NCD980602163_19970819_Warren County PCB Landfill_SERB C_Ecologic - Phase I Pilot Scale Testing (Gas Phase Chemical Reduction)-OCR

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August 19. 1997
To: Mike Kelly, Technical Committee, Pat Barnes
From: Joel Hirschhorn
Re; Comments on Draft Eco Logic Phase 1 report
Table 4: add dio"-.in TEQ levels in feed, similar to PCB data.
Table 6: data on PCB levels --and perhaps other contaminants --appear to be rounded numbers,
compared to Table 4: only actual data should be used. The PCB data in Table 4 does not
correlate exactly ¼•ith data in Appendi.x E; it appears that Total PCB + EMPC data were not used
and. if so, than the report should defend excluding the EMPC data.
All tables: whenever ND is gjven as a result place actual detection limit in parentheses next to
ND If some data are suspect because of findings in blanks, then that should be noted. For
example, it is stts.-picious that toluene was found at a higher level in Run 2 treated solid than in
oJiginal feed.
In the calculation of dio'-i!J TEQs it is not acceptable to asswne NDs = 0 if the NDs are high; a
more proper and conservatiYe approach is to use onehalf of the NDs.
Section 5. should include some information on length of time for actual full-scale cleanup of the
:::ice. Should check statemeuts about estimated price of $350-400 per ton and what it includes or
excludes. ls it really a total, tum-key remediation cost, which statements no"v imply?
Section 4.2.3: would like to see some more detailed ex-planation ofhow TRM temperature "'as
''inadvertently allowed to drop to 500°C, \vhich is below the minimum operating temperature of
S socc." Ho\,. \.vould this typ~ of malfunction be prevented in actual full-scale equipment?
Section 4.2.3: statemeot about infeasibility of reaching a I ppt TEQ should be reexamined,
because it is not correct.
Table 9: would like some explanation for finding of dioxin in Run. 3 treated scrubber water and
,Yhether th.is would be found in full-scale equirment. Tue e)l.."_Planation on p.25 about "interference
in the analytical technique" is not satisfactory.
Would like to see a special sub-section in 4.2 about levels of PCBs and dioxins in all process
,\·aste streams (solid, air, water) and discussion of meeting regulatory requirements and/or
providing treatment of process residuals in company's equipment, or whether offsite
treatment/disposal \Vould be required. Should have some discussion of PCB/dioxin air emissions.
Section 5.5: statement th.at the process "requires minimal processing of untreated soil prior to
treatment" should be amplified, so that exact processmg that may be necessary in. full-scale
operation is folly detailed.
Was PM measured in exhaust gas?
TI1e dioxin data for Rw1 2, S l and S5 need more discussion. In both cases the levels and
distribution of dioxiu congeners is not typical for PCB impurities. But in the treated material,
there is even more dioxins than in the feed material. especially of the most toxic fonns. Is it
possible that some reactions have occurred during desorption processing?
Titere should be more detailed information on exactly bow the materials received by the company
were treated and handled prior to becoming designated as the feeds for the three runs. Was a
composite roade from all incoming containers? Did each run con-espond to one particular bucket?
How much oversize material was screened out as a percent of the origiual soil sample provided?
What did this materiaJ look like?
The report should present some discussion of its approach to give PCB data in tenns of total
PC Bs rather than more typically used m.ethod of giving data iu terms of Aroclors. At least for the
S 1 data. some ruscussion oflab data should be given to relate to more typical data on Aroclors.
Should present some information on relative toxicities of different PCBs.
2
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SENT BY :EPA 5-27-97 16:05 NAT'L CHEM PROG DIV~
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
MAY 2 7 1997
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OfFIC(;Of
PREVENTION, PESTICIDES AND
TOXIC SUBSTANCES
Dr . WRyland Swain
Vice President
EL I Eco Logic International Inc.
2385 Huron Parkway
Ann Arbor, MI 48104
Dear Dr. Swain:
Enclosed j_s the approval document for the R&D studies
entitled "Approval to Conduct. RP-search and Development Tests to
Dispose of Polychlorinated Biphenyls (PCBs), ELI Eco Logic
International Inc., {Eco Logic), Ann Arbor, Michigan, Removal of
.PCBs from Soil." It grants approval to Eco Logic to conduct
research and development (R&D ) tests on their processes to r emove
polychlorinated biphenyls (PCBs) from soils and other media
containing PCBs. The PCB disposal system to be demonstrated has
been described in the Eco Logic permit application (submitted in
March 5, 1997) aml subsequent submittals which were received at
EPA Headquarters.
