United States EPA-600/2-81-033b
Environmental Protection
Agency March 1981
'-'' •'
v>EPA Research and
Development
APPLYING FOR A PERMIT
TO DESTROY PCB WASTE OIL
Vol. II. Documentation
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 -81-033b
March 1981
Applying for a Permit to Destroy
PCB Waste Oil
Volume II. Documentation
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
Region V, Library
230 South Dearborn Street
Chicago, Illinois 60604
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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 General 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 Agency
ii
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CONTENTS
Abstract ii
Appendices
A. Chronicle of Events 1
B. Relevant Documents 8
C. Press Coverage of Permit Application Process 181
iii
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APPENDIX A
CHRONICLE OF EVENTS
Page No .
1974-1977
3/5/76
7/14/77
9/02/77
9/06/77
11/03/77
2/17/78
3/27/78
4/17/78
5/10/78
6/02/78
6/20/78
6/15/78
6/28/78
11/02/78
1/11/79
1/79
PCB-Waste Oil Burned at Chevy-Bay City
Memo from U.S. Government Recalculation of PCB Air
Emissions
DNR Denied Chevrolet Bay City Exemption Application
DNR Stopped PCB Waste Oil Burning
Chevrolet-Bay City Applied for Permit
Chevrolet-Bay City Withdrew Permit
EPA Issued PCB Regulations
Chevrolet-Bay City Issued Pollution Incident Prevention
Plan Including PCB Handling and Disposal Procedures
Chevrolet-Bay City Applied for Permit to Burn Reclaimed
Oils
SS. Unit Michigan DNR Notified Permit Unit that PCB Test
on May 17, 1976 was Unacceptable
Chevrolet-Bay City was Notified of DNR Recommendation
to Deny Permit
DNR Staff Activity Report on Chevrolet-Bay City Issued
Chevrolet-Bay City Requested Withdrawal of Permit
Application
DNR Notified Chevrolet-Bay City of 30-Day Limit to
Appeal Voiding of Permit Application
Letter from Potter (GM) to Costle (U.S. EPA) Recommending
that EPA Choose Incineration Facilities
Ontario Ministry of the Environment Issued Press Release
on Release of Mississauga Report
Ontario Ministry of the Environment Released Highlights of
the Ontario Research Foundation Report
*
86
*
*
*
*
*
8
t
30
38
40
41
43
44
45
47
49
Documents not contained in this report.
See Appendix D.
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Page No.
1/79 Chronology Concerning Chevrolet-Bay City's 1979 Permit
Application t
4/06/79 EPA Requested GM Boiler for PCB Burn t
4/18/79 Work Assignment Issued for GCA to Test PCB Emissions t
4/18/79 Meeting of EPA, GM and GCA Held to Discuss Testing of
PCB Burning at GM 52
4/25/79 GCA Work Plan Sent to GM and U.S. EPA 55
5/01/79 GCA Sent Revised Project Schedule to GM and EPA 57
5/23,24/79 Meeting of EPA, GM and GCA Held to Discuss Necessary
Conditions for Permit Issuance 60
5/29/79 GM Sent Air Use Permit Application to EPA 63
5/31/79 EPA PCB Regulation Updated *
5/31/79 GCA Did Pretest Survey of Site at Bay City *
6/06/79 Environmental Analysis Assessment Prepared 65
6/11/79 Meeting of GCA, GM and EPA Held in Washington, D.C. to
Refine GCA Environmental Report on Burning PCBs at
Chevrolet-Bay City 76
6/15/79 GCA Notified EPA of Revised Man-Hours Estimated 77
6/18/79 Meteorological Model Revised to Include Deposition Test
Plan of PCBs t
6/22/79 GCA Mailed Final Draft of Test Plan to EPA and Chevrolet-
Bay City 78
6/27/79 Chevrolet-Bay City Applied for Air Use Permit to
Michigan DNR t
7/06/79 Chevrolet-Bay City Sent EPA Air Use Permit Application 81
7/23/79 John McGuire (Regional Administrator) 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 82
7/24/79 Meeting of GCA, GM, EPA and DNR in Bay City, Michigan 84
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7/27/79 U.S. EPA Sent Michigan DNR Summary of Data on PCB Levels
in Ambient Air
7/27/79 Chevrolet-Bay City Mailed Letter to DNR Regarding
Information Requested
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
8/15/79 Information on Distance to Nearest Residential Areas
from Al Garwick
8/16/79 Meteorological Model Revised to Include PCB Calculations
to 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 Concentration from 2 Minute Full Release
9/06/79 GCA Sent John Vial Written Confirmation of ASHA
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 of Hal Snyder
9/14/79 Memo Given to A. Engelman (GCA) on Need for Additional
Man-Hours for Permit Application and Meteorological
Modeling
9/18/79 Chevrolet-Bay City Sent EPA Region V Letter Requesting
Verification 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
Page No.
85
97
99
100
105
106
107
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Page No.
9/20/79
9/28/79
9/28/79
9/28/79
10/03/79
10/09/79
10/09/79
10/10/79
10/10/79
10/11/79
10/11/79
10/11/79
10/11/79
10/12/79
10/15/79
10/16/79
10/16/79
10/16/79
10/16/79
DNR Proposed Conditional Approval
Michigan Air Pollution Control Commission Announced
Public Comment Through October 15 and Public Hearing
on October 11 and October 16
The Bay City Times "Chevy Gets OK to Burn PCB Oil
Contaminates"
DNR Notified Chevrolet-Bay City of Additional Public
Hearing
The Bay City Times "Operators Label Boiler Unsafe for
Burning PCB"
Position Paper Released Describing PCB Burn Including
Action Taken by CM, GCA and EPA
Manistique Pioneer-Tribune "Air Commission to Hear
PCB Incineration Proposal"
The Bay City Times - Notification Requested UAQ Members
to Attend November 12 Commission Meeting
New Views (GM) Released Information to Chevrolet-
Bay City Employees on Burning
Meeting in Bay City-Public Hearing
The Bay City Times "Hearing Today on Chevrolet Request to
Burn PCB"
The Detroit News "GM Wants to Burn PCB at Chevy Site"
The Flint Journal "EPA Backs Requests to Burn Toxic PCB"
The Bay City Times "Union Workers, City Official Protest
PCB Test Burn"
Ontario Ministry of the Environment Provided EPA with
Their Protocol for Incinerating PCBs in a Cement Kiln
Meeting in Bay City- Commission Meeting
The Bay City Times "PCB Burn Decision Delayed"
Unknown "Group Condemns PCB Burning"
DNR Requested Delay from MAPCC
108
111
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120
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121
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10/16/79
10/16/79
10/16/79
10/16/79
10/16/79
10/17/79
10/17/79
10/17/79
10/17/79
10/17/79
10/17/79
10/22/79
10/25/79
11/01/79
11/01/79
11/02/79
11/02/79
11/08/79
11/08/79
DNR Staff Activity Report on Chevrolet-Bay City Issued
Supplement to State of Michigan Staff Activity Report
David Sanchez (U.S. EPA) in Letter to Diane Carlson (DNR)
GM Burning Necessary for Tests to be Included in a
Technical Paper Presentation in June 1980
*
Mt. Clemens Macomb Daily "PCB Disposal"
South Haven Daily Tribune "ALA Against PCB Burn"
GCA Memo, Information Submitted as Part of Public
Hearing - PCB Burning
The Bay City Times "Bay City 'Show1 Gets Results on
PCB Plan"
The Hillside Daily News - "Burning of PCB Oil Delayed"
The Detroit News "State Delays Test - Burning of PCB"
St. Joseph Herald Palladium "State Seeking Answers Before
PCB (sic) Is Burned"
Grand Rapids Press "PCB Buildup at Issue in GM Bid to
Burn Oil"
U.S. EPA Sent GM OK to Burn PCBs
John Vial (DNR) Sent Chevrolet-Bay City List of Questions
from the Public Hearings to be Answered
GM Prepared "Response to News Media Inquirites on the
Medical Examinations of Employees at Chevrolet's Bay
City Plant, Site of the Proposed PCB Test Burn"
The Detroit News Editorial "PCB's are Not Easy to Dump"
The Bay City Times "Bay City Chevrolet to Test Workers
for PCB Poisoning"
The Bay City Times "Canadian Officials to View Bay City
Chevrolet's PCB Burn"
DNR Letter to Concerned Citizens Included Staff Summary
and Announced November 20 Meeting
DNR Notified GM of Meeting on November 20; Agenda
Page No.
112
123
125
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122
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4-
i
128
130
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135
Included
151
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Page No.
11/08/79 Proposed Supplement to Permit Application Drafted by DNR 136
11/10/79 The Bay City Times Letter to the Editor "PCB Test Burn
Should Concern the Community" f
11/12/79 Bay City Commission Opposed the Burn *
11/13/79 The Bay City Times "Commission Opposes Chevy Waste
Oil Test Burn" t
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" t
11/16/79 DNR Notified GM that Application for Permit was Voided
Due to GM's Request to Withdraw Pending Further
Investigation 155
11/16/79 The Bay City Times "Expect Month's Delay for PCB Burn
Here" t
11/16/79 Meteorological Model Revised to Reflect Winter Conditions 159
11/20/79 Commission Meeting in Lansing, Michigan. Gm Presented
Their Position - Requested Delay Until December 18
Meeting. A Question and Answer Period Followed 152
11/20/79 Addendum to DNR Staff Activity Report of October 16
Includes Revised Special Conditions 154
11/20/79 The Bay City Times "Delay Expected in Decision on PCB
Burn" t
11/21/79 The Bay City Times "PCB Test-Burn Proposal: GM Gets
Month to Sell City on Plan, Bay Environment Office
Favors It" t
11/26/79 GM Responded to DNR Answering Questions from Mr. Morton
Sterling 166
11/27/79 The Bay City Times "GM Woos City on PCB Burn" f
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 173
11/28/79 PCB Blood Serum Results Received t'
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Page No.
11/28/79
11/30/79
12/01/79
12/01/79
12/06/79
12/11/79
12/11/79
12/11/79
12/13/79
12/14/79
Ontario Ministry of Environment Published Fact Sheet on
PCB's Stating That They Have Found it is Safe to Burn
PCBs *
Results of PCB Blood Tests Released to the Press *
The Bay City Times "Local Chevy Workers PCB Levels Up,
But Within Average Range" t
The Bay City Times "Laws Regulating Toxic Chemicals
are Riddled with Loopholes" on Talk by William Cooper t
Telephone Conversation with John Vial - Discussed TAGA 3000*
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 *
Letter from Koenig (GM) to Rector (DNR) Requested
Postponing Decision on the Test Burn Until the
February 1980 Commission Meeting
174
DNR Posted Notice of Cancellation of Consideration of the
GM Permit Application From the Agenda of the December 18
MAPCC Meeting 175
The Bay City Times "Chevrolet-Bay City Asks State to Delay
Test-Burn Decision" t
Copy of GM Press Release Sent to DNR
t
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APPENDIX B
RELEVANT DOCUMENTS
POLLUTION INCIDENT PREVENTION PLAN
CHEVROLET - BAY CITY
BAY CITY, MICHIGAN
November 15, 1973
RoviNod August 9, 1977
Revised March 27, 1978
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INDEX
Section I
Section II
Section III
Section IV
Section V
Section VI
Section VII
Page 10 - Introduction
Page 10 - Spill Prevention
Page 11 - Spill Containment and Clean-Up
Page 17 - Notification Requirements and Procedure
Page 19 - In-Plant Material for Clean-Up
Page 21 - Contractor's List
Appendix
"V - Tank Truck DnlaoclinR Procedure
"B" - Manufacturers and Distributors of
Absorbents
"C" - PCB Handling and Disposal Procedures
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Chevrolet - Bav Citv
Pollution Incident Prevention Plnn
I. Introduction
The prevention of spills of oil, fuel and other hazardous materials
is far superior to clean-up. Established surveillance procedures
are designed to detect, prevent or minimize spills at their source.
An accidental discharge caused by operator error or equipment fail-
ure could occur, however, during the unloading of bulk shipments of
fuel oil, gasoline, or spillages of other hazardous material on the
plant premises. These accidental discharges could enter the water-
ways directly as surface runoff or indirectly through either comb-
ined sanitary or storm sewer systems. Some of the types of materials
subject to spillage include fuel oil, gasoline, oils, solvents, thin-
ners, paints, acids and cleaners. If spilled they can enter the
waterways through yard drains, roof drains, storm sewers in plant,
etc.
This plan is issued by Chevrolet-Bay City to establish the procedures
to prevent pollution from storage and use areas, manufacturing pro-
cess, treatment systems and areas for receipt of bulk shipments and
to provide prompt containment and clean-up of a spill.
II. Spill Prevention
A. Employe Training
All employes who are involved with handling of oils and other
pollutants will be properly instructed. Periodic promotional
activities and training of employes will be conducted to main-
tain awareness of pollution dangers. This will be the respon-
sibility of the Plant Engineering Department.
B. Visual Outfall Inspection Daily
Visual inspection of storm sewer outfalls are conducted daily
by maintenance personnel. Irregularity reports on plant
installations and storage facilities from Plant Security pat-
rols during off hours will be investigated.
C. Tank Inspection Week
Routine visual inspection of storage tanks, treatment tanks,
sump pits within diked areas, processing tanks and nipine,
<
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BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGE HAS BEEN RETYPED FOR CLARIFICATION
II. Spill Prevention Con't:
D. Receiving Procedure
The procedure to be used for tank truck receiving, material,
sampling, surveillance, inspection of connections, unloading,
etc., is attached as Appendix "A".
E. Inventory
Inventories of oils, solvents, paints, metals, metallic salts,
etc., are maintained in our General Stores & Material Depart-
ments.
Procurement and disbursement records are available for each
material from the named departments.
Daily visual surveillance for effectiveness of oil skimming
of the cooling water lagoon will be maintained by Maintenance
personnel.
Decant samples from the plating waste treatment system will be
analyzed for metal and cyanide content.
Metallic sludges to be hauled by authorized waste haulers will
be analyzed for hexavalent chromium and cyanide content.
Weekly composite analysis of metal content in water discharged
from the treated plating water holding lagoon will be made.
Records of sludges disposed of by authorized waste haulers will
be maintained by the Plant Engineering Department.
Freon extractable oil content of waste discharged from the oil
waste treatment system will be determined daily.
F. Containment
The following installations are protected by pits, sumps, dikes,
perimeter drains or other means of isolation and containment:
1. Oil Storage.
2. Process Tanks.
3. Storage of paint, thinner, solvent, oil drums, etc.
III. Spill Containment and Clean-Up
a. Spill First Action
The first action to be taken in the event of a spill, or the
observation of spillage, is to prevent the pollutant from en-
tering a public sewer or waterway. Immediate action should be
taken to prevent further spillage and to confine the spilled
material. Following are general instructions to confine spills:
1. On land, use dirt, sand, or other relatively impervious
materials to dam the spill to prevent the flow of the ma-
terial.
11
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BECAUSE OF ILLEGIBLE ORIGINAL, THIS
PAGE HAS BEEN RETYPED FOR CLARIFICATION.
2. Should spillage occur which may result in contamination
of a public waterway either directly or indirectly, use any
boom arrangement to confine the spillage.
12
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III. Spill Containment and Clean-Up Con' t
2a. For oil or other floating matt-rials use hay, straw,
or any boom arrangement to confine the spillage.
b. For soluble materials use any means possible to
prevent entering waterway or further spread of
contaminant.
See Appendix C for special procedures concerning the Siting,
Handling, Identifying and Disposing of PCB's and PCB Containing
Items.
13
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B. Internal Nitification
In the event of a spill or observation of spillage the following
persons should be immediately notified:
Phone
Plant Engineer - D. R. Koenig Plant
Home 251-684-6951
Plant Metallurgist - E. W. Lee Plant
Home 381-684-2798
Maintenance Supervisor Plant 261, 262
Plant Security Plant 366, 335
Information to be supplied as:
1. Location of spillage
2. Type of material
3. Estimated quantity and extent of spillage
4. What measures have been taken to confine and prevent
further spillage
C. Spill Confinement
In the event the spillage cannot be contained, the Maintenance
Department is to immediately procure the necessary materials
to confine the spill. Refer to Appendix B.
D. Manpower Assignment
The responsibility for the supervision of the spill clean-up and
manpower assignment will normally be the Maintenance Dept. pro-
vided such responsibility is not superceded by regulatory agencies.
Supervision of the clean-up of an oil spill in a navigable open
waterway is the responsibility of the U.S. Coast Guard. If no
Maintenance personnel are in the plant, Plant Protection wilt pro-
vide supervision until Maintenance personnel are available.
E. Disposal of Material
After containment of the spilled fluid, it shall be romoved. Mat-
erial will be subsequently removed and placed in specific containers
for proper disposal in accordance with sound evnironntrntal practices.
In no evf-nt shall di.spersinp, materials be uspd unless specifically
authorized by regulatory personnel.
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Ke c e i p t _o f Extr-rn.il Not.i. f icat i on of Spill
In the event plant personnel receive notification of a spill
or contaminant problem from any source external of the plant,
the following information is to be requested:
1. Location of spillage.
2. Nature of material.
3. When did observation occur and is it continuous or a
slug.
4. Does caller wish to identify himself so we can report
on results of our investigation. Can we contact caller
for further assistance if we can't locate spill?
15
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IV. Not if icnt inn Requirc-montr^ ?in_d Vrqc-j or f-:nJl1 to a miblic
watervny or storm ^ewer loading to sut fare waters, tlie Pl.tnt
Engineer, or in his absence, the Plant Metallurgist will have
the sole authority to notify the appropriate local, state and
federal agencies. The Sgt. of the Plant Security, in the
absence of the Plant Engineer and his alternate, shall notify
said persons at home who will then notify the necessary agencies.
Of primary concern and urgency is notification of the U.S. Coast:
Guard. In the case oi an oil spill, such notification shall be
accomplished immediately and not to exceed twenty (20) minutes
after discovery of spill. Agencies and personnel to be notified
are:
1. U. S. Coast Guard Office
Captain of the Port
Port, Detroit
Detroit , Michigan
Telephone (313) 226-6860
2. Michigan Department of Natural Resources
Pollution Emergency Allerting System (PEAS)
Phcne 517-373-7560"
3. Chevrolet Central uffice
Staff Engineer - Environmental
G. E. Calhoun
Telephone 8-535-4619
In the event of spillage of highly flammable materials:
Plant Security Fire Dept.
Ext. 288
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B. Sanitary and Combined Sewers
In the event of spillage of contaminants to the
sanitary or combined sewer in sufficient quantity
to potentially cause an upset in the municipal
treatment plant, notify the following:
1. Bay City Waste Water Plant
2905 North Water
Superintendent
William Grevel
Phone 893-5121
2. Chevrolet Central Office
Staff Engineer - Environmental
G. E. Calhoun
Phone 8-535-4619
3. GM Plant and Environmental Engineering
Environmental Activities Staff Building - 3rd Floor West
General Motors Technical Center
Mound Road @ 12 Mile Road
Warren, Michigan 48090
Phone 8-535-8605
4. In the event of spillage to a combined sewer, notify
additionally:
Michigan Department of Natural Resources
Pollution Emergency Allerting System (PEAS)
Phone 517-373-7660
17
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C. Information Content
The information to be relayed to the contacted agencies is:
I. Name of person reporting.
2. Address of facility.
3. Substance spilled.
4. Estimated quantity.
5. Time spill occurred.
6. Name, of waterway receiving spillage.
7. Person to contact and phone number at facility.
8. Answer any question asked by agency to best of ability.
D. Written Reporting
After verbal notification, a written report shall be submitted within
five (5) days to the Staff Engineer-Environmental, Chevrolet Central
Office. This report should include all items listed in "C" above and
an investigative report detailing events leading to the spill and
corrective action taken to eliminate reoccurrence.
In-Plant Material For Clean-Up
Equipment and materials available for clean-up are kept In storage boxes
near the mouth of the RIVER WATER SLIP and near the DISCHARGE WEIR of
the RETENTION POND.
1. Floating boom - (200 ft.).
2. Shovels and hand tools.
3. Sand bags and dam material.
4. Absorbents.
18
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Attachment
Uo S* Coast Guard Office, LX District
Captain of the Tort
Port Detroit
Detroit, Michigan
Telephone: (313) 226-6860
1!. S, Coast Guard Office, IX District
Captain of the Port
Port Muskegon
Muskegon, Michigan
Telephone: 616-759-0951
Uo S. Coast Guard Office, DC District
Captain of th,^ Tort
Port Sault Ste, Marie
Sault Ste. Marie, Michigan
Telephone: (906) 635-5241
19
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VI. CONTRACTORS LIST
CJ_enn-Up Contractors:
Berlin ft F'arro Liquid incineration, Inc,
8322 South Morrish Rond
Swart^ r.icek, Michigan 4.84.73
Telephone: (313) C>35-(555Q
Chem-Met Services, Inc.
IS.V'O Allen Rond
Wvnndotte, Michigan 48192
Telephone: (31 3) 282-9250
Hartley and Hartley, Inc.
2J70 S. Two Mile Road
Kavknwlin, Michigan 48^31
Telephone (313) 684-3960
Nelson Chemical Compnny
123'tr> Schaefer Highway
Detroit, Michignn 48227
Telephone: (313) 933-1500
Marine Pollution Control Corporation
C631 W. Jefferson
Detroit, Michigan 48209
Telephone (313) 849-2333
F'.ccovery Units - Skimmers
Michigan Marine Salvage
32475 S. River Road
Mt. Clemens, Michigan 48045
Telephone: (313) 468-2430
Mnrine Pollution Control Corporation
8631 W. Jefferson
Detroit, Michigan 48209
Telephone (313) 849-2333
Oil Spill Recovery -- Trucks
Chem-Met Services, Inc.
18550 Allen Road
Wynndotto, Michigan 48192
Telephone: (313) 282-9250
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Oil Spill Recovery Con'
Hartley and Hartley, Inc.
2370 S. Two Mile Road
Kawkawlin, Michigan 48G31
Telephone (517) 684-3(iCO
Marine Pollution Control Corporation
8631 W. Jefferson
Detroit, Michigan 48209
Telephone (313) 849-2333
Nelson Chemical Company
12345 Schaefer Highway
Detroit, Michigan 48227
Telephone - (313) 933-1500
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Tank Truck Unload inp; Procedure
1. Insure that tank trailer is nccuratHv spotted at the proper unloading
spot.
2. Tank trailer brakes will he set and the driver will remain with the
vehicle during the entire unloading period.
3. Caution signs will he placed In the vicinity of the tank trailer to
give necessary warining to approaching personnel and must be left up
until after tank trailer is unloaded and disconnected from discharge
connection. Signs will be metal or other suitable material, at leAst
12 inches by 15 Inches in size, and bear the words "Stop-Tank Trailer
Connected." Letters will be white on a blue background.
4. Unloading operations shall be performed only by reliable persons pro-
perly instructed and made responsible for careful compliance with
applicable regulations.
5. Unloading of tank trailers will he done during daylight hours except
under emergency conditions.
6. No open flame of any kind shall be permitted, for any purpose whatsoever,
near the tank trailer or within the vapor area surrounding the tank
trailer. Smoking Is strictly forbidden within this area. Only spark-
proof tools will be used.
7. Make sure the permanent storage tank Is vented before connecting the
unloading line.
8. Determine by tape sounding and/or King gauge sounding of receiving
storage tank that sufficient space Is available in storage tank to
receive contents of the tank trailer.
9. Tank trailer number is to be compared with that on shipping papers on
invoice to determine contents of trailer and avoid mixing of products.
10. To verify tank trailer contents a sample will be withdrawn and material
Identified. Powerhouse personnel will Identify fuel oil received.
Maintenance personnel will identify gasoline received. Laboratory per-
sonnel will Identify all other bulk materials. Samples will be secured
by:
a. Insure that tank car is relieved of all interior pressure by
venting tank by opening vent on dome at short Intervals.
b. After relieving pressure, open manhole cover and obtain sample
through the manhole.
11. Attach ground strap (plant) to bumper of tank trailer (for flammable
materinls).
22
-------
Appendix "A" Con't:
12. Remove closure from valve through which car is to be unloaded after
placement of catch basin in position to catch any liquid that may
be in the outlet chamber.
13. If leakage shown upon starting to remove cap, cap must not be en-
tirely unscrewed, but sufficient threads must be left engaged and
sufficient time allowed to permit escape of any accumulation of liq-
uid in the outlet chamber. If leakage stops or initial rate of
leakage diminishes materially, the cap may be entirely removed. If
initial rate of leakage continues, valve must be actuated a couple of
times to see that outlet valve in bottom of tank is on seat. If this
fails, the cap must be screwed up tight and trailer must be unloaded
through top manhole.
14. After removing cap, visually inspect the outlet chamber to insure
that no blockage exist. If blockage does exist immediately replace
cap and unload trailer from the top.
15. Attach unloading line to the proper connection on the outlet leg.
16. Open bottom outlet valve and proper valves in the unloading lines.
17. Start pump checking to insure there is no leakage at any of the con-
nections. Should leakage be present immediately stop pump.
