-------


^.
1







eo

0
vO
S
_
5
3
O
H
CN
vO
CN

W
O
J
0
o




fa
o
co
u
M
.H


ft
O
ea
§
cn
53

fc
A
<
^j
<
0
i— i
S
w
o


•
a
pa
^C
H










o
*o
m




CM
-a-
m





in
NO
-*









m
vO
m
CM







o
i-4





CO
vO






CM

CM











•-4
U
O
CM
 <•
i o o c* CM
h o ij a < i i-i i
03 r^ QJ *r4 C^ in in CO O
•-4 41 § 41 CO • .CM


CJ
o
CO CT*
- 3 >* CM a\
a .-4 o -H a* m o o
a) 1-4 T4  <$ in • «CM
™ ° -0 ** a *° ^ °'~'


4)
a
1^
f>-l
1-4
03 h
4) U 41
e£l g s ^ g^

o

O JJ o
J3 >4 2 S 2
41 3 41 Z O 1
»£ O Oi rH vO O O N™*


g
fl ^\
i-i mo
41 < . c)
X m 3 CM 2 2 3 o dS


«?
O •*«*
U 00 0
1 1 I p
4) "S "S If 33 (?
S § K . lu -H


8 ^ § S « |

_
i^N
o ^>
O GO
m m 3
cs 
O ' 00
m o ss
0 ^1 °
r» o CM i § ^-i
st m • in o CM
•-4 ^ i-i CM ^ 0 C3



O ^
O CO
m o S3 to
CM CM CM .
°. 0



^^
o
0
m  * a -a a
•^ a h -o s o- •
u> A 5SS o"8 S£
o • aua u * Nom


1 1 s«l 11 Is







n. a*
3 3
H H
Z Z




SE
CM <•




O. O4
« «
SS Z










<: <
Z Z






P- A4
11





PU CU
pa ca
Z Z







3 3
Z Z





a
O 4)
°_<§-
a "o
"2 *


tx.
                     S
                     as
                     11
                     si
                      a
15

-------























-^
•o
tu
3
•f*4
JJ
e
o
u

g
m
W
t5

































o
vo

in



CM

•a-
m




in
vO




m
vo
in
CM




O
r-
CM
1-1



CO
vO
CM





CM

CM
1-4












U
0
1-4
U
o

in
vO
m CM i-i
O CM 1
f-l CM O
1 1 VO
CO CO VO
•< •< en o •
Z Z CM i-4

CM CM
in 1-4
1 1
vo in vo in
-a- 1-4 sr 1-1 •<
••-I r> &


vo
vO
1-4 1-5
vo in I

o a vo
X Z "° 3 *4
CM
CM VO
r» 1-1
I i
\o en
Z Z r-4 Z



Z
CO
1
en
•<; •< -* <; <
z z CM z z

O CO
r« «n
•-! cn
t i
O CM
< < in o <
x si ~i m &
1-4

t-4
1
1-1
CO O
co in
i in vo
co en ^4 -ai  CM
•H U C W i-l
0 -4 4JO
B.Z eg o CM
t4 Ul 4J CO U Q
3 ^ 44 ^ *M
O •-^ O --^ tl (3
04 0) »