The purposes of this ongoing R&D testing are: (1) to use the
Eco Logic process (process) to demonstrate the destruction of
PCBs from soils and other media; (2) to investigate the
feasibility of the process at the commercial scale; and (3) to
identify any possible process defects prior to the scheduling of
a full-scale commercial demonstration.
All test recults and related information on this R&D project
shall be incorporated into a test report and submitted to the
Environmental Protection Agency (EPA) Headquarters' National
Program Chemicals Division (NPCD) for evaluation . The R&D test
report should include, at a minimum, the items listed in
Conditions of Approval numbers six and seven in this enclosed
approval.
No wastes generated as a result of this study may be
transported off site except for disposal in accordance with the
r equirements for the original concentration of PCBs in the feed.
Recy~ .. d/Recyclllblti
Prtnted wllh SoylCanola ,,. on paper that
contMns at lea&t !>0% recydod fiber
SENT BY:EPA 5-27-97 16 :05 NAT'L CHEM PROG DIV~
2
The effective date for this approval is trom May 26, 1997 through
May 26, 1998 (See Condition 17).
Please direct matters concerning this subject to Winston Lue
of my staff on [phone].
Enclosure
cc:
Ed Cohen, PCB Coordinator
U.S. EPA, Region III
o W. Melone, Director
tional Program Chemicals Division
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SENT BY :EPA 5-27-97 16 :06 NAT'L CHEM FROG DIV~
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
APPROVAL TO CONDUCT RESEARCH AND DEVELOPMENT TESTS
TO DISPOSE OF POLYCHLORINATED BIPHENYLS (PCBS)
ELI ECO LOGIC INTERNATIONAL INCORPORATED
ANN ARBOR, MI 48104
REMOVAL OP PCBs FROM SOILS BY CHEMICAL REDUCTION
Autho rity .
'I'his approval to conduct research and development studies
R&D into PCB disposal ic icaucd pursuant to Section G(e) (1) of
the Toxic Substances Control Act (TSCA of 1976, Public Law No.
94-469, and the Federal PCB Regulations, 40 CFR, Section
761. 60 (e), (48 Federal Register, 13181, March 30, 1983).
Background
ELI Eco Logic International Inc. (Eco Logic) submitted a
Research and Development application and had tiled an R&D permit
application with EPA headquarters on March s, 1997 with
supplementary submission on April 14, 1997. The Eco Logic
process involves gas phase reduction of organic compounds by
hydrogen at 850 C or higher. Polychlorinated biphenyls are
chemically reduced to methane and hydrogen chloride. The
hydrogen chloride can be recovered as acid or neutrulized in a
caustic scrubber downstream of the process reactor. In the
treatabil ity scale unit, the components of the system include the
Thermal Reduction Mill, TRM, a gas-phase chemical reduction
reactor, a two-stage gas scrubbing system, and a prodlH_;L gas
compression and storage system with continuous emission
monitoring.
Proposed Tests
The purposes of this ongoing R&D testing a:n'!: ( 1 ) to use the
Eco Logic process (process) to destruction of PCBs from soils and
other media; (2) to investigate the feasibility of the process
at the commercial scale; and (3) Lo identify any possible process
defec ts prior to the scheduling of a full-scale commercial
demonstration.
The proposed tests will attempt to dGmonstrate the ability
of the Eco Logic process to reduce the PCB concentration: (1) in
soil and sediment, liquids and other liquid to< 2 ppm .
The R&D project is classified into two phases of work for
chemical destruction as follows:
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SENT BY :EPA 5-27-97 16:06 NAT'L CHEM FROG DIV~
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Phase 1 involves the determination of a range of process
,variables on a larger scale to remove PCBs from soil, sediment,
and liquids to less than 2 ppm.
Phase 2 involves the development of Eco Logic commerc.i.al
process and the identification of any possible process defects
prior to the scheduling 01: a full··scale commercial demonstration
with EPA Headquarters.