18. After liquid has been removed, stop pump, close all valves, discon-
nect plant unloading line from tank trailer, replace cap to outlet
and make all other closures tight.
19. Remove all portable signs and release tank trailer.
23
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Appendix "D1
Manufacturers and Distributors of Absorbents
Fiberperl
(absorbent]
Marine Pollution Control Corporation
8631 W. Jefferson
Detroit, Michigan 48209
Telephone - 313-849-2333
Dow Imbiber Beads
(absorbents)
Gedcor Envoronmental Protection Corp,
32816 Manor Park
Garden City, Michigan 48135
Telephone - 313-261-1000
Common collecting materials are normally available locally
as they are routinely stocked for other purposes.
Common collecting materials: straw
hay
sawdust
Normal local vendors for these materials are:
Lumber Yards
Nurseries
Local Farmers
24
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BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGE HAS BEEN RETYPED FOR CLARIFICATION
APPENDIX C
PCB HANDLING & DISPOSAL PROCEDURES
(A) See plant layout Exhibit 1, for substation transformer locations
containing PCB's.
(B) All motors over 7% HP have PCB capacitor located on the motor
control panel.
2. Handling
(A) Electrical items containing PCB material will not be purchased.
All orders for transformers or capacitors contain the statement,
"must not contain PCB's".
(B) The Plant Engineering Department is responsible for labeling and
removal of a PCB-containing item. The PCB-containing item shall
be placed in specially marked scalable drums located in the motor
repair shop Col. 22G. When a disposal quantity of items is
collected, the Purchasing Department will prepare the necessary
shipping papers, and will obtain the necessary approvals.
3. Identification
(A) PCB-containing items will be labeled in accordance with U.S.
E.P.A. rules when they are promulgated.
(B) However, until the rules are finalized, all PCB-containing
items SHALL BE identified with a label stating:
"CAUTION — This item contains PCB. Use extreme care
to prevent spills or leaks. If this item leaks,
immediately call Plant Engineering, Ph. 251.
If this item requires routine disposal call Plant
Engineering Ph. 251."
4. Disposal
(A) Chevrolet-Bay City's disposal procedures for PCB items will
conform to U.S. EPA regulations, when they are promulgated.
(B) However, interim disposal methods include:
1. Soaking and containment of spills with, Imbiber
beads and pads, stored in designated areas.
2, Spills are washed with perchloroethylene, with
all rags, gloves and associated equipment being
disposed of in approved manner.
25
-------
Appendix C - Con't:
Item 4 Disposal Con't:
3. All electrical items containing PCS
material and all material used in
cleanup operations are disposed of by:
Drilling and Draining capacitors in
accordance with Michigan DNR Act 60.
Depositing them in scalable 55 gal.
drums in the motor repair shop. These
drums when full, are labeled and stored
in a dyked-roofed-posted area, until a
shipping quantity is accumulated.
4. (A) All PCB containing items are shipped
to approved disposal sites; see
listing of facilities, Exhibit 2.
Shipping is in accordance with
Michigan E.P.A. Regulations, Rule
10 (R299.3310).
(B) All electrical personnel and
maintenance supervision have
received written instructions on
clean-up of PCB spills, handling
and disposal of PCB materials.
26
-------
/-TV \
Cr^L. ,!J I 5-/'_ 'J
CHEVROLET-BAY CITY
DIVISION OF GENERAL .VOTGfeS COR^ORAT'CN
BAY CITY, MICHIGAN
EXHIBIT I
-------
Exhibit 2
PCB TREATMENT 0R DISPOSAL FACILITIES
Rollins Environmental Services
Main Office: Wilmington, Delaware
Telephone 302-658-8541
Facilities: Bridgeport, New Jersey
Baton Rouge, La.
Houson, Texas
Can handle solids and liquids by incineration.
28
-------
Attachment "D"
Bay City - Reclaim Oil
HCL Calculations
Weight Of HCL produced/min.
mg PCB = 4 gpm x 3.78 L/Gal. x 50 ppm
mg PCB = 756
mg CL =756 mg PCB x 0.42 CL/PCB
mg CL =317
T,^T /„„• on ^T 36-4 Mol. Wt. HCL
mg HCL/Min = 317 mg CL x 35.4 Mol. wt. CL
mg HCL/Min. = 326
HCL Vol. @ STP
MoXes HCL/Min. -
SCFM HCL
SCFM HCL
= 0.0089 Moles/Min. x 22.4 L/Mole x
0.0353 Cu. Ft. /Liter
= 0.0070
PPM of HCL
r,™ r T,^T
PPM of HCL =
PPM of HCL = .81
0.0070 SCFM HCL
Exhaust
, nrm nnr.
1,000,000
29
-------
OHEVROLET MOTOR DIVISION
Gerxral Motors Corporation a,y city Plwit
100 Fitzgerald Strwt
Bay City. MleMgin 48706
Air Quality Division
Michigan Dept. of Natural Resources
P.O. Box 30028
Lansing, Michigan 48909
Attn: Mr. Gerald L. Avery
In accordance with the state laws governing air
pollution, we are applying for an air use permit to. burn
.reclaimed oils containing incidental concentrations of
PCB's in our No. 3 Boiler. For any additional information
or clarification required, please contact this department
at (517) 894-4111, Ext. 251.
TD. R.
Plant Engineer
s—/
30
-------
AIR QUAL1IY DIVISION
MICHIGAN DEPARTMENT OF NATURAL PESOURCES-,,.,..,;„ rnrtrn,
P.O. BOX 30028, LANSING. MICHIGAN 48909'v "Cn t0filf01
APPLICATION TO THE AIR POLLUTION CONTROL COJAMISSIOH °
for outfiority to conttruct, inttoll or oltcr
and
tot permit to operot* proctn, fvtl burning, rcful* burning and/or air pollution control •o.uipmcnt
385-78
TO 1C OIUCD TO r£w.«K LIC..I. ,%«•« c< O»»or.lu»». />>rt»«r
Chevrolet Motor Division, CMC
MAILIKO ADORISl rnwit
100 Fitzgerald Street. Bay City. Michigan 48706
Uimt NT OX 'HOCUS LOCATION fftunoo. Sl'ril. f.aj or t,ll*(c. TowiuJklf. Zip
100 Fitzgerald Street, Bay City, Michigan 48706
« TY?t Or OMGANIIATION
'.f~\ Corpo«*
| 1 O«v«rnl*i«nl»l
I. OCMCKAL. NATUHC Or »Ull»t5J
Manufacturer of Automobile Parts
OI»C»ir-TIOM:
c.B,|fl)Ct, ,
l M .ll.r .^ to
I.Mo..n(
Burn reclaimed oils containing incidental concentrations
of PCB's in existing No. 3 Boiler.
I UTIMATIO COIT:
Dliric <
n roHvtion (.ftMrol tqutpm«M 1
Tin
Totcl rr«|«ct
I P*CSE*T STATUS or EQUIPHCMT
(,*) Construction o* initoftol.on not itorteo*
( ) Construction of • nttelloiion portly completed .
( ) Equipment it lo k* ottered - . .
( ) Equipment i* portly alteree*
{ ) Equipment hot be»n altered
Starling Dote
6/1/73
C»«»letie* Dot*
7/1/78
I > «AM£ Or PRIOR OWNER AS IN 111 »BOVt AND PPIOX AIR POLLUTION CONTROL PERMIT NUKtCR. ir ANY:
I '0 TYPC OR PRINT NAME AND TITLE OF OWNER OR AUTHORIZED MEUtER Or FIRM:
(Tul,i Supt.-Maint. & Pit. Eng.
(D,i,l /t/^.?./nf ffl (Pk»», NO i- • '-' r i .•!//>
/
Pormtt tb*m
.opprovt^ anrf i
i •ppre/crf int
r
'ORUAP-I IU •'"
>M for
74
31
-------
AIR POLLUTION CONTROL COMMISSION
AIR QUALITY DIVISION
MICHIGAN DEPARTMENT OF NATURAL RESOURCES
A PPLJCAT10N INSTRUCTIONS
Submit (hit (otm in triplicate; complete application requires specification* and drawings in duplicate. An application
is requited tot baaic processing equipment as well as air pollution control equipment. Baaic equipment includes any
article, machine, equipment o« other contrivance. 4he use of which may cuuse the issuance of air contaminants. Air
pollution control equipment includes any article, machine, equipment or other contrivance, the uae ol which may elim-
inate 01 reduce or control the issuance of air contaminants. One application will suffice for an interrelated process.
This application must be signed by the owner or authorized member of firm. Please attach the following:
1. Equipment Locution Drawing! - Submit drawings showing: ;'
a. Plan view of ownei's property to boundary lines, include outline «nd height of all structures.
b. Locate and identify proposed equipment on property line.
c. Locate and identify all adjacent properties and all structures within 150 feel of proposed equipment showing
outlines and heights.
d. Indicate north direction on drawing.
2. Equipment Specification - State make, model, sue and type, etc. of proposed equipment and all major accessory
equipment.
3. Precan er U«» Spacificotion - Attach a complete written description of each process covered by this permit »pplt.
cation. Explain clearly and in detail each process stage by including the nature, quantity, concentration, particle
size, pressure, temperature, etc. of materials which may be discharged to the atmosphere. Prove sufficient control
method detail to show the extent and efficiency of air pollution control devices.
4. Operoting Sehadula - Specify proposed equipment operating lime in hours per day and days pel week.
5. Pfoc«»i Waighl - Detail type and feed rale in pounds per hour or similar me-jsure for each process material charged.
6. Fu«U ond Fifing Dtvicei - Indicate for gaseous fuels: type and cubic feet per hour, for fuel oil. grade and gallons
pel hour, sulfur content, and specify temperature to which oil is preheated, for solid fuels: type, ultimate analysis
and pounds per hout, indicate f»r firing dcvue make, model, size, type, number of devices and capacity tange of
each device (from minimum to maximum).
7. Flow Diogrom - For continuous processes, show the flow materials either on a separate flow diagram or on the
drawings accompanying the application. »
8. Drawing! or Equipment - Supply an assembly drawing, dimensioned to scale, in plan, elevation and as many sec-
lions as are needed to show, clearly, equipment design and operation and the means for controlling air contaminants.
Structural design calculations and details are not required. When installing standard commercial equipment, the
manufacturer's scale describing the equipment may be submitted in lieu of the parts of Item 8 that it covers. The
following must be shown:
a. Size and shape of the equipment, exterior and interior dimensions and features and materials of construction.
b. Locations, sizes and shape details of materials handling equipment and all features which may affect the produc-
• tion, collection, conveying or control of an contaminants.
c. Horsepower rating of driving motors. ,
d. Additional information may be required.
e. Indicate where in the system provision is made for source testing.
9. A permit application should pertain to an individual unit of equipment or to an operation or to a series of related
operations within a process which are scheduled for simultaneous installation or alteration.
After authority to construct, install or alter is granted (or any equipment, deviations from the approved plans and
application information required are not permissible without first securing written approval.
Further information or clarification concerning permits can be obtained from the A1r Quality Division
(517)373-8630, (Lonsmg) Mjchigon Department of Natural Reiources, P.O. BOX 30028
Lansing, Michigan 48909
75
— yellow copy lo b* r»r.in»J fcy applicant —
32
-------
PERMIT TO BURN PCB CONTAINING OILS
Item //I - Refer to attached drawings //PE-B-160, sheet #268
and PE-H-22.
Item #2 - //3 Boiler will be used to burn PCB containing oil.
This boiler is used to produce steam. It is a
Wickes, Type "A"65-4K-7, with a capacity of
60,000 Ibs. steam/hr. The State boiler permit
number is M71616M.
Item #3 - For information on the process specifications,
refer to the test report sent to your office by
Mr. E. R. Bangel of Chevrolet Central Office.
The report covered the test procedure and results
of the emission tests conducted by Chevrolet
while burning PCB containing oils in our boilers.
Also, refer to the attached letter, dated
November 16, 1977, from Mr. Gerald L. Avery,
Department of Natural Resources, concerning a
list of information necessary to process a permit
to burn PCB's. Enclosed is a list of answers to
those questions (See Attachment "A").
Item #4 - The powerhouse normally operates on two (2)
boilers, 24 hours/day, 7 days/week. Since oil
is reclaimed @ 4000-5000 gallons/month, burner
requirements dictate that reclaimed oil could
provide 3-4 days of fuel per month for the
operation of one boiler when mixed with ??2 fuel
oil so as to reduce the PCB concentrations to
less then 50 PPM.
Item #5 - Does not apply, see Item //6.
Item #6 - Fuel consumption for the boiler burning reclaimed
oils will be approximately 240 gallons/hr. The
fuel supplied to the boiler will be reclaimed oils
mixed with //2 fuel oil ( @ .208% Sulfur content )
so as to reduce the PCB concentrations to less
than 50 PPM. Annual usage of the reclaimed oiJs
will be approximately 60,000 gallons.
Item 117 - Sc;c! attached sheet, Illustration //I.
I turn i'/8 - KcfVr to the attached manuf acturor' K Drawjnj;
T SA-HK/i.
33
-------
ILLUSTRATIONX1 - FUEL OIL FLOW DIAGRAM
RECLAIMED
OIL
FUEL OIL
u>
5000 GALLON
STORAGE
FUEL OIL BURNERS
-------
Attachment "A"
1. Refer to Drawinq's #PE-B-160, sheet $268 and PE-ll-22.
2. (a) Acceptance as a reclaim oil from our manufacturing
plant only.
(b) Laboratory analysis of each batch of reclaim oil
for PCB content.
(c) All PCB's are contained in the reclaim oil and are
the residuals from the hydraulic systems operated
within the manufacturing plant.
(d) Not Applicable (N.A.), the sources of the reclaim oil
are within the manufacturing facility.
(e) N.A.
(f) N.A.
(g) Reclaimed oils are accumulated in a holding tank.
This tank will be equipped with a carbon filter
vent cap.
3. See attached Pollution Incident Prevention Plan for
Chevrolet-Bay City (Attachment "C").
4. The reclaim oil will be transferred via pipeline in
small quantities to the powerhouse and mixed with a
predetermined amount of ^uel oil so as to reduce the
PCB concentrations to less than 50 PPM, this oil will
be used to fire one boiler.
5. None, because of the low concentrations of the material.
6. Normal plant security.
7. Reclaim oil containing not more than 50 PPM PCB and
mixed with No. 2 Fuel Oil will be burned in one boiler
only, at a rate compatible with the steam demand.
8. Reclaim oil and No. 2 Fuel Oil.
9. -8 PPM, see attached calculations (Attachment " D") .
10. Boiler manufacturer'specifications indicate one (1)
full second retention in the combustion zone. Burner
temperature of 2600 to 2700°F; back wall temperature
of 1500 to 1600°F. See page 5 of test report of 5-19-75.
35
-------
Attachment "A"
11. Not Applicable (N.A.). SOP tost report of 5-19-75.
12. N.A.
13. Reclaim oil is handled as a batch process. Tach
batch is sampled and Laboratory tested to confirm
concentrations of less than 50 PPM of PCB before
burning.
14. Usual boiler controls monitored during normal fuel
burning.
15. None.
16. N.A.
17. N.A.
18. N.A.
19. N.A.
20. Test report of 5-19-75 demonstrated reliability of
destruction of PCB's in reclaim oil when held to
less than 100 PPM of PCB. No further testing is
contemplated.
21. See test report of 5-39-75.
22. None.
23. None.
36
-------
Attachment "B"
(See PE-H-22 also)
Manufacturing Building - Height
Administration Office 3V
Area #1 37'0"
Area #2 27'0"
Area #3 26'0"
Area tik 29'0"
Area #5 32'
Out-of-Plant Facilities Height - Size
Warehouse 13'6" 60' x 400'
Powerhouse *»2' 108 x 123'
Oil Pumphouse 8' 18' x 32'
Primary Switch Room 15' 20' x 60'
Metal Storage Area - *»0' x 72'
Hazardous Mat'l Storage 28' 6W x 8W
Barrel Storage 33'6" ^2'8" x 96'8"
Watertower 100' 28' Dia.
Oil Storage Tanks 32' 33' Dia
and Dikes
Wastewater Facility *»3' 108'2"x 123'2"
Tank Farm 20' 32'8" x 59'V'
Oi1 Pump Room 30' 1A' x kO'
37
-------
MICHIGAN DEPARTMENT OF NATURAL RESOURCES
INTEROFFICE COMMUNICATION
May 10, 1978
-*
TO: Jerry Avery, Permit Unit
FROM: John Shaffer, S. S. Unit
SUBJECT: Chevrolet Bay City - PCB Test, May 17, 1976
This test is not acceptable based upon the following:
1. Sampling method needs to be verified in the laboratory with respect to the
following:
a) Capture efficiency of Florisil tube based on the volume flow rates as
. applied.
bj Effects of stack moisture on capture efficiency.
Analytical recovery efficiency of Florisil tube.
Detection level of Florisil method as applied.
Maximum level of saturation of Florisil - maximum amount of PCB that
can be adsorbed per gram of Florisil.
2. Sampling was not conducted isokinetically. In all cases, sampling for
PCB's shall be done isokinetically. This is based on the low vapor pressure
of PCB and its (assumed) tendency to adsorb
-------
Chevrolet Motor Division
June 2, 1978
Page 2
Thank you for your cooperation.
Mr. Gerald Avery at (517) 322-1333.
If you have any questions, please contact
Very truly yours,
Delbert Rector, Chief
Air Quality Division
DRrgav
Enclosure
cc: Ben White
Richard Powers
Office of Toxic Materials Control
Environmental Services Div.
Department of Natural Resources
39
-------
STATE OF MICHIGAN
NATURAL MSOURCCS COMMISSION
CARL T JOHNSON
E U LAITALA
DEAN WIDGEON
HILARY f SNELL
KARRr H WHnELEY
JOAN L. WOLFE
CHARLES G YOUNGLOVE
j WILLIAM G MILLIKEN. Governor
DEPARTMENT OF NATURAL RESOURCES
HOWARD A. TANNER. Dirtctor
June 2, 1978
AIR POLLUTION CONTROL COMMISSION
Mjurm S R>«n. MO.
Cteirnun
Witxm A Gilpm. MO
Miry L Q'»*I
Robert L Htnry, Jc
Edwird J Klopp. Jr . M O
Geofg, H Rtxks
Suntoy R OiuckinDulh
Philip L Riclurdl
O J Sctwrtchltgt
Edwin S Shannon
Monon Sterling
Bi» 30028
U/vnto Ml 4*909
Chevrolet Motor Division
General Motors Corp.
TOO Fitzgerald Street
Bay City, HI 48706
ATTENTION:
Gentlemen:
R. D. Koenlg, Superintendent
Maintenance and Plant Engineering
This letter is in reply to your application received on April 17, 1978, for
a Permit to burn oil containing polychorinated blphenyls (PCB) 1n your existing
no. 3 oil firing boiler, proposed for location at 100 Fitzgerald Street, Bay
City, Michigan.
The staff of the Michigan Air Pollution Control Commission is presently
unable to approve this application pursuant to the delegation of authority entered
by the Commission because 1t is the judgemnt of the staff that the equipment for
which the permit is sought would not operate in compliance with Rule 46 of the
Commission's rules. Enclosed is a copy of our staff report which explains the
basis of our judgement.
Accordingly, the staff will recommend that the Michigan Air Pollution Control
Commission deny your application for a Permit to Install this equipment. This
action is scheduled for June 20, 1978, and will be considered during the time set
aside for review of the permit applications. At that time, you will be given
an opportunity to appear before the Commission on behalf of your application for the
Permit to Install.
You are advised not to install the aforementioned equipment until such time as
you receive an approved Permit to Install from the Commission. By law, any person
who installs such equipment without first obtaining the Permit to Install is guilty
of a misdemeanor and subject, upon conviction, to a substantial fine.
MICHIGWN
CMAT
i«"
»T»It
40
-------
MICHIGAN DEPARTMENT OF NATURAL RESOURCES
AIR QUALITY DIVISION
STAFF ACTIVITY REPORT
June 20, 1978
Applicant
Chevrolet Motor Division
General Motors Corporation
100 Fitzgerald-Street
Bay City, MI 48706
Permit to Install No. 385-78
Significant Dates
April 17, 1978 — Application for Permit to Install received.
•
Proposed Facility
The applicant is proposing to burn oil containing polyclorinated biphenyl
(PCB) in their existing 60,000 Ibs. of steam per hour boiler. The PCB
contaminated oil would be mixed with No. 2 fuel oil in order to reduce the
PCB concentration to less than 50 parts per million. The total amount of
PCB contaminated oil that would be burned is approximately 240 gallons per
hour or 60,000 gallons per year.
History
The applicant had been burning PCB contaminated oils in their three existing
boilers for approximately 2 years. On July 14, 1977, the Office of Toxic
Materials Control, Environmental Services Division, Department of Natural
Resources denied the applicant's exemption application to burn PCB contami-
nated oils in the boilers since the applicant had not fully complied with
the provisions of Act 60, P.A. of 1976, and the administrative rules
promulgated pursuant to the act. Act 60 is the PCB control act that regulates
the manufacture, sale, use, and disposal of PCB. On September 2, 1977, the
Commission's staff notified the applicant that an approved air use permit
application must be obtained from the Commission before any further burning
of PCB contaminated oils would be authorized.
On February 17, 1978, final regulations for disposing of PCB were promulgated
pursuant to Section 6, (e)(l) of the United States Toxic Substance Control
Act. These federal regulations require that the combustion criteria for
disposing of PCB shall be either of the following:
1. Maintenance of the PCB for a 2 second dwell time at 2192°F and
3% excess oxygen in the stack gas, or
41
-------
Staff Activity Report - Page 2
GMC, Chevrolet Motor Division
June 29, 1978
2. Maintenance of the PCB for 1.5 second dwell time at 2880°F
and 2% excess oxygen in the stack gas.
Analysis of Impact
The applicant has submitted data that indicates that the dwell time of the •
PCB contaminated oils in the combustion zone of the boiler would be equal
to 1 second at a temperature that would vary from approximately 2550° at
the burner to approximately 1550° at the back wall. These combustion
conditions clearly do not meet the criteria listed above. Therefore, it
is the judgement of the staff that the burning of PCB contaminated oil would
not comply with Rule 46 of the Commission's rules since there is not adequate
assurance that the PCB would be completely combusted. Rule 46 prohibits the
emission of an air contaminant which causes or will cause detriment to the
safety, health, welfare or comfort of any person.
The following are a list of additional items that were not adequately
covered in the present application which staff did not investigate in detail
since the proposed equipment would not satisfy the basic combustion criteria:
1. The application did not include a water scrubber which is required
to control the hydrogen chloride that would be generated by burning
the PCB.
2. The stack test that the anolicant-conducted on May 17, 1976 and which
indicated a 99.99+% PCB destruction was unacceptable. It was
unacceptable because the sampling method was not verified in a
laboratory, the sampling was not conducted isokinetically, and the
stack test report did not describe the exact field and analytical
procedures used in the test.
3. Other data necessary for a complete application was not submitted.
Recommendation
The staff recommends denial of the Permit to Install No. 385-73, pursuant
to rule 336.28(a) which states: "The Co,7mission shall deny an application
for a Permit to Install if, in the judgerrent of the Commission, the equipment
for which the permit is sought would not operate in compliance with the
rules of the commission or state law".
Submitted by: Gerald L. Avery
May 31, 1978
GLA:mb
42
-------
BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGE HAS
BEEN RETYPED FOR CLARIFICATION
GM SWC DETROIT
SNB0001 NS BYCA
LWA GERALD AVERY DEPT. OF NATURAL RESOURCES, LANSING, MI
GERALD AVERY, SUPV. OF PERMIT UNIT
DEPARTMENT OF NATURAL RESOURCES
SECONDARY COMPLEX-GENERAL OFFICE BLDG BOX 30023
LANSING, MI 43000
REFERENCE IS MADE TO OUR APPLICATION FOR A PERMIT TO INSTALL 0. 335-78
RECEIVED BY YOU ON APRIL 17, 1973, TO BURN RECLAIMED OILS CONTAINING
INCIDENTAL CONCENTRATIONS OF PCB'S IN OUR EXISTING N.3 OIL FIRED BOILER
LOCATED AT CHEVROLET-BAY CITY, 100 FITZGERALD STREET, BAY CITY, MICHIGAN,
48706. WE REQUEST THAT THE SUBJECT PERMIT APPLICATION BE WITHDRAWN AND
REMOVED FROM CONSIDERATION BY THE AIR POLLUTION CONTROL COMMISSION.
D. R. KOENIG, SUPT. MAINT. & PLT. ENGR., CHEVROLET BAY CITY
43
-------
STATE OF MICHIGAN
-H/lUt RESOURCES COMMISSION - A£2/> A,R POLUmOK CONTROL t
C«L ^JOHNSON ^_y M.^SR.-.n.MO.
