NCD980602163_19960212_Warren County PCB Landfill_SERB C_R&D Permit Application Comments - BCD Pilot Scale Projects, 1995 - 1996-OCR

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Mon, 12 Feb 96 7:25:32 +1100
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SoilTech R&D approval
Bill -the R&D approval for SoilTech was signed Feb 8th by
the Div Director. Expect the original and cc's will be sent
out later today.
CB
.J
' • I
December 11 , 199 5
Memorandum ,
TO:
FROM:
RE:
BillMeyer ~
David J. Lown ~
Proposed BCD Pilot Study
ETG/Aquaterra and SoilTech Proposals
Air Monitoring Permits
Neither SoilTech and ETG/Aquaterra nor includes plans for ambient air monitoring.
Plans are made for flue g i.s sampling. A brief discussion of each proposal is given below.
SoilTech
SoilTech proposes a bench-scale test to be completed on site. A thorough discussion of
how the bench scale test relates to the full scale operation is not included in the documents
submitted. A demonstration of the full-scale operation should be completed before full-scale
remediation waste in the landfill is approved.
Figure 1 is a diagram showing the process for the bench-scale test. Figure 2 is a
schematic diagram showing the proposed sampling points. As proposed, all the gases generated
by the test will be captured in a tedlar bag.
Capture of the gas by a tedlar bag is a good safety measure; however, testing the captured
gases by pumping them through a XAD Resin Tube as shown in Inset A of Figure 1 is not
representative of gas composition. Particles and condensate can be trapped by the bag before
being sampled. Gas samples for dioxin/furan should be collected from the vapor train prior to
and after the carbon filter units. The samples should be collected by EPA Method 23 and
analyzed using method 8290. This method requires collection of the flue gases isokinetically. A
similar method should be •1sed for PCB.
The proposal is ~o treat less than 500 pounds of soil in 10 to 15 pound batches.
Aguaterra/ETG
The scale of this test is larger than that proposed by SoilTech. For the pilot test, 9 to 10
cubic yards of material will be tested. One batch will be run in a day and each run will process
about 3 cubic yards. A schematic of the process is shown in Figure 3 and a drawing of the
equipment is given in Figure 4.
Memo
BCD Air Quality Monitoring
Page 2
The contractor proposes testing gases from the thermal desorption unit and from the
vapor recovery unit, but does not specify methodology. Gases collected for dioxin/furan should
handled according to EP A method 23 and analyzed using method 8290. Similar EPA methods
should be used for PCB.
cc: Jack Butler
Bruce Nicholson
N ~ I N CJ) I co N 0 o er Zw ~~ ~ ::, oz LEGEND: ~ t¾ ~ ® @ VENT VACUUM PUMP PRESSURE RELlff VALVE TWO WAY VALVE PRESSURE REDUCING REGULATOR PRESSURE CUAGE THERMOCOUPLE & 1i;_27_951TSSUED FOR PROPOSAL No. I DATE ISSUE / REVISION CARBON nL TER cr-1 WIT TEST GAS rLOW MITER M...>Jil J>.JT JHH WN. BYICK'O BYIAP'O SY fLOW __...,,_ ,§-=-~ s~~• ,v.o ROTAIIE'TER T(DLAR BAG RESIN TEFLON TUBE IEOLAR BAG DIAPHRAGII COLLECTED HUE PUfJP GAS INSET A rLUE GAS SAMPLING TRAIN ORSA! ANALVZER co co, o, ~I ROTAll[l[R ~~ PURGE GAS NITROGEN PURGE GAS AIR ROTAM[TER rEEO/OISCHARGE PORT WATER nJ.-----wi~Ll~tT IMPINGER CONO[NSAT[ ORA/ti W~ COOLING WATER OUT [MERG[NCY PRESSURE REUff RECEM:R ROTARY BATCH UNIT PROCESS FLOW DIAGRAM WARREN COUNTY LANDFILL PREPARED FOR NORTH CAROLINA DEPT. OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES So Tech DATE: 10-20-95 SCALE: N.T.S. FIGURE 1 DRAWING NUMBER 028-92-A22 &
n N <{ I N (j) I OCl N 0 (.'.) a:: Zw 3= ~ ~ ::, oz 6 ..____ CARBON FILTER & l,0_27_95pssurn FOR PROPOSAL ·•No.I DATE ISSUE / REVISION TREATED (COKED) SOLIDS 2 ROTARY --------UNIT N -0 0 z z er er 0 0 VJ VJ z z w w 0 0 z -z 0 0 u u T T t PHASE SEPERATOR CONDENSATE COLLECTOR J.D.J. I AJT I JHH WN. BYICK'D BYIAP"D BY 1 OILY/FINES FROM CONDENSATE AQUEOUS CONDENSATE COLLECTION TREATED SOIL QUENCH/WffilNG FEED AND BCD CHEMICALS BLENDING z 0 .:= u L) Q'. z 0 ~ Q X 0 :::,; 0 er LL w (.'.) 0 ::::, ....J VJ OXIDATION VESSEL FEED MATERIAL BCD CHEMICALS 3 4 CLEAN CARBON AQUEOUS ADSORPTION STORAGE ,___ ~ ROTARY BATCH UNIT SAMPLING POINTS WARREN COUNTY LANDFILL PREPARED FOR NORTH CAROLINA DEPT. OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES S ····Ti h ,.,,, ... , .. ,; '.~ ec U".il. DATE: 10-24-95 SCALE: N.T.S. FIGURE 2. DRAWING NUMBER 028-92-AZ.3 ill
COHTAMIHATED SCREENED SOILS ~-/0 HED HOPPER DECHLORINATION REAGENTS (Ir REQUIRED) .c::,,_A '\../---c7' FEED CONVEYOR HEU SOURCE 5.5MM ITU/HR BCD SOLIDS REACTOR MEDIUM TEMPERATURE THERMAL DESORPTION (MTTD) q,~ VAPOR DISCHARGE WATER SPRAY COOLING UNIT B-1J ~ ~DAY TREATED WATER RECYCLED OH-SIT[ OH-SITE BACKrtU. OR ----------~ Off-SITE DISPOSAL DECONTM,CIHATED SOLIDS CONTAINER NOTE: VAPOR RECOVERY SYST[I.I CAH BE MODIFIED FOR SPECIFIC CONDITIONS. ~j{j @ENVIRONMENTAL. INC. Date: 10.,l~/95 -40258.DWG Drawn By: I.I. Brocker TO ATMOSPHERE 200 sr CHILLER CONDENSING UNIT (? . . ... r ~ 0 ' 20-so scn,1 AQUEOUS COHDEHSATE STORAGE CARBON .ADSORPTION BAG nLTER ----~ LTR PURGE VEHT AHO EMERGENCY RELIEF OILY COHOENSAT[ STORAGE 5 CFH OECHLORIHA TIOH REAGENTS 1 (;fo'r:____ INERT GAS ,. ..,.n PURGE 70 GALLONS/ BATCH I TREATED OIL/HC RECYCLED Off-SITE BCO/THERM-0-0ETOX• BATCH VACUUM SYSTEM Reference: HA FIGURE 3
-·-. -· -.. -----.... --·---------·-------2" Stack Sampling Port~ ' 0 ;;i-T"" l 0 N T"" 26' 3" Final Carbon Polishing Condensers (2) Condenser \ Polishers ,--Oxidizer Vacuum Pump (1) \ Circulating Pumps (2~ I \ ' ' -Process Stack ! 0 c.o I $1 I OO 'ill.I~ l_l_ Control-J Panel Chiller System-_:, 26 feet above r ground level -' Cooling T ewer. Chiller System Cooling Tower 4" Diameter -Process Stack 48' O" ---------------------··--------------------j-oa1e·-10,919s _____ ------.{~ff~_J{!/J ENVIRONMENTAL, INC. ~±~~~~~~~~~~;-__ -------------------------------THERM-O-DETOX ,.,,BATCH VACUUM UNIT #1, TRAILER CONFIGURATION Reference: NA FIGURE 4
{ -I .. \
December 11, 1995
Memorandum
TO:
FROM:
RE:
Bill Meyer {l") p
David J. Lown ~
Draft R&D Permit for
SoilTech BCD Pilot Study
I have reviewed EPA's proposed R&D permit for the SoilTech BCD process and have the
following comments:
Sec. 4.b. Pg. 5. Any process intermediaries, including oily condensate and, sludge from
oxidation treatment of aqueous condensate, should be sampled for dioxin/furan and PCBs prior
to being recirculated through the ATP/BCD unit or being disposed.
