United States EPA-800/2-,81-033a
Environmental Protection
Agency March 1981
c/EPA Research and
Development
APPLYING FOR A PERMIT
TO DESTROY PCB WASTE OIL
Vol. I. Summary
Prepared for
Office of Toxic Substances
Prepared by
Industrial Environmental Research
Laboratory
Research Triangle Park NC 27711
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RESEARCH REPORTING SERIES
Research reports of the Office of Research and Development, U.S. Environmental
Protection Agency, have been grouped into nine series. These nine broad cate-
gories were established to facilitate further development and application of en-
vironmental technology. Elimination of traditional grouping was consciously
planned to foster technology transfer and a maximum interface in related fields.
The nine series are:
1. Environmental Health Effects Research
2. Environmental Protection Technology
3. Ecological Research
4. Environmental Monitoring
5. Socioeconomic Environmental Studies
6. Scientific and Technical Assessment Reports (STAR)
7. Interagency Energy-Environment Research and Development
8. "Special" Reports
9. Miscellaneous Reports
This report has been assigned to the ENVIRONMENTAL PROTECTION TECH-
NOLOGY series. This series describes research performed to develop and dem-
onstrate instrumentation, equipment, and methodology to repair or prevent en-
vironmental degradation from point and non-point sources of pollution. This work
provides the new or improved technology required for the control and treatment
of pollution sources to meet environmental quality standards.
EPA REVIEW NOTICE
This report has been reviewed by the U.S. Environmental Protection Agency, and
approved for publication. Approval does not signify that the contents necessarily
reflect the views and policy of the Agency, nor does mention of trade names or
commercial products constitute endorsement or recommendation for use.
This document is available to the public through the National Technical Informa-
tion Service, Springfield, Virginia 22161.
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EPA- 600/2 -81-033a
March 1981
Applying for a Permit to Destroy
PCB Waste Oil
Volume I. Summary
by
Steven G. Zelenski, Joanna Hall, Sue Ellen Haupt
GCA Corporation
GCA/Technology Division
Bedford, Massachusetts
Contract No. 68-02-2607
Task Order No. 33
Program Element No. C1Y1B
EPA Project Officer
David C. Sanchez
Industrial Environmental Research Laboratory
Office of Environmental Engineering and Technology
Research Triangle Park, N.C. 27711
Prepared for:
U.S. Environmental Protection Agency
Office of Research and Development
Washington, D.C. 20460
U.S. Environmental Protection Agency
Ration V, Library
230 South Dearborn Street
Chicago, Illinois 60G04
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ABSTRACT
This report documents the permitting process followed by the State of
Michigan before allowing a trial destruction burn of polychlorinated biphenyls
(PCBs) at the Genral Motors (GM) Chevrolet Bay City plant. The report is
divided into two volumes. Volume I includes a chronology of events and a
matrix depicting the interaction of Federal, state, and local government
agencies and GM in the permitting process. The matrix presents a list of who
requested and who responded to each need for additional information. An
analysis of the significance of interactions, including interagency communica-
tions, private sector-public communication, and the flow and quality of infor-
mation developed, is provided. Finally, recommendations that are based on this
permit application process and that might facilitate subsequent permit applica-
tions for burns of hazardous materials are made.
Volume II of this report contains the relevant documents summarized in
the lists presented in Volume I. Copies of Volume II may be obtained on request
from EPA.
This work was performed under Contract No. 68-02-2607, Task Order No. 33
during the period May 1979 through December 1979.
U,S. Environmental Protection Agenr-
ii
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CONTENTS
Abstract ii
Figures iv
Tables iv
1. Introduction 1
Background of need for permit application 1
Participants involved in permitting process 3
Background of public sentiment regarding incineration
of PCBs 4
2. Chronicle of Events 6
3. Information Required During Permitting Process 13
4. Press Coverage of Permit Application Process 16
Press coverage during the application process 16
5. Conclusions and Recommendations 18
Appendix
A. GCA/Technology Division Original Test Plan 20
iii
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FIGURES
Number Page
Organization chart of Air Quality Division of Michigan Department
Department of Natural Resources 5
TABLES
Number
Display Depicting Types of Information Requested, Who Requested
It, and Who Provided It, Along with Dates for Each Event. ... 14
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SECTION 1
INTRODUCTION
BACKGROUND OF NEED FOR PERMIT APPLICATION
Before the enactment of the Toxic Substances Control Act (TSCA) in
October 1976, the EPA's authority covering polychlorinated biphenyls (PCBs)
was limited to the regulation of contaminated water from point sources. In
the Clean Water Act of February 2, 1977 under Section 307(a) (42FR6532-6556),
the Environmental Protection Agency (EPA) promulgated a rule banning the
discharge of PCBs into navigable waters by electrical transformer and capacitor
manufacturers.
Then, on February 17, 1978 (43FR7150-7164), acting under TSCA, the EPA
promulgated a rule regulating the disposal of PCBs and requiring that special
warning labels be applied to large capacitors, transformers, and other PCB
items. This Disposal and Marking Rule covered liquid PCBs as well as other
material and equipment components containing or having contained PCBs in con-
centrations greater than 500 ppm. This rule was further clarified by amend-
ments published on August 2, 1978 (43FR33918).
The Final PCB Ban Rule appeared in the Federal Register on May 31, 1979
(44CFR761:31514-31568) and took effect on July 2, 1979. This rule integrates
the February 17, 1978, PCB Disposal and Marking Rule with the Production Ban
Rule; therefore, the Final Ban Rule provides the total scope of PCB regulations
up until July 2, 1979, its effective date. These regulations have led to the
accumulation of large volumes of PCB-contaminated fluids while sources attempt
to develop and use acceptable means of disposal as provided by Subpart B.
One source of PCB-contaminated fluids is produced by the contamination of
process machinery oils by PCB residuals. PBCs had been used previously in cut-
ting oils because of their flame retardant properties, which provide greater
machine operator safety. Because of the tenacity of PCBs to surfaces, each
time the machinery is flushed with oil free from PCBs, the flushings become
contaminated by residues in the machinery.
The EPA has established that if the PCB concentration of these fluids is
in the range of 50 to 500 ppm, the fluid may be destroyed by incineration in
an industrial boiler. The Federal regulation (4QCFR761) stipulates that:
(1) the boiler must be rated at least at 50 million Btu/hour,
(2) the PCB-contaminated waste must constitute no more than
10 percent of the total volume of fuel,
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(3) the waste must not be added to the boiler during startup
or shutdown,
(4) certain combustion and fuel feed conditions must be
monitored during the burn,
(5) the regional EPA administrator must be notified within 30 days
of the proposed burn, and
(6) the regional EPA administrator must grant approval for the
burn.
The facility at Bay City, Michigan, run by Chevrolet Division of General
Motors (GM) is presented with the problem described above, having accumulated
approximately 60,000 gallons of hydraulic fluids contaminated with PCBs in the
concentration range of 50 to 500 ppm. This facility has the following basis
for disposing of its wastes by incineration.
It possess two boilers in the size range required by EPA for
incineration of waste oil.
It possess a large volume of PCB-contaminated oil in the con-
centration range allowed by EPA for industrial incinerator
destruction.
It had previously burned PCBs in its boilers, and its tests
showed excellent destruction efficiencies,
After receiving notification from Mr. Potter, Vice President
for Environmental Activity of GM, EPA had contacted GM and
asked if they would be willing to conduct the test.
In addition to notifying the EPA regional administrator, Michigan air
quality regulations require that GM obtain a permit from the State Air Quality
Division under Michigan Act No. 348, Rule No. 21. This regulation provides
that any source of contamination to the air needs a permit to operate. Thus,
a permit is necessary for any construction, reconstruction, and alteration of
any process, fuel burning equipment, or refuse burning equipment that is a
potential source of air contaminants. No specific procedure for obtaining
the permit is outlined in the regulation, and public comment period, at staff
discretion, is used in significant or controversial cases only.
Because of the regulatory requirements, certain engineering and operating
protocols were established by GM and EPA's contractor, GCA Corporation in
support of anticipated technical needs. The Appendix contains a copy of the
analytical sampling and analysis support developed by GCA Corporation. In
addition, this Appendix presents the preliminary environmental analysis, in-
cluding dispersion modeling and relevant health and ecological standards
considered important for evaluating the proposed burn.
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PARTICIPANTS INVOLVED IN PERMITTING PROCESS
Because many groups and individuals will be mentioned in this report, it
is appropriate that a comprehensive list be presented here for reader reference
as the report is read. A list of persons and phone numbers is also available
in Volume II of this report.
EPA:
Office of Pesticides and Toxic Substances, Control Action Division
William Gunter, Team Leader PCB Team (8/79-Present)
Hal Snyder, Team Leader PCB Team (through 8/79)
Office of Research and Development, Industrial Environmental
Research Lab
David C. Sanchez, Project Officer (7/25/79-Present)
Ronald A. Venezia, Project Officer (4/79-7/25/79)
Regional Office, Region V
Y. J. Kim
GCA/Technology Division:
Steven G. Zelenski, Project Manager
General Motors:
Donald R. Koenig, Plant Engineer, Bay City Plant
Larry L. Johnson, Senior Mechanical Engineer
Facilities and Environmental Engineering
Chevrolet Main Plant (Warren, MI)
Alvin P. Garwick, Senior Mechanical Engineer, Bay City Plant
J. David Hudgens, Chevrolet Public Relations
Anthony R. Fisher, Environmental Activities Staff, GM Corporation
Frederick Fromm, Legal Staff, GM Corporation
Thomas Hockman, Plant Medical Director, Bay City Plant
State of Michigan:
Mr Pollution Control Commission
Maurice S. Reizon, Chairman
James A. Brewer, Sr.
Watson A. Gilpin
Mary L. Graves
Edward L. Klopp, Jr.
Donald R. Naish
Glenda F. Robinson
Edwin S. Shannon
Morton Sterling
W. G. Turney
Emmanuel Van Nierop
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Air Quality Division, Department of Natural Resources
(see Figure 1, Organization Chart)
Howard A. Farmer, Director
Del Rector, Chief, Air Quality Division
George Su, Technical Services Section
Gerry Avery, Head, Permit Unit
John Vial, Engineer, Permit Unit
Interest Groups:
Bay City residents
United Auto Workers Local 362
Andre Day, Boiler Operator
American Lung Association of Michigan
City Commission
County Commission
This list does not include the names of all the people who may have been
involved in this permit application process. The list, however, does include
the principals in the process.
BACKGROUND OF PUBLIC SENTIMENT REGARDING INCINERATION OF PCBs
At the time of GM's application for a permit for the incineration of
PCBs, public invovlement and awareness of the process of PCB destruction by
incineration had already become significant. In mid-1977, Peerless Cement
Company in Detroit, Michigan, had requested permission to store and incinerate
PCB-contaminated waste fluids on a commercial basis. Although the State Air
Quality Permit Section recommended approval of a permit and much expert testi-
mony was received in favor of the safety and efficacy of the cement kiln for
destroying PCBs, the permit was not granted. It is not within the scope of
this report to analyze the reasons for denial, but much public awareness and
emotion was generated by the public hearings and press coverage associated
with the permit application process. In addition, a significant polybrominated
biphenyl (PBB) spill had occurred within the last 2 years and much press
coverage had been devoted to detailing the hazards of this class of compounds,
which are related to PCBs. Finally, comments in the public record of the
Peerless Cement Hearings and limited reading of press coverage of that hearing,
indicate that much public awareness and anxiety related to incineration of
PCBs were generated. It was at this stage that GCA/Technology Division received
a Task Order for sampling and analysis assistance to accomplish the test. The
resulting Test Plan is included as an appendix.
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MICHIGAN DNR
DIRECTOR - HOWARD A. TANNER
AIR QUALITY DIVISION
CHIEF - DEL RECTOR
AIR PROGRAMS BRANCH
(performs engineering
functions)
ASST. DIV. CHIEF - DAN MEYER
ENGINEERING SECTION
PAUL SHUTT
- PERMIT UNIT
- AIR QUALITY EVALUATION
UNIT
-SIP REVISION
UNIT
TECHNICAL SERVICES
SECTION
GEORGE SU
SOURCE SAMPLING
UNIT
AIR MONITORING
UNIT
EQUIPMENT SUPPORT
UNIT
HAZARDOUS MATERIAL
UNIT
COMPLIANCE BRANCH
(performs enforcement
functions)
ASST. DIV. CHIEF - BOB MILLER
WESTERN AND NORTHERN
REGION
DENNIS DRAKE
GRAND RAPIDS
DISTRICT
PLAINWELL DISTRICT
MARQUETTE DISTRICT
CADILLAC DISTRICT
EASTERN REGION
RICK JOHNS
- SAGINAW DISTRICT
- PONTIAC DISTRICT
- LANSING DISTRICT
- ANN ARBOR DISTRICT
Figure 1. Organization chart of Air Quality Division of Michigan
Department of Natural Resources.
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SECTION 2
CHRONICLE OF EVENTS
To provide an understanding of the path taken by the permit application
process to date, a chronology of events is included in this report. It is
impossible to document all events that might have played a part in this
permit application process; however, events that were a part of the process or
that appeared to influence the process are included. No events that might have
been important to the permit application process have been knowingly omitted.
This list includes major announcements, communications, meetings, requests
for information, responses to requests for information, news releases and
press headlines. Dates cited are referenced to correspondence or official
records and, in some cases, to personal handwritten notes. Dates that are
based on handwritten records are noted with an asterisk in the following chro-
nology. Copies of all available documentation of events cited in this chro-
nology are presented in Volume II of this report.
The chronology indicates that there have been three phases governing the
incineration disposal of PCBs at the GM-Bay City plant. The first, or pre-
regulatory phase, was the period between 1974 and Fall 1977 when PCBs were
incinerated at the plant without restrictions. This period occurred before
any GCA involvement.
The second or regulatory phase was initiated by state-applied restrictions
on PCB incineration. Regulatory action was intensified when EPA issued PCB
regulations. During this phase, from Fall 1977 to mid-1979, the structure of
the PCB incineration permit and permitting process was gradually developing as
the control agencies gained implementation experience.
Failure to supply sufficient data to meet Federal combustion criteria for
PCB disposal was cited in 1978 by the DNR as reason for GM permit application
denial. It was apparent that GM would require technical assistance in obtain-
ing the incineration permit. The commercial availability of PCB incineration
facilities had become an EPA waste management goal, thus, in the interest of
that goal, EPA contracted GCA/Technology to provide active assistance to GM
in the permit process. GCA's initial involvement was to gather technical in-
formation to support GM's permit application efforts.
The third phase was characterized by the interactions of the press and
public in the already complicated permitting process. This period was replete
with the public hearings, agency inquiries, GCA responses, incineration dis-
posal support/condemnation statements, and decision delays. GCA's role was
broadening as areas of concern expanded from combustion details to estimating
human and environmental impact of PCB incineration.
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PRE-1979 PERMIT APPLICATION CHRONOLOGY
1974-1977 PCB Waste Oil Burned at Chevrolet-Bay City
7/14/77 DNR denied Chevrolet-Bay City Exemption Application.