WILLIAM G. M.LUKEN. Governor «-»
H"««RYYH WH^ELEY DEPARTMENT OF NATURAL RESOURCES -«,•.*«.
JOA>, L wOCfE HOWARD A TANNER. D.rector ££,J TC * UO
CHABUS G YOONGLOVE . . George H ReiHa '
JUN 2 8 1978
Stanley A
Philip L ftictiardt
O J Scr«racNqt
Edwin S Shannon
Uonon Sterling
Chevrolet Motor Division, GMC
100 Fitzgerald Street
Bay City, MI 48706
ATTENTION: R. 0. Koenig, Superintendent
Maintenance and Plant Engineering
Gentlemen:
This letter is in reference to your application received on April
17, 1978, for a Permit to burn oil containing polychlorinated biphenyls
(PCB) in your existing no. 3 oil fired boiler, located at 100 Fitz-
gerald Street, Bay City, Michigan, The application, identified as flo.
385-78, has been voided by the staff.
Action to void this application was due to your June 15, 1978, re-
quest to withdraw this application.
Please contact this office within 30 days if you wish to appeal
this action or have any questions concerning it.
Very truly yours,
Gerald L. Avery, ActingCthief
Permit Unit
Air Quality Division
GLA:jv
Enclosure
cc: Ben White
MICHIGAN
TH»
encAt
STATC
All
10/77
44
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Environmental • ..•<»* Stall
General Motors Corporator
General Wstors Technical Center
V.'arren. Michigan
David S Potter
November 2, 1978
Mr. Douglas M. Costle
Administrator
U. S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
Dear Mr. Costle:
On September 1, 1978, Mr. E. M. Estes, President of General
Motors Corporation, received an August 29 letter from
Mr. V. V. Adamkus, Acting Regional Administrator, EPA
Region V, regarding 40 CFR Part 761, Polychlorinated Biphenyls
(PCB's) Disposal and Marking Regulations. Since the regulations
were published in the February 17, 1978, Federal Register, my
staff has been maintaining a continuing watch for the availability
of EPA approved PCB incineration facilities. We believe that
incineration is most appropriate for preventing future problems
caused by PCB wastes.
I am very much concerned that in the eight months since publica-
tion of the regulations, no EPA approved incineration facility has
become commercially available. This, of course, impedes the
orderly destruction of existing PCB's in this country, and may
cause adverse environmental consequences due to spills and
illegal disposal. I wish to call your attention to this matter and
recommend that:
• EPA should evaluate whether the waste disposal industry
will be able to meet federal, state, and local requirements
for PCB incineration facilities. As yet, no commercial
facilities have been approved and we are particularly
concerned that there might be siting problems. In addition,
the time schedule and capacity for these planned facilities
should be determined to assure they can meet the demand for
45
-------
Mr. Douglas M. Co.tl. _2_ November Z, 1978
disposal needs in light of the proposed ban on manufacture
and use of PCB's.
• If, in the judgment of EPA, the waste disposal industry
cannot handle this matter expeditiously and with adequate
capacity, EPA should actively assist the industry where
necessary. For example, EPA could design and build
demonstration incineration facilities, local ordinances
permitting, for sale and/or lease to private contractors
or local governments. These facilities could serve as a
model for further expansion of the private waste manage-
ment industry.
• EPA should encourage and assist private industry, state,
and local governments in developing hazardous waste
treatment and disposal facilities, including those for PCB
wastes.
If members of my staff can be of assistance to you, please let
me know. I earnestly hope your Agency will move quickly and
positively to correct the current untenable situation.
Very truly yours.
cc: John McGuire
Regional Administrator
EPA Region V
230 South Dearborn Street
Chicago, Illinois 60604
bcc:W. D. Brusstar
G. E. Calhoun, Chev-C.O.
J. P. Chu
E. M. Estes
J. J. Hollis
\V. R. Johnson
R. E. Magill
J. B. Medved, CFD, Saginaw
D. P. Parrish
W. J. Way
46
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Ontario #NUAM n, 1979
Ministry FOR FURTHER INFORMATION:
ofthe L.F. Pitura (416) 636-8015
Environment A 0 Raymond (416) ^5-7ll
HISSISSAUGA REPORTS RELEASED
DY ENVIRONMENT MINISTER HARRY PARROTT
Two reports on the burning and air levels of PCBs in Mississauga hove been
released today by Environment Minister Harry Parrott in preparation for public
hearings on the subject.
The "Director's Report to the Environmental Assessment Board on the pro-
posed burning of PCCs at St. Lawrence Cement, Mississauga" was filed with the
board as the government's basic background document for the hearings, expected
to take place in late February or cariy March.
Prepared by Len Pitura, director of the Ministry's waste management branch,
the report contains information on the nature of PCBs, how they should be
handled and destroyed, and available d.Ua on their effect on human health. It
also provides a synopsis of the Ministry's position and a summation of the case
it will present at the public hearings.
The second report is a study of the levels of PCBs in Mississauga air
prepared by the Ontario Research foundation for the Ministry. Although the
report indicates that PCBs are present in trace amoupts, it stresses that more
study is needed to determine the accuracy and significance of the levels.
"I want all meaningful background data and available information about PCBs
to be on the public record before the hearings start in Mississauga," Dr. Parrott
said. •
47
-------
The question regarding atmospheric levels of PCBs in the Mississauga area
originally arose after trial burnings of the substance took place in the cement
kiln at the St. Lawrence Cement Company. It had also been determined that some
of the liquid wastes burned at St. Lawrence and the Tricil Ltd. facility con-
tained trace amounts of PCBs. The Ministry has banned the burning of liquids
conta i ni ng pes ti c i dcs and jo^ejthu n__100 parts per million of PCBs penduig
further scientific investigation and public hearings.
"To ensure that Mississauga residents will have access to all the data the
need, the Ministry is holding several information open houses in the community.
This will give interested citizens and environmental groups an opportunity to
obtain comprehensive technical information and to consult with Ministry experts
who will be on hand," the Minister said.
"We hope to announce the dates and locations of these information meetings
within a few weeks."
Copies of both reports are available from:
Waste Management Branch
Ontario Ministry of the Environment
4375 Chesswood Drive
Downsview, Ontario M3J 2C2
Tel: (416) 63G-8015
- 30 -
48
-------
Ministry IDS a Oa« Avenue WCM
' SwIclOO
Of the loionlo.OnloiiO
Environment Mf ,PCBs_a.Qd...scw.eral_o_thor
yi lures. pfl the.1.. •lir_(l".ij)i^- ckU_.su~ggest_tha.t_ t))e..repprted
ievels..o.f .L'C.fis ."iir.the a"Ljjios|>l:ere .are higher. lhan_ the_actiial
aiiibunt duoto ij]te.rfrencos tliotexist in the method of
49
-------
_
average PCB concentrations ranged from a low of 6 ng.m in.
t he res i dontial areas to a hi(ji^_of M_nq .
~~~
_
TWerage colikentrations~~a~f the residential sites
jiancjed from 6 to 12 __ng.ni_~3, '
(jTb. ng.nr^ means a naiiogram per cubic meter of air. One
nanogram equals one billionth of a gram in weight or one-tenth
of a part per trillion by volume, in effect miniscule quantities.)
comparison of the PCB levels at upwind and downwind sites and
the correlations of PCB concentrations with wind direction,
indicate that emissions from
_^
. .
in the residential areas surrounding the plants.
- storage and handling operations of liquid waste by the plants
appear to contribute to the PCR concentrations found on plant
property sites. (Some liquid wastes such as crankcase oils arc
burned in the cement kilns as an alternative fuel source and
may contain some PCBs.) Burning of any liquid waste containing
pesticides or more than 100 parts per million of PCBs has been
banned by the Ministry until further scientific investigation
and public hearings can demonstrate the complete safety of the
process.
- the results suggest that airborne PCBs at levels indicated
above, may be coming into the area from other sources in the
southwest. This is in agreement with the generally held
concept that atmospheric transport is one important method by
which PCBs spread through the atmosphere.
Background
Most background PCB air quality data from other areas in Ontario is
difficult to compare to previous measurements because newer analytical
techniques are being used.
In August 1978, the Ministry ran air sampling equipment in tv/o
locations for five days to obtain some more recent control c'ata. Using a
similar analytical method to that used in the ORF report, the following
PCB levels were measured:
Downtown^ Toronto -• 31 nanggranis TiPjl,p.uUlC-j.ietLcr
(average for five days)
Rural arca^ casjt_of - 8 nanogranisjper_cu.ij.i^_njgtc.r
nOrangevfTTe_ [average for five days)
This and other similar data from around the world indicates the
presence of PCtts in the atmosphere, evert in areas like Bermuda, Hawaii,
and the polar ice cap.
50
-------
Measurements Elsewhere
(Analysis by different techniques; results not compared or confirmed)
Bermuda: 0.3 ng.ni!*
Rhode Island: 9 ng.m
Fort Collins (Colo.): 2.1 to 15.4 ng.m"3
Miami (Ha.): 0.9 to 37 ng.m-3
Gainesville (Fla.): Jl to 44 n9.m-3 ,
Lafayette (Ind.): 1.7 to 13,7 ng.m"*
New Bedford (Mass.): 8.5 to 13Q9 ng.nf::
Jackson (Miss.): 1.8 to 16;9 ng.m
Harrisburg (Pa.): 1.7 to 7.8 Rg.m-3
The prevalence of this substance strengthens £he Ministry's opinion,
as spelled out in the director's report, that PCB-eontaminated material
must be completely destroyed rather than permitting it to escape into the
environment and then the food chain.
The director's report states that the Ministry is not aware of any
studies which indicate that exposure to current atmospheric levels of
PCBs poses a health hazard. It states that according to medical author-
ities in the Occupational Health and Safety Division of the Ontario
Ministry of Labour (Special Studies arid Services Branch) the major sourcc_
of human exposure to PCBs is from fresh water fish. ~
The report gives an example which puts this in perspective. The
maximum recommended safe level for PCBs in fish, as set by the federal
government, is two parts per million. If you ate half a kilogram
(1.1 pounds) of fish containing PCBs at this level, you would consume
5,000 times more PCBs than you could get from breathing Nississauga air
for 24 hours.
This is based on 10 nanograms per cubic meter of air, the averaqe
level of airborne PCBs found in Mississauga. That's 10 billionths o-f a
gram per cubic meter, a concentration well within the levels normally
found in a wide range of North American communities.
In February, Environment Ontario expects to receive delivery of a
mobile TAGA 3000 (Trace Atmospheric Gas Analyser) monitoring system,
developed and manufactured by Sciex Inc., Thornhill.
This mobile unit will be used for further sampling and for com-
parative monitoring in Mississauga nnd other parts of Ontario and to
develop more accurate sampling and analytical procedures. A TAGA 2000
owned by the federal government has been used previously for this purpose.
In addition, Sciex Inc. has been hired to do a comparative analysis
of the Ontario Research Foundation samples taken last summer to eliminate
and-explain the suspected interference in the levels reported by the
study. Preliminary results indicate lower concentrations or even the
absence of some forms of PCD-;, fins suggests the likelihood that the
values reported in the ORF stiu!., and other Ministry surveys may be
artificially high, due to interference in the method of analysis.
The TAGA 3000 will give Environment Ontario the most advanced and
sophisticated means available to analyze organic substances of all kinds,
according to l.W. Cross, director of the Ministry's air resources hmnch.
51
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OCA/TECHNOLOGY DIVISION
—-. R. Bradway
TO: N. Surprenant DATE: A?ril «. 1979
FROM: W- Piispanen
SUBJECT: Trip Report for PCB Test Meeting
Purpose: To discuss PCB sampling and analysis for GM boiler test.
Attendees: From EPA: Ron Venezia
Hal Snyder (Office of Toxic Substances)
Larry Johnson
From GM; David Aldorfer (Environmental Activities)
G. E. Calhoun (Staff Engineer)
also three late attendees from G. M.
From GCA: W. Piispanen
S. Zelenski
Discussion:
The proposed regulations for disposal of PCfa's were discussed by Hal
Snyder. Ron Venezia then discussed the purpose of the testing at the G.M.
facility. The problem of testing the Bay City, Michigan site was discussed
with regard to acceptance of a test plan by the State of Michigan. A
possibility of testing at other G. M. boilers was considered but the problem
of transporting PCB's and other logisticswas not considered feasible.
The remaining discussion was directed primarily towards testing at the
Bay City boiler. The proposed test methods were discussed and compared
against the tests completed by G. M. The method proposed by GCA was one
similar to the "Mitchell Method". The advantages and disadvantages of
florasil as a collection medium were discussed with no serious objection
to the use for PCB collection. Larry Johnson reaffirmed the choice of
florasil but noted that problems of plugging had been reported in high
moisture tests.
52
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R. Bradway -2- April 19, 1979
N. Surprenant
In addition to the testing for PCB's, Ron Venezia requested that tests
for dibenzo furans, total organic hydrocarbons, total chlorinated hydrocarbons,
HC1, and total particulate be conducted. In addition, on-line monitors for
CO, CCL, 0 and total hydrocarbons would be required since these parameters are
not measured by G. M.
The discussion of these proposed tests resulted in a final plan to include
three tests with a second Method 5 sampling train including a heated filter to
collect the particulate. The particulate would be weighed and analyzed for
dibenzo ferons. An XAD-2 sorbent column will be included on this train for
the determination of total organic hydrocarbons by gravimetric and TCO methods.
The HC1 emissions will be measured in the sampling train by a method to be pro-
posed by GCA. The inclusion of these additional tests would require the
addition of a second sampling train and a crew of two more sampling personnel.
The on-line monitoring equipment will tentatively be provided by EPA along
with a gas conditioning system! GCA will be responsible for installation and
operation of these instruments during the tests. An additional team memker
will be required for this task.
No measurements or tests will be performed for total chlorinated hydrocarbons,
NO , or SO .
x x
The fuel/waste to be combusted during the tests was then discussed.
Currently, G. M. has a pre-mixed batch of 54ppm PCB fuel similar to a #4 fuel
mixture. The problem in using this fuel is that the regulations specify that
only 10% of the fuel may be waste material. Burning the available waste would
then result in a 5.4ppm mix which would not be feasible for test purposes. Also,
the work assignment requires 1 test to be conducted at background conditions,
i.e. - fuel without waste added. This condition would not be possible if the
54ppm waste were fired directly.
Instead, it will be necessary for G. M. to provide a holding tank for a
prepared 500 ppm PCB waste material which will be mixed at a 1:9 ratio during
testing. A #2 fuel will be used during test operations due to ease of mixing
the waste in this material.
As a result, G. M. will provide one operation of burning #2 fuel only
and 3 test burns of a fuel containing a total of approximately 50 ppm PCB's.
An integrated trickle sample will be taken of the fuel burned during each test.
Expected firing rate will be 240 gal/hr with steady operations. It was noted
that the firing rate was lower than originally reported to GCA and may result
53
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R. Bradway -3- April 19, 1979
N. Surprenant
in a longer than proposed test time. (A rough calculation indicated that
370 min. would be required for the collection of 10 yg at 99.9% destruction
efficiency).
The conclusion of the meeting was that GCA should contact Ron Venezia
with a new estimate of man hours required for the testing as discussed. A
work plan for the testing and analyses should be provided directly to Ron
Venezia, Hal Snyder and G. M. (David Aldorfer) by April 27.
'JU
W. Piispanen
WP/baf
54
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25 April 1979
Mr. Hal Snyder
Office of Toxic Substances
TS-794
_
U.S. Environmental Protection Agency ___ 0 'jj I _____
Washington, D.C. 20460 Ho\ MS^^^e' _ _ f ]
Dear Mr. Snyder:
Enclosed is a copy of the work plan generated by GCA for an
evaluation of the PCB-destruction efficiency of the GM boiler at Bay City,
Michigan. The major elements of this plan are based on the results of
our discussion of April 18, 1979, at Research Triangle Park. Please read
and note any changes you feel might be necessary.
Dr. Venezia will contact you shortly for your comments on this
work plan.
1 hope that we can proceed wila this project as cxpeditiously
as possible.
Best regards.
Very truly yours,
i /; v . v •_; t ,. 'X^ ,.^/t-
Steven G. Zelenski, Ph.D.
SGZ:jaf
Enclosure
cc: Dr. R. Venezia
55
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GCA
25 April 1979
Mr. Gene E.Calhoun
Staff Engineer
Facilities & Environmental Engineering Department
Central Office Warren Annex
Chevrolet Motor Division
General Motors Corporation
30007 Van Dyke
Warren, Michigan 48090
Dear Mr. Calhoun:
Enclosed is a copy of the work plan generated by GCA for an
evaluation of the PCB-destruction efficiency of the GM boiler at Bay City,
Michigan. The major elements of this plan are based on the results of
our discussion of April 18, 1979, at Research Triangle Park. Please
read and note any changes you feel might be necessary.
Dr.Venezia will contact you shortly for your comments on this
work plan.
*
I hope that we can proceed with this project as oxpeditiously
as possible.
Best regards.
Very .truly yours,
,^ ..
Steven G. Zelensk'i, Ph.D.
SGZ:jaf
Enclosure
cc: Dr. R. Venezia
56
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May 1, 1979
Dr. Ronald Venezia
Chemical Processes Division
Particulate and Chemical Processes Branch
Industrial Environmental Research Laboratory
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
Dear Ron:
Enclosed are six copies of the revised project schedule
to replace Section 4.0 in the workplan on the "Evaluation of PCB
Destruction Efficiency in Industrial Boilers." These changes are
based on our conversation of April 25, 1979, and reflect:
1. the addition of milestones for preliminary
reporting of PCB and DBF analysis results,
2. initiation of data analysis and report
preparation at earlier stages in the program
and,
3. changing the date of final report submission
to October 12, 1979.
I have also sent two copies each to Hal Snyder and
Gene Calhoun.
Sincerely yours,
Steven G. Zelenski, Ph.D.
Head, Organic Analytical Section
SGZ/mjl
Enclosure
57
-------
May 1, 1979
Mr. Hal Snyder
Office of Toxic Substances
TS-794
U.S. Environmental Protection Agency
401 M Street, SWT
Room 525, East Tower
Washington, DC 20460
Dear Mr. Snyder:
Enclosed are two copies of the revised project schedule
to replace Section 4.0 in the workplan on the "Evaluation of PCB
Destruction Efficiency in Industrial Boilers." These changes are
based on my conversation with Ron Venezia of April 25, 1979, and
reflect:
1. the addition of milestones for preliminary
reporting of PCB and DBF analysis results,
2. initiation of data analysis and report
preparation at earlier stages in the program
and,
3. changing the date of final report submission
to October 12, 1979.
Sincerely yours,
SGZ/mjl
Enclosure
Steven G. Zelenski
Head, Organic Analytical Section
58
-------
May 1, 1979
Mr. Gene E. Calhoun
Staff Engineer
Facilities & Environmental Engineering Department
Central Office Warren Annex
Chevrolet Motor Division
General Motors Corporation
30007 Van Dyke
Warren, MI 48090
Dear Mr. Calhoun:
Enclosed are two copies of the revised project schedule
to replace Section 4.0 in the workplan on the "Evaluation of PCB
Destruction Efficiency in Industrial Boilers." These changes are
based on my conversation with Ron Venezia of April 25, 1979, and
reflect:
1. the addition of milestones for preliminary
reporting of PCB ard DBF analysis results,
2. initiation of data analysis and report
preparation at earlier stages in the program
and,
3. changing the date of final report submission
to October 12, 1979.
Sincerely yours,
Steven G. Zelenski, Ph.D.
Head, Organic Analytical Section
SGZ/mjl
Enclosure
59
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
DATE: june 1, 1979
SUBJECT Trip Report: Michigan Dept. of Natural Resources, Lansing, Michigan
May 23-24, 1979
FROM: Ronald A. Venezia
TO:
Files
May 23, 1979
t
Attende3s: EPA—Hal Snyder, Ron Venezia
GCA—Steven Zelenski
Michigan; Air Quality Div.—George Su
Permit Unit-'-Gerald Avery (Head of Unit), John
Vial, John Trout
Discussion on 5/23 centered on conditions necessary for the State
of Michigan to grant a permit to run the proposed PCB confirmation
burn in General Motor's boiler at Bay City. Technical discussion
covered the proposed sampling and analytical procedures.
May 24, 1979
Attendees: see attached list:
Again discussion was directed to the administrative procedures
necessary to conduct the study.
Summary:
The State, General Motors, and EPA are in general agreement that the
PCB program should be undertaken as soon as possible. However, the
State has reservations and wants them resolved prior to allowing the
PCB's to be burned. It was the opinion of the EPA representatives
that to go to another State would not speed-up the program as the PCB
issue is nationwide with most jurisdictions having the same concerns
and similar requirements. To move the program as expeditiously as
possible, the following was agreed upon by the State of Michigan,
General Motors, and EPA.
1. General Motors would resubmit their application for a permit
to burn PCB contaminated oil in their #1 boiler at Bay City,
Michigan.
2. U.S. EPA will assist General Motors with their permit ap-
plication.
re^]r^iH -,t. 3. G. M. will send EPA "old" permit package for review and update.
4. GCA will prepare the sampling and analysis plan as soon as
EPA Form 13IO-* (R.v. 3-76)
60
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possible (within two weeks). This will be included as part
of the permit application.
5. GCA will prepare an environmental impact evaluation that will
assist the State in determining if the program is a "Major
State Action" requiring an EIS. This will also be attached
to the permit application.
6. The permit application will be reviewed with the State prior
to official submittal to correct any perceived problems.
7. EPA/OTS or Region V. will submit a letter to the State of
Michigan requesting waiver of the 21 day public comment period
and subsequent Air Pollution Control Commission hearing. The
basis of the request will be minimal/non-existent impact.
Because of the State's administrative requirements it will not be pos-
sible to conduct the program in June. The earliest possible date would
be mid-July. However, a more realistic estimate would be late July or
early August.
RV/cj
61
-------
BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGE HAS
BEEN RETYPED FOR CLARIFICATION
5-24-79
8 a.m.
MTG WITH DNR, EPA, GCA
Exit 98B and 196 Canal Street
L.L. Johnson, Chevrolet C.O.W.A., 8-535-8961
W.W. Travers, Chevrolet - Bay City
D.R. Koenig, Chevrolet - Bay City
A.P. Garwick, Jr., Chevrolet - Bay City
W.J. Collinson, GM Environmental Activities Staff
G.E. Calhoun, Chevrolet C.O., 8-535-4619
R. Sobczynski, Chevrolet C.O., 8-535-8771
Jerry Avery, AQD, DNR, (517) 322-1333
John Vial, AQD, DNR
George Su, Ph.D., Air Quality Division, DNR
Ron Venezia, U.S. EPA, Research Triangle Park, NC (919) 541-2547
Gary Gettel, DNR-Enforcement Division, (517) 373-3503
Completed
1. From GM - A. Garwick to EPA - Ron Venezia, Copy of Permit
2. From GCA Work Plan - George Su - Prepare Sampling and Analysis Plan
Coord, with R. Sobczynski
3. Shipping directions to Ron Venezia.
4. Submit Revised Permit Application 3.
62
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CHEVROLET MOTOR DIVISION
General Motors Corporation
Bay City Plant
100 Fitzgerald Street
Bay City, Michigan 48706
May 29, 1979
Dr. Ronald A. Venezia
EPA/IERL
MD 62
Research Triangle Park, North Carolina 27711
Dear Dr. Venezia:
Please find enclosed a copy of Air Use Permit Application
No. 385-78, as submitted to the Air Quality Division of the
Michigan Department of Natural Resources, requesting approval
to burn reclaimed oils containing incidental concentrations of
PCB's in our No. 3 boiler. The application includes the follow-
ing items:
Cover letter to the Michigan Department of Natural
Resources (MDNR) from Chevrolet Motor Division
(Chevrolet)..
Application to the Michigan Air Pollution Control
Commission .
Application Instructions.
Permit Item Sheet.
November 16, 1977 letter to Chevrolet from MDNR
(3 pages).
Illustration No. 1 - Fuel Oil Flow Diaaram.
Attachment "A"
(2 pages)
- Response to Nov. 16, 1977 letter
Building Detail
Pollution Incident Prevention Plan
Attachment "B" -
Attachment "C" -
(20 pages).
Attachment "D" - HCL Calculations.
Drawing PE-B-160 sheet 268 - Boiler House Elevations
Drawing PE-H-22 - Plot Plan.
Drawing SA-884 - Boiler Setting Plan.
Drawing SA-888 - Boiler Auxiliaries.
Drawing SA-889 - Boiler Auxiliaries.
In addition, the following correspondence is included as a
supplement to the history of the application:
Page 1 of 2
63
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CHEVROLET MOTOR DIVISION
General Motors Corporation Bay City Plant
100 Fitzgerald Street
Bay City, Michigan 48706
May 10, 1978 Memo, MDNR
June 2, 1978 Letter to Chevrolet from MDNR
(2 pages).
June 20, 1978 Staff Activity Report, MDNR
(2 pages).
June 15, 1978 Telegram to MDNR from Chevrolet.
