NCD980602163_19951031_Warren County PCB Landfill_SERB C_TSCA Permit Application-OCR

~ , -==--aQuaTerra® CORPORATE HEADQUA RTERS: '7"'=" POST OFFICE Box 37579 • RALEIGH, NC • 27627-7579 • [phone] • FAX [phone]
A GREAT LAKES C H EMICAL CORPORATION COMPANY
October 31, 1995
Mr. William Meyer
Director
Division of Solid Waste Management
North Carolina Department of Environment, Health, and Natural Resources
401 Oberlin Road
Raleigh, North Carolina 27607
Reference: TSCA Permit Application
Warren County PCB Landfill
Dear Mr. Meyer:
Attached are five copies of the TSCA permit application required for ETG Environmental,
Inc.'s proposal to conduct a pilot study demonstration test at the Warren County PCB
landfill.
If you have any questions, please call me at [phone].
Sincerely,
AQUATERRA, INC.
~~~
Steven C. Lewis
ENVIRON MENTAL C ONSU LTANTS
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PERMIT APPLICATION
PCB DESTRUCTION UNIT
BASE CATALYZED DECOMPOSITION
WARREN COUNTY PCB LANDFILL
WARRENTON, NORTH CAROLINA
SUBMISSION DATE: OCTOBER 30, 1995
SUBMISSION NUMBER 1
Submitted by:
Aquaterra, Inc.
. 4901 Waters Edge Drive
Raleigh, North Carolina 27606
Mr. Steven C. Lewis
[phone]
AND
ETG Environmental, Inc.
660 Sentry Parkway
Blue Bell, Pennsylvania 19422
Mr. Loren A. Martin
[phone]
Volume 1 of 1
Submitted to:
EPA Region IV
345 Courtland St. N.E.
Atlanta, Georgia 30365
----------------. -. , ... ·--------...... ---~-.. ·----
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TABLE OF CONTENTS
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I 1.0 SUMMARY 1
2.0 PROJECT ORGANIZATION 2
I 3.0 WASTE DESCRIPTION 5
4.0 PROCESS ENGINEERING DESCRIPTION 6
I 4.1 General 6
4.2 Waste Feed System 9
4.3 Automatic Waste Feed Cutoff 10
I 4.4 Destruction System 11
4.5 Pollution Control System 13
I 4.6 Summary of Process Operating Parameters 14
5.0 SAMPLING AND MONITORING PLAN 14
I 6.0 SAMPLING PROCEDURES 15
7.0 ANALYTICAL PROCEDURES 20
I 7.1 Analytical and Calibration Procedures 20
7.2 Analytical Procedures 21
7.3 Calibration Procedures 21
I 7.4 Quantitation 22
7.5 Data Reduction, Validation and Reporting 22
I 8.0 MONITORING PROCEDURES 26
9.0 WASTE HANDLING AND DISPOSAL 26
I 10.0 DATA REPORTING AND RECORD KEEPING 26
11.0 INSPECTION PROCEDURES 27
I 12.0 SPILL PREVENTION CONTROL
AND COUNTERMEASURES PLAN 27
13.0 HEALTH AND SAFETY PLAN (HASP) 28
I 13.1 Organization and Responsibilities 28
13.2 Hazard Characterization and Levels of Protection 30
I 13.3 Emergency Procedures 31
14.0 TRAINING PLAN 31
I 15.0 DEMONSTRATION TEST PLAN 32
16.0 TEST DATA 32
I 17.0 OTHER PERMITS/APPROVALS 33
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18.0
19.0
20.0
21.0
TABLE OF CONTENTS (cont.)
SCHEDULE OF EVENTS
QUALITY ASSURANCE PLAN
19.1 Project and QA Organization
19.2 Quality Assurance Objectives
19.3 Monitoring Procedures
19.4 Sampling and Data Collection Procedures
19.5 Analytical Procedures
19.6 Sampling Procedures
19.7 Internal Quality Control
19.8 System and Performance Audits
19.9 Calculation of Data Quality Indicators
19.10 Corrective Actions
19.11 Quality Assurance Reports to Management
STANDARD OPERATING PROCEDURES
CLOSURE PLAN
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LIST OF FIGURES
1. Project Organization Chart
2. Site Location
3. Process Flow Diagram
4. System Configuration
5. On-Site Location of THERM-O-DETOX Unit
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LIST OF TABLES
1. Physical Characteristics of Soils
2. Chemical Characteristics of Soils
3. Process Deviation Action Chart
4. Emergency Shutdown Procedures
5. Sampling Plan for Each Trial Run
6. Objectives and Representativeness of Sampling and Monitoring Points
7. Exposure Limits
8. Health Effects and First Aid
9. Health and Safety Monitoring and Action Levels
10. Protective Equipment
11. Treatability Test Results, Koppers Site, Morrisville, NC
12. Data Quality Objectives
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1.0 SUMMARY
Aquaterra, Inc. (Aquaterra), on behalf of ETG Environmental, Inc. (ETG), the North
Carolina Department of Environment, Health, and Natural Resources (DEHNR), and the
Joint Warren County/State PCB Landfill Working Group (Working Group), is submitting to
USEPA Region IV an application for a Research and Development (R&D) permit to
conduct a pilot-scale test for the base catalyzed decomposition (BCD) method of disposal of
polychlorinated biphenyls (PCBs) in accordance with 40 CFR 761.60 ( e) under the authority
of the Toxic Substances Control Act (TSCA).
The pilot study will be conducted by ETG at the Warren County PCB landfill in Warrenton,
North Carolina under a contract with DEHNR. The soils used for this test will be obtained
from the landfill and contain Aroclor 1260, Aroclor 1254, and some dioxin. The average
PCB concentration is 300 to 350 parts per million (ppm) with a maximum PCB
concentration of 900 ppm. The maximum dioxin concentration is less than 30 parts per
quadrillion (ppq). Between nine and ten cubic yards of soil will be required for the pilot
study. The pilot study will be performed over a two-week period with a total processing
period of up to five days.
The BCD process was developed by the Risk Reduction Engineering Laboratory (RREL) in
Cincinnati, Ohio. ETG developed the THERM-0-DETOX system using medium-
temperature thermal desorption (MTTD) and combined it with the BCD process chemistry
licensed from RREL. ETG successfully demonstrated the technology under the Superfund
Innovative Technology Evaluation (SITE) program at the Koppers Company Superfund
Site in Morrisville, North Carolina from August through September 1993. EPA Region IV
has approved BCD for full-scale remediation at the Koppers site.
Project objectives are:
1.
2.
Provide the technical data and scientific basis for recommendations by the
Joint Warren County/State PCB Landfill Working Group (Working Group)
to the North Carolina State Legislature for full-scale detoxification of the
landfill.
Determine the appropriateness and feasibility for full-scale detoxification of
the landfill.
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TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
Appropriateness will be largely measured by the extent and degree of
detoxification with a minimum goal to reduce PCB concentrations to less than
2.0 ppm and a proportionate reduction in other chlorinated constituents.
Feasibility will be determined primarily by considerations for safety of the
technology, rate of detoxification, cost per unit of detoxification, and
reduction in long-term potential for environmental releases from residuals of
the process. Dioxin emissions will be of particular interest.
This permit application conforms with EP A's guidance document, Draft Guidelines for
Permit Applications and Demonstration Test Plans for PCB Disposal by Non-Thermal
Alternative Methods, dated August 21, 1986.
2.0 PROJECT ORGANIZATION
The person responsible for obtaining the TSCA permit for the Warren County facility is Mr.
Steven Lewis of Aquaterra. Mr. Loren Martin of ETG will be the permit coordinator. Key
personnel for this project follow and are shown in Figure 1.
1.
2.
Person responsible for obtaining permit:
Mr. Steven C. Lewis
Aquaterra, Inc.
4901 Waters Edge Drive
Raleigh, North Carolina 27606
[phone]
Project Manager:
Mr. Mitchell Moss
ETG Environmental, Inc.
660 Sentry Parkway
Blue Bell, Pennsylvania 19422
[phone]
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. ----~-------·--··-··
I TSCA Permit Application
I Warren County PCB Landfill
October 30, 1995
I 3. Operations Supervisor:
I Mr. Eli Clevenger
ETG Environmental, Inc.
I
660 Sentry Parkway
Blue Bell, Pennsylvania 19422
[phone] ,,
4. Reviewing Engineer:
I Mr. Mitchell Moss
ETG Environmental, Inc.
I 660 Sentry Parkway
Blue Bell, Pennsylvania 19422
I [phone]
5. Maintenance Supervisor:
·I Mr. Randy Crosby
ETG Environmental, Inc.
I 660 Sentry Parkway
Blue Bell, Pennsylvania 19422
I [phone]
6. Quality Assurance Officer: I Dr. Yei-Shong Shieh
ETG Environmental, Inc.
I 660 Sentry Parkway
Blue Bell, Pennsylvania 19422
'I [phone]
I 7. Safety Officer:
Mr. Kevin Brentlinger
I ETG Environmental, Inc.
660 Sentry Parkway
Blue Bell, Pennsylvania 19422
I [phone]
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Laboratory Technical Director:
Mr. Donald J. Harvan
Triangle Laboratories, Inc.
801 Capitola Drive
Research Triangle Park, North Carolina 27709
[phone]
Person responsible for training:
Mr. Rick Crosby
ETG Environmental, Inc.
660 Sentry Parkway
Blue Bell, Pennsylvania 19422
[phone]
Person responsible for demonstration test:
Mr. Mitchell Moss
ETG Environmental, Inc.
660 Sentry Parkway
Blue Bell, Pennsylvania 19422
[phone]
Person responsible for operation of monitoring system:
Mr. Mitchell Moss
ETG Environmental, Inc.
660 Sentry Parkway
Blue Bell, Pennsylvania 19422
[phone]
Person responsible for record keeping and reporting:
Mr. Mitchell Moss
ETG Environmental, Inc.
660 Sentry Parkway
Blue Bell, Pennsylvania 19422
[phone]
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TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
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3.0 WASTE DESCRIPTION
TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
The contaminated soil was the result of the illegal dumping in 1978 of approximately 30,000
gallons of PCB-containing transformer oil along approximately 271 miles of North Carolina
roadways. The soil was removed from the shoulder areas of the roadways and was placed in
a PCB chemical waste landfill located in Warren County, North Carolina (see Figure 2) in
1983. The landfill is now closed and is owned and maintained by the State of North Carolina
(State). The landfill is permitted in accordance with TSCA and 40 CFR Part 761. The site
is located about .5 mile off of State Road 1604 about 3.5 miles south of Warrenton, North
Carolina. The land use is a mixture of grazing land and wooded areas.
The contaminated soil is a sandy loam with less than 2% decomposed organic content.
While on the roadways, the soil was tacked with liquid asphalt. Generally, the soils are
coarse-grained, with less than 30% passing through a #200 sieve. The liquid limit and
plasticity index are 25 and 8 respectively. Table 1 presents the physical characteristics of the
soils as determined by the State.
The uppermost ten to twelve feet of soil in the landfill is relatively dry. Soils below this level
are saturated with water. Soils provided for the pilot study will vary in moisture content
from relatively dry to saturated.
The chemical characteristics of the soils are shown in Table 2. The State has determined the
average PCB concentration to be 350 ppm with a range of 150 to 880 ppm. There is a
mixture of PCB congeners with approximately 61 weight % Aroclor 1260, 27 weight %
Aroclor 1254, and 12 weight % Aroclor 1242. Other chemicals including chlorinated
benzenes and dioxins are present in parts per billion or quadrillion concentrations.
