NCD980602163_19960208_Warren County PCB Landfill_SERB C_US-EPA approval for R&D by Soiltech and Division of Waste Management-OCR

UNITED ST ATES ENVIRONMENT AL PROTECTION AGENCY
REGION ◄
3 ◄5 COURTLAND STREET. N .E.
ATLANTA. GEORGIA 30365
4APT-PTSB
Mr. Anthony J. Trentini
Operations Manager
SoilTech ATP -Systems, Inc.
800 Canonie Drive
Porter, Indiana 46304
Dear Mr. Trentini:
Enclosed is the approval document permitting Soiltech in
conjunction with the North Carolina Division of Solid Waste
Management to conduct research and development (R&D) on the
disposal of polychlorinated biphenyls (PCBs). The U.S.
Environmental Protection Agency Region 4 is issuing this R&D
approval pursuant to 40 CFR § 761.60(e) under the authority of
the Toxic Substances Control Act of 1976 (Public Law 94-469).
This approval is effective on the date it is signed and is good
for one year.
The R&D studies will be conducted at the Warren County PCB
Landfill located in Warren County, North Carolina. Soiltech will
use its bench scale Anaerobic Thermal Process/Base Catalyzed
Dechlorination process to treat up to 500 pounds of PCB
contaminated soil. This R&D project will provide data for
evaluating full scale treatment/disposal of PCB contaminated soil
contained within the Warren County. PCB Landfill.
Please direct inquiries concerning this approval to Craig
Brown of my staff. He may be reached at [phone],
extension 6918.
Enclosure
cc: Bill Myer, NCDSWM
Sincerely yours,
~~. c# f. ~f
Wi:ton :. Smith .
Director
Air, Pesticides and Toxics
Management Division
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ..
APPROVAL TO CONDUCT RESEARCH AND DEVELOPMENT TESTS
TO DISPOSE OF POLYCHLORINATED BIPHENYLS (PCBs)
SoilTech ATP Systems, Inc., in conjunction with
North Carolina Division of Solid Waste Management
Warren County, North carolina
RESEARCH .AND DEVELOPMENT STUDIES INVOLVING THE REMOVAL OF PCBs
FROM SOILS WITH A BASE-CATALYZED DECHLORINATION PROCESS
This approval is issued to SoilTech ATP Systems, Inc.,
(SoilTech) of Porter, Indiana and to the North carolina Division
of Solid Waste Management, (NCDSWM) to conduct Research and
Development (R&D) tests on the use of the Alberta Taciuk Process
(ATP), a high-temperature anaerobic thermal desorption process
and base-catalyzed dechlorination (BCD) for disposal/treatment of
PCB contaminated soils at the Warren County, North carolina PCB
Landfill. This project will be used to evaluate the
appropriateness and feasibility of ATP/BCD technology for full-
scale disposal/treatment of PCB-contaminated soil contained
within the Warren County PCB Landfill.
Authority
This approval to conduct R&D into PCB disposal is issued
pursuant to Section 6(e} (1) of the Toxic Substances Control Act
of 1976 (TSCA}, Public Law No. 94-469, and the Federal PCB
Regulations, 40 C.F.R. Part 761.60(e}, (Federal Register. 13185,
March 30, 1983).
Effective Dates
This R&D approval will become effective on the date of
signature and will expire one year after the date of signature.
Proposed Tests
The R&D tests will be conducted at the Warren County PCB
Landfill site. SoilTech will test less than 500 pounds of PCB
contaminated soil over a two to three week period. Soil will be
processed through the treatment unit in 10 to 15 pound batches.
The average concentration of PCBs in the soil is approximately
350 parts per million (ppm} with a range of 150 ppm to 900 ppm.
The concentration of PCBs in the treated soil is expected to be
less than 2 ppm. All process wastes will be analyzed for PCBs
prior to disposal.
SoilTech will use ATP testing equipment developed by UMATAC
in conjunction with BCD technology to thermally separate and
dekhlorinate the PCB contaminated soil. The UMATAC test unit to
be used in this ·pilot study is a bench-scale model of SoilTech's
full scale ATP unit. The unit consists of a rotary heating unit
processor (drum), primary and secondary condensers, air pollution
control devices (impinger type gas trap and carbon filters) and
monitoring instrumentation. Heat input to the drum comes from
electric heating elements installed on the outside of the steel
shell.
During treatability test runs, BCD chemicals will be mixed
with the batch samples prior to being placed in the drum. The
BCD reaction takes place as the soil is mixed and heated in the
drum. Each batch will be slowly rotated in the drum for
approximately 30 minutes, at temperatures in the range of
900 -1000 degrees Fahrenheit. Hot vapors evolved in the drum
flow through a rotary seal to two condenser tubes (primary and
secondary), connected in series, which are externally cooled by
cold water circulation. Condensed liquids drain by gravity to a
collector vessel, which accumulates the water and organic liquids
and allows the gases to disengage. Gases exiting the secondary
condenser pass through a gas filter trap (impinger), a wet test
gas flow meter and dual phase carbon filters before being vented
to the atmosphere or collected in a Tedlar• bag for sampling.