June 28, 1978 Letter to Chevrolet from MDNR.
Should you require additional information with regard to
the permit application or the proposed verification burn, please
contact myself (ext. 251) or Al Garwick (ext. 257) at (517)
894-4111.
Advance materials and/or test equipment may be shipped to the
following address:
Chevrolet Motor Division
Bay City Plant
100 Fitzgerald Street
Bay City, Michigan 48706
Attn: A. P. Garwick Jr.
Plant Engineering Department
XV >C jffrfaM
D. R. Koenig /7
Supt. - Maint.Cs Pit. Eng,
DRK:APG/dar
cc: L. L. Johnson, C.O.W.A.
File (2)
Page 2 of 2
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
not only the maximum pollutant concentration possible emitted but also assumes
the pollutant will be dispersed under the meteorological conditions that are
least favorable to its dilution.
Table 6 displays the pollutant source information used in various phases
of the modeling. These data were obtained from plot plans and reports supplied
by General Motors Corporation. Two emission conditions were selected for mo-
deling 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.
While it is difficult to determine the exact atmospheric conditions of
wind direction, wind speed, and stability that wi€l result in the maximum con-
centration for a given source, for elevated point sources, maximum concentrations
generally occur with unstable conditions. The test program being proposed will
Lake place in early August (mid-summer) when strong solar radiation could cause
the lower atmosphere to be unstable for a significant length of time. It is
impossible to predict the exact meteorological conditions during the test per-
iod but a very realistic estimate can be made based on historical data. From
past data published 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). Turner3 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 meteorologically "worst case" was then chosen as 8 hours of class B insta-
bility with southwest winds at 4.5 m/s.
Due to the low stack configuration of the building under test, the model-
ing uas approached from two viewpoints. First, PCB concentrations were predicted
for a normal transport of the plume, dispersing it under the worst case meteoro-
logical 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 aerodynamic wake of
the building and being dispersed into the small volume directly behind the build-
ing as illustrated in Figure 11. Again, both the no destruction and 99.9 per-
cent destruction cases were an.ilyzed.
65
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TABLE 6. SOURCE PARAMETERS FOR MODEL INPUT.
Fuel Rate
PCB Concentration in Fuel
Stack Height (above ground)
Stack Diameter
Stack Gas TepDeiature
Stack Gas Velocity
PCB Emission Rate
PCB Emission Rate
Stack Gas PCB Concentration
4 gal/min
50 ppjn by weight
18.3 meters
1.07 meters
430°K
7.48 m/s
1) No PCB Destruction 0.0107 grams/sec
2) 99.9% Destruction l.lxlQ-5 grams/sec
1) No PCB Destruction 1603 ug/m3
2) 99.9/o 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.
-------
\
XKETENTION PONDS
WASTE WATER
FACIUIT Y
Figure 11. Dispersal of plume in aerodynamic
wake of building.
67
-------
PCB concentration estimates for the. normal, plume approach were based on a
steady-state Gaussian plume model developed by Pasquill and Cifford 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 Briggs5 and
was estimated to be 26.1 meters. This plume rise added to the physical stack
height resulted in a final effective pjume height of -4-4,4 wpbeta rur a id mprt
(A.') m/s) wind. The resulting maximum short-term concentrafJ';n estima,.,.-. £/nlid
for 1-hr) occurred under stability clasy "A" with 2 m/s Winds. Howev.^M., , this
"A" stability condition Lould not last the 8 hours of test duration so computa-
tions 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 0.4981* for the 8 nour test period.
Table 7 presents the short term maximum and 8 hour mean concentrations for che
worst case normal plume dispersion case for both no destruction and 99.9 percent
destruction of PCB.
The estimated concentr.it ions for the wake dispersing plume were based on
the approach suggested by Smith'* 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 8.
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 thi estimate as conservative as
possible, it was assumed that the plume path was identical for all three 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 12 presents n graph developed by Murphy21 of dry gas-
eous velocities for a variety of ground covers. The equation solved for depo-
sition velocity x-;as:
Va = T, . ,,.
+ Vb + Vc
where Va = a momentum transfer term
Vb = a concentration gradient term
Vc = a surface (ground cover) term.
If it is assured 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 12 is approximately
1.4 cm/s.
Plume depletion fractions were computed by Markee5 for a plume under vary-
ing stability classes with a variety of deposition velocities. The most
68
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TABLE 7. MAXIMUM CONCENTMTIONS WHEN PLUME DISPERSED DOWNWIND -
WORST CASE METEOROLOGY.
Short-tenn 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 yg/m3
99.9% Destruction 3.8 * 10"1* yg/m
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 yg/m3
99.9% Destruction 8.4 * 1CT5 yg/m3
TABLE 8. WORST CASE MAXIMUM CONCENTRATIONS WHEN PLUME DISPERSED IN
BUILDING WAKE.
Short-term Maximum (1 hr., "A" Stability, 2 m/s wind speed).
No PCB Destruction 9.74 yg/m3
99.9% Destruction 9.7 * 10~3 yg/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 10~3 yg/m3
69
-------
10"
A PINF FOREST IN WET PALL OR WINTER
B CUT GRASS IN WET FALL OR WINTER
C GFiOWN GRASS IN HUMID SUMMER
D- OAK-HICKORY FOREST IN HUMID SUMMER
o>
>
10
-2
_L
J_
_L
6 8 10
WIND SPFEO AT 10m (m/s)
12
14
Figure 12. Deposition Velocity versus Wind Speed,
70
-------
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 9.
Note that 79 percent of the plume Is depleted by the downwind distance of
100 Km of 0.85 yg/m2 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 9) more deposition will occur with closer distances
to the stack.
HEALTH AND ENVIRONMENTAL EFFECTS BASED ON WORST CASE EXPOSURE
PCS 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 oi.cur 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 arc 4.36 yg/m3 (0.32 parts per billion
(ppb)) and 4.4 < 10~3 ug/m3 (3.2 x lO""4 ppb) , respectively (see Table 8).
TABLE 9. PCB TRANSFER/AREA
Plume
Sector
(Km)
0-1
1-5
5-10
10-50
50-100
I lur.ie
%
11
17
11
30
10
depletion
Grants
101.7
157.2
•101.7
277.35
92.5
Sector
area
(106i.i2)
.0108
a. 311
6.504
173.828
462.250
Deposition
(yg/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 hrs
of U'Stin;1, - No Destruction.
The average respiratory volume of air for adults is 30 in3 for 24 hours.7
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 indi-
vidual would be exposed to a total of 43.6 \ig 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 indicate 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
71
-------
exposed to a single does of PCB range from 2 to 11 g/kg. 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 efforts on the liver, the
gastro-intentinal track, and the central nervous system.6 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.9
We have calculated that an individual may be exposed to 130.8 yg 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 (A.CGIH) Threshold Limit Value (TLV) for
PCBs. TLVs describe .levels assumed to be safe based on evidence of both ~cute
and chronic toxic effects to humans, including carcinogenic effects, and on
studies of animal toxicity data which describe acute, chrjnic, and oncogonic
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 ACC1II TLV for PCBs is 37 ppb. Assuming an average respiratory
volume, this equates to ,:ii 8 hour exposure to a total of 50A. 1 yg PCB. Direct
comparison may he 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 .
-------
The figures in Table 9 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 particulate
matter to which PCBs are absorbed, or other potential transport mechanisms have
not been considered.
As listed in Table 9, 0.1 km from the point of release, PCB concentrations
on the ground level have been calculated to 946 yg/m 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. This is
approximately 76 liters/m . 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 DCBs
more effectively. Even in the worst case, however, less than 0.05 perct it of
the total Aroclor present was leached from the soil under the test conditions
and after 4 months of exposure.16 In addition, only the less-chlorinated,
more easily degradablc ibomers 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 approximately 0.2 percent of the total initially present.17'18
•
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.15 In relating final concentrations of toxic
substances in ambient freshwaters to the concentrations released in a^dilu-
tion on the order of 100,000 or more can be expected. Such dilutions9»13
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.9
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 is used for calculating che 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 fresh-
water criteria.
As Table 10 summarize.1;, even under worst possible conditions of no PCB
destruction during combustion, the potential environmental and health detriment
due to release of PCBs by this test program will be negligible.
73
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Table 10. Comparison of Health and Ecological PCB Standards to PCB
Levels Resulting From Wori,t Case Human and Environmental
Exposure.
PCB Level
From Air
Inspiration
In Water
(ng/1)
Total Human
Exposure
130.8
Workplace Standard 1512.3
Potential Croundwater
Levelt
Proposed EPA Level
Typical North American -
Freshwater Levels
0.00026
1.0
i 3
5-5009
Worst Case exposures based on three
8-hour periods of PCB trial destruction.
j.
'ACGIH TLV which is the maximum level
considered safe for 8-hour/day, 5-day
week continuous esposure.
•^Assuming 3 in. rain, 946 pg/m2 deposition
in the 0-1 Km sector and a minimum of
100,000 dilution factor after PCBs reach
groundwater.
74
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BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGE HAS BEEN
BEEN RETYPED FOR CLARIFICATION
Because of the toxicity of chlorinated dibenzofurans, some consideration
was given to their potential formation during the test program. Because of
the low concentration of PCBs used in the program, and the high destruction
efficiency expected, these by-products of incineration will not be formed in
any significant concentration from PCBs. In addition, these compounds are
photolabile, so it is unlikely that they could accumulate in dispersed
emissions resulting from the test.
75
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Inter-Organization
Environmental Activities Staff
General Motors Corporation
General Motors Technical Center
Warren, Michigan 48090
Date: June 12, 1979
Subject. June 11, 1979, Meeting Regarding Burning
of PCB's at Chevrolet-Bay City
From: . n ,.. ,
A. R. Fisher
Messrs. A. P. Garwick Chevrolet-Bay City
L. L. Johnson Chevrolet-Central Office
H. J. Snyder EPA Washington
R. A. Venezia EPA Raleigh
S. G. Zelenski GCA
On June 11, 1979, representatives from the EPA, GCA Corporation
and General Motors helped refine the GCA environmental report on
burning of PCB's at Chevrolet-Bay City. Also, a response to the
permit questionnaire prepared by the Michigan Department of Natural
Resources on November 16, 1977, for Chevrolet-Bay City was developed.
As a result of this meeting, it was decided that (1) the EPA Office
of Toxic Substances, Office of Chemical Control, would draft a
letter for subnrittal to EPA Region V in support of burning PCB's
at Chevrolet-Bay City, and (2) representatives from EPA and General
Motors would review the permit application and the GCA report by
the end of June with the Michigan Department of Natural Resources
prior to submitting the permit.
A. R. Fisher, Ph.D.
Plant Environment
jl
cc: G. L. Avery, Michigan DNR
J. P. Chu
W. R. Johnson
N. C. Kachman
R. J. Phillips
76
-------
GCA/TECHNOLOGY DIVISION
June 15, 1979
Dr. Ron Venezia
U.S. E.P.A.
Chemical Processing Section
IERL
Research Triangle Park, NC 27709
Dear Ron:
After our last meeting in Washington I reevaluated the hours
needed to complete the revised task. An additional 150 hours will be
sufficient for completion. Extra travel costs of $800 will be required.
The revision of the test plan, especially the monitoring information
required of G.M, is more extensive than I had anticipated and will be
available later in the week.
Steven A. Zelenski, PhD,
Head, Organic Analytical Section
SZ/gg
77
BURLINGTON ROAD, BEDFORD, MASSACHUSETTS 01730 / PHONE: 617-275-9000
-------
GCA/TECHNOLOGY DIVISION
BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGE HAS BEEN
RETYPED FOR CLARIFICATION
June 22, 1979
Dr. Ron Venezia
U.S. EPA
Chemical Processing Section
IERL
Research Triangle Park, NC
Dear Ron;
Enclosed are 12 copies of the final draft of our test
plan. I have sent three copies to Al Garwick with instructions
that they are not to be used until he receives final approval
for their release from you. I have also forwarded three copies
to Hal Synder for his review.
Best Regards,
Steven G. Zelenski, Ph.D.
SZ/gg
Enclosures
BURLINGTON ROAD, BEDFORD, MASSACHUSETTS 0)730 / PHONE: 617-275-9000
78
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Technology Division
GCA :.
June 22, 1979
Mr. Ai Garwick
Chevrolet Motor Division
100 Fitzgerald Street
Bay City, MI 48706
Dear Al;
Enclosed are three copies of the final draft of our
test plan for the PCB trial destruction. These are final
drafts and are not to be used until you receive final
approval for their release from Dr. Venezia. I have sent
them now to facilitate your schedule.
Sincerely,
Steven G. Zelenski, Ph.D.
Head, Organic Analytical Section
SZ/gg
Enclosures
cc: Dr. R. Venezia
79
-------
Technology Division
GCA
Jxme 22, 1979
Dr. Leo Weitztaan
U.S. E.P.A.
26 West St. Clair Street
Ci\\cinnatti, OH 45263
Dr. UeJtzman:
Enclosed is CCA/Technology's "Test Plan for the Evaluation
of PBC Destruction Efficiency in Industrial Boilers." Thi3
document is a final draft and has not been anproved for release
by Dr. Venezia.
If I can offer any assistance in your project, please let
me know.
Sincerely,
Steven G. Zelenski, Ph.D.
Head, Organic Analytical Section
SZ/?g
Enclosure
cc: Dr. R. Venezia
80
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CHEVROLET MC , ^,, . DIVJ
General Motors Corporation Bay C
IOOriLTfl.r.1
B*y City.
July 6, 1979
Control Action Division
Environmental Protection Agency
c/o Mr. H. J. Snyder
6042 Camelback Lane
Columbia, Maryland 20145
Dear Hal:
Please find attached one (1) copy of the air use permit
application for burning reclaim oil containing PCUs in
our No. 3 boiler. This permit application was submitted
to, and received by the Permit Section of the Air Quality
Division, Michigan Department of Natural Resources on
Friday, June 29, 1979.
One (1) copy of the permit application has also been
sent to Region V, Environmental Protection Agency at the
address below, as per your telephone request of July 5,
1979. Should either you or Karl have questions regarding
the permit application, please contact me at (517) 894-
4111 cxt. 257.
Alvin P. Garwick, J-c.
Senior Mechanical Engineer
APG/c-ig
cc: Region V
Environmental Protection Agency
c/o Mr. Karl Urcmcr
989 Bosworth
Barrington, Illinois 60010
81
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BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGE HAS BEEN
RETYPED FOR CLARIFICATION
Don Koenig - Please Note and return. 8/6/79
JULY 23, 1979
Dr. Howard A. Tanner, Director
Department of Natural Resources
State of Michigan
Stevens T. Mason Building
Box 30028
Lansing, Michigan 48909
Dear Mr. Tanner:
On June 29, 1979, the Chevrolet Division of General Motors Corporation
submitted an Air Quality permit application to the Air Quality Division
requesting approval to conduct tests at their Bay City, Michigan plant
involving low concentration PCB waste oils.
The Environmental Protection Agency has been working closely with General
Motors on this project and I wish to take this opportunity to appraise you
of our objectives in pursuing this study at Bay City and seek your support.
When the Agency was assessing the possible alternatives for modifying the EPA
to PCB Disposal and Marking regulations to include additional requirements for
the disposal of low concentration PCB wastes, it became apparent that we
would have to include additional disposal alternatives in the new rules in
order to provide sufficient capacity for this increased waste volume. The
most viable option was the use of high efficiency boilers for burning waste
mineral oil dielectric fluid and other waste oils containing 500 ppm or
less of PCBs.
The combustion data available to EPA boiler experts clearly indicated that
properly operating high efficiency boilers could destroy PCBs when they
are fed to the boiler in relatively low concentrations. We want to provide
additional confirmation of this technique by conducting tests at an industrial-
type high efficiency boiler.
EPA's Office of Research and Development and its contractor, GCA Corporation
of Bedford, Massachusetts, would conduct the sampling and provide the
analytical chemistry support of the test, and GM's Bay City personnel would
be responsible for operating the boiler and providing the necessary physical
facilities.
82
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BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGE HAS BEEN
RETYPED FOR CLARIFICATION
The tests would involve three runs of 250 gallons of industrial waste oil
containing 500 ppm PCBs with the waste oil comprising only 10 percent of
the total fuel to the boilers. A fourth test of the waste oil without PCBs
would be run as a control. We expect at least 99.9 percent destruction of
the PCBs.
We have included an environmental analysis of the probable impact of this
test on the surroundings area, and, even for a worst case condition, we
believe that the impact would be minimal.
In order to provide additional information to prospective high efficiency
boiler users as soon as possible, we want to move expeditiously in con-
ducting these tests. In order to meet our timetable for these objectives,
I would like to request that you determine that the decision on the test
permit application is not a "Major State Action" and thereby preclude the
requirement for a State environmental impact statement.
If General Motors is interested in pursuing this process on a long-term
basis after the tests are completed and the data is analyzed, then public
comment and a hearing might be more useful.
EPA staff members have been working closely with Gerald Avery and George Su
of your Department on this project, and we appreciate their time and effort.
The EPA project personnel hope to be able to meet with your air quality staff
in the middle of July to finalize the plans for the project. Your support
for this undertaking would be greatly appreciated.
Sincerely yours,
/S/ Original Signed by John McGuire
John McGuire
Regional Administrator
83
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7-24-79
Name
Paul Shutt
John Vail
Al Garwick, Jr.
L.L. Johnson
Y.J. Kim
Phil Synder
Dave Sanchez
Ron Venezia
Anthony R. Fisher
Steven G. Zelenski
George Su
CHEVROLET-BAY CITY
PCB MEETING
Group
DNR, Jerry Avery's Supervisor, Supervisor of
Engineering
DNR, Air Quality, Permits
Chevrolet-Bay City
Chevrolet Central Office, Warren, Michigan
EPA, Region V, (312) 253-2197, Chicago
EPA, Washington, D.C.
EPA, IERL, Research Triangle Park, N.C.
EPA, IERL, Research Triangle Park, N.C.
General Motors Environmental Staff
GCA/Technology Division
DNR - Air Quality Division
84
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BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGE HAS BEEN
RETYPED FOR CLARIFICATION
July 27, 1979
Mr. Alvin P. Garwick, Jr.
Chevrolet Motor Division
100 Fitzgerald Street
Bay City, Michigan 48706
Dear Mr. Garwick:
As you have requested during the meeting on your proposal for test
burning of PCB-contaminated mineral oil, I am enclosing the vapor
pressure data and related materials you could use in estimating the
PCB emissions from storage tanks.
If there is anything else I can do for you, please feel free to
drop me a line, or call me at (312) 353-2197.
Sincerely,
Y.J. Kim, Chemical Engineer
WASTE MANAGEMENT BRANCH (5AHWM)
Enclosures:
cc: S.G. Zelenski
GCA Corporation
Gerald Avery
Michigan DNR
85
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BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGES HAS BEEN
RETYPED FOR CLARIFICATION
TO:
FROM:
SUBJECT:
Gerald F. Regan, Chief, Air
Surveillance Branch
DATE: MARCH 5. 1976
Technical Advisor, Special Projects Section
Air Surveillance Branch
Calculation of PCB Air Emissions from Storage and
Dispensing Operations at the Krummrich Plant of
Monsanto
Potential air emissions from the storage and dispensing of PCB were
calculated based on information supplied by Monsanto. The results
of these calculations are:
Storage tanks for virgin product - 597.4 kg/year
Product loading - 0.0184 kg/year
Storage and handling waste aroclors - 0.00066 kg/year
R. Edwin Zylstra
Attachment (Calculations)
For Vapor Pressure of Mineral Oil I believe you could use No. 2
Fuel Oil data (abt. 150°F Flash, Distillate) which is about
0.5 mmHg at 60°F. (MW - 200) Both Figure 5-77 and Table 8-2
gives similar values.
86
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BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGE HAS BEEN
RETYPED FOR CLARIFICATION
July 27, 1979
Dr. George C. Su
Supervisor, Technical Service Section
Air Quality Division
Michigan Dept. of Natural Resources
P.O. Box 30028
Lansing, Michigan 48909
Dear George:
I am enclosing the summary of data on the PCB levels in ambient air which
were abstracted from "Directors Report to the Environmental Assessment Board
Regarding Burning of PCBs at St. Lawrence Cement, Mississauga," dated
December, 1978.
If there is anything else on PCBs that I can help you with, please feel free
to call me at (312) 353-2197.
Sincerely,
Y.J. Kim, Chemical Engineer
Waste Management Branch (5AHWM)
Enclosures
cc: A.P. Garwick, Jr. - Chevrolet Motor Div.
S. G. Zelenski - GCA Corporation
87
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BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGE HAS BEEN
RETYPED FOR CLARIFICATION
SUMMARY
.2 PCB's in Ambient Air
LOCATION
Sheridan Park, Ont.
Hamilton, Ont.
Shericf.an Park
Hamilton, Ont.
Bermuda
Between Bermuda
& Mainland
Univ. of R.I. Campus
Providence, R.I.
(Urban Location)
Atlantic, 2000 km off
Off Mass Coast
PCB
ANALYSIS
12 ng/m3
100 ng/m3
DATE OF
SAMPLE
1972
1972
1 ng/m3
2 8 ng.m3
0.5 ng/m3
(0.3 0.6 ng)
1 ng/m3
(0.7 1.6 ng)
4 ng/m3
(2.0 6.0 ng)
9 ng/m3
(One Sample)
0.05 ng/m3
5.0 ng/m3
1974-
thru
1975
1973
1973
1973
1973
1973
1973
REMARKS
Gas Chromatography
Electron Capture
Detector Method
(B-C/ECD)
Univ. of R.I.
Woods Hole
Oceanc graphic
Institute, Mass.
88
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BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGE HAS BEEN
RETYPED FOR CLARIFICATION
SUMMARY
.2 PCB's in Ambient Air (Cont'd)
LOCATION
Fort Collins,
Colorado
Miami, Fla
Lafayette, Ind.
Jackson, Miss.
Harrisburg, Penn.
Gainsville, Fla.
PCB Burial Site,
New Bedford, Mass
Upwind
41 " On Site
Downwind
PCB Filling PLT. Downwind
" " Upwind
" " Downwind
Hamilton
Peterborough
London
Toronto
Sarinia
Windsor
Toronto, Downtown
Orangeville, Ont.
PCB
ANALYSIS
2 15 ng/m3
1 37 ng/m3
2-14 ng/m3
1 17 "
2 18 "
6 20 "
1300
9
21
13
490
6
19
Avg 10 (3-29) '
Avg 5 (2-10) '
Avg 5 (1-10) '
Avg 4 (2-5) '
(one) 4 '
Avg 4 (1-6) '
Avg 31 (18-67)
Avg 7 (3-11)
DATE OF
SAMPLE
1975-
1976
1977/1978
6/77
1/78
it
REMARKS
U.S. EPA Data
7/1976
8/1978
Gov't of Canada
Avg. PCB Cone, of Innocent, Ambient Air: 0.5 - 100 ng/m3.
89
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BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGE HAS BEEN
RETYPED FOR CLARIFICATION
a) No significant surface water contamination
is expected from the St. Lawrence Cement site
because of precautions taken there, but should
it occur, the municipal water supply would not
be contaminated directly. Direct human exposure
by this route would be negligible.
b) Contaminated soils, produced by spill or leakage,
for example, will be removed to a secure
disposal site, so that again, no direct human
exposure to this material would occur.
c) Lake and stream sediments and sewage sludges
lead to no direct human exposure in Mississauga.
d) Evaporation of PCBs from spilled material,
soils, sediments, sludges and water leads
to direct human exposure through ambient
air, so that measured concentrations in
this medium represent contributions to direct
human exposure from all sources.
2,2.2 Summary of Reported Ambient Air Data -
Ontario and Elsewhere
Experimental data for the assessment of airborne
PCB are very limited. Since 1970, the Ministry of the En-
vironment has initiated or performed several studies on PCB.
The first study was funded by research grants to Ontario
Research Foundation between 1971 and 1975 (4,5). Labora-
tory development work and subsequent measurements of air-
borne PCB in Hamilton, Toronoto, and Mississauga (Sheridan
Park) were the first attempt anywhere in the world to
90
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BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGE HAS BEEN
RETYPED FOR CLARIFICATION
measure PCB in ambient air. Only a few samples were collected and
analyzed by a gas chromatography-electron capture detector method
(GC/ECD). Reported results in 1972 ranged from about 12 ng m~3* at
Sheridan Park to about 100 ng m~3 of Aroclor at a site in Hamilton.
The results reported for 1974/1975 were about 1 ng m~3 at Sheridan
Park, 2 to 8 ng m~3 at Hamilton and 1 to 3 ng m~3 at Toronto.
A research group from the University of Rhode Island (6)
report PCB concentrations in 1973 of about 0.5 ng m~3 (with a range
of 0.3 to 0.6 ng m~3) for Bermuda, about 1 ng m~3 (range: 0.7 to
1.6 ng m~3) over the North Atlantic Ocean between Bermuda and the
mainland, about 4 ng m~3 (range 2 to 6 ng m~3) at the University,
and one value of 9 ng m~3 in urban Providence, Rhode Island.