As stated, between nine and ten cubic yards of soil will be treated with the THERM-O-
DETOXJBCD process. The soil will be processed at a rate of one test run per day. Each
run will process about three cubic yards of soil and last between four to six hours.
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4.0
4.1
PROCESS ENGINEERING DESCRIPTION
General
TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
The process flow and system configuration are shown in Figures 3 and 4. Discrete units
include the waste feed system; the indirectly-heated MTTD rotary vacuum desorber unit; an
extensive vapor recovery system including oil and water scrubbers, chiller condensing units
and a carbon polisher; a BCD liquid tank reactor (LTR) unit for treating oily wastes
containing PCBs; oil and aqueous condensate storage; and a cooling conveyor.
The THERM-O-DETOX system will be located outside the western fence of the landfill just
off the access road to the site ( see Figure 5). A ten cubic yard system on one mobile trailer
will be used for this pilot study. About two days will be needed for setup of the unit after
arrival at the site. The system will be left on-site during the two-week pilot study and then
demobilized.
The THERM-O-DETOX system is an indirect heated system which operates under a
vacuum (27" -29" Hg) at temperatures up to 900°F to effectively desorb organic compounds
from soils and other matrices. The system operates in a batch mode and has internal
heating and mixing.
The feed material is processed by the rotary vacuum desorber. The complete mixing action
afforded by the desorber's internal mixing flights and internal central heating mixing bar
constantly agitate and break up the soil particles. Heat transfer is enhanced by a large
surface area to allow rapid heating of the soil for optimum contaminant removal. The
desorber is contained within an outer insulated heating chamber where a Powerflame Inc.
Model C4-0A, 5.5 million BTU/hour #2 fuel oil burner supplies the indirect heat. Exhaust
gas from the fuel burner is discharged from the top of the insulated heating chamber.
The desorber will heat the material to 900°F. The throughput rate depends upon waste
moisture content, contaminants, and treatment standards. A waste with higher moisture
content will result in reduced production while lower moisture content will allow faster
production. The desorber will operate on an eight-hour day basis for this pilot study with a
typical batch time of four to six hours.
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TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
During heating and mixing, vacuum is applied to the rotary desorber, greatly enhancing the
desorption of the contaminants. The vacuum pump provides a nominal 150 CFM of air flow
at 28" Hg allowing the system to operate under an inert condition.
Vapors in the off-gas will be condensed and recovered by non-contact shell and tube heat
exchangers/condensers in the vapor recovery system (VRS). On-board cooling tower and
chiller units deliver 70° to 8G°F and 35° to 40°F non-contact cooling water to the condensing
units. The condensed contaminants and water from the vapors are collected in two 1,000
gallon receiving tanks. Recovered liquid remains in the tanks, while the non-condensable
vapor travels through the condensing units and vacuum pump into in-line carbon canisters.
The carbon canisters polish the vapor prior to discharge to an oxidizer. The oxidizer
virtually eliminates non-condensables and residual contaminants not removed by the
physical separation/adsorption equipment of the VRS, and acts only as a polisher prior to
final discharge of air to the atmosphere.
The MTTD process is started by establishing cooling and chilled water flows to the
condensers, and establishing the system vacuum from the receiver tanks up to the MTTD
vessel vacuum shut-off valve. A weighing conveyor is moved into position inside the MTTD
drum charging opening and screened, stockpiled waste soils are loaded into the feed hopper
using a small backhoe. If necessary, dechlorination reagents can be added before the soil is
fed into the MTTD unit. Soils are loaded into the MTTD drum until it is filled to the
desired amount as determined by the weighing conveyor.
The weighing conveyor is moved away from the MTTD drum opening and the vapor
recovery door is swung into position in its place. Opening the MTTD vessel vacuum shut-off
valve allows the condenser system vacuum to be connected to the MTTD drum, thereby
pulling the door closed as it begins to evacuate the drum.
Once the vacuum has fully recovered, the drum rotation is begun and the process heater is
turned on. The process temperature controller modulates the heater firing rate based upon
the set point temperature established by the operator. Typical operating temperature is
900°F. Interlocks on the system provide safety backups in case of flame failure, loss of
cooling, loss of vacuum, or loss of power.
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TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
Upon completion of the processing cycle, the heater is shut down and the MTID vessel is
allowed to cool under vacuum for approximately fifteen minutes to one hour. The vapor
recovery door is removed by releasing the system vacuum after which the discharge door is
moved into place over the drum opening.
The drum rotation is reversed to discharge the treated soils through the discharge door into
the quench blender, where they are cooled and remoisturized to control dust. The product
comes out of this device onto a discharge conveyor for stockpiling.
The oil vapor phase is condensed and sent to the BCD LTR. This vessel is a 75-gallon,
electrically heated, mixing reactor. The LTR is prepared to treat contaminants by adding a
base (i.e., sodium hydroxide), a catalyst, and a hydrocarbon which serves as the reaction
. medium and as the hydrogen donor. The LTR contents are heated to 6l0°F to 650°F for one
to three hours to dechlorinate the contaminants. When the dechlorination reactions are
completed, the LTR contents can be reused during the next run or recycled off site as a fuel
supplement in an industrial boiler or cement kiln.
The following theoretical description of the BCD process is taken from Proceedings: Fifth
Forum on Innovative Hazardous Waste Treatment Technologies: Domestic and International,
USEP A, EP N540/R-94/503, May 1994. The BCD process detoxifies and chemically
decomposes contaminants by removing chlorine atoms. The process can be combined with
MTID to dechlorinate high-hazard organics including PCBs, polychlorinated dibenzo-p-
dioxins (PCDDs), polychlorinated dibenzofurans (PCDFs), pentachlorophenol (PCP),
pesticides, and herbicides. The MTTD/BCD combination for treating contaminated soil
allows the minimization and concentration of the organic solvents required for BCD, the
minimization of air and water discharges, and the recovery of dechlorinated organic
compounds for use as a fuel supplement. The treated soil can remain on site as fill material.
The principle of the BCD process is to use hydrogen radicals generated from a hydrogen
donor to completely replace chlorine ions in the chlorinated hydrocarbons (1). The key
(1) Rogers, C. J.; Kamel, A.; Sparks, H. L.; Haz Pac '91, Hazardous Waste Management
in Pacific Basin. Randol International, Ltd., Golden, CO, 1991.
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TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
operating variables for the reactions are the base catalyst and hydrogen donor
concentrations, the operating temperature, and the retention time.
Thermal desorption of organics from contaminated soils and sludges by indirect heating are
well-studied and documented. Two of the most critical factors for effective thermal
desorption are heat transfer to the waste and the degree of waste mixing. Increased mixing
reduces residence time. A thermal desorption system that processes a material quickly and
thoroughly also has less chance for thermal decomposition of organic compounds or the
formation of coke in the system caused by higher hydrocarbon concentration from the feed
material. A continuing trend is to increase the process temperature of the thermal
desorption system to a higher range for the removal of heavy organic and chlorinated
organic compounds.
The BCD chemistry (2) in the LTR is illustrated as follows:
R-(Cl)x+R' Na+ >R-H+NaCl+R"
620°F-6S0°F
R-(Cl)x as shown can be any halogenated compound such as PCDDs, PCDFs, PCBs, 2,4-D
or 2,4,5-T. In principal, R' is a hydrogen donor whose oxidation potential is sufficiently low
to generate nucleophilic hydrogen in the presence of base Na+ ( sodium hydroxide) at
temperatures between about 480°F and 660°F. Under these conditions, chlorine on R-Cl is
replaced by H to produce R-H with loss of hydrogen from R' to R" and the formation of
sodium chloride. This reaction achieves complete dechlorination of chlorinated compounds.
The reaction product of all treated PCBs is biphenyl.
4.2 Waste Feed System
The waste soil will be removed from the landfill under a separate contract issued by
DEHNR. It will be screened to less than 2.0 inches and stored in a rolloff container on-site
(2) Rogers, C. J.; Kornel, A.; Sparks, H. L.; Method for the Destruction of Halogenated
Compounds in a Contaminated Medium. Patents: Number 5,019,175 (May 28, 1991);
5,039,350 (August 13, 1991); and 5,064,506 (November 12, 1991).
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TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
until processing. Leachate containment from the rolloff will be the responsibility of the
contractor who removes the soil from the landfill. A weighing conveyor will be used to
determine the amount of soil processed per batch.
The waste soil will be placed in the feed hopper with a small backhoe. Approximately 5%
by weight of sodium bicarbonate will be added to enhance the dechlorination reaction.
It is expected that nine to ten cubic yards of waste soil will be processed during five days of
operation over a two-week time period depending on weather conditions and turnaround
time for analytical samples. The rolloff container will store the complete supply of soil to be
processed during the pilot study. It is expected that about three cubic yards of soil will be
used per test run. A test run will last between four to six hours.
4.3 Automatic Waste Feed Cutoff
When process conditions deviate beyond standard or safe operating conditions, various
automatic interlocks are activated to shutoff the process heater. The remaining systems
(vacuum and cooling) are inherently safe and utilized to provide as close to a controlled cool
down as possible until the affected area's trouble can be corrected and the heater restarted
to resume processing. A process deviation action chart is included as Table 3.
In the event of a cooling or vacuum system problem which could result in a total loss of
vacuum while the MTTD unit is hot, the emergency shutdown procedures would be
implemented. An emergency shutdown chart is included as Table 4. These procedures are
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Automatic shutdown of the process heater
Stop drum rotation
Secure MTTD vessel door
Initiate inert gas or steam purge
Re-establish normal vacuum and condensing operations prior to any
resumption of processing
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4.4 Destruction System
TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
The thermal desorption process used in the MTTD unit is well-studied and documented. In
the LTR, the chemical reaction used to dechlorinate PCBs is described in Section 4.1. The
LTR is a 75-gallon, electrically heated, mixing reactor. It is also operated in a batch mode.
A batch quantity will be about 70 gallons.
A petroleum hydrocarbon oil, a heavy paraffinic distillate (CAS 64741-88-4), is the reaction
medium and hydrocarbon donor. Sodium hydroxide (NaOH), is the base needed to
generate hydrogen. The catalyst is proprietary knowledge of ETG. When the PCB-
containing fluid from the condensing unit is combined with the hydrocarbon oil, the NaOH,
and the catalyst and heated to between 610°F and 650°F, the resultant reaction strips the
chlorine from the PCBs and replaces it with a hydrogen ion. The reaction products are
biphenyl and sodium chloride (NaCl).
A pre-determined monitoring plan for key operating parameters will be followed during the
pilot study. The purpose is to record and document operating parameters and conditions.
The monitoring data, in combination with the sampling data, will be used to determine the
efficiency of contaminant removal.
Critical operating parameters will be monitored to verify the operating conditions and to
determine where problems exist if malfunctions occur. The data collected at these
monitoring points will be recorded on monitoring data sheets. These parameters include
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Contaminated soil weight and estimated volume
Sodium bicarbonate weight
MTTD set point temperatures and off-gas flow rate
LTR off-gas temperature and flow rate
Stack gas temperature and flow rate
Volume of LTR influent
• Volume of LTR effluent
• Volume of condensate water
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TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
Figure 3 shows the various locations of the vacuum and temperature gauges on the system.