EPA believes that when conducted in accordance with the
conditions of approval in this permit, these tests will not cause
an unreasonable risk to health or the environment by
inadvertently releasing PCBs into the environment.
Business Confidentiality
Pursuant to the regulaLions at 40 CFR Part 2, Subpart B (41
Federal Register, 36905, September 1, 1976, and 43 Federal
Register, 39997, September 8, 1978), Eco Logic is entitled to
assert a business confidentiality claim covering any information
Eco Logic submits under this R&D approval. If such a
confidentiality claim is not asserted with any submission, EPA
may mak<:>. this information available to the public without further
notice to Eco Logic. 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 niust conform to the requirements set
forth in 40 CFR §2.203{b).
Liability
The issuance of this R&D approval does not release Eco Logic
. 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 ot this approval are
enforceable under TSCA and its implementing regulations, 40 CFR
Part 761. Any actions by Eco Logic whic.h violate. the terms and
conditions of this letter, TSCA, or the regulations may result in
administrative, civil 1 or criminal enforcement by EPA in
accordance with Section 16 of TSCA, 15 U.S.C. §2615.
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SENT BY:EPA 5-27-97 16:06 NAT'L CHEM PROG DIV~
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Conditions of Approval
1. Advance Notificat:Lon: A 30-day advance written notice
of the proposed tests must be provided to the PCB Coordinator of
the appropriate EPA Region, and the State, and local officials
governing the site where the Eco Logic mobile test equipment is
located. These notices must include the dates and sites of
operation for Eco Logic's process, along with an estimaLe of the
length of testing. In addition, these notices must include
information pertaining to tho type of process to be used, type::: of
material to be treated~ amount and concentration of material to
be treated, and information on how to contact responsible
parties. A sample form is enclosed. Copies of these letters
must be sent to the Chief, Fibers and Organic Branch of the
National Program Chemicals Division, (7404) at EPA Headquarters
to be kept on file.
?. . .A.gency Permits and Approvals: Prior to commencing the
tests, Eco Logic must obtain any necessary Federal, State or
local permits or approvals. During the course of the testing,
Eco Logic shall comply with all conditions and requirements .of
::mch permit::; or u.pprovu.ls. Waste materials containing PCBs in
the concentration range of approximately 200 ppm o:f PCBs or above
may also contain levels of hexachlorobenzene at levels regulated
for disposal under the Toxicity Characteristic Revisions (55
Federal Register, 11796, Mctrch 29, 1990 of the Resource
Conservation and Recovery Act (RCRA) regulations.
3. Feedstock Quality and Restrictions: 'rhe Eco Logic
process may be used to treat the following:
Media mP-an8 ~ont-.ami nAted soils, sediments, paint coatings, PCB
oils, PCB soaked insulation and othe~ bulk solid materials.
a. For chemical destruction:
Phase l -
1000 pounds of contaminated media with a maximum
concentration of 500,000 ppm.
lO tons maximum of con'taminc:itcd media with a maximum
concentration of 500,000 ppm~
A report for the work on Phase 1 is required to be submitted
before the beginning ot Phase 2 to EPA.
4. ProcRRS WaRtR Restri.c tions: All waste generated as a
result of this process must be disposed of as if it contained the
original concentration of PCBs as found in the feedstock. The
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SENT BY:EPA 5-27-97 16 :07 NAT'L CHEM PROG DI V_,
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wa s t es produced by this process inc lude, but are not limite d to,
t h e pro cessed wastes and solvents, any used filters a n d p rocess
water employed in the sysU:::n1.
5 . Process Quality Control: All sample s drawn mu st be in
accordanc e with Eco Logic's QAPP to the permit application dated
April 4, 1995. The final samples drawn at the end o f the
decontamination process, to c onfirm that PCB c onc e n tra Llons is <2
ppm wi ll he drawn i.n duplicat e .