Par. 3, Pg. 3. Gases generated should not be collected in a Tedlar bag for sampling.
Sampling should be done isokinetically by EPA Method 23. The Tedlar bag will trap particles
and condensate.
Sec. 5. Pg. 5. Flue gas emissions should be sampled and tested by EPA Method 23 for
dioxin/furan and by appropriate methods for PCB prior to treatment by a carbon filter and after
treatment by carbon filter.
Sec. 7.a. Pg. 6. The weight and volume of any condensate or sludge that is that is
recirculated through the ATP retort unit should be recorded.
Figure 1 and Table 2 from the SoilTech proposal have been modified to show proposed
sample locations and analytical methods. These sampling locations have been selected to track
what is happening to the ,J1oxin and should provide adequate data for mass balance calculations.
With modification of the EPA permit as indicated above, the EPA permit should require
the additional sampling shown in Figure 1.
cc: Jack Butler
Bruce Nicholson
N N <( I N 0) I OJ N 0 Cl 0:: Zw ~ CD i? 5 oz LEGEND: ct tl:J ~ ® Q) N"+-tb be-5A~plecl VENT VACUUM PUMP EPA f,lle_ th.od 23 4;)£"1L-\ff>!IT f PAftiG<JLAT€ r~ pil,\1e-r -s,..'"P' i IAj T 'l""<ll.' ~ _f;,'f" 'Pc..B 1 J)iox, IA EPA He:l-kcJ z:s Se\.\l\;-vos-l-£ Vt:t.rtio.c.-lc-J-e. . ( r:'°"' P l~jf Y-Sa.. IA-\ P 1"1 IA' +r4 i I.'\ +ov f/L G1 1)io}(tV\ PRESSURE REUff VALVE TWO WAY VALVE PRESSURE REDUCING REGULATOR PRESSURE GUAGE THERMOCOUPLE WET TEST GAS rLOw MITER .n.. I 51 ISSUED FOR PROPOSAL UJ. 10-27-9 M...>JA I I.IT JHH No. I DATE ISSUE / REVISION WN. BY!CK'D BYJAP'O BY 'P("t>fDSetj :S0-\M.r(e Loc.a...tioV\s ~I RO!AM[T[R ~I~ ROTA.,(TER INSET A rLUE GAS SAMPLING TR,41N PURGE GAS PURCE GAS NITROGEN AIR '~Ji:" Tc:..~+-'D;f>C...~Cl\.~ WAT[R ~ ~ 0 z a 0 ~ ~ z a ti "' T lllf---w~~u~tT P ,, D'e."' .......,. '(_g/ 1vAPOR ~ '\ PIPE W...-£---w;rtRU~tr EMERGENCY PRESSURE RELIEr RECEIVER Te-s + q,r,-ul,I..$ QCI\\A€"'-$t.e.+-e. p~;.,V' -to '("~c..·,,r,. ~r f-r~+\,,\\e \.'\..1--pc. B 'D ,c>c, \/\ . ROTARY1BATCH UNIT PROCESS FLOW DIAGRAM WARREN COUNTY LANDFILL ~~ f>-PREPARED FOR IMPING(R I L.cl::>--CONDENSATE NORTH CAROLINA. ···•··DEPT. OF ENVIRONMENT, DP.AIN 'f'CS '();0,_:1\1\ HEALTH, AND _NATURAL RESOURCES J S..ic, ... ac,,IIWlech u,c~ &1 ~ o,l'f 5\rul~e.. . -~ ,n.a ') Ji, xiii\ DATE. 10-20-95 FIGURE 1 DRAWING NUMBER ~o~ rv0 2f IJ SCALE: N.T.S. 028-92-A22 -prio-r ,ei, t'GU.. lo.:\10 \,\ & ... ~
-T/ : 2 SAMPLING PLAN SUMMARY ,, WARREN COUNTY LANDFILL PILOT SCALE STUDY PARAMETER SAMPLING FREQUENCY LOCATION ANALYSIS ANALYSIS LIMIT CONTINGENCY METHOD PARAMETERS METHODS Waste Feed Composite from One per series 1 -Feed mixing . PCB SW-846-8080 NIA Substitute with a composite D 1o)(iV\ 82..<to feed preparation after manual bowl % Solid EPA -160.3 N/A from the main feed pile SS bowl homogenation Grain Size ASTMD-4220 N/A (Series = 50Ibs) BTU Value ASTMD -2015 N/A Treated/Coked Composite from One per series 2 -treated soil PCB 1)',ox.·, V\. SW-846-8080 < 2 ppm Collect sample of treated ~z.. '10 Solids treated soil after manual mixing bowl Grain Size ASTMD -4220 N/A solids from one individual mixing bowl compositing batch in the series Liquid Phase Composite Once-at project 3 -from filter PCB SW-846-8080 N/A Carbon Sample completion cannister J))oxi"'-Sl'lO 'jltA.+<A'" =freated-Sample from Once-at project 4 -from t, eatgg:: PCB SW-846-8080 N/A . Dio)l it\ ~2-c:io Condensate aqueous storage completion a,iueous ~Sl~~f's:: 'l<ese rvo·,'(' OMd oi 't. sliuli)e.. ( a.~ " -o; '1 '--re' Pc.8 Bll>BO <:;:" con ainer .._storage container Dioit;"' 82,qo Vapor phase Composite Once-at project 5 -from filter PCB SW-846-8080 N/A Carbon Sample completion cannister Dit>X~\I\ ~2qo Flue Gas ~D resin t e 4 times, 1 ea 6 -from flue gas PCB High Res 680 N/A Sample can also be xz esi tube @ 50fb, 150 lb exhaust tube Dioxin/Furan M 23, 8290 N/A collected from any one tedl ag 300fb, 450fb downstream of co M 3 -Orsat NIA batch, however, it may not / t tilar ba of soil treated carbon filters 02 M 3 -Orsat N/A correspond to the "worst tedlar bag CO2 M 3 -Orsat N/A case" condition, as planned. EPA M 3 PRIW:192-028\WARRNR&D.XLW [10/26/95] ,;-.._~Tech
December 11, 1995
Memorandum .