Another research group from Woods Hole Oceanographic
Institute, Massachusetts (7) found PCB levels, also during 1973, as
low as 0.05 ng m~3 in air over the Atlantic Ocean, 2000 km from the
North American mainland, ranging to about 5 ng m~3 just off the
Massachusetts coast. The concentrations decreased exponentially with
distance from the mainland.
The point of quoting these results is to indicate that
measurable quantities of PCBs in the several nanogram per cubic
meter range have been reported for areas with no local industrial
sources.
*FOOTNOTE: ng m~3 is used throughout the Report to designate the
concentration of chemicals in air. It is an abbreviation
for "nanograms per cubic meter." This unit is 0.000000001
grams of substance in each cubic meter of air. Once micro-
gram per cubic meter (yg m~3) is one thousand times
greater than 1 ng m~3.
91
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BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGE HAS BEEN
RETYPED FOR CLARIFICATION
In a continuing survey for pesticides and PCB at selected
sites in the U.S.A., preliminary unpublished results indicated the
following range of PCB daily average concentrations at sites away
from known industrial sources of PCB in 1975/1976:
Fort Collins, Colorado 2 to 15 ng m~3
Miami, Florida 1 to 37 ng nr3
Lafayette, Indiana 2 to 14 ng m~3
Jackson, Mississippi 1 to 17 ng m~3
Harrisburg, Pennsylvania 2 to 8 ng m~3
A more recent study by the U.S. Environmental Protection Agency
(EPA) during 1977/78 found concentrations (collected during
periods from 30 minutes to 12 hours) in air at Gainesville,
Florida, in the range of about 6 to 20 ng m~3 PCB (8). The same
research team made measurements in June, 1977 at a landfill site
near New Bedford, Massachusetts, where previously some 22,000 Kg
of PCB had been disposed of. They found levels up to 1300 ng m~3
of PCB. At the same site in January, 1978, concentrations of PCB
upwind, at the site, and downwind of the site, were about 9, 21,
and 13 ng m~3, respectively. Concentrations upwind of two users
of PCBs (capacitor filling) were 6 and 19 ng m~3, and downwind
of one user as high as 490 ng m .
During the summer of 1976, the Ministry conducted a
province-wide survey oriented to research and method develop-
ment for sampling and analysis of PCBs (9). The concentrations
of PCB for the cities included in the survey were (24-hour
averages):
92
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BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGE HAS BEEN
RETYPED FOR CLARIFICATION
Hamilton 3 to 29 ng m~3; average 10 ng m~3
Peterborough 2 to 10 ng m~3; average 5 ng m~3
London 1 to 10 ng m~3; average 5 ng m~3
Toronto 2 to 5 ng m ; average 4 ng m~3
Sarnia 4 ng m~3 (only 1 sample)
Windsor 1 to 6 ng m~3; average 4 ng m~3
A very recent study by the Ministry during August,
1978, at 880 Bay Street, in downtown Toronto and at a semi-
rural site near Orangeville gave the following results
(24-hour averages):
880 Bay Street 18 to 67 ng m~3; average 31 ng m~3
Orangeville 3 to 11 ng m~3; average 7 ng m~3
Each of the above surveys or studies was of a research
nature and produced a very limited set of data, but the aggregate
of all of these studies provides a reasonable number of typical
concentrations of airborne PCBs at a variety of sites with which
to compare the measured concentrations in Mississauga (Section 4.2).
2.2.3 PCS Inventories in Ontario
According to statistics compiled by Environment Canada,
and provided by Environmental Protection Service, Ontario Region (10),
current inventories of PCB in Ontario as of September, 1978, may
be summarized as follows:
Quantity
in Kg
Quantity
in pounds
Volume in
gallons
PCB in Use
8,565,185
18,882,806
1,258,853
PCB in Storage
258,643
570,204
38,013
In Storage
for Disposal
203,023
447,584
29,839
93
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BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGE HAS BEEN
RETYPED FOR CLARIFICATION
Clarence Buckley of Monsanto estimated that storage and loading operations
at the plant would displace the following volume of headspace gases:
1. Storage tanks 635,000 ft3
2. Loading 460,000 ft3
Calculation of emissions:
From Fig. 2.2 from the Draft Mitre report the vapor pressure of Aroclor 1242
is 3 mm Hg at 100°C and 10""* at 21°C. The aroclors are stored at 100°C.
It may be assumed that the temp, in the tanks being loaded would be
approximately 70°F (21°C).
From Dolton's law of partial pressure:
Px
Bx = - — ; — where Bx = proportion by volume of a gas component
1: mix •
Px = partial pressure of gas component and
B mix. = absolute pressure of gas mixture.
Bx = -- = .- or 3900 ppm at 100° c
/oU 1
To change ppm to mg/M3 use the following formula:
,.,3 mol. wt.
me/M = ppm x — : - ; - ; -
6 rr molecular volume
mol. wt. = 261
molecular volume = 30.62 liters/mol. at 100°C
o/: -t
mg/M3 = 3900 x -^^ = 33242
Emissions from storage tanks :
Emissions kg/year = Vol. of gas displaced/year x concentration of PCB
Kg/yr = 635000 ft3 x 0.0283 p- 33242 x
Kg /year = 597.4
Emissions from loading operations
Bx = • - !-3 x 10~7 or °-13 ppm
mp/M3 = 0.13 x 2Q4 = 1.41 mg/M3
94
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BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGE HAS BEEN
RETYPED FOR CLARIFICATION
Emissions:
Kg/yr = 460,000 x 0.0283 x 1.41 x ^^
Kg/yr = 0.0184
Emissions from handling of waste aroclors:
Total waste material received into plant as reported by Monsanto for
9 months of 1975 - 1,431,000 Ibs. Assume that all this material is
received and stored at 70°F and that it displaced an equal volume of
tank headspace gas at 70°F.
Volume of produce = 1,431,000 Ibs x - x 3-785
xio"3"
= 471 M3
M
The concentration would be the same as in the loading operation that
is 1.41 mg/M .
Emissions:
Kg/yr = 471 M3 x 1.4 mg/M3 x -^b^
Kg/yr = 0.00066
95
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BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGE HAS BEEN
RETYPED FOR CLARIFICATION
Table 1.3.2-1
Solubility, Vapor Pressure and Halflife for
Vaporization from Water of Selected Aroclors at 25°C
PCB Type
Solubility
(mg/1)
Vapor pressure
(mm Hg)
Theoretical halflife
for vaporization
from 1 m water column
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260
0.24
5.4 x 10
_2
-2
1.2 x 10
2.7 x 10~3
4.06 x 10
4.94 x 10
7.71 x 10
4.05 x 10
,-"*
-5
,-5
5.96 hr
58.3 min
1.2 min
28.8 min
96
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CHEVROLET MOTOR DIVISION
General Motors Corporation Bay City Plant
100 Fitzgerald Street
Bay City, Michigan 40706
July 27, 1979
Air Quality Division
Michigan Dept. of Natural Resources
P. 0. Box 30028
Lansing, Michigan 48909
Attn: John Vial
This letter is intended to confirm our telephone conversation of July 25,
1979 regarding additional information required for air use permit applica-
tion 484-79 (burning reclaim oils containing PCB's) and to present that
information to participants of the July 24, 1979 meeting in Lansing.
I have indicated below the name of the individual(s) who will supply the
required information, and ask them (with this letter) to provide that
information directly to you, with a copy to me for our permit application
file.
The additional information required is as follows:
1. The measuring accuracy of the carbon monoxide and excess oxygen
monitors and of the PCB sampling train/quantification process for
the verification burn will be provided by Dr. Steve Zelenski.
2. Ambient levels of PCB's in various cities will be provided by Mr.
Y. J. Kim. PCB exposure limits will be provided by Dr. Zelenski
and Mr. Hal Snyder. This information will be used for comparison
with the expected concentrations from the verification burn.
3. PCB emissions from the various storage tanks will be provided by
Mr. Al Garwick from sample calculations provided by Mr. Kim.
4. The measuring accuracy of carbon monoxide and excess oxygen
monitors which might be installed for permanent monitoring of
reclaim oil burning will be provided by Mr. Garwick (and any
others who cae/assist).
5. The location of all existing and proposed check valves for the reclaim
oil system will be provided by Mr. Garwick.
97
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Mr. John Vial
Page 2
July 27, 1979
In addition, page 4 of Attachment "A" will be revised to correct the
technical errors in item No. 17, which you and I have discussed.
Should you or any of the others require additional information or
assistance, please contact me at (517) 894-4111, Ext. 257.
Alvin P. Garwick, Jr.
Sr. Mech. Engr.
cc: Gerry Avery (517) 322-1333
' Tony Fisher (313) 575-ftg±J;
• Larry Johnson (313) 575-8961
'Y. J. Kim (312) 353-2197
Dave Sanchez (919) 541-23§G_
Paul Shutt (517) 322-1333
Hal Snyder (202) 755-1188
George Su (517) 322-44^3-
-Ron Venezia (919) 541-2547
Steve Zelenski (617) 275-9000
98
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GCA
Technology Division
GCA
BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGE HAS BEEN RETYPED FOR CLARIFICATION
17 August 1979
Air Quality Division
Michigan Department of Natural Resources
P.O. Box 30028
Lansing, Michigan
Attention: Mr. John Vial
Gentlemen:
This letter provides certain data requested of GCA/Technology
Division by you or George Su at the July 24, 1979 meeting in
Lansing. Specifically, the enclosures include:
1) the specifications relative to the operation
of the continuous monitors,
2) the collection efficiencies for several PCB
isomers on three different adsorbents including
the Florisil which will be used at the test,
3) a brief discussion of our approach to
utilizing a field spike to provide constant
monitoring of the efficiency of both the
sampling and analysis procedures, and
4) further discussion of the potential health
effects due to the trial destruction burn.
If you need any other information, please contact me.
Sincerely,
SGZ/jpm
cc: D. Sanchez
H. Snyder
G. Avery
A. Garwick
K.T. McGregor
Encls (4)
Steven G. Zelenski, Ph.D.
Head, Organic Analytical Laboratory
G. Su
99
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Technology Division
6 September 1979
Mr. John Vial
904 Thomas L. Parkway West
Lansing, Michigan
Dear John:
Enclosed is the information I indicated I would send to
you concerning the OSHA standards. I hope this helps to
clarify any remaining questions.
If 1 can be of further assistance, please do not hesitate
to call.
Sincerely,
Steven G. Zelenski, Ph.D.
Head, Organic Analytical Laboratories
Sf.Z/ jpm
Encls (2)
100
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Enclosure 1:
PCS Regulations:
Under the provisions of CFR Title 29, Chapter XVII,
Section 1910.1000 of Subpart 2 (July 17, 1979), the OSHA
40 hour/week limit for Aroclor 1242 is 1 mg/m-* and for Aroclor
1254, it is 0.5 mg/m^.
In September, 1977, NIOSH recommended a time-weighted
average for all PCBs of 1.0 Mg/nr*. However, the OSHA
standard has not been changed.
101
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Enclosure 2:
Time-averaged PCS Concentration From 2-Minute Release
To make the estimate as realistic as possible, the change of
meterology along with the long averaging time (10 hour average)
must be allowed. Therefore, the problem will be approached as
such: assume a 2-minute undestroyed PCB release at 1300 hours
during the test with the following 10 hours meterology as listed in
Table 1. After this concentrated 2-minute release, the PCB
emissions drop to an assumed background concentration in the fuel
oil (1 ppm or 1/50 of the concentration in the PCB oil).
The resulting concentrations by minute of the 10 hours is
presented in Table 2, assuming it takes 1 minute for the maximum
ambient concentration to be^reached, and 1 minute for it to decline
to the low background fuel pil concentration. This assumed back-
ground oil concentration is then affected by the following 10 hours
of meterology discussed above.
Table 1. Representative 10-Hour Meterology
Hour
1300-1400
1400-1500
1500-1600
1600-1700
1700-1800
1800-1900
1900-2000
2000-2100
2100-1100
2200-2300
Stability Class
A
A
B
B
C
C
D
D
D
D
Wind Speed (m/s)
2
2
3
3
4
4
4.5
4.5
4.5
4.5
102
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Table 2. Average Minute Concentrations of PCB After
2-Minute Release
Duration In
Minutes
1
"2
1
56
60
120
120
240
600 Minutes
Concentration
3
4.87
9.74
4.87
0.194
0.194
0.128
0.096
0.086
(10 Hours)
Comments
Increasing to Peak
Peak - 2 Minutes
Decreasing to Normal
Oil Level ,£$•
Rest of 1300-1400 Hours
1400-1500 Hours
1500-1700 Hours
1700-1900 Hours
1900-2300 Hours
s/V
103
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The time-average concentration for a 10-hour period
would then be 0.165 yg/m^. This is significantly less than
>-.he 1.0 yg/m3 10-hour NIOSH recommendation for occur.itioaal
•iXpc. sure, and clearly less than the present OSHA regulation
oi 0.5 to 1 mg/nH. The average concentration tor f.ho 'irsr
hour after tho release would bo 0.67 ]:,;/m .
104
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GCA TECHNOLOGY DIVISION
1(1. A. Engelman DATT : 14 September 1979
f - /
f'kfiM: S. G. Zeler.ski N ','
> \
5)ijf if.t.T: Supplement To Memo Of 10 September 1979 (1-614-043)
Additional manhours are required to meet the information needs
of the State of Michigan, Oeparf.rient of Natural Resources, before
rhev can process a permit application from GM for a trial do struct ion
burn of TCBs. Moro de.tnils concert! ing tha sampling methodology and
projected health effc'cts as well.as refinements in the deposition modeling
and projected effects have been supplied. Several additional meetings
lave been held in Lansing than expected, and one more meeting in
Lansing is anticipated.
In addition, more lours will be required to reassemble, clean and
test the sampling train and continuous monitoring equipment before the
projected sampling trip in October. This effort will be required to
insure that the lapse of time between the original preparation and the
projected sampling period does not affect the integrity of the sampling
equ ipment.
1pm
105
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CHEVROLET MOrOR DIVISION
General Motors Corporation
Bay City Pl«r
100 Flugercld Slrse
B«y City, Michigan 43TO
Septerrber 18, 1979
United States of America
Environmental Protection Agency
Region V
230 South Dearborn Street
Chicago, Illinois 60604
Attn: Mr. Karl L. Klepitsch, Jr.
On June 29, 1979, the Bay City Plant, Chevrolet Motor Division,
General Motors Corporation submitted an air use permit application to
the Air Quality Division of the Michigan Department of Natural Resources
for burning reclaim oil containing PCD concentrations of 500 ppm or less
in an existing steam boiler at this location. Complete copies of that
permit application were submitted to Mr. H. J. Snyder of E.P.A. Control
Action Division and Mr. Karl Bremer of E.P.A. Region V on July 6, 1979
(a copy of the letter of transmittal is attached).
Conditional upon approval of the permit application by the Michigan
Air Pollution Control Conmission at their October 16, 1979 meeting, the
verification burns described in the permit application will be conducted
during the week of October 22, 1979. Pursuant to the notification require-
irents of 40 CFR port 761 for disposal of liquid wastes with 50 to 500 ppm PCB,
approval of the Region V Administrator is required for these verification
burns. Please consider this letter and the information previously sub-
mitted to Mr. Brener as our request for approval.
Should further information be required, please contact this office at
(517) 894-4111 extension 257.
DRK:APG/dar
cc: Dave Sanchez
L. L. Johnson C.O.W.A.
File
D. R. Koenig
Supt. - Maint. & Pit
106
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NOTICE OP AIR POLLUTION COMMENT PERIOD AMD PUBLIC HEARING
Notice Is hereby given that the staff of the Michigan Air Pollution Control Commission
will hold a public comment period until October 15, 1979, and a public hearing on October
16, 1979, to afford all Interested citizens the opportunity to comment on the Commission
staff's proposed conditional approval of GENERAL MOTORS CORPORATION, CHEVROLET
MOTOR DIVISION'S Permit to Install equipment to burn oil containing polychlorinated
biphenyls (PCB) In an existing oil-fired boiler proposed for location at 100 Fitzgerald
Street in Bay City, Michigan.
Copies of the Commission staff's analysis and proposed permit conditions are available
for Inspection at the following locations:
BAY CITYi Bay County Health Department, Washington Park Plaza, 301
Second Street.
SAGINAWi Air Quality Division, Department of Natural Resources, Washburn
Building, Room 202, 1230 South Washington.
LANSING: Air Quality Division, Department of Natural Resources, State
Government Secondary Complex, General Office Building, 3rd
Floor, 7150 Harris Drive.
All persons are encouraged to present their written views on the proposed permit action.
Written comments should be sent to the Department of Natural Resources, Air Quality
Division, P.O. Box 30028, Lansing, Michigan, 48909, to the attention of the Chief of
the Permit Unit. All statements received by Monday, October 15, 1979, will be entered
into the permit record.
The public hearing will be held during the regular monthly meeting of the Michigan Air
Pollution Control Commission on Tuesday, October 16, 1979, beginning at 9tOO a.m.,
at Holly's at the Inn, 3450 Hoyt Street in Muskegon Heights, Michigan.
MICHIGAN AIR POLLUTION CONTROL COMMISSION
Delbert Rector, Executive Secretary
9/19/79
107
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4.
PROPOSED SUPPLEMENT TO PERMIT No. 484-79
Chevrolet Motor Division, GMC
Bay City, Michigan
Grafted September 20, 1979
GENERAL CONDITIONS
DRAFT
1. Applicant shall demonstrate compliance with all Commission rules and with all
specific conditions of this permit prior to issuance of the Permit to Operate.
2. The restrictions and conditions of this Permit to Install shall apply to any
person or legal entity which now or shall hereafter own or operate the facili-
ties for which this Permit to Install 1s Issued. The Applicant shall Immediately
notify the Comn1ss1on of such change in ownership or principal operator status
of this facility.
3. Act No. 53 - Applicant shall notify any public utility of any excavation, tunr.el-
1ng and discharging of explosives or demolition of buildings which may affect
said utility's facilities in accordance with Act No. 53 of the Public Acts of
1974, being Sections 460.701 to 460.718 of the Michigan Compiled Laws and comply
with each of the requirements of that Act.
Rule 21(4) - Trial operation of the equipment Is permitted until the Commission
acts upon the Permit to Operate.
5. Rule 29(2) - Not more than 30 days after completion of the installation, the
Applicant shall apply, 1n writing, to the Commission for a Permit to Operate.
Completion of the Installation is deemed to occur not later than commencement
of a trial operation pursuant to Rule 21(4). Written application should be
sent to: Chief, Permit Unit, Air Quality Division, Department of Natural Re-
sources, P.O. Box 30028, Lansing, Michigan 48909.
6. Rule 29(3b) - Operation of this facility shall not Interfere with the attain-
ment or maintenance of the air quality standard for any air contaminant.
7. Rule 29(3d) - Operation of this facility shall not result in substantial deter-
ioration of air quality.
8. Rule 46 - Operation of this facility shall not result in the emission of an air
contaminant which causes or will cause detriment to the safety, health, welfare
or comfort of any person or which causes or will cause damage to property or
business.
9. Rule 21 - Applicant shall not reconstruct, alter, modify, expand or relocate
this facility unless plans, specifications and an application for a Permit to
Install are submitted to and approved by the Commission.
10. Approval of this permit does not obviate the necessity of obtaining such permits
or approvals from other units of government as required by law.
11. Notification of any malfunction of process or control equipment resulting 1n
emissions in violation of the Commission rules or of any permit conditions
should be made to the District Engineer. Such notice should be made as soon
as possible but not later than 9:00 A.M. of the next working day. The notice
shall Include a program of corrective action and shall be confirmed 1n writing.
108
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PROPOSED SUPPLEMENT DRAFTED September 20, 1979
Chevrolet Motor Division, GMC
Permit No. 484-79
Page 2
DRAFT
SPECIAL CONDITIONS
12. The applicant shall not incinerate PCS contaminated oil in boiler
No. 3 except as outlined in the verification test burn procedures,
unless written approval has been received by the Chief, Air Quality
Division. Approval to burn PCB contaminated oil on an ongoing
basis is contingent upon the following:
a. Verification that the destruction efficiency of PCB is greater
than 99.9%;
b. The submission of specifications for acceptable combustion
monitoring instrumentation; and
c. Upon request, the submission of an acceptable environmental
assessment report.
13. The applicant shall conduct the test burn in strict accordance
with the submitted test procedure. Any variance from the submitted
test procedure shall not be implemented without the approval of
the Air Quality Division.
14. The applicant shall verify the combustion efficiency of the boiler
under the anticipated test conditions. The test program shall
not be initiated unless it has been demonstrated that carbon monoxide
levels do not exceed 50 ppm at the proposed test conditions with
at least 3% excess oxygen.
15. The applicant shall operate this boiler under steady state or base
load conditions while burning PCB contaminated oil. Fuel oil flow
rate and air flow rate shall be maintained at constant levels.
In no event shall the furnace be operated at less than 25* of full
rated capacity while burning PCB contaminated oil .
16. The applicant shall equip the boiler with instrumentation and control
capable of continuously monitoring excess oxygen, carbon dioxide,
and carbon monoxide concentrations and opacity levels in the boiler
flue gases prior to the verification test burn.
17. The applicant shall not incinerate PCB oil in the boiler unless
all of the following conditions are met:
a. The contaminated mineral oil (maximum PCB concentration of
500 ppm) shall be no more than 1055 of the total fuel feed rate.
b. The contaminated oil shall not added to the combustion chamber
during boiler start-up or shut-down operations.
109
-------
PROPOSED SUPPLEMENT DRAFTED September 20, 1979
Chevrolet Motor Division, GMC
Permit No. 484-79
Page 3
DRAFT
c. The flue gas excess oxygen content shall be in excess of 3%.
d. The flue gas carbon monoxide level shall not exceed 50 ppm.
e. The primary fuel and mineral oil feed rates shall be continuously
monitored. The selected primary fuel flow fate shall not be
less than the flow rate corresponding to 25% of full rated
capacity.
f. The boiler shall be at a level of output no less than the output
at which the carbon monoxide, carbon dioxide, and excess oxygen
levels were measured.
g. Windbox differential pressure shall beat least 0.5" WC.
In the event that any of the above conditions are violated, the
flow of PCB contaminated oil to the furnace shall immediately cease.
18. All instruments and control for combustions control and in stack
monitoring shall either be self-calibrating or shall be calibrated
before initiation of this test. The instruments and controls subject
to this condition shall include, but may not be limited to, the
following:
a. opacity monitor
b. fuel flow measuring devices
c. excess oxygen monitor
d. carbon dioxide monitor
e. carbon monoxide
f. flame scanners
19. Except for the verification burn, the applicant shall incinerate
only PCB waste oil generated within the plant premises.
20. The exhaust gases shall be discharged unobstructed vertically upwards
to the atmosphere from a stack with a maximum diameter of 3.5 feet
and at an exit point not less than 65 feet above ground level.
DJV:mb
110
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NOTICE OF AIR POLLUTION COMMENT PERIOD AND PUBLIC HEARING
Notice is hereby given that the staff of the Michigan Air Pollution Control Commission
will hold a public comment period until October 15, 1979, and public hearings on October
11, 1979, and October 16, 1979, to afford all interested citizens the opportunity to comment
on the Commission staff's proposed conditional approval of GENERAL MOTORS CORPORA-
TION, CHEVROLET MOTOR DIVISION'S, Permit to Install equipment to burn oil containing
poly chlorinated biphenyls (PCB) in an existing oil-fired boiler located at 100 Fitzgerald
Street in Bay City, Michigan.
Copies of the Commission staff's analysis and proposed permit conditions are available
for inspection at the following locations:
BAY CITY: Bay County Health Department, Washington Park Plaza, 301
Second Street.
SAGINAW: Air Quality Division, Department of Natural Resources, Washburn
Building, Room 202, 1230 South Washington.
LANSING: Air Quality Division, Department of Natural Resources, State
Government Secondary Complex, General Office Building, 3rd
Floor, 7150 Harris Drive.
All persons are encouraged to present their written views on the proposed permit action
Written comments should be sent to the Department of Natural Resources, Air Quality
Division, P.O. Box 30028, Lansing, Michigan, 48909, to the attention of the Chief of
the Permit Unit. All statements received by October 15, 1979, will be entered into the
permit record.
THE OCTOBER 11, 1979, PUBLIC HEARING WILL BE HELD AT 7:30 P.M. AT THE
COUNTY BUILDING, 515 CENTER AVENUE, BAY CITY, MICHIGAN. The previously
announced public hearing will be held during the regular monthly meeting of the Michigan
Air Pollution Control Commission on Tuesday, October 16, 1979, starting at 9:00 a.m.,
at Holly's at the Inn, 3450 Hoyt Street, Muskegon Heights, Michigan.