Design values are 900°F at 27" to 29" Hg vacuum pressure for the MITD rotary vacuum
desorber and 610°F to 65Q°F at atmospheric pressure for the LTR.
Since both the MITD unit and the LTR are batch processes, feed rates for reactants and
catalysts are based on the quantity of waste soil and PCB-containing condensate that are in
the respective reactors.
The design capacities of the particular systems (THERM-O-DETOX Batch Vacuum Unit 1
in combination with LTR Unit 1) that will be used for this pilot test are eight to ten tons per
day of waste soil for the MITD unit and 70 gallons of fluid in the LTR unit.
The THERM-O-DETOXJBCD system has several advantages because of unique design
features. As mentioned previously, the unit has a large heat transfer surface area which
results in high heat transfer efficiency. The MITD unit provides complete local mixing
action by exposing most of the soil particles to the heat transfer surface. This reduces the
dependency of heat movement on the thermal conductivity of the process.
The uniform bed conditions promote direct surface thermal desorption compared to the
ineffective diffusion phenomena that exists when particles are stuck together in lump or
cake. The homogeneous bed also results in the reduction of the retention time. The
uniform bed and higher temperature enhances the removal rate for high boiling point
contaminants.
Additional advantages include
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The system components are commercially available and have been proven to
be effective. No experimental equipment is required.
The system can be modified to incorporate stabilization/fixation additives if
heavy metals are present.
The MITD unit can process sludge, sediment and clayey soils directly with no
pre-drying required.
There is no large volume of sweep gas flowing through the MITD unit,
resulting in non-oxidative physical separation. Therefore, the off-gas can be
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•
TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
condensed without the requirement for an afterburner and associated air
permit.
BCD reagents are inexpensive and do not require reuse .
There are essentially three recycling processes that are part of the system. Condensed water
from the vapor recovery system (VRS) is recycled to supplement the cooling water that is
sprayed on the treated soil in the cooling conveyor as it exits from the MTTD unit. The
treated non-hazardous soil can be used as backfill. The treated non-hazardous hydrocarbon
oil mixture from the LTR can be recycled as fuel for industrial furnaces such as at a cement
kiln.
4.5 Pollution Control System
The effluents from the process are treated soil, treated hydrocarbon liquid, air emissions
from the VRS, and heater stack air emissions from the fuel oil used to fire the MTTD unit.
Treated water from the VRS condensing unit is recycled for cooling the treated soil.
The VRS consists of non-contact shell and tube heat exchangers arranged in series and
cooled by a 75-ton evaporative cooling tower and a 20-ton refrigerated chiller. Process
emissions are controlled by
• 61 square feet of air-cooled heat exchanger
• 32 square feet of water-cooled heat exchanger using cooling tower water
• 200 square feet of water-cooled shell and tube condenser on cooling tower
water
• 200 square feet of water-cooled shell and tube condenser on chilled water
• Passage through a 1750 RPM liquid ring vacuum pump
• 100 square feet of water-cooled shell and tube condenser on chilled water
N on-condensables exiting the final condenser are passed through primary and secondary
activated carbon adsorption canisters and then an 180Q°F oxidizer for a two-stage polishing
process. The applicable control equipment codes are
• Condensing Unit, Tube Type -Control Equipment Code 072
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TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
• Carbon Polisher -Control Equipment Code 048
• Thermal Oxidizer, without Heat Exchanger -Control Equipment Code 021
The following emissions calculations for the heater stack are based on USEPA's AP-42
Compilation of Air Pollution Emissions Factors, Fifth Edition, January 1995, Table 1.3-1,
uncontrolled emission factors for fuel oil combustion.
Normal Emission Rates Maximum Emission Rates
Particulate 0.0629 lbs./hr. 0.14 tons/yr. 0.0786 lbs./hr. 0.34 tons/yr.
SO2 0.0223 lbs./hr. 0.05 tons/yr. 0.0279 lbs./hr. 0.12 tons/yr.
co 0.1571 lbs./hr. 0.36 tons/yr. 0.1964 lbs./hr. 0.86 tons/yr.
NOx 0.6286 lbs./hr. 1.45 tons/yr. 0. 7857 lbs./hr. 3.43 tons/yr.
voes 0.0175 lbs./hr. 0.04 tons/yr. 0.0218 lbs./hr. 0.10 tons/yr.
4.6 Summary of Process Operating Parameters
Target and design values are 900°F at 27" to 29" Hg vacuum pressure for the MTTD rotary
vacuum desorber and 61Q°F to 65Q°F at atmospheric pressure for the LTR.
Actions to be taken when parameters deviate outside control limits or emergency conditions
exist are summarized in Tables 3 and 4. Time allowed for corrective action before shutdown
varies from immediate action for emergency conditions to several minutes for readily
identifiable and correctable conditions such as incorrect setpoints.
5.0 SAMPLING AND MONITORING PLAN
The primary objective of the sampling and monitoring data collection activities is to evaluate
the effectiveness of the BCD process in dechlorinating all possible PCB congeners. The key
factor in evaluating the effectiveness of the BCD process is determining the total PCB
concentration before and after treatment. Also of importance is determining the
concentrations of dioxins and VOCs before and after treatment.
A detailed description of the process and the system design is presented in Section 4. The
objectives for each sampling or monitoring point and the representativeness of the
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TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
particular point are summarized in Table 5. A summary of the overall sampling and
monitoring plan for each test run is presented in Table 6.
A sample of the waste feed soil will be collected and analyzed for PCBs, dioxins, biphenyl,
and volatile organic compounds (VOCs ). A treated soil sample and a treated hydrocarbon
liquid sample will be collected at the end of the reaction for each test run. These samples
will be analyzed for PCBs, dioxins, biphenyl, and VOCs. During the first two processing
runs, one additional treated soil and one additional treated hydrocarbon liquid sample will
be taken for a quick turnaround analysis. These results will be used to make adjustments to
the processing conditions for the remaining runs. Three air emissions samples will be taken
per run at the locations specified in Table 6.
Other parameters vital to the evaluation of the process effectiveness are the temperatures
of the reactions in the MTID and the LTR; LTR influent and effluent volumes; weight and
volume ratios of NaOH, hydrocarbon oil, and catalytic reagent to the PCB-containing fluid
in the LTR; LTR off-gas temperature and flow; VRS exhaust stack gas temperature and
flow; and the volume of condensed water from the VRS. Temperatures of the reactions will
be measured in degrees Fahrenheit using a calibrated thermocouple and monitored through
a digital display. The untreated soil will be weighed on the conveyor before processing. The
weights of NaOH and hydrocarbon oil, and the weight of the catalyst used in the LTR will
be recorded in the field log book.
Time ( on a 24-hour clock) of each action or observation which is part of the system
operation will be recorded in the field log book. This will include, but not be limited to, the
time of addition of each component to the reactor; the times when the mixing is started,
interrupted or stopped; when the heat application is started, interrupted or stopped; when
each soil and/or solvent sample is collected; when the temperature recorder is started; and
when periodic temperature readings are entered in the log book.
6.0 SAMPLING PROCEDURES
Sampling of the treated and untreated soil, treated and untreated liquid phases, and air
sampling will be involved in the pilot study.
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Dry Soil Sampling
TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
Prior to the start of each batch run, the waste feed soil will be removed from the rolloff
container and transferred to the weighing conveyor. Using a decontaminated trowel, a
sample of the waste feed soil will be transferred and collected into 4-ounce wide-mouth jars.
These jars will be labeled and shipped by overnight courier service to the analytical
laboratory for analysis.
Liquid Phase Sampling
Before and after each LTR run, a liquid sample will be withdrawn from a tap on the LTR.
The liquid will be transferred to 40 mil VOA vials. These jars will be labeled and shipped by
overnight courier service to the analytical laboratory for analysis.
Air Phase Sampling
The system includes non-contact condensers, two chilled condensing units, an activated
carbon polishing unit, and an oxidizer polishing unit. Possible contaminants are PCBs,
dioxins, semi-volatile organics compounds (SVOCs ), VOCs, and PCDD and PCDFs.
Air samples will be taken at three locations: the MTTD off-gas exhaust to the VRS, after
the activated carbon canister, and at the VRS exhaust stack to the atmosphere.
The offgas exit line will be modified to accept 4-inch polyvinyl chloride (PVC) tubing. The
tubing will be routed to facilitate sampling. Ports will be installed at appropriate distances
to comply with the EPA Method 1. Gas velocity and temperature will be measured with a
standard pitot and thermocouple as specified in EPA Method lA. The gas samples will be
collected by either standard EPA stack sampling methods as published in 40 CFR Part 60
(Standards for Performance for New Stationary Sources, Appendix A, Reference Methods)
or methods outlined in the methods manual for compliance with the BIF regulations (EPA
1991a).
Samples for SVOCs will be collected by an MM5 sampling train, M0OlO in SW-846.
Samples for PCDDs and PCDFs will be collected by M23 (EPA 1991a). The sampling
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TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
approach and requirements for both MM5 and M23 are identical. Differences exist in the
preparation and recovery of the trains. Method 23 has more stringent requirements for
preparing the filter and XAD-2 resin than does M00lO.
For each test run, the following material will be recovered from the MM5 and the M23
sampling trains as described in M00lO and M23:
•
•
•
•
•
•
rinsate from the sample probe and the front half of the filter holder
the filter
the XAD-2 resin sorbent module
liquids collected in the 1-liter condensate trap
rinsate from components between the back half of the filter holder and the
condensate trap.
the final toluene rinse from M23
The recovered material will be extracted and analyzed for SVOCs or dioxins and furans.
Each sampling train will generate several samples; however, the extracts of each sample will
be combined to produce one final analytical sample per train.
The BIF Method 050 sampling train (EPA 1991a) will be used to measure particulate
HCl/Clz and moisture content of the gas stream. This sampling is similar to the MM5/M23
train described above, with the following exceptions:
• The water cooled condenser and sorbent module are removed.
• The impinger train will consist of five impingers. The first is empty. The
second and third will contain lO0mL of 0.1 N sulfuric acid. The fourth
impinger will contain lO0mL of 0.1 N sodium hydroxide. The last impinger
will contain silica gel as a final water trap.
VOCs will be collected using Summa passivated canisters for analysis by GC/MS following
the general guidelines of EPA Compendium Method TO-14 (Compendium of Methods for
the Determination of Toxic Organic Compounds in Ambient Air, June 1988).
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TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
Preparation of Sampling Equipment
Sampling equipment used in the field such as spoons or shovels for soil sampling, ladles and
glass beakers, etc. for liquid/solvent sampling shall be cleaned according to the following
procedure:
1.
2.
3.
4.
5.
Remove gross soil from the surfaces of the equipment with a dry brush or
scraper.
Wash item in tap water with laboratory grade non-phosphate detergent.
Rinse thoroughly with tap water.
Rinse thoroughly with ASTM Type II deionized (DI) water.
Rinse with methanol.
6. Rinse with hexane.
Rinse with diglyme.
Allow to air dry.
7.
8.
9. Wrap with clean aluminum foil, shiny side out for later use.
Preparation of Sample Containers
Precleaned sample containers will be obtained from Triangle Laboratories, Inc: and/or a
reputable supplier of such containers.
Sample Preservation
Samples shall be cooled and maintained at a temperature of 4°C until they are analyzed.
This will be accomplished by storing and shipping the samples on ice.