TO:
FROM:
RE:
Bill Meyer {l) p
David J. Lown ~
Draft R&D Permit for
SoilTech BCD Pilot Study
hlf#lt-3(¥,f-s
l') ii> 0A. CJttu~ lt1a.0~
~\-so,~~
l'3>)
I have reviewed EPA's proposed R&D permit for the SoilTech BCD process and have the
following comments:
Sec. 4.b. P~. 5. Any process intermediaries, including oily condensate and, sludge from
oxidation treatment of aqueous condensate, should be sampled for dioxin/furan and PCBs prior
to being recirculated through the ATP/BCD unit or being disposed.
Par. 3. P~. 3. Gases generated should not be collected in a Tedlar bag for sampling.
Sampling should be done isokinetically by EPA Method 23. The Tedlar bag will trap particles
and condensate.
Sec. 5. P~. 5. Flue gas emissions should be sampled and tested by EPA Method 23 for
dioxin/furan and by appropriate methods for PCB prior to treatment by a carbon filter and after
treatment by carbon filter.
Sec. 7.a. P~. 6. The weight and volume of any condensate or sludge that is that is
recirculated through the ATP retort unit should be recorded.
Figure I and Table 2 from the SoilTech proposal have been modified to show proposed
sample locations and analytical methods. ,These sampling locations have been selected to track
what is happening to the dioxin and should provide adequate data for mass balance calculations.
With modification of the EPA permit as indicated above, the EPA permit should require
the additional sampling shown in Figure 1.
cc: Jack Butler
Bruce Nicholson
N N <{ ! N O'l I CX) N 0 (.) a:: Zw ~~ ~::, oz LEGEND: ct cki ~ ® C) p 1 I I j 1 Not--to be.... :;0-.~pLeq V(r;: J VN:UVM PUMP Ep 11 ,v1-..:..1 I -23 • t'-t ; ~, l-1_0~ :5 Ef.fL-'-I05T { PA£r iwLAre I"' pi~~e-r ,-, -5a..lMpl i 11\j T,~,~ -ro< 'Pc..S1 J)ioX l IA E p A-M e...fkoJ Zs :)l.W\~ -Vost £ ?4rticu.l-J-e. • I r:~ P''"-je,.. ~""pr,\,\' +r~; I,,\ +ov -Pc. 01 "Dio>ct\l\ PRtsSURE REUff VAi.';[ TWO WAY VAi.VE PRESSURE REDUCING REGULATOR PRESSURE CUACE THERMOCOUPLE WCT TEST CAS now MrnR L1). l10-27-9~11SSUED FOR PROPOSAL ~I A.JI JHH No. I DATE ISSUE / REVISION WN. BYfCK'O BYIAP'D BY i' i (,rcocsea I , •· ! -=:-ci_\M.f)le. 'I , ~ .. Loc....~:-ic1,\5 "' .· .. ~"~~ / (77~~ ~~! 1 ROIA,..[T[P, SO:A .. [l[R ®-j 0.:1 T~ ~~~PN COLL£CT£0 r~ 01.APHAAGl.4 / CAS U( PUUP I INSET A rLUE GAS S._MPLING TRAIN !5 "' 0 0 z 0 u I 0 u ... "' PURGE CAS PURCE GAS NITROGEN AIR Tc:..-..r n;~~~~ 'jJi~~ lrJI---; COOllNC WAT[" OUT P ., D'e~i (_gj •v-.p--\I\ Pl TH(RMOCOVPI.ES ,W',L---, COOI.JNC WATER OUT ATP RETORT IJNlT -\R \ CHART R[CORO£R *· Et.lERC[NCY PR[SSURE RWE• RECEMR Tes+ ctr,-uf.4.~ ~~e"'-$~--l-e. F.''r -ft, "("~-,~ . e>r fr~""-~ "':t-,... T) ;A1/TE" ~ CONDENSATE RESERVOIR ~ 'PC. B 'D•C>c1\/\0 ROTARY1BATCH UNIT PROCESS FLOW DIAGRAM WARREN COUNTY LANDFILL PREPARED FOR WATER CONDENSATE DAAIN NORTH CAROLINA DEPT. OF ENVIRONMENT, 'D,.n 'i"I· • t HEALTH, AND-NATURAL RESOURCES (L-O v,o,S.•V\ S 1 cit.Tech d · t 5liul~e..-------.-------,---------◄ ~ ~ '{) ,r. .9\ Oi,TE: 10-20-95 FIGURC" 1 DRAWING NUMBER :;o~ Ro t ..,,ox, SCALE: N.T.S. '-028-92-A22 -prio-r re.ii t"C..IA. \cd,o'" & ( ' 'i.