MICHIGAN AIR POLLUTION CONTROL COMMISSION
Delbert Rector, Executive Secretary
9/28/79
111
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MICHIGAN DEPARTMENT OF NATURAL RESOURCES
AIR QUALITY DIVISION
STAFF ACTIVITY REPORT
October 16, 1979
Applicant
Chevrolet Motor Division
General Motors Corporation
100 Fitzgerald Street
Bay City, Michigan 48706
Permit to Install No. 484-79: Permit to incinerate waste oil containing 500 ,
ppm or less of polychlorinated biphenyls (PCB's)
in Chevrolet Motor Division's Industrial Boiler
No. 3.
Significant Dates
May 22, 1979
May 23, 1979
May 31, 1979
June 29, 1979
July 2, 1979
-- Staff met with EPA to discuss feasibility of conducting
a PCB verification burn.
— Staff met with applicant and his consultants to determine
required data and information for permit application.
— Final rule for the manufacture, processing, distribution,
and use prohibitions of polychlorinated biphenyls (PCBs)
published in the Federal Register (40 CFR Part 761)
-- Application received.
-- District Engineer performed a preliminary site investi-
gation.
The Condensed Chemical Dictionary, Van Nostrand Reinhold Company, 1977, page
696"! "polychlorinated biphenyl (PCB). One of several aromatic compounds
containing two benzene nuclei with two or more substituent chlorine atoms.
They are highly toxic. Their chief use is in heatexchange and insulating
fluids in closed systems. FDA has prohibited their use in plants manufacturing
foods, animal feeds, and food-packaging materials, and has established strict
tolerances on their presence in many food products (2.5 ppm).
NOTE: Because of their persistance and ecological damage from water pollution
their manufacture has been discontinued in the U.S. (1976)."
112
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Page 2
July 24, 1979 -- Staff met with applicant and his consultants to discuss
and clarify technical aspects of permit application.
August 2, 1979 -- Site evaluation performed by District Engineer and
Permit Unit.
Sept. 10, 1979 -- Additional information necessary to complete the application
received by the staff.
Site Location
Chevrolet Motor Division's Bay City Plant is located in Bay County and within
the boundaries of Bay City. The facility is located adjacent to the Saginaw
River and is surrounded by residential, industrial; and municipal establishments.
The nearest residences and plant boundaries are as follows:
Distance from No. 3 Distance to Property
Compass Stack to Nearest Line from Stack No. 3
Point Residence (meters) (meters)
N 750 310
NE 1,580 680
E 1,270 570
SE 620 520
S 450 430
SW 630 190
W 1,050 130
NW 730 230
History
The applicant had been burning PCB contaminated oil in all three existing
boilers at this facility for .approximately two years previous to July 14,
1977. On July 14, 1977, the Office of Toxic Materials Control, Environmental
Services Division, Department of Natural Resources, denied the applicant's
exemption application to burn PCB contaminated oils in the boilers since the
applicant had not fully complied with the provisions of Act 60, Public Acts
of 1976, and the administrative rules promulgated pursuant to the Act. Act
60 is the PCB Control Act that regulates the manufacture, sale, use, and disposal
of PCB. On September 2, 1977, the Commission's staff notified the applicant
that an approved air use permit application must be obtained from the Commission
before any further burning of PCB contaminated oils would be authorized.
On February 17, 1978, final regulations for disposing of PCB were promulgated
pursuant to Section 6(e)(l) of the United States Toxic Substance Control Act.
These federal regulations require that the combustion criteria for disposing
of PCB shall be either of the following:
113
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Page 3
1. A 2.0-second dwell time at 2,192°F in the furnace and 3% excess oxygen
in the stack gas; or
2. A 1.5 second dwell time at 2,880°F and 2% excess oxygen in the stack
gas.
In 1978 staff received and reviewed the applicant's application to burn PCB
oil and recommended that the application be denied. The applicant withdrew
the permit before final action was taken on the staff's recommendation.
The staff recommendation for denial action was based upon the following:
1. Combustion conditions did not meet the criteria as set forth by Section
6 of the U.S. Toxic Substances Control Act.
2. Stack testing methods were unacceptable.
3. Control of hydrogen chloride was not addressed.
On Thursday, May 31, 1979, final rules were promulgated which implement provisions
of the Toxic Substances Control Act (Federal Register 40 CFR Part 761). This
final rule amends the regulations first promulgated on February 17, 1978,
and then amended on August 2, 1978 (43 FR 33918).
The final ruling has determined that mineral oil dielectric fluid with 50
to 500 parts per million PCB, which was subject to disposal in incinerators
meeting the requirements of Annex I (2 second dwell time at 2,192 F and 3%
excess oxygen, or 1.5 second dwell time at 2,880 F and 2% excess oxygen) could
now be incinerated in high efficiency boilers. The applicant's existing boiler
No. 3 meets all of the technical criteria for high efficiency boilers established
by EPA in the final ruling for PCB manufacturing, processing, distributing,
and use.
Existing Facility
It is proposed that the waste oil containing PCB will be incinerated in Chevrolet
Motor Division's industrial steam boiler No. 3. Boiler No. 3 is a Wickes
industrial oil-fired package boiler with a maximum steam generating capability
of 60,000 pounds/hour (approximately 70 million Btu's per hour heat input).
Boiler No. 3 operates in conjunction with two other oil-fired package boilers.
The steam generated by these boilers is used for heating and process applications
within the applicant's facilities. All three of the boilers are currently
in compliance with all of the Michigan Air Pollution Control Commission's
rules.
The existing boiler controls are automatic with manual overide. The control
system shuts off the main fuel supply to the burners for the following conditions:
1. Loss of flame in either burner
2. Failure to maintain minimum air flow requirements
3. Failure to maintain minimum burner atomizing pressure
4. Low steam drum water level
114
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Page 4
Boiler controls fail safe (i.e., shut off oil supply to the boiler) in the
event of compressed air or electrical service loss.
All other facilities for the transport and storage of the waste oil are in
compliance with the appropriate divisions of the Department of Natural Resources.
Description of the Proposed Verification Burn
The applicant has requested a permit to perform a verification burn program
for the incineration of waste oil containing polychlorinated biphenyls in
the high efficiency boiler and to burn the waste oil on a continuing basis if
the verification burn is successful.
The purpose of this verification burn is to accurately measure the destruction
efficiency of this type of boiler for PCB. The test results are expected to reveal
minimum destruction efficiencies of greater than 99.9 percent based on other stack
test results and information contained in scientific literature.
The program is to be implemented by the GCA Technology Corporation of Bedford,
Massachusetts, under the auspices of the Environmental Protection Agency's
Office of Toxic Substances and with the cooperation of the Chevrolet Motor
Division. The verification program will be carried out in strict accordance
with the procedures set forth in GCA's test plan (Appendix A) and the special
permit conditions (Appendix B). Staff has reviewed GCA's proposed test procedures
and concurs with the sampling and analysis methodology as proposed.
The waste oil, which contains no more than 500 ppm PCB's, will be diluted
10:1 with No. 2 fuel oil resulting in a final oil mixture containing no more
than 50 ppm of PCB's. This mixture will be fired at a rate of four gallons
per minute. There will be three separate tests utilizing PCB contaminated
oil, each test lasting approximately six hours. There will be approximately
4,300 gallons of the final oil mixture used for the three verification tests.
The EPA allows oil with final PCB concentrations of 5 ppm to 50 ppm to be
incinerated in this type of boiler. Mixtures with less than 5 ppm can be
treated as noncontaminated oil. Contigent upon a successful verification
burn, and approval by the Air Quality Division, waste oil containing about
50 ppm PCB's will be diluted 10:1 with No. 6 fuel oil and fired in the No.
3 boiler. This is expected to occur on a routine basis for as many years
as the waste oils are contaminated with PCB. The verification burn must demonstrate
greater than 99.9X destruction of PCB in order to be considered successful.
Required Modifications to the Existing Facilities
The existing facilities are capable of burning PCB containing waste oil at
present; however, to provide the required safeguards, the control system will
have to be modified to include additional instruments which will continuously
monitor carbon monoxide, carbon dioxide, and excess oxygen levels. Since
carbon monoxide, excess oxygen, carbon dioxide, and opacity levels in the
boiler flue gas are indicative of combustion and destruction efficiency, these
controls must have alarm and boiler shutdown capabilities to insure that the
desired destruction efficiencey is maintained,
115
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Page 5
Boiler and Operational Requirements
The following conditions are boiler and operational requirements as set forth
by the EPA and as required by the Air Quality Division:
EPA Requirement
(Federal Register 40 CFR Part 761)
1. Boiler must be rated at a minimum
of 50 MM BTU per hour.
2. Oil containing PCB's must be less
than 10% of the total fuel flow.
3. Oil containing PCB must not be added
to the boiler during start-up or
shutdown.
4. Before burning PCB contaminated
oil, the owner/operator must con-
duct tests and determine that the
combustion emissions contain at least
3% excess oxygen and no more than
50 parts per million of carbon
monoxide.
5. The company must notify the
appropriate EPA Regional Adminis-
trator at least 30 days prior to the
test and has supplied the combustion
emissions data required in No. 4.
Air Quality Division
Requirements
1. Same
2. Same
Same
Same
Same.
6. The combustion process is moni- 6.
tored continuously or, for boilers
burning less than 30,000 gallons of
mineral oil annually, at least once
each hour that PCB contaminated oil
is being burned.
7. The primary fuel and mineral oil 7.
feed rates are monitored at least
every 15 minutes whenever PCB con-
taminated mineral oil is being
burned.
The combustion process must
be monitored continuously for
all boilers.
Staff requires that the feed
rates be monitored continuously
and the control system to alarm
on PCB contaminated waste oil
flow exceeding 4 gallons per
minute.
116
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Page 6
8. The carbon monoxide and excess 8. Staff requires CO, C0?. excess
oxygen levels are checked at least 0- and opacity levels to be
every 15 minutes whenever burning monitored continuously. Boiler
PCB contaminated mineral oil. controls will have alarm and
oil flow shutdown capabilities
if any of these parameters exceed
allowable limits. The CO, COp,
Oo, and opacity monitors will
have fail-safe capabilities.
9. Records are maintained that include 9. Same.
monitoring data in Nos. 6 & 7 above
and the quantities of PCB contaminated
mineral oil burned each month.
Anaylsis of Impact
For the impact analysis, an absolute worse case failure mode was assumed.
The worse case analysis includes the following criteria:
1. Poor atmospheric stability and, hence, plume dispersion
2. 0% destruction of PCB contaminated waste oil
3. Stack plume entrained in the aerodynamic wake of the building
4. All modeling assumes an 8 hour test time, whereas the test program
indicates that PCBs will not be incinerated for more than 6 hours
per day.
All four of the above conditions were used to determine the maximum expected
ground level concentrations. The worst case failure mode assumes that there
is no destruction efficiency, which is theoretically impossible because of
the existing controls and because of the additional redundancy which will
be integrated into the control system. The worst case conditions also assume
a PCB concentration of 50 ppm for the test burn.
Under the verification burn conditions listed above, the3worst case dispersion
analysis predicts a maximuw 8-hour exposure of 4.36 ug/m . Assuming an average
respiratory volume of 30 m for 24 hours, an individual could be exposed to
a maximum of 43.6 ug for an 8-hour period under worst case conditions.
The current legal Threshold Limit Value (TLV) for PCB's as established by
the American Conference of Govermental Industrial Hygienists (ACGIH) is
500 ug/m . The National Institute for Occupational Safety and Health (NIOSH)
recommends a time-weighted average of 1.0 ug/m . This, however, is a recommendation
and is not legally binding.
It can be seen that under worst case (no destruction) conditions the concentration
will be about 4 1/2 times the NIOSH recommendation but will not exceed 1%
of the ACGIH standard. If we assume the minimum expected destruction efficiency
of 99.9%, the ground level concentration would be 0.00436 ug/m or less than
0.0009% of the ACGIH standard and 0.5% of the NIOSH recommended time-weighted
average.
117
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Page 7
Under worst case conditions, the maximum ground level concentrations will
occur within the plant boundaries. PCB ground level concentrations were also
calculated for the residential areas surrounding the plant. The maximum concentration
of 0.28 ug/m occurs at the closest plant boundary. This closest boundary
area is approximately 130 meters west of the plant. Again, worst case meteorological
conditions were assumed and 0% destruction efficiency was assumed. This worst
case concentration indicates that the meximum ground level concentration is
28% of the NIOSH recommended value and 0.056* of the ACGIH standard.
As a means of comparing the amount of PCB's involved in this test, an analogy
can be made with a specific amount of food ingested. The FDA (Food and Drug
Administration) PCB limit for fish has recently been reduced to 2 ppm. At
2 ppm, if it is assumed that a person consumes 8 ounces of fish once, he would
have then consumed 454 micrograms of PCB's, or nearly 3% times the maximum
amount an individual can be exposed to during this test burn using worst case
assumptions.
The generation of hydrogen chloride is substantially less than the allowed
TLV. The OSHA TLV for hydrogen chloride is 5 ppm and the amount being generated
by this test is 0.8 ppm calculated as an instack concentration.
PCB Background Concentrations
A number of studies have indicated that PCB are very widespread throughout
the environment. The mechanisms by which PCB's enter the environment are
as follows:
1. Volatization of PCB's from paints and plasticizers as well as volatization
from PCB oil spills.
2. Incomplete incineration of PCB containing materials.
3. Co-distillation from PCB contaminated waters.
In addition, it is possible to volatize PCB contaminated oil currently stored
in landfills.
Levels of,airborne PCB,measured in the United States were found to range from
0.01 ug/m to 0.5 ug/m . Assuming 99.9% minimum destruction, the maximum
8-hour ground level concentration would be 0.0044 ug/m which is substantially
less than the ambient levels measured in the United States.
Recommendation and Summary
Staff recommends issuance of the permit to burn waste oil containing PCB's
subject to the attached conditions. Staff bases its recommendation on the
following criteria:
1. A demonstration, even under the worst case assumptions, that the
environmental and health impacts are acceptable. Under the expected
minimum destruction efficiency, the impacts are negligible.
118
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Page 8
2. Incineration in high efficiency boilers provides an environmentally
acceptable and desirable means of disposing of PCB waste oil in lieu
of disposal in landfills, storage, or other uncontrolled or unknown
methods of disposal.
3. Destruction efficiencies far in excess of the required 99.9% are
expected to occur. In addition, staff recognizes that, in light
of the new criteria established by EPA for disposing of PCB contaminated
oil, all of the reasons for the previous permit denial action have
been resolved.
Submitted by: D. John Vial
September 14, 1979
DJV:mb
Attachments
119
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STATE OF MICHIGAN
r35*V
NATURAL RESOURCES COMMISSION (^^1 AIB pol-'-UTION CONTROL COMMISSION
^tuBB*^ Maurice S Reuen, M.D.
JACOB A. MOEFER rh.,,-.n
CARL T JOHNSON WILLIAM G. MILLIKEN, Governor J±T2 „
DEPARTMENT OF NATURAL RESOURCES
GftEAT
LAKE
$TAT£
H1Q264
a/78
CHARLES G YOUNOLOVE Gtelvtt F Rob,nra,
Edwin S Shannon
September 28, 1979 SH-ST9
Emmanuel Van Nwrop. Ph 0
Box 3002«
L«n».ng, Ml 4»SO»
Mr. 0. R. Koenig
Superintendent of Maintenance
and Plant Engineer
Chevrolet Motor Division
General Motors Corporation
100 Fitzgerald Street
Bay City, Michigan 48706
Dear Mr. Koenig:
The staff of the Michigan Air Pollution Control Commission has received
a request to hold a public hearing in the Bay City area on your applica-
tion for a Permit to Install equipment to burn oil containing polychlorinated
biphenyls (PCB) in an exisitng oil-fired boiler at 100 Fitzgerald
Street in Bay City, Michigan.
Therefore, in addition to the public hearing which was previously
scheduled for the Commission's regular monthly meeting on October
16, 1979, the staff will conduct a public hearing at the County Building
which is located at 515 Center Avenue in Bay City, Michigan, beginning
at 7:30 p.m. A copy of the revised hearing notice is attached for
your information.
If you have any questions, please contact this office at (517) 322-
1333.
Very truly yours,
D. John Vial
Engineer, Permit Unit
Air Quality Division
DJV:mah
Attachment
cc: Senator Jerome T. Hart
Representative James A. Barcia
Mr. Edward Golson, Bay County Health Departmetn
Mr. Eric Cohen, EPA, Region V ---
Mr. D. Sanchez, EPA, Research Triangle Park"^^
East Central Michigan Planning and Development Commission
County of Bay
,.,„...-.-,.. City of Bay City
""""IJSi Mr. Benjamin I. White, District Engineer
120
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NOTICE OF AIR POLLUTION COMMENT PERIOD AND PUBLIC HEARING
Notice is hereby given that the staff of the Michigan Air Pollution Control Commission
will hold a public comment period until October 15, 1979, and public hearings on October
11, 1979, and October 16, 1979, to afford all interested citizens the opportunity to comment
on the Commission staff's proposed conditional approval of GENERAL MOTORS CORPORA-
TION, CHEVROLET MOTOR DIVISION'S, Permit to Install equipment to burn oil containing
poly-chlorinated biphenyls (PCS) in an existing oil-fired boiler located at 100 Fitzgerald
Street in Bay City, Michigan.
Copies of the Commission staff's analysis ana proposed permit conditions are available
for inspection at the following locations:
BAY CITY: Bay County Health Department, Washington Park Plaza, 301
Second Street.
SAGINAW: Air Quality Division, Department of Natural Resources, Washburn
Building, Room 202, 1230 South Washington.
LANSING: Air Quality Division, Department of Natural Resources, State
Government Secondary Complex, General Office Building, 3rd
Floor, 7150 Harris Drive.
All persons are encouraged to present their written views on the proposed permit action.
Written comments should be sent to the Department of Natural Resources, Air Quality
Division, P.O. Box 30028, Lansing, M.Jiigan, 48909, to the attention of the Chief of
the Permit Unit. All statements received by October 15, 1979, will be entered into the
permit record.
THE OCTOBER 11, 1979, PUBLIC HEARING WILL BE HELD AT 7:30 P.M. AT THE
COUNTY BUILDING, 515 CENTER AVENUE, BAY CITY, MICHIGAN. The previously
announced public hearing will be held during the regular monthly meeting of the Michigan
Air Pollution Control Commission on Tuesday, October 16, 1979, starting at 9:00 a.m.,
at Holly's at the Inn, 3-50 Hoyt Street, Muskegon Heights, Michigan.
MICHIGAN AIR POLLUTION CONTROL COMMISSION
Delbert Rector, Executive Secretary
9/28/79
121
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GCA
BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGE HAS BEEN
RETYPED FOR CLARIFICATION
rechnc!ogy Division
File 1-614-043 l.ve 17 October 1979
S. G. Zelenski
Information Submitted As Part Of Public Hearing On
PCB Burning Per GM Permit In Bay City, MI
Two forms of testimony were submitted at this hearing. The
first consisted of written testimony submitted on instruction of
the Project officer, Dave Sanchez, and a copy is enclosed as
part of this memo. The second form consisted of oral testimony
in response to a question. This consisted of the following
statement: "Analysis will reveal other chlorinated compounds
at a similar detection limit described for PCBs. Thank you.1'
A comment was made in response to Hal Synder's (OTS) question
as to scheduling restraints on GCA. My response was, I believe
not part of the recorded record, and referred Hal to my Project
Officer, Dave Sanchez, for more information.
/jpm
Enc
cc: K. T. McGregor
A. Engelman
122
-------
Supplement to State of Michigan, Department: of
Natural Resources Staff Activity Report ami
Attachment E, dated October 16, 1979.
(.LAK1FICATTON OF ENVIRONMENTAL ANALYSIS
Of major concern is the potential release of PCBs during the
trial burn. Calculations were made to predict worst case air concen-
trations of PCBs as well as worst case deposition of PCBs downwind
from the stack.
To calculate the highest expected air concentration of PCB,
the condition during which the plume from the stack was displaced
into the downwash of the building northeast of the stack was assumed.
In this case, the emission rate rather than the meteorological
conditions are assumed to be the prime determinant of exposure levels.
A non-destruction time period of two minutes was considered the maximum
possible with the safeguards and monitoring equipment installed on the
boiler for the test. This would yield a peak concentration of 9.74 yg/m^
air approximtely two minutes alter a two minute no-destruction release of
PCBs. This concentration would be highly localized in the region of the
building downwash. An individual in the area for one hour would be
exposed to a time-weighted average of 0.68 i;g/m-' air concentration of
PCBs.
To calculate the deposition which might occur en populated areas
near the stack, a meteorological model was 'Hypothesized which would yield
the highest concentrations at distances away from the stack. This mode!
relied on a stability condition referred to as Stability E and which
maintained the plume in a narrow, concentrated vedge radiating out from
the stack. The air concentration of PCB at the nearest populated area in
a northeasterly direction is calculated to be approximately 6.7 X 10~3 pg
after a two minute no-destruction release, averaged over one hour, and
2.0 X 10~4 iJg/rn-*, assuming 99.9% destruction for the 10 hour duration of
the trial burn. The deposition is calculated to he approximately 68 yg/m
at the same distance for the entire 24 hour trial burn.
These air concentrations should be compared to the documentation
available for PCB exposures. The first of these is the regulation in
effect from OSHA, and is 1000 yg/m3 for Aroclor 1242, and 500 pg/m3 for
Aroclor 1254. The second is the recommendation from NIOS11 approximately
two years ago suggesting a maximum exposure of 1 ^g/m^ ''he third is the
ACGIH TLV of 500 ug/m-^. These all are related to occupational exposure
not to exceed 40 hours/week, with a maximum of 10 hours/day.
Prepared by
GCA/Tfi: iinology 1) j '•• : •-, i >-.n
Fx'dford, MA OH30
123
-------
Calculated bov-nwind Air Con.'Ml vat ions Of PUB.s A!t'T A ? Minutf !'•-;-
Destruction Release Averaged > v or 1 Hour And Aff'.'r 10 Hours Of
Testing At 9'I. 9"' Destruct to- .
PCU Concentration t'CB Conceutrat i<--r.
Downwind No Destruction 99.9% Dcst- ;ction
Distance 2 Minute Release
(m) i:g/n3 yg/m3
250 1 X 10~2 3.2 X 10 4
500 9.3 X 10~3 2.8 X 10~4
7'30 8 X .^ ?t4 ;< 10
1,000 0.7 •; C>~3 2.0 X 10"
5,000
10,000
r;0,000 1.3 • '("
u0,000 f>.u :• io~5 i .3 x jo~''
124
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Research Triangle Park, North Carolina 2771 1
October 16, 1979
Diane Carlson
Department of Natural Resources
P. 0. Box 30028
Lansing, MI 48909
Dear Diane;
I hope the timing of this transmittal doesn't cause too much of an
inconvenience.
As you know, the availability of the information end findings we plan to
report on in our proposed paper are dependent upon the continued coopera-
tion of facilities applying for PCB test burns as well as public acceptance.
At the present time, our planned study at the Bay City GM plant has
encountered some delay; we should know by November 20 whether we will
be able to conduct a verification burn at that site. Our Sanford,
Florida verification burn test site is in a preliminary stage.
I will keep you informed as to when we obtain necessary State approvals
to conduct our tests. Please note that the proposed paper will be co-
authored by Dr. Steven Zelenski with GCA, Inc.
Sincerely,
David C. Sanchez
Environmental Engineer
Chemical Processes Branch
Industrial Processes Division
DCS/bld
Enclosure
125
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TECHNICAL PAPER PRESENTATION PROPOSAL FORM
73rd Annual Meeting
Air Pollution Control Association
Place Bonaventure, Montreal, Quebec
June 22-27, 1980
To the prospective author:
Complete this proposal form in triplicate (original and two copies) and return it
not later than October 15,1979 in accordance with instructions shown directly be-
low. Please indicate clearly whether or not your proposal was invited.
Dr. Louis-Philippe Roy
Div. Head, Phys. Ecology
Hydro Quebec
855 St. Catherine East (17th Floor)
Montreal, Quebec H2L 4M4, Canada
Q Proposed paper was invited by Diane Carlson
who is —X_ Session Arranger for Session Topic Hazardous Waste Incineration
and/or Chairman of responsible APCA Committee
(Proposal form should be sent directly to this primary contact)
OR
Q Proposed paper was not invited but is a response to the Invitation for
Submission of Papers and is submitted under subject area (code)
(topic)
(In this event, proposal form should be sent directly to Dr. Roy)
I agree to provide a complete manuscript by March 15th for review and accept-
ance.
In accordance with APCA policy, I certify that, to the best of my knowledge, this
paper will represent:
[X] The first publication of original Q Informative review only
material j—| An original compilation of infor-
[xl Will include experimental data mation from a number of sources
as specifically noted by foot-
LJ other notes and/or bibliography
In submitting a finished manuscript for publication I attest that the sole author(s)
will be the individual(s) whose name(s) will appear on the title page, with the possi-
ble exception of editorial or research assistance.
I am offering this paper to the APCA with full knowledge of the deadlines and other
requirements.