9/02/77 DNR Stopped PCB Waste Oil Burning
9/06/77 Chevrolet-Bay City Applied for Permit
11/03/77 Chevrolet-Bay City Withdrew Permit
2/17/78 EPA Issued PCB Regulations
3/27/78 Chevrolet-Bay City Issued Pollution Incident
Prevention Plan Including PCB Handling and Disposal Procedures
4/17/78 Chevrolet-Bay City Applied for Permit to Burn Reclaimed Oils
5/10/78 SS. Unit Michigan DNR Notified Permit Unit that PCB Test on
May 17, 1976 Was Unacceptable
6/02/78 Chevrolet-Bay City Was Notified of DNR Recommendation to Deny
Permit
6/20/78 DNR Staff Activity Report on Chevrolet-Bay City Issued.
6/15/78 Chevrolet-Bay City Requested Withdrawal of Permit Application.
6/28/78 DNR Notified Chevrolet-Bay City of 30-Day Limit to Appeal
Voiding of Permit Application
11/02/78 Letter from Potter (GM) to Costle (U.S. EPA) Recommending that
EPA Choose Incineration Facilities
1/11/79 Ontario Ministry of the Environment Issued Press Release on
Release of Mississauga Report.
1/79 Ontario Ministry of the Environment Released Highlights of the
Ontario Research Foundation Report.
CHRONOLOGY CONCERNING CHEVROLET-BAY CITY'S
1979 PERMIT APPLICATION
4/06/79 EPA Requested GM Boiler for PCB Burn
4/18/79 Work Assignment Issued for GCA to Test PCB Emissions.
4/18/79* Meeting of EPA, GM, and GCA Held to Discuss Testing of PCB
Burning at GM
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4/25/79 GCA Work Plan Sent to GM and U.S. EPA
5/01/79 GCA Sent Revised Project Schedule to GM and EPA
5/23,24/79 Meeting of EPA, GM, and GCA Held to Discuss Necessary Conditions
for Permit Issuance
5/29/79 GM Sent Air Use Permit Application to EPA
5/31/79 EPA PCB Regulation Updated
*
5/31/79 GCA Performed Pretest Survey of Site at Bay City
6/06/79 Meteorological Model Representing Dispersion Prepared
&
6/11/79 Meeting of GCA, GM and EPA Held in Washington, D.C. to Refine
GCA Environmental Analysis on Burning PCBs at Chevrolet-Bay City
6/18/79 Meteorological Model Revised to Include Deposition Test Plan
of PCBs.
6/22/79 GCA Mailed Final Draft of Test Plan to EPA and Chevrolet-Bay
City
6/27/79 Chevrolet-Bay City Applied for Air Use Permit to Michigan DNR
7/06/79 Chevrolet-Bay City Sent EPA Air Use Permit Application
7/23/79 John McGuire (Regional Administrator, EPA) Requested Support
of Howard A. Tanner (Director, Michigan DNR) in Testing PCB
Emissions and to Classify as Not a "Major State Action" so
that No Environmental Impact Statement Would Be Necessary.
7/24/79 Meeting of GCA, GM, EPA, and DNR in Lansing, Michigan
7/27/79 GCA Sent Letter to Chevrolet-Bay City Including Vapor Pressure
Data and Related Materials for Use in Estimating PCB emissions
7/27/79 Chevrolet-Bay City Mailed Letter to DNR Regarding Information
Requested
7/27/79 U.S. EPA Sent GM Summary of Data on PCB Levels in Ambient Air
8/09/79 Compass Directions and Distance to Property Line Obtained
from Al Garwick
8/14/79 Meteorological Model Revised PCB Concentrations at GM Property
Line
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8/15/79 Information on Distance to Nearest Residential Areas Obtained
from Al Garwick
8/16/79 Meteorological Model Revised to Include PCB Calculations at
Nearest Residential Area
8/17/79 GCA Sent Data Requested by George Su to Michigan DNR
8/30/79 Meteorological Model Revised to Include Time Averaged PCB Con-
centration from 2-minute Full Release
9/06/79 GCA Sent John Vial Written Confirmation of OSHA Standards
9/10/79 Conversation Between John Vial and Al Garwick Concerning 21 or
30-day Comment Period
9/13/79 Conversation Between Sanchez and Garwick Requesting Notification
to Region V of Proposed Burn Date and Reference to the July 6
Letter to Hal Snyder
9/18/79 Chevrolet-Bay City Sent EPA Region V Letter Requesting Verifi-
cation of October 22 Burn Data
9/19/79 Michigan Air Pollution Control Commission Issued Notice of
Public Comment Through October 15 and Public Hearing October 16
9/20/79 Included PCB Concentrations at Plume Sector Cutoff Points in
Meteorological Model
9/21/79 DNR Proposed Conditional Approval
9/28/79 Michigan Air Pollution Control Commission Announced Public
Comment Through October 15 and Public Hearing on October 11 and
October 16
9/28/79 The Bay City Times "Chevy Gets OK to Burn PCB Oil Contaminants"
9/28/79 DNR Notified Chevrolet-Bay City of Additional Public Hearing
10/03/79 The Bay City Times "Operators Label Boiler Unsafe for Burning
PCB"
10/09/79 Position Paper Released Describing PCB Burn Including Action
Taken by GM, GCA, EPA
10/09/79 Manistique Pioneer-Tribune "Air Commission to Hear PCB Incinera-
tion Proposal"
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10/10/79 The Bay City Times - Notification Requested UAW Members to
Attend November 12 Commission Meeting
10/10/79 New Views (GM) Released Information to Chevrolet-Bay City
Employees on Burning
10/11/79 Meeting in Bay City-Public Hearing
10/11/79 The Bay City Times "Hearing Today on Chevrolet Request to Burn
PCB"
10/11/79 The Detroit News "GM Wants to Burn PCB at Chevy Site"
10/11/79 The Flint Journal "EPA Backs Request to Burn Toxic PCB"
10/12/79 The Bay City Times "Union Workers, City Official Protest PCB
Test Burn"
10/15/79 Ontario Ministry of the Environment Provided EPA with Their
Protocol for Incinerating PCBs in a Cement Kiln
10/16/79 Meeting in Bay City - Commission Meeting
10/16/79 The Bay City Times "PCB Burn Decision Delayed"
10/16/79 Unknown "Group Condemns PCB Burning"
10/16/79 DNR Requested Delay from MAPCC
10/16/79 Mt. Clemens Macomb Daily "PCB Disposal"
10/16/79 South Haven Daily Tribune "ALA Against PCB Burn"
10/17/79 The Bay City Times "Bay City 'Show' Gets Results on PCB Plan"
10/17/79 The Hillside Daily News - "Burning of PCB Oil Delayed"
10/17/79 The Detroit News "State Delays Test - Burning of PCB"
10/17/79 St. Joseph Herald Palladium "State Seeking Answers Before PCB
(sic) Is Burned"
10/17/79 Grand Rapids Press "PCB Buildup At Issue in GM Bid to Burn Oil"
10/22/79 U.S. EPA Sent GM OK to Burn PCBs
10/25/79 John Vial (DNR) Sent Chevrolet-Bay City List of Questions from
the Public Hearings to be Answered
10
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11/01/79 GM Prepared "Response to News Media Inquiries on the Medical
Examinations of Employees at Chevrolet's Bay City Plant, Site
of the Proposed PCB Test Burn"
11/01/79 The Detroit News Editorial "PCB's are Not Easy to Dump"
11/02/79 The Bay City Times "Bay City Chevrolet to Test Workers for
PCB Poisoning"
11/05/79 The Bay City Times "Canadian Officials to View Bay City
Chevrolet's PCB Burn"
11/08/79 DNR Letter to Concerned Citizens Included Staff Summary and
Announced November 20 Meeting
11/08/79 DNR Notified GM of Meeting on November 20; Agenda Included
11/08/79 Proposed Supplement to Permit Application Drafted by DNR
11/10/79 The Bay City Times Letter to the Editor "PCB Test Burn Should
Concern the Community"
11/12/79 Bay City Commission Opposed the Burn
11/13/79 The Bay City Times "Commission Opposes Chevy Waste Oil Test
Burn"
11/13/79 Bay County Commission Asked for Delay of Burn
11/14/79 The Bay City Times "County Board Opposes Chevy's PCB Test Burn"
11/16/79 DNR Notified GM that Application for Permit was Voided Because of
GM1s Request to Withdraw Pending Further Investigation
11/16/79 The Bay City Times "Expect Month's Delay for PCB Burn Here"
11/16/79 Meteorological Model Revised to Reflect Winter Conditions
11/20/79 Commission Meeting in Lansing, Michigan. GM Presented Their
Position - Requested Delay Until December 18 Meeting.
A Question and Answer Period followed.
11/20/79 Addendum to DNR Staff Activity Report of October 16 Includes
Revised Special Conditions
11/20/79 The Bay City Times "Delay Expected in Decision on PCB Burn"
11/21/79 The Bay City Times "PCB Test-Burn Proposal: GM Gets Month to
Sell City on Plan, Bay Environment Office Favors it"
11/26/79 GM Responded to DNR Answering Questions from Mr. Morton Sterling
11/27/79 The Bay City Times "GM Woos City on PCB Burn"
11
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11/27/79 GCA Communicated with U.S. EPA (Sanchez) Regarding Report of
Application Process
11/28/79 GM Letter to U.S. EPA (Sanchez) Addressed Test Burn Date in
1980
11/28/79 PCB Blood Serum Results Received
11/28/79 Ontario Ministry of the Environment Published Fact Sheet on
PCB's Stating that They Have Found it is Safe to Burn PCBs
11/30/79 Results of PCB Blood Tests Released to the Press
12/01/79 The Bay City Times "Local Chevy Workers PCB Levels Up, but
Within Average Range"
12/01/79 The Bay City Times "Laws Regulating Toxic Chemicals are Riddled
with Loopholes" on Talk by William Cooper
it
12/06/79 Telephone Conversation with John Vial - Discussed TAGA 3000
*
12/11/79 Telephone Conversation with Tony Fisher. GM Requesting a
60-day Delay. Stated that It Is Not Necessary for GM, GCA
or EPA to Appear at December Hearing of MAPCC.
12/11/79 Letter From Koenig (GM) to Rector (DNR) Requested Postponing
Decision on the Test Burn Until the February 1980 Commission
Meeting
12/11/79 DNR Posted Notice of Cancellation of Consideration of the GM
Permit Application From the Agenda of the December 18 MAPCC
Meeting
12/12/79 GM Press Release Concerning Postponement of Application
Decision Released
12/13/79 The Bay City Times "Chevrolet-Bay City Asks State to Delay
Test-Burn Decision"
12/14/79 Copy of GM Press Release Sent to DNR
12
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SECTION 3
INFORMATION REQUIRED DURING PERMITTING PROCESS
As noted earlier, EPA originally contracted GCA/Technology Division to
provide the sampling and analysis support required by EPA. The original
work plan and pretest survey were begun to provide this service. However, as
the permit application process in the State of Michigan progressed, it became
apparent that the State Air Quality Permit Division would require additional
information to allow informed processing of the permit application. As these
requests were made by various members of the Permit Division or by the public
through public hearings, information was supplied by a variety of sources,
including the Region V Office, CCA/Technology Division, and GM.
The chronology presented in the preceding section details these requests.
However, it is also of interest to see who requested the information and who
provided it, as well as the delay between the request and the provision. In
addition, it would also be helpful to note when participants in the process
were introduced. Therefore this information is presented in the matrix display
shown in Table 2, which allows these factors to be rapidly surveyed and also
allows certain conclusions to be drawn.
Perusal of the table immediately reveals a significant fact: GM worker
and other public interaction did not occur until the permit application process
was well underway. Another important observation is that the overwhelming_
number of questions relate to potential health effects of PCB emissions.
Little concern was apparently expressed for the technical merits of the sam-
pling and analysis plan nor for the ecological (nonhuman) effects of PCB
emissions. However, about one-half of responses shown in this table were
produced by GCA/Technology Division, which shows the evolving role of GCA/
Technology Division in providing the necessary information not directly related
to the sampling and analysis program, but essential to the permit process.
13
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TABLE 2. DISPLAY DEPICTING TYPES OF INFORMATION REQUESTED, WHO REQUESTED IT,
AND WHO PROVIDED IT, ALONG WITH DATES FOR EACH EVENT
Information requested DNR GM EPA GCA orators Pub"C Mln^f "the Env.
Sampling & Analysis Plan
Environmental Analysis R5.23.79
Ground Deposition
Rates tor PCBs
R6.ll.79
Measuring Accuracy of R7.24.79
Continuous Monitors
PCB Sampling Train/
Quantification
Process
Ambient PCB Levels in
Various Cities
PCB Exposure Limits
PCB Emissions From
Storage Tanks
Sample Calculations
for PCB Emissions
Location of Propobed
Chock Valves for
Reclaim Oil
R7.24.79
R7.24.79
R7.24.79
R7.24.79 P9.10.79
R5.24.79 P6.22.79
R5.24.79 P6.ll.79
P6.18.79
P8.17.79
P8.17.79
P8.17.79
R7.24.79 P7.27.79
R7.24.79 P9.10.79
PCB Concentration off R7.24.79 P8.9.79
GM Property
PCB Concentration off
GM Property
Distance to GM Proper-
ty Line
PCB Concentration at
Nearest Residential
Area
PCB Concentration at
Nearest Residential
Area
R7.24.79
P8.9.79
R7.24.79 P8.18.79
R8.10.79
Distance to Nearest Res-
idential Area
Model for 2 min Full R8.29.79
PCB Release
Information Concerning R9.4.79
OSHA PCB Standards
R8.8.79
P.8.16.79
Test Plan for the Evaluation of PCB Destruction
Efficiency in Industrial Boilers
Environmental report refined at June 11 meeting
of EPA, GCA, and GM
Meteorological Model Revised
Meteorological Model Revised
Meteorological Mode Revised
(continued)
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TABLE 2 (continued)
Information requested DNR GM EPA GCA Boiler Publlc ^V^l" Remarks
operators Min. of the Env.
PCB Concentrations in R7.24.79 P9.20.79 Meteorological Model Revised
Plume at Cutoff Points
Inspection of Boiler P10.5.79 RIO.3.79
and Repair of Holes
Clarification of Mete- RIO.4.79 P10.ll.79 GCA Testimony at October 11 Public Hearing
orological Model
Information on Ontario RIO.12.79 P10.15.79 Sent Protocol for Use of Cement Kiln for
m.v. Vulcanus PCB Destruction
operation
OSKA Standards for Rll.25.79 PH.25.79
HC1
Answers to 13 Ques- RIO.17.79 Pll.26.79
tions About Permit
Application (diben-
zofurans, discharge
water storage, etc.)
Effects of Winter Con- Rll.8.79 PH.16.79 Revision of Meteorological Model
ditions of Meteorolo-
gical Model
PCB Levels in Boiler Pll.28.79 Rll.1.79 R.11.1.79 Boiler Room Workers and Control Group Tested for
Room Workers PCB in Blood
Information on TAGA 3000 Rll.20.79 P12.6.79 Agreed TAGA 3000 Not Suited to Needs of
Bay City
R = Requested
P = Provided
-------
SECTION 4
PRESS COVERAGE OF PERMIT APPLICATION PROCESS
The Michigan press had already had an influence on this permit applica-
tion process because of coverage of the Peerless Cement Permit Application
2 years previously. The press had been the major source of public information
at that time, and the emotionalism associated with the Peerless permit had
certainly not dissipated by the time of the current permit application.