T.' :2 \ SAMPLING PLAN SUMMARY ... WARREN COUNTY LANDFILL PILOT SCALE STUDY PARAMETER SAMPLING FREQUENCY LOCATION ANALYSIS ANALYSIS LIMIT CONTINGENCY METHOD PARAMETERS METHODS Waste Feed Composite from One per series 1 -Feed mixing PCB SW-846-8080 NIA Substitute with a composite Diox.'1V\ Bz.qo feed preparation after manual bowl % Solid EPA -160.3 NIA from the main feed pile SS bowl homogenation Grain Size ASTMD -4220 NIA (Series = 50Ibs) BTU Value ASTMD -2015 NIA Treated/Coked Composite from One per series 2 -treated soil -p· PCB SW-846-8080 < 2 ppm Collect sample of treated , ox.", V\. ~ z.. C/0 Solids treated soil after manual mixing bowl Grain Size ASTMD-4220 NIA solids from one individual mixing bowl compositing batch in the series Liquid Phase Composite Once-at project 3 -from filter PCB SW-846-8080 NIA Carbon Sample completion cannister J))ox.i"'-9210 \&IA-r<A"' =f1e8ted Sample from Once-at project 4 -from I: 1 ti.RP PCB SW-846-8080 NIA . Dio)C.i~ ~ 2..'iO Condensate aqueous storage completion a~ueous ~~II&~~ t<eSef"'/o·,,. c:_A °''t. sl~t-( AMA 'i -0;11 t.,,.yer i>c.8 eeeo con ainer .. storage container Diox.;"' B2qo Vapor phase Composite Once-at project 5 -from filter PCB SW-846-8080 NIA Carbon Sample completion cannister "Dic,')\;\I\ ~2CJO Flue Gas ~D resin t e 4 times, 1 ea 6 -from flue gas PCB High Res 680 NIA Sample can also be xz esi ube @ 50Ib, 150 lb exhaust tube DioxinlFuran M 23, 8290 NIA collected from any one tedl ag 300lb, 450Ib downstream of co M 3 -Orsat NIA batch, however, it may not ~ t larba of soil treated carbon filters 02 M 3 -Orsat NIA correspond to the "worst / tedlar bag CO2 M 3 -Orsat NIA case" condition, as planned. EPA M PRiW:192-029\WARRNR&D.XLW (10/26195) -S.~, ... Tech
Post-if" Fax Note 7671 Date
Phone # Phone# 733 --~
Fax #
Memorandum;
DATE: December 8, 1995
TO: Henry Lancaster
FROM: Bill Mey~
SUBJECT: PCB Landfill
• Craig Brown (EPA Region II TSCA staff) called l 1 /29 -received 2 sets of issues raised
in review of SoilTech's application.
• Enclosed are issues raised by EPA
• I will respond to issues to EPA and copy you
• Staff time for technical review is going to be intensive for a short term, I have assigned 2
of our best engineers, Dave Lown (100% federal funded) and Bruce Nicholson (60%
federal funded) to the project.
• If technical review ( other the myself) gets move resource intensive, I may have to ask for
a temporary engineer for technical input.
facsim
TRANSMITTAL
to:
fax#:
re:
date:
pages:
Craig,
CRAIG BROWN
404-347-5205
Warren County PCB Landfill
December 6, 1995
/, including cover sheet.
1
Here are the preliminary comments on the PCB landfill R&D Permit Application issues.
If you have any questions, please give me a call.
From the desk of...
Bill Meyer
Director
Division of Solid Waste
[phone]
Fax:
SEN-T, BY: ·'4 APT PTSB j 12-6-95 10:02AM; 404 347 1681 => 919 715 3605;
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
3◄5 COURTLAND STR.£ET, N.E.
ATLANTA. GEORGIA 30365
FACSIMILE COVER SHEET
TO: Ii,// /11t?,,,-1r
I
DRAFT
oRGANIZATIONa Al c. I),"' f f'(,jL1; kiut-" ns-t
FAX No.: 21, I 7, 1--,Jt," s· •
ORGANIZATION: f;,.--eA-7; {I T .{ 8
7
PHONE NO: I y t, r) J fr 7 .~ J r .r j X 6 '1 I fl
DATE ; / 1-/ t., ( 9 _r
NO. OF PAGES (including cover eheet)i_~2 _________ _
/ .> r ,lr.~(t--61 ,r11,( Ii f I) /h'r -, ~T f-..,.,-s., ,· L l~clt. , N4r: J "-:r 74,f
I? r, ,, f ;i:. "" , ~ ,.,i:, ;--~ c < e e ./·r.d h~ ~ee I,, u:. tz P-'1 ~ ,. ~.,...,,,, /11 "~,.,
e.'1/ r f1 I/ ~I/( 9-"'.eJf,n-i. ~ fp,,,. ..r,,: l t-;-e A
#1
. . SENT BY: 4. APT PTSBj 12-6-95 10:02AM; 404 347 1681 => 919 715 3605j
DRAFT
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
APPROVAL TO CONDUCT RESEARCH AND DEVELOPMENT TESTS
TO DISPOSE OF POLYCIILORINATED 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) 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 fu11-
scale disposal/treatment of the Warren County PCB Landfill
contents.
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 (TS~.A), 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 180 days after the date of signature.
Proposed Test:s
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. 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 thennally separate and
dechlorinate 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 uniL
processor (drum), primary and secondary condensers, pollution
#2
SENT . BY: 4 APT PTSB; 12-6-95 10:02AM; 404 347 1681 => 919 715 3605;
control equipment, and monitoring instrumentation. Heat input to
the drum comes from electric heating elements installed on the
outside of the steel shell.
Soil will be processed through the treatment unit in 10 to
15 pound batches. A ramp test will be performed on the feed
material prior to treatability testing. A ramp test is a
variable temperature test starting at ambient and slowly
increasing to a maximwn 70ooc. The ramp test will be done to
characterize vaporization temperatures of the contaminants and
provide data on waste feed volatility.
During treat.ability t.est. 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 480 -
5400F. 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 tor sampling.
Business Confidentiality
Pursuant to the regulations at 40 C.F.R. Part 2, Subpart B
(41 Federal Register, 39997, September 8, 1978), SoilTech is
entitled to make a business confidentiality claim covering any
information submitted under this R&JJ 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 C.F.R. 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 C.F.R. 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.
Findings
#3
SENT BY: .4 APT PTSBj 12-6-95 10:03AM; 404 347 1681 => 919 715 3605;
l. This permit is specifically for the treatment of no more
than 500 pounds (227 kilograms) of PCB contaminated soil. In
addition to the FCB 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, iL is necessary
and appropriate to conduct site specfic testing at the pilot or
bench scale to confirm process effectiveness and safety.
4. Because flue gases from the ATP unit at the Warren
County PCB Landfill will be purged through dual carbon filters
prior to release to the atmosphere and air in the work space of
the test unit will be drawn through an exhaust fan and filter
system, EPA has determined the SoilTech R&D project to be
designed to protect workers and the public from PCB exposure and
precludes any apparent release of PCBs to the environment.