Signed
Title Environmental Engineer
APCA Affiliation . Member,
Non-Member,
Address IERL/RTP, (HP-62)
Date _1QA5-/Z9 US-EM
Research Triangle Park, NC 27711
126
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1 TITLE OF PAPER PCB Disposal - Verification Test Burn Results
2. AUTHORS
Under/ins name of speaker
Steven G. Zelenski
David C. Sanchez
o. work done at
7. Plan APCA _
Business Mailing Address
Including Zip Code and
Telephone Number
GCA Corporation
Burlington Rd.
Bedford, MA 01730
APCA
Member
ivit
n Yes n
LJ No D
Tech
Committee
Member
Yes
No
Industrial Environmental Research Laboratory
US EPA
Research Triangle Park, NC 27711
Bay City, Michigan and Sanfcrd, Florida
. nonAPCA publication. Where?
Professional
Discipline
of Primary
Author
n Engineer
Q] Chemist
O Physicist
O Biologist
Q Meteorologist
D Other
No
. Uncertain
8. Brief Des.. 200 words or equivalent.
Use ruled area below.
• EPA promulgated regulations 40 CFR, Part 761 on May 31, 1979 (44 FR 31514) to implement pru-
I visions of the Toxic Substances Control Act which prohibits the manufacture, processing, ',
distribution in commerce and use of PCB's. Subpart B of those regulations provides minimum '
requirements for the disposal of PCB's via thermal destruction.
IERL/RTP, EPA has contracted with the GCA Corporation of Bedford, Ma. to prepare and conduct
i thermal destruction verification test at two facilities. The verification tests wi.ll evalu-
! ate through the analysis 8f quantitative measurements for variousPCB's, potential inter-
1 mediates to the thermal destruction and boiler performance parameters, e.g., CO, 02> and
particuletesjthe PCB destruction characteristics of the two facilities.
i
Measurements for the presence of PCB's will be made in the fuel and stack emissions during
ithe uest. Multiple runs will be made as part of the T.est. Stack gas emissions will be sampleo
using a standard EPA Method 5 particulate train and PCB sampling train. Organic emissions in
the flue gas will be collected using an XAD-2 adsorbent column
Analysis of the samples, after the necessary extraction and concentration, will be accomplished
using gas chromatography coupled with either electron capture detection or mass spectrometry. i
i
Quality essurence and quality control in the analysis will be incorporated through the emission
Sampling of blank runs (fuel without PCB's) as well as the PCB fueled burns and the spiking !
pf emissions and samples to measure sampling efficiencies and analytical capabilities.
i The boiler thermal destruction verification tests are expected to confirm the ability of
boilers greater than 50 million BTU/hr heat input to provide for greater than 99.9*
(destruction of PCB's.
127
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UNITrD STATES
3 R! >N v
230 SOUTH .ARBORN ST.
ry
>N CHICAGO INOIS 60604
GCT
Mr. D.R. Koenig
Superintendent of Maintenance
and Plant Engineer
Chevrolet Motor Division
General Motors Corporation
100 Fitzgerald Street
Bay City, Michigan 48706
Dear Mr. Koenig:
This letter is to acknowledge the receipt of your notification,
dated September 18, 1979, to the U.S. Environmental Protection
Agency (USCPA) of your intention to burn mineral oil containing
less than 500 ppm of polychlorinated biphenyls (PCBs) in your
high efficiency boiler.
The notification has been reviev/ed by one of my staff and found
to be adequate in addressing the technical requirements as described
in Section 761.10(a)(2)(iii), of PCBs Manufacturing, Processing
Distribution in Commerce, and Use Prohibitions Final Rule which
was published by USEPA on May 31, 1979, in the Federal Register
40 CFR Part 761.
You have our consent to proceed with the burning of the PCB contaminated
mineral oil in the high efficiency boiler, Boiler No. 3, anytime after
October 18, 1979. It should be noted, however, that our consent
does not relieve you from complying with any other applicable Federal,
State, and local regulations and ordinances for the initiation
and continuation of such burn.
It is the responsibility of you and your company, Chevrolet Motor
Division, General Motors Corporation, to ascertain that all applicable
provisions of Sections 6(e)(l) and 6(e)(2) of the Toxic Substances
Control Act (Public Law No. 94-469), and the Final PCB Rule
(40 CFR Part 761) are fully adhered to in exercising the burn.
The pertinent provisions of the 40 CFR Part 761 include, but are
not 1imited to:
Subpart A - General
Subpart B - Disposal of PCBs and PCB Items
Subpart C - Marking of PCBs and PCB Items
128
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Subpart F. - List of Annexes
Annex III - Storage for Disposal
Annex IV - Decontamination
Annex V - Marking
Annex VI - Records and Monitoring
USEPA reserves the right to inspect the high efficiency boiler and
other auxiliary facilities to be used for the disposal of the PCC
contaminated mineral oil, including the records on the disposition
thereof.
Enclosed are copies of the Final PCR Rule and the Toxic Substances
Control Act of 1976. Should you have any questions regarding this
letter, please contact Jay Goldstein or Y.J. Kim of our Haste
Management Branch at (312) 353-2197.
Sincerely yours,
David Kee, Director
Air and Hazardous Materials Division
Enclosure
129
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STATE OF MICHIGAN
<^^>
NATURAL RESOURCES COMMISSION V~^ STEVENS 7 UASON BUILDING
•»C08 A HOEFER ""*" BO* 30°"
»RL T JOHNSON WILLIAM G MILLIKEN. Governor LANSING ui 45909
DEPARTMENT OF NATURAL RESOURCES
HOWARD A TANNER. Oirtcto
October 25, 2979
HARRY H WHITELEY HOWARD A TANNER. Director
JOAN L WOLFE
CHARLES G YOUNGLOVE
Mr. D. R. Koenig
Chevrolet Motor Division, GMC
100 Fitgerald Street
Bay City, MI 48706
Dear Mr. Koenig:
In regards to your application for the test burn of waste oil containing
PCB, I have compiled a list of questions raised at both the October
11 hearing in Bay City, Michigan and the regularly scheduled meeting
of the Michigan Air Pollution Control Commission held in Muskegon, Michigan
on October 16, 1979. After each question listed, I have indicated who
we think should be providing the response.
Obviously we could not list every individual question brought up at
the hearing and at the Commission meeting. Therefore, we have posed
questions which are representative of the general nature of the questions
asked at both the Cormission meeting and the public hearing. Since
we had determined at the Commission meeting that this permit application
would just be for a test burn only, all the questions listed are applicable
to the test burn only. In the event you are allowed to burn PCB contaminated
oil on a continuous basis, I anticipate that there would be additional
questions that would have to be answered before issuance of that permit.
Because we have a relatively short time frame to answer all these questions,
I request that you provide your written response by November 6, 1979.
If you have any questions, please feel free to contact me at (517) 322-
1333.
Yours very truly,,
D. -oohn Vial, Engineer
Permit Unit
Air Quality Division
DJV:mb
Enclosure
cc: B. White
Anthony Fisher
Bave Sanchez
130
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QUESTIONS RESPONSE
I. GENERAL
1. Aren't there more favorable and less populated areas DNR
where this, program could be implemented with less
risk to public health?
2. Can't this program be delayed until some type of DNR
state regulated chemical waste incinerator is built?
What effect if any, will Act 64, P.A. of 1979 (Hazardous
Waste Management Act) have on this application?
3. Wouldn't it be more advantageous to incinerate PCB DNR
in an incinerator instead of a high efficiency boiler?
4. What is an acceptable limit for PCB destruction? DNR
5. Why was the incineration criteria for PCB disposal DNR
changed?
6. Was this permit application evaluated on the basis DNR
of dwell times and temperature published in previous
regulations?
7. Has the State of Michigan ever issued a permit for DNR
the incineration of PCB?
8. Can the waste oil be recycled or reused in lieu of GM
incinerating it?
9. Will Chevrolet Bay City be permited to incinerate DNR
waste oils from other General Motors facilities or
other outside sources?
10. How long will it take to dispose of all the existing GM
waste oil stored on site?
11. How much waste oil is being generated and what operating GM
schedule will be used to dispose of the waste oil?
12. Is this a permit for a test burn only? DNR
13. Will the verification burn be performed with the type GM
of fuel oil that will be used under normal operating
circumstances?
14. What is the exact chemical composition and origination GM
of the PCB that is to be mixed with the fuel oil
during the test burn? "
131
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15. Did the 'boiler operators have any input into this DNR
application?
16. When would test burn take place, assuming approval GM
of the application by the Michigan Air Pollution
Control Commission?
17. Will a control device be required for the generation DNR
of hydrogen chloride?
II. HEALTH EFFECTS
1. How much PCB was burned previously without the boiler GM
operators knowledge, and what ramifications will
this have on this test, as far as worker exposure?
2. What action is Chevrolet taking to analyze what amount GM
of PCB the boiler operators were exposed to during
past burning of PCB contaminated oil?
3. What steps will be taken to prevent further worker GM
exposure to PCB during the verification burn and
during the cleaning of the boiler?
4. What actions are being taken to measure the health GM
impact that this test will have on boiler house operators?
5. Taking into account the bio-accumulative effects DNR
of PCB, will the level of PCB that could possibly
be emitted to the air in and around the Bay City
Chevrolet plant be harmful or cause cancer?
6. What are the long term effects of exposure to PCB? DNR
7. Can you guarantee that the amount of PCB being emitted DNR
from this stack will not cause or contribute to cancer
in humans?
8. What assurances are there that currently enforceable DNR
PCB exposure limitations will not become obsolete,
or will not become more stringent in the future?
9. Do the currently enforceable OSHA exposure limitations DNR
take into account the carcinogineric or mutageneric
effects of the contaminant?
III. BOILER CONDITIONS
1. Has the dwell time reading submitted by General Motors DNR
been verified by the Department of Natural Resources?
132
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2. When will GM substantiate test measurements with GM
operating personnel and DNR representatives as witnesses?
3. How can a continued high degree destruction efficiency DNR
be maintained when burning PCB contaminated waste
oil?
4. What redundant control features will be used on the DNR
furnace when burning PCB?
5. Will controls automatically shut off the flow of DNR
contaminated fuel oil to the furnace in the event
that a furnace upset condition is encountered?
6. How will the level of PCB be measured in the stack? DNR
Can we instantly detect high levels of PCB in the
furnace flue gases?
7. Will flame temperature be monitored continuously GM
while burning PCB contaminated waste oil?
8. How can it be guaranteed that waste oil with PCB DNR
concentrations exceeding 500 ppm will not be generated
and incinerated after permit issuance?
IV. SAMPLING AND ANALYSIS
1. Have we analyzed this plant's critical materials DNR
list?
2. Will dibenzofurans be generated during the combustion DNR
or partial combustion of PCB?
3. Will dioxin be generated during the combustion of DNR
PCB?
4. Will other toxic materials, created by the incineration DNR
of PCB or other contaminants in the waste oil, be
generated?
V. AMBIENT AIR MONITORING
1. What will Chevrolet do to monitor the ambient levels GM
of PCB in the atmosphere before, during, and after
the test burn?
2. Was state of the art modeling procedures and meteorological DNR
data was used to calculate ambient impact?
133
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3. Was the modeling based on the same boiler operating DNR
load as that boiler load used for the verification
burn?
4. Was the applicant's modeling study independently DNR
verified by the Air Pollution Control Commission's
staff?
5. What are the existing ambient levels of PCS in Bay DNR
City?
6. All of the modeling performed assumed meteorological DNR
parameters for the originally anticipated test burn
schedule in mid-August. Since this test, if granted
a permit, would be performed in the fall or winter, should
there be a re-evaluation in the study relative to
changes in meteorological conditions?
VI. BOILER MAINTENANCE
1. How will Chevrolet determine if there is PCB accumulation GM
in the boiler? If this requires washing, what will
be done with the washing medium while the test are
being done?
2. What will be done with the residue that is filtered GM
out of the waste oil?
10-25-79
134
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Ul UMUKCIt COMMIUION QfSif) *"* ^LU/DON COtlTHOt COMMISSION
.
L r JOHNSON WILLIAM G MILLIKEN, Governor
DEPARTMENT OF NATURAL RESOURCES
HOWARD A TAMNER. Director Edw.nl J KKw * MD
MICHLGWN
THI
0 III AT
LAKE
STATt
COoln 1 SMnnon
Morton
November 8, 1979 wo Tu™»
an NMrop. n 0
•01 won
UK*!*. W
-------
PROPOSED SUPPLEMENT TO PERMIT No. 434-79
Chevrolet Motor Division, GMC
Bay City, Michigan
Drafted November 8, 1979
GENERAL CONDITIONS
1. Applicant shall demonstrate compliance with all Commission rules
and with all specific conditions of this permit prior to issuance
of the Permit to Operate.
2. The restrictions and conditions of this Permit to Install shall
apply to any person or legal entity which now or shall hereafter
own or operate the facilities for which this Permit to Install
is issued. The Applicant shall immediately notify the Commission
of such change in ownership or principal operator status of this
facility.
3. Act No. 53 - Applicant shall notify any public utility of any excavation,
tunneling and discharging of explosives or demolition of buildings
which may affect said utility's facilities in accordance with Act
No. 53 of the Public Acts of 1974, being Sections 460.701 to 460.718
of the Michigan Compiled Laws and comply with each of the requirements
of that Act.
4. Rule 29(3b) - Operation of this facility shall not interfere with
the attainment or maintenance of the air quality standard for any
air contaminant.
5. Rule 29(3d) - Operation of this facility shall not result 1n substantial
deterioration of air quality.
6. Rule 46 - Operation of this facility shall not result 1n the emission
of an air contaminant which causes or will cause detriment to the
safety, health, welfare or comfort of any person or which causes
or will cause damage to property or business.
7. Rule 21 - Applicant shall not reconstruct, alter, modify, expand
or relocate this facility unless plans, specifications and an application
for a Permit to Install are submitted to and approved by the Commission.
8. Approval of this permit does not obviate the necessity of obtaining
such permits or approvals from other units of government as required
by law.
SPECIAL CONDITIONS
9. The Applicant shall not burn any PCB contaminated waste oil in
this boiler except as outlined in the submitted test procedure.
Any variation from this test procedure shall not be allowed without
written approval from the Air Quality Division.
10. The Applicant shall provide written notification to the Air Quality
Division as to the exact starting date and duration of the test,
at least one week prior to the initiation of the test.
136
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PROPOSED SUPPLEMENT DRAFTED November 8, 1979
Chevrolet Motor Division, GMC
Permit No. 484-79
Page 2
11. PCB contaminated oil shall not be fired in the boiler unless all
of the following conditions are satisfied.
a. The Applicant has verified by measurement of carbon monoxide,
that the boiler combustion efficiency is at least 99.9%.
b. The boiler is operating under stable conditions. Steam pressure,
steam flow, flue gas temperature, combustion air temperature,
fuel oil flow rate, and air flow rate shall be used as indicators
of the boiler stability.
c. The boiler is operating at a fuel oil flow rate of 4 gallons
per minute.
d. The fuel oil contains no aore than 10<, by volume, PCB contaminated
reclaim waste oil.
12. The Applicant shall analyze the PCB contaminated oil mixture for
all of the following:
a. polychlorlnated biphenyls (PCB)
b. dibenzofurans
c. chlorphenols
d. triaryl phospate esters
e. lead
f. zinc
g. nickel
h. mercury
1. copper
j. cobalt
k. hypochlorite
1. selenium
m. chromium
n. arsenic
o. cyanides
p. phenols
q. aniline
r. nitrogen
s. sulfur
t. chlorine
u. carbon
v. hydrogen
w. ash.
x. water
y. sediment
z. calorific value
aa. carbon residue
bb. flash point
137
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PROPOSED"•SBPPIEWWT DRAFTED November 8, 1979
Chevrolet Motor Division, GMC
Permit No. 484-79
Page 3
RA PT
Ar i
13. Input of PCB contaminated oil to the boiler shall cease immediately
if any of the following conditions occur at any time while burning
PCB contaminated oil:
a. The feed rate of the PCB oil mixture does not equal 4 gallons
per minute.
b. The carbon monoxide level in the flue gas exceeds 50 parts
per million.
c. The excess oxygen level in the flue gas falls below 3%.
d. Flue gas opacity exceeds 5X.
e. Windbox differential pressure falls below 0.5* W.C.
f. Atomizing steam pressure falls below 15.0 PSIG.
g. Fuel oil temperature falls below 155°F.
h. Steam dn» water water level falls 5" below the center line
of the steam drum.
i. Oil temperature exceeds 250°F.
14. The Applicant shall verify the emission rates of PCB, dibenzofurans,
total hydrocarbons, and hydrogen chloride in accordance with the
GCA test procedures.
15. The Applicant shall verify the emission rates of dioxlns and polycycllc
aromatic hydrocarbons. Prior to the test, the testing procedure
for these compounds must be submitted to and approved by the Air
Quality Division.
16. The Applicant shall test the inplant air, the ambient air and the
inside of the boiler for PCBs in accordance with the submitted
procedures.
17. All instrumentation and control used for combustion control and
in stack monitoring shall be self calibrating or shall be calibrated
before initiation of this test. The instruments and controls subject
to this condition shall include, but may not be limited to the
following:
a. opacity monitor
b. fuel flow measuring devices
c. excess oxygen monitors
d. carbon monoxide monitor
e. flame scanner
138
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PROPOSED SUPPLEMENT DRAFTED November 8, 1979
Chevrolet Motor Division, GMC
Permit No. 484-79
Page 4
18. The exhaust gases shall be discharged unobstructed vertically upwards
to the atmosphere from a stack with a maximum diameter of 3.5 feet
and at an exit point not less than 50 feet above ground level.
DJV:mb
139
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MICHIGAN DEPARTMENT OF NATURAL RESOURCES
AIR QUALITY DIVISION
Summary of Comments Received During the October 11 and 16, 1979, Public Hearings
on Chevrolet Motor Division, Bay City, Permit to Install No. 484-79
I. GENERAL
1. Are there more favorable and less populated areas where this program
could be implemented with less risk to public health?
Response: Yes, since any area with less population could be considered
to nave less risk if transportation issues are not considered.
However, the Michigan Air Pollution Control Commission does not
have the authority to deny a permit because a better site exists
elsewhere.
2. Can this program be delayed until some type of state-owned or regulated
hazardous waste incinerator is built? What effect, if any, will
Act 64, Public Acts of 1979 (Hazardous Waste Management Act) have
on this application?
Response: Technically, this program could be delayed as long as
there are facilities available for safely storing or disposing
of this waste. A well managed hazardous waste incineration facility
would be a viable alternative to this program.
It is difficult to define exactly what impact the rules pursuant
to Act 64, Public Acts of 1979 (Hazardous Waste Management Act)
will have, because these rules are only in the proposal stage.
However, Act 64 does not become effective until 1980.
3. Would it be more advantageous to incinerate PCB in an incinerator
instead of a high efficiency boiler?
Response: Incinerating PCB in a high temperature incinerator in
lieu of a high efficiency boiler would provide a larger margin
of safety because higher flame temperatures can be achieved in
the incinerator. Highly concentrated PCB waste (500 parts per
million and above) will still be required to be disposed of in
high temperature incinerators that can achieve 99.9999 percent
destruction efficiency. However, the rules recently promulgated
by the Environmental Protection Agency allow lower concentrated
PCB waste oil (up to 500 parts per million) to be incinerated in
high efficiency boilers and should provide an acceptable margin
of safety since these boilers are expected to achieve destruction
efficiencies of 99.9 percent to 99.999 percent.
4. What is an acceptable limit for PCB destruction?
Response: This test burn program will be judged to be acceptable
if a minimum destruction efficiency of 99.9 percent is achieved.
140 -
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- 2 -
5. Why was the EPA incineration criteria for PCB disposal changed?
Response: The incineration criteria for PCS disposal has not changed
for highly concentrated PCS waste oil (500 parts per million and
above). Such waste is still required to be disposed of by high
temperature incineration (2,197 degrees Fahrenheit at 2 seconds
dwell time or 2,880 degrees Fahrenheit at 1.5 seconds dwell time).
The new regulations do allow lower concentrated PCB waste oil (50
to 500 parts per million), which was not required to be incinerated
under old regulations, to now be disposed of in high temperature
boilers after a 9 to 1 dilution with regular fuel oil. The majority
of this lower concentrated waste was in the past disposed of in
landfills or simply held in storage. These new regulations are,
therefore, in addition to the past requirements.
6. Was this permit application evaluated on the basis of the dwell
times and temperatures published in previous regulations?
Response; No. The PCB concentration is low enough that these
regulations do not apply. The evaluation was performed by comparing
this furnace's combustion parameters with the temperature, dwell
time, and PCB destruction efficiencies measured and documented
in other test situations.
7. Has the State of Michigan ever issued a permit for the incineration
of PCB?
Response: No.
8. Can the waste oil be recycled or reused in lieu of incineration?
Response; Reclaim oil containing less than 50 parts per million
PCB may legally be recycled. Approximately 18,000 gallons of the
38,000 gallons being stored at Chevrolet-Bay City meet this criteria.
However, Chevrolet plans to burn this oil if allowed. Another
10,000 gallons of the 38,000 contain less than 50 parts per million
PCS but are sludges and, thus, cannot be recycled nor can they
be burned in General Motor's existing boilers. This material will
require additional processing or disposal in a PCB approved incinerator
or landfill. The remaining 10,000 gallons contain greater than
50 parts per million, but less than 500 parts per million PCB,
and may not legally be recycled. Additionally, technology does
not exist to physically remove the PCB from the waste oil.
9. Will Chevrolet-Bay City be permitted to incinerate waste oils from
other General Motors facilities or other outside sources?
Response: No.
10. How long will it take to dispose of all the existing waste oil
stored on site?
Response: Approximately 28,000 gallons of the 38,000 gallons being
stored are burnable in General Motors' existing No. 3 boiler.
141
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- 3 -
Approximately 1,200 hours of burning time will be required to dispose
of the 28,000 gallons at a firing rate of 4 gallons per minute
when mixed to comprise not more than 10 percent by volume of the
fuel oil fed to the boiler.
11. How much waste oil is being generated and what operating schedule
will be used to dispose of the waste oil?
Response: Reclaim oil is being generated at a rate of 1,000 to
2,000 gallons per month. Approximately 80 hours of burning time
will be required to dispose of 2,000 gallons at a firing rate of
4 gallons per minute when mixed to comprise not more than 10 percent
by volume of the fuel oil fed to the boiler. Reclaim oil will
be mixed with fuel oil to produce batches of approximately 10,000
gallons. Each batch will be burned on a continuous 24-hour per
day basis.
12. Is this a permit for a test (verification) burn only?
Response: Yes
13. Will the test burn be performed with the type of fuel oil that
will be used under normal operating circumstances?
Response: The permit application has been amended so that the
test burn will now be conducted using No. 6 fuel oil, which is
the fuel oil used under normal operating conditions.
14. What is the exact chemical composition and origination of the PC3
that is to be mixed with the fuel oil during the test burn?
Response: For the test burn only, the United States Environmental
Protection Agency has requested that the reclaim oil be spiked
to raise its concentration to approxiamtely 500 parts per million
PCS. The spiking fluid is 98% PC8 and originates from an electric
capacitor formerly used at this location. The PCS present in the
capacitor fluid is Aroclor 1242 which is the same Aroclor present
in the reclaim oil. The spiked reclaim oil will be mixed with
No. 6 fuel oil to comprise not more than 10 pecent by volume of
the fuel oil fed to the boiler. The PCS concentration at the
burner will be approximately 50 parts per million during the veri-
fication burn.
15. Did the boiler operators have any input into this application?
Response; Yes. All parties interested in this permit application
had an opportunity to provide input both at the public hearing
held at Bay City on October 11, 1979, and at the regularly scheduled
meeting of the Michigan Air Pollution Control Commission on October
16, 1979. In fact, this report is in response to comments raised
by the boiler operators and others.
16. When would the test burn take place, assuming approval of the appli-
cation by the Michigan Air Pollution Control Commission?
142
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- 4 -
Response: Weather permitting, the verification burn would be con-
ducted during the week of December 3, 1979. This date is contingent
upon the Michigan Air Pollution Control Commission's approval on
November 20, 1979.
17. Will a control device be required for the generation of hydrogen
chloride?
Response: No. The hydrogen chloride concentration is low enough
that control is not necessary.
II. HEALTH EFFECTS
1. How much PCS was burned previously without the boiler operators'
knowledge, and what ramifications will this have on this test as
far as worker exposure?
Response: Reclaim oil containing residual PCB's has been burned
in boilers at this location as shown below:
Year ReclaimOil Burned Estimated PCS Concentration
1974 27,399 gallons 100 ppm - 500 ppm
1975 17,163 gallons 100 ppm - 500 ppm
1976 45,075 gallons 100 ppm - 500 ppm
1977 12,556 gallons 100 ppm - 500 ppm
102,193 gallons
The exact concentration of PCB's present in the oil that was burned
is not known. Analysis of available information would indicate
that the concentrations were between 100 parts per million and
500 parts per million. The ramifications are addressed in the
next question.