Public objection was the major problem the Chevrolet Bay City Plant
encountered when applying for this permit to burn waste oil containing PCBs.
As the application process proceeded, various public interest groups received
their information primarily from the press and made value judgments based on
this information. The Bay City Times and newspapers from neighboring cities
covered the matter extensively. The coverage in itself may have influenced
public opinion, which, when aroused, delayed the permit process.
PRESS COVERAGE DURING THE APPLICATION PROCESS
The proposed burning of PCBs in Bay City received front page coverage
and lead story priority in the Local section of The Bay City Times. The
coverage began in late September 1979 and became more extensive before
public hearings. The press was particularly quick to emphasize any adverse
feelings of individuals or groups as they became apparent. In fact, the boiler
operators claim that they obtained their knowledge of the permit application
from members of the local press. One of the early articles was entitled "Opera-
tors Label Boiler Unsafe for Burning PCB" and appeared as the lead local story.
This is one example of an early headline that was apparently accurate and cer-
tainly attracted attention to the issue. However, later in the permitting pro-
cess, GM issued a press release on the testing of workers (some of whom had
worked in the boiler room in 1976 when PCBs were being incinerated) for PCB
levels in their blood-stream. The following day, the lead story on the front
page was "Bay City Chevrolet to Test Workers for PCB Poisoning." This is an
example of a pejorative term "poisoning" being inaccurately used by the press
to headline events as they evolved. In general, the press in Bay City had a
tendency to perceive the permit process as a battle ground between good and
evil rather than a means to inform and protect the public.
16
-------
This type of reporting, however, was not typical. The Detroit News, the
Flint Journal, the Macomb Daily, South Haven Daily Tribune, Manistique Pioneer-
Tribune, Hillside Daily News, as well as others covered the development of
events, and not all press coverage was antagonistic towards the test burn. In
fact, an editorial by Ted Douglas in the November 1 Detroit News was very
favorable to PCB burning. He gave a factual development of the issue, an anal-
ysis of alternatives, and a strong case for choosing burning as the best
available alternative to destroy PCBs. His closing statement accurately
summarized his opinion on this issue. "The issue comes down to two choices:
do nothing or try something. There are risk to both.... The Commission must
try something, or the problem will never be solved.
Finally, it is clear that the press provided virtually all of the infor-
mation that the public received on the permitting process. In the early
stages of the permitting process, the information was largely based on in-
vestigative reporting rather than on information supplied by GM, DNR, or EPA.
As the process progressed, more information was funneled to the press from
the public relations arms of GM and DNR. The early impressions made by the
press, however, were difficult to counter. Thus, a partially informed press
and public were left to their own devices to evaluate a technically complicated
problem and its proposed solution. Because the press coverage was so important
to the evolution of the permitting process, copies of much of the available
press coverage are presented in Volume II of this report.
17
-------
SECTION 5
CONCLUSIONS AND RECOMMENDATIONS
Perusal of the events detailed in this report describing the permit
application process can present a confusing picture. However, certain con-
clusions based on the progression of events and documentation presented in
previous sections can be drawn. Although each permit application process is
unique, these conclusions may be representative of the difficulties that
could be encountered in any similar process.
The public, either directly or through elected represen-
tatives, was not informed of the proposed permit application
during the early planning stages.
Special interest groups, i.e., the Michigan Lung Association,
the Michigan Branch of the American Cancer Association, and
United Auto Workers, were not informed of the proposed permit
application during early planning stages.
The GM personnel to be involved in the test resulting from
approval of the permit application were apparently not
initially informed of the permit application, but were informed
only when queried by the press.
The public has, by legislation, an important influence on
the permitting process.
Previous incidents in the state, such as the Peerless Cement Co.
permit application for PCB incinerations and the PBB spill
incident, had already formed much of the public's attitude
toward hazardous waste disposal.
GM-Chevrolet Bay City did not adequately anticipate the
public's and special interest groups' needs for information.
Information finally provided to the public and special interest
groups by nonmedia sources such as presentations at public
hearings was perceived as too technical.
There was apparently a lack of adequate communication and of
clearly delineated responsibility assignments between par-
ticipants in the permit application process.
18
-------
Although these are certainly not the only conclusions that may be drawn
from the available documentation, they do represent a composite of: (1) a
distillation of the documentation and (2) the problems cited most by partici-
pants in the permitting process during informal interviews.
If these conclusions accurately reflect the incidents that occurred as
part of the permitting process, certain recommendations to facilitate similar
action in the future are appropriate.
1. Identify all groups that may play an important role in
future permitting process.
2. Contact these groups by letter or personally.
3. Develop a relationship of cooperation with these groups.
4. Determine level of support for proposed action, and deter-
mine necessary course of action based on level of support.
5. If warranted, proceed with formal permit applications.
In conclusion, the following quotation from Carl Sagan may be appropriate:
"To facilitate informed public participation in technological
decision making to decrease the alienation too many citizens feel
from our technological society...we need better science education.
The most effective agents to communicate science to the public are
television, motion pictures and newspapers..."
19
-------
APPENDIX A
GCA/TECHNOLOGY DIVISION
ORIGINAL TEST PLAN
TEST PLAN FOR EVALUATION OF
PCS DESTRUCTION EFFICIENCY
IN INDUSTRIAL BOILERS
TEST PLAN
MAY 1980
Prepared by
J. Hall-Enos
S. Zelenskl
GCA CORPORATION
GCA/TECHNOLOGY DIVISION
Bedford, Massachusetts
20
-------
CONTENTS
Figures 22
Tables 23
Test Plan for Evaluation of PCB Destruction Efficiency in
Industrial Boilers 25
Introduction 25
Summary 25
Combustion Emission Assessment 25
Stack Sampling 26
Fuel Sampling 43
Ambient Monitoring 43
Analytical Approach 53
Environmental Analysis Assessment 65
Ambient PCB Concentration Estimates 65
Health and Environmental Effects Based on Worst Case Exposure 71
References 78
21
-------
FIGURES
Number Page
A-l PCB sampling train 27
A-2 Sampling ports on Stack No. 3 at GM, Bay City, Michigan .... 28
A-3 Sampling points at GM, Bay City Boiler House, Stack No. 3 ... 29
A-4 Basic trap for sampling organics in gas streams 31
A-5 PCB train sample recovery 34
A-6 Method 5 train sample recovery 35
A-7 Sampling port for continuous monitors 36
A-8 Plot plan of plant facilities. Structure heights are indicated
in feet 44
A-9 Sketch of GM facilities and surrounding area 45
A-10 Normalized concentration as a function of distance from stack
for three stability conditions 47
A-11 Normalized concentration as a function of crosswind distance
and angular bearing for C stability. Distance from stack
is 480 meters 47
A-12 Ambient sample combination scheme and resulting samples for
analysis 49
A-13 PCB train: organic analysis flow scheme 54
A-14 PCB Train: Abbreviated analysis for rapid turnaround 58
A-15 Method 5 train organic analysis flow scheme: particulate
filters 59
A-16 Method 5 train organic analysis flow scheme: resin 60
A-17 Fuel samples: organic analysis flow scheme 62
A-18 Dispersal of plume in aerodynamic wake of building 67
A- 19 Deposition velocity versus wind speed 70
22
-------
TABLES
Number Page
A-l Operation Parameters Monitored by GM at the Bay City
Powerhouse 30
A-2 Samples to be Collected at General Motors Boiler House 33
A-3 Routine Parameter Measurements During Test 37
A-4 Test Schedule for PCB Testing at General Motors 38
A-5 Operating Characteristics for Decision Rules Concerning
Acceptance of Hypothesis that Boiler Destruction
Efficiency ^99.9% 41
A-6 Key to Stability Categories 46
A-7 Factors to Mathematically Convert Decachlorobiphenyl to an
Equivalent Amount of Aroclor 56
A-8 Source Parameters for Model Input 65
A-9 Maximum Concentrations When Plume Dispersed Downwind - Worst
Case Meteorology 68
A-10 Maximum Concentrations When Plume Dispersed in Building Wake -
Worst Case Meteorology 68
A-11 PCB Transfer/Area 69
A-12 Comparison of Health and Ecological PCB Standards to PCB
Levels Resulting From Worst Case Human and Environmental
Exposure 74
A- 13 Maximum Concentrations When Plume Dispersed Downwind - Winter
Meteorology 76
A- 14 Maximum Concentrations When Plume Dispersed into Building
Wake - Winter Meteorology 76
A-15 PCB Deposition/Area (Winter) 77
23
-------
TABLES (continued)
Number Page
A-16 Short-Term PCB Ground Level Concentrations at Plume Sector
Cutoffs (Winter) 77
24
-------
TEST PLAN FOR EVALUATION OF
PCB DESTRUCTION EFFICIENCY IN INDUSTRIAL BOILERS
INTRODUCTION
EPA has promulgated a final rule to implement provisions of the Toxic Sub-
stances Control Act prohibiting the manufacture, processing, distribution in
commerce and use of PCBs. Subpart B of 40 CFR Part 761 relates to disposal of
PCBs.
In order to gather more data relative to PCB destruction efficiency of
industrial boilers, a sampling and analysis protocol was developed for the
boiler at the GM plant in Bay City, Michigan, which will be the test site for
a confirmation test destruction of PCB. An environmental analysis assessment
of the proposed burn has been included in this test plan.
The following sections address: (1) the sampling plan including details
of a pretest visit to the site; (2) the analysis plan based on state-of-the-
art analytical methodology; and (3) the environmental analysis based on worst
case emissions estimates as well as 99.9 percent destruction efficiency.
SUMMARY
A confirmation destruction of polychlorinated biphenyls in an industrial
boiler is proposed in this plan. State-of-the-art sampling and analysis meth-
odology are used to determine both the presence and quantity of polychlorinated
biphenyl which may be present in either the fuel or stack emissions during the
test.
An environmental analysis assessment based on assumptions of worst case
destruction and meteorological conditions has been performed. This analysis
indicates that maximum levels of polychlorinated biphenyls which could be re-
leased during the test are well below regulatory levels for both human and
environmental exposure. Ambient monitoring will be performed before, during,
and after the test burn to document PCB background levels and any increases
due to the test burn.
COMBUSTION EMISSION ASSESSMENT
The primary objective of the stack emissions assessment is to evaluate
the destruction efficiency of PCB contaminated waste oil during combustion.
Because of widespread concern over toxic by-product emission during the com-
bustion, the assessment scheme attempts to correlate PCB destruction with
measured emissions of HC1, dibenzofurans, chlorinated dibenzofurans, dioxins,
25
-------
and total organic residue. Samples of PCB contaminated fuel will be analyzed
in the laboratory for PCB content, dioxins and dibenzofurans. The fuel data
will be used in conjunction with field-measured combustion parameters to deter-
mine PCB destruction efficiency.
The analysis plan which supports the stack emissions assessment is
complex and will therefore be addressed in a separate section labeled
"Analytical Approach." This section encompasses stack, fuel and ambient
sample analyses.
STACK SAMPLING
Sampling Schedule and Methods
The proposed method for sampling PCBs in the combustion flue gas will
include three complete tests of the boiler at normal load operation and burn-
ing a No. 6 fuel containing approximately 10 percent waste material and
50 ppm PCB (500 ppm PCB in the waste). The waste fuel will be fed to the
boiler after a normal burn temperature has been established. The sampling
will require up to 6 hours for each run. This sampling time is the minimum
required based on an assumed destruction efficiency of 99.9 percent at the
conditions described below, yielding approximately 10 \>g of PCB for analysis.
The sampling train to be used for PCBs will be a modified RAC train as
described in "A Preliminary Procedure for Measuring the PCB Emissions from
Stationary Sources," W. J. Mitchell, U.S. EPA, August 26, 1976. A schematic
of the train is shown in Figure A-l. The solid adsorbent tube will contain
7.5 grams of pre-extracted 30/60 mesh Florisil.
The sampling and velocity traverse will be along two diameters of the
stack. A total of 44 points will be sampled to provide a representative
sample of the flue gas composition.1 A schematic of the stack and the spe-
cified sampling points are shown in Figures A-2 and A-3.
Total sampling time will be 308 rain at 7 min per point. The flow rate
will be approximately 0.6 ft3/min. This sampling flow rate will yield approx-
imately 10 yg of PCBs based on a feed rate of 4 gpm of 50 ppm PCB contami-
nated waste fuel with a destruction efficiency of 99.9 percent.
Sampling will be isokinetic (±10 percent) with readings of flue gas
parameters recorded at every sampling point during the traverse. In the
event that isokinetic sampling cannot be maintained, the train will be shut
down and the problem remedied. In the event that either steady operation is
not maintained, or monitored gas parameters (CO, C02, 02) are out of the speci-
fied limits (Subpart B - Disposal of PCBs), the testing will be stopped until
conditions are stabilized. Steady operation of the boiler will be the respon-
sibility of GM personnel but the flue gas parameters and composition will be
26
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TUBE
4
FLOW
tl
STACK
WALL UNGREASEO
FITTINGS
THERMOMETER
CHECK
VALVE
ORIFICE
MANOMETER
PlTOT
MANOMETER
THERMOMETER
i
L_
if'iiifi
IMPINGE
J t
RS
VACUUM/
LINE
VACUUM
GAUGE
Figure A-l. PCB sampling train.
27
-------
42'
1
21
0"
I
6
1
c
3"
'
o
1 "
3^«-3V2 PIPE NIPPLES(4)
(2'/2" STACK DIAMETERS
UPSTREAM OF BEND)
,,,,,, ROOF
77777
Figure A-2. Sampling ports on Stack No. 3 at GM, Bay City, Michigan,
28
-------
POINT
NO.
1
2
3
4
5
6
7
6
9
10
II
DISTANCE
|noh«>
I"
V
2 '/2"
V
4 V
'V
i '/z"
ll"
IS1/*"
16 '//
POINT
NO.
12
13
14
15
16
17
18
19
20
21
22
DISTANCE
Inchtt
2S'/2"
26 5/8
31"
7 "
327/8
34 '/2
« '/;
37 '/s"
38 3/8M
i "
39 72
40 l/2"
41
Figure A-3. Sampling points at GM, Bay City Boiler House,
Stack No. 3.
29
-------
monitored by GCA. Any changes will be noted and relayed to GM personnel so
that appropriate action can be taken. Parameters monitored by GM are listed
in Table A-l.
TABLE A-l. OPERATION PARAMETERS MONITORED BY
GM AT THE BAY CITY POWERHOUSE
Parameter
Range
Fuel oil temperature
Fuel oil pressure
Fuel oil flow rate
Atomizing steam pressure
Steam flow rate
Air heater temperature IN
Air heater temperature OUT
Air heater gas temperature IN
Air heater gas temperature OUT
Air pressure IN
Air pressure OUT
Wind box pressure
Furnace pressure
% smoke density
50 - 300°F
0 - 160 psig
0-8 gpm
0 - 160 psig
0 - 70M Ib/hr
0 - 600°F
0 - 600°F
0 - 600°F
0 - 600°F
0-15 in. W.C.