Sample Designation
Sample tracking will be accomplished by assigning each sample a unique number as it is
collected in the field. This number will be traceable back to the day, time, and site of
collection and the corresponding process conditions under which it was taken. A master log
of the identification numbers will be maintained by the on-site crew chief. A label will be
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TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
attached to all sample containers at the time of collection. The label will be completed in
indelible ink and contain the following information:
• Date and time collected
• Project name
• Type of analysis ( -ses)
• Sample identification number
• Preservation
• Matrix and method of collection
• Name or initials of collector
Sample Custody
A critical aspect of sound sample collection and analysis protocols is the maintenance of
strict chain-of-custody (COC) procedures. COC procedures include inventorying and
documentation during sample collection, shipment and laboratory processing. A sample is
considered to be in an individual's custody if the sample is: 1) in the physical possession or
view of the responsible party, 2) secured to prevent tampering, or 3) placed in a restricted
area by the responsible party. The crew chief will be responsible for the custody of the
samples collected until they have been properly transferred to a courier service or directly to
the laboratory. A COC form will be used to document the integrity of all samples.
Sample Packaging and Shipping
All glass sample containers will be wrapped with plastic bubble wrapping material and
placed in individual plastic isolation bags to prevent contact with other sample containers.
Samples will be packaged in thermally insulated, rigid coolers, in accordance with applicable
DOT specifications. All samples collected during the course of this project will be shipped
to:
Triangle Laboratories, Inc.
801 Capitola Drive
Research Triangle Park, North Carolina 27709
[phone]
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Documentation and Corrections
TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
Daily logs will be kept during field activities by the on-site ETG crew chief or his designate
in a bound notebook of water resistant paper. All entries will be made legibly, in indelible
ink, signed, and dated. Unless restricted by weather conditions, all original data recorded in
field notebooks, sample ID tags, COC records, and receipt-of-sample forms are written in
waterproof ink. These accountable documents are not to be destroyed or thrown away,
even if they are illegible or contain inaccuracies that require a replacement document.
If an error is made on an accountable document assigned to one person, that individual may
make corrections simply by crossing out the error and entering the correct information. The
erroneous information should not be obliterated. Any error discovered on an accountable
document should be corrected by the person who made the entry. All corrections must be
initialed and dated.
7.0 ANALYTICAL PROCEDURES
7.1 Analytical and Calibration Procedures
Standard analytical procedures (EPA Test Methods for Evaluating Solid Waste SW-846 3rd
edition) will be used to analyze the solid and liquid samples whenever possible. If it becomes
necessary to develop special procedures under the pilot study conditions, the reliability of
these procedures will be verified and documented.
For untreated solid and liquid samples, the standard SW-846 Method 8080 will be used for
analysis following preparation of the samples by SW-846 3580 (liquids) or 3550 (solids).
Solvent samples will be diluted and analyzed directly. The SW-846 Method 8270 will be
used to analyze liquid and solid samples for the semi-volatile organic compound biphenyl.
The SW-846 Method 8260 will be used to analyze the waste feed and treated soil for VOCs.
For air samples, the following table summarizes the methods chosen for the analysis of each
parameter. Most of the parameters will be analyzed using EPA-approved methods (SW-
846) or Standard Methods for the Examination of Water and Wastewater (APHA, A WW A,
WPCF, 1989).
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TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
METHODS FOR GAS SAMPLES
Parameter Preparation Analysis
Methods Method
PCDDs/PCDFs 8290 8290
SVOCs 3540 8270
Particulate EPAMethod5 Gravimetric
voes 8240 8240
HC1/Cl2 EPA SW-91-010 EPA300
Moisture Content EPAMethod5 EPAMethod4
7.2 Analytical Procedures
Solid samples will be prepared by extracting with 1:1 methylene chloride:acetone using
sonication. The extract will be concentrated and exchanged into hexane. A surrogate
standard will be added prior to extraction, although dilutions may be required which will
impact recovery. Solvent samples will be diluted and analyzed directly. surrogate standards
will be added to monitor retention times and injection technique. The PCB extract will also
be analyzed by GC/MS (SW-846 Method 8270) for biphenyl. Internal standards will be
added prior to injection.
7.3 Calibration Procedures
Calibration will be performed for Aroclor 1260 by initially analyzing at least three standards
at a low, mid-point and high concentration. The initial calibration will be verified daily by
the analysis of the mid-point standard. Criteria for the initial calibration require the relative
standard deviation (%RSD) to be less than 30%. The continuing calibration must have a
calibration factor (CF) within +30% of the average CF from the initial calibration. GC/MS
calibration for biphenyl will be performed using three standard concentrations and
generating the average response factor (RF). The relative standard deviation (%RSD) for
the three RFs will be less than 30%. Calibration will be verified daily by the analysis of the
mid-point standard. The RF of the continuing calibration relative to the average RF from
the initial calibration will have a difference of less than 35%.
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7.4 Quantitation
TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
Untreated samples will be quantified for PCBs using SW-846 Method 8080. Calculation of
the concentrations in untreated samples will be in accordance with the method using several
key peaks in the Aroclor 1260 chromatographic pattern. However, the treated samples will
no longer have a recognizable PCB pattern due to the dechlorination of some or all of the
congeners. Rather than report all such samples as "not detected" for PCB Aroclor 1260, the
largest peaks (three to five) in the chromatogram which have a retention time (RT)
corresponding to any of the peaks in the Aroclor 1260 standard will be used to estimate a
PCB concentration. In addition, a "total PCB" value will be calculated for both treated and
untreated samples using the total area of the chromatogram. Biphenyl will be quantified
using the GC/MS analysis, which will also provide some information on specific congeners
for selected samples.
7.5 Data Reduction, Validation and Reporting
Accurate and detailed recordkeeping and reporting of all events, data generated and
information connected with the proposed testing will be an integral part of the Standard
Operating Procedures (SOPs) for the project. This section provides an overview of the data
reduction, validation, and reporting plan.
Data Reduction
All measurement system outputs ( e.g., absorbance units, peak areas, etc.) must be reduced
into units which are consistent with the methods and which meet the comparability
objectives. In general, all raw data are recorded in laboratory notebooks or on worksheets
in standardized format by the analyst performing the test. Each analytical method contains
detailed instructions and equations for calculating the respective analyte concentration. All
results will be calculated on a dry weight basis.
Results of the PCB and other chemical analyses of soil and liquid will be summarized and
reported in standard units such as ppm or ppb. The soil mass, before and after each run,
will be reported in pounds. The mass of the reagents and catalyst used per run will be
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TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
reported in pounds. Temperature measurements will be in °F. Time will be recorded on a
24-hour basis.
PCB destruction and removal efficiencies will be calculated on a mass basis. The modified
EPA Method 8080 that will be used for PCB analysis will generate concentration data on a
dry weight basis for several key peaks of Aroclor 1260 in a given batch. The sum of these
concentrations will be considered as the total PCB concentration in that sample. The
equations listed below will be used to compute PCB removal efficiency in a given batch run.
where,
CSOILa
CSOILA
csoili
csoilj
n
m
MPCBa
MPCBA
MSOILa
MSOILA
11 M
CSOILs =2.csoih· CSOILA =Ecsoilj
i "I j: I
Removal Efficiency (in percent) = {1 -(MPCBAIMPCBA)} x 100
=
=
=
=
=
=
=
=
=
=
concentration of total PCBs in the before treated soil, ppm
concentration of total PCBs in the after treated soil, ppm
detected concentration of the ith PCB component in the before treated
soil, ppm
detected concentration of the jth PCB component in the before treated
soil, ppm
number of components detected in the before treated soil
number of components detected in the after treated soil
total mass of PCBs in the before treated soil, mg
total mass of PCBs in the after treated soil, mg
total mass of the before treated soil, mg
total mass of the after treated soil, mg
The equations listed below will be used to compute PCB destruction efficiency in a given
test run.
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TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
Destruction Efficiency (in%)= {1-(MPCBA/MPCBB)} x 100
where,
CSOILa
CSOILA
CSOLA
csoili
csoilj
n
m
p
MPCBa
MPCBA
MSOILa
MSOILA
VSOLA
=
=
=
=
=
=
=
=
=
=
=
=
=
=
Data Validation
concentration of total PCBs in the before treated soil, ppm
concentration of total PCBs in the after treated soil, ppm
concentration of total PCBs in the residual solvent after treatment,
mg/I
detected concentration of the ith PCB component in the before treated
soil, ppm
detected concentration of the j1h PCB component in the before treated
soil, ppm
detected concentration of the kth PCB component in the residual
solvent, mg/I
number of components detected in the before treated soil
number of components detected in the after treated soil
number of components detected in the residual solvent
total mass of PCBs in the before treated soil, mg
total mass of PCBs in the after treated soil and the residual solvent, mg
total mass of the before treated soil, mg
total mass of the after treated soil, mg
total volume of the residual solvent, 1
The measurement data generated by the analyst are validated in several ways. Strict
adherence to the analytical methods, and ensuring that the instrumentation employed was
operated in accordance with defined calibration procedures, are critical functions to
determine the validity of the data.
Documentation of field sampling and laboratory analyses will be performed in order to
assure data validity. These procedures include
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TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
Maintenance of field logbooks containing information pertinent to the field
sampling program and the equipment operations, including temperature
monitoring and reagents dosing regime. Field logbooks will be bound and
entries will be made in ink. Corrections will be made by drawing a single line
through the incorrect entry and dating and initiating the correction. Field
logbooks will be signed, dated and maintained by the operators during field
activities and transferred to the project files for a record of sampling and field
operations.
Implementation of a Chain-of-Custody record procedure for all samples
collected during the pilot study to assure the identification and tracking of a
sample throughout the collection/analysis process.
Recording of data related to sample preparation and analysis, as well as
observations by laboratory analysts will be permanently recorded into bound
laboratory notebooks. Laboratory notebook pages will be signed and dated
daily by laboratory analysts. Corrections to notebook entries will be made by
drawing a single line through the incorrect entry and dating and initialing the
correction. Corrections will be initialed and dated by the analyst.
Within the laboratory, raw data reductions will be verified by an independent analysis by a
section QA specialist. Any problems or errors discovered during this review will initiate a
100% review of the batch.
Data Reporting
All original laboratory data will be recorded in a permanent manner, and will be readily
traceable, through all steps of the data generation/reduction/validation/review process.
Field measurements will be recorded in appropriate field notebooks, and results will be
reported in tabulated summary form.
Laboratory data will originally be reported by the analyst on analysis specific report forms.
After the data has been reviewed, validated, and approved by a senior technical staff
member, the final report will be approved by the laboratory director prior to being issued.
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8.0 MONITORING PROCEDURES
TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
Temperature of the reaction, mass and/or volume of the reactants/products, off-gas and
exhaust gas flow rates and temperatures, and time are the parameters that will be
monitored and documented during each test run.
A thermocouple with output leads connected to a real time temperature indicator,
controller and logger will be used to monitor and control temperature of the reaction. At
specified timed intervals, temperature readings will be entered into the field log book by the
operator.
Mass of the reactants and/or products involved in the reaction will be measured as shown in
Table 6. These measurements will be entered into the field log book by the operator.
The time (using a 24-hour clock) of each action or observation which is part of the system
operation will be recorded in the field log book. This will include the time of addition of
each component to the reactor; the time when the mixing operation is started, interrupted,
or stopped; when the heat application is started, interrupted, or stopped; when each soil
and/or solvent sample is collected; when the temperature recorder is started; and when
temperature readings are taken.