Business confidentiality
Pursuant to the regulations at 40 CFR Part 2, Subpart B (41
Federal Register, 39997, Septembers, 1978), SoilTech is entitled
to make a business confidentiality claim covering any information
submitted under this R&D approval. If such a confidentiality
claim is not asserted with any submission, EPA may make this
information available to the public without further notice.
Information subject to a business confidentiality claim may be
made available to the public only to the extent set forth in the
above cited regulations. Any such claim for confidentiality must
conform to the .requirements set forth in 40 CFR Part 2.203(b).
Liability
The issuance of this R&D approval does not release SoilTech
or NCDSWM from any liability for damage to persons or property
caused by or resulting from the operation or maintenance of
equipment covered by .this approval. The conditions of this
approval are enforceable under TSCA and its implementing
regulations, 40 CF~ Part 761. Any actions which violate the
terms of this approval, TSCA, or the regulations may result in
administrative, civil, or criminal enforcement by EPA in
accordance with Section 16 of TSCA, 15 u.s.c. Part 2615.
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Findings
1. This permit is specifically for the treatment of no more
than 500 pounds ·(227 kilograms) of PCB contaminated soil. In
addition to the PCB contaminated feed soil, process condensate
and condensate-entrained fines may be recirculated back through
the treatment process.
2. All tests will be conducted at the Warren County PCB
Landfill site in Warren County, North Carolina. Materials
handling, test unit operations and monitoring programs are
designed to .prevent and control spills and minimize the potential
for hazardous materials exposure to workers and the general
population.
3. The SoilTech ATP process has been tested at other
hazardous waste sites at pilot and full scale and reduced PCB
concentrations in treated materials to below EPA standards.
Because of waste variability from site to site, it is necessary
and appropriate to conduct site specific testing at the pilot or
bench scale to confirm process effectiveness and safety prior to
treatment of Warren County PCB Landfill soil at full scale.
4. Flue gases from the ATP test unit at the Warren County
PCB Landfill will be purged through dual carbon fi+ters prior to
release to the atmosphere. The State of North Carolina will also
conduct perimeter air monitoring at the site. Therefore,
pursuant to 40 CFR Part 761.60(e) EPA finds that the SoilTech R&D
project (when operated in accordance with the approved permit
application and under the conditions described below) does not
pose an unreasonable. risk of injury to human health or the
environment.
conditions of &2prova1
1. Advance Notification: SoilTech shall provide the EPA
Region 4 with a thirty (30) day advance written notification of
intent to start operating the R&D project.
2. Other Approvals or Permits: Prior to commencing the
tests, SoilTech must obtain •any necessary federal, state or local
permits or approvals. During the course of the testing, SoilTech
shall comply with all conditions and requirements of such permits
or approvals. Copies of such permits must be forwarded to EPA,
Region 4, within five days of the start of the testing.
3. Feedstock Quality and Restrictions: The PCBs to be used
in the thermal desorption and BCD experiments are limited to
samples of PCB contaminated soils taken from the adjacent Warren
County PCB Landfill. The total quantity of PCB waste feed to be
treated under this approval is less than 500 pounds. In
addition, SoilTech is permitted to treat certain process wastes
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(condensate, air and water pollution control residuals) generated
as part of this R&D approval by the ATP/BCD treatability tests.
soilTech ~Y request modifications to these restrictions,
with appropriate justification. Requests should be submitted to
the Director, Air, Pesticides and Toxics Management Division
(APTMD} of EPA Region 4.
4. Feed soil and Process waste Characterization: Feed soil for testing and all process wastes generated by the ATP/BCD
process must be characterized as follows:
a. At -a frequency of one composite sample per series
(Series• so pounds), feed soil shall be tested for
PCBs, grain size, moisture content (percent solids),
and BTU value.
b. Process wastes that must be characterized for disposal
include: treated/coked solids, liquid phase carbon
filter media, vapor phase carbon filter media, treated
aqueous condensate and spent solvents used for
equipment cleaning. Any process intermediaries,
including oily condensate and, sludge from oxidation
treatment of aqueous condensate, must also be
characterized prior to disposal or recirculation
through the ATP/BCD unit. Each waste stream must be
sampled at least once except for treated/coked solids
which shall be sampled and tested at a once-per-series
frequency. At a minimum, all wastes shall be analyzed
for PCBs.
c. Any process wastes, whether treated or not, that are to
be disposed of on-site at the Warren County PCB
Landfill following completion of the tests shall also
be analyzed for the following compounds:
PCDFs, polychlorinated dibenzofurans
PCDDs, polychlorinated dibenzo-p-dioxins
TCDFs, tetrachlorinated dibenzofurans
TCDDs, tetrachlorinated dibenzo-p-dioxins
2,3,7,8-TCDFs
2,3,7,8-TCDDs
s. Exhaust Emissions Monitoring: Flue gases shall be
sampled at the frequency and by the methods specified in
SoilTech's R&D Permit Application dated October 26, 1995, as
amended on January 1.7, 1996, except as modified herein.
a. The •first Tedlarft bag in the flue gas sampling train
described in Section 6.3 and depicted in Inset A,
Figure 1 in the Permit Application shall be eliminated.