0-15 in. W.C.
0-10 in. W.C.
0-10 in. W.C.
0 - 100%
The standard Method 5 particulate train will be run simultaneously with
the PCB sampling train to provide for real-time comparison samples for HCi,
dibenzofuran, chlorinated dibenzofurans and dioxins analyses. The sampling
will include a total of 44 points along the two stack diameters. Sampling
will be at 7 min per point for a total duration of 308 min. Samples of flue
gas particulate will be collected on a 4-inch glass fiber filter. In addition
to total particulate, a temperature controlled adsorbent column will be in-
cluded in the sampling train to collect organic emissions from the flue gas.
This column, shown in Figure A-4, contains approximately 25 grams of XAD-2 res-
in. The temperature of the condenser is maintained at 70°F and the conden-
aate is collected in the first impinger of the sampling train.
This sampling train will also be used to determine HCI emissions from
the flue gas. The second impinger of the Method 5 train will contain 200 ml
of 8 percent Na2C03/H20 as a trapping solution for HCI emissions.
In addition to the second impinger solution, an aliquot (20 percent) of
the first impinger water (condensate for XAD-2 resin trap) will be taken and
preserved by addition of Na2C03, The remaining condensate (80 percent) will
be extracted in the field with distilled in glass (D.I.G.) methylene chloride.
30
-------
FLOW DIRECTION
8 MM GLASS
COOLING COIL
GLASS WATER
JACKET
ADSORBENT
GLASS FRITTEt
DISC
RETAINING SPRING-*
'-"^7
GLASS WOOL PLUG-'
FRITTED STAINLESS STEEL DISC
15 MM SOLV-SEAL JOINT
Figure A-4. Basic trap for sampling organics in gas streams.
-------
This extract will be available for total organic residue analysis. A complete
listing of samples to be taken in the flue gas stream is found in Table A-2.
The flow diagrams for sample recovery are shown in Figures A-5 and A-6.
In order to provide background data on emissions from the boiler, a pre-
liminary test will be conducted with No. 6 fuel oil only, 1 day prior to the
initiation of the 3-day PCB test burn. This test will be for the same dura-
tion and at the same conditions as those to be used for the PCB sampling. The
test will include both a FCB train and a standard Method 5 particulate train.
This test will provide background information on the test conditions and also
provide emissions data for the boiler as operated at normal load and firing
No. 6 fuel oil.
A measurement of the precision of stack collection of PCB will be pro-
vided by the simultaneous operation of duplicate PCB trains on the second day
of PCB waste oil burning. The Method 5 particulate train from that day will,
therefore, be replaced by the second PCB train. A recent study determined
that chlorinated dibenzofurans were not a significant PCB combustion pro-
duct of high temperature incineration^ In light of these findings, it is
believed that the elimination of the Method 5 train-from 1 day's sampling
will not compromise the total emissions hazard evaluation.
Field Parameters Measurements
During each of the four tests, various physical parameters will be mea-
sured and monitored by GCA. The operation of the boiler currently includes
the monitoring of the fuel feed rate, the opacity in the stack, and steam and
process temperatures. The fuel feed rate will be required during the test
and other available plant data will be taken as available.
GCA will provide continuous monitoring of flue gas for CO, C02, 02 and
total hydrocarbons. These instruments will be set up on the third floor of
the boiler room with a suitable sampling probe in the existing 2-inch port.
A schematic of this sampling location is shown in Figure A-7.
The monitors will be equipped with a gas conditioning system and recorders.
Monitors will be calibrated prior to use and as required. Parameters will be
continuously recorded during each test.
Other physical parameters will also be measured in this testing program.
These parameters include the flue gas velocity, static pressure and tempera-
ture. These measurements will be made prior to each run for the determination
of proper nozzle size and sampling rate. Other physical parameters will be
measured during the course of each test. A complete list of all parameters
(including those for ambient testing) is included in Table A-3.
32
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TABLE A-2. SAMPLES TO BE COLLECTED AT GENERAL MOTORS BOILER HOUSE
Sample
Source
Container
Species analyzed
Number
LO
U>
Flue gas particulate
Flue gas particulate
XAD-2 resin
Condensate, preserved
Condensate extracted
Na2C03 solution
Florisil resin
Condensed water
impinged particulates
Train wash
Florisil blank
Train wash blank
Filter blank
XAD-2 blank
CH2C12 blank
Na2C03 blank
Fuel feed
Method 5 filter Petri dish Dibenzofurans, etc.
Method 5 rinse Amber glass Total particulate
Method 5 trap Amber glass Total organic residue
Aliquot, Method 5 condenser Nalgene HC1
Method 5 condenser Amber glass Total organic
Method 5 second impinger Nalgene HC1
PCB train Amber glass PCBs
PCS train impingers
D.I.G. hexane
D.I.G. acetone
Blank PCB train
Blank PCB train
Filter lot sample
XAD-2 lot sample
CH2C12 sample
Solution blank
Trickle value (integrated)
Amber glass PCBs
Amber glass PCBs
Amber glass PCB background
Amber glass PCB background
Petri dish Background dibenzofurans, etc.
Amber glass Background organics
Amber glass Background organics
Nalgene Background HC1
Amber glass Dibenzofurans, etc., PCB
3
3
3
3
3
3
5
5
5
4
4
1
1
1
1
4
-------
AMBi:R GLAS S B01TL F,
A
HEXANK RINSE
AMBER GLASS BOTTLE
IMPINGER RINSE
ACETONE
IMPINGER RINSE
HEXANE
PROBE RINSE
ACETONE
PROBE RINSE
HEXANE
AMBER GLASS BOTTLE
(BLANK TRAIN RECOVERED SAME)
Figure A-5. PCB train sample recovery.
34
-------
GLASS FIBER FILTER
-> PETR1 DISH
PROBE RINSE
CH2C12
FILTER RINSE
CH2C12
AMBER GLASS BOTTLE
FIRST IMPLKGER
CONDENSATE
ADD Na2C03
EXTRACT 3X
CH2C12
-> NALCENE BOTTLE
AMBER GLASS BOTTLE
(RESERVE)
XAD-2
RESIN
-> AMBER GLASS BOTTLE
/CH2C12 RINSE J-
SECONI) IMPINGCR
SOLUTION
THIRD IMPTNGER
WATER
NALGENE BOTTLE
A A
H?0 RINSE
Figure A-6. Method 5 train sample recovery.
35
-------
TO STACK
.OPACITY MONITOR
PREHEATER
7
JL
145
FLOOR
\
\
EXISTING -^^^ I
2" NIPPLE I
45'
I
L
-- 81'
\
\
\
\
\ FLOW
STRAIGHTENERS
FROM BOILER
Figure A-7. Sampling port for continuous monitors.
36
-------
TABLE A-3. ROUTINE PARAMETER MEASUREMENTS DURING TEST
Parameter measured Method
Fuel feed rate Continuous chart recording (GM)
C02 in flue gas Continuous gas analyzer Infrared Ind 703-353
CO in flue gas Continuous gas analyzer Beckman 865 (IR)
02 in flue gas Continuous gas analyzer Beckman 742
Total hydrocarbons Continuous gas analyzer Beckman 108A
Flue gas velocity Calibrated pitot tube/manometer
Flue gas temperature Thermocouple
Flue gas pressure Pitot tube/manometer
Grain loading (particulate) Results of Method 5 tests
Percent moisture in flue gas Moisture gain in Method 5 tests
Flue flow rate Ultrasonic flowmeter
Sampling Requirements
The stack sampling program will require 1 week of testing with five team
members on site. A total of three tests and one background test of at least
5 hours, but possibly longer, will be conducted. The boiler operation will
be at steady rate operation with a fuel feed rate of 4 gallons per minute.
Boiler operation, including fuel mix and delivery, will be the respon-
sibility of GM personnel, but fuel feed samples will be drawn by a GCA team
member. Other requirements to be provided by GM include the following:
three 20 amp circuits accessible to stack;
three 20 amp circuits for monitors;
laboratory area for sample recovery;
parking near building for GCA truck.
A tentative schedule is included in Table A-4.
Requirements of the ambient sampling program are discussed in the ambient
testing section.
Quality Control
In order to prevent any contamination of samples with materials which
may interfere with analysis, the highest level of quality control will be
observed in all field testing. All solvents and resins will be checked for
purity before the sampling program; filter paper and glass wool will be
solvent-cleaned. Appropriate blanks will be included to provide background
37
-------
TABLE A-4. TEST SCHEDULE FOR PCB TESTING AT GENERAL MOTORS
Day
Tasks, GCA
Tasks, GM
Arrive site, unload equipment
Set up trains
Set up monitors and meteorological
system
Set up for background tests
Collect meteorological data
Run velocity traverse
Start monitoring equipment
Run 5-hr PCB test
Run 5-hr Method 5 test
Run four 3-hr ambient tests at
four locations
Monitor flue gas
Recover trains
Set up for PCB burner tests
Procedure, same as 2.
A Set up for PCB burner tests
Collect meteorological data
Preliminary velocity traverse
Run two 5-hr PCB tests
Run four 3-hr ambient tests at
four locations
Monitor flue gas
Recover trains.
5 Set up for PCB burner tests
Procedure, same as 2.
6 Pack equipment, leave site
Provide electric
circuits, lab space,
parking, meteoro-
logical system.
Establish steady run
No. 6 fuel oil.
Monitor fuel feed
rate. Maintain
ambient monitor
security.
Collect fuel samples
(1/2-hr intervals).
Establish steady run
on waste oil. Moni-
tor fuel oil rate.
Maintain ambient
monitor security.
Collect fuel samples
(1/2-hr intervals).
Same as 3.
Same as 3; shutdown.
None
38
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information. The sampling trains are all glass and are precleaned to remove
any residues.J At no time will plastics or grease be used on the organic
sample portions of the sampling train. Sample packing IJsts will be included
for each test with information regarding source lot numbers and preservation/
extraction techniques.
In addition to reagent blanks, there will be a blank PCB train set up at
the sampling site, which will be recovered with each PCB run in order to pro-
vide a field-biased blank.
Each PCB train will be spiked in the field with a solution containing a
known amount of deuterated tetrachlorobiphenyl internal standard. Laboratory
analysis of the internal standard will provide information on sampling and
analysis efficiency.
Standard QC procedures and field data sheets will be used for Method 5
testing and continuous monitor measurements. The continuous monitors will be
calibrated against NBS traceable calibration gases in spectroseal cylinders
prepared according to Protocol No. 1.
Data Interpretation
The major concern is to determine if the destruction efficiency for PCB
destruction equals or exceeds 99.9 percent. To make this determination
3 days of testing will be undertaken (days 2, 3, and 4). For each of these
days there will be one of three possible statements about the data for that
day:
1. Data point valid for use, efficiency ^99.9 percent was
attained,
2. Data point valid for use, efficiency ?_ 99.9 percent not
attained, and
3. Data point not valid for use; e.g., malfunction in system.
Ideally, the data from all 3 days will be valid for statistical analysis.
However, it is possible that at least 1 day of the study may have to be dis-
carded and so option 3 above is needed.
If all 3 days of testing are valid for use, two possible decision rules
for accepting the null hypothesis that "the boiler's destruction efficiency
is greater than or equal to 99.9%" can be employed. They are as follows:
Decision Rule I:
Decision Rule II:
Accept the hypothesis that the boiler's destruction
efficiency >_ 99.9 percent if all 3 days produce
efficiency >_ 99.9 percent. Reject the hypothesis
that the destruction efficiency >_ 99.9 percent if
at least 1 day produces efficiency < 99.9 percent,
Accept the hypothesis that the boiler's destruction
efficiency >_ 99.9 percent if at least 2_ or _3 days
produce efficiency > 99.9 percent. Reject the
39
-------
hypothesis that the destruction efficiency
>_ 99.9 percent otherwise.
If only 2 of the 3 days are valid for statistical analysis, a third decision
rule can be employed. It is:
Decision Rule III: Accept the hypothesis that the boiler's des-
truction efficiency >_ 99.9 percent if both of
the days produce efficiency ^99.9 percent.
Reject the hypothesis that the destruction
efficiency >_ 99.9 percent if at least 1 of the
2 days produces efficiency < 99.9 percent.
The statistical properties of the above three decision rules depend on
the boiler's "true" probability that on a given day it will produce a des-
truction efficiency >^ 99.9 percent. In particular, if
p = Probability boiler will produce on a given day
destruction efficiency >_ 99.9 percent,
the probability that the above three decision rules will lead to acceptance
of the hypothesis that "the boiler's destruction efficiency is greater than
or equal to 99.9 percent" are:
Probability of accepting hypothesis
Decision Rule I p3
Decision Rule II 2p2(l-p) 4- p3
Decision Rule III p2
Table A-5 contains values of these acceptance probabilities as functions of the
true probability p. That is, Table A-5 presents the operating characteristics
of these three decision rules. As is to be expected with only 3 days of test-
ing, there are substantial probabilities of accepting the hypothesis that the
boiler's destruction efficiency is greater than or equal to 99.9 percent even
when the probability that such an efficiency attained on any given day is
small (e.g., the acceptance probabilities for the three decision rules are,
respectively, 61.4 percent, 83.1 percent and 72.2 percent, when the probability
of the efficiency being >_ 99.9 percent for a given day is p = 0.85).
Estimation of Sources of Variation (Components of Variance)
The present plan calls for 3 days (days 2, 3 and 4) of testing with one
destruction efficiency measure per day. One reasonable mathematical model
for this test plan is:
E± = UE + a± + £t (1)
for i - 2, 3, 4. Here
E is the observed efficiency for day i,
E is the "true" efficiency for the 3 days,
40
-------
TABLE A-5. OPERATING CHARACTERISTICS FOR DECISION
RULES CONCERNING ACCEPTANCE OF HYPOTHESIS
THAT BOILER DESTRUCTION EFFICIENCY
> 99.9%
Probability p that
on a given day
efficiency _> 99.9?
1.000
0.995
0.990
0.95
0.90
0.85
0.80
0.70
0.60
0.50
0.40
0.30
0.20
0.10
Operating characteristic
Decision rules
)
I
1.000
0.985
0.970
0.857
0.729
0.614
0.512
0.343
0.216
0.125
0.064
0.027
0.008
0.001
II
1.000
0.995
0.990
0.948
0.891
0.831
0.768
0.637
0.504
0.375
0.256
0.153
0.072
0.019
III
1.000
0.990
0.980
0.902
0.810
0.722
0.585
0.490
0.360
0.250
0.160
0.090
0.040
0.010
41
-------
a is the effect of day i, and
e is the random error.
A reasonable set of assumptions for the model given in (1) are:
Mean (e ) = 0, Variance (e ) = a2, Concurrence (E^CJ) = 0 for i f j
A
Given the model (1), an unbiased estimate of y is y given by:
fcj lj
and estimates of the a. are given by a. where
a = E - E. (3)
Unfortunately with model (1) there is available no unbiased estimator
of o2. The sample variance of the E^ values given by:
(E. - I)
is an unbiased estimator of:
a2 + L,^ a 2 (5)
and not o2 alone. The implication of this is that the plan would not
allow for a separation of "within day" variability from "among day"
variability.