z z z
o
a

1
2zl
z z fn
u
o
CO
•-1
O to
in o
i-* in
1 VO
< O C-4
Z cn ~




zzS






ggg







z z z
u
0
1-1
0 —
m to o
co o es
1 O i-l
O vO 1
O i-l vO
VO •^ CO




a ^ catjea

§a oo 
t4 • • •
U 0 t—  co m en

C3 co

u u a o o o
•-4 rt 0 CO i-4
a O X 1-4 »H CM
0 J3 H
o >%c/>
ca oj <
> W ^












































C
ft
o
PH
00
a
• i-i

"* "°
1-4 O
vl 4J

> 11

U Z
a
Z 1
i eu

z z
16

-------
production because of widespread environmental concerns about PCBs.  Monsanto
marketed PCBs under the tradenames "Askarel" and "Aroclor."8'13  Dielectric
fluids containing PCBs have been marketed by several companies under a variety
of tradenames which are listed in Table 6.
    Before 1977, PCBs were produced by the chlorination of -biphenyl with
anhydrous chlorine, using iron filings or ferric chloride as catalysts.  The
crude product was purified to remove traces of hydrogen chloride and
catalyst.8  Commercially produced PCBs contained no major components other
than chlorobiphenyls.  Small amounts of chlorodibenzofurans have been detected
in PCB mixtures, possibly as a result of aqueous alkaline washing and steam
distillation in the production process.  PCB mixtures were sold in two
grades:  a purified grade and a darker, less pure, technical grade.^
    Uses of PCBs are presented in Figure 1.  Prior to 1957, virtually all PCBs
were used in the manufacture of electrical transformers and capacitors.  As
discussed earlier, PCBs exhibit low flammability, high heat capacity, and low
electrical conductivity and are virtually free of fire and explosion hazards.
Consequently, PCBs can be used where failures of oil insulated transformers
would present a potential danger to life and property.  PCBs were therefore
used wherever fire protection was particularly important -- for about
5 percent of all transformers.^
    The PCB containing fluids used in transformers are called "askarels."^
These fluids typically contain from 60 to 70 percent PCBs by weight, and from
30 to 40 percent chlorobenzene.^  The amount of askarel contained in a
transformer varies with transformer size.  The literature reports that the
quantity ranges from 150 to 1,890"liters (40 to 500 gal) which weighs 235 to
2,932 kg (516 to 6,450 lb).20
    PCBs have been used in electrical capacitors for many of the same
reasons.  They are needed for safety, reliability and long life and to achieve
sizes compatible with equipment and installation requirements.  PCBs were used
principally in high voltage power capacitors for'power factor correction in
the distribution of electric power; in low voltage power capacitors installed
in industrial plants (typically in large motors); in ballast capacitors to
improve the efficiency of lighting systems; and in small industrial capacitors
                                    17

-------
CO
                1-1
                O
            fl t-4
            o> fi
            o  u
            4J  Q)
            rl  C
            (U  (3
           rl                .13  C
C\     r-4  O      4)      1-130)
00 -C  Or-4r-4  Cl-4  OW.C
-*T4BO3a>Or-4l  4-1
l-4l-43Ot8l-4f3UHO
    o pq  c  i-i  a)    l-l  ^  t-l  4-4  C
O  0)  OfJ3  ^t^k^P^cO^ W     ^
                 ft W W  W
                            1-4  rl
                            0)  O
QUO
O  (3  3
fl  "I
 vO

 (^
 H
                                                  18

-------
O
O
                                           g
                                           o
                                                                    g
                                                                    o
 U <-4
 w  a
 o  o
 4J iH
 TJ  Id
 U W
 a  o  oo
 a.  u  c
 Q i->  -rl
 O W  i-l
        o
  »<-,  o
 u  K  o  a
 v<  o  -. B
 a  e  eo o
    ei-(  C  "^
    S3  -E  u
 o -^  u  a
   c  O.
 H O  M  <
•a  a
•rt  TJ
a  -H
-<  a
(U  rH
    h  a
O      4J
•n  K  a
•-I  u  a
3  , U  3
as  EH  ,j
                  q     0)  n  a
                 VM -o  >  OJ  CM
                  la  B  i-l -O
                  3  (8  a  B  ^>
                 en     a)  41  a.
                     X  ^  u  o
                   -  o  -o  M  a
                  u M  <  u
                  (4            a
                  41   -  .  4)  m
                  H  a  a  -o  4)
                 1-1  eo n  -H  •-!
                  o  s  «  o  B
                 •r! -H  -rt  -r*  O
                  4J  4J  h  4J  ^3  a
                  B  «J  lj  O  H  M
                 1-1  o  m  o)  «  :*,
                 PK o  o  e-  cj  a
     01
     U
     -H  a
 •o  n  a
  a  u  u
  o  o  u
  o  «  m
 1-4  1-1  >\
 u  M  eo
 a -o  B
 B  o  u
•H  as  u
    §0  a
   •-<  ?>
Z O  CO
                                                a
                                                C
                                                o
                  [t]  U
                   i  -r<
                   e i-i
                   a  a.
                   a.  a.
                  o <
 o
U-l

