Checklists for Completeness of Submittal
Appendix B -Sampling and Analysis 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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Figure
1
2
3
4
5
7
List of Ftgures
Title
Major steps in the OTS operating permit process
Process to ob~ain an operating permit from OTS.
Research permitting proce~s ...
·Example permit application cover.
Schematic of sampling and monitoring locations for a
chemical dechlorination process ..
Cover for the. Demoijstration Test Plan
Demonstration Test Report cover
V
Page
8
9
10
16
.
21
31
44
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•
Table
• 1
2
3
4
5
·G
7
8
9
10
List of Tables
Title Page
Outline 6f Major Sections of 40 CFR 761. 3
Disposal Options by PCB Waste Categories 4
Summary of Permit Approval Authority. . 5
Format for Permit Applications for Alternative Method of
PCB Destruction . . . . . . . . . . . . . . . . . . . 15
Example of a Sampling and Monitoring Plan Summary for a
Chemical Dechlorination Method. . . . . . . 22
Format .of Demonstration Test Plans for Nonthermal
Destruction Systems . . . . . . . . . . .
Example Summary of Anticipated Test Parameters for a
Batch Chemical Dechlorination Process ....
Example: Proposed Schedule for Demonstration.
Format for the Demonstration Test Report.
Example Demonstration Test Results Summary for a Batch
Chemical Dechlorination Process .....
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34
38
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ABBREVIATIONS
AA: Assistant Administrator for Pesticides and Toxic Substances.
°C: Degrees Celsius.
CFR: Code of Federal Regulations.
CWA: Clean Water Act. See 40 CF~ 129.
DD/EEO: Division Director, Exposure Evaluation Division
DVE: Data variance estimate.
ECO: Electron capture detector.
I
EIMS: Electron impact mass spectrometry (low resolution).
EPA: U.S. ·Environmental Protection Agency.
FID: Flame ionization detector.
g: Grams.
gal.: Gallons.
GC: Gas chromatography.
GC/FID: Gas chromatography with flame ionization detection.
GC/ECD: Gas chromatography wtth electron captuie detection.
GC/MS:. Gas chromatography/mass spectrometry'.
GPC: Gel permeation chromatography.
h: Hours.
HCl: Hydrochloric aci.d.
HECD: Hall electrolytical conductivity detector.
H20: Water.
HRGC: High resolution GC, also termed capillary GC.
in.: Inch(es).
kg: Kilograms ..
lb: Pounds.
vii
..
".
mg: Milligrams.
min: Minutes.
MS: Mass spectrometry.
NEPA: National Environmental Policy Act.
NPDES: .National P·ollutant Discharge Elimination System.
OPTS: Offtce of Pesticides andToxic Substances.
OSHA: oc·cupational -Safety and Health Act. See 29.CFR 1910.1.
OTS: Office of Toxic Substances, a suborganization of OPTS.
PCB~ Polychlorinated biphenyls.
PCDD: Polychlorinat~d dibenzo-E-dioxin.
PCDF: Polychlorinated dibenzofuran.
PGC: Packed column gas chromatography.
pH: Measure of acidity or alkalinity.
ppm: Parts per million.
QA: Quality assurance.
QC: Quality control.
RA: Regional Administrator.
RCRA: Resource Conservation and Recovery Act. See 40 CFR 122-124 and
260-265.
sec: Seconds.
TCDD: Tetrachlorodibenzo-E-dioxin.
TCDF: Tetrachlorodibenzofuran.·
TSCA: Toxic Substances Control Act, PL 94-469 (1976). See 40 CFR Part 761.
viii
· -GLOSSARY .
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 ..
Data -variance estimate (DVE): Either a numerical value such as a standard
deviation,_ or a qualitative evaluation such as 11 good. 11
Demonstration Test: A test to demonstrate system performance, commonly
called a process demonstration test.
Ele~tron impact mass spectrometry (EIMS): Low resolution mass spectrometry
operated i_n the electron impact ionization m6de.
High resolution gas chromatography: Gas-liquid chromatography performed _
using a c:api -11 ary column, typically 10-50 m long x 0. 2 mm .IO, 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'-dichlorobiphenyl and
2,3-dichlorobiphenyl are isomeric·; 4-chlorobiphenyl and 2,3,4-trichlorobiphenyl
are not. ·
Liquid: A substance is a liquid if it 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 techniques or procedures which form a specific, well-
defined destruction, sampling, chemical analysis, or other procedure for
a specified compound(s)/matrix(ces) combination.
polychlorinated biphenyl (PCB): One of 209 individual compounds having the
molecular f6rmula C12HnC1 10_n, where n = 0-9. This definition includes
monochlorobiphenyls. •
Polychlorinated dibenzo-£-dioxin (PCDD):· One of 75 individual compounds hav-
ing the molecular formula C12H Cl 8 _ 02 , where n = 0~7. This definition
includes mono ch l orodi benzo-£-d~oxi n~. .
Polychlorinated dibenzofuran (PCDF): One of 135 individual compounds having
the molecular formula C12H C1 8 _ 0, where n = 0-7. This definition includes
monochlorodibenzofurans. n n
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.
ix
•
•
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 ~
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
~or low ~oncentration aqueous s~mples, 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) basii 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 pro-
cess.
QC blank: A sample processed and analyzed to obtain background concentrations
of the analytes.
QC control: A sample containing a known amount of analyte which is processed
with sample batches to monitor recoveries.
Solid: A substance is a solid if its melting point is greater than 20°C
and it passes the structural integrity test (Weller 1982).
Technique: Specific destruction, laboratory, or sampling operation usually
conducted as part of a method. GC/EIMS and Soxhlet extraction are
techniques.
X
I)
. '
i.O INTRODUCTION
The Code of Federal Regulations, Title 40, Part 761 (40 CFR 761)
(USEPA 1985) establishes rules on the disposal of PCBs and PCB items. Under
these fules, organizations or persons wishing to dispose of PCBs are required
to use approved methods and must obtain a permit.
This document provides guidance for persons applying to the EPA for
approval of PCB disposal by methods alternative to incineration (§761.60(e)).
This document presents and discusses the format, content, and level of detail
requiTed fo,r permit applic'ations, demonstration test plans, a·nd .demonstration·
test reports~ . · ·
Alternative methods of PCB destruction include, but are not limited
to, catalytic dehydrochlorination, chlorolysis, plasma arc, ozonation, cata-
lyzed oxidation, microbiological, and sodium-catalyzed decomposition of the
PCB 'molecules . Methods for decontamination of PCB-contaminated materials by
removal and concentration of the PCBs also are considered alternative methods
of PCB destruction. An example of this technique is fractional distillation
of PCB-contaminated dielectric fluid or rinse solvent.
These guidelines address only permit requirements for the 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 addi-
tional permi t requirements.
Section 2.0 provides a brief summary of pertinent EPA procedural
requirements and ·guidance as well as a summary of pertinent Part 761 regula-
tions. Section 3.0 describes the EPA Office of Toxic Substances (OTS) permit-
ting procedures. Sections 4.0 and 5.·o provide guidance regarding preparation
and submission of permit applications and demonstration test plans, respec-
t i vely . Section 6.0 briefly discusses conducting a demonstration test.
Section 7.0 provides guidance regarding preparation of a demonstration test
report . Section 8.0 lists the references for this document. Appendix A pro-
vides checklists 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 PCBs . Appendix C provides
guidaAce to the applicant in the f6rm of answers to some frequently asked
questions. Appendix D lists the addresses for OTS Headquarters and for the
10 Regional Offices. Appendix Eis an annotated .bibliography of sources of
·related information.
1
'2.0 SUMMARY OF 40 CFR 761 REGULATIONS AND GUIDANCE
This section summarizes pertinent provisions of Title. 40 of the Code
of Federal Regulations, Part 761 (40 CFR 761) related to the disposal of PCBs.
Part 761 ·establishes prohibitions of and requirements for the manufacture,
. processing, distribution in commerce, use, disposal, storage, and marking of
PCBs and PCB items in the United States. These regulations 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 ~FR 761 as of July 1, 1985 .
. ,
2.1 General
. .
The major sections of 40 CFR 761 are outlined in Table 1. The stor-
age and disposal of PCBs is addressed in 40 CFR 761, Subpart D. In Subpart D,
Para~raph 761.60, disposal requirements are differentiated according to waste
type and PCB concentration; Table 2 summarizes the disposal options o.f §761.60.
This guideline document is intended to provide guidance only for
approval of alternative disposal methods (§761.60(e)) which may require ap-
proval by the Division Director, Exposure Evaluation Division of the Office
of Toxic Substances (DD/EEO). A companion document, "Guidelines for Permit
Applications and Demonstration Test Plans for PCB Incinerators" (Neulicht
et al. 1986), also prepared by Midwest Research Institute for EPA/OTS,
Washington, D.C., provides guidelines for approval of incinerators by the
OD/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
Section 761.60. Table 3 summarizes EPA approval authority for PCB disposal
facilities. Addresses for EPA headquarters and the regional offices are pro~
vided in Appendix 0.
2.3 §761 .60(e)_ Alternative Methods of Disposal
According to §761.60(e) any person may submit a written request to
the DD/EEO or RA for an exemption from the incineration requirements of Part
761 (see Table 2). Section 761.60(e) states that the applicant for an alter-
native method of destroying PCBs must show that:. (a) the method can achieve
a level of performance equivalentto§761.70 incinerators or §761.60(a)(2)(iv)
high efficiency boilers and, (b) the method will not present an unreasonable
risk of injury to health or the environment. These two requirements must be
taken into consideration by the applicant and must be appropriately addressed
in th~ permit application. Because alternative methods of PCB destruction
usually differ significantly from incineration, it is difficult to define
11 equivalent level of performance. 11 For _processes which destroy PCBs in con-
taminated liquids, the agency has generally required the applicant to show
2
. '
Table 1. Outline ·of Major Sections of-40 CFR 761a ·
Subpart A -General
761.1 Applicability
761.3 Definitions
761.19 References
Subpart B -Manufacturing, Processing, Distribution .in Commerce,
. ·and Use of PCBs and-PCB Ite~s
761.20 Prohibitions
761.30 Authorizations'
Sub.part C -Marking of PCBs and PCB Items
· 761.40 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.
. 3
~ ,..,. .~ ·,•'11>f;1•""'j ·,f; ,¼M"f,."Wf"'ll' • ...,.l-19f.!~~1"~-..-y .,.-o, PCB waste category Mineral oil dielectric fluid Other liquids Honliquids (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 articles Other PCB articles PCB containers PCB containers All other PCBs ~Hot specified. ""\__ CFR section 761. 60[a][2] 761. 60[a][3] 761.60[a][4] 761. 60[ a)[ 5] 761. 60[b][l] 761. 60[b][2] 761.60[b][4) 761.60[b][3) 761. 60[b)[ 4 J 761. 60[b][5] 761.60[b)[5] 761. 60[c] 761. 60[c] 761. 60[a] Table 2. Disposal o·ptions by PCB Waste Categories (USEPA 1985) PCB concentration (ppm) 50-500 50-500 ~ 50 ~ 50 HSa ~ 500 50-500 ~ 50 ~ 5oof 50-500 ~ 5oof < 500 ~ 50 Incinerator (§761. 70) X X X X X X X X X X Cliemical waste landfill (§761. 75) X X X X X X xg X d Htgh efficie,:icy boiler (§761. 60) X X Disp_osal method Alternative method (§761. 60(e)) X X X Method approved by region X Oraln, dispose as solid waste xc,d X e X e X d cExemptions for some small capacitors. dMust also be flushed if hydraulic fluid contains> 1,000 ppm PCBs and flushing solvent disposed of in accordance with §761.-60(a). Decon-laminatii>n .h X h X eDrained liquid must be disposed of in accordance with §761.60(a). . · Must 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 ~e 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 l, 1985, p. 163) erroneously states this value as 50 ppm; refer to Federal Register, 44, 31514-31568 (May 3, 1979) (USEPA 1979). ~Drained of any free-flowing liquid and liquid incinerated in §761.70 incinerator. Decontaminated in compliance with §761. 79. •
Table 3. $ummary of Permit Approval Authority
Type facility
Alternative disposal methods which are mobile or are
of identical design to be used in more than one EPA
Region
Research and development method$ disposing of
> 500 lb PCB-containing material
Research and development methods disposing of
~ 500 lb PCB-containing material
Site-spec if i c a 1 terna·t i ve di sposa 1 methods to be
used in only one EPA Region
Approval permit
authority
Assistant Administra-
tor for Pesticides ang
Toxic S~bstances (AA)
AAa
Regional Administra-
tors (RAs)
RAs
aAuthority has been delegated to the Division Director, Exposure Evaluation
Division, Office of Toxic Substances (DD/EEO).