In order to obtain a measure of "within day" variability two PCS trains
must be produced on the same day. That is, two simultaneous PCB trains are
needed. If this is done, then the two measurements produced can be written
as:
Dj ~ U 0D EDj or H - >
where D represents the day. The estimator of a2, the within day variability
is then given by:
(6)
42
-------
Of course, if an extra day of testing with two PCB trains is undertaken, more
efficient estimators of average efficiency (estimator yj? of (2)) and among
day effects (Sj of (3)) are obtainable employing the values EDJ and E^n.
FUEL SAMPLING
Fuel samples will also be obtained and analyzed for PCBs, dibenzofurans,
dioxins by GCA and the following classic parameters: N, S, Cl, C, H, ash,
water, sediment, calorific value, carbon residue and flash point by GM. The
fuel samples will consist of:
A trickle sample obtained during each run
A sample of the concentrated (~500 ppm) PCB
contaminated waste oil.
The waste oil sample will be taken by GM personnel in a container pro-
vided by GCA and analyzed for PCB, dibenzofurans and dioxins concentrations
before the actual test if the sample is provided at least 2 weeks prior to
the test.
The trickle fuel samples will be analyzed for these organics along with
other samples taken during the test.
AMBIENT MONITORING
Network Design
The monitoring network has been designed to measure PCB concentrations
in the ambient air as it enters plant property, and ambient concentrations
in the nearest populated area expected to lie downwind from Stack 3 during
the test burns. Meteorological conditions on the date of burn will be used
to position the monitors in areas on the plant property where maximum impact
from the stack effluent is predicted. In this way, it is hoped to determine
background levels, population exposure, and any increases in concentration
due to the test burn. Figure A-8 shows the location of the powerhouse with
respect to nearby plant facilities. Figure A-9 shows the locations of neighbor-
ing populated areas. An example of appropriate placement of monitors during
a period of westerly winds is given in these figures. PCB monitors are in-
dicated by the letter M. A continuously recording wind system will measure
local wind speed and wind direction at the stack.
Field Procedures for Monitor Placement
Wind directions expected to prevail during the 4-day test period will
be used to select an upwind background site and a nearby downwind populated
area site. Once the populated area site has been selected and arrangements
have been made for the operation of the monitor, no within-day change in the
location of this monitor is planned. Also, no change will be made in the lo-
cation of the background monitor unless a major shift in wind direction indi-
cates that it is clearly unsuitable for background measurements. This monitor
will be located in a well-exposed area on plant property, however, and can be
moved if circumstances so dictate.
43
-------
100
I
29
SCALE
200 ft
SO
RETENTION PONDS
PUMP HOUSE
POWER HOUSE
STACK *3
*M BACKGROUND
M OOWNWASH
WASTEWATER
FACILITY
CHEVROLET
MANUFACTURING
26'
Figure A-8. Plot plan of plant facilities.
are indicated in feet.
Structure heights
44
-------
I I~"T "» -* , .
\ 1 » u/j-)" '-/'
A -'I /; I ^f -i ' '
nH'iitTV )'/ "/iir
'/o,
Figure A-9. Sketch of GM facilities and surrounding area.
45
-------
Positioning of the two on-site downwind monitors will be done each morn-
ing prior to the start of the first 3-hour sampling period. This will be
done on the basis of forecast weather, on-site wind conditions, and expected
plume dispersal. Table A-6 will be used with forecast meteorological condi-
tions to estimate stability conditions throughout the day's test period.
Figure A-10 will then be used to determine a distance from the stack at which
a monitor is likely to be impacted by the effluent under the predicted stabil-
ity conditions. The goal v;ill be to select a compromise distance suitable
for all expected stabilities during the 6-hour burn period and thus avoid
having to reposition monitors during the test burn, rather than attempting
to locate the monitors in the area of maximum impact during each individual
3-hour sampling period. After establishing an expected mean downwind direc-
tion, plume width information, such as that provided in Figure A-ll, will be
used in conjunction with Figure A-10 to locate the two monitors. The curves
shown in Figures A-10 and A-ll have been calculated for 3-hour release times.
Consideration will also be given to any anticipated hotspots from plume down-
wash if a trajectory directly over a nearby building is predicted. In addi-
tion to these theoretical considerations, the actual placement of monitors
may be constrained by the physical characteristics of the plant property
(e.g., site accessibility and seasonal condition). In the event of an ob-
vious misJudgment in the selection of the two monitors, adjustments in their
locations will be made during the test period.
TABLE A-6. KEY TO STABILITY CATEGORIES
Day Night
Surface wind
speed (at 10 ra) Incoming solar radiation Thinly overcast ./Q
_l < j/o
m sec l or £. ,
Strong Moderate Slight > 4/8 low cloud
< 2
2-3
3-5
5-6
> 6
A
A-B
B
C
C
A-B
B
B-C
C-D
D
B
C
C
D
D
E
D
D
D
F
E
D
D
The neutral rlass, D, should be assumed for overcast conditions
during day or night.
Sampling Method and Schedule
Sampling will be with high-volume samplers, modified as described in
"A Method for Sampling and Analysis of Polychlorinated Biphenyls (PCBs) in
Ambient Air," EPA-600/4-78-048. The airborne PCB is collected on a series of
two precleaned polyurethane foam plugs housed in the sampler throat, a
16-ctn long threaded, aluminum tube. Motor exhaust is diverted from the
sampler intake by a duct. Flow rate through the sampler will be maintained
at between 20 and 35 ft3/min for a 3-hour sampling period.
-------
5 X 10
i >o o
-5
200 400 600 800
DISTANCE FROM SOURCE, m
1000
1200
Figure A-10. Normalized concentration as a function of distance from
stack for three stability conditions.
sxio'V
4 X I0~ -
-ZOO -160 -120 -80 -40 0 40 80 120 160 200 METERS
-25 -20 -15 -10
10 15 20 25 DEGREES
Figure A-ll. Normalized concentration as a function of crosswind dis-
tance and angular bearing for C stability. Distance from
stack is 480 meters.
47
-------
Ambient sampling will occur on the same days as stack sampling; i.e.,
1 day of background burn (No. 6 fuel oil only) followed by 3 days of 10 per-
cent waste fuel burn. Monitors will operate for 12 hours each test day,
resulting in four 3-hour samples per monitor per day. This schedule is
arranged to provide one pre-burn and one post-burn sample. Additionally,
the 6-hour burn period sample will be collected during two 3-hour intervals.
The polyurethane foam plugs from the latter will be combined for analysis
as one sample. Each day's upwind, background and downwind population
samples will be a combination of the four 3-hour samples. This combination
scheme and the resulting number of samples to be analyzed from each monitor
is illustrated in Figure A-12. Transition from sampling in each period will
be expedited in the field by the use of two ambient monitors at each location
with timed tandem switching. This procedure will also aid correlation of
ambient samples with wind speed and direction at the time of sampling.
The measurement of field parameters has previously been addressed in the
stack sampling section. See Table A-3 for a complete listing.
A tentative test schedule for stack and ambient monitoring was presented
in Table A-4.
Sampling Requirements
The sampling program will require an additional field team member besides
the four at the stack. GCA will provide generators to operate monitors dis-
tant from accessible circuits. Other requirements to be provided by GM
include:
two 20 amp circuits for ambient monitors;
security of unattended ambient monitors and generators
located on GM property;
primary wind speed and direction monitor (GCA will provide
a back-up system for use in the event of primary system
malfunction).
Quality Control
In order to prevent any contamination of samples with materials which
may interfere with analysis, the highest level of quality control will be
observed in all field testing. All solvents and resins will be checked for
purity before the sampling program. Appropriate blanks will be included to
provide background information. Blank polyurethane foam plugs will be
transported to the field to provide a field-biased blank. Sample packing
lists will be included for each test with information regarding source lot
numbers and preservation/extraction techniques.
48
-------
TIME
(THEORETICAL)
SAMPLING LOCATION
UPWIND BACKGROUND
DOWNWIND/ON-SITE 0
DOWNWIND/ON-SITE @
DOWNWIND/POPULATION
£ A UD 1 r X1T
k '*
PERIOD
A
e- TEST
PERIOD
B
7 10
AM AM
A
A
A
A
B
B
8
B
MOM 1 TfiR 1 NT " -.--^
BURN >|
! PERIOD
I C
1
PERIOD
D
A 7
PM PM
1
I
' C
1 C
I C
! c
D
D
D
D
SAMPLES FOR ANALYSIS
SAMPLING LOCATION
UPWIND BACKGROUND
DOWNWIND/ON-SITE CD
DOWNWIND/ON-SITE (j)
DOWNWIND POPULATION
TOTAL FOR
ANALYSIS
TEST
DAY
1
1 (A+B+C+D)
3 (A.B+C.D)
3 (A.B+C.D)
1 (A-t-B-t-C-t-D)
8
TEST
DAY
2
1 (A+B+C+D)
3 (A.B+C.D)
3 (A.B+C.D)
1 (A+B+C+D)
8
TEST
DAY
3
1 (A+B+C+D)
3 (A.B+C.D)
3 (A.B+C.D)
1 (A+B+C+D)
8
TEST
DAY
4
1 (A+B+C+D)
3 (A.B+C.O)
3 (A.B+C.D)
1 (A+B+C+D)
8
TOTAL
FOR
ANALYSIS
k
12
12
b
32
Figure A-12.
Ambient sample combination scheme and resulting samples
for analysis.
49
-------
The modified Hi-Vol samplers will be calibrated at GCA before and after
the test runs; appropriate field data sheets will be used to record data.
Data Interpretation
At the conclusion of the test program the following ambient samples will
have been taken:
Four background observations upwind from the stack.
Six on-site observations downwind from the stack during
test burns.
Eighteen on-site observations downwind from the stack during
no-burn periods (12 pre-burn and 6 post-burn).
Three observations from the populated area on test burn
days.
One pre-burn observation from the populated area.
The analysis of the above data will be approached in two ways. First,
statistical procedures will be used to determine the significance of any
elevated PCB levels that appear to be related to the test burns. Second,
simple dispersion calculations will be carried out using the actual meteo-
rological conditions at the site during each test burn and measured PCB
emission rates to predict values at the downwind monitors and maximum
values. These calculations will be used to identify in-plume samples and to
Judge the appropriateness of the observations in estimating the impact of
the PCB burn on ambient concentrations. A presentation of statistical tests
suitable for use in the analysis of the field data follows.
The present test plan calls for the placement of two monitors that are
to measure the maximum levels of PCBs. Given the configuration of the plant
and its surroundings, it is anticipated that these will be placed close to
the building housing the boiler. In the following we assume that these two
monitors have been placed optimally and do measure maximum levels. Further,
we assume that there is available a third station which measures only back-
ground levels. We now present a mathematical model for the PCB levels at
these monitors and the statistical power of the statistical test appropriate
for detecting if the plant adds significantly to the ambient PCB levels.
Model
Let Station A be the background station. Its PCB level is given by A
and is:
A = y + e (7)
50
-------
Here, y is the average background and e is the random error. Let the other
two stations be given as B and C with PCB levels:
B=y+ky+e'+ke' (8)
C = vi + ky + e" + ke" (9)
Here k > 0 represents the constant showing the increase in PCB (e.g., k = 1
would imply average PCB is y + ky = 2y so level of PCB is doubled), e', e", e'
and e" are random measurement errors. We assume all random errors are indepen-
dent with mean zero and variance a2. Further, we assume the mean levels are
equal to the standard deviation o; i.e.:
y = a (10)
The assumption basically assumes a low background PCB level with variability
equal to its average. One final assumption is that the levels of PCB are
above the error level of the monitoring measurement instruments.
Statistical Test
On each day there will be three samples available at each on-site monitor
(one obtained during boiler test, one obtained before and one after). An appro-
priate statistical test for testing the null hypothesis of the equality of
PCB levels at the three monitors (i.e., no plant contribution) versus the
alternative hypothesis of differences between the background station and the
other two stations (i.e., plant adds to PCB levels) is a paired t test. Let
A±, BI, GI represent the PCB levels at stations A, B and C for time 1, 2 and
3, then the t statistic of this t test is:
where
3
E n
D=^V^ (12)
and
with
B. + C.
D± = 2 1 - AA (14)
for i = 1,2,3. The power of the test (i.e., probability of rejecting in-
correct null hypothesis) depends upon the level of significance and the true
51
-------
value of k. If we view the t test as a one-sided test with level of signif-
icance 0.05, then some estimated maximum power values for various k values
are:
Estimated
k maximum power
1 0.20
1.5 0.40
2 0.45
3 0.50
4 0.55
6 0.60
Population Exposure
To measure the impact of the PCBs from the plant on human population,
a fourth monitor will be placed in a nearby population center located down-
wind. If this is represented by F, a model for its PCB levels can be:
FI = p + ky + e1" + ke"' (15)
The assumptions made for (7) to (10) are assumed here also. An appropriate
paired t test here is:
t - ^ G
t - c (.10;
^G
where
(17)
and 2
with
Gi ' Fi - Ai
Some estimated maximum power values for various k values of model (15) are:
Estimated
k maximum power
1 0.15
1.5 0.20
2 0.30
3 0.35
4 0.37
6 0.39
52
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ANALYTICAL APPROACH
Stack Samples
As addressed earlier, two different sampling trains will be utilized
during the stack sampling period. One train is designed to accommodate the
PCBs emitted from the source. The second train is designed to collect HC1,
dibenzofuran, chlorinated dibenzofurans, dioxins and polynuclear aromatic
hydrocarbons in the stack gas.
PCB Train-
As outlined previously, there will be a total of five runs conducted for
PCB emissions. These will consist of four samples taken while the PCBs are
present in the fuel and a method blank. The blank will be identical to the
samples except for the absence of PCB in the fuel being burned. All nonblank
trains will be spiked to assess PCB sampling efficiency. Each of these trains
will generate three types of samples: (1) a series of water impingers; (2)
combined hexane and acetone rinses; and (3) a Florisil cartridge. The following
analysis flow scheme is outlined in Figure A-13.
The impinger water will be returned to the lab as one combined sample.
The aqueous sample in each case is transferred to a liter separatory funnel.
The sample container is rinsed with acetone and hexane which are, in turn,
added to the separatory funnel. The sample is extracted with three 100 ml
portions of hexane which are then combined. The total volume is transferred
to a Kuderna-Danish evaporator and the contents reduced to 5 ml. The extract
is then dried via a micro sodium sulfate column to remove residual water.
This extract is now ready for combination with the Florisil adsorbent tube
extract and the concentrate of the hexane and acetone rinses.
Each of the Florisil adsorbent tubes is to be analyzed separately in the
following manner: the entire contents of the adsorbent tube is Soxhlet
extracted with a given volume of hexane (200 ml) for at least 4 hours. Upon
completion of extraction the apparatus is allowed to cool and the contents
transferred to a Kuderna-Danish (K-D) evaporator unit. At this point the
impinger water extracts are combined with the contents of the K-D unit. The
total volume is reduced to 10 ml and allowed to cool.
The combined extracts are partitioned against concentrated sulfuric acid
in a 50 ml separatory funnel. The layers are allowed to separate and the
acid layer discarded. Further cleanup is accomplished by shaking the extract
with 5 ral of KOH in methanol. Again the layers are separated and the methanol
layer discarded.