Therefore, pursuant to 40 C.F.R. Part 761.GO(e) EFA finds that
the SoilTech R&D project (when operated in accordance with the
approved per:mit application and under the conditions described
below) does not pose an unreasonable risk of injury to human
health or the environment.
Conditions of Approval
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 pennits 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, containing PCBs in the range of 150 ppm to
900 ppm. The total quantity of PCB waste feed to be treated
under this approval is 500 pounds or less. In addition, SoilTech
is permitted to treat certain process wastes (condensate, air and
water pollution control residuals) generated as part of this R&D
#4/9
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approval by the ATP/BCD treatability tests.
SoilTech may 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= 50 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 intennediaries,
including oily condensate and, sludge from oxidation
treatment of aqueous condensate, that are not
recirculated back through the ATP/BCD unit for
treatment, must also be characterized prior Lo
disposal. Each waste stream must be sampled once at
project completion 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 onsite at the Warren County PCB Landfill
following completion of the tests shall also be
analyzed for the tallowing 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
5. Exhaust Emissions Monitoring: Flue gas emissions shall
be sampled and tested for the following parameters:
0 2 , oxygen
CO, carbon monoxide
CO2, carbon dioxide
HCl, hydrogen chloride
PCBs, polychlorinated biphenyls
PCDFs, polychlorinated dibenzofurans
PCDDs, polychlorinated dibenzo-p-dioxins
#5/9
SENT _BY:,4 APT PTSB; 12-6-95 10:03AM; 404 347 1681 => 919 715 3605;
TCDFs, tetrachlorinated dibenzofurans
TCDDs, tetrachlorinated dibenzo-p-dioxins
2,3,7,8-TCDFs
2,3,7,8-TCDDs
PCDF and PCDD analytical results must include the values for
the 2,3,7,8-TCDF and 2,3,7,8-TCDD cogeners, 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 BPA 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 making
such determinations (note: sampling and analytical methods listed
in SoilTech's R&D Permit Application dated November 6, 1995, are
considered "EPA approved11 for this purpose).
7. Process Mon..i_t...Q..:_ingj,Re!; .. QX'.Q._ing: Provisions must be made
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
unit.
b. The weight of treated/coked solids removed from the
treatment unit.
c. volume and weight of condensate produced.
d. volume of gas produced as measured by the wet test gas
flow meter.
e. Temperature and pressure of reaction.
f. Date, time and duration of run.
g. Name of operator and supervisor.
8. Operating Restrictions: SoilTech shall comply with the
following operating requirements:
a. In order to control the release of fugitive gases and
vapours during materials loading and unloading to the
test unit or during upset conditions, an overhead vent
fan equipped with a HEPA filter and charcoal filter is
required to collect fugitive emissions.
b. Feed soil for the R&D tests and all process wastes will
#6 /9
SENT BY:'4 .APT PTSB; 12-6-95 10:04AM; 404 347 1681 => 919 715 3605;
be stored in compatible, weathertight 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.
c. The graphite gasket at the access port of the retort
unit shall be replace following each batch test. 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 believ~s. or has reason to believe,
that a release has or might have occurred, the facility operator
must inform the EPA Region 4 PCB Coordinator immediately.
A written report describing the incident must be submitted
by the close of business on the next regular business day. No
PCBs may be processed in that facility until the release problem
has been corrected to the satisfaction of EPA Region 4.
12. PCB Spills: Any spills of PCBs or other fluids shall be
promptly contained and cleaned up. In addition, a written report
describing the spill, operations involved, and cleanup actions
must be submitted to EPA Region 4 within five (5) business days.
13. Personnel Training: SoilTech is responsible for ensuring
that personnel directly involved with the handling or disposal of
PCB-contaminated material using the ATP process are demonstrably
familiar with the general requirements of this R&D approval. At
a minimum this must include:
a. The type of material which may be treated during the
testing of the ATP unit, and the upper limit of the PCB
#7/9
SENT ·BY:·4.APT PTSB; 12-6-95 10:04AM; 404 347 1681 => 919 715 3605;
contamination which may he treated;
b. Basic reporting and recordkeeping requirements under
this R&D approval and the location of records at the
test site;
c. Notification requirements; and
d. Waste disposal requirements for process and by-product
wastes generated during the testing of the ATP process .
In this regard, SoilTech must maintain the following
documents on-site during the testing of its ATP/BCD studies; a
copy of this R&D approval, the spill prevention and cleanup plan,
and the sampling and analysis plane to collect and test untreated
and treated materials.
14. PCB Material Transport: Untreated PCB material may not be
transported off-site except for proper disposal. PCB-
contaminated equipment on the ATP unit may be transported off-
site in accordance with 40 CFR Section 761.40 and the U.S.
Department of Transportation requirements of Title 49, CFR Part
172. Such requirements include placarding the equipment and
labelling all PCBs.
15. PCB Regulation Compliance: SoilTech shall comply with all
applicable requirements of the Federal PCB Regulations, 40 CFR
Part 761, in the operation of the ATB"unit. Particular notice
should be given to:
a. 40 CFR, Section 761.65 -storage for disposal;
b. 40 CFR, Section 761.79 -decontamination; and
c. 40 CFR, Section 761.180 -records and monitoring.
16. Approval Modifications: EPA reserves the right to impose
additional conditions when it has reason to believe that the
continued operation of the ATP/BCD disposal process presents an
unreasonable risk of injury to public health or the environment,
or for any other valid cause.
17. Permit variance: Any departure from the conditions of this
R&D approval or the terms expressed in the application and R~
plan must receive prior authorization by the EPA. Verbal
authorizations by EPA must be followed within ten working days by
a written notification from SoilTech describing all
modifications. In this context, 11 application and R&D plan" shall
be defined as all data and materials which have been received by
this Agency from SoilTech regarding the PCB destruction method.
18. R&D Test Report: All test results and related information
on this R&D project shall be incorporated into a test report and
submitted to EPA for evaluation no later than sixty (60) days
#8/9
SE~T BY:,4 APT PTSB; 12-6-95 10:05AM; 404 347 1681 => 919 715 3605;
after completion of testing. The R&D Test Report shall include,
at a minimum, the following items:
a. Certification letter. This letter signed by an
authori2ed official, must certify on be~alf of the
applicant that the tests were carried out in accordance
with the approved application and the results of all
determinations are submitted in the report. Any
changes or deviations by the applicatanc from the
application must be documented and submitted in writing
to the EPA.
b. Detailed discussion of all process operations,
operational problems, if any, and corrective actions.
c. Chronology of significant events.
d. Quality assurance (QA) report. This shall address all
the QA objectives, including whether or not precision
and accuracy objectives were met, as well as results of
quality control samples, performance audit samples and
systems audits .
e. Waste handling. Applicant shall provide documentation
(copies of manifest and certificates of destruction or
analytical results) to ahow all wastes generated during
the R&D process tests were properly disposed according
to TSCA and other applicable regulations.