5
that the concentration of any individual PCB congener in the product (decon-
taminated) liquid is no more than 2 ppm. Fractional distillation of PCB-
containing liquids must remove PCBs to a level of< 2 ppm total PCBs, quanti-
tated using the original formulation (e.g., Aroclor 1260) as a standard. Any
aspects of the process that may pose certain risks of injury to p~rsons or
environment must be addressed in the application. Examples of such risks
include: (a) emission of toxic solvents to the atmosphere and (b) explosion/
fire .hazards from sodium reagent. ·
_Section 4.0 of this guideline document presents and discusses the
suggested cpntents of. an application for a permit to operate an alternative
method for· PCB disposal.· ·
6
3.0 OFFICE OF TOXIC SUBSTANCES (OTS) PERMITTING PROCEDURES
The Code of Federal Regulations, ~itle 40, Part -761 {40 CFR 761)
specifies that the Assistant Administration {AA) for Pesticides and Toiic
Substances has approval authority for certain PCB disposal facilities [this
approval authority has been delegated to the Division Director, Exposure
. Evaluation Division of the Office of Toxic Substances {DD/EED)]; Regional
Administrations {RAs) have approval authori"ty for other facilities. Facili-
ties for which the DD/EED has approval authority 1nclude PCB treatment pro-
cesses 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·; stationary incinerators, high-efficiency boilers, and research and
development into PCB methods involving a total of 500 lb or less of PCB
materials.
This section describe$ the process used by EPA/OTS to issue an oper-
ating permit or an R&D permit to the applicant. Figure 1 shows the major
steps in the operating permitting process. Figure 2 gives a more detailed
process diagram which also includes the loops at various points in the operat-
ing 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 communications 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 development (R&D) permit is to assist
the facility operator _in brfoging the destruction process from conception to ·
commercial operation; R&D permits can be issued for bench-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 "shakedown" 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&D activity.
7
Establish Communications with
EPA/OTS Permit Writer
., '
Submit Complete Operating --Submit Complete Demonstrati~n
Permit Application to DD/EED . --Test Plan to DD/EEO
' 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.
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t ~
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Test Pion
F.evised by
Applicant
0.ficiencie,
Noted and
Returned to
Applicant
·-r-------.
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Operating Penntt Application
Rwlwed by DD/EEO
Demonltratlon TNt
Plan Rece!Yed by
DD/EEO
Test Pion
Requested
by OD/EEO
Test Pion Reviewed
Test Pion
Complete
and ·
Acceptable
Acceptable to OTS
Facility (;orrects
Minor Deficiencies
and Requests New
Test Dote
Has O.monsttction
Test Pion INn
Submitted?
O.monstTotion
Permit issued
Test Dote Set
and OTS ·Notified
30 Days Prior
Demonstration
Test Initiated
Applicotion-
Ac:ceotable
Revised
Application
Submitted
Deficiencies
Noted and
Returned to
Applicant
OTS Recommends
Ajipiicont Submit ·
R & 0 Permit
Application in Lieu
of Opercting
Permit A!:iplicotion
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I OTS Requires
Operoling, Design,
Sompli ng/Anal11i1
Deficiencies
Demonstration
Test Completed
~ . I -~----------~
to be Co,,..cted
OTS Request,
Corntclion of
·Deficiencies
and Another
Demonstration T■st
OTS Requests
Revised Permit
Application
Operoting
Permit
Denied
---,
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Opercting
Permit
Denied
0emonstrotion
T ■st Results
Submitted
Results
Revie-d
by OTS
Operotin;
Permit Issued
------
Additional Data/
Information Requested
Figure 2.· Process to obtain an operating permit from OTS.
9
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t
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R&D
Permit
Denied
R & D Permit
Application
Received by
DD/EEO
-------,
· Application
Reviewed
Application ~·
_c_o_m_p_le_t_e __ --~ ~
R&D
Permit
Issued
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.
10
The R&D activity should provide process .information and operating experience
_needed for application fo~ an operating permit. The ·R&O results should be
used for planning a full-scale demonstration such that there is a high prob-
ability of a successful demonstration. The R&O results may be appropriate
for inclusion in the application for the -Operating permit.
R&D permits can be issued by the appropriate EPA Regional Adminis-
trator for the destru.ction of a total of 500 lb or less of PCB-containing
material (regardless of PCB concentration), or by the Division Director,
Exposure Evaluation Division of the Office of Toxic Substances (DD/EED), for
the destruction of more than 500 lb .of PCB-containing _material ~ R&D _permit
applicatioris can be submitted at any time, eve~ if an application for~ per-
mit 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
de~ciencies will be ~ent to the applicant, who must then revise and resubmit
the application. In some cases, EPA/OTS may recommend that the applicant
submit 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&O work, a 30-day
notice must be given to EPA regional, state, and local officials. After com-
pletion of the R&D activities,~ 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/EED
The permit applicant must submit both an operating permit applica-
tion and demonstration test plan to DD/EED 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 submis~i6ns are acceptable if the submission clearly indicates the
portions of the application -to be submitted later, and if the applicant and
EPA permit w·riter 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 determined by EPA to be complete before a demonstration
permit can be issued.
The suggested format for an operating permit application, based on
the §761.70(d)(l) incinerator requirements, is presented in Table 4 in Section
4.0 of this document . A complete application must address each .topic in the
format given in Table 4. As an aid to the applicant in determining if all
requirements for an application have been addressed, a checklist is provided
in Appendix A.
11
A Demonstration Test Pl an is a docu·ment 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-
plicant in determining whether all required items have been addre~sed.
3.4 EPA/OTS Review of Permit Application and Demonstration Test Plan
EPA/O_TS reviews the permit application and demonstration test plan
for completeness, accuracy, clarity and technical ·-viability. If either docu-
ment is •uriacceptable to EPA, a notice o.f 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 s~bmitted to the DD/EED. In some
cases, this process may need to be repeated more than once.
·3.5 EPA/OTS Issues Demonstration Test Permit
After the EPA approves the permit application and demonstration test
plan, the DD/EED 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 demonstration and other conditions based on
the applicants permit applicati-0n and demonstration test plan. The time
· period for which the demonstration permit is valid also wiil be limited .
. 3.6 Conduct Demonstration Test
A demonstration test 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. The RA of the EPA
region where ·the demonstration will be conducted, state officials, and rele-
vant local authorities should be notified.
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 require that the plan be
significantly modified during the test. demonstration, then the permit writer
should be con_tacted immed.iately -to discuss the implications of any modifica-
tions . As with normal operation, any significant deviations from or altera-
tions in th~ test plan must be documented in writing to EPA/OTS (permit writer)
within 10 days after the event. Throughout the test demonstration, an "event
log11 shoul~ be maintained. This log should be submitted as part of the demon-
stration test report.
The test should be conducted unde-r conditions s1mulating normal com-
mercial operations. Operating permit r~quire~ents 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.
12
If the demonstratioM test is· initiated, but cannot be co~pleted for
some reason, EPA/OTS can exercise several options. The first option is to
deny the operating permit without further consideration, which is rare1y done.
A second option is to recommend that the applicant submit an R&D permit ap-
plication in order to have a chance to correct operating deficiencies prior
to another demonstration. A third option is to reschedule 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 de-
ficiencies JllUSt be corrected before another demonstration test can ·be performed.
3.7 ·· Submit Demonstration Test Report to DD/EED
After a complete demonstration test ·has been performed, a report of
the results must be made and submitted to the DD/EEO . 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 sub-
mitted 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 and other
information are acceptable, EPA/OTS will issue an operating permit to the
applicant.
3.9 DD/EED Issues and Operating Permit
An operating permit allows the operator to operate commercia l ly.
After acceptance of the permit application and demonstration test results,
t~e DD/EEO will issue a fina~ operating permit .. Generally, the final oper-
ating .permit will specify the type of PCB-containing material which can be
processed, 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 least 90 days, but not more than 180
days, prior to the expiration date of the .permit.•
13
'4.0 PERMIT APPLICATION FORMAT
This section describes the information required in permit applica-
tions for alternative methods of PCB destruction. EPA's supplemental guidance
(48 FR 13181, March 30, 1983) (USEPA 1983a) establishes the required contents ·
. of an application for a permit to operate an alternative ·method for PCB de-
struction. The suggested format for the permit application is presented in
Table 4. Each major item of the permit format is discussed in the following
sections. · ·
A checklist is provided ·in Appendix A to aid the applicant in deter-
m1n1ng, prior to submittal, if all requirements for an application to operate
an alternative method for PCB destruction have been .addressed.
A preliminary, partial application may be submitted to initiate ·
communication between the applicant and the EPA at the earliest possible
moment. Early communications can be helpful to both parties: unnecessary
submissions can be avoided; needed engineering changes can be made while the
facility is being designed or constructed; and provisions can be made. for site
visits duri'ng construction or shakedown. If a preliminary permit application
is submitted, the applicant should clearly identify in the body of the pre-
liminary application those sections or items to be provided at a later date.
A resear'Ch and development permit application should follow the same
format as an operating permit application. Although the R&D application need
not contain the detail required for an operating permit, it 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 infor-
mation on the specific objectives of the R&D activity.
4.1 Permit Application Cover
Each submission must have a permit application cover. The applica-.
tion cpver format is presented in Figure 4. ·If the application or the appen-
dices must be bound separately (i.e., multiple volumes), number each volume
of the submission 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 in-
formation~ The principal manager is the person identified by the applicant
as the primary contact for written or verbal communications from the EPA per-
mit writer.
4.2 Section I -Summary
The applicant is encouraged to begin the permit application with a
short summary presenting the document organization and any pertinent back-
ground information. ·
14
i
ii
I.
II.
III.
IV. ,
V.
VI.
VII.
VIII.
IX.
X.
XI.
XI I.
XIII.
XIV.
xv.
XVI.
XVII.
XVII I.
XIX.
xx.
XXI.
Table 4. Format for Permit A~plications for Alternative
Method of PCB Destruction
Permit Cover
Table of Contents
S_ummary
Project Organization
Waste Description
Process Engineering Description
Sampling and Monitoring Plan
Sampling P~ocedures
Sample Analysis Procedures
Monitoring Procedures
Waste Handling and Disposal
Data Reporting/Recordkeeping
Inspection Procedures
Spill Prevention Control and Countermeasure Plan
Safety Plan
Training· Plan
Demonstration Te~t Plansa
Test Data or Engineering Performance Calculations
Other Permits/Approvals
Schedule of Preoperation Events
Quality Assurance Plan
Standard Operating Procedures
Closure Plan
aFor a research and development application, this section would present the
_planned research. activities.
15
(PRELIMINARY) PERMIT APPLICATION
PCB DESTRUCTION UNIT
[Type and location]
[Test site for mobile units]
Submission date:
Volume m of n --
Submission number [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.
16
4.3 Section 11 ·-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 pe~mit;
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.
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 concentrations. Heating
value, viscosity, Cl, ash, water content, and other charac-
t~ristics of the waste material. should be included, if appro-
priate: ·
4.5 Section 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 o·peration, pollution control equipment, and anticipated
performance. 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.
17
4.5.1 General
Process flow diagram and narrative description of the system;
Description of the theoretical basis for the destruction
process;
Layout diagram and description of the plant or mobile unit;
Detailed engineering drawings;
Intended location of the mobile· unit or facility (e-.g., by
. waste lagoons or at transformer substations); and
Intended location of where the unit will be stored when not in
·use (if mobile unit).
4. 5. 2 Waste· Feed System
Narrative description of the waste feed system (e.g., procedure
for unloading the PCB-containing material, storage of waste,·
and transfer from storage to the process operations);
Description of waste preparation, if applicable (e.g., filtra-
tion, blending with reagents, solvents, preheating, shred-
ding, and/or hammering). Note: §761.l(b) prohibits treat-
ment which dilute PCB wastes during treatment. Any step
which involves dilution must be specifically permitted;
Waste volume expected to be handled at the facility per month
or other ti me period; -
Waste feed storage capacity and average waste feed stored at
the location (e.g., gallons, number of days' supply); and
Description of method for measurement of the waste feed rate.
4.5.3 Automatic Waste Feed Cutoff System
Description of the automatic waste feed cutoff system when
process conditions deviate beyond the stated limits for re-.
quired destruction efficiency or beyond safe operating limits
and delay time prior to cutoff; and
Description of the procedures to shut off the waste feed line
and the whole process in the event of an equipment malfunction.