 Ifl
                                                                                                                  0
                                                                                                                  M
                                                                                                                  3
                                                                                                                   n
                                                                                                                   u
                                                                                                                  •H

                                                                                                                   0)
                       •o
                        4)
                        B  --10
                       •*  >>  a
                        U  B  I
                        o  a o
                       .-i  j: i-i
                       X  cus-
                        U  i-l CM
                        X« i-l
                       -I    U
                        O    — '
                                                                                         u

                                                                                         60
                    !-«*-»     0
                     l>\ O    B
                     a  1-1    -3~
                     u  x     M  CM
                    A  CM+  O --I
                     o. ^    ^ o
                    •rf  o
                    «--'
                                             19

-------
for power factor improvement in  such equipment as  air  conditioning units,
pumps, fans, etc.21  The large high voltage capacitors typically weigh  54 kg
(120 Ib) of which 11 kg  (25 Ib)  are PCBss while  the  small ballast capacitors
weigh 1.6 kg (3.5 Ib) of which 0.05 kg  (0.1 Ib)  are  PCBs,,22
    Transformers and capacitors  continued to be  the  main products using PCBs
after 1957, however, additional  industrial applications began  to absorb a
share of PCB production at this  time.   The relative  product use of PCBs for
industrial application between 1957 and 1971, when Monsanto restricted  sales
to closed systems (capacitor and transformer applications), is shown  in
Figure 2.  Additional PCB applications  included  uses in hydraulic fluids and
lubricants, plasticizers, heat transfer fluids,  investment castings,  and in
miscellaneous industrial applications.   These applications are considered
either "nominally closed" or "open systems" due  to the ease with which  the
PCBs may enter the atmosphere during use (when compared to
transformer/capacitor use).  The grade  of Aroclor  used in each of the
aforementioned applications is shown in Table 7.   PCBs were employed  in
industrial hydraulic and lubricant applications  because they exhibited  good
heat and fire resistance and they were  relatively  inexpensive additives that
depressed fluid pour points.  These qualities are  essential when hydraulic
fluids are used in or near a hot operating environment.  For example,
hydraulic dye casting machinery and aircraft engines are two applications
where moderately high operating temperatures combined  with a high probability
for accidents often lead to hydraulic system leaks and the possibility  of
fire.  PCBs were used as lubricants due  to the previously mentioned qualities,
and also because of their oxidation and  foam resistance characteristics and
their low vapor pressure.25
    PCBs gained widespread use in plasticizers because PCBs are permanently
thermoplastic, chemically stable, non-oxidizing, non-corrosive, fire
resistant, and are excellent solvents.   In addition, they are not normally
attacked by acids, alkalines or water and are insoluble in water, glycerol and
glycols.  These compatibility properties are especially useful in
plasticizers.  A plasticizer is a material incorporated in a plastic to
increase its workability and flexibility.  A plasticizer typically is added to
                                    20

-------
      35,000
     30,000
_   25,000
 en
 •z.
 o
 I-
 cc
en
ui
en

0


en
LJ
•s.
o
a

en
 •
     20,000
15,000
10,000
      5,000
                      1   I   '   I   '  I  '  i   '   I   '  i
                                      HEAT
                                      TRANSFER
                            MISC.

                            INDUSTRIAL
                     PLASTICIZER .
                     APPLICATIONS
           HYDRAULICS

           LUBRICANTS
                        CAPACITOR
            I  I   I   I   I   I   I   I   I   I   I  I  I
                                                        i
           1957
                 1961
 IS65

YEAR
1969
'71
I   I
EST.
Figure 2.  Domestic sales of Monsanto1s Polychlorinated Biphenyls

          in the U.S.  (by use).
                           21

-------
               TABLE 7.  THE USE OF PCBs PRIOR TO 197024
           Use
 Grade(s)  of Aroclor
Electrical capacitors