Approval
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 environment .
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 Managment, subject to the
conditions expressed herein, and consistent with the materials
and data included in SoilTech's application 11 TSCA R&D Permit
Application for Pilot Scale Study" submitted October 26, 1995 by
Mr. Anthony J. Trentini of SoilTech ArP Systems, Inc. This R&D
approval is valid when conducted at the Warren County PCB
Landfill located in Warren County, North Carolina.
Date Winston A. Smith
Director
Air, Pesticides and Toxics
Management Division
#9/9
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Warren County PCB Landfill R&D Permit Application Issues
1. Perrnittee -Since the landowner where the R&D work will take
place is owned by the State or County, should the approval be
jointly issued to both NC Div of Solid Waste and SoilTech?
2. LF Permit Mod -Since the landfill is closed, EPA will have
to issue an approval modification to allow partial cap removal
and soil extraction for the R&D projects. Does NC plans to
submit the RFP for the soil removal contract to EPA to serve as a
written plan describing how this work will be carried out in a
safe and effective manner? If so, will the RFP also address how
the excavated soil for both projects is to be stored for the•
duration of the test period?
3. Unused Feed Soil ~ On-site storage of unused or inadequately
treated soil following completion of the R&D projects is not a
viable option. Nor is placement back in the landfill. Any
unused feed soil or process waste containing PCBs above 2 ppm (3
ppb for aqueous wastes) must be sent to an operating TSCA
facility for disposal.
4. Dioxins -Despite NC's concerns about an increase in dioxin
concentration in treated residuals and other process streams,
SoilTech has not proposed to test any process stream other than
flue gas for dioxins and furans. We are attempting to confer
with Dr. Brian Gullett of EPA's RTP lab for his opinion on the
likelihood of dioxin production and impacted process streams. We
are prepared to include dioxin testing thru permit conditions
beyond what SoilTech has proposed if recommended by Dr. Gullett.
If Dr. Gullett does not respond to our request or indicates that
dioxin production is not likely to be a problem, then EPA does
not plan to impose dioxin monitoring requirements except for flue
gases. However, if NC Div of Solid Waste has any specific
suggestions for permit conditions for dioxin monitoring, action
limits for treatment residuals or process waste streams, we would
welcome the help.
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Warren County PCB Landfill R&D Permit Application Issues
1. Permittee -Since the landowner where the R&D work will take place is owned by the
State or County, should the approval be jointly issued to both NC Division of Solid
Waste and SoilTech?
Approval for the SoilTech project should be jointly issued to the North Carolina Division
of Solid Waste Management (Division) as owner and SoilTech as operator.
2. LF Permit Mod -Since the landfill is closed, EPA will have to issue an approval
modification to allow partial cap removal and soil extraction for the R&D projects. Does
NC plan to submit the RFP for the soil removal contract to EPA to serve as a written plan
describing how this work will be carried out in a safe and effective manner? If so, will
the RFP also address how the excavated soil for both projects is to be stored for the
duration of the test period?
The Division will submit a request for proposal (RFP) for soil extraction, pre-treatment
( drying) of soils and storage (handling) for the duration of the project test period. The
RFP will be significantly more detailed than the standard RFP. This should provide EPA
with sufficient detail to determine that these activities will be conducted in a safe and
effective manner. It is imperative that the Division and EPA be provided with both a
reasonable accurate total volume of soil needed for testing the treatment process and
optimum moisture content of the soil. A portion of the soils in the bottom of the landfill
are saturated and will require some draining/drying process. The extent of drying will
depend upon the sensitivity of the R&D process to moisture content. In order to provide
soils that are close to optimum moisture several technical methods must be evaluated for
effectiveness. For example, simple gravity drainage may suffice, however, if a belt filter
press ( or other mechanical device) is needed or thermal dehydration is required, then the
cost and design are significantly different. The Division will notify both vendors of this
concern and will draft the RFP to meet their needs.
3. Unused Feed Soil -On-site storage of unused or inadequately treated soil following
completion of the R&D projects is not a viable option. Nor is placement back in the
landfill. Any unused feed soil or process waste containing PCB's above 2ppm (3 ppb for
aqueous wastes) must be sent to an operating TSCA facility for disposal.
The Division will condition the contract with vendors to require all feed soil to be
treated. There will be no untreated soils. Contract conditions will also be written to
require reasonable multiple or repeated treatments of soils until the 2ppm standard is
obtained. In addition, vendors will be required to provide financial assurance, such as a
performance bond, for timely off site management of any residuals that cannot be treated
to the 2ppm standard.
4. Dioxins -Despite NC's concerns about an increase in dioxin concentration in treated
residuals and other process streams, SoilTech has not proposed to test any process stream
other than flue gas for dioxins and furans. We are attempting to confer with Dr. Brian
Gullett of EPA's RTP lab for his opinion on the likelihood of dioxin production and
impacted process streams. We are prepared to include dioxin testing thru permit
conditions bJ!yond what SoilTech has proposed if recommended by Dr. Gullett. If Dr.
Gullett does not respond to our request or indicates that dioxin production is not likely to
be a problem, the EPA does not plan to impose dioxin monitoring requirements except
for flue gases. However, if NC Division of Solid Waste has any specific suggestions for
permit conditions for dioxin monitoring, action limits for treatment residuals or process
waste streams, we would welcome the help.
The DSWM is hopeful that Dr. Gullet will provide recommendations for dioxin/furan
testing. However, the DSWM will condition the contract for SoilTech to require
dioxin/furan testing at least for untreated soils, condensates or other materials extracted
from the treatment process, flue gases and treated soils. SoilTech will be required to
utilize in-stack impingement capture devices in accordance with EPA method 23 and
analysis performed in accordance with method 8290 for tetra-octa dioxin and furans. In
addition to vendor process monitoring, the DSWM will monitor ambient air emissions in
accordance with method T09 (or equivalent) and method 8290 for tetra-octa dioxin/furan
analysis.
The Joint Warren County/State PCB Landfill Working Group (working group) has expressed
concern with the existing dioxin and furan concentrations in the landfill. There is no consensus
on action levels in the working group, however, it is the division's opinion that the action level
that is selected by the working group will be lower in concentration that EPA levels (CERCLA
for example). It is suggested that your review proceed without regard to State action levels for
dioxin/furan in treatment residuals or process waste streams.
, ·.
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Preliminary Questions/Comments on SoilTech R&D Application
Environmental and He~lth Impact-Information: A brief discussion
of potential impacts to human health and the environment arising
from the proposed R&D tests must be added to the application.