4._5.4 Destruction System
Narrative description of the destruction system (e.g., descrjp-
tion of chemical reactions, stoichiometry, reagents, cata-
lysts, process design capacity, etc.); ·
Engineering diagrams;
List of products and by-products and their concentrations;
Description of how essential parameters (~.g., temp~rature,
pressure, flow rate, etc.) are monitored and the design
values;
Description of reactant/oxidant/fuel/catalyst/feed rates and
how they are monitored;
Design capacity of the system;
18
Detailed description of the unique engineering -features· of the
process (e.g.~ high temperature, pressure, long residence
time, heat transfer, etc.); and
Description of any regeneration/recycling processes applied in
the process.
4.5.5 Pollution -Control System (PCS)
A description of the pollution control system for process
·effluents (air emissions, liquid effluents, sludge, .so1id
waste, et~.); · · · ·
Destgn parameter~; ~nd
·· • The important operating parameters of the PCS and how ·they wil 1
be monitored .
4.5.6 Summary of Process Operating Parameters
Provide a summary which lists target values as well as upper and
lower boundaries for all major measured operating parameters, instrument set-
tings, and control equipment parameters. All values must be reported in com-
mon, consistent units. The application must also describe the action to be
taken whenever the parameter deviates outside the control limits. These ·ac-
tions may include adjusting the operating conditions, stopping the PCB feed,
shutting down th~ process, etc. The time allowable for corrective action
before shut-down or other action must be specified.
4.6 Section V -Sampling and Monitoring Plan
The applicant must develop a sampling and monitoring plan to monitor
process operation and to verify that the PCB destruction is equivalent to de-
struction in §761.70 incinerators. In most cases, GC/ECD is adequate to de-
termine the PCB content of product oils or related matrices. In some cases,
surrogate parameters for PCB .destruction (such as the CO-CO2 ratio allowed
for §761.70 incinerators) may be applicable; in most cases,· actual measurement
of PCB concentration .is necessary. A PCB screening method such as infrared
spectroscopy, or a total chloride detection kit (e.g., Chlor-N-Oil® or McGraw-
Edison PCB field test kit), a chlorine~specific detector, or ultraviolet spec-
troscopy may be appropriate ·for measurement of PCB concentration in some cases,
while in other cases, 'GC/EIMS analysis may be required.
For thermal destruction units, the regulations specify the param-
eters which must be monitored. Since each alternative method for destruction
of PCBs is different, it is up to the applicant to specify the process param-
eters which will be monitored (continuously or routinely) and the effluent
streams which will be sampled routinely during operation to demonstrate per-
formance. In general, EPA will require monitoring and sampling of every waste
stream, unless the applicant can show that it·is inappropriate. The plan
should include:
Process parameters to be monitored;
Monitoring locations;
Monitoring method~~
19
Monitoring frequencies;
Effluent streams to be sampled;
Sampling locations;
Sampling methods;
Sampling frequencies;
Analysis methods; and
Acceptable 1 imits for result ..
A schematic diagram can be .used to i~lustrate the sampling and mon-
itoring locations; Figure 5 is an .example .. The specific location of ~ach .
sampling p~int shriuld be discussed briefly in the narrative. Other impo~tant
parameters of the sampling and monitoring plan can be concisely presented in
a tabular format. · Table 5 is an example of a sampling and monitoring pian
summary.
The sampling plan must include:
A description of the syste~ or process being sampled and a
breakdown of the process into discrete sampling units (stack
emissions, liquid waste, product, etc.).
The objective of the sampling for each unit (e.g., collect a
11 representative11 sample; follow an EPA test protocol; or
co 11 ect a 11wors t case11 sample).
The parameters to be tested: List the compounds, physical
measurements, frequency, and media.
· The sampling design for each unit.· This may require a mathe-
matical sampling design or simply a reference to a standard
.protocol. 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., triplicates for 10% of the sam-
ples or 2 samples, whichever 1s greater), number of surrogate-
spiked samples, and total number of samples should be listed
for each sample type.
An estimate of the sample rep·resentativeness. This 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·could be characterized as 11 highly11
representative).
Contingencies for action if samples cannot be collected accord-
•ing to plan (e.g., alternate sites or times or an entirely
new sampling plan).
4.7 Section VI -Sampling Procedures
Details of the sampling methods to be used on a routine basis should
be discussed in this section. Include an explanation of the apparatus, cali-
bration procedures, and maintenance procedures, if applicable.
20
r-Vent----------------·t ----. --. _.-. -----·-f
I I
Bulk ~toroge
Tonk
legend
Q lv'onitoring Location
(-) Sampling Location ~--
: I
I I
I I
I I
I I
\------~-........, I
Reagent
Quench
I
I
I
I
I
I
I
I
I I Vent
Bulk Storoge
for Product
Figure 5. Schematic of sampling and monitoring locations for a
chemical dechlorination process.
21
To Atmosphere • 19' \ .)
Carbon
Adsorption
Unit
•· -7•t1 !':~, .... -7 Table 5. Example of a Sampling and Monitoring Plan Summary for a Chemical Dechlorination Method Parameter Sampling (monitoring) Frequency locati ona Analysis Analysis limit Contingency method parameters methods A. Waste feed Grab samp_le from line Once per batch !--Storage tank PCB homologs GC/ECO <· 2 ppm Olp from reaction vessel tap line tap B. Process product Grab sample from Once per batch 2--Reactor vessel PCB homologs GC/ECO < 2 ppm Hold batch until sample reactor tap 1 I ne tap obtained and analyzed Grab sample from At end of de-3--Product Storage PCB homologs GC/ECO < 2 ppm . storage tank monstratlon tank C. Waste feed rate Positive displacement Each batch 4--Storage tank l/mln --Discontinue operallon until meter 1 lne repaired 0. Product rate Positive displacement Each batch 5--Product tank l/mln --Discontinue operation until N meter 1 i ne repaired "' E. Reagent feed Positive displacement Each batch 6--Vesse 1 feed l/min --Discontinue operation until rate meter 1 ine repaired F. Quench feed rate Positive displacement Each batch 7--Vessel feed l/min - -Discontinue operation until meter line repaired G. Reaction vessel Pressure gauge 15 min. 8--Vessel 111111 Hg --Discontinue operation at pressure end of batch H. Reaction vessel Thermometer 15 min. 8--VP.ssel oc - -Discontinue operation at temperature . end of batch I. Vent emi ss Ions~ lota 1 hydrocarbon Continuously 9--Carbon adsorp-Total GC/FID < 1 ppm Discontinue operation at to ambient air analyzer tlon vent hydrocarbon end of batch ~Refers to Figure 5.
---------·-------------
When 11 standard methods" will be used, they may be referenced and
included as an appendix. ~owever, any deviations from standard procedures ·
must be noted. Furthermore, when the standard method allows different pro-
cedural variations to be used, the applicant must be specific as to the pro-
cedures which will be followed.
The discussion of sampling and analysis methods should include:
,Sampling equipment;
Sampling equipment calibration;
~ ·Sampling procedurei;. ·
Sample recovery, storage, and preservation;
Sample transport and custody;
Analytical equipment;
Reagents;
Reagents preparation;
Calibraiion standards; and
• Calibration procedures.
Appendix B to this document provides guidance on -sampling and analyt-
ical methods.
4.8 Section VII -Sample Analysis Procedures
Summarize the analytical procedures (including sample preparation)
which will be used for each sample. The summary should include the analytical
method, apparatus, data reduction procedures, pata storage, equipment cali-
bration, and equjpment maintenance. Specific details of the analytical pro~
cedures need not be included in this section, but should be referenced (if
standard published procedure) or should be inciuded as an appendix, if un-
published or if the publication is not readily available.
4.9 Section VIII -Monitoring Procedures
Provide a summary of the procedures which will be used to monitor
the parameters presented in the sampling and monitoring plan. Include a di~-
cussion of the ~ethods and apparatus which will be used, as well as the data
.reduction, data storage, equipment calibration, and equipment maintenance .
procedures w~ich will be followed. ·
4.10 Section IX -Waste Handling and Disposal
The permit application must identify any by-product wastes (both
PCB and non-PCB) that will be generated and how the wastes will be disposed,
e.g., in-line filters for the PCB waste feed line.
4.11 Section X -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.
23
Include example calculations, units of measurements, and example record re-
porting forms. -Paragraph 761.lSO(b) establishes the minimum data record
requirements for disposal and storage facilities. Minimum records include 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 waste which has not
been demonstrated to be free of PCB contamination) were dis-
posed of or transferred; . . .
Summary of the tota·1 weight (kg) of PCBs an·d PCB articles in
containers and PCBs in transformers which have been received,
transferred to other facilities, and retained at the facility;
and
Summary of the 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:
The demonstration test results;
Additional information as specified in the operating permit by
the RA or DD/EED.
4.12 Section XI -Inspection Procedures
The permit application shall identify the routine inspection proce-
dures used to identify problems and malfunctions associated with the facility.
The frequency of inspections also should be addressed. Inspection procedures
should be identified for items such as:
Waste feed system;
Destruction system;
Waste feed cutoff syst€m;
Po·llution control system;
Process alarms; and
Fire extinguisher system
4.1~ Section XII -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-
l owed should a spi 11 occur. Coast Guard regulations specifying spil 1 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 plan pro-
vided in the permit application need not be in the format or detail specified .
in 40 CFR 112. 7 .
24
•
4.14 Section XIII -Safety Plan
This sect ion addresses the safety program which wi 11 be ini t 'i ated
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-
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 outag.es~ etc,, a_lso
should be addressed. ·
4.lS Section XIV Training Plan
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 wi-th standard operating
procedures);
Emergency shut-down procedures;
Use of protective clothing;
Waste handling; ·
Spill prevention/control;
Fire control; and
Hazards of PCBs.
4.16 Section XV -Demonstration Test Plans
This section of the permit shoul~ 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 docu -
ment). However, summary information which should be presented in this section
includes:
Tentative date (month/year) for the test;
Tentative location for the test;·
· Parameteri to be te~t~d;
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 that a demonstration test will not be required.
One of the few reasons for not requiring a demonstration test is that an
identical unit has been previously tested ~nd permitted.
4.17 Section XVI -Test Data or Engineering Performance Calculations
The applicant should present a summary of any relevant test data
from R&D activities, non-PCB tests, or other sources, or any engineering cal-
culations-which support the abili_ty of the system to destroy PCBs. Detailed
25
test results need not be presented in this section, but instead may ·be pro-
vided as an appendix, or referenced if already on file with the Office of
Toxic Substances.
4.18 Section XVII -Other Permits/Approvals
List other permits/approvals which .have been obtained or are being
sought for this unit; identify the permitting agency and the person to con-
tact for additi'onal information {permit writer); Relevant permits include ·
PCB research and development permits, operating permits issued by an RA, sta_te
or local permits · to operate, RCRA ·permits, NPDES permits,. and DOT permit's.
4.19 Section XVIII..; Schedule of Pre-Operatien Events
Provide .a proposed schedule (month and year) for complying with the
regulatory requirements associated with approval of the facility. Scheduled
ite~s to be -ddressed include: begi~ning construction date, construction
completion date, submittal of demonstration test plan, equipment shakedown
period, initiation of demonstration test, submittal of demonstration test re-
sults, and initial operating date.
4.20 Section XIX -Quality Assurance Plan
Each pe.rmit application must include a Quality Assurance (QA) Plan.
Note that the QA plan must address all data-generating activities (e.g., 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., monitoring) parameters. Additional
guidance in the preparation of QA project plans is available in "Quality
Assurance Program Plan for the Office of Toxi~ Substances'' (USEPA 1983b).
The purpose of the Quality Assurance Plan is to establish a specific
program to: (a) help assure that the monitoring data meet specific quality
objectives, and (b) routinely assess the quality of the monitoring data. Ap-
propriate QA is imperative. If the data (physical or chemical measurement)
·are of unknown quality, the data are unacceptable and cannot be used to show
a facility is operating within permit requirements. Data of poor quality, 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 Plan should address the following items:
Organization and responsibility for QA;
Quality assurance objectives for each measurement parameter
(e.g., process temperature, pressure);
Monitoring procedures (brief description);
Sampling procedures;
Analytical procedures;
Sample custody;
Specific calibration procedures and frequency;
26
. .
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
QuaJity assurance reports to management .
Ea.ch of these _items is discussed in ''Interim Guidelines and Specifi-
cations for Preparing Quality Assurance Plalis11 ; the applicant is advised· to·
follow this document. ·
4.21 Section XX -Standard Operating Procedures
, A summary of the standard operating profedures (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 pro-
cess operating manual · to satisfy this requirement.
Applicants should be required to develop an SOP (standard operating
procedure) and submit 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 sampling or monitoring equipment 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 proced~res .
The SOP should be part of the training plan. Each employee should
sign and date a statement indicating that the employee has read and understood the SOP. . .
4.22 · Section XXI -Closure Plan
The closure plan for the facility should address two situations:
For mobile units, closure of the facility at each site prior
to moving to a new site; closure must address items such as
decontamination of equipment, placarding any contaminated
equipment, and disposal of any wastes generated from decontam-
ination/cleanup procedures .