A Teflonft diaphragm pump, as depicted in the referenced
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figure, may be used in the sampling train if needed to
compensate for pressure losses across the sampling
train. Other sampling configurations may be allowed if
approved by EPA in writing.
b. Flue gas samples shall be tested for the following
parameters:
02; oxygen
CO, carbon monoxide
CO2, carbon dioxide
- · . ..HCl, hydrogen chloride
PCBs, polychlorinated biphenyls
PCDFs, polychlorinated dibenzofurans
PCDDs, polychlorinated dibenzo-p-dioxins
TCDFs, tetrachlorinated dibenzofurans
TCDDs, tetrachlorinated dibenzo-p-dioxins
2,3,7,8-TCDFs
2,3,7,8-TCDDs
c. PCDF and PCDD analytical results must include the
values for the 2,3,7,8-TCDF and 2,3,7,8-TCDD congeners,
total TCDFs and TCDDs and total PCDFs and PCDDs.
6. Process waste Handling and Disposal: SoilTech shall dispose of all waste generated during the R&D studies which have
been found to contain 2 ppm or more PCBs or 3 ppb or more PCBs
for aqueous waste, as calculated by comparison to an external
standard homolog peak having the nearest retention time to each
appropriate PCB peak to be quantified, in an off-site PCB
disposal facility approved by EPA under 40 CFR Part 761. EPA
approved sampling and analytical methods for PCBs in different
media (water, solids, and oil) must be used by SoilTech in ma.king
such determinations (note: sampling and analytical methods listed
in SoilTech's R&D Permit Application dated October 26, 1995, are
considered "EPA approved" for this purpose).
7. Process Monitoring/Recording: Provisions must be ma.de to ensure that the following process elements are suitably
monitored and recorded for each batch of PCB contaminated
material processed:
a. The weight of soil feed charged into the SoilTech ATP
retort unit.
b. The weight and volume of any condensate or sludge that
is recirculated through the ATP retort unit~
c. The weight of treated/coked solids removed from the
treatment unit.
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Q-. volume and weight of condensate produced.
e. volume of gas produced as measured by the wet test gas
flow meter.
f. Temperature of reaction.
g. Date, time and duration of run.
h. Name of operator and supervisor.
s. Operating Restrictions: SoilTech shall comply with the
following operating requirements:
a. Feed soil for the R&D tests and all process wastes will
be stored in compatible, weather-tight containers
within a locked building or fenced enclosure.
Containers of untested liquid wastes or liquids
containing PCBs in concentrations above PCB treatment
standards must be stored within secondary containment.
b. The graphite gasket at the access port of the retort
unit shall be inspected following each batch test and
replaced as necessary. Other items listed as Routine
Maintenance Items in SoilTech's "Operating Manual for
the Bench Scale Test Equipment,• shall be replaced as
necessary to ensure proper operation of the test
equipment.
9. Safety and Health Standards: SoilTech or its agents
must take all necessary precautionary measures to ensure that
operation of the UMATAC bench scale ATP unit is in compliance
with the applicable safety and health standards, as required by
Federal, State and local regulations and ordinances. The
occurrence of any lost-time injury or illness which results from,
or may have resulted from, exposure to PCBs during the ATP
process must be reported to the EPA Region 4, PCB Coordinator by
the next regular business day.
10. Facility Security: The UMATAC ATP unit and PCB·
contaminated materials stored at the site shall be secured (e.g.,
fence, alarm system, etc.) to restrict unauthorized access to the
area. Any security breach that resulting in a release of,
removal of or exposure to PCB contaminated materials or equipment
shall be reported to the EPA Region 4 PCB Coordinator by the next
regular business day.
11. PCB Releases: In the event the SoilTech or an
authorized facility operator of the ATP believes, or has reason
to believe, that a release has or might have occurred, the
facility operator must inform the EPA Region 4 PCB Coordinator
inunediately.
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.
I . . '
~royal i..
Under the above conditions, and given the circumstances
under which the R&D tests will be conducted, EPA Region 4 finds,
pursuant to 40 CFR 761.60(e), that these tests will not present
an unreasonable risk of injury to health or the enviromnent.
Approval to perform R&D for PCB disposal is hereby granted
to SoilTech ATP Systems, Inc., in conjunction with the North
Carolina Division of Solid Waste Management, subject to the
conditions expressed herein, and consistent with the materials
and data included in SoilTech's application •TSCA R&D Permit
Application for Pilot Scale Study• dated October 26, 1995, as
amended on January 17, 1996. This R&D approval is valid when
conducted at the Warren County PCB Landfill located in Warren
County, North Carolina.
FFO OP TP.~'i
Date
"
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Winston A. Smith
Director
Air, Pesticides and Toxics
Management Division