Electrical transformers

Vacuum pumps

Hydraulic fluids
Plasticizer in synthetic
     resins

Adhesives
Wax extenders

Pesticide extenders

Inks

Lubricants

Cutting oils

Carbonless copying paper

Heat transfer systems
 1221,  1242,  1254

 1242,  1254,  1260

 1248,  1254

 1232,  1242,  1248,
 1254,  1260

 1248,  1254,  1260,  1262
 1268

 1221,  1232,  1242,  1248,
 1254

 1242,  1254,  1268
>1254
 1242
                                    22

-------
change the viscosity, make the plastic softer (lower its elastic modulus) or
impact some other specific property.  PCBs added several of these properties
at a relatively low cost.26
    Heat transfer fluids are used to absorb thermal energy from a source and,
by cooling or phase change, deliver heat to a place'of utilization.  PCBs have
been used for these fluids due to their fire resistance, their low power and
viscosities, their good thermal stability and their high heat capacity.2?  In
addition, they are inert and are relatively inexpensive.  However, the
principle reason for use of PCBs as heat transfer fluids is their
fire-resistance.  This is a critical factor in cases where the possibility
exists that fire from high temperature leaks could endanger life and property.
    PCBs were als'o used by the investment casting industry in the production
and subsequent use of PCB-filled pattern waxes.  The investment casting
process is a lost wax casting process.  A pattern is molded by the injection
of the molten casting wax into a metallic die where the wax cools and
solidifies to form the desired shape.  The wax pattern is then surrounded by a
slurry containing a refractory ceramic (known as the investment) to form the
final mold.  After the model dries to an appropriate strength, the wax pattern
is smelted in an autoclave and the wax is recovered for possible future use or
disposal.  Residues of wax remaining in the pores of the ceramics mold are
burned out in a furnace at 1000°C to 1100°C.  Molten metal may then be poured
into the cavity of the ceramic mold to form a casting.  Addition of fillers
such as PCBs or polychlorinated triphenyls (PCTs) to investment casting waxes
was a development of the 1960's.  By reducing the wax content through addition
of low shrinkage fillers, volumetric shrinkage of the ceramic mold may be
controlled.  Between 300,000 and 500,000 kg of PCBs were imported from Italy
for this application in 1972.28
    PCBs are also found used in a host of minor industrial uses.  They were
used in laminating adhesive formulations involving polyurethanes and
polycarbonates to prepare safety and acoustical glasses.  The laminates
improved strength and resistance to delamination over a broad temperature
range, and improved sound absorption and energy dissipation properties.  PCBs
were also used in adhesive formulas to improve toughness and resistance to
oxidative and thermal degradation when laminating ceramics and metals.2^
                                    23

-------
    PCBs were employed with textile coating mixtures for ironing board covers,
as coatings for polypropylene films and yarns and in sealing  formulations to
waterproof canvas.  These applications took advantage of PCBs1 ability to
resist photochemical degradation, oxidation and  fire.30
    PCBs were used in paints and varnishes to impart weatherability, luster
and adhesion.  In combination with other plasticizers, they were employed to
prepare film casting solutions for electrical coatings, insulating  tapes and
protective lacquer.  PCBs are compatible with epoxy resins and give good final
hardness and impact resistance to resin.  These  PCB resins were then used as
protective coatings for metals.  In addition, PCBs were used  in sealing and
caulking compositions to seal joints against water, dust, gas, heat and
certain chemicals.  Here, again, the good chemical and physical resistance
properties of PCBs, their elasticity, weatherability and relative low cost
made PCBs a valuable additive.31
    Chlorinated biphenyls were employed as part  of the formulations used to
prepare pressure sensitive record and colored copying papers, including
graphic duplicating processes, xerographic transfer processes and solvent free
printing.  PCBs used in this application later found their way into many paper
products, when the carbonless copy paper was recycled into a host of other
paper goods, including food packaging.32
    Finally, PCBs were employed for an assortment of miscellaneous uses such
as a soil erosion retardant, in combined insecticide and bactericide
formulations, in plastic decorative articles, as a metal quencher and as an
aid in fusion cutting of stacked metal plates.33
    By 1970, 60 percent of PCBs sales were for closed system electrical and
heat transfer uses, 25 percent for plasticizer applications, 10 percent for
hydraulic fluids and lubricants, and less than 5 percent for miscellaneous
applications such as surface coatings, adhesives, printing inks, and pesticide
extenders.  In late 1970 Monsanto confined PCB sales to closed systems.  By
1971, 90 percent of all PCBs were used in this 'manner, and by 1972,
100 percent.24  Monsanto ceased manufacture of PCBs completely in 1977 due to
increased environmental concerns and the availability of replacement products
to the electrical industry.?
                                    24