27
For both mobile and stationary facilities, permanent .clos-ure
(_i.e., ·removal from service).
The closure plan(s) should address:
R~sponsible personnel;
Disposal of by-product wastes on a routine basis; .
Disposal of equipment;_ and
·financial responsibility of ·the company.
28
5.0 DEMONSTRATION TEST PLANS
This section presents the suggested format for a Demonstration Test
Plan and briefly discusses the major items of information which must be sub-
mitted in the plan .
. A Demonstration Test Plan is a document prepared specifically for
the demonstration tests and provides details of ·how the test will be con-
ducted. This i,ncludes 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
For alternative methods of destruction, the applicant must show that
the method will not present an unreasonable risk(§ 761 .60 (e)). Supplemental
Guidance to Part 761 (48 FR 13181, March 30, 1983) (USEPA 1983a) for procedures
to approve alternative methods indicates that a process demonstration may be
required by the AA prior to approval. The supplemental guidance specifies the
minimum information requir~d for a process demonstration test plan as follows:
Time, date, and location of the demonstration;
Quantity and type of PCBs and PCB items to be processed;
Parameters to be monitored and location of sampling points;
Sampling Plan and Quality Assurance Plan including sampling
frequencies, methods, and schedules for sample analysis; and
Name, address, and qualifications of persons who will review
analytical results and other pertinent data, and who will
perform technical evaluation of the process demonstration
effectiveness .
Subsection 5.2 of this section provides the demonstration test plan
format and describes the required contents of a Demonstration Test Plan . Ap-
pendix B sum~ariz~s and discusses applicable methods for monitoring and sam-
pling proces~ feed streams, effluent products, and emissions.
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-
st ration 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 checklist to aid the applicant in determin_ing 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,
29
r
i
Table 6. Format of Demonstration -Test Plans for Nonthermal
Destruction Systems
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.' Sampling and Monitoring Plan
VI ; Sampling and Analysis Procedures
VII. Monitoring Procedures
VIII. Data Reporting
IX. Miscellaneous Tests
X. Waste Handling and Disposal
XI. Test Schedule
XII. QA Plan (addenda to Permit QA Plan)
XIII. Standard Operating Procedures (addenda to Permit SOP)
30
"(PRELIMINARY) DEMONSTRATION TEST PLAN
PCB DESTRUCTION UNIT
[Type and location]
[Te§t 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
401 M Street S.W.
Washington, DC 20460
Figure 6. ·Cover for the Demonstration Test Plan.
31
'provide a cover ,for each .volume and number each volume in the upper right hand
corner, "Volume .m ofll."
5.2.2 Section I -Summary
The applicant should begin the plan with a sho·rt 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 al~o is
useful (e.g; type of unit, intended l!Se, summa.ry of previous tests or opera-
tions).
5.2.3 Section II -Project Organization
-Provide an organizational chart and narrative 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 authority/responsibility
for the project. It is not necessary to repeat detailed information on overall
project authority/responsibility that has previously been submitted in the
permit application. However, a consolidated organizational chart is generally
advisable so that lines of authority can be identified. Key areas of responsi-
bility which should be identified 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; and ·
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 ~ith·the Demonstration Test Plan.
5.2.4 Section 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 modifications
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.
32
. .
, I
5.2.5 Section IV -Process 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;
Antjcipated 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~(~ detailed schedule of events. In the opetational plan explain
the operating parameters which will be maintained while 6ringing the ~nit on-
line, while conducting the demonstration, and while taking the unit off-line.
For example, will a non-PCB "waste feed" first be used to demonstrate 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 a chemical dechlorination process. 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, and composition including antic-
ipated PCB concentration. State the total quantity of feed to be used during
the demonstration. Explain how the waste feed used for the demonstration com-
pares to the waste which will normally be processed during routine operation;
i.e., the same, worst case condition, or mixture of anticipated wastes . Ex-
plain the provisions established for storage of the wast~s 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 detailed and specific to the demonstration.
The plan should address all sampling and monitoring 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 plan should include the following
elements:
A description of the system or process being sampled or moni-
tored (including sampling location) and breakdown of the pro-
cess into discrete sampling units, liquid waste, product, etc.).
The number of tests to .be conducted and the schedule. Gener-
ally, three tests have been conducted on successive days for
incinerators: For batch-type operations, a minimum of three
batches generally is processed.
33
Table 7. Example Summary of Anticipated Test Parameters
for a 8atch Chemical Dechlorination Process
Parameter
Waste feed
Waste feed rate {kg/batch)
Waste feed rati (gal./b~tch)
.PCB concentration in feed (mg/kg)
Total ~hlorine in feed (mg/kg)
PCB feed rate (kg/batch)
.Chlorine feed rate (kg/batch)
Destruction conditions
Batch residence time (h)
Reactor temperature (°C)
Reactor pressure (mm Hg}
Emissions
Final PCB concentration (µg/g/peak}
Pollution control
Not applicable
PCB content of waste products
Water (mg/L/peak)
Filter (µg/g/peak)
Sludge (µgig/peak)
~Required by regulation or 0TS policy.
NA (not applicable)
Anticipated
value
. 1,000
275
5,000
3,500
5
3.5
2
40
800
< 2
0.005
< 2
< 2
34
Control
limits
850-1100
250-300
NA
NA
NA
NA
< 12
35-45
760-880
< 2
< 2
< 2
< 2
Requireda
value
NAb
NA NA .
NA
NA
NA
NA
NA
NA
< 2
< 2
< 2
< 2
•
The objective of the sampling or monitoring for each unit (e.g.,
collect a "representative" sample; follow an EPA test protocol;
or collect a "worst case" sample).
The parameters to be tested: List the compounds, physical
measurements and media.
The sampling or monitoring methods: List the methods to be
.used. Detailed descriptfon of the methods may be -presented in
this section or an ~ppendix.
Trie sample analysis method: List the analytical methods to be
used. Detailed description of the methods may be presented in
this section or an appendix.
The sampling or monitoring design for each unit. This may re-
quire a .mathematical sampling design or simply a reference to
a standard protocol. 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 9reater, 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 L for water).
An estimate of sample representativeness. This 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 accord-
ing to the plan (e.g., alternative sites or times, an entirely
new sampling plan, or repeat tests).
The parameters which typically should be included in the sampling/
monitoring pl ari are discussed below.
· The applicant must propose a set of sampling/monitoring parameters
to verify that PCB destruction is equivalent to disposal in §761.70 inciner-.
ators. At a minimum this will include measurement of PCBs in the final prod-
uct and effluent streams (wastewater, filters, vent gas, etc.). In many cases
for alternative methods of PCB destruction, destruction equivalent to a
§761.70 incinerator has been defined as a measured effluent stream concentra-
tion of not greater than 2 µgig/resolvable chromatographic peak. The other
monitoring sampling parameters will depend upon the process design and the
type of waste feed/effluent streams. · Process operating parameters (e.g. ,
feed rate, reaction temperature and pressure) must be monitored. The appli-
cant should include all applicable operating parameters in the sampling/
monitoring plan. If applicable, pollution control system operating parameters
should be included in the sampling/monitoring plan. ·
35
For physical separation processes· where PCBs are concentrated into
a fraction for subsequent destruction by an approved method, the applicant
must propose a set of sampling/monitoring parameters to verify that (a) the
residual 11 clean11 fraction contains~ 2 µg/g (ppm) total PCBs, (b) no PCBs are
emitted from the system through drains, vents, etc ., and (c) the process does
not present an unreasonable risk of injury to health or the environment. Pro-
cess operating parameters (e.g., feed rate, reaction temperature and pressure)
must pe monitored. The applicant should include all applicable ope·rating
parameters in the sampling/monitoring plan. If applicable, pollution control
system op~rating parameters should be included in the .sampling/monitoring plan.
The agency may require applicants to amend the sampling and ·monitor-·
ing list. The paramete·rs which may be requ-ired include, but a·re not limited
to, PCDDs, PCDFs, and other chlorinated organics.
5.2.7 Section VI Sampling and Analysis Procedures
Specific details of any sampling and analysis procedures which will
be used during the demonstration test but were not previously addressed in
the permit application must be included in the Demonstration Test Plan. This
section should review the methods previously given in the corresponding sec-
tion of the permit application and any additional details or new information
~t the time of the demonstration test.
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 u~ed for .PCB d~struction systems are presented in Appendix B to this
report.
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 ~eporting units should be presented. Include information for process data;
pollution control system operation (if applicable); and the PCB concentrations
for the waste feed, effluent waste, and product streams.
36
Al 1 chemical analytical values -must be reported as concentrations,·.
expressed as:
Micrograms per liter for water; and
·Micrograms per gram for nonaqueous liquids or solids.
PCB values in waste feed are to be reported as 11 total PCB 11 (a sum
of all 209 congeners). A breakdown of the total PCB value by homolog or con-
gener may be us~ful for certain destruction tests. PCB values in product oil,
liquid waste,~soiid waste,_ and other streams must be reporte~ in microg~ams
per gram (µ.g/g) per resolvable chromatographic peak. In many cases for al t er-
. native methods of PCB destruction; destruct ion equivalence to a Sect i_on 761. 70
incinerator has been defined as a measured effluent stream concentratfon of
not greater than 2 µgig/resolvable chromatographic peak. If this or some
other maximum allowable concentration of the ~ffluent stream(s) is used to
demonstrate equivalency, measured values less than the allowable limit may
not'need to be reported (i .e., it is acceptable to report results as ''less
than 2 µg/g/peak11·). The analytical results may not be reported in terms of
Aroclor (or other mixture) concentrations, even if ~n Aroclor is used to cali-
brate the instrument (as in the waste feed) unless EPA gives prior approval .
5.2.10 Section IX -Miscellaneous 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 :
below).
Waste feed cut-off system;
Alarm systems (e.g., high temperature); and
Fire extinguisher system.
These tests must be included on the schedule (see Section 5.2.12
5.2.11 Section X ~ Wast~ Handling and Disposal
The demonstration ·test plan must identify any by-product wastes
(both PCB and non-PCB) that will be generated and how the wastes will be dis-
pose.ct, e.g., in-line filters for the PCB waste feed line.
5.2.12 Section XI -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 8 i.s an example demonstration test
schedule. The schedule should be realistic iri the sense of including suffi~
cient time to address problems which can be expected to occur in operating a
new process.
37
Day
0
1
2
3
Table 8. Example: 'Proposed 1Schedule for Demonstration
Tentative
date
xx/yy/zz
Activity
AM • Inventory waste feeq
AM/PM .• · Begin system shakedown using
non-PCB feed
AM/PM • Destruction test no. 1
AM/PM • Destruction test no. 2
AM/PM • Destruction test no. 3
38
• Test of emergency systems
• Shut unit down at comple-
tion of test according to
to closure plan
5.2.~3 Section XII -Quality 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 Pian. Those portions of the QA pl an
which apply to normal operations and those which apply only to the d~monstra-
tion test must 'be _ clearly ident"ified. In any event, the QA plan, with ~ddenda,
must address all measurement parameters (e.g., destruction vessel temperature ,
distillatidn .column temperature) not merely PCB sa~pling and analyits. · . . .
··The QA plan must confbrm to the specifications established i~ 11 In-
terim Guideline and Specifications for Preparing Quality Assurance Project
Plans 11 (USEPA, 1980). A QA plan prepared according to these specifications
wil) 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 preparatiorfof QA project plans is available in
11 Quality Assurance Program Plan for the Office of Toxic Substances11 (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 samples, whichever is greater, must be QC controls; and a
minimum of 10% or 2 of the samples, whichever is greater, must be QC blanks.
5.2.14 Section XIII -Standard Operating Procedures
Provide any addenda to the standard operating procedures which were
submitted with the permit application, if. necessary. !
39
· 6·. 0 CONDUCTING A DEMONSTRATION T£ST
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 notification of the
demonstration to other appropriate authorities (e.g., Regional Administrator),
PCB-containing ·rnaterial(s) to be treated, sampling, analysis, waste disposal,
QA, ~ite security, record keeping, ·and reporting requirements. A copy of the .
demonstrati-0n p~rmit must be on site and ad~ered to during the demonstration ..
. If iny modifications to the test plan are required pri-0r to the
demonstration test, the Agency (permit writer) should be notified in writing
withi.n 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 docum~nted in writing to
the Agency· (p~rmit 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. 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
demon~tration (see Section 3.2).
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, etc.) to prevent contamination from pre-
vious tests or other use.
The test should· be cond~cted under conditions simulating normal op-
~ratioris. Permit requirements usually reflect the operating conditions dur-
ing the demonstration test. Therefore,_the applicant should give very careful
consideration to the design and conduct of the demonstration test. Each demon-
stration-usually consists of the following three steps:
6.1 Start-up
The facility is prepared for operation with no PCBs in the system.