9.0 WASTE HANDLING AND DISPOSAL
All wastes containing PCBs generated during the pilot study will be handled, stored and
disposed of in accordance with 40 CFR Part 761. This will include personal protective
equipment, sampling equipment, decontamination materials, and sorbent materials used for
spill cleanups. The waste will be shipped to the Chemical Waste Management facility in
Model City, New York. The waste will be properly manifested and transported by an
authorized waste hauler.
10.0 DATA REPORTING AND RECORDKEEPING
All original laboratory data will be recorded in a permanent manner and will be readily
traceable through all steps of the data generation/reduction/validation/review process. Field
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TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
measurements will be recorded in appropriate field notebooks and results will be reported
in tabulated summary form.
Laboratory data will originally be reported by the analyst on analysis specific report forms.
After the data has been reviewed, validated, and approved by a senior technical staff
member, the final report will be approved by the laboratory director prior to being issued.
Within 90 days after receipt of final validated data, ETG will issue a final report to DEHNR,
the Working Group, and EPA. The report will include all analytical results and will describe
in detail the pilot test, the procedures used to select and monitor the process operating
conditions, the Quality Assurance Review, and the handling and disposal of the waste and
equipment used in the pilot study.
11.0 INSPECTION PROCEDURES
Inspection procedures during the pilot study will be performed daily and documented by the
field supervisor. The equipment status of the feed hopper, the weighing conveyor, the
MTTD unit, the vapor condensing system, the LTR, the cooling conveyor, the condensate
storage tanks, the feed cutoff system, the pollution control system, process alarms, and the
fire extinguisher system will be evaluated. The system will not start operation or will be
shutdown until equipment problems or malfunctions are corrected.
12.0 SPILL PREVENTION CONTROL AND COUNTERMEASURES PLAN
All liquid reagents and solvents will be securely stored and carefully handled by properly
trained personnel. Liquids will be stored close to the ground to reduce the potential for
dropping and breakage. Transferring liquids from one container to another will be done
either close to the ground or on a work bench surface. A dedicated pump will be the
preferred method of transferring liquids.
Solids handling will use appropriately sized scoops/spoons. When handling dry soils,
appropriate precautions will be taken to ensure that airborne dust is not generated.
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TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
Spilled liquids will be soaked up immediately using commercially available sorbent material.
Sorbent material containing liquid will be carefully swept up and placed in properly marked
hazardous waste drums.
In the event of a soil spill, the waste will be swept up without creating a cloud of dust. The
soil will be placed back into the rolloff container. Finer soils will be collected with a HEP A
vacuum filter. Filter bags from the HEP A unit will be placed in a drum for proper disposal.
The U. S. Coast Guard regulations applicable to PCBs or PCB-containing materials
specified in 40 CFR Part 112. 7 will be followed where applicable.
13.0 HEALTH AND SAFETY PLAN (HASP)
The health and safety plan identifies the requirements for site safety for ETG employees
and visitors to the site. The plan complies with OSHA's Health and Safety Standards and
addresses protection of workers and others from PCB exposure and provisions for
emergency situations. If the pilot study activities change, the plan will be revised.
13.1 Organization and Responsibilities
A Site Safety Coordinator will be assigned who will be on-site at all times during the pilot
study. The Site Safety Coordinator will report directly to ETG's Health and Safety Manager
and shall have the authority, independent of the Project Manager, to shutdown any and all
site activities in the event of unsafe or potentially unsafe conditions. Responsibilities of
various individuals are described below.
Project Manager
Mr. Mitchell Moss is assigned as the Project Manager (PM) and will coordinate on-site
health and safety activities. Primary health and safety responsibilities include:
• Assuring that personal protective equipment (PPE) is available and properly
used.
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TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
Assuring that personnel are aware of the provisions of the HASP, are
instructed in the work practices necessary to ensure safety, and are familiar
with emergency procedures.
Supervision of the safety performance by all personnel to ensure that safe
work practices are employed.
Correcting conditions that may result in injury to personnel or exposure to
hazardous substances.
Health & Safety Manager
Mr. Rick Crosby is assigned as the Health and Safety Manager for this project. He is
responsible for the health and safety of all workers on this project and will report to the
Project Director and the Project Manager about health and safety activities and concerns.
Mr. Crosby will provide technical information and assistance to the PM on the hazards of
wastes, chemicals and materials involved in the project and those related to the operation of
the THERM-0-DETOX!BCD system. He will also provide information for measuring and
controlling exposure to toxic or unsafe components.
Mr. Crosby will conduct training of project team members on the subject of potential
hazards and provisions for exposure monitoring, use and care of PPE, and on the specific
requirements of this plan. He will perform an on-site audit and ensure adequate health and
safety precautions are being taken. While not on-site, Mr. Crosby will designate a Site
Safety Coordinator to carry out the necessary health and safety procedures. Additional
duties and responsibilities will include:
• Reviewing the health and safety monitoring and incident reports submitted by
the Site Safety Coordinator
•
•
•
Coordinating with the PM and Site Safety Coordinator to address any safety
problems
Determining what level of PPE protection will be used at the site under the
conditions as reported by the Site Safety Coordinator
Supervising the purchasing of safety and emergency supplies and equipment
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October 30, 1995
Site monitoring to identify the extent of hazard and to document exposures of
ETG employees and other people at the site
Assuring that all project personnel have current hazardous waste training and
medical monitoring
Site Safety Coordinator
Mr. Kevin Brentlinger will be the Site Safety Coordinator (SSC) and will be responsible for
implementing the details of the HASP. As the full-time representative of the Health &
Safety Manager, the SSC will have authority to suspend site activities until safety and health
issues arising during the pilot study are satisfactorily resolved. The duties of the SSC also
include:
13.2
• Enforcement of all health and safety procedures at the site
• Upgrading PPE levels depending on site-specific conditions
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Obtaining emergency assistance
Preparing and submitting incident reports
Conducting daily review of key aspects of the HASP to respond to changes in
weather or operational conditions
Ensuring the proper cleaning and maintenance of PPE
Maintaining OSHA Forms 102 and 200 ( occupational illnesses and injury)
and records of individual site assignment and exposure monitoring results
Hazard Characterization and Levels of Protection
Exposure limits and recognition signs for identifying hazards associated with compounds
involved in this project are summarized in Table 7. Health effects resulting from exposure
to these hazardous compounds and first aid treatments that need to be administered are
presented in Table 8. Health and safety monitoring methods and action levels at which
specific minimum protective measures will go into effect are listed in Table 9. Protective
equipment that will be used for various hazard levels are specified in Table 10.
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October 30, 1995
13.3 Emergency Procedures
An emergency is defined as an accident, illness, explosion, hazardous situation at the site, or
intentional acts of harm. While effective implementation of the HASP can minimize the
chances for occurrence of an emergency event, an emergency situation can not be totally
prevented. The field personnel will need to be prepared to respond to emergencies. To
ensure a timely response to an emergency, the SSC with assistance from the Health and
Safety Manager, will complete the following activities before the start of the pilot study.
•
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•
Locate the nearest telephone and check on-site communications .
Confirm and post emergency numbers and the route to the nearest hospital
equipped to handle emergency situations.
Post site map marked with locations of emergency equipment and supplies .
Test drive route to hospital.
• Evaluate capabilities of local response teams.
•
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•
Designate one vehicle as the emergency vehicle and keep car keys readily
accessible to field personnel.
Inventory and check out emergency equipment and supplies
Review response action plans .
The SSC will be the first person to respond to an emergency unless he himself is involved in
an accident. The SSC shall be responsible to summon assistance from local response teams
and initiate first aid or decontamination where appropriate. He should also be responsible
for reporting the event to the Health and Safety Manager and the PM, preparing a formal
incident report, and notifying the injured person's office and other authorities.
14.0 TRAINING PLAN
All personnel involved with the testing operations or sampling will be fully trained.
Personnel will have received the OSHA 40-hour Health and Safety Training for Hazardous
Waste Site workers. In addition, prior to start-up, ETG will conduct project-specific training
for field personnel which will include:
• Equipment operation (in accordance with standard operating procedures)
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Emergency shutdown procedures
Review of the HASP including
TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
Hazards of PCBs and all chemicals to be used
Material Safety Data Sheets (MSDSs) for these chemicals
Use of protective equipment
General safety procedures
Waste handling
Fire control
Recordkeeping
Reporting requirements
15.0 DEMONSTRATION TEST PLAN
The pilot study will consist of the batch processing of nine or ten cubic yards of waste soil. A
batch will be approximately three cubic yards. The first batch will consist of relatively dry
waste soil from the top portion of the contents of the rolloff container. The second batch
will be about the same weight but with a greater moisture content. This batch will be taken
from the mid-level soils in the rolloff. The third batch will also be of approximately the
same weight but with a high moisture content. These soils will be taken from the bottom of
the rolloff.
16.0 TESTDATA
The THERM-O-DETOX system has been used successfully at nine sites to date and has
treated more than 50,000 tons of soils and sludges impacted by herbicides, pesticides, PCBs,
PCP, dioxins, and furans. The system has been used at several refineries to process K048 -
K052 hazardous wastes to meet RCRA Universal Treatment Standards and Best
Demonstrated Available Technology standards. ETG is also operating batch and
continuous thermal desorption systems at a fixed base facility in Cleveland, Ohio.
As mentioned in the introduction, ETG conducted a SITE demonstration of the THERM-
O-DETOX technology in September 1993 at the Koppers Superfund site in Morrisville,
North Carolina. Approximately twelve tons of soil contaminated with PCP, PCDD, PCDF,
and isopropyl ether were treated at the Koppers site. Seven thermal desorption test runs
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October 30, 1995
were made. Four runs were for the purpose of determining process parameters. Three runs
were for the performance verification. Two liquid BCD test runs were conducted in the
LTR.
PCP in the treated soil was reduced from an estimated concentration of 1,600 to 8,100 ppm
to a non-detect level of below 1 ppm. PCDD/PCDF in the soil was also treated to non-
detect levels. PCP concentrations in the BCD oil ranged from 140,000 to 2,100,000 ppb.
PCP was not detected in the treated oil samples. PCDD/PCDF in the oil was treated from a
total of 68,000 to 96,000 ppb to below 1 ppb. Based on the results of the demonstration test,
Region IV has selected BCD as the permanent remedy to replace incineration at the
Koppers site. Table 11 shows data from the treatability test, a soil treatment run, and a
BCD oil treatment run.
17.0 OTHER PERMITS/APPROVALS
The Warren County PCB landfill was operated and closed under a TSCA permit, therefore
the implementation of this pilot study requires the approval of this permit application by the
EPA Regional Administrator, EPA Region IV, Atlanta.
At this time, it is believed that air emissions from the test will be below allowable levels and
it is not anticipated that an air permit would be required. However, North Carolina
DEHNR will be monitoring ambient air quality during the pilot study and has the option to
require an air permit should conditions warrant.
18.0 SCHEDULE OF EVENTS
Mobilization
Setup and Shakedown
Pilot test runs
Demobilization
Submittal of preliminary demonstration test results
Submittal of final demonstration test report
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mid-March 1996
mid-March 1996
late March 1996
late March 1996
mid May 1996
end June 1996
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19.0 QUALITY ASSURANCE PLAN
TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
To assure that data collected and generated during the pilot study of the BCD process meet
specific quality objectives and to assess the quality of monitoring systems, the following
Quality Assurance Plan (QAP) specific to this project is described in the following sections.