-------
    On February 17, 1978, EPA issued a rule governing the marking and disposal
of PCBs.15  The rule applied to any substance, mixture, or item with 500 ppm
or greater PCB concentrations.  In 1979, EPA issued the PCS Ban Rule which
superceded the previous labeling and disposal regulation and lowered the
cut-off point from 500 ppm to 50 ppm.  The final rule was published in the
Federal Register on May 31, 1979, and specifically does the following:

    (1)  classifies the use of PCBs in transformers, capacitors, and
         electromagnets as "totally enclosed;"
    (2)  prohibits, unless authorized or exempted by EPA, the manufacturing,
         processing, distribution in commerce, and the use of PCBs except in a
         totally enclosed manner;
    (3)  provides authorizations for certain processing, distribution in
         commerce, and use of PCBs in a non-totally enclosed manner.
    (4)  prohibits waste oil containing any detectable concentrations of PCBs
         from being used as a sealant, coating, or dust control agent.

Also, the February 17, 1978 PCB Disposal and Marking Rule requirements were
integrated into the PCB Ban Rule.15
    Because the Toxic Substances Control Act (TSCA) considers the term
"import" to be.synonomous with "manufacture", no PCBs (except waste) could be
imported or exported after July 2, 1979 under the Ban Rule unless an exemption
was obtained.  Anyone wanting an exemption from the PCB
manufacturing/importation ban or the PCB processing/distribution ban must
petition EPA for if.  In some instances, individuals may not have to seek
separate exemptions when the Agency grants "class" exemptions from certain
processing and commercial distribution bans.  EPA also could grant exceptions,
known as authorizations, without a specific request from those who would
benefit from the authorization to enable the continued processing,
distribution, or use of PCBs in a non-totally enclosed manner after
July 2, 1979.  Exemptions are only valid for a maximum of one year, while
authorizations may be granted for longer periods of time.  Examples of
non-totally enclosed PCB activities and uses which have been authorized by EPA
are as follows s^
                                    25

-------
    •    Servicing PCB Transformers and PCB-Contaminated Transformers;
    •    Use in and Servicing of Railroad Transformers;
    •    Use in and Servicing of Mining Equipment;
    •    Use in Heat Transfer Systems;
    •    Use in Hydraulic Systems;
    •    Use in Carbonless Copy Paper;
    •    Pigments;
    •    Servicing Electromagnets;
    •    Use in Natural Gas Pipeline Compressors;
    •    Small Quantities for Research & Development;
    •    Miscroscopy Mounting Medium.

    On October 30, 1980, in response to a petition from the Environmental
Defense Fund, the U.S. Court of Appeals for the District of Columbia Circuit
set aside portions of the May 31, 1979 Ban Rule.  The court remanded the set
aside portions to EPA for further action.  Responding to the court order, EPA,
on August 25, 1982, amended the May 31, 1979 rule by authorizing the totally
enclosed use of PCBs in certain electrical equipment.33  Among other things,
this amendment authorizes the continued use of PCB small capacitors, the use
of PCB large capacitors until 1988 or longer if certain conditions are met,
and the use of PCB transformers and PCB-contaminated transformers, if certain
conditions are met.  The 1979 rule was further amended on October 21, 1982
when EPA issued a rule excluding from regulation the manufacture, processing,
distribution in commerce, and use of PCBs created in closed manufacturing
processes and controlled waste manufacturing processes.-*3  EPA considers these
PCBs to present very low risks.  This rule permits the manufacture,
                                               t
processing, and distribution in commerce of PCBs without an exemption,
provided that (1) the PCBs are released only in concentrations below the
practical limits of quantitation for PCBs in air emission, water effluents,
                                   26