Conditions should be noted and samples collected to characterize background
conditions if appropriate.
6.2 PCB Waste Destruction
The PCB waste is introduced into the facility at expected normal
feed rates and expected maximum PCB ~oncentrations. During the test, samples
should be collected and records kept of the readings of process monitors,
40
.gauges, and meters. Visual observation of the effluent should also be made,
where appropriate. The number and the length of individual test runs required
depends on the process. For example, the demonstration test for a batch type
destruction process might consist of test runs on three batches. For.a con-
tinuous distillation process, the demonstration test might consist of 8 h of
continuous operation with samples of the final product stream taken at 2-h
intervals and a sample of the final product batch taken .at the end of the test.
6.3 Shutdown
Waste feed is terminated and the facility is.then shut down per
normal procedures or kept running on non-PCB feed -at the.discreti~n of the
operator.
41
-7.0 DEMONSTRATION TEST REPQ,RT
After the demonstration test has been performed, a report of the
results must be prepar.ed-·and submitted to the DD/EEO. The format and the re-
qui red contents of the ·t~t report are presented in this section: _,, ·-
7.1 Format and Contents
Table· 9 presents the format for the demonstration test report .. The
following paragraphs briefly describe the report contents. The test report
must contain all of the required is:iformation as described in this ·document.
7.1.1 Demoristration Test Report Cover
Figure 7 is the specified format for the report cover. If the re-
'port or the appendices must be bound separately, number each part of the sub-
mission in order (Volume m of n). The covers of each volume should have the
full cover information as-described above.
7.1.2 Certification Letter
This letter, signed by an authorized official, must certify on be-
. half of the applicant that th~ test was carried out in accordante with the
approved test plan and the results 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 10 is an example sum-
mary table for a chemical dechlorination demonstration test. A brief narra-
tive should summarize whether or not the facility met all performance require-
ments . Major problems encountered and major deviations from the test plan
should be mentioned.
7.1.4 S~ction II -Proc~ss Operation
7.1.4.1 ·General
Provid_e a general overview of the process using simplified
flow diagrams and a brief riarrative. 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
destruction test. Include physical characteristics of the feed, PCB content
of the feed, feed rates, total feed quantity, temperatures, pressures, ef-
fluent stream flow rates and volumes, and pollution control system operating
parameters (if applicable).
42
•
Table 9. Format for the Demonstration Test Report
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
VI I. Visits and Audi ts
VII I. Closure
IX. . Waste Disposal Manifests
Appendices
43
DEMONSTRATION TEST PLAN
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
401 M Street S.W.
Washington, DC 20460
Figure 7. Demonstration Test Report cover.
44
•
Table 10. Example Demonstration Test Results Summary for
a Batch Chemical Dechlorination Process
Date
Time test begun
.Time test ended
Operating parameters:
Waste feed rate (kg/h)
Batch volumes waste feed (kg)
'Batch volumes waste feed (gal.)
PCB concentration in feed (g/kg)
PCB feed (kg)
Reaction start time (24-h clock)
Reaction end time (24-h clock)
Reaction time (h)
Final batch size (kg)
Final batch ~iie (gal.)
Average'reactor temperature (°C)
Average reactor pressure (mm Hg)
Sampling/Analysis Results
Final PCB concentration of product
(µg/g/peak)
PCB concentration of wastewater
(mg/L/peak)
PCB concentration of filters
(µg/g peak)
PCB concentration of sludge
(µg/g/peak)
45
Test
1
Test
2
Test
3
A tabular format with explanatory ·narrative~·as -necessary, is preferred.· De-
tailed data such as tables of 15-min temperature readings and the process
operator's log, should be relegated to an appendix.
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.
These deviatiori's shou_ld have been previously reported to the permit writer,
verbally during the test and as ·a separate wri~ten ·incident report _witbin 14
days · of the· i nci den_t. These irici den_t reports should be presented in an ~p-
pendix. This section should summarize the incidents, discuss their effect on
the test results, and discuss their effect on the overall ability of the sys-
tem 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-
sis. The purpose or reasons for these types of changes should be explained
in this section.
7.1.·5 .Section III -Sampling and Monitoring Procedures
Describe the sampling and monitoring 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 results discussed.
7.1.6 Section IV -Analytical Procedures
Describe the analytical procedures used for each p.arameter (e.g.,
PCBs in water). Standard 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 all pertinent parameters such as:
Influent and effluent stream analyses;
Analyses of filters, wastewater, and other by-products; and
System performance results.
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.
46
..
Identify and discuss any anomalies in the system operation, sampling,
monitoring, or analyses that may have significant impact on the test results.
Raw data and the raw analytical results (e.g., chromatograms, mass
meas~rements) also should be presented in the appendices .
7.1.8 Section VI -Quality Assurance Summary
Summ~rize 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 pre'sented, authored and signed by the QA officer. The QA report
should address all the QA objectives, including whether or not precisfon 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 ~uring 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
vi sits 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.
7.1.10 Section VITI -Closure
The applicant should summarize the facility closure after the demon··
stration. Any deviations from the closure plan should be discussed. Appli-
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 landfi l l restrictions can be d~monstrated.
7.1.11 Section IX -Waste Hahdljng and Disposal .
The demonstration test report should provide documentation that all
wastes generated during the demonstration test were properly disposed in ac-
cordance with TSCA and RCRA . Manifests should be included in the test report,
when applicable.
7.1.12 Appendices
Supporting information (e.g., detailed procedures, analytical re-
sults, sample calculations, QA report) should be presented in the appendices.
Include the chronological demonstr.ation test events log and any incident re-
ports.
47
1 t J
7.2 Review
The permit writer will review the report 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 deter-
mination that the process operates within all of the pertinent requirements.
of 40 CFR .7µ1 and .the.conditions of the demonstration permit, the DD/EED shall
issue a final permit to operate commercially. The operating permit will con-
tain certain condition~, including matrices to be treated, maiimum PCB con-
centrations to be treated, waste disposal, site security, recordkeeping, re-
porting, and closure requirements. A permit will normally be issued for up
to 3 years 1 operation. A copy of this approval should be on site and adhered
to during all operations.
48
8.0 REFERENCES
Neulicht, R. M., R. V. Shah, G. Kelso, B. L. Carson, and M. D. Erickson,
"Guidelines for Permit Applications and Demonstration Test Plans for PCB
Incinerators," Draft Interim Report No. 1, Revision No. 3, MRI Project No.
8501-A(06), EPA Contract No. 68-02-3938 (May 28, 1986).
U.S. Environmental Protection Agency, "Polychlorinated Biphenyls (PCBs) Manu-
facturing, Processing, Distribution in Commerce, and Use Prohibitions," Fed-
eral .Register, 44, 31514-31568 (May 31, 1979).
u:s. Enviro,nmental Protection Agency, "Guidelines and Specifications for Pre-
paring Quality Assurance Project Plans,11 Office of Monitoring Systems and ·
Quality Assurance, QAMS-005/80, December 27, 1980.
U.S. lnvironmental Protection Agency, 40 CFR Part 761, "Procedural Amendment
of the Approval Authority for PCB Disposal Facilities and Guidance for Obtain-
ing Approval, 11 Federal Register, 48, 13181-13186 (1983a).
U.S. Environmental Protection 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, 1985, Code of Federal Regulations,
Title 40, Part 761 (40 CFR 761), 11 Polychlorinated Biphenyls (PCBs) Manufac-
turing, Processing, Distribution in Commerce, and Use Prohibitions,11 Revised .
as of July 1, 1985 .
Weller, P. J ., J. Andis, and S. Baig, "Preliminary Study Regarding Alternative
Definitions of PCB Solid/Liquid Wastes," dated October 1981, Appendix Hin
R. G. Mclnnes and R. J. Johnson, "Provision of Technical Assistance to Support
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, !ERL, Research Triangle Park, NC,
1982, 186 pp.
49
~-~-··--Alr.. --' • i
APPENDIX A
CHECKLISTS FOR COMPLETENESS OF SUBMITTAL
50
' .
. APPENDIX A.,.l
PERMIT APPLICATION CHECKLIST FOR
NONTHERMAL DESTRUCTION SYSTEMS
, 1:. Permit Cover
2. Summary (Section I)
3. Project Organization (Section II)
'A. Chart
B. Text
4, Waste Description (Section III)
A. Type
B. Total Amount/Feed Rate
C. Phys i ca 1 /Chemi ca 1
Descri p_t ion
5. Process Engineering (Section IV)
A. General Overview
Descri'ption
· Flow Diagram
· Location
· Site Maps
B. Waste Feed System
C. Waste Feed Cut Off System
D. Destruction System
E. Pollution Control System
F. Process Operating Parameters
6. Sampling and Monitoring ·Plan
(Section V)
A. Sampling/Monitoring ·
Parameter List
(see attached supplemental
checklist)
To Be
Submitted
Submitted At Later Date 1
B. Sampling/Monitoring Frequency ___ _
C. Frequency/Number of Samples
(Sample Design)
D. Methods
· Sampling
Monitoring
· Analytical
E. Equipment
Sampling
· Monitoring
· Analytical
51
Not
Applicable
7. Sampling Procedures (Section VI)
A. Appropriate Methods
B. Written Protocols
C. Apparatus
D. Calibration
E. Maintenance
8~ Sample Analysis Procedures
(Section VII)
A. Appropriate Methods 8. Written Protocols
' C. Apparatus
D. Calibration
E. Data Reduction
F. Data Storage
G. Maintenance
9. Monitoring Procedures
(Section VIII)
A. Appropriate Methods
B. Written Protocols
C. Apparatus
D. Calibration
E. Data Reduction
F. Data Storage
G. Maintenance
10. Waste Handling and Disposal
A. List of All Wastes (type
and amounts)
B. Disposal Methods
.11. Data Reporting/Recordkeeping
(Section IX)
A. Format
B. fxampl~ Calculations
C. Units
12. Inspection Procedures (Section X)
A. Waste Feed System
B. Destruction Feed System
C. Waste Feed Cut-Off System
D. Pollution Control System
E. Alarms
F. Fire Extinguisher Systems
To Be
Submitted ·
Submitted At Later Oate1
52
Not
Applicable
.. 13. Spill Prevention Control and
Countermeasures Plan
(Section XII)
14.
15.
16.
17.
18.
19.
20.
. . .
Safety Pl~n (Section XIII)
Train~ng Plan (Section XIV)
Demonstration Test Plan
(Section XV)
A. Tentative Date
·B .. Tentative Location
, C. Parameters to be Tested
· D. Type Waste
Test Data or Engineering
Performance Calculations
(Section XVI)
A. Previous Test Results
B. Engineering Calculations
Other Permits or Approvals
(Section XVII)
A. Regional R&D
B. Regional Full-Scale
C. RCRA
D. State or Local
E. DOT
F. Other
Schedule (Section XVIII)
Quality Assurance Plan
·(section XIX)
A. Format
B. Organization and
Responsibility
C. QA Objectives
1. Precision
2. Accuracy
3. Completeness
4. Representativeness
5. Comparability
D. Monitoring Proced~res
E. Sampling Procedures
To Be
Submitted
Submitted At Later Date 1
53
·Not
Applicable
,
F. Analytical Pi:ocedures
G. Sample Custody -
H. Calibration Procedures
and Frequency
I. Data Reduction, Validation
. and Reporting .
J. Internal Quality Control
· Checks ·
K .. Audits
1. Performance
2. System
L. Preventive Maintenance
M. Specific Routine Procedures
Used to Assess Data
Precision Accuracy and
. Completeness
N. Corrective Action
0. Quality Assurance Reports
to Management
21. Operational Plan (Section XX)
22. Closure Plan (Section XXI)
A. Site-to-Site
B. Permanent
C. Routine Waste Disposal
To Be
Submitted
Submitted At Later Date1
Not
Applicable
1 Section of the permit should be reserved for revised submittal and the
deficiency should be noted in the application.