6 . Process Moni toring/Recordkeeping: P:t.·ovi s i ons must be
made t.o assure that the following process elements are suitab l y
monitored and recorded for each run during these tests:
a. amount and initial PCB c oncentration of
contaminated media;
b . final PCB concentration of the processed waste;
c. date, time, and duration of each run ;
d. the name of laboratory manager or proj ect manager mus t
be written in each bound not~ho ok. Each p roject will
be contained i.n a single notebook;
e . final concentration of the dibenzofurans a nd
dibenzodioxins in the scrubber effluent (liquid u.nd
particulate), scrubber product, treateq. s olids, s tack
exhaust and scrubbed product gas
7. R&D Test Report: All test results and related inf ol:ma Lion
on this R&D project shall be incorporated into a test r eport
and submitted to National Program Chemical Division, NP CD
for e v aluation. The R&D test report should inc lude, at a
minimum, the following items:
a . Certification letter. This letter, signed by a n
authorized official, must certify on behalf o f the
applicant that the tests were carried out in acco rdance
with tl~ approved application and the results o f a l l
determinations are s ubmitt::e d in the report. l'my
changes or deviations by the applicant from the
application must be documented and submitted in wrj.ting
to NPCD.
b. Detailed discussion of all p r ocess operations,
operational problems, if any, and corrective actio ns.
c. Chronology of significant e vents.
d. Quality assurance (QA) report. This report should
address all the QA objectives, including whether o r not
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SENT BY:EPA 5-27-97 16:07 NAT'L CHEM PROG DIV~
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precision and accuracy objectives were met, as well as
results of quality control samples, performance audit
samples and systems audits.
e. Waste handling. Eco Logic must provide documentation
(copies of manifest and certificates of destruction) t o
show that all wastes g cnGrated during this R&D project
were properly disposed of according to the regulations
found in TSCA, the ResourcP-Conservation and Recovery
Act (RCRA), and the Clean Water Act (CWA). Eco Logic
should be aware that all waste generated during these
tests should be disposed of by incineration and not
landfilling, unless compliance with the L:mdfill
restrictions can be demonstrated.
This intormation along with the information in Condition 6
and all other pertinent test data shall be incorporaLed into a
summary test re.port. and submitted to EPA Headquarters befo re a
process demonstration test with Eco Logic starts. Phase 1 test
report shall be submitted to NPCD before Phase 2 is approved by
NPCD orally or in writing. Phase 2 test report ehall be
submitted to NPCD before a process demonstration approval is
issued by NPCD.
8. PCB Releases: In the event Eco Logic believes, or has
reason to believe, thal a reled8e has or might have occurred, the
facility operator must inform the Chief of Fibers and Organico
Branch at 202-260-3933 and the appropriate EPA Region PCB Region
coordinator immediately.
A w:r·itten report describing the incident must be submitted
by tqe close of business on t.he next. regular business day. No
PCB-contaminated waste may be processed in the facility until the
release problem has beeh corrected to the satisfaction of EPA.
9. Facility Ini:::pect:i.on: EPA employees shall have acc ess
to the Eco Logic process during the test runs for purposes of
inspection, observation, or sampling. This access is subject to
the normal safety requirements placed on Eco Logic personnel.
10. Safety and He«lth: Eco Logic must take all necessary
precautionary measures to ensure that the operation of the Eco
Logic process is in compliance with the applicable safety and
heal'th standards, as required by Federal, State, and local
regulations and ordinances.
11. Facility Security: The Eco Logic process shall be
secure d {e.g., fence, alarm system, etc.) at the t e st site to
restrict pubJ.j,c access to the area. Any personal injury
occurring as a result of the Eco Logic process must be reported
to the EPA PCB Coordinator by the next regular business day.
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SENT BY :EPA 5-27-97 16:07 NAT'L CHEM PROG DIV---1
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12. PCB Spills: Any spills of PCBs or other fluids shall
be promptly controlled and cleaned up in accordance with the TSCA
PCB Spill Cleanup Policy and procedures (see 52 Federal Register,
10688, April 2, 1987). In addition, a written report describing
the sp.ill, operations involved, and cleanup actions must be
submitted to EPA within five (5) business days.
PCB spills must be :r.·eported in accordance with Lhe PCB spill
reporting requirements prescriherl under Section 311 of the CWA
for discharges to navigable waters and under the Comprehensive
Environmental Response, Compensation, and Liability Act
(Superfund) for discharges to other media.