At this point the sample is ready for quantitative analysis of PCB resi-
due. However, if significant color appears in the extract, further cleanup
may be necessary.
As described in Figure A-13, the extract will be aliquotted for each of
three quantitative procedures plus a 1 ml reserve for a prescreening by gas
chromatography with electron capture detection (GC/ECD) and gas chromatography/
mass spectrometry (GC/MS). If results indicate that further cleanup is
53
-------
IMPINGER WATERS COMBINED TR
I
EXTRACT
i J
CONCENTRATE CONCEN
DRY
MN RINSES FLORISIL ADS
I
EXTR
I I
TRATE CONCEN
1 \
COMBINE
I
CONCENTRATE (10 ml)
*
PARTITION CLEANUP
*
RESTORE TO 10 ml
SCREEN 1 ml BY GC/ECO AND GC/MS AND RETAIN IN RESERVE
TRIPLICATE QUANTITATION FOR BIPHENYL, PCB ISOMERS,
AND d6-TETRACHLOROBIPHENYL (FIELD SPIKE ONLY)
GC/ECD
DUPLICATE PERCHLORINATION
I
GC/MS
GC/MS
QUANTITATE ON
BASIS
OF PATTERN
Figure A-13. PCB train: Organic analysis flow scheme.
54
-------
unwarranted, the remaining 9 ml will be divided into three 3 ml aliquots. To
these portions will be added d^g-anthracene internal standard for quantitation
by GC/MS selected ion monitoring (SIM). The GC/MS quantitative data will be
collected on an HP-5985 GC/MS data system.
Data are acquired on a select subset of masses and integrated. Isotopic
abundance patterns will be utilized in the qualitative identification of a
PCB.
Mass chromatograms will be constructed for each sample based on a single
m/e ratio, which is representative of each PCB isomer. Quantitation will be
based on responses for pure chlorobiphenyl isomers. A listing of the isomers
to be implemented include the following:
Biphenyl
2-Chlorobiphenyl
3,3'-Dichlorobiphenyl
2,3',5-Trichlorobiphenyl
2,4,5-Trichlorobiphenyl
2,3',4 ',5-Tetrachlorobiphenyl
2 ,2',4,5,5'-Pentachlorobiphenyl
2,2,4,A',6,6 '-Hexachlorobiphenyl
2,2',3,3',4,4',5,5',6,6'-Decachlorobiphenyl
2,2',3,4,5,5',6-Heptachlorobiphenyl
d^ - Tetrachlorobiphenyl (field-spike)
As shown in Figure A-13, two of the three aliquots will be analyzed by gas
chromatography coupled with an electron capture detector. A Perkin-Elmer
3920 gas chromatograph will be utilized coupled with a Ni63 detector. Chro-
matographic conditions to be employed are outlined in the method for PCBs
in Industrial Effluents, Fed. Reg. 38_, No. 75, Pt II (1973). Peaks will be
recorded and integrated on a 3380S HP data system. Qualitative matching is
performed by comparison of the elution pattern with that of a known Aroclor
standard. Once the subjective match has been established the sample is quan-
titated on the basis of instrument response for a known concentration of the
matched Aroclor.
After GC/ECD analysis, one of the 3 ml aliquots will be divided into
two portions (see Figure A-13). Each portion will be perchlorinated using the
modified Mitchell method as described in the EPA document, (EPA-600/4-78-048). .
The analytical procedure to be employed will be summarized here.
Chloroform is successively added to the hexane extract and azeotrophic
evaporation carried out in a microconcentrator apparatus until the sample
volume is 1.0 ml. The sample is then transferred to a reaction vial and the
55
-------
volume reduced to 0.1 ml for perchlorination. A 0.2 ml portion of SbCl5 will
be added and the capped reaction vial heated at 160 (±3)°C for 3 hours.
At the conclusion of this reaction period, the vial is air-cooled and
finally cooled in an ice bath to 0°C. The residual SbCls is neutralized by
the addition of 1 ml of 6 N HC1. Subsequent steps include 3 x 1 m]_ extrac-
tion of hexane, followed by a ^280^ drying procedure. The total hexane vol-
ume is eventually reduced to 1 ml prior to quantitation. A GC/MS procedure
ia used to quantitate the decachlorobiphenyl (DCB) in the sample by compari-
son of the peak area with that of a known concentration of a DCB standard.
Computed DCB values are then converted to approximate equivalent PCB values
by utilizing the values summarized in Table A-7. These values will be corrected
for any biphenyl or internal standard quantitated by prior GC/MS of the
extract.
TABLE A-7. FACTORS TO MATHEMATICALLY
CONVERT DECACHLOROBIPHENYL
TO AN EQUIVALENT AMOUNT OF
AROCLOR
Aroclor Av. No. Cla MWb
1221
1232
1242
1016
1248
1254
1260
1262
DCB
1
2
3
3
4
5
6
7
10
188.5
223
257.5
257.5
292
326.4
361
395.3
499
0.38
0.45
0.52
0.52
0.59
0.65
0.72
0.79
1.00
a
Average whole number of chlorines
calculated from percent chlorine
substitution for a specific Aroclor.
Molecular weight of Aroclor based
on the average whole number of
chlorines calculated from percent
chlorine substitution.
X = molecular weight Aroclor/
molecular weight DCB (499). To
convert ppm DCB to ppm for a spe-
cific Aroclor, multiply ppm x DCB
by X for the Aroclor.
In order to provide a real-time estimate of the PCB emissions from the
test period, testing days 1 and 2 PCB train samples will be air freighted to
GCA's Bedford, Massachusetts laboratory for analysis of PCBs. An aliquot from
56
-------
the PCB train sample collected on the first day of PCB burn will be analyzed.
Blank correction will be accomplished by utilizing an aliquot from the PCB
train collected the day before. As illustrated in Figure A-14, the analytical
methods for rapid turnaround are an abbreviated method of PCB analysis. PCB
quantitation at the GCA laboratory will utilize SIM-GC/MS and GC/ECD without
the replicate analyses required by the full analysis flow scheme. The results
of the analyses will be used only as a preliminary indication of PCB destruction
efficiency. The abbreviated analysis for PCB is still quite lengthy. The com-
plexity of the determination, and the time required for sample transport from
Michigan to Massachusetts, may preclude results being obtained much before the
end of testing.
Method 5 Particulate Train
Operated simultaneously with the PCB train, the Method 5 train will
provide a total of two runs during PCB burning plus a blank run with
No. 6 fuel oil only. Each Method 5 train will produce three types of
samples: (1) particulates collected on a filter, (2) XAD adsorbent resin,
and (3) impinger condensates. Their respective analytical schemes are shown
in Figures A-15 and A-16.
The recovered filters will be returned to the GCA laboratory for par-
ticulate analysis as outlined in Figure A-10. Once particulate weights have
been recorded, the filter(s) will be aliquotted prior to extraction. The
combined filters from each sample run will be soxhlet-extracted for a period
of 24 hours in cyclohexane. The resultant extract will undergo a solvent
exchange with a mixture of dimethylformamide/H20 followed by back extraction
into cyclohexane. Prior to concentration, each extract is divided into two
fractions and dried. Each fraction is concentrated on a rotary evaporator to
0.5 ml. Extracts are spiked with deuterated anthracene and scanned by means
of selected ion monitoring GC/MS for: dibenzofuran, 2,8-dichlorodibenzofuran
and octachlorodibenzofuran, dioxin, and polynuclear aromatic hydrocarbons
(PAH).
The XAD resin utilized will be recovered from the sampling train in the
field and returned to the laboratory for subsequent analyses. Each resin
sample will be soxhlet-extracted for a period of 24 hours with methylene chlo-
ride. The extract will be combined with the probe and filter rinses, concen-
trated to a working volume of 10 ml and dried. A 3 ml aliquot will be rotary
evaporated to 0.5 mol, spiked with deuterated anthracene and analyzed for
dibenzofuran. The quantitative procedure will proceed as outlined earlier, by
GC/MS with selected ion monitoring. It is believed that the majority of the
dibenzofurans will be associated with the particulate matter. The resin ex-
tract analysis will be conducted to assess any dibenzofurans, dioxins or PAH
not absorbed on the particulates. The 7 ml remainder of the XAD extract will
be aliquotted into a 1 ml reserve and two 3 ir.l portions for assessment of to-
tal organic residues (see Figure A-16). This analysis consists of total chro-
matographable organic (TCO) and gravimetric analyses. A total chromatographable
organic analysis is performed providing a simple boiling point distribution
of organics between lOOo to 3000C. By comparison of sample chromatographic
data with that of a standard alkane mixture, distribution of organics in each
boiling point region can be assessed.
57
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IMPINGER WATERS
I
EXTRACT
A J
4
EXTRACT
I
CONCENTRATE CONCENTRATE CONCENTRATE
A
DRY
Or N
f . . ^
(
COMBINE
CONCENTRATE (10 ml)
8.0 ml RESERVE
PARTITION CLEANUP
SOLVENT EXCHANGE
I
GC/ECD PERKIN ELMER 3920
QUANTITATE FOR AROCLOR }2k2
CONCENTRATE (0.1 ml)
GC/M-SIM
I
QUANTITATE FOR
d6-TETRACHLOROBIPHENYL,
PCB ISOMERS
Figure A-14.
PCB train: Abbreviated analysis for
rapid turnaround.
58
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FILTER
V
WEIGH
ALIQUOT-
RESERVE
EXTRACT W/CYCLOHEXANE (Ik hr]
V
SOLVENT PARTITION W/DMF/H20
V
SPLIT
CONCENTRATE
TO 0.5 ml
SPIKE d10-ANTHRACENE
GAS CHROMATOGRAPHY/
MASS SPECTROMETRY
(DIBENZOFURANS, DIOXINS, PAH,
CHLORINATED DIBENZOFURANS)
V
CONCENTRATE
TO 0.5 ml
V
SPIKE d10-ANTHRACENE
GAS CHROMATOGRAPHY/
MASS SPECTROMETRY
(DIBENZOFURANS, DIOXINS, PAH,
CHLORINATED DIBENZOFURANS)
Figure A-15.
Method 5 train organic analysis flow scheme:
particulate filters.
59
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PROBE AND
FILTER RINSES
RESIN
I
EXTRACT W/METHYLENE CHLORIDE
COMBINE
CONCENTRATE TO 10 ml
DRY
0
3 ml
3 ml
1 ml
RESERVE
©
3 ml
CONCENTRATE (0.5 ml)
TOTAL TOTAL
CHROMATOGRAPHABLE CHROMATOGRAPHABLE
ORGAN ICS ORGAN ICS
GRAVIMETRIC
ANALYSES
GRAVIMETRIC
ANALYSES
SPIKE dlO-ANTHRACENE
GAS CHROMATOGRAPHY/
MASS SPECTROMETRY
(DIBENZORJRANS, CHLORINATED
DIBENZOFURANS, DI OX INS, PAH)
Figure A-16. Method 5 train organic analysis flow scheme: resin.
60
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Quantitative calibration of the TCO procedure is accomplished by use of
mixtures of known concentrations of normal hydrocarbons. Analysis is per-
formed on a Tracor 560 gas chromatograph equipped with a flame ionization de-
tector. Data outputs are recorded on an HP 3380S recorder/integrator.
The gravimetric analysis will be used for the quantitation of organic
sample components with boiling points higher than 300°C. From each of the
3 ml aliquots discussed earlier, 1 ml is removed and evaporated to dryness
in a tared aluminum weighing pan. Evaporation is performed at ambient tem-
peratures and the pan subsequently weighed to a constant weight. The pro-
cedure is quite useful in quantitating the nonvolatile organics in sample
extracts.
The 20 percent aliquot of the first impinger solution and the combined
second and third impinger solutions will be analyzed separately for HC1.
The results of the analysis of the first impinger solution will be aliquot
corrected and added to the results of the second and third for a total HC1
value. The 80 percent extracted aliquot from the first impinger solution
will be held in reserve. Analysis for HC1 will be accomplished by ion chro-
matography on a Dionex System 14 Ion Chromatograph. The chloride ion is re-
tained on the separator column (Dionex No. 030065). Sodium bicarbonate is
used to elute the chloride ion from the separator column. The second column
(Dionex No. 030064) through which the eluant passes removes interfering ions
before detection. Quantitation is achieved by comparison of peak response
from the unknowns to peak responses obtained for a standard calibration
curve.
Fuel Samples
As previously mentioned, fuel samples will consist of one mixed waste
fuel grab sample (pretest) and four time-integrated trickle samples from the
fuel feed during testing. The samples will be returned to the GCA laboratory
and aliquotted for analysis of PCB, dioxins, dibenzofurans and chlorinated
dibenzofurans (see Figure A-17). The PCB analysis scheme is comparable to that
for stack samples with the exception that the GC/ECD pattern matching step
is eliminated. This step is only necessary when selective enhancement of
one or more PCB isomere from a mixture is expected to occur, such as in
stack sampling.
Ambient Samples
Polyurethane foam plugs will be collected from ambient monitors and re-
turned to the laboratory in precleaned amber glass jars with Teflon-lined caps.
The samples will be Soxhlet extracted for 3 hours with hexane. After cooling,
the extracts will be transferred to a Kuderna-Danish (K-D) evaporative con-
centrator and the volume reduced to 5 ml. The extract will then be divided
into a reserve plus a portion for duplicate GC/ECD analysis of PCB. Quantita-
tion of PCB will be performed on the basis of aroclar pattern-matching if
61
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FUEL SAMPLE
5 ml
I
5 ml
AC IDIC
PARTITION
CLEANUP
I
REMAINDER
(RESERVE)
BASIC
PARTITION
CLEANUP
*
GC/MS-SIM
QUANTITATE FOR
DIBENZOFURANS,
CHLORINATED DlBENZO-
FURANS, DI OX INS
NO
V
GC/ECD
QUANTITATE FOR
AROCLOR 1242
T
GC/MS
AROCLOR CLUSTER
CONFIRMATION
Figure A-17. Fuel samples: Organic analysis flow scheme,
62
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possible or by individual PCB isomers if no pattern is evident. Because the
expected ambient levels will not provide sufficient sample for GC/MS analysis,
no comfirmation is presently planned.
Quality Control
All reagents, solvents and adsorbents will be subjected to rigorous
quality control testing prior to use.
Each matrix for PCB quantitation requires a separate verification of
PCB extraction efficiency. In order to accomplish this, GCA/Technology
Laboratory Analysis Department will analyze three samples each of Florisil
30/60 mesh, No. 6 fuel oil (PCB waste diluent) and polyurethane foam. Two
samples of each type will be spiked with Aroclor 1242 at a level three times
the expected detection limit. The other sample will be a blank. Each of the
samples will follow the field-generated sample analysis flow scheme with the
averaged results being a measure of blank-corrected extraction efficiency.
Quality Assurance
The Division QA Manager has reviewed this test plan and will continue to
interact with key technical personnel throughout the program. Specific QC
measures for sampling and analysis procedures are included in the test plan
sections describing those activities; the QA Manager will audit to assure
that the sampling and analysis teams are provided with written operating pro-
cedures which Include these QC measures in appropriate detail. EPA's and
GCA's QA/QC Manuals23"26 and procedures will be utilized.