54
APPENDIX A-2
CHECKLIST FOR NONTHERMAL DESTRUCTION
SYSTEM DEMONSTRATION TEST PLAN
1: Test Plan Cover
2. Summary (Section I)
3. Project Organization (Section II)
'A. Key Personnel Identified
B. Organization thart
4. Process Engineering Information
(Section III; new information
from Permit Applications)
5. Process Operation Test
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 Monitored 2
C. Parameters to be Sampled2
-D . Sampling/Monitoring Locations
E. Numb~r/Frequency of Samples
F ·. s·amp l i ng Methods
G. Monitoring Methods
H. Analysis Method
7. Sampling/Analysis Procedures2
(Section VI)
A. Methods
B. Written Protocol
C. Equipment
D. Calibration
To Be
Submitted
Submitted At Later Date 1
----
55
Not
Applicable
8. Monitoring Procedures2
(Section Vil)
A. Written Protocol
B. Equipment
C. Calibration
9. Data .Reportihg (Section VIIIj
A. Data to be Reported, Units
B. · Example Calculations
10. Miscellaneous Tests (Section IX)
'A. Waste Feed Cut-Off
' B. Alarm Systems
C. Fire System
11. Waste ·Handling and Disposal
(Section X)
12. Test Schedule (Section XI)
13. Addenda to QA Plan (Section XII)
14. Addenda to Standard Operating
Procedures (Section XIII)
To Be
.Submitted
Submitted At Later Date1
Not
Applicable
1 Section of the permit should be reserved for revised submittal and the
deficiency should be noted in the application.
2 See supplemental checklist.
56
SAMPLING AND MONITORING PARAMETER SUPPLEMENT FOR NONTHERMAL PCB DESTRUCTION PROCESSES
C:
Cl .,..
Ill
QI QI -C Cl z >, ........ u l'O
Cl $.. . ~ C: -QI
>, ·c: 0 u .,.. "C +J ::::, C: ,-0 V') -~ er
QI QI
QI C. .c ........ 0 ::::, E +J c u
$.. $.. "C
0 'LA... QI
er l'O a, ·0 0 a, V') :E: .,.. +J
+J ,-$.. ........ +J C: a, . 0 .,.. . Cl C. i.. Cl ,... u 0 u $..
C: C: E C: Ill l'O ::::, .,.. C: Q.
0 .,.. l'O Cl .,.. ::::, u "C +J l'O :::E: $.. V') C: $.. +J .,.. a, l'O C: C:
0 .,.. ·o "C l'O +J . c::: $.. a, QI
QI +J QI a:> .,.. a:>
,-+J 0 $.. >, .:J +J +J
0. .,.. ~ l'O ,-l'O .,.. C: +J
C: E C: +J 0. l'O +J ,-.,.. .,..
0 0 0
I-:::E: I-
l'O 0 a, 0. C: l'O l'O l'O $..
V') .. :E: :E: <C <C C u :::E: ~
a. PCBs in ' Waste Feed
b. Feed Composition -c. Waste Feed Rate
. d. Reagent Feed Rate
e. Reaction Temperature
f. Reaction Pressure
g. pH of Product
h. Residual Reagent in Product
i. PCB Concentration in Product
j. PCBs in Aqueous Effluents -
k. PCBs in Other Wastes
l . PCBs in Ai r Emissions
m. Pollution Cont~ol System
Operation
n. Other
57
•
· APPENDIX B
SAMPLING AND ANALYSIS PROCEDURES
58
•
This appendix reviews methods of sampling and analysis of PCBs in
feed materials and final products or effluents. Analytical methods for PCBs
have been reviewed (Erickson and Stanley 1982; Erickson et al. 1985b; ·
Erickson 1986).
1.0 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 ~nd
is often the_ weakest portion of an ·application. The _ applicant and permit" re-
viewer m~st work together to develop a detailed s~mplihg plan which will pr6-
. duce the · desired information. In some cases, a II typi ca·111 sample may" be de-
sired, while in others a 11worst 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 iQ which the destruction test is generally held. The·sam-
pl_ing plan must reflect the realities of the destruction unit and make every
attempt to meet the stated objectives. The plan should propose alternatives
to the optimum samples. In cases where a sampling plan is compromised, the
demonstration test report should present an explanation.
Several examples of approaches (not full sampling plans) to sam-
~ling situations are presented below.
1. A chemical de~hlorination system is to be demonstrated. The
batch process vessel is to be filled from numerous drams. The process vessel
is filled and the mixer activated. Thirty minutes after mixi~g, a sample is
drawn from the vessel tap; a second sample is drawn 10 min later.
2. 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. ·
3. The plan stipulates that if a bung on a drum ·i s frozen, the sam-
pl er 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
wi ih similar markings) are all frozen, the rep~esentativeness of the sampling
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 frozen bungs or cutting a new hole in the drum.
2.0 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 "Sampling and Analysis Methods for Hazardous Waste Combustion" (USEPA 1983).
59
2.1 Liquids
Liquids may be co 11 ected by grab or integrative techniques. Grab
sampling may include tilling a jar. from a spigot or dipper collection of
water from a 1 a goon. -·}req'uency of samp 1 i ng and amount to be co 11,ected 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.
Additional guidance is av.ailable (Berg 1982).
2.·2 Solids
Solid sampling techniques vary 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.
I
2.3 Mixed Phase Samples
Mixed phase samples represent a challenge to the sample collector.
In tanks and other static systems, a phase separation during sampling is pre-
ferable, provided that the total volume or weight of each phase is 'measured.
Phases collected separately must be analyzed separately. Propo~tions of each
phase in the system (e.g., a holding tank) shall be measured volumetrically.
Examples including skimming solids off liquids and drawing off oil and water
layers from a tank. Where phase separation is impractical, such as a sus-
pended solid, the whole must be mixed to assure that the sample is representa-
tive. 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 ~robably contain more PCBs than the water and
would represent a maximum (worst case for waste, best case for feed). The
representativeness or lack thereof should be noted.
3.0 SAMPLE ANALYSIS
For many alternative technologies, the PCB content of the feed,
product, and -waste samples must be determined. This section addresses the
analysis of these matrices for PCBs. As discussed elsewhere in this document,
EPA may require additional analyses to demonstrate that an alternative tech--
nology is equivalent to incineration. The applicant is responsible for pre-
senting detailed methods for these matrices, other matrices, or non-PCB analy-
ses, as required.
OTS does not specify analytical ·methods for PCBs; however, this
section presents certain guidelines on methods which OTS has reason to believe
will 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 proposed methods meet the
OTS data quality objectives (e.g., analysis for all PCBs in samples with de-
tection limits adequate to meet permit requirements). Applicants should re-
view these guidelines and propose complete, specific ~ethods in their test
60
•
plan. Many methods, including some of -those. discussed in this section,
present one or more optionJ to the analyst. The applicant must state which
option is to be used. If selection 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 far commonly found in the feed material generally contain
from 20 to 80 of these 209 PCB congeners: In most cases for final product or
effluent samples, however, it can be anticipated that the PCB pattern will be
qualitatively different from that ·in· the feed, unles~ the PCBs were trans-
mttted through the system without any chemical alteration by the destruction
process. For final product or ·effluent samples, the analytical method must .
identify and quantitate all of the PCBs present in each sample, not just the
Aroc,or present in the feed.
' 3.1 Feed Materials
As lorig as the feed material contains PCBs which qualitatively re-
semble one of the commercial mixtures, such as the ·Aroclors, the traditional
analytical methods which use Aroclor mixtures for GC calibration are accep-
table. These methods are discussed below.
If the PCB composition in the feed material does not resemble a
commercial mixture, the samples . should be analyzed using the methods recom-
mended for the final product and effluent samples, as discussed below.
3.1.1 _Oils
The EPA procedure for analysis of PCBs in transformer oils and waste
oils (USEPA 1981, Bellar and Lichtenberg 1981) provides a generalized approach
with respect to sample preparation and instrumental analysis. Several cleanup
techniques are provided as optional approaches in this procedure. For the
iristrumental analysis, GC with halogen specific, electron capture, or mass
spectrometry 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 precisior1 records, and instrumental and chromatographic perfor-
ma nce · cri"ter,a is required to support all data generated by the method.·
The ASTM (1983) D4059-83 procedure for mineral insulating oils
utilizes solvent dilution and a Florisil slurry cleanup prior to PGC/ECD de-
te rmination. The _procedure assumes that the composition of the PCBs present
in transformer or capacitor oils closely resembles that of the Aroclor stan-
da rds. 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 .
61
3.1.2 Soils, Sludges, and Solid Wastes.
A variety of standard methods are available for these matrices.
Several EPA methods utilize dichloromethane extraction, followed by
cleanup and GC determination with different detectors. Soil and other solid
wastes may be analyzed by EPA's SW-846 methods (USEPA 1984a). Method 8080 is
the packed column GC/ECD method; 8250 is the· packed column GC/EIMS method;
and 8270 is th.e capi 11 ary column GC/EIMS meth.od. A 11 three methods 'have a •
stated 1 imit .of detection of 1 µg/g . · Some options are presented in these
methods an.d the quant i tat ion procedure is not we 11-def i ned for PCBs; therefore,
applicants 'must supply additional details on the planned analysis. · ·
. .
The sludge method EPA 625-S (Haile and Lopez-Avila 1984) gives op-
tional' Florisil, silica gel, and GPC cleanups and stipulates electron imp·act
mass ·spectrometry as the GC detector. Quantitation is by total areas compared
to total areas of Aroclor standards.
ASTM Method D3304-74 (ASTM 1981b) utilizes a hexarie/water/acetonitrile
extraction ·for soil samples . Several optional cleanups are presented. Samples
are analyzed by packed column GC/ECD and quantitated using the total areas of
Aroclor standards .
3.1.3 Capacitors and Other. Solids
No standard methods exist specifically for these matrices .. The
sample should be physically prepared by shredding or grinding and then ex-
tracted with an appropriate solvent (e.g., benzene or hexane), preferably with
a Soxhlet apparatus over multiple cycles. Cleanup and analysis can then fol-
low one of the methods given above .
3.2 Final Product or Effluent Samples
3.2.1 Processes Which Do Not Change Aroclor Pattern
For processes which do not alter the PCB composition, such as sol-
vent cl~aning/distillation processes , the .methods listed above for feed sam-
ples can be adapted to the final product or effluent samples. With the lower
required detection 1•imits, additional blanks and other QC measures may be
appropriate.
3.2.2 Processes Which Alter the Aroclor Pattern
If the Aroclor pattern is significantly altered by the destruction
process, or if other PCBs (e .g., partially dechlorinated homologs) are ob-
served in the samples, then the traditional methods described above are not
appropriate. For these samples, the analytical method must identify and quan-
titate all of the PCBs present in the sample, not just the Aroclor present in
the feed.
62
3.2.2.l Oils and Other Nonvolatile Organic Liquids
The sample preparation procedures may follow those listed for
the feed samples, above. Samples may then be analyzed by an,,appropriate in-
strumental technique.
If the applicant chooses to use GC/ECD as the instrumental
method, a mixture of 10 PCB congeners (one each for the various degrees of
chlorination) may be used for -the calibration. This mixture was determined
by the Ory Color ·Manufacturers Association (DCMA) to give an average .ECO re-
sponse for .ea~h homolog (OCMA 1982). Instrumental an~lysis ~an · be -done ac-
~ordin9 to EPA Method 608 (USEPA 1984b) or ASTM (1983) D4059-83. To quanti-
tate the ··samples, the following protocol (Midwest Research Institute ·1985)
may be used:
a. OetEi!rmine the retention windows. Note: This is an arbi-
trary demarcation and results in misidentification of some congeners as
either a higher of lower homolog. However, ~ince the ECO cannot discriminate
by homologs, this is the best approach to partitioning the peaks.
(1) Record the retention time 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 window sufficiently ahead of the stan-
dard elution time (e.g., 0.1 min) to allow for retention time drift.
(3) The windows f6r 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.
b. Caiculate a linear regression curve for each homolog. The
m1n1mum 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 perform corrective action 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 samples,
only peaks equal to or greater than 1 µg/g need be reported. Those peaks much
less than this value do not need to be calculated. Where it appears that the
peaks wi 11 be be 1 ow the cutoff, ca 1 cul ate the area· counts necessary for 2 µg/g
and then visually compare these with the ·sample data. Thisr1shortcut 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 greater than 6r equal to 2 µg/g.
63
e. Automated quantitation routines , incorporating the above
principles may be substituted.
An EPA method for by-product PCBs in commercial products and
product wastes (Erickson et al. 1982; 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.
~.2.2.2 Vol~tile Organic Liquids
No specific standard. procedures are recommended for the~e
matrices. If the matrix is compatible with the analytical method (e.g., a
hydrocarbon an·d GC/ECD), direct injection or evaporative concentration may be
sufficient. If the matrix is not compatible with the analytical method (e.g.,
· a chlorofluorocarbon and GC/ECD), then a solvent-exchange must be conducted
-(MRI ·1985). A higher boiling hydrocarbon 11 keeper11 should be added, sp that
the' sample · is not evaporated to dryness. The sample analysis by GC/ECD or
GC/MS can follow that given in Section 3.2.2.1, above.
3.2.2.3 Dissolvable Solids (Process Waste, Sludge, etc.)
For samples which readily dissolve in organic solvents such as
hexane, benz~ne, or methanol/hexane, a weighed aliquot can be dissolved to a
known concentration, mixed thoroughly (MRI 1985), and then either analyzed
directly, or cleaned up as an oil •sample (see Section 3.2.2.1). The sample
analysis by GC/ECD or GC/MS can follow that given in Section 3.2.2.1, above.