The QAP complies with the Interim Guidelines and Specifications for Preparing Quality
Assurance Project Plans (USEP A 1980).
19.1 Project and QA Organization
ETG will be responsible for the overall quality assurance of the data gathered during the
pilot study. Analytical laboratory services will be subcontracted to Triangle Laboratories,
Inc., 801 Capitola Drive, Durham, North Carolina.
19.2 Quality Assurance Objectives
The data quality objectives established for the pilot study are based on project deliverables
and are designed to ensure that the data generated during the tests are of known and
acceptable quality to achieve the project's objectives. Critical measurements to determine
the feasibility of the BCD process at this site will be the concentrations of PCBs and dioxins
in the air, soil, and liquid waste streams and at various discrete units of the THERMO-O-
DETOX system. This section describes the QA objectives for each of the measurements in
terms of the data quality indicators: precision, accuracy, method detection limits,
representativeness, and comparability. The QA objectives are summarized in Table 12 and
apply to overall project analyses.
Data Quality Indicators
Precision objectives for PCBs and biphenyl are expressed as the relative percent difference
(RPD) between duplicate analyses.
To assess accuracy, laboratory control samples will be analyzed and recoveries will be used
for PCBs and biphenyl. Matrix spikes will be difficult to perform due to the elevated levels
of PCBs in the pre-treatment samples and due to the potential presence of mono-and
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dechlorinated biphenyls in the treated soil. While a matrix spike will be performed on the
treated soil and the results reported and discussed, QA objectives for accuracy will be
assessed by control sample analyses.
The method detection limits (MDLs) the various analyses are presented in Table 12. All
MDLs will be adjusted as necessary based on necessary dilutions, etc.
A well-defined sampling strategy ensures that the samples collected are representative of
the matrix/site at that given stage of the treatment process. Field QC samples are also
useful in assessing the representativeness of sampling activities. Equipment blanks will be
used to demonstrate that samples were collected using contaminant-free equipment.
Analyzing well-mixed subsamples within the laboratory, according to standard laboratory
procedures, ensures that the measurement data are representative of the sample and,
therefore, the process and system conditions being evaluated.
The use of standard, validated EPA methods achieves comparability of measurement data.
Reporting the data in standard units of measure as specified in the methods, adhering to the
method defined calibration procedures, and when possible meeting the method detection
limit, all contribute to the comparability of the data.
19.3 Monitoring Procedures
See Section 5.0.
19.4 Sampling and Data Collection Procedures
See Section 5.0.
19.5 Analytical Procedures
See Section 7.0.
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19.6 Sampling Procedures
See Section 6.0.
TSCA Permit Application
Warren County PCB Landfill
October 30, 1995
I 19.7 Internal Quality Control
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Reliable analytical measurements of environmental samples require continuous monitoring
and evaluation of the analytical processes involved, i.e., quality assurance. To ensure
optimum valid data generation, a scientifically sound quality control program must be
incorporated into the sample collection and analytical laboratory program and adhered to
strictly. Such a QC program employs a prescribed sequence of routine procedures to
control and measure the quality of the data generated. Specific quality control samples,
collected and analyzed by the appropriate methods, are introduced into the laboratory as a
check on the overall analytical system.
Field QC Blanks
Field QC blanks are used to demonstrate that samples were collected with properly
decontaminated equipment, and stored and shipped without cross-contamination between
samples occurring. Equipment blanks are reagent grade DI water which has been exposed
to the cleaned sampling equipment in a manner similar to the actual samples. An
equipment blank will be collected during each test run.
Duplicate Samples
Some samples, solid as well as liquid, will be collected in duplicate to assess sampling and
analytical variability and matrix homogeneity.
Matrix Spike/Matrix Spike Duplicate (MS/MSD)
The use of a matrix spike and matrix spike duplicate (MS/MSD) is a means of measuring
both precision and accuracy in an analysis. The analysis of an unspiked sample produces
sample data, and the analysis of the two spiked duplicate samples generates recovery data
(accuracy). Comparison of the results of the duplicate spiked samples with the results of an
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October 30, 1995
unspiked sample allows the calculation of the precision in terms of the relative percent
difference (RPD) between the two measurements. One pair of MS/MSD analysis will be
performed for PCBs, dioxins, biphenyl, and VOCs per treatment run.
Spiking the treated sample may be difficult depending on the remaining PCB congeners.
Similarly, spiking biphenyl into the treated sample may be difficult based on the biphenyl
concentration expected after dechlorination. However, at least one treated sample will be
spiked (in duplicate) with PCB Aroclor 1260 and one biphenyl MS/MSD will be analyzed
during the pilot study. Results will be evaluated, reported and discussed with final data from
the project.
Other QC Analyses
Besides MS/MSD analysis, the laboratory will perform other internal QC analyses at a
frequency specified by and in accordance with the protocol prescribed by the respective
analytical method. These analyses may include, but not be limited to, spiked blanks, method
blanks, QC Check Standards, and laboratory control samples.
19.8 System and Performance Audits
I Audits are an independent means of confirming the operation or capability of a
measurement system, and document the use of QC measures designed to generate valid I data of known and acceptable quality. An audit is by necessity performed by a technically
qualified person who is not directly involved with the measurement system being evaluated.
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A performance evaluation is generally an objective audit of a quantitative nature, whereas a
systems audit is a qualitative evaluation of the capability of a measurement system to
produce data of known and acceptable quality. Both types of audits will be performed
within the laboratory using samples collected during the pilot study.
The project QA Manager will review the overall project performance and complete a
Technical Systems Review of procedures and methods for taking critical measurements
specified in this QAP and perform a laboratory audit. Information obtained during this
audit will be relayed to the laboratory and field staff to ensure compliance with the QAP and
initiate corrective action if necessary.
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19.9 Calculation of Data Quality Indicators
The quality assurance objectives established for this project are presented in Section 19.2
and are measured by the analysis of the QC samples specified in Section 19.7. This section
provides the equations and data reduction procedures that will be used to obtain a
quantitative measure of precision, accuracy and method detection limit.
Precision
Precision is the ability of the measurement system to generate reproducible data. For most
parameters, precision is determined from the results of the analysis of duplicate samples
and/or spiked duplicates, and is reported as relative percent difference (RPD):
% RPD = {(Di-D2) X 2/(Di + D2)} X 100
where D1 and D2 are the two observed values (the spike and spike duplicate recovery values
for the given PCB congener or biphenyl).
For data sets of greater than two points ( e.g., triplicate field samples), the relative standard
deviation (RSD) will be determined according to the following:
% RSD = {Standard Deviation/Mean} x 100
Accuracy
Accuracy is defined as the nearness of the analytical result to the "true" value. Accuracy is
assessed by the analysis of matrix spikes (for most parameters) and reported as percent
recovery:
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October 30, 1995
where Ci is the measured concentration m the spiked sample, C0 is the measured
concentration in the unspiked sample and C1 is the known concentration of analyte added to
the sample.
Method Detection Limit (MDLs)
MDLs are determined based on the analysis of extracted low level spiked blanks. Multiple
spiked blanks at concentration approaching the estimated MDL are extracted and analyzed
according to method protocols. The MDLs are determined by calculating the standard
deviation of the multiple analyses time the student "t" value at n-1 degrees of freedom.
MDLs to be used for this project are summarized in Section 19.2 and are target values which
will vary based on sample matrix.
19.10 Corrective Actions
Strictly-defined sample handling procedures, calibration procedures, QC sample analyses,
and all associated acceptance criteria are all part of a comprehensive QA program which
enables recognition of situations which do not meet QNQC requirements. The specific
corrective action steps to be taken in response to failed analytical criteria will be established
by the laboratory QA Manager and will be confirmed with ETG's Project QA Manager.
19.11 Quality Assurance Reports to Management
The quality-related results, actions, and decisions described by this QAP require a reporting
mechanism to keep project management informed as to the project status. These reports
are intended to provide management with the information necessary to assess the adequacy
and success of the QA program.
Laboratory Reports
After each sampling event, the laboratory will prepare a summary of samples received and
the dates of extraction and analysis of samples. This summary will be submitted to the
Project QA Manager within two weeks after the receipt of the last sample in the batch. The
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summary will also note the extraction method employed for the samples. Separate reports
including but not limited to summarized results for each trial run will be required.
Monthly Reports
A monthly memo summarizing quality-related activities will be prepared by the Project QA
Manager and submitted to ETG's PM and Project Director. Information submitted in this
summary will include any proposed changes or modifications to the QAP, summary of field
QNQC activities, and an overall tentative assessment of data quality to date. Any proposed
deviation from the QAP will be approved by the PM and Project Director prior to
implementation. The reports will discuss any problem conditions and corrections and
corrective actions, audit events and results, sampling and analysis QNQC status, and a
general review of the achievement of data objectives for the project to date.
Final Report
The final report on the pilot study test of the BCD process submitted to USEP A, DEHNR,
and the Working Group will include a separate QA section that will document the QNQC
activities which lend support to the credibility and validity of the data generated. A
summary of the data quality information will be provided including an assessment of the QA
objectives which were achieved and which were not, why they were not, and what the impact
to the project is.
20.0 STANDARD OPERATING PROCEDURES
See Section 4.0.
21.0 CLOSURE PLAN
Upon completion of the pilot study, ETG will initiate decontamination of all pieces of
equipment and disposal of any wastes (including personnel protective equipment)
generated from the pilot study. Closure procedures will ensure that the possibility of
releases of or exposures to PCBs are eliminated.
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All equipment that comes in direct contact with PCB-containing soil and/or materials will be
decontaminated using the following procedure:
•
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Wash with Alconox and potable water.
Rinse with potable water.
Air dry .
After final decontamination of equipment, wipe samples will be collected to ensure that
adequate decontamination has occurred prior to demobilization. Once the decontaminated
equipment has been verified to be below the 10 ppb/100 cm2 level, it will be considered
clean and can be removed from the site.
Whenever the decontamination personnel are handling materials contammg PCBs,
appropriate protective clothing will be worn (see Section 13). This will include activities
such as waste handling, collecting samples, decontaminating surfaces, and cleaning spills.
Impermeable gloves and protective clothing will be worn at all time during the cleanup and
decontamination process.
Any waste material generated during the pilot study and decontamination will be collected
and disposed of in accordance with USEP A and North Carolina requirements. Excluding
unused soils, the maximum amount of solid PCB waste which may be generated during the
project is estimated to be five DOT 17H drums. These drums will contain contaminated
PPE, disposable sampling equipment, and other PCB contaminated materials. It is
estimated that an additional five 55-gallon drums of PCB-contaminated rinse/decon water
will be generated.
Contents of the PCB containing waste drums will be sampled and analyzed to establish
waste profiles that meet TSCA and RCRA requirements. The waste will be shipped to the
Chemical Waste Management facility in Model City, New York.
It is estimated that the total cost of closure activities for this project will be on the order of
$20,000. This estimate includes
• labor for decontamination and dismantling and demobilizing equipment
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TSCA Permit Application
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October 30, 1995
transportation of waste drums to the disposal facility
disposal of waste
waste analysis
paperwork associated with waste profiling
The PM will be responsible for ensuring that all activities will be performed in accordance
with this plan. He will oversee and ensure proper containerizing, labeling, handling, and
manifesting all waste and residues generated from this project. The PM will be responsible
for signing all required paperwork including manifest forms that accompany shipment of
waste drums.