One of GCA's statisticians, Ralph D'Agostino, has prepared the statis-
tical evaluation included herein which demonstrates that, given optimally
placed monitors and PCB levels which are above the error level of the sampling
and analysis techniques, statistically valid decision rules may be used to
establish if the burner destruction efficiency equals 99.9 percent of the PCB
concentration. The appropriate statistical analyses to use in judging whether
the PCB emissions from the plant during the test burn are significantly dif-
ferent from the background PCB levels both on the plant site and at the
nearest populated area downwind of the test burn stack are also specified.
Dr. D'Agostino will review the actual statistical analyses performed.
GCA field teams are experienced in general ambient and stack sampling as
well as PCB sampling and in the use of continuous monitoring instrumentation.
Field/laboratory meetings have been held by appropriate staff members to de-
termine and schedule the necessary equipment and reagent preparation. The
QA Manager will attend the last of these coordination meetings to assure that
the preparation for the sampling trip and later analysis is adequate.
The analysis scheme includes the use of confirmatory procedures which
are especially important in the identification of PCBs.2^ A prescreening
GC/ECD run on each sample extract will assure that sufficient sample cleanup
63
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has been achieved. GC/MS with selected ion monitoring will then be performed
on extract aliquots to utilize the qualitative and quantitative sensitivity
of this technique. GC/ECD following the Aroclor pattern matching technique
and the perchlorination procedure followed by GC/ECD analysis will be per-
formed on the submitted stack samples for confirmation purposes. The per-
chlorination provides an independent measurement of a derivative formed by
chemical reaction; the use of all three procedures should provide the best
PCB identification and quantitation reasonably attainable.
The analysis sections of this test plan include the specific QC proce-
dures to be followed in analyzing for each of the required components. The
laboratory staff has considerable experience in handling these complex pre-
paratory and analytical procedures and the laboratory QC Committee inserts
appropriate QC checks, and validates data as the samples proceed through the
analysis scheme. In all cases, an aliquot of sample extract is reserved for
use if needed to check questionable results.
The interpretation of analytical data will be performed and reviewed
by chemists experienced in working with complex organic compounds such as
those expected to be found in this project. The data interpretation will
benefit both from their experience and from the laboratory's ongoing QC pro-
gram. The QA Manager will participate in the final review meeting before the
analytical report is issued.
64
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ENVIRONMENTAL ANALYSIS ASSESSMENT
AMBIENT PCB CONCENTRATION ESTIMATES
In the prediction of the maximum concentration of a sensitive pollutant,
it is common practice to model the "worst case" conditions that could occur
as well as the most probable conditions. This worst case approach involves
using the maximum pollutant concentration possible and assumes the pollutant
will be dispersed under the meteorological conditions that are least favor-
able to its dilution.
Table A-8 displays the pollutant source information used in various phases
of the modeling. These data were obtained from plot plans and reports sup-
plied by General Motors Corporation. Two emission conditions were selected
for modeling the impact of the proposed test program. First, the emissions
were estimated for the absolute worst case of no PCB destruction at all during
the combustion process. The second emission condition modeled was that of
99.9 percent destruction (minimum expected) of PCB during combustion.
TABLE A-8. SOURCE PARAMETERS FOR MODEL INPUT
Fuel rate 4 gal/min
PCB concentration in fuel 50 ppm by weight
Stack height (above ground) 18.3 meters
Stack diameter 1.07 meters
Stack gas temperature 430°K
Stack gas velocity 7.48 m/s
PCB emission rate 1. No PCB destruction 0.0107 grams/sec
2. 99.9% destruction 1.1 x 10~5 grams/sec
Stack gas PCB concentration 1. No PCB destruction 1603 ug/m3
2. 99.9% destruction 1.603 ug/m3
Above stack parameters will result in plume rise of 26.1 meters.
Effective plume height (stack and plume rise) =44.4 meters.
While it is difficult to determine the exact atmospheric conditions of
wind direction, wind speed, and stability that will result in the maximum
concentration for a given source, for elevated point sources, maximum concen-
trations generally occur with unstable conditions. It is impossible to pre-
dict the exact meteorological conditions during the test period but a very
65
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realistic estimate can be made based on historical data. From past data pub-
lished by the National Weather Service, the wind direction and speed in lower
Michigan, during the mid-summer, are southwesterly at 10 mph about 50 percent
of the time during the midday hours (the time of strongest instability).
Turner1* states that for wind speeds of 10 mph (4.5 m/s) the stability class
most appropriate would be class "B" moderately unstable (this is a valid
assumption since stability class "A", extremely unstable, could not exist for
the 8 hours of test duration or at wind speeds as high as 10 mph). The mete-
orologically "worst case" was then chosen as 8 hours of class B instability
with southwest winds at 4.5 m/s.
Due to the low stack configuration of the building under test, the model-
ing was approached from two viewpoints. First, PCB concentrations were pre-
dicted for a normal transport of the plume, dispersing it under the worst case
meteorological conditions. Both cases of no destruction and 99.9 percent
destruction of the PCB were modeled. The second approach was to take that of
the plume, due to its low height and ejection speed, being caught in the aero-
dynamic wake of the building and being dispersed into the small volume directly
behind the building as illustrated in Figure A-18. Again, both the no destruc-
tion and 99.9 percent destruction cases were analyzed.
PCB concentration estimates for the normal plume approach were based on
a steady-state Gaussian plume model developed by Pasquill and Gifford and
used by Turner. PCB was assumed to disperse as a gas with no depletion from
the plume for this part of the analysis. The plume rise was computed from
Briggs6 and was estimated to be 26.1 meters. This plume rise added to the
physical stack height resulted in a final effective plume height of 44.4 me-
ters for a 10 mph (4.5 m/s) wind. The resulting maximum short-term concen-
tration estimates (valid for 1 hour) occurred under stability class "A" with
2 m/s winds. However, this "A" stability condition could not last the 8 hours
of test duration so computations of the maximum concentration were made based
on class "B" stability also. Then, due to meteorological fluctuations over
long time periods, the maximum concentration was reduced by a factor of 0.4985
for the 8-hour test period. Table A-9 presents the short-term maximum and
8-hour mean concentrations for the worst case normal plume dispersion case
for both no destruction and 99.9 percent destruction of PCB.
The estimated concentrations for the wake dispersing plume were based on
the approach suggested by Smith5 where the emitted pollutant is dispersed into
the volume directly behind the building, producing the maximum concentration
of PCB directly behind the building. There are no concentration reductions
for long time periods applied here, however, since the plume always disperses
into virtually the same volume. The resulting short-term maximum and 8-hour
mean concentrations for the no destruction and 99.9 percent destruction cases
are presented in Table A-10.
An attempt was then made to estimate the quantity of PCB which may be de-
posited on the ground due to normal plume depletion mechanisms. To model the
worst case, the least horizontally dispersing plume (smallest ground area) was
used with the maximum possible depletion rates to yield highest average PCB
loading in the smallest ground area. To make the estimate as conservative as
possible, it was assumed that the plume path was identical for all three
66
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RETENTION PONDS
WASTE WATER
FACILITY
Figure A-18. Dispersal of plume in aerodynamic wake of building.
67
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TABLE A-9. MAXIMUM CONCENTRATIONS WHEN PLUME DISPERSED DOWNWIND -
WORST CASE METEOROLOGY
Short-term maximum (1 hr, "A" stability, 2 m/s wind speed).
Maximum will occur 225 meters to the northeast of the building.
No PCB destruction 0,376 pg/m3
99.9% destruction 3.8 * 10~k pg/m3
8-hour mean concentration (8-hr, "B" stability, 4.5 m/s wind speed)
Maximum will occur 320 meters to the northeast of the building.
Reduction factor due to 8-hr sampling period = 0.498
No PCB destruction 0.084 pg/m3
99.9% destruction 8.4 * 10~5 yg/m3
TABLE A-10. MAXIMUM CONCENTRATIONS WHEN PLUME DISPERSED IN
BUILDING WAKE - WORST CASE METEOROLOGY
Short-term maximum (1-hr, "A" stability, 2 m/s wind speed).
No PCB destruction 9.74 pg/m3
99.9% destruction 9.7 x 1CT3 pg/m3
8-hour mean concentration (8-hr, "B" stability, 4.5 m/s wind speed),
No PCB destruction 4.36 yg/m3
99.9% destruction 4.4 x io~3 pg/ro3
68
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8-hour test periods, thus depositing the maximum PCB on the smallest ground
area. Only the case of no PCB destruction during combustion was investigated
for maximum impact. Figure A-19 presents a graph developed by Murphy22 of dry
gaseous velocities for a variety of ground covers. The equation solved for
deposition velocity was:
i
V =
g V -f V, + V
& a b c
where V_ = a momentum transfer term
d
Vjj = a concentration gradient term "
Vc = a surface (ground cover) term
If it is assumed that the ground cover within 100 km is predominantly a combi-
nation of grass and oak-hickory forest in summer, for a wind speed of 10 mph
(4.5 m/s), the average dry deposition velocity from Figure A-19 is approximately
1.4 cm/s.
Plume depletion fractions were computed by Markee7 for a plume under
varying stability classes with a variety of deposition velocities. The most
applicable case, and the one used here, was for a 1.0 cm/s deposition velocity.
The results of this analysis are presented in Table A-11.
TABLE A-ll. PCB TRANSFER/AREA
Plume
sector
(km)
0-1
1-5
5-10
10-50
50-100
Plume
%
11
17
11
30
10
depletion
grams
101.7
157.2
101.7
277.35
92.5
Sector
area
0.108
2.311
6.504
173.828
462.250
Deposition
(pg/m2)
946.
68.
16.
1.6
0.20
Total: 0-100 79 730.4 645.000 1.13
Total: Maximum of 924.5 grams emitted during 24
hours of testing - No destruction.
Note that 79 percent of the plume is depleted by the downwind distance of
100 km with 0.85 yg/m2 deposition over an area of 645 * 106m2. However, by
breaking the plume into downwind sectors the realism of the estimation can be
increased, since (as seen in Table A-ll) more deposition will occur with closer
distances to the stack.
69
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2 -
e>
>
10-2
A'PINE FOREST IN WET FALL OR WINTER
B= CUT GRASS IN WET FALL OR WINTER
C- GROWN GRASS IN HUMID SUMMER
D> OAK-HICKORY FOREST IN HUMID SUMMER
DEPOSITION VELOCITY
_L
4 6 8 10
WIND SPEED AT 10m (m/«)
14
Figure A-19. Deposition velocity versus wind speed.
70
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HEALTH AND ENVIRONMENTAL EFFECTS BASED ON WORST CASE EXPOSURE
PCB concentrations in air to which individuals may be exposed as a result
of the test schedule have been calculated for a variety of exposure conditions.
A worst case exposure would occur if maximum ground level concentrations are
assumed to exist in the area immediately downwind of the point of release.
Values calculated are based on the assumption of no PCB destruction as well as
99.9 percent PCB destruction during incineration. The 8-hour mean concentra-
tions of PCBs under these conditions are 4.36 yg/m"1 (0.32 parts per billion
(ppb)) and 4.4 x 10~3 yg/m3 (3.2 x ID"14 ppb), respectively (see Table A-9).
The average respiratory volume of air for adults is 30 m3 for 24 hours.
For the 8-hour duration of one test, this translates to 10 m air respired.
Based on our estimated worst case concentrations of PCB (4.36 yg/m3), an in-
dividual would be exposed to a total of 43.6 yg for one test period. Over the
24 hours of the complete test program, this is an exposure to an estimated
130.8 ug PCB.
Potentially adverse health effects due to PCB exposure include both short-
term (acute) and long-term (chronic) effects. The chronic toxicity of PCB
appears to be of greater significance than does acute toxicity. Acute exposure
studies have yielded data which show that LD50 values for laboratory mammals
exposed to a single dose of PCB range from 2 to 11 g/kg.9 Human exposures
are unlikely to ever reach such levels. As a long-term concern, however,
PCBs have been shown to accumulate in body tissues since they are not readily
metabolized or excreted. They have been shown to exert toxic effects on the
liver, the gastro-intestinal track, and the central nervous system.10 PCBs
have been implicated as human teratogens and some carcinogenic and embryotoxic
effects have been noted in laboratory animals receiving large doses for lengthy
periods of time.10
We have calculated that an individual may be exposed to 130.8 ug PCB (for
the entire duration of the test program) under worst case exposure conditions.
Potential detrimental health effects for exposure of individuals to this level
of PCBs may be evaluated by contrasting this value with the American Conference
of Governmental Industrial Hygienists (ACGIH) Threshold Limit Value (TLV) for
PCBs. TLVs describe levels assumed to be safe based on evidence of both acute
and chronic toxic effects to humans, including carcinogenic effects, and on
studies of animal toxicity data which describe acute, chronic, and oncogenic
responses. TLV concentration levels are time-weighted averages which assume
that a worker or other individuals will be continuously exposed to the sub-
stance(s) in question 8 hours a day and 40 hours a week, for a normal working
lifetime. The ACGIH TLV for PCBs is 37 ppb. Assuming an average respiratory
volume, this equates to an 8-hour exposure to a total of 504.1 yg PCB. Direct
comparison may be made between this level of PCB and that arising from the test
program since they are on an equivalent hourly basis. Total PCBs to which an
individual may be exposed based on 8 hours of testing is 43.6 yg, even under
worst conditions (assuming no PCB destruction). Based on this comparison, PCB
levels arising from the complete test program pose no threat to human health,
even assuming worst case exposure.
71
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A limited number of bioassays of PCBs have been performed and additional
tests for carcinogenicity and teratogenicity are being conducted. PCBs have
produced some carcinogenic responses in rats and mice but the lowest dose re-
sulting in such effects is reported as 1200 mg/kg.10
Effects likely to occur from PCB contamination of the environment to plant
or animal life may include histological, or other sublethal effects. Aquatic
organisms accumulate PCBs from water, dietary sources, and sediment. This
cumulative potential of PCBs is of concern in considering toxicity to aquatic
life. It has been reported that fish can concentrate 200,000 times more PCBs
in their flesh than is present in surrounding water.13 The indirect toxicity
of PCBs to predators through accumulation in tissues of food organisms may
cause death from concentrations in water that would not cause a directly lethal
effect.
These data have led EPA to propose water quality criteria of 0.001 pg/1
(1.0 ppt) PCB for freshwater and marine aquatic life.1"4 Also, PCB concentra-
tions in whole fish should not exceed 0.5 mg/kg of the wet weight for protec-
tion of fish-eating birds and mammals according to NAS/NAE Water Quality
Criteria.15
At present, typical values for PCB concentrations in North American fresh-
waters range from 5-500 or more ppt depending on the industrial effluent or
other discharge the waters receive.10 Values as high as 15,800 ppt have been
reported.10
The figures in Table A-ll may be used to estimate potential environmental
effects of the PCB incineration test program. It is assumed that such environ-
mental effects will be totally dependent upon PCB emissions eventually reaching
a freshwater source and exerting an effect on aquatic organisms, and through
such organisms to mammalian predators and other species. It is likewise assumed
that leaching of PCBs deposited on the soil is the mechanism by which they are
transported to the freshwater source. Runoff, direct deposition of particu-
late matter to which PCBs are adsorbed, or other potential transport mechanisms
have not been considered.