-3.2.2.4 Insoluble Granular Solids (Soils, Ash, and Non-Bulk
Solid Wastes, etc.)
The sample preparation for soils, sludges, and solid wastes ·
can follow that in Section 3.1.2 above. No specific published method is
available for analysis of ash samples using the DCMA quantitation mixture.
Sample preparation (extraction, cleanup, etc.) can be done according to EPA's
SW-846 (USEPA 1984a) or the EPA by-product method (Erickson 1984b; Erickson
et al. 1985a). The sample analysis by GC/ECD or GC/MS can folJow that given
·in Section 3.2.2.1 above. · ·
3.2.2.5 Insoluble Bulk Solids
No standard methods exist specifically for filter media and
other bulk solids .. The entire sample should be extracted with an appropriate
solvent, preferably with a Soxhlet apparatus over multiple cycles. It is
important that the entire sample be extracted since the PCB content is most
likely not homogeneous and, thus, a subsample would probably not be represen-
tative. The choice of extraction solvent depends on the nature of the sample.
If the sample is heavily water-laden or hydrophilic, the ¥flvent should wet.
the surface (e.g., mixed hexane/acetone or hexane/water/acetonitrile). If
the sample is hydrophobic, then extraction with a nonpolar solvent such as
hexane or benzene may be appropriate. The sample analysis by GC/ECD or GC/MS
can fol~ow that given in Section 3.2.2.1 above. ·
64
r .
-3.2.2.6 Aqueous Samples
Scrubber water and other aqueous samples can be analyzed by
EPA Method 608 (USEPA 1984b) or ~25 (USEPA 1984c) or ASTM method 03534-80
(ASTM 1981a) only if the Aroclor pattern remains intact after the incineration.
If the Aroclor pattern is significantly altered by the-destruc-
tion 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 1984a) may be
used with GC/MS ·as the instrumental method. This method presents several' op-
tions, so permit applicants must stipulate which _optidns are to ·be used.
If the applicant chooses to use GC/ECO as the instrumental
method, the DCMA (1982) quantitation discussed above may be used. No specific
published method is avail~ble for analysis of ash samples using the DCMA quan-
ti t ation mixture. Sample preparation (extraction, cleanup, etc.) can be done
according to EPA Method 608 (USEPA 1984b) or 625 (USEPA 1984c) or the EPA by-
product method (Erick~on 1984b). Instrumental analysis can be done according
to EPA Method 608 (USEPA 1984b). To quantitate the samples, the protocol pre-
sen.ted in Section 3.2.2.1 may be used. ·
4. 0 REFERENCES
American Society for Testing and Materials. 11 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. 11 Standard Method f9r Analysis of
Environmental Materials for Polychlorinated Biphenyls, ANSI/ASTM D 3304-77,11
in Annual Book of ASTM Standards Part 31, Philadelphia, Pennsylvania (1981b),
pp. 877-885 .
American Society for Testing and Materials, "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.
Bellar, T. A., and J. J. Lichtenberg, "The '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., "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.
Dry Color Manufacturers Association, "An Analytical Procedure for the Deter-
mi nation of Polychlorinated Biphenyls in Ory Phthalocyanine Blue, Phthalo-
cyanine Green, and Diarylide Yellow Pigments," Arlington, Virginia (1982).
65
Erickson, M. 0., "Analytical1 Method: The Analysis of By-Product Chlorinated
Biphenyls in Water, Revision 2,11 U.S. Environmental Protection Agency, Office
of Toxic Substances, Washington, O.C., EPA 560/5-85-012 (1984a).
,
Erickson, M. 0., "Ana1ytital Method: The Analysis of By-Product C.hlorinated
Biphenyls in Commercial e_roducts and Product Wastes, Revision 2/1• U.S. Environ-
mental Protection Agency, Office of Toxic Substances, Washington~ DC, EPA
.560/5-85-010 (1984b).
Erickson, M. 0., "Analytical Chemistry of PCBs,11 Boston: Butterworth Pub".'
lishers· (i9B6). · · ·
·Erickson; M. 0., and J; S. Stanley, "Methods of Analysis for By-Product PCBs--
Literature Review and Preliminary Recommendations," Interim Report No. 1, Of-
fice of Toxic Substances, U.S. Environment~l Protection Agency, Washington,
D.C.; EPA-560/5-82-005, October 1982, 135 pp.
I
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.· Environmental Protection Agency, Office of Toxic Substances, Washington,
D.C., EPA-560/5-85-023 (February 1985a).
Erickson, M. 0., J. S. Stanley, J. K. Turman, J. E. Going, D: P. Redford, and
D. T. Heggem, "Determination of By-Product PCBs in Commerci"al Products and
Wastes by Hi~h Resolution GC/EIMS,11 Environ. Sci. Technol. (submitted) (1985b).
Haile, C. L., and V. Lopez-Avila, "Development of Analytical Test Procedures
for the Measurement of Organic Priority Po 11 utants--Project Summary, 11 U.S.
Environmental Protection Agency, Environmental Monitoring and Support Labora-
.tory, Cincinnati, Ohio, EPA-600/S4-84-001; (Full Report available as NTIS No .
. PB .84~129 048) (1984). .
Midwest Re~earch Institute, "Operating Procedure -Analysis of Samples for
PCBs by GC/ECD, 11 EPA Contract No. 68-02-3938, MRI Project No. 8501-A6
(December 1985).
U.S. Environmental Protection Agency, 11Samp l ers 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,'' 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).
. 66
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 (Ap~il 1984a).
U.S. Environmental Protection Agency, "Organochlorine Pesticides and PCBs--
Method 608,11 Fed . Regist., 49(209), 89-104 (October 26, 1984b).
U.S. Environmental Protection Agency, "Base/Neutrals, Acids, and Pesticides--
Method 625,11 Fed. Regist ., 49(209), 153-174 (October 26, 1984c). ·
67
APPENDIX C
OTS GUIDANCE ON FREQUENTLY ASKED QUESTIONS
June 1986
68
'
·l
PREFACE
This Appendix presents answers to frequently asked _ questions ·related
to permitting of incinerator facilities. The an~wers represent OTS guidance,
as of June 1986.
69
Types of Processes Permitted
Question 1: How does OTS approve extraction and distillation type processes?
Answer: OTS will issue a permit -for the overall system and not for individ-
ual unit .operations. The system must be closed. All working fluids
must be labeled in accordance with the original concentration of the
treated material, t;1nless .shown to be of a lower concentration .. All
fluids, filters, wastes, and the system itself must be appropriately
marked before leaving the site, unless shown to be less than 2 ppm
per r~solvable chr6matographi~ peak in the PCB retention window.
· All fluids and PCB-containing materials should be tested before
leaving the site so that ·a formal accounting or mass balance of
PCBs is maintained. Records must be kept for any effluent streams.
The PCB-containing product materials (fluids, filters, etc.). must
be disposed of according to regulations (i.e., incinerated).
Specific examples include:
a. Processes which are authorized (as defined in Glossary of
Terms) according _to 40 CFR 761.30 are:
* Closed filtration units to remove PCBs from transformer
dielectric fluids; and
Extraction/distillation processes which remove PCBs from
transformer dielectric fluids if the dielectric is reused
in PCB-controlled equipment and the concentrated waste is
_disposed according to the regulations.
b. An extraction/distillation process which uses a solvent working
fluid to remove PCBs from transformers must incinerate all the
resulting material, or must label all the material as PCB-
containing in accordanc~ with the original concentration of the
fluid being treated, or must obtain a PCB destruction permit
· : requiring. the PCBs to be destroyed to below 2. ppm per re-
solvable chromatographic peak.
·c. Destruction systems with an ancillary extraction/distillation
process will be permitted as an entire unit and must treat the
PCB material to below 2 ppm per resolvable chromatographic peak.
Question 2: How should companies apply f6r disposal of more than one kind of
material by a single process?
Answer: Applicants must justify the applicability of the process to the dif~
ferent types of PCB materials. The justification must include a
documentation of the effectiveness of the process with the different
matrices. This may be limited to calculations showing the lack of
70
( .
matrix effect on PCB destruction efficiency or, preferably, would
include R&D results demonstrating the .process effectiveness. EPA
normally wi 11 require that a fie 1 d demonstration may be adequate
for each matrix.
Conditions Which May Be Included in Permits
Question 3:. What physical/chemical param~ters for matrices to be tested will
' be· specified for PCB fluids in PCB disposal permits issuect to
chemical destruction and other alternate methods of ~estruction
facilities.
Answer: In general, permits are issued only for the matrices demonstrated.
Permits will be issued according to the following scheme:
a. Mineral oil dielectric fluid (MODEF) -the qualifier 11 dielec-
tric fluid11 identifies a specific type of mineral oil. There-
fore, additional description within the permit is unnecessary.
b. Heat transfer fluid -the wide range of fluid types used in
heat transfer applications makes it necessary to specify,
within the permit, either the .particular brand name authorized
(i.e., Therminol 55) on a specific set of chemical and phys-
ical characteristics.
c. Hydraulic fluid -the material used in this capacity is suf-
ficiently similar that it will not be permitted by brand name.
Rather, the allowable bottom solids, water cont~nt (e.g., 10%)
or other physical or chemical ·properties will be specified.
d. Other -:-in this category are waste oi 1 s, • kerosene, etc.
Authorizations to dispose of these fluids will be written on
~n individual basis. Chemical analysis and category of appli-
cation will be the description criteria used for the permits.
Quesiion 4: Can le~s rigorous or less itri.ngent analytical -techniques be used
during commercial operation-of chemical processes than were used
during the proc~ss demonstration(s)?
Answer: No. For chemical treatment processes, the analytical technique
which will be used during commercial site operation is considered
integral to the process and therefore must be demonstrated on-site.
Quality assurance information for that technique must be provided
to support the application/demonstration plan.· Confirmatory testing
(i.e., by another laboratory) should be conducted to verify the re-
sults of field units. OTS reserves the right to spotcheck the ana-
lytical methodology and results. In order to meet th~ equivalency
requirement to incineration, the-additional burden of analyzing the
final concentration of each batch is deemed appropriate and neces-
•sary by OTS.
71
Question 5: ls !'blend-down" ·pf PCB fluids :authorized?.
Answer: Blending and/or spiking is allowed only for the purpose of achiev-
ing a particµlar treatment concentration during process demonstra-
tions. However/during commerdal operation no material which ex-
ceeds the concentration level demonstrated and authorized by the
permit, may be diluted or blended.
Question 6: How should process filters be disposed?
Answer:· ·For proiess .filters which uti.lize activated charcoal or macroretic-
alar resins (e;g .. , XAD-2}, the used and contaminated material must
be disposed 6f by EPA-approved incineration. Othei filter media
shall also be incinerated unless the PCB concentration of the fil-
ters, as determined by chemical analysis, is< 2 µgig/resolvable
chromatographic peak, in which case, the filters are not regulated.
The applicant must obtain approval for alternate disposal from OTS.
Question 7: What are the requirements for handling by-product wastes from
alternative technology processes?
Answer: Permits issued for alternative destruction processes generally will
require that all treated materials and by-product waste streams must
have PCB concentrations of less than 2 µgig/resolvable chromatographic
peak (ppm). If this condition is not met, the effluents containing
2 ppm or greater must be disposed as if they contained the PCB con-
centration of the original influent material.
Demonstration Test Protocol
Question 8: What are the testing requirements for dioxins and furans during
process demonstrations?
Answer : Chemical reaction systems which use sodium reduction will not b~
required to perform dioxin and furan analyses if operated below ap-
proximately 50-0°C. Systems which operate in excess of 500°C will
be evaluated on a case-by-case basis. Similarly, other alternate
destruction systems will be evaluated individually.
Question 9; Should all process effluents be analyzed?
Answer: If the PCB feed material being treated by the process is pver 500
ppm PCB, then the resulting effluents must be incinerated unless an
analysis is conducted and indicates that the PCB concentration is
below 2 ppm per PCB peak.
72
(
Question 10: Does OTS require testing of air emissions (e.g., PCBs or benzene)
-during chemical process -0emonst~ation tests? .
Answer: Any emissions (gaseous, liquid, or solid in nature) must comply with
all other relevant Federal, state, and local regulations. For chem-
ical treatment processes, OTS requires documentation verifying that
no air emission regulations are violated. OTS reserves the right
to require or conduct samp 1 i ng of any _gaseous effluent stream. Re-
sults of pr~-demonstration testing for air emissions will be re-
viewed by OTS, but not necessarily accepted in lieu of data acquired
during a demonstration test:
Question 11: How many batches must be treated during a chemical process demon-.
st ration?