-------
products, and process wastes and (2) the wastes from these manufacturing
processes are controlled and disposed of in accordance with the methods for
disposal specified in the rule.33
    On July 10j 1984, a third amendment to the 1979 rule was issued by EPA
that excludes from the TSCA ban on PCBs certain processes that inadvertently
generate PCBs in low level concentrations.  Other rules were issued by EPA en
the same date which dealt with over 100 pending exemption petitions to
manufacture, process and distribute PCBs in commerce and which authorized the
use of PCBs in certain kinds of microscopy, and research and development
situations.  EPA believes that the PCBs permitted by these activities would
not present an unreasonable risk to human health or the environment.33
    Results from a study of the current distribution of PCBs in the United
States are as follows:

         Category                    Amount                      Percent
    Presently in use              3.40 x 108 kg                    60%
    In landfills and dumps        1.32 x 108 kg                    23%
    Released to environment       0.68 x 10** kg                    127»
    Destroyed                     0.25 x 108 Kg                     5%
                   TOTAL          5.65 x 108 Mg                   100%

The results indicate that of the 5.65 x 108 kilograms (1.25 x 109 Ibs) sold
between 1930 and 1977, 95 percent remains in service, in landfills, or at
large in the environment.^3
                                   27

-------

-------
                                   SECTION 4
                              PCB- EMISSION SOURCES

    The development of emission factors for PCBs presents unique problems not
encountered with standard emission factor development.  These problems can be
summarized as follows:

    •    PCBs have not been produced (except for limited cases) in the U.S.
         since 1977;
    •    PCBs have not been used in "open systems" (those with maximum
         atmospheric release potential) since 1971;
    •    Atmospheric evaporation, transformation and degradation of PCBs 'are
         complex phenomena dependent upon many variables; and
    •    Little research has been conducted to quantify PCB emission rates
         from product use and/or disposal.

    Due to the ban on PCB production and open system use, PCB emissions from
these sources have effectively been halted.  Release to the environment as a
consequence of all PCB use occurred prior to 1970 and was, for the most part,
unintentional.  The major mechanisms by which PCBs are lost to the environment
include aerosolization (during leaks and spills), adsorption onto particulates
(during combustion), and volatilization.  Prior to 1970, the major pathways by
which PCBs were released during use included spillage and vaporization of FCB
containing paints, coatings and plastics; migration and leaching froiu surface
coatings and packaging; leakage from faulty heat exchange systems and
partially sealed hydraulic systems; and burnout of PCB containing ballasts in
fluorescent light fixtures.34-  As the PCB-containing products have been
discarded, the major source of PCB emissions into the environment has shifted
to disposal/destruction methods (e.g., incineration, landfilling).  Incomplete
combustion in an incinerator or boiler may result in the release of PCBs or
PCB byproducts.  Another source of PCB emissions is accidental release due to
failure of an existing piece of PCB equipment (resulting in spills or leaks)
                                   28

-------
or an accident (e.g., fire) to a piece of PCS equipment in service.  This
section discusses these activities and presents information on the potential
for PCB releases from each.

DISPOSAL/DESTRUCTION METHODS

    EPA's PCB regulations  (40 CFR 761) set specific disposal requirements for
PCBs and PCB items currently in service.35  The requirements are summarized in
Figure 3.  The regulations make distinctions between PCBs, PCB articles (items
that contain PCBs and whose surface(s) have been in direct contact with PCBs),
and PCB containers (barrels, drums, containers, etc. that contain PCBs and
whose surface(s) have been in direct contact with PCBs).  Within these
categories, the regulations make a further distinction based on the PCB
concentration of the waste.  Acceptable PCB disposal technologies are then
based on this PCB concentration.  There are a limited number of disposal
options, summarized as follows:

    •    "Annex I" Incinerators;
    •    High Efficiency Boilers;
    •    "Annex II" Chemical Waste Landfills; and
    •    Other Approved Disposal Methods.

A brief review of these disposal techniques will serve to highlight the
principal characteristics of each.