As listed in Table A-ll, 0-1 km from the point of release, PCB concentrations
on the ground level have been calculated to be 946 pg/m2 assuming no destruction
of PCBs, which is a "worst case" concentration. Values calculated assuming
99.9 percent PCB destruction are 1,000 times less or 946 ng/m2.
During the summer months, the locale in which the test site is situated
receives an average of approximately 3 in. of rainfall per month.16 This is
approximately 76 liters/m2. Because solubility of PCBs in water is minimal,
leaching will not remove 100 percent of the total present in the soil. Tucker
et al. percolated water through columns packed with several types of soil
coated with Aroclor 1016 and the effluent water was analyzed for PCBs in one
laboratory study. As expected, soils with higher clay content retained PCBs
more effectively. Even in the worst case, however, less than 0.05 percent of
the total Aroclor present was leached from the soil under the test conditions
and after 4 months of exposure.1'' In addition, only the less-chlorinated,
72
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more easily degradable isomers were leached. More recent leaching studies
involving actual measurements of PCBs after equilibrium conditions were reached
in situ have concluded that the total amount of PCBs released from soil due to
leaching is approxiamtely 0.2 percent of the total initially present.17~ly
Taking this latter estimate as worst case leaching and applying it to
one model results in a calculated PCB concentration of approximately 26 ppt
before dilution by ground-water sources. As mentioned previously, the U.S.
Environmental Protection Agency has proposed water quality criteria levels
for PCBs in freshwater of 1 ppt.16 In relating final concentrations of toxic
substances in ambient freshwaters to the concentrations released, a dilu-
tion on the order of 100,000 or more can be expected. Such dilutions111 >2U
would reduce the levels of PCBs from the test program to values well below
the EPA water criteria. An undiluted value of 26 ppt is well within the
typical background levels now reported for North American freshwaters.1'-'
Likewise, it should be reiterated that this concentration (26 ppt) of
PCB is based on an absolute worst case model; i.e., no PCB destruction in the
stack, maximum deposition of the airborne PCBs on the ground, maximum ground
concentration for calculating the amount potentially leached, and maximum
leaching due to rainwater. If, as is more likely, 99.9 percent of the PCBs
are destroyed during combustion, concentrations of PCBs potentially entering
ground water will, even with no further dilution, meet the EPA freshwater
criteria.
As Table A-12 summarizes, even under worst possible conditions of no PCB
destruction during combustion, the potential environmental and health detri-
ment due to release of PCBs by this test program will be negligible.
A reevaluation of the possible "worst case" air quality impact was per-
formed to ensure that meteorological conditions occurring during the winter
would not result in a more severe condition than would occur in the summer.
Historical records published by the National Weather Service indicate
that, besides the temperature being much lower, the major difference between
summer and winter is the increase in wind speed. The prevailing direction is
still from the southwest, but the average speed increases from approximately
3.5 m/s in summer to about 6 m/s in the winter. Winter speeds this great can
only result in a "neutral" atmospheric stability condition, especially when
coupled with the decrease in sunlight intensity in the winter. In light of
this, the summer analyses were performed using winter meteorological
conditions.
During the part of the day when testing will occur, the atmosphere, with
a 6 m/s wind speed, will be "neutral." However, for short-term "worst case"
maximum concentrations, a "slightly unstable" condition will be "forced" to
provide an extra measure of conservatism to the estimates. Therefore short-
term concentrations will be based on 1 hour of "C" (slightly unstable) stabil-
ity and long-term mean concentrations, based on 10 hours of "D" neutral
stability.
73
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TABLE A-12. COMPARISON OF HEALTH AND ECOLOGICAL PCB STANDARDS TO PCB
LEVELS RESULTING FROM WORST CASE HUMAN AND ENVIRONMENTAL
EXPOSURE3
From air ,.
In water
1I1S^g)tl0n
-------
Tables A-13 and A-14 list the maximum concentrations that may be expected
during the winter season for the normal plume transport case, and the case
of the plume dispersing into the volume immediately behind the building,
respectively.
Using the approach described in the previous (summer) analysis, the
PCS deposition per unit area of ground was computed for a "neutral" plume.
These deposition notes are presented in Table A-15. Note that the resulting
winter deposition will be much smaller than the estimates for the summer.
Table A-16 presents the hourly average ground level ambient concentrations
during the conditions that will produce the deposition reported in Table A-15.
The concentration resulting from a 2-minute release of PCB was deter-
mined for 1 hour and 10 hours. Assuming the 2-minute release occurred
at the start of the 1 hour of "C" stability and was followed by 9 hours of
"D" stability, the 1-hour concentration immediately downwind of the building
would be 0.22 yg/m3 and the 10-hour average would be 0.081 pg/m3.
75
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TABLE A-13. MAXIMUM CONCENTRATIONS WHEN PLUME DISPERSED
DOWNWIND - WINTER METEOROLOGY
A. Short-term maximum will occur 420 m downwind to the northeast
of the building
1 hour, "C" stability, 6 m/s wind speed
No PCB destruction 0.16 yg/m3
9.99% destruction 1.6 x IQ-1* yg/m3
B. 10-hour mean concentration will occur 780 m downwind to the
northeast of the building
10 hours, "D" stability, 6 m/s wind speed
Reduction factor due to 10 hour sampling periond = 0.63
No PCB destruction 0.048 ug/m3
99.9% PCB destruction 4.8 x io~5 yg/m3
TABLE A-14. MAXIMUM CONCENTRATIONS WHEN PLUME DISPERSED INTO
BUILDING WAKE - WINTER METEOROLOGY
Short-term maximum (1-hour, "C" stability, 6 m/s wind speed)
No PCB destruction 3.24 yg/m3
99.9% destruction 3.24 * 10~3 yg/m3
10-hour measurement concentration will be the same.
76
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TABLE A-15. PCB DEPOSITION/AREA (WINTER)
Plume depletion _. . .
Plume sector Sector area Deposition
(km) %
0-0
0.25 -
0.50 -
0.75 -
1.0 -
5.0 -
10.0 -
50.0 -
tal 0 -
.25
0.5G
0.75
1.0
5.0
10.0
50.0
100
100
4.
2.
1.5
1.5
11.
5.
14.
8.
47
grams
37.0
18.5
13.9
13.9
101.7
46.2
129.4
73.9
434.5
(106m2)
0.0102
0.0274
0.0462
0.0666
3.075
8.600
224.675
623.500
860.000
(Pg/m*>
3627.
675.
301.
209.
33.1
5.37
0.576
0.119
0.505
TABLE A-16. SHORT-TERM PCB GROUND LEVEL CONCENTRATIONS
AT PLUME SECTOR CUTOFFS (WINTER)
Downwind PCB concentration PCB concentration
distance no destruction 99.9% destruction
(m) (pg/m3) (pg/m3)
250
500
750
1000
5000
10000
50000
100000
0.49
0.34
0.23
0.18
0.021
0.0082
0.00088
0.00033
4.9 x
3.4 x
2.3 x
1.8 x
2.1 x
8.2 x
8.8 x
3.3 x
itr"
10-*
10-"
10-"
10-5
10~6
io-7
io-7
77
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REFERENCES
1. Standards of Performance for New Stationary Sources, Code of Federal
Regulations, Method I of Appendix A, Part 60, Title 40.
2. Flynn, N. W. Analysis of Polychlorinated Dibenzofurans and the Iden-
tification of Selected Products from Thermal Destruction of Poly-
chlorinated Biphenyls. Proceedings of Symposium on Process Measure-
ments for Environmental Assessment. Atlanta. 1980.
3. Manual of Analytical Methods for the Analysis of Pesticide Residues
in Environmental Samples. U.S. EPA, Environmental Toxicology Division.
1974.
4. Turner, D. B. Workbook of Atmospheric Dispersion Estimates. U.S. De-
partment of Health, Education, and Welfare. 1970.
5. Smith, M. (Ed.). Recommended Guide for the Prediction of the Dispersion
of Airborne Effluents. American Society of Mechanical Engineers. 1968.
6. Briggs, G. A. Some Recent Analyses of Plume Rise Observations.
Proceedings of the Second International Clean Air Congress. 1971.
7. Markee, E. H. On the Behavior of Dry Gaseous Effluent Deposition and
Attendant Plume Depletion. Joint Conference on Applications of Air
Pollution Meteorology. 1977.
8. Bond, R. G., C. P. Straub, and R. Prober (Editors). Handbook of En-
vironmental Control. Volume I: Air Pollution, Table 21.-15 entitled
Respiratory Frequency, Tidal Volume, and Minute Volume: Vertebrates.
The Chemical Rubber Co., Cleveland, Ohio (1972).
9. American Conference of Governmental Industrial Hygienists. Threshold
Limit Values for Chemical Substances and Physical Agents in the
Workroom Environment. ACGIH, Cincinnati, Ohio (1976).
10. Fuller, B., J. Gordon, and M. Kornreich. Environmental Assessment of
PCB's in the Atmosphere. Prepared for U.S. Environmental Protection
Agency, OAQPS, Research Triangle Park, North Carolina by the Mitre
Corp., McLean, Virginia. Report No. EPA-450/3-77-045, November 1977.
11. Price, H. A., and R. L. Welch. Occurrence of Polychlorinated Biphenyls
in Humans. Environ. Health Perspec. 1: 73-78 (1972).
78
-------
12. Yobs, A. R. Levels of Polychlorinated Biphenyls in Adipose Tissue of
the General Population of the Nation. Environ. Health Perspect. 1: 79-81
(1972).
13. Nebeker, A. V. Summary of Recent Information Regarding Effects of PCB's
on Freshwater Organisms. Presented at the National Conference on Poly-
chlorinated Biphenyls, Chicago, Illinois, November 19 through 21, 2975.
14. U.S. Environmental Protection Agency. Quality Criteria for Water.
EPA-440/9-76-023 (1976).
15. National Academy of Sciences, National Academy of Engineering. Water
Quality Criteria. Report No. EPA-R3-73-033. (1973).
16. Conway, H. Me., S. L. May, E. Armstrong (Editors). The Weather Hand-
book. Conway Publications, Atlanta, Georgia (1963).
17. Tucker, E. S., W. J. Litschgi, and W. M. Mees. Migration of Poly-
chlorinated Biphenyls in Soil Induced by Percolating Water. Bulletin
of Environmental Contamination and Toxicology 13(1): 86-93 (1975),
18. Pavlou, S. P., and R. N. Dexter. Distribution of Polychlorinated
Biphenyls (PCB) in Estuarine Ecosystems. Testing the Concept of
Equilibrium Partitioning in the Marine Environment. Environ. Sc.
Technol. 13(1): 65-70. (1979).
19. Martell, J. M., D. A. Rickert, and F. R. Siegel. PCB's in Suburban
Watershed. Reston, Virginia. 'Environ. Sci. Technol. 9(9): 872-875
(1975).
20. U.S. Environmental Protection Agency. 40 CFR 129, Water Program,
Proposed Toxic Pollutant Effluent Standards. Federal Register
38(247) 35388 - 35395 (1973).
21. Grant, D. L., and W. E. J. Phillips. The Effect of Age and Sex on the
Toxicity of Aroclor 1254, a Polychlorinated Biphenyl in the Rat.
Bulletin of Environmental Contamination and Toxicology 12(2): 145-152
(1974).
22. Murphy, B. D. Deposition of S02 on Ground Cover. Third Symposium on
Atmospheric Turbulence Diffusion and Air Quality. 1976.
23. Quality Assurance Handbook for Air Pollution Measurement Systems.
Volume 1 - Principles, EPA-600/9-76-005; Volume 2 - Ambient Air Specific
Methods, EPA-600/4-77-027a; Volume 3 - Stationary Source Specific
Methods, EPA-600/4-77-027b; Research Triangle Park, North Carolina.
1977.
24. Manual for Analytical Quality Control for Pesticides and Related Com-
pounds in Human and Environmental Samples. EPA-600/1-79-008. Research
Triangle Park, North Carolina. 1979.
79
-------
25. Handbook: Continuous Air Pollution Source Monitoring Systems.
EPA-625/6-79-005, U.S. Environmental Protection Agency Technology
Transfer, Cincinnati, Ohio. 1979.
26. GCA/Technology Division Quality Assurance Manual: Part 1: General
Principles; Part 2: Sampling and Field Measurements QC Manual; Part 3:
Analytical QC Manual; Part 4: Environmental Engineering and Planning
QC Manual; Part 5: QC Manual for Instrument Development and Manufacture.
GCA Corporation, Bedford, Massachusetts. 1979,
80
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-600/2-81-033a
2.
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Applying for a Permit to Destroy PCB Waste Oil;
Vol. I. Summary
5. REPORT DATE
March 1981
6. PERFORMING ORGANIZATION CODE
7. AUTHORIS)
S.G. Zelenski, Joanna Hall, and S.E.Haupt
8. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME AND ADDRESS
GCA/Technology Division
Burlington Road
Bedford, Massachusetts 01730
10. PROGRAM ELEMENT NO.
1LB764
11. CONTRACT/GRANT NO.
68-02-3168, Task 9
12. SPONSORING AGENCY NAME AND ADDRESS
EPA, Office of Research and Development
Industrial Environmental Research Laboratory
Research Triangle Park, NC 27711
13. TYPE OF REPORT AND PER
Task Final; 5-12/79
ERIOD COVERED
14. SPONSORING AGENCY CODE
EPA/600/13
15.SUPPLEMENTARY NOTES J.ERL-RTP project officer is David C. Sanchez, Mail Drop 62,
919/541-2547.
16. ABSTRACT
The two-volume report documents the permitting process followed by the
State of Michigan before allowing a trial destruction burn of poly chlorinated biphe-
nals (PCBs) at the General Motors (GM) Chevrolet Bay City plant. Volume I includes
a chronology of events and a matrix depicting the interaction of federal, state, and
local government agencies and GM in the permitting process. The matrix presents
a list of who requested and who responded to each need for additional information.
An analysis of the significance of interactions, including interagency communications
private sector/public communication, and the flow and quality of information devel-
oped, is provided. Finally, recommendations that are based on this permit applica-
tion process and that might facilitate subsequent applications for burns of hazardous
materials are made. Volume II contains the relevant documents summarized in the
Volume I lists. Recommendations include: (1) identification of all groups that may
play an important role in future permitting processes; (2) contacting these groups by
letter or in person; (3) developing a relationship of cooperation with these groups;
(4) determining the level of support for proposed action; and (5) determining the
necessary course of action based on the level of support.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Pollution
Chlorine Aromatic
Compounds
Biphenyl
Insulating Oil
Combustion
Incinerators
Waste Disposal
Boilers
Licenses
Toxicity
Communicating
Pollution Control
Stationary Sources
Poly chlorinated Biphe-
nyls (PCBs)
Permitting Process
Waste Oil
13 B
07C
11H
21B
13A
05D
06T
15E
8. DISTRIBUTION STATEMENT
Release to Public
19. SECURITY CLASS (ThisReport)
Unclassified
21. NO. OF PAGES
85
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (t-73)
81
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