Answer: For chemical treatment processes, a demonstration should include as
a minimum, three full-scale batches treated on separate days, or on
the same day •following system shutdown(s). At least two concentra-
tion levels should be tested. A replicate run at the highest con-
centration should be conducted. The higher concentration should be
approximately double the lower unless the applicant has reason to
use different concentrations.
Question 12: What PCB standards are recommended for analytical testing?
Answer: The PCB standard chosen depends on the PCB composition in the sam-
ples and the purpose of the data.
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 Aroclor or
combination of Aroclors. The standard concentrations must be
within the 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 miitu~es, the applicant must dem-
onstrate that all PCBs are being ~easured. The product oil
from a chemical treatment process and similar samples are in
.this category. For chemical destruction processes, all peaks
must be less than 2 ppm/resolvable chromatographic peak.
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).
73
. ,
.-. As with the Aroclor calibration, the standard concen~rations
·fllust 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 demonstr~te through use of
blanks, confirmatory techniques, or other methods that the
peak(s) in question is not a PCB.
Preparations-for a Demonstration
Question 13: 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
while on-site or leave the demonstration before it is completed.
Another demonstration cannot be rescheduled for a minimum period of
three months.
Question 14: 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 anaiyses 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 15: What criteria will be used to make an on-site determination to
discontinue a demonstration?
Answer:. For chemical treatment methods, an acceptable run must be completed
on the first day or EPA representatives will have sufficient cause
to leave. Two interruptions will be allowed during processing of
any batch. Additional interruptions automatically invalidate the
run' s results.
If the demonstration schedule is not adhered to, OTS will reserve
the right to rescind the permit while on-site or leave the demon-
stration before it is .completed. ·Another demonstration cannot be
rescheduled for a minimum period _ of three months.
74
: l
APPENDIX D
ADDRESSES FOR HEADQUARTERS AND REGIONAL OFFICES
75
Aqdresses follow for U.S. EPA Headquarters and Regions. Headquarters will
supply the names of Regional PCB Coordinators· upon request.
Headquarters
Di~ector of the Office of Toxic
Substances (TS-792)
Environmental Protection Agency
401 M Street, S._W.
Washington, O.C. 20460
Region 1 __
(Connecticut~ Maine, Massachusetts,
New Hampshire, Rhode Island, Vermont)
Regional Administrator
Envi~onmental Protection Agency
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Re ion 2 .
New Jersey, New York)
Regional Administrator
Environmental Protection Agency
26 Federal Plaza
New York, New York 10278
Region 3
(Delaware, District of Columbia,
Maryland, Pennsylvania, Virginia,
West Virginia)
Regional Administrator
Environmental Protection Agency
841 Chestnut Street
~hilade)phia, Pennsylvania 19107 .
Region 4
(Alabama, Florida, Georgia, Kentucky,
Mississippi, Nrirth Carolina, South
Carolina, Tennessee)
Regional Administrator
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
76
: (.
• Region 5.
(Illinois, Indiana, Michigan, Minnesota
Ohio, Wisconsin)
Regional Administrator .
Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois 60604
Re ion ·G·
Arkansas, Louisiana, New Mexico,
Oklahoma, .Texas)
Regional Administrator
Environmental Protection Agency
First .International Building
1201 Elm Street
DalY~s, Texas 15270
Region 7
(Iowa, Kansas, Missouri, Nebraska)
Regional Administrator
Envfronmental Protection Agency
726 Minnesota Avenue
Kansas City, Kansas 66101
Re ion 8
Co 1 or ado, Montana, North Dakota_,
South Dakota, Utah, Wyoming)
Regional Administrator
Environmental Protection Agency
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
77
/
.. APPENDIX E
ANNOTATED BIBLIOGRAPHY
78
l
D. G. Ackerman, L. L. Scinto, P. S. -Bakshi, R .. G. Delumyea, R .. J. Johnson, G.
Richard; A. M. Takata, and .E. M. Sworzyn; 11Destruction and Disposal 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-6OO/2-82-O69], and
2. Ackerman et al., (1981) [EPA-6OO/2-81-O22].
--------·-----------------------------------------------------------------·---. .
Department of Health, Education, and Welfare, Public Health Service, Center
for Disease Control, National Institute for Occupational Safety and Health,
''Criteria for a Recommended Standard ... Occupational Exposure to Polychlorinated
Bi phenyl s (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-
p 1 ace be contra 11 ed by adherence. to the fo 11 owing sect ions. The standard is
designed to protect the health and provide for the safety of employees for up
to a 1O-hour workday, 4O-hour workweek, over a .normal working lifetime. The
standard is measurable by techniques that are valid, reproducible, and avail-
able to i ndustry 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 environmental 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 anim~ls 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 section of report]
79
R. L. Durfee, G. Contos, F. D. Whitmore, J. 0. Barden, E. E. Hackman: III,
and R. A. Westin., "PCBs in the United States -Industrial Use and Environmental
Distributions," U.S. Environmental Protection Agency, Office of Toxic Sub-
stances, Washington, DC, Report No. EPA 560/676-005 [NTIS No. PB-252012], 1976,
488 pp.
Review of Disposal and Destruction Methods
' This document presents the current state of knowledge about the produc-· l
. tion, usage, -and c;iistribution of polychlorinated biphenyls (PCBs) in the
United States. The information presented is derived from detailed studies· on . -1 ·the production and first tier user industries, the past and present genera-
tion and dispositirin of PCB~containing wastes; environmental transport ind
cumulative loads, potential alternatives to PCBs usage, inadvertent losses to
and potential formation in the environment, and current regulatory authorities
for PCBs control. These results indicated that, although PCBs content of in-
dustrial wastei can be reduced through various approaches (treatment, substi-
tution, etc.), there exists a potentially severe future hazard in the form of
large amoun~s 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] -
Environmental Protection Agency, 11 40 CFR Part 761, Polychlorinated 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 prov1s1ons of the Toxic Substances·Control
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, 1979, unless spe-
cjfically exempted by the Environmental Protection Agency (EPA);
(2) -Prohi~its the processing, distribution in commerce, and use of PCBs
except in a totally enclosed manner 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]
-~--------------------------------------------------------------------------
80
Environmental Protection Agency, "Region V Strategy for Permitting PCB Dis-·
posal Sites," 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 providiAg examples of approval and consent letters. -
Participant programs (public hearings) procedures and a checklist for_ ev-aluat-
ing applications are appended.
Environmental Protection Agency, 11 40 CFR Part 761, Polychlorinated Biphenyls
(PCB~) Manufacturing, Processing, Distribution in Commerce and Use Prohibitions;
Rec6dification,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 provides 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 Approval 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 fa~ilities 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 Administtators will continue to have the authority to approve
all unique, site-:specific facilities such as landfills, stationary incinera-
·to~s: ~nd researc~ and development into PCB disposal methods. This amendment
does not change any standards for approving PCB 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. [autho_r.' s summary]
81
M.· O. ·Erickson-and J. S. Stanley, "Methods o-f Analysis for By-Product PCBs--
Literature Review and Preliminary Recommendations," 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 literatt1re 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 rul~ regulating by-~roduct PCBs. The .published literatute on
PCB analysis is critically reviewed. Several hundred references are cited in
a bibli-0graphy. The review is subdJvided into extraction, cleanup, determina-
tion,, data reduct ion, confirmation, screening, qua 1 ity assurance, and by-
product 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).
Tech'niques 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 Research Institute, Kansas City,
MO, to David P. Redford, U.S. Environmental Protection Agency, Office of Toxic
Substances, Field Studies Branch, Washington, DC, EPA-560/5-82-006, 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 analytical method for commercial products and product waste streams
consists of a flexible approach for extraction and cleanup of particular ma-
trices.· The 1~C~labeled PCB surrogates are added as part of a strong quality
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 revision of a propbsed EPA method
for the collection and analysis of PCBs iri 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 and 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 I abstract]
82
L. Fradkin and S. Barisas, "Technologies for Treatment, Reuse, and Disposal
of ·Polychlorinated Biphenyl Wastes," Prepared for U.S. Department of Energy,
ANL/EES-TM-168, 1982 (NTIS No. DE82013715).
Review of Disposal and Destruction Methods
Several technologies being developed by private industry and government
to meet U.S. Envi~onmental Protection Agency regulations for PCBs were as-
sessed to assist in the selection of 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 TM process, plasma-arc technology, ultraviolet-ozone treatment,
catalyzed· wet oxidation, hydrothermal dechlorinat,on, light-activated reduc-
tion, and EPAC filters as well as the approved method~ of land disposal and
incineration.
-----------------------------------------------------------------------------,
Navy, "PCB Compliance, Assessment, and Spill Control Guide,11 Naval Energy. and
Environmental Support Activity, Fort Hueneme, CA, Report No. NEESA-20.2-028A
[NiIS No. AD-A121 329/7] August 1982, 105 pp. .
Guidance
Polychlorinated biphenyls (PCB) are toxic belongihg 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, tra.ns-
port and disposal of PCBs leading to a total ban on use of PCBs. This guide
was designed to assist Navy activities in complying with these complex and
intricate regulations. [author 1 s abstract]
E. M. Sworzyn and . D. G. Ackerman, "Interim Guidelines for the Disposal/
Destruction of PCBs and PCB Items by N·on-therma l Methods, 11 Report by TRW,
Inc., Redondo Beach, CA 90278, to David Sanchez, EPA, Office of Research and
Development, Research _ Triangle Park, NC, EPA-600/2-82-069, 1982, 177 pp.
(NTIS No. PB82 217498). . .
Guidance -Non-Thermal
The report is an interim resource and guideline document to help EPA
regional offices implement the polychlorinated biphenyl (PCB) regulations
(40 CFR 761) for using non-thermal methods of destroying/disposing of PCBS.
The report describes and evaluates various alternative chemical, physical,
and biological PCB removal and/or destruction technologies, including:
carbon adsorption; catalyti£ dehydrochlorination; chlorinolysis; sodium-based
dechlorination; photolytic and microwave plasma destruction; catalyzed wet-air
oxidation; and activated sludge, trickling .filter, and other bacterial methods.
83
0. ·---. . j
The :alternative technologies '"'ere ·evaluated usin technical, ·--regulatory, ··envi-
ronmental · impact, economic;-and energy criteria .. Because the technologies in-
vestigated are in various stages of development (only sodium-based dechlorina-
tion is available commercially), data deficiencies exist and good engineering
judgment was used to. ~upp-lement ayailable quantitative infonnatif:)n. Of the
technologies evaluated, many show potential for> 90% PCB destruction with
minimum environmental impact and low-to-moderate economic cost. These tech-
nologies are: catalytic dehydrochlorination, sodium-based dechlorination,
and photolytic and microwave plasma processes. [author's abstract]
-------·-·-~-----._ -.--·--------------------------~·------------~ --------
J. V. Zbo.zinek, T. J. Chang, J. R. Marsh,· P. K. McCormick, and J. E. ..Mccourt,
"PCB Disposal Manual," Report by SCS Engineers, Inc., Long Beach, California
for the Electric Power Research Institute, Palo Alto, California, CS-4098,
1985 .. -
Guidance
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 the technology in the intervening period.
This report emphasizes those areas which were subject td the greatest change,
as well as new areas that were not considered when the previous volume was
published. Among the various areas of PCB disposal which are addressed in ·
this report are PCB materials and their distribution in the utility industry,
regulations, thermal destruction technology, land disposal, treatment tech-
nologies, 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].
84
i
; i
Table 4. Format for Permit A~plications for Alternative
Method of PCB Destruction
Permit Cover
Table of Contents ·
I. Summary • ~{t . ,'/l-/,;
II. Project Organization • s-t-,,udu.re /;u.:t: nat; ,',,,d,:..,;cUu:.../5.
III. Waste Description • a.// ,'11 fo
IV. ,
V.
VI.
VII.
VIII.
IX.
X.
XI.
XI I.
XIII.
XIV.
xv.
XVI.
XVII.
XVII I.
XIX.
. d.lJ!;c-L
Process Engineering Description • t:t va //~le,. w( n/'la..l de.'!.lj VJ
Sampling and Monitoring Plan
Sampling P~ocedures
'10-
Sample Analysis Procedures
Monitoring Procedures
Waste Handling and Disposal
Data Reporting/Recordkeeping
Inspection Procedures
Spill Prevention Control and Countermeasure Plan
Safety Plan
Training Plan
Demons t ration Test Plansa
Test Data or Engineering Performance Calculations
Other Permits/Approvals
Schedu l e of Preoperation Events
Quality Assurance Plan
XX. Standard Operating Procedures
XXI. Closure Pl an
a For a research and development application, this section would present the
_planned research. activities.
15