What hazardous constituents, at what concent rations might be
expected in air emissions from the treatment unit? Describe the
surrounding area. How far away are the nearest off-site
residences, businesses and schools?
Sec. 4.1.2, Pg. 7: The description of the Soil~ech and UMATAC
Process states that the process operates at temperatures in the
250 -300 oc range. In Section 4.4 and else where in the
application statements indicate that the combustion unit will
operate in the 900 -1000 oF range. Which is correct?
Sec. 4.2, Pg. 7: A more detailed description of front-end
materials handling for the feed soil must be provided. Besides
blending dry and wet soils, what other processing (e.g., removal
or reduction of oversize material, debris removal) will be
required to prepare the feed soil? What will be done with reject
material? Where will this processing be performed and how will
spillage be prevented or controlled?
Sec. 4.5.1. Pg. 10; EPA literature on pyrolysis methods suggests
that HCl may be produced in the effluent gas stream when PCBs are
present in treated wastes. How are HCL and other corrosive gas
emissions controlled in SoilTech's process?
Sec, 5.1. Pg. 13; What are the expected concentrations of PCBs
in the condensate process streams and why is it necessary to
perfo:nn additional oxidation treatment to remove PCBs if the
dechlorination reaction occurs upstream in the combustion unit?
Also, provide a more detailed description of the oxidation
treatment (what chemicals will be used, in what type of vessel
will the treatment take place, etc.)
Sec. 5.3, Pgs. 15-18: In light of NC's concerns about dioxins
and furans why is it that SoilTech proposes to test only flue
gases for these substances?
sec. 5.3.1, Pg. 16: A better description of how the feed soil is
to be stored must be provided. "Stockpiling 11 • is not an ..:. acceptable storage method for PCBs.
sec. 5.3.2, Pg. l6: Why is it necessary or desirable to test for
grain size in the treated soil?
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Sec. 5.3.4. Pg. 17; Please note that the aqueous process stream
must be treated to below 3 ppb in order to reuse or dispose of it
on site.
Sec. 5.3.6. Pg. 18: What is the "Fenton's Reaction" mentioned in this section?
Sec. 9.0. Pg. 24: The "off -site" disposal designation specified
for several process waste stream.~ is unacceptably vague. Are
these materials going to a TSCA or non-TSCA facility? Note: any
process waste stream containing PCBs above 2 ppm must go to a
TSCA factlity .
Sec. 17.0, Pg. 39i This section of the application is intended
for identification and discussion of any other permits approvals
SoilTech needs to conduct the proposed R&D testing at the .Warren
County PCB Landfill. This section must be rewritten accordingly.
If no additional permits or approvals are needed a statement to
that effect should be provided.
Sec. l 9 .1. 4. Pg. 42: lUber Environmental Services of Atlanta is
identified as the lab that will perform chemical analyses for
work conducted under this approval. If this is true, why include
SOPs from a RTP based lab in Appendix B?
Sec. 21.2, Pgs. 55 & 56: Second paragraph statements concerning
disposition of aqueous condensate appear to conflict with
statements in preceding sections indicating the aqueous
condensate would be applied to treated soil. What is the site
discharge permit referred to in this paragraph? Does the Warren
County PCB Landfill have an NPDES permit?
First paragraph on page 56 indicates untreated teed soil will be
left on-site for backfilling by others. This is unacceptable.
Any teed soil that is not treated to below 2 ppm PCBs must be
sent to an off -site TSCA facility for disposal.
Appendices A & B: SOPs from Triangle Labs are stamped
"Confidential" and "Uncontrolled Copy." These two designations
seem to be at odds. Is SoilTech asserting that these materials
are confidential business information (CBI)? If so, EPA requires
one copy ot the application with all CBI material excised.
Appendix E: Same question as #11. Is SoilTech asserting a CBI
claim for the Operating Manual?
Comment:
Response:
Comment:
Response:
Comment:
Response:
Comment:
Response:
Preliminary Questions/Comments on SoiITech R&D Application
Comments From Division of Solid Waste Management
Environmental and Health Impact Information: Describe the surrounding area.
How far away are the nearest off-site residences, businesses and schools?
Enclosed are copies of the Afton Quadrangle, North Carolina, 7.5 minute series
map (topographic); Warren County, NC, NCDOT map of roads with locations of
schools, churches, hospitals & population centers; copy of orthophoto map of
Warren County (map #2944) with approximate 1 mile radius from landfill
indicated. The closest school is South Warren Elementary K-6, approximately
1. 7 5 miles from the landfill with approximately 200 students attending. If these
maps are not sufficient (quality or information), please respond to the Division for
further clarification. Also enclosed are copies of road maps identifying residences,
by name and numbered location, within a 2 mile radius of the PCB landfill.
Sec. 4.2, page 7: What will be done with reject material?
The Division was present during the placement of soils in the landfill and only soils
and associated vegetation was placed in the landfill. It is not anticipated, based on
reasonable knowledge, that any debris will be encountered. However, if debris is
removed the Division will assume responsibility for management including
containerization, labeling, analyzing, transportation and management at a TSCA
approved facility.
Sec. 5.3, pages 15-18: In light ofNC's concern about dioxins and furans why is it
that SoilTech proposes to test only flue gases for these substances.
The Division will require (by contract) that SoilTech test for dioxin/furans at least
for untreated soils, condensates or other materials extracted from the treatment
process, flue gases, and treated soils. ( see responses to issue on Warren County
PCB Landfill R&D Permit Application Issues)
Sec. 5.3.1, page 16: A better description of how the feed soil is to be stored must
be provided. "Stockpiling" is not an acceptable storage method for PCB's.
The Division will include in the RFP for providing materials for the R&D project a
section addressing storage prior to treatment. The section will include placement
in 80 gallon over pack 17-H carbon steel containers, labeling, and placement in a
"connex box" (a portable completely enclosed steel 20-40yd3 container). This
should provide/meet all TSCA requirement for storage including secondary
containment and controlled access. If more design or other information is needed
please contact the Division.
Comment:
Response:
Comment:
Response:
Comment:
Response:
Sec. 17.0, page 39: This section, if applicable, is intended for identification and
discussion of any other permits approvals SoilT ech needs to conduct R&D testing.
The Division will request, from the NC Air Quality Program, information as to the
applicability of air quality permits. There should be no other applicable permit
required.
Sec. 21.2, pages 55-56: What is the site discharge permit referred to in this
paragraph? (second paragraph) Does the Warren County PCB landfill have an
NPDES permit?