ETG will be financially responsible for all estimated closure costs. Documentation of
fiduciary responsibilities will be submitted in a separate package.
42
-------------------FIGURE 1 -PROJECT ORGANIZATION CHART NCDEHNR RALEIGH, NC WILLIAM MEYER DIRECTOR PROJECT MANAGER ETG MITCHELL MOSS OPERATIONS SUPERVISOR QUALITY ASSURANCE SAFETY OFFICER ETG ETG ETG ELI CLEVENGER DR. YEI-SHONG SHIEH KEVIN BRENTLINGER ANALYTICAL LABORATORY '---TRIANGLE LABS, INC. ~ DONALD HARV AN
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SR1613
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Road
~--~~-3 mile --------------~------
- -- -- ------------ - -CONT AMINA TED SCREENED SOILS ~-10 200 Sf CHILLER r-?it'i7\ fi>I CONDENSING '-t' 't' i UNIT @. r TO ATMOSPHERE FEED HOPPER DECHLORINATION REAGENTS (If REQUIRED) .c::,_r,.. V V FEED CONVEYOR HEAT SOURCE 5.5MM BTU/HR s,\o BCD SOLIDS REACTOR MEDIUM TEMPERATURE THERMAL DESORPTION (MTTD) VAPOR DISCHARGE WATER SPRAY COOLING UNIT B-10 ~ ~DAY TREATED WATER RECYCLED OH-SITE ON-SITE BACKFILL OR -Off-SITE DISPOSAL DECONTAMINATED SOLIDS CONTAINER 0 NOTE: VAPOR RECOVERY SYSTEM CAN BE MODIFIED FOR SPECIFIC CONDITIONS. gc;;:i~ Cs O ~ ENVIRONMENTAL, INC. Date: 10/5/95 Orawln_g_ No.: -4O25B.DWG Drawn By: M. Brocker 0 AQUEOUS CONDENSATE STORAGE CARBON ADSORPTION BAG FILTER 20-50 SCfM .__ ___ __, LTR PURGE OILY CONDENSATE STORAGE VENT AND EMERGENCY RELIEF 5 CfH DECHLORINATION REAGENTS 1 ('2?-r INERT GAS ,. n"" PURGE 70 GALLONS/ BATCH I TREATED OIL/HC RECYCLED Off-SITE BCD/THERM-0-DETOX• BATCH VACUUM SYSTEM Reference: NA FIGURE 3
-------------------2" Stack Sampling Port~ ..... 1 0 ~ ..-c=J~~ ----[S O ~ ENVIRONMENTAL, INC. l 0 N ..-J 26' 3" Date: 10/9/95 Final Condensers (2) Condenser. Vacuum Pump (1) Circulating Pumps (2) Polishing Oxidizer -Process Stack ~-~--,..__ -_-_.::::=--_.::::=-~~1 0 co I ¼I 1® "11/.1~ 11 Control Panel 48' O" Chiller System____:i 26 feet aboveJ ground level Cooling Tower 4" Diameter -Process Stack Cooling Tower Chiller System, \ > ' ' n Reference: NA Drawing No.: BATCH2.DWG THERM-O-DETOX ®BATCH VACUUM UNIT #1, TRAILER CONFIGURATION FIGURE 4 Drawn By: M. Brocker/G. Chin
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FIGURES
WARREN COUITTY PCB LANDrn.L SITE
And Sunounding Vioiniry
0 1200FEET -c:-----)Iii:•• @ :
--T _,_c-•o.....--•-,11---• ...._.c~ • ~n,--
ATTACHMENT lA
---------------------TABLEl PHYSICAL CHARACTERIZATION OF PCB CONTAMINATED SOILS IN WARREN COUNTY Physical Properties of Landfill Contents -Standard Soil Test Soil Class HM% WN CEC 85% Ac pH P-1 K-1 Ca% Mg% Mn-1 Zn-1 Cu-1 Min 0.1 0.96 1.2 69 0.4 5.4 011 18 38.2 24.4 90 146 60 / EXHIBIT 1
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TABLE2
Physical Properties of Landfill Contents -Quality Test
NORTH CAROLINA DEPARTMENT OF TRANSPORTATION
DIVJSION OF HIGHWAYS
MA T£R1Al5 & TEST UNIT
SOILS LABORATORY
T.LP. ID NO.:
REPORT ON SAMPLES OF: SOIL FOR QUALITY
PROJECT: MISC.
DATE SAMPLED:
SAMJ>L'ED FROM:
COUNTY: WARREN
07/28/94 RECEIVED: 0IUOl/94
PCB LANDFILL
OWNER:
.R.'£POR1'ED: 08/0~/94
DY: -
SUDMITIED BY: 1990 STD. SP£CJFICATJONS
TEST H..£S UL TS
08/)2/94
PHOJ. SAMPLE NO. WL--002-LC
LAD. SAMPLE NO. 587075
Rct:aincd 114 Sic,·c •✓ .. 2
P:assin!! #/JO Sieve -✓• 9S
Passini! #40 Sic\'C •✓ .. 71
P:minl! #200 Sieve •/• 2M
MINUS #10 FRACTION
SOIL MORTAR-JOO%
Cu:1rsc S:11uJ Rel -IIGO •/., .C4
Fine Sand Rel -#270 o/o 30
Sill 0.05 • 0.005 mm •/., 9
Cl:iv < 0.005 mm •;., 17
Pilssinf #40 Sieve e;., -
P~s.sine #200 Sieve e;. -LL .. 25
P.L 11
AASHTO Cl:assific:ition A-l--1(0)
Terture
St:ition
Hole No.
Dcolh (Fl)
to
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EX'H TBIT l A
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I CHEMICAL CHARACTERIZATION OF PCB CONTAMINATED SOILS IN WARREN COUNTY
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IQh~mt¢tIJae.nUfieit.ion:t rP<in~e."fitrijtion·. :':YJtr:::••
PCB (all congeners) Average 350 ppm
{Range 151 to 880)
Chlorobenzene 60 ppb
1,3 Di-chlorobenzene 23.9 ppb
1 ,4 Di-chlorobenzene 48 ppb
Arsenic 2 ppm◊
Barium 23 ppm◊
Chromium 12 ppm◊
Lead 35 ppm◊
◊ TCLP results did not exceed standards.
EXHIBIT2
--------~~---------EMERGENCY SHUTDOWNS •,:.,-:-·i..~ ,~:•:t.:..;;«·°lcJ:,,;'"·'t.:.p_. 1·:.,L;n•, .. r ••. 1 ·.•,.., · .. ,:·/#'-" .... ,,.-; :•' _.·,\\"¼'(..:,., 1--~ ·': ~.: '·-i,:'.::•.-·,'.".,11(.y . ... !;.~ ,.,f} ·\:.. .:.'i'-• •. J~.f~.-... -,1 .. }I .'·,'"-'"i' ,}·.; ~:. I 'f ,:;._.c~· .. ,.-,';.-, 1' .. ~-• , ' l -~~'•t•·' ·.; ' .-~ -•.1·\, ·► M~,i~~SIJ:UATIONIINDICATION_":.:t/:!;;&t• l-:;";i./->":~:·.1g_t;'-.fi.lJMPACT;itf:~\;~·IliPl~1i :f~~i-i~/~:.. ACTIONSTO'fB£:TAKEN/< rt\:..-. { 1::-);~~t}} ,.,,..~~,:~~~~ ---·-• ,_ ··· -·~• • ,-.-.. ,•~·l·-,•,r,.,.,. . ..,.1 .,,·,--,-,, .. .,_,.. ·--:-~---,.,., .)~' -~""-··•·•·:·,.:;,t.·.,.,,•."'-··'-""-;::c;--,.,i f·""-;~~r"".I.::.:·, .. ,-, .. ,, .~•, •.. _-,,., .. ,,··~· .. ,,,,.~·-_..,,...,.1,.,,.f··,.'"'E:-Loss of Cooling Tower System (Cold Water) Loss of Chiller System (Chilled Water) Loss of Power (Dead Quiet) Loss of Make-up Water (Low cooling tower sump level) Loss of System Vacuum on gauges "emerchar.2" Insufficient condensing Insufficient condensing Everything shuts down Cooling tower circuit will stop • Door seal will be lost • 02 may enter vessel and cause dangerous conditions • Burner will shut off If cooling cannot be re-established, shut off burner maintain vacuum until MTTD unit is below 350°F -Maintain chiller system operation. If cooling cannot be re-established, shut off burner maintain vacuum until MTTD unit is below 350°F -Maintain chiller system operation, but maintain cooling tower system until MTTD is below 350°F. • Secure MTTD Door • Initiate inerting purge • Reset system controls to natural state in preparation for restart • Attempt to re-establish normal or temporary water supply • Begin orderly cool down of MTTD system • Ensure vac pump is running, if not attempt to restart • If pump is running, check for vacuum across all condensers; ifthere is low or no vac everywhere, check pump coolant level and temperature • If a pluggage is noted begin cool down procedures to clear blockages • Ensure vac pump is running, if not attempt to restart • If pump is running, check for vacuum across all condensers; if there is low or no vac everywhere, check pump coolant level and temperature • If a pluggage is noted begin cool down procedures to clear blockages
- - - -- -- ------11111 -- --h':Com~onerit,,. MTTD Vessel MTTD Vessel MTTD Vessel MTTD Vessel YRS Components YRS Components "process.mm" TABLE4 PROCESS CONDITION DEVIATIONS ..: Deviation ., <. ':Possible.Cahse .' l> ,:.Conseqrience"· j '. L, ·.···_.-ActitinR~quir~d: Low Process Temp • Incorrect controller set point • Burner off • Burner stays at low fire High Process Temp Wrong set point Burner stays at high fire Low Process Vacuum I • High temperature on vac pump cooling fluid • Loss of vac pump • Pluggage in condenser system • System Leak High Process Vacuum I Normal operation Low Process Temp (YRS) I Normal operation High Process Temp (YRS) I • Loss of cooling tower water pump • Loss of cooling tower fan • Loss of chiller system • Loss of chiller fluid pump Insufficient heat for processing • Loss of process efficiency • Loss of seal on vessel door • Burner shuts off None None • Burner shuts off • Precooler & 1st condenser outlets too hot (no condensing) • 2nd condenser outlet too hot • Loss of vacuum • Reset controller to correct set point • Restart burner • Trouble shoot burner and controls • Adjust processing duration • Readjust controller Set point • Trouble shoot burner • Shut down burner if critical conditions exist • Check cooling system • Check packing gland for leakage • Check vac readings across all vessels to locate pluggage • Check piping & vessels for leaks None None • Check motor starter overloads • Check fuses/breakers • Check for system blockages using pressure gauges • Trouble shoot chiller controls • Flush vac pump fluid reservoir with cold water to maintain vacuum -
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I Point
I Waste feed hopper
I Treated soil hopper
I L1R
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I MTTD off-gas
exhaust
I Activated carbon
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adsorption canister
I VRS exhaust
to atmosphere
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Table 5
Objectives and Representativeness of
Sampling and Monitoring Points
Objective
Collect representative
sample of untreated soil
Collect representative
sample of untreated soil
Collect representative
sample of treated oil/
hydrocarbon liquid
Collect representative
sample of influent to
vapor recovery system (VRS)
Collect representative
sample of effluent to
oxidizer
Collect representative
sample of atmospheric
emissions
Representativeness
Highly;
well-mixed
Highly;
well-mixed
Highly;
well-mixed
Highly;
well-mixed
Highly;
well-mixed
Highly;
well-mixed
