NCD980602163_19830628_Warren County PCB Landfill_SERB C_QA and QC Control Procedures for Demonstrating PCB Destruction in Filing for a PCB Disposal Permit-OCR

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QUALITY ASSURANCE AND QUALITY CONTROL PROCEDURES FOR
DEMONSTRATING PCB DESTRUCTION IN FILING
FOR A PCB DISPOSAL PERMIT
I~1TRODUCTION
The ap-plicant shall provide information on the overall
company organization and the organization of the actual group
carrying out the processing or PCB destruction. Include a table
or chart showing the _project organization and the line of
authority. This table or chart should list all the key
individuals, including those who are responsible for ensuring the
collection of valid measurement data and routine assessment of
measurement systems for precision and accuracy.
A general description of the project shall also be
included. This should contain; the experimental design, flow
diagrams if available, tables, charts, and dates anticipated for
start and completion.
A demonstration of destruction of PCBs by a chemical process
will require specific quality assurance and quality contro l
(QA/QC) measures.
As a minimum these measures are a Quality Assurance.Plan
signed by process officials and containing:
(l) documents demonstrating the capability and capacity
to destroy PCBs in the materials to be processed by the
potential permitee to levels at or above the requested
permit level;
(2) chemical reactions and process conditions (for
example; temperature changes, viscosity changes,
stirring) changing the kinds of products, amounts of _
products, or rates of reaction .resulting from the
destruction of PCBs in the medium for which the permit
is requested;
(3) procedures_ for select"'ing the portions of -the
process-ed material spec irnens to be chemically analyzed
to demons-trate PCB destruction and chain of custody of
the specimens;
(4) treatment of the material to be chemically
analyzed;
(5) ~he chemical analysis procedures used including
refere nc es, specimens and instrument settings1
(6) calculations employed to transform instrument
readings into raw data and raw data into reported dataJ
(7) method of verifying reported results;
(8) certification that there are no PCBs below EPA
required levels in any waste materials.
'De tailed De script ions
(l) Preliminary laboratory testing on -the material to be
treated (e.g. mineral oil dielectric fluid) should be done
befo r e applying for a permit. The -potential permittee must
provide--aaeessary documentation to demonstrate that, for the
medium to be treated the process has the capability and
capacity to destroy PCBs. Part of the demonstration would
be:
(a) how any specimens analyzed in such a demonstration
were sampled from ·the larger amount to be treated. An
example might be: a 100 milliliter specimen \las
withdrawn by a volumetric pipette from each of three
different randomly selected fifty-five gallon drums.
The .three specimens were emptied, in turn, into a brown
glas~ one liter bottle with a teflon lined c~p;
(b} ~r-ea-tment of the material, collected in .(a) above,
prior to chemical analysis;
( c) analytic al procedures for quan ti fyi ng PCBs in the
material collected in (a) and located in (6);
(d) results of the chemical analyses before am after
the destruction process.
(2) Relevant chemical reactions to be reported are all
reactions of PCBs with t~e ingredients •in the process. Anv
confidential business information (CBI) must be submitted
through established procedures. A version eliminating CBI is
more easily and expeditiously handled in permit review. In
addition to chemical reactants and products, the applicant
must detail all changes in operating conditions which effect
the destruction of PCBs, ·such as temperature or impurities
which canpete for the process ac~ive ingredients. Products
of reaction of the process active ingredient with the medium
to be processed and. impurities in that med i urn shal 1 be
stated.
(3) For the actual full scale or large capacity destruction
demorts~tion, there must be a written description of how the
medium to be processed is sampled to obtain specimens for
analysis. To demonstrate destruction, a representative
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sample ts necessary. One way of obtaining a representative
sample, when only limited sampling sites are available, is by
randanly (over time) collecting subsamples and then
compositing the subsamples to a single composited sample.
7he sampling must take place fran the material as it is
returned to the customer for storage or use. Mid-process
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specimens, whta,t ·helpful:,~;do0 not ,demonstra.te destruction.
( 4) Details of the hand1.ing, physical and chemical treatment
of a specimen te · be chemically analyzed for PCBs must
include, but are·· not -limited to, reagents added, source of
collection vessels, preparation of collection vessels, any
extractions or separations of a treated specimen.
Examination of all separated parts for PCBs is necessary.
For example, if a separating funnel is used and there are two
layers, if one:layer is assumed to contain PCBs and the other
lay,r is discarded, then the discarded layer must be examined
and proven·~~free of PCBs •. If a process is "quenched" with
sulfuric acid, detailed descriptions are required to
demonstrat e that the sulfuric acid used is in the same
proportion in quenching . the specimen to be analyzed as in
quenching the large volu~e of the medium processed. -This
~escription is necessary because of the degradation of less
highly chlorinated PCB congeners by sulfuric acid.
(5) Details of the chemical analysis must include the method
used· :,a.nd reference of that method to_ any published method
which nas been demonstrated to detect chlorinated. biphenyl
congeners with a known precision and accuracy. EPA will .
provide methodology guidance for chemical analysis of PCB
destruction in a separate document.
It is ~ssible to use screening techniques employing
very sensitive but not specific chemical analyses to
determine quantities of potential chlorinated biphenyl
congeners. EPA will identify and confirm PCBs by the
techniques described in ·"Analytical Me ·thods for By-Product
PCBs;.. Preliminary Validation and Interim Methods". Quality
assurance ·and quality control for analytical methodology
i ncludes but is not restricted to:
raf = a tible :6f instrumental settings and other
C parameters required to · reproducibly ·.mt~~tire .. ~C:Bs. E'or a
gas .chr~matographic technique some requirement~ include
type of column material, column packi ng/coit,ing, column
length, gas composition, gas . flo'!J ~ate r i nject~on
volume, attenuation, type of d~ tector, column _.,
temperature, detector temperature, an<L brand and morle l
number of instrument(s);
(b) precision and accuracy determination procedures and
result~, including frequency of calibra~~on, replicated
analyses, standard reinforced specimens,~PCB standards ,
and blanks. ·standards must cover the range from
monochloro bi phenyl through decachloro bi phenyl and it
is suggested that at least one congener frails e.ach
hanolog be used in a standard "cocktail". The level of
this cocktail should be such that PCBs can be quantified
at the Lev.el of Quantitation as defined by the (Clo~ed
and Controlled Rule 4 7 FR 46980). Any meas ur,able
indication of a canpound in the r4nge between and
including monochlorobiphenyl and decachlorobiphenx~ i s
considered PCBs unless confirmed by mass spectr .. aJ. .. , ,· •.J';.'1(,,,
analysis.
(c) traceability of standards;
(d) participation in audit programs when available;
(e) confirmation of split specimens with an independe n t
laboratory:
(f) copies of instrument charts. or tracings, such as
chromatograms with all information .necessary for ..
interpretation and reference ac; in part ~·~ ( ~/,•.
( 6) All formulas, calculations, and equations used in
converting instrument reading$ or t_)rintouts .. to refined dao:a
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or results must be documented. Include procedures used to .
conf i~ correct calculations and transcription.
(7) A·ny other checks employed to verify results but no·t
given in 1-6 above.
(8) A statement, signed by the responsible official seeking
the permit, that:
All "clean" materials have been documen-ted and
demonstrated to have no PCBs above EPA required levels,
additionally all waste materials have either been
documented and demonstrated to have no PCBs, or the
plans for disposal of these wastes are attached. Wastes
include, but are not limited to, quenching water,
unprocessed material leaked or spilled during connection
to or release fran the process, any polymers formed, and
the residue resulting fran the destruction of PCBs.