2. What action is Chevrolet taking to analyze the amount of PC8 the
boiler operators were exposed to during past burning of PCB contami-
nated oil?
Response: Chevrolet-Bay City has provided physical examinations,
inc luding blood analysis, for all powerhouse boiler operators who
worked in the powerhouse during previous burning of PCB contaminated
oil. PCB levels in the operators will be addressed through blood
serum analysis. The Michigan Department of Public Health Laboratory
in Lansing and the Raltech Laboratory in Madison, Wisconsin, will
share split samples of blood serum from each operator and analyze
independently for PCB levels. Identical examination and analysis
has also been conducted on a control group from within the Chevrolet
plant population. The control group includes both infrequent and
frequent consumers of fish taken from the Saginaw Bay. Comparison
of the blood serum levels of the two groups will indicate those
candidates, if any, who should undergo further examination through
body fat biopsies.
143
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- 5 -
3. What steps will be taken to prevent further worker exposure to
PCB during the verification burn and during the cleaning of the
boiler?
Response: Reclaim oil will be delivered to the boiler through
closed system transfer piping and presents no exposure potential
to the operators. However, the General Motors Industrial Hygiene
Department will take air samples in the powerhouse during the
verification burn. After completion of the verification burn,
the boiler will be shut down and inspected. Samples will be taken
of residue on the waterwalls and heat wheel. The boiler will then
be closed until the residue is analyzed for PCB content. Based
on the results of the analysis, appropriate protective clothing
and respirators will be provided to the operators who will clean
the boiler.
4. What actions are being taken to measure the health impact that
this test will have on boiler house operators?
Response: General Motors Industrial Hygiene Department will collect
air samples in the powerhouse during the verification burn. GCA
Corporation, the United States Environmental Protection Agency's
contractor, will collect continuous exhaust stream samples during
the verification burn. Samples will be taken of residue on the
waterwalls and heat wheel before and after the verification burn.
The results from the analyses of these tests will quantify total
operator PCB exposure.
5. Taking into account the bio-accumulative effects of PCB, will the
level of PCB that could possibly be emitted to the air in and around
the Bay City-Chevrolet plant be harmful or cause cancer?
Response: PCB's are generally recognized as proven animal carcinogens.
However, there is no good data as yet to Indicate that it is a
human carcinogen. Dr. Ray Harbison of Toxic Substances Control
Laboratory at Vanderbilt University, Nashville, Tennessee, is quoted
in the October 26, 1979, issue of Environmental Reporter as saying:
"PCB's are totally Immobile and not carcinogenic to humans." However,
we learned in talking to Dr. Harbison, that what he actually said
was that there was no evidence that PCB's are carcinogenic in either
humans or animals. He felt that the available evidence that suggests
PCB's to be carcinogenic is weaker than the case presented for
saccharin.
Renate Kimbrough, M.D., of the Center for Disease Control in Atlanta,
who has done research on PCB toxicology, indicated that it is her
professional judgment that an ambient level of 0.3 micrograms per
cubic meter would be safe. Based on calculations, incinerating
50 parts per million PCB with 99.9 percent destruction at the Bay
City-Chevrolet plant would have a maximum ground level concentration
of 0.004 micrograms per cubic meter. This concentration will occur
on Chevrolet's plant site. So, with 99.9 percent destruction,
the maximum ground level concentration would be nearly 100 times
lower than the level that Dr. Kimbrough judged to be a safe ambient
144
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- 6 -
level. Furthermore, the maximum concentration that will occur
off of Chevrolet's plant property (0.28 micrograms per cubic meter)
will be less than this level that 1s considered to be safe even
1f there was no destruction.
6. What are the long-term effects of exposure to PCB?
Response: Long-term effects of PCB to animals are generally considered
to include cancer and reproductive failure. In humans, the more
serious effects are that it can cause chloracne and possibly liver
ailments. Recently, Dr. Ralph D. Dougherty of the Department of
Chemistry, Florida State University, suggested that PCB's may be
related to observed reduced sperm counts in humans.
7. Can you guarantee that the amount of PCB being emitted from this
stack will not cause or contribute to cancer in humans?
Response: No. Again, however, based on Dr. Kimbrough's professional
judgment and the fact that our calculated maximum ground level
concentration is substantially below her suggested safe ambient
levels, the risk is minimal.
Additionally, the staff's calculations show that the amount of
PCB that will be emitted from the storage tanks is very insignificant
due to the very low vapor pressure of PCB.
8. What assurances are there that currently enforceable PCB exposure
limitations will not become obsolete or will not become more stringent
in the future?
Response: No one can give any kind of assurance that it will not
be lowered. Already the National Institute for Occupational Safety
and Health (NIOSH) recommended level is 1 micrograms per cubic
meter compared to the TLV of 500 micrograms per cubic meter for
Aroclor 1254. There is no enforceable ambient PCB limit and it
is not known what it will be if and when one is established.
9. Do the currently enforceable Occupational Safety and Health Adminis-
tration (OSHA) exposure limitations take into account the carcino-
gineric or mutageneric effects of the contaminant?
Response: No. However, the recommended NIOSH standard did take
into account these effects.
10. What happens to PCB that accumulates in the body? Is it ever expelled
from the body?
Response: It is not known exactly what happens when PCB accumulates
in the body. However, based on animal studies, there does not
seem to be any apparent effect after it is accumulated in the body.
Animal studies have indicated that PCB's are expelled from the
body. However, the rate of expulsion, to some extent, depends
on the various PCB isomers. There is some indication that certain
isomers may never be expelled from the body. In one experiment,
145
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- 7 -
rats were fed for six months with 100 parts per million (ppm) of
Aroclor 1242 in their diet. At the end of six months, the PCB
level in the adipose (fat) tissues was 240 ppm. Four months after
the feeding study, the level dropped to 35 ppm, and at the end
of five months, the level dropped to 30 ppm. Furthermore, it appears
that there is no observable effect when the PCB's are being expelled
from the body in these animal studies.
11. Is there an upper limit that the body will reach when exposed to
a continuous low level concentration of PCB's?
Response; There is no definitive answer to this question. In
one rat study, there appears to be an indication that an equilibrium
level may be approached but the data is flawed by the fact that
in such a long-term study the rats continued to grow and their
food consumption varies and decreases as they grow old.
12. What effects will a short-term high concentration exposure have
when compared to low level long-term exposure?
Response: There is also no information on this.
III. BOILER CONDITIONS
1. Has the dwell time reading submitted by General Motors been verified
by the Department of Natural Resources?
Response: Yes. Our calculations indicate the dwell time is one
second.
2. When will General Motors substantiate temperature measurements
with operating personnel and Department of Natural Resources repre-
sentatives as witnesses?
Response: A flame temperature measurement demonstration will be
scheduled for DNR representatives and Interested operators prior
to the November 20, 1979, meeting of the Michgian Air Pollution
Control Commisison.
3. How can a continued high degree of destruction efficiency be main-
tained when burning PCB contaminated waste oil?
Response: A high degree of destruction efficiency will be assured
by closely monitoring and controlling the boiler combustion conditions.
Because combustion conditions are indicative of destruction efficiencies,
combustion conditions will be maintained under very controlled
conditions. The boiler combustion gases must contain at least
3 percent excess oxygen and no more than 50 parts per million of
carbon monoxide to assure that combustion is complete. Any violation
of these conditions will shut off the supply of PCB contaminated
oil to the boiler. In addition to excess oxygen and carbon monoxide,
the boiler will be monitored for opacity.
146
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- 8 -
4. What redundant control features will be used on the boiler when
burning PCS?
Response: The boiler combustion parameters will be monitored and
controlled. The parameters monitored will be carbon monoxide,
excess oxygen, and opacity, which are all indicators of combusion
efficiency. If any one combustion parameter is violated, the flow
of PCS oil to the furnace will be shut off. In addition, flame
conditions will be monitored. If the flame begins to decay, the
flow of PCB contaminated oil to the furnace will be shut off.
The valves which control the flow of PCB contaminated oil to the
boiler are fail safe. The burner solenoid valves will close,
shutting off oil flow, in the event of a loss of control voltage.
The pneumatic (air operated) oil flow control valve will close,
shutting off oil flow, in the event of a loss of compressed air.
All of the aforementioned controls are in addition to the other
existing furnace controls presently installed on the boiler.
5. Will controls automatically shut off the flow of contaminated fuel
oil to the boiler in the event that a boiler upset condition is
encountered?
Response: For the verification burn, all of the aforementioned
controls will not have automatic shut off capabilities. The verifi-
cation burn will rely on operator intervention to stop the flow
of PCB oil to the boiler in the event that one of the boiler para-
meters is violated. Air Quality Division staff will witness the
entire test program. However, in the event that PCB incineration
is allowed on an ongoing basis, the controls will be automated
with provisions for alarm and shut down capabilities.
6. How will the level of PCB be measured in the stack? Can we instantly
detect high levels of PCB in the boiler flue gases?
Response: For the verification burn, representative flue gas samples
will be taken and collected by the use of implngers and adsorbents
as described in GCA Technology's test procedure which was included
with the Air Quality Division's October 16, 1979, staff report.
All of the collected samples will have to be analyzed in a laboratory
to determine the level of PCB that was present in the stack. When
the stack concentration has been determined from analysis of the
collected samples, the total amount of PCB being emitted out of
the stack can be determined and the destruction efficiency calculated.
The staff is not aware of any device which can instantly detect
PCB stack concentration without laboratory analysis.
7. Will flame temperature be monitored continuously while burning
PCB contaminated waste oil?
Response: No. To date, neither General Motors nor staff has been
able to find anyone who can supply this type of equipment.
147
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- 9 -
8. How can it be guaranteed that waste oil with PCB concentrations
exceeding 500 parts per million will not be generated and incinerated
after permit issuance?
Response: The permit conditions only allow the burning of PCB
contaminated oil during the test burn. The District Engineer for
the Bay City area will be responsible for the strict enforcement
of this and all other conditions. Violation of any permit condition
subjects the permit applicant to a substantial fine and possible
permit revocation.
IV. SAMPLING AND ANALYSIS
1. Have we analyzed this plant's critical materials list?
Response; Yes, General Motors will be required to analyze the
reclaimed oil for all 15 of the compounds on their critical materials
list and for dibenzofurans, chlorophenols, nitrogen, sulfur, chlorine,
carbon, hydrogen, ash, water, sediment, calorific value, carbon
residue, and flash point.
2. Will dibenzofurans be generated during the combustion or partial
combustion of PCB?
Response: The amount of dibenzofurans generated will depend on
combustion conditions. Significant amounts of dibenzofurans could
be genrated under poor combustion conditons. In this boiler and
with 50 parts per million PCB's with 99.9 percent destruction,
it is expected that maximum stack concentration of dibenzofuran
to be below 1 part per billion. Additionally, the test procedures
will quantify the stack concentration of dibenzofuran if 1t is
present.
3. Will dioxin be generated during combustion of PCB's?
Response: The test procedures will quantify the stack concentration
of dioxin if it is present. Assuming that chlorophenols are not
present in the waste oil, it is unlikely that dioxins will be
generated. An analysis for the presence of chlorophenols in the
waste oil will be required. If chlorophenols are present in the
waste oil, further analysis will be done before we evaluate burning
PCB on a continuous basis. The Dow Chemical Company claims that
incineration of any organic material can result in generation of
dioxins. However, Dr. John R. Gledhill of Dow Chemical Company
has indicated that usually no dioxins are detectable when the
incineration temperature is above 2000 degrees Fahrenheit as is
the case with this boiler.
4. Will other toxic materials, created by the incineration of PCB's
or other contaminants in the waste oil, be generated?
148
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- 10 -
Response: The most obvious toxic material that could be generated
would be polycyclic aromatic hydrocarbons. This type of compound
is usually generated under poor combustion conditions.
Additionally, the test procedure will detect the presence of any
polycyclic aromatic hydrocarbons and any halogenated organic compounds.
V. AMBIENT AIR MONITORING
1. What will Chevrolet do to monitor the ambient levels of PCB in
the atmosphere before, during, and after the test burn?
Response: Outside grab samples will be collected upwind of the
boiler stack during the verification burn to determine ambient
background levels in Bay City. Continuous samples collected inside
the boiler stack by GCA, EPA's contractor, during the verification
burn will be used along with the background readings to determine
the amblnet air levels around the plant.
2. Were state of the art modeling procedures and meteorological data
used to calculate ambient impact?
Response: The modeling techniques and computer programs used by
the staff is representative of the most recent technical advances
in this field.
3. Was the modeling based on the same boiler operating load as the
boiler used for the test burn?
Response: Yes. The modeling and the test procedures are based
upon the furnace load corresponding to a fuel oil flow rate of
4 gallons per minute.
4. Was the applicant's modeling study independently verified by the
Air Pollution Control Commission's staff?
Response: Yes.
5. What are the existing ambient levels of PCB in Bay City?
Response: It is not known at this time what the existing ambient
levels of PCB are. However, as previously stated, the ambient
levels will be determined during the test.
6. All of the modeling performed assumed meteorological parameters
for the originally anticipated test burn scheduled in mid-August.
Since this test, if granted a permit, would be performed in the
fall or winter, should there be a re-evaluation in the study relative
to changes in meteorological conditions?
Response: It will not be necessary to re-evaluate the dispersion
estimate based on changes in meteorological conditions during the
verification burn. The analysis conducted assumes worst case meteoro-
logical conditions, regardless of time or season of the year.
149
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- 11 -
VI. BOILER MAINTENANCE
1. How will Chevrolet determine if there is PCB accumulation in the
boiler? If this requires washing, what will be done with the
washing medium while the tests are being done?
Response: Samples will be taken of residue on the waterwalls and
heat wheel before and after the verification burn and analyzed
for PCB content. The boiler will not be cleaned until the results
of the analysis of the residue are known. Liquids used to clean
the boiler will enter process sewers and go to the Chevrolet-Bay
City waste water treatment facility where contaminants such as
oil containing PCB will be removed. Solid wastes removed at the
waste water treatment facility or directly from the boiler will
be disposed of in an appropriate landfill, as per existing PCB
regulations. Currently, all of the approved PCB landfills are
located outside of Michigan.
2. What will be done with the residue that is filtered out of the
reclaim waste oil?
Response: Residue from filtered reclaim oil will be disposed of
in an appropriate landfill, as per existing PCB regulations.
Prepared by: John Vial and George Su
November 8, 1979
JV:GS:mah
150
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STATE OF MICHIGAN
NATURAL RESOURCES COMMISSION QS*» *'" rOLUrrio'< CONTROL COMMISSION
JACOB A HOEFER ^Sn^"^ Miunn S H«-t»g
November 8, 1979 w.o. T^»,
C ERTIFIED M AIL
TMt
CM EAT
LAKE
STATE
Mr. Don R. Koenig
Plant Engineer /-,
Chevrolet Motor Division ^
General Motors Corporation
100 Fitzgerald Street
Bay City, Michigan 48706
Dear Mr. Koenig:
The Michigan Air Pollution Control Commission will meet on November 20,
1979, in the Executive Training Room, Long's Convention Center, which is
located at 6810 South Cedar Street in Lansing, Michigan. A copy of the meeting
agenda is enclosed.
At 1:00 p.m. the Commission has scheduled consideration of Chevrolet Motor
Division's application (No. 48*-79) to install equipment to conduct a test burn
of oil containing polychlorinated biphenyls (PCS). Enclosed is a copy of the
staff's summary and responses to concerns expressed at the October 11, 1979,
public hearing in Bay City and the October 16, 1979, Commission meeting in
Muskegon. It is respectfully requested that a representative of Chevrolet Motor
Division be present at the November 20, 1979, Commission meeting.
If you have any questions concerning the permit application or the Commission's
meeting, please contact Mr. Gerald Avery or Mr. John Vial at (517) 322-1333.
Very truly yours,
AIR POLLUTON CONTROL COMMISSION
Delbert Rector
Executive Secretary
DR:mah
Enclosures (2)
cc: Benjamin E. White
Eric Cohen, EPA, Ration V
EPA, R«earch Triangle Park
151
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11/6/79
Meeting Agenda
MICrlGAN fm. POLLUTION CONTROL COMMISSION
November 20, 1979
Long's Convention Center
Executive Training Room
6810 South Cedar Street
Lansing, Michigan
9:09 a.m. - MEETING CONVENES: Items 1 throygh I will be considered as time
allows during either the morning or afternoon session:
1) Announcements
2) Approval of Minutes of Previous Meeting
3) Executive Secretary's Report
*5 Report on staff efforts to handle emissions of toxic discharges.
b) Staff report on oxidant and lead SIP revisions.
c) Staff report on proposed Administrative Rules changes.
d) Proposed Calendar of Meetings for 19SO.
0) Legal Counsel's Report
5) Disbursement of Surveillance Fees
Consideration of requests from Macomk* County and Mwkejon
County Health Departments for air surveillance fee funds to support
their air pollution control programs.
6) Air Surveillance Fees
Staff recommendation to estaWish the unit cost of scheduled investi-
gations and investigation difficulty and frequency factors to be
used in calculation of the February 1, 19X0, surveillance fees.
7) Proposed Fugitive Dust Rules
Staff recommendation for Commission to approve proposed rules
R 336.1370 and R 336.1371 for purposes of conducting public hearings.
1) Redesignation of Nonattainment Area for Total Suspended Particutates
Consideration of staff recommendation to redesignate a portion
of Delta County as attainment for total suspended particuiatec
and a portion as nonattainment for primary total suspended paniculate
standards.
SCHEDULED APPEARANCES
9:30 a.m. 9) City of Lansing, Asphalt Plant
Public hearing on proposed Stipulation for Entry of Consent Order
to discontinue operation of the City's asphalt plant.
(continued on reverse side)
152
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MAPCC Agenda
- 2-
November 20, 1979
11:00 a.m. 10) Superior Metal Shredders, Inc., Kalamazoo
Staff recommendation to deny operating permit for metal shredding
plant.
11:30 a.m. 11) Public Comment; This is a regularly scheduled agenda item to
give individuals and organizations an opportunity to discuss items
with the Commission without prior scheduling.
12:00 noon - Lunch
1:00 p.m. 12) General Motors Corporation, Chevrolet Motor Division, Bay City
Consideration of an application for a Permit to Install equipment
to conduct a test burn of oil containing polychlorinated biphenyls (PCB).
13) Robinson Asphalt, Inc., Jackson
Staff recommendation to deny permit application to burn No. k
oil because existing plant in Parma Township is violating the Commisison's
rules.
14) Cunningham-Gooding, Ann Arbor
Staff reommendation to deny permit to operate the drum mix asphalt
plant.
#»#*#*****»****
December 18, 1979
Long's Convtntion Center
Lansing, Michigan
153
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•MICHIGAN DEPARTMENT OF NATURAL RESOURCES
AIR QUALITY DIVISION
STAFF ACTIVITY REPORT
November 20, 1979
Applicant
Chevrolet Motor Division
General Motors Corporation
100 Fitzgerald Street
Bay City, Michigan 48706
Permit to Install No. 484-79
Addendum to October 16. 1979. Staff Activity Report
On June 29, 1979, the staff of the Air Quality Division received from Chevrolet
Motor Division, Bay City Plant, an application for a permit to install equipment
necessary for burning waste oil containing polychlorinated biphenyls (PCB)
in their exisitng oil-fired industrial boiler. Based on the data in the appli-
cation, identified as No. 484-79, and subsequent meetings with the applicant
and other concerned parties, staff had anticipated making a recommendation
to the Commission for approval of this permit application at the October 16,
1979, Commission meeting.
Staff held public hearing in Bay City on October 11, 1979, and in Muskegon
on October 16, 1979, in regard to this applicaiton. Because of a number of
questions raised at this hearing that could not be immediately resolved and
because of a request for additional time for review by the Bay City Commission,
staff decided to delay recommendation of this application at the October 16,
1979, Commission meeting until all questions could be resolved.
A 11st of representative questions have been compiled from the two hearings.
Attached 1s the 11st of these questions and appropriate responses.
Staff intends to discuss this proposal with the Bay City Commission on November 12,
1979. Additionally, this staff report addendum and the attached summary of
the public hearing concerns is being sent to all of the people that have expressed
an interest in this application. Based upon staff's October 16, 1979, staff
report and the attached responses, staff intends to recommend approval of
this permit for the verification burn only to the Michigan Air Pollution Control
Commission on November 20, 1979, subject to the attached revised special condi-
tions, unless new information is presented at the Bay City Commission meeting
or the November 20, 1979, Commission meeting.
Submitted by: John Vial
November 8, 1979
JV:mah
Attachments (2)
See pages 158-172 for attachments. 154
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BECAUSE OF ILLEGIBLE ORIGINAL, THIS
PAGE HAS BEEN RETYPED FOR CLARIFICATION
STATE OF MICHIGAN
NATURAL RESOURCES COMMISSION
Carl T. Johnson
E. M. Laitala
Dean Pridgeon
Hilary F. Snell
Harry H. Whiteley
Joan L. Wolfe
Charles G. Younglove
WILLIAM G. MILLIKEN, Governor
DEPARTMENT OF NATURAL RESOURCES
STEVENS T. MASON BUILDING, BOX 30028, LANSING, MICHIGAN 48909
HOWARD A. TANNER, Director
November 16, 1977
Chevrolet Motor Division
General Motors Corp.
100 Fitzgerald Street
Bay City, MI 48706
ATTENTION: Mr. D. R. Koenig, Superintendent, Maintenance and Plant
Engineering
Gentlemen:
Your application (no. 511-77) for Permit to Install polychlorinated
biphenyls (PCBs) oil storage, handling and burning equipment in the three
oil fired Wicks boilers has been voided per your request that this applica-
tion be withdrawn pending further investigation.
We understand that you intend to submit a new application for this
equipment in the near future. The following is a list of information that
is necessary to process a permit to burn PCBs.
1. A scaled plot plan that clearly shows height, length, and width of all
buildings; the height, inside diameter, and location of each boiler
stack; the property lines and any significant terrain features.
2. A management control and record keeping program which performs the
following functions:
a. Indentifies the basis for the acceptance or rejection of each batch
of polychlorinated biphenyl (PCB) waste material.
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Chevrolet Motor Division
November 16, 1977
Page 2
b. Identifies the procedures for analyzing and evaluating each
batch of PCB waste material.
c. Identifies and records the source, chemical composition, and
quantity of each batch of PCB waste material received for
destruction.
d. Identifies the procedures for the picking up of each batch of
PCB material and how the emissions from the pick-up procedures
are controlled.
e. Identifies the procedures for transporting the PCB waste mate-
rial and how the emissions from this operation are controlled,
f. Identifies the procedures for unloading the PCB material and how
the emissions will be controlled during unloading.
g. Identifies the procedures for storing the PCB material and con-
trolling the emissions during the storage phase.
3. A copy of the submitted Pollution Incident Prevention Plan which ad-
dresses the possible spill of pollution materials.
4. A detailed description of how the PCB material will be transferred from
the storage equipment to the boilers and how the material will be in-
jected into the boilers.
5. A description of the means (i.e., ambient monitoring program or other
test program) that will be conducted to ensure that there are no
emissions of PCBs to the atmosphere from the storage and handling of
the material.
6. A description of the security measures that will be undertaken to pro-
tect against vandalism, sabotage, etc.
7. The analysis, the burning rate, and the total quantity of PCB that is to
be burned. Will all three boilers be equipped to burn PCBs at the same
time?
8. A description of the possible fuel combinations (oil, gas, waste oils,
and PCB) that may be burned in any one boiler at the same time.
9. The maximum expected concentration of HC1 in the exhaust gases from
burning PCBs. Please show all calculations of this mass balance.
156
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Chevrolet Motor Division
November 16, 1977
Page 3
10. The calculated retention time of the PCB material in the boiler at a
temperature greater than or equal to 1800 F and 2000 F. Please show
all the calculations used to derive these numbers.
11. The temperature and volumetric flow profile through the boilers and a
description of how this profile was derived.
12. The oxygen content profile for the boiler and a description of how
this profile was obtained.
13. A description of how the PCB flow to the boilers will be continuously
measured and recorded.
14. A description of all of the existing boiler controls that will be used
to monitor the operation of the boiler during the burning of PCB
material.
15. A description of all of the proposed boiler controls that will be added
to monitor the operation of the boiler and the burning of the PCB
material.
16. The normal ranges for the parameters being monitored in items 14 and 15.
17. A description of how the parameters listed in item 16 will be monitored
and how their measurement will initiate automatic shutdown of the in-
troduction of the PCB material into the boiler.
18. A description of the other procedures not outlined above that will be
followed to shut off the supply of PCB material to the boiler. This
description should detail each condition that will initiate a shut
down of the introduction of the PCB material and the mechanisms that
will be used to actually accomplish the shut off of the material.
19. A description of the redundancy that is being designed into each ele-
ment of the control system.
20. A list of the compounds and a description of the procedures that are to
be used to test for these compounds in the exhaust gases from the boil-
ers. The minimum detection level, the collection efficiency of the
sampling