Annex I Incinerators

Technology Descriptions—

    These incinerators take their designation from the technical standards and
other criteria that they are required to meet when destroying liquid PCB
wastes.  These standards and criteria are found in Annex I of EPA's PCB
                                    29

-------
                                                          WASTE CHARACTERIZATION
                                                                                                                     DISPOSAL REQUIREMENTS
                                      t— Mineral Oil Dielectric fluid*
                                             Frena PCS Tranaformera
                                       — Mineral Oil Dielectric Fluid*
                                             From FOB Contaminated
                                             Transformer*
                                          PCS Liquid Haite* Other Than   	
                                             Mineral Oil  Dielectric fluid
                                                                               Thoae Analyzing > 500 PPM FOB
                                                                               Thoae Analyzing 50 - 500 PPM PCB —
                                                                               Thoae Analyzing > 500 PPM PCB
                                                                           	 Thoae Analyzing 50 - 500 PPM PCB —
                                      1— Bon-Liquid PCB Waate* —
                                             (e.g.  Contaainated
                                             Material*  from Spill*)
                                      — Dredged Material! and -
                                             Municipal  Sewage
                                             Treatment  Sludge*
                                             Containing FGBa
                      PCB Article*
                                          Iran*former•
    CFCB Tran*former* —••—•—'-—•—•-—



    PCB Contaminated tran*former*
                                      —— PCB Capacitor*
                                          PCB Hydraulic Machine*
C
                                      -— Other PCB Articles
r—


*—*
                      PCB Container* —
                                         • fho«* U*ed  to Contain Only PCB*  •
                                             At a Concentration < 500 PPM
                                          Other PCB Container*
    Thoae Containing > 1000 PPM PCB


    Tboae Containing < 1000 PPM PCB


    Those Containing PCB Fluid* 	
                                                                              Those Hoc Containing PCS Fluid*
                                           Annex I Incinerator'"

                                           Annex X Incinerator

                                           Bigh Efficiency  Boiler 140 CFR 761.10

                                           Annex I Incinerator

                                           Annex I Incinerator

                                      	 High Efficiency  Boiler [40 CFR 761.10U)(3)(111) I

                                           Other Approved Incinerator

                                           Annex II Chemical Ua*te Landfill

                                           Annex I Incincerator

                                           Annex II Chemical Waate Landfill

                                           Annex I Incinerator

                                                                  Landfill
•C
E      Annex I Incinerator

      Annex II Chemical  Wa*te Land

      Other Approved Dicpoial Method
       (40 CFR 761.10(*)(5KUi]

C      Annex I Incinerator

      Drained and Rlnaed tranaforcer*
                                     May be Disposed
       of In Annex II  Chemical Waste Landfill

    - Disposal of Drained Transformers
       1* Not Regulated

    * Annex I Incinerator*^'

    * Drained and Rinsed Machine* Hay be Disposed of
       A* Municipal Solid Hast* or Salvaged

    • Drained Machine* May be Disposed of as
       Municipal  Solid Waste or Salvaged

    * Drained Machine* May be Disposed of Per
       Annex I or Annex II

    1  Annex I Incinerator or Annex II Chemical
       Wa*t* Landfill

    '  A*  Municipal Solid Waste Provided  any  Liquid
       PC&a are Drained Prior to  Disposal

    - Annex I Incinerator
E                                          Annex I Incinerator

                                          Annex II,  Provided Any Liquid PCB* Are
                                           Drained Prior to Disposal

                                          Decontaminate Per Annex IV
                      (1)   Annex I Incinerator defined in 40 CFR 761.40.
                      (2)   Requirement* for other  approved incinerator* are defined in 40 CFR 761.10(c).
                      (3)   Annex II chemical v**t« landfill* are described In 40 CFR 761.41.   Annex II diapoaal la permitted If the PCB vaate
                           analyze* It** than 500  pom PCB and 1* not  Ignltabl* a* per 40 CFR  Fart 761.Al(b)(8)(iii).
                      (4)   Dl*po**l of containerized capacitor* in Annex  II landfill* 1* permitted until Kerch 1(  1981.  Thereafter, only Annex I
                           Incineration la permitted.
                                        Figure  3.    Disposal  requirements  for  PCBs  and  PCB  items.
                                                                                                                                            36
                                                                                 30

-------
regulations.35  The minimum operating requirements for disposal of liquid
wastes presented in Annex I include:

    •    2 second dwell time at 1200°C (2190°F) and 3 percent excess oxygen; or
    •    1.5 second dwell time at 1600°C (2910°F) and 2 percent excess oxygen.