-------------------Waste Feed Soil Treated soil Grab sample Grab sample Treated Oil/ Grab sample Hydrocarbon (HC) Liquid Air discharge Grab sample Activated carbon Grab sample adsorption canister VRS exhaust to atmosphere Grab sample Table 6 Sampling and Monitoring Plan Summary Per batch Feed hopper Per batch Treated soil hopper Per batch LTR Per batch MTI'D off-gas exhaust Per batch After carbon Per batch canister Exhaust stack PCBs GC/MS Dioxins GC/MS voes GC/MS Biphenyl GC/MS PCBs GC/MS Dioxins GC/MS voes GC/MS Biphenyl GC/MS PCBs GC/MS Dioxins GC/MS voes GC/MS Biphenyl GC/MS PCBs GC/MS Dioxins GC/MS voes GC/MS PCBs GC/MS Dioxins GC/MS voes GC/MS PCBs GC/MS Dioxins GC/MS voes GC/MS 1 ppm Sample from drum lOppq or rolloff 5 ppb 330ppb lppm Hold batch lOppq until sample lOppb analyzed 330ppb lO0ppb Discontinue 5 ppq until lOppb repaired 330 ppb lOOppb Discontinue 5 ppq until lOppb repaired 100 ppb Discontinue 5 ppq until lOppb repaired 100 ppb Discontinue 5 ppq until lOppb repaired
- - - - - - - - - ----- - - - - - -Waste feed rate NaOHfeed rate Condensate water feed rate Volume of LTR influent Volume of L TR effluent LTRoff-gas temperature LTR off-gas flow rate Weighing Metering pump Float gauge Float gauge Float gauge Thermocouple Flow gauge Table 6 (cont.) Sampling and Monitoring Plan Summary Per batch Feed hopper conveyor Per batch 15 minutes Start of batch End of batch 15 minutes 15 minutes LTR Storage tank LTR LTR LTR LTR lbs. per batch gallons and lbs. per batch gallons gallons gallons degrees F SCF per minute Scale Volume +2% +.5 gallons + 1 gallon Discontinue at end of batch + 1 gallon Discontinue at end of batch Discontinue at end of batch Discontinue at end of batch
_________ , _________ _ MITDvessel temperature Stack gas flow rate Stack gas temperature NOTES: Thermocouple Flow gauge Thermocouple ppm parts per million ppb parts per billion ppq parts per quadrillion Table 6 (cont.) Sampling and Monitoring Plan Summary 15 minutes MITD 15 minutes Exhaust to atmosphere 15 minutes Exhaust to atmosphere degrees F SCFper minute degrees F Discontinue at end of batch Discontinue at end of batch Discontinue at end of batch
-------------------Comp_ound PCBs Sodium Hydroxide Sodium Bicarbonate Catalyst Hydrocarbon Oil Hydrogen NOTES: 0.5 mg!m3 54% Chlorine 2.0mg!m3 5.0mg!m3 Table 7 Exposure Limits and Recognition IDLHLevel (b) (ppm) None Established Possible gas evolution Possible gas evolution Odor Mild Hydrocarbon none none none none none Warning Concentration LEL (c) (%) UEL (d) (%) not not determined determined not not determined determined 4 75 (a) OSHA Permissible Exposure Limit or American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Value (b) Immediately Dangerous to Life or Health Level (c) Lower Explosive Limit (d) Upper Explosive Limit
-- - - - -------- -- - - -Table 8 Acute and Chronic Effects and First Aid Treatment Compound Routes of Entry Eye Irritant PCBs Inhalation Yes Ingestion Skin or Eye Contact Sodium Inhalation Severe Hydroxide Skin or Eye Contact Ingestion Sodium Skin or Eye Contact Slight Bicarbonate Hydrocarbon Skin or Eye Contact Yes Oil General First Aid Treatment (First aid kit will be kept in trailer on-site.) Eye Skin Inhalation Ingestion Irrigate immediately; a portable eye-wash will be kept in trailer. Wash with soap promptly. Move to fresh air. Get medical attention. Acute Effects Skin irritation chloracne eye irritation Severe burns to skin, mouth, throat, and eyes, skin irritation may be delayed Generally recognized as safe Skin irritation with prolonged contact Target Organs Skin, eyes, liver Skin, eyes, mucous membranes, respiratory tract None Skin and eyes -
-------------------Hazard Monitoring Method Toxic HNU Vapors or OVA HNU or OVA HNU or OVA NOTES: Table 9 Health and Safety Monitoring and Action Levels Action Level (1) Measurable above background based on judgement of SSC up to 1 ppm (1) Measurable above background based on judgement of SSC up to 1-5 ppm (1) Measurable above background based on judgement of SSC up to >5ppm Protective Measures Level D+ (see Table 6) Level C (see Table 6) STOP WORK EVACUATE AREA NOTIFY HEALTH & SAFETY MANAGER Monitoring Schedule Monitor every 15 minutes/every sample retrieved Continuous monitoring (1) The above levels are not solely based on the criteria for selecting levels of protection by the 1984 EPA Standard Operating Procedures, but also on the professional judgement and experience of the Site Safety Coordinator (SSC).
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Table 10
Protective Equipment for On-site Activities
Activity
1. Oversight of operation
2. Sampling of reactor
3. Handling of
sodium hydroxide,
sodium bicarbonate,
hydrocarbon oil, and catalyst
D
D+
C
Protective Equipment
Long sleeve work clothes or coveralls,
steel-toed safety shoes.
Hearing protection (foam ear plugs
or muffs) if necessary
Same as above plus Tyvek coveralls
and chemical-resistant gloves
Same as above plus
splash goggles and
organic vapor respirator
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I TABLEll
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I 95-RPl45.01
Koppen Superfund SITE Demonstntion
I Ana~tical results for PCDD/PCDF in soil saml?les !~~sl
Test Run S (Performance Run)
Input 011tp11t
I Analyte CNI CNI CNl CNJ
-SLl D.L -Sl..J D.L -Sl..J D.L -Sl..J D.L
2,3,7,8-TCDD ND 0.9 ND 2.2 ND 2.2 ND 2.0
I TotaJ TCDD ND 2.2 ND 4.2 ND 4.4 ND 5.5
Total PeCDD ND 6.4 ND 4.1 ND 7.2 ND 3.7
Total HxCDD 87.4 J ND 7.4 ND 10.6 ND 8.8
Total HpCDD 1,520 J ND 8.1 ND 12.6 ND 9.4
I OCDD 7,400 J ND 12.4 ND 17.0 ND 12.4
2,3,7,8-TCDF ND I.I ND 1.3 ND 1.9 ND 1.3
I Total TCDF 36.3 J ND 1.6 ND 2.8 ND 2.2
TotaJ PeCDF 93.9 J ND l.6 ND 2.6 ND 3.0
TotaJ HxCDF 482 J ND 1.5 ND 3.0 ND 1.3
TotaJ HpCDF 793 J ND l.9 ND 2.8 ND 1.8 I OCDF 1,420 J ND l.9 ND 6.4 ND 0.5
ND• Non Detect
J • Estimated value only. Below insttument calibration range.
I Detection Limits (D.L.) may vary from sample lo sample due to dilution factors.
I Koppen Superfund SITE Demonstntion
Ana!ltical results for PCDD/PCDF in condensed oil {µ~sl
Condensed Oil Treated Oil
I Analyte Run I Runl Run I Runl
2,3,7,8-TCDD 570 J 650J ND (0.15) ND (0.18)
I Total TCDD 18,150 14,560 ND (0.21) ND (0.28)
Total PeCDD 14,350 17,370 0.24 J,B ND(0.20)
Total HxCDD 12,700 24,140 0.26 J,B 0.38 J,B
Total HpCDD 10,060 15,550 0.70 J,B 0.69 J,B
I OCDD 8,850 19,480 5.11 J,B 2.26 J,B
2,3,7,8-TCDF ND (57) ND (120) ND (0.92) ND (0.11)
I Total TCDF 722 845 J ND (0.16) ND (0.11)
Total PeCDF 258 851 J ND (0.15) ND (0.12)
Total HxCDF 289 993 J 0.26J,8 ND (0.11)
Total HpCDF 1,273 1,127 ND (0.19) ND (0.13)
I OCDF 238 470 J 0.25 J,8 0.17 J,8
B • Analyte found in associated laboratory blank.
J m Estimated onl~. Below ins1n1men1 calibration ramie.
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each run. Preliminary results look encouraging and appear to be similar to the bench-scale
treatability results. Final results will be reported in the USEP A's SITE Demonstration
Summary Report expected to be released in 1994.
Bench scale analytical testing on the contaminated soils indicated that the
MTTD /BCD process was very successful in dechlorinating the PCP, dioxins and furans. As
indicated in Table 1, destruction and removal efficiencies of 99.99% or greater were
achieved in most cases<6). These results indicate that the treatment standards of 95 ppm for
PCP and 7 ppb for dioxins specified in the Morrisville, North Carolina ROD will be easily
met.
.
Treatability Test Results For A Soil Sample From
The Koppers Site, Morrisville, NC
l lll!f#Jllfllllilltiliii1i1Jt~V4
:111:1:1:!l!1:l!lll!l!!!lj!ili1llji!::::jljl!!lll!iil!!!!i!!i!l!!!;:;:::111:::::1:1:1:1:::::1::1:1::11:1:11::11:1:111!1:1::1:::::1:1;::::::1::1ii~§fii.!~l~~!:!~(~j;:::1p~M!!ililij1ljll:1::::::111::j:j:!!!l1!!:!i!i!!iji!:l::::1::1:1:::::::1:::1:::1!!1!!!li!::1!il!!!i!l!lll!il1iilli!1ltijll!;llli:::;::;:1:111::::
Total Tri-CP 90 0.001 99.99
Total Tetra-CP 750 0.0005 99.999
Penta-CP 35,000 0.0006 99.9999 · 95
Total TCDDs 1.46 0.121 29.489 1.0·
Total PeCDDs 11.40 0.129 90.373
Total HxCDDs 726.00 0.173 99.349
Total HpCDDs 4810.00 0.122 99.978
OCDD .31.20 0.0945 99.997
Total TCDFs 3.5 ND ( < 0.0007) >99.832
Total PeCDFs 40.9 ND ( <0.0012) >99.975
Total HxCDFs 529.0 ND ( < 0.0016) >99.997
Total HpCDFs 3020.0 ND ( < 0.0030) >99.999
OCDF 3540.0 ND ( < 0.0057) >99.999
2,3,7,8 TCDD equivalent
94
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Table 12
Data Quality Objectives
Parameters/Measurements Method
PCBs (solids)
PCBs (liquid)
Dioxins (solid)
Dioxins (liquid)
VOCs (solids)
VOCs (liquid)
Biphenyl (solid)
Biphenyl (liquid)
SW 846 3550/8080
SW 846 3550/8080
SW-846 8290
SW-846 8290
SW-846 8260
SW-846 8260
SW-846 8270
SW-846 8270
ppm = parts per million
ppb = parts per billion
ppt = parts per trillion
ppq = parts per quadrillion
Precision
(RPD)
+25%
+25%
+20%
+20%
+50%
+50%
Accuracy
( % Recovery) MDL
70-130 lppm
70-130 lO0ppb
75-125 1 ppt
l0ppq
varies with analyte
varies with analyte
30-150 <50ppb
30-150 l0ppb