There can be no discharge from the site. The TSCA permit currently allows
treatment of leachate through a sequential sand and carbon filter(s) followed by
irrigation over the landfill surface. Aqueous condensates may not be suitable for
this existing treatment system(s). The State cannot practically issue the NPDES
permit since the receiving stream is small (low volume) and above several drinking
water supplies. A plan for managing the condensates and other materials extracted
from the process must be included in the R&D proposal. The Division will work
with the vendor and EPA to make this as reasonable as possible. Again the vendor
should be aware that any off-site management of residuals will be a major concern
to the Warren County community.
Sec. 21.2, pages 55-56: 1st paragraph indicates untreated feed soil will be left on-
site for backfilling by others.
See Division's response to issue 3 on Warren County PCB Permit Application.
There will be no untreated soils. This will be accomplished by providing only the
amount of soils needed, treatment of all soils provided ( even if extra batches are
required to be treated) or repeated treatments of soils to ensure that less then
2ppm PCB's is attained.
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I
Preliminary Questions/Comments on SoilTech R&D Application
?nvironmental and Health Impact Information~ A brief discusslun
of potential impacts to human health and the environment arising
from the proposed R&D tests must be added to the application.
What hazardous constituents, i'.lt what concentrations might be
expected in air emissions from the treatment unit? Describe the
surrounding area. How far away are the nearest off-site
residences, businesses and schools?
Sec. 4 .1.2, Pg. 7: The description of the SoilTech and UMATAC
Process states that the process operates at temperatures in the
250 -300 oc range. In Section 4.4 and elsewhere in the
application statements indicate that the combustion unit will
operate in the 900 -1000 oF range. Which is correct?
Sec. 4.2, Pg. 7: A more detailed description of front-end
materials handling for the feed soil must be provided. Besides
blending dry and wet soils, what other processing (e.g., removal
or reduction of oversize material, debris removal) will he
required to prepare the feed soil? What will be done with reject
material? Where will this processing be performed and how will
spillage be prevented or controlled?
Sec. 4.5.1, Pg. 10, EPA literature on pyrolysis methods suggests
that HCl may be produced in the effluent gas stream when PCBs are
present in treated wastes. How are HCL and other corrosive gas
emissions controlled in SoilTech's process?
Sec. 5.1, Pg. 13; What are the expected concentrations of PCBs
in the condensate process streams and why is it necessary to
perform additional oxidation treatment to remove PCBs if the
dechlorination reaction occurs upstream in the combustion unit?
Also, provide a more detailed description of the oxidation
treatment (what chemicals will be used, in what type of vessel
will the treatment take place, etc.)
Sec. 5.3, Pgs. 15-18: In light of NC's concerns about dioxins
and furans why is it that SoilTech proposes to test only flue
gases for these substances?
Sec. 5.3.1. Pg. 16: A better description of how the feed soil is
to be stored must be provided. 11 Stockpiling".~ is not an
acceptable storage method for PCBs. =
Sec. 5.3.2, Pg.~ Why is it necessary or desirable to test for
grain size in the treated soil?
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Sec. 5.3.4. Pg. 17; Please note that the aqueous process stream
must be treated to below 3 ppb in order to reuse or dispose of it
on site.
Sec. 5.3.6, Pg. 18: What is the "Fenton's Reaction" mentioned in this section?
Sec. 9.0, Pg. 24: The "off-site" disposal designation specified
for several process waste streams is unacceptably vague. Are
these materials going to a TSCA or non -TSCA facility? Note: any
process waste stream containing PCBs above 2 ppm must go to a
TSCA facility.
Sec. 17.0. Pg. 39&.. This section of the application is intended
for identification and discussion ot any other permits approvals
SoilTech needs to conduct the proposed R&D testing at the .Warren
County PCB Landfill, This section must be rewritten accordingly.
If no additional permits or approvals are needed a statement to
that effect should be provided.
Sec. 19.l.4, Pg. 42: Kiber Environmental Services of Atlanta is
identified as the lab that will perform chemical analyses for
work conducted under this approval. If this is true, why include
SOPs from a RTP based lab in Appendix B?
Sec. 21.2, Pgs. 55 & 56: Second paragraph statements concerning
disposition of aqueous condensate appear to conflict with
statements in preceding sections indicating the aqueous
condensate would be applied to treated soil. What is the site
discharge permit referred to in this paragraph? Does the Warren
County PCB Landfill have an NPDES permit?
First paragraph on page 56 indicates untreated teed soil will be
left on-site for backfilling by others. This is unacceptable.
Any teed soil that is not treated to below 2 ppm PCBs must be
sent to an off-site TSCA facility for disposal.
Appendices A & B: SOPe from Triangle Labs are stamped
"Confidential" and "Uncontrolled Copy." These two designations
seem to be at odds. Is SoilTech asserting that these materials
are confidential business information (CBI)? If so, EPA requires
one copy ot the application with all CBI material excised.
Appendix E: Same question as #11. Is SoilTech asserting a CBI
claim for the Operating Manual?
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Warren County PCB Landfill R&D Perm.it Application Issues
1. Permittee -Since the landowner where the R&D work will take
place is owned by the State or County, should the approval be
jointly issued to both NC Div of Solid Waste and SoilTech?
2. LF Permit Mod -Since the landfill is closed, EPA will have
to issue an approval modification to allow partial cap removal
and soil extraction for the R&D projects. Does NC plans to
submit the RFP for the soil removal contract to EPA to serve as a
written plan describing how this work will be carried out in a
safe and effective manner? If so, will the RFP also address how
the excavated soil for both projects is to be stored for the•
duration of the test period?
3. Unused Feed Soil -On-site storage of unused or inadequately
treated soil following completion of the R&D projects is not a
viable option. Nor is p1acement back in the landfill. Any
unused feed soil or process waste containing PCBs above 2 ppm (3
ppb for aqueous wastes) must be sent to an operating TSCA
facility for disposal.
4. Dioxins -Despite NC's concerns about an increase in dioxin
concentration in treated residuals and other process streams,
SoilTech has not proposed to test any process stream other than
flue gas for dioxins and furans. We are attempting to confer
with Dr. Brian Gullett of EPA's RTP lab for his opinion on the
likelihood of dioxin production and impacted process streams. We
are prepared to include dioxin testing thru permit conditions
beyond what SoilTech has proposed if recommended by Dr. Gullett.
If Dr. Gullett does not respond to our request or indicates that
dioxin production is not likely to be a problem, then EPA does
not plan to impose dioxin monitoring requirements except for flue
gases. However, if NC Div of Solid Waste has any specific
suggestions for permit conditions for dioxin monitoring, action
limits for treatment residuals or process waste streams, we would
welcome the help.
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