    The dwell time refers to the residence time of the PCBs in the combustion
chamber, while the oxygen content is measured in the stack gas.  Additional
criteria, including monitoring requirements, approval conditions, and trial
burn requirements, are also included in the Annex I citation.  These
requirements should be referenced directly to resolve any questions.
    While the .Annex I incinerators were established for liquid PCS wastes,
they may also be employed for solid PCB disposal, provided a destruction and
removal efficiency of 99.9999 percent is met.  Eeference 36 provides a
complete description of operating principles, advantages and disadvantages and
test data for each incinerator design.
    Commercial or industrial incinerators that are intended to destroy liquid
PCB wastes must demonstrate compliance with the Annex I requirements through a
comprehensive trial burn program.  As of 1986, four stationary commercial
incinerators, eight industrial incinerators and two mobile incinerators were
approved as Annex I incinerators under these requirements.37-40  However,
these numbers are subject to change as new approvals are granted, operations
are terminated, and so on.  The commercial units include those operated by
Rollins Environmental Services in Deer Park, Texas; Energy Systems Company
(ENSCO) in El Dorado, Arkansas; General Electric Company in Pittsfield,
Massachusetts; and SCA in Chicago, Illinois.  In addition to approval under  .
the Annex I requirements, Rollins and ENSCO have been approved for solid PCB
disposal under the 99.9999 percent destruction requirement.
                                              i '
    The industrial PCB incinerators approved under Annex I are operated by the
General Electric Company in Waterford, New York; by Dow Chemical in Freeport,
Texas; Oster Creek, Texas; and Plaquemine, Louisiana; by Vulcan Materials in
Geismar, Louisiana; by PPG in Lake Charles, Louisiana; by LaPort Chemical
Corporation in Pasadena, Texas; and by Los Alamos Scientific in Los Alamos,
                                   31

-------
New Mexico.  The Annex I mobile incineration systems are operated by EPA,
Edison, New Jersey; and by Pyrotech, Tullahoma, Tennessee.  The Annex  I mobile
systems have been tested and approved to operate in all ten U.S. EPA regions.^
    Finally, it must be mentioned that municipal sewage sludge incinerators
are used to incinerate PCB-containing sludges at certain locations throughout
the country.  This condition has resulted from the inadvertent PCB
contamination of municipal sewer systems resulting from historical PCB
disposal.  As sludge incinerators are not designed to operate in the
temperature ranges specified for the Annex I requirements, they do not insure
sufficient destruction of the PCBs.  In addition, municipal waste incinerators
have been identified as potential PCB emission sources due to their processing
of PCB-containing wastes.  Sewage sludge and municipal incinerators are
discussed later in this section.

Emissions—

    ApprovedIncineration of Liquid PCB Wastes-Published PCB destruction
efficiency test data for 11 of the EPA approved Annex I liquid waste
incinerators are presented in Table 8.  The location and type of incinerator
associated with each facility is also presented along with the PCB emission
factor that results from applying the stated destruction efficiency on inlet
PCB level for each unit.  The units for the emission factors are grams of PCB
emitted per kilogram of PCB charged (g/kg).  As can be seen from the table,
these emission factors vary as much as four orders of magnitude.  However,
this is not reflective of optimum Annex I incinerator performance.  Several of
these tests were not compliance determinations, but rather research and
development efforts, and were not necessarily conducted under optimum
conditions.  Furthermore, several of the destruction efficiency values were
reported to only two significant figures, making it impossible to calculate an
emission factor less than 0.1 g/kg.  For those'test results that were reported
to five or six significant figures, the corresponding emission factor is, in
most instances, less than 0.001 g/kg.  This level is indicative of optimum
Annex I performance.  The average PCB destruction efficiency for all
stationary incinerator test data presented in the table is 99.997.  This
corresponds to an emission factor of 0.03 g/kg.

                                   32