13. R~rsonnel Training: Eco Logic is responsible for
ensuring that personnel directly involved with handling PCB or
PCB-Contaminated material or using the Eco Logic process are
demonstrably familiar with the general .requirements of this R&D
approval. At a minimum, this information includes:
a. the type of material which may be treated during
the testing of the Eco Logic process;
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 wastes
generated during the testing of the Eco Logic process.
In r.l, i r: regrn:-d, Eco Logic must maintain. on-site, during the
testing of their destruction process, a copy of this R&:D
approval, the spill prevention and cleanup plan, and the sampling
and analytical procedures used to determine l?CB concentrations in
the uced proceas water.
14. PCB Transgort Restrictions: All PCB material, and
other waste by .. products may not be transported off-site except
for purposes of proper disposdl. PCB material transported off
the site for purposes of disposal must be in accordance with 40
CFR Section 761.40 and the DOT requirements of Title 49, CFR Part
172. Such requirements include placarding and labelling all
PCBs.
15. PCB Regulations Com~lianQ~: Eco Logic shall comply
with all applicable requirements of the Federal PCB Regulations,
40 CFR, Section 761, in the operation of the Eco Logic
destruction process. Particular note should be gi.ven to:
a. 40 CFR, Section 761.60 -Disposal requirements;
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SENT BY:EPA 5-27-97 16 :07 NAT'L CHEM PROG DIV~
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b . 40 CFR, Section 761 .65 -Storage for disposal;
c. 40 CFR, Section 761. 79 ·· Decontamimttion; and
d. 40 CFR, Section 761.180 -Records and monitoring.
e. 40 CFR, Section 761.202-218, subpart K, PCB waste
disposill -Records and reports.
16. Process/Equipment Modifications: Any departure from
the conditions of this R&D approval or the terms expressed in the
application submitted by Eco Logic must receive authorization
from EPA Headquarters. Verbal communications with EPA must be
followed within ten working days by a written notification from
Eco Logic describing all modifications. In this context,
"application and R&D plan11 shall be defined as all data and
materinls which have been received by this Agency from Eco Logic
regarding their decontamination and treatment process.
17. Permit Effective Dates: This R&D approval shall become
effective on May 26, 1997, and shall expire on May 26, 1998.
Under the above conditions, and given the circumst.anr.es
under which the R&D tests will be conducted, EPA Headquarters'
National Program Chemicals Division finds, pursuant to 40 CFR,
Section 76l.60(e), that these tests will not present an
unreasonable risk of injury to health or the environment.
This approval is valid when conducted within the Edgewood
Research Development, Engineering Center {ERDEC) Toxic Test
Chamber Facilities, Aberdeen Proving Ground, Maryland. This
approval is also valid when conducted at a laboratory facility
which offers the same standards of protection to human health and
the environment and analytical equipment as that of Eco Logic.
This approval is valid only when the process is operated by Eco
Logic personnel and/or ERDEC personnel.
Approval to conduct R&D testing into decontamination and
treatment of PCB-contaminated waste is hereby granted to ELI Eco
Logic Int!=!rnational Inc., of Ann Arbo.r·, Michigan, subject to Lhe
conditions expressed herein, and consistent with the materials
and data included in the Eco Logic application.
Melone, Director
ational Program Chemicals Division
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SENT BY:EPA 5-27-97 16:08 NAT'L CHEM FROG DIV~
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Sample Form
THIRTY DAY NOTIFICATION OF INTENT TO DISPOSE OF PCBs
Company Name
Person and Phone Number for:
EPA Regional Contact
State Contact (including organization ap~lication)
Local (Town/City/County) Contact (include organization
application)
Nature of the Dispo@al Activity
Please indicate:
Kind of Process:
(1) Incineration, (2) Other Thermal, (3) Chemical
Dechlorination, (4) Other (describe)
Kind:s of Material to be Treated:
Location
(1) Soils, (2) Aqueous and nonaqueous waste
streams, (3) Liquids from decontamination
operations (4) Other Fluids (describe sou,rce), (5 )
Other Solid Materials (describe source)
Street Address or Other Identifier for All Sites:
Telephone Contact and Address for Site Manager:
Time of Processing
Date ( s) :
Time (s) :
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