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)

-------
                                                      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

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                                  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

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     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

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                                  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

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     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

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        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

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                                  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

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                                   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

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                                    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

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                                TABLES  (continued)
 Number                                                                  Page

A-16     Short-Term PCB Ground Level Concentrations at Plume Sector
         Cutoffs (Winter) 	    77
                                       24

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                          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

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                      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

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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

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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

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                  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

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                                 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

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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

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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

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            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

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 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

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                        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

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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

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                  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

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 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

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        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

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    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

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     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

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     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

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                                        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

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     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

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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

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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

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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

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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

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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

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 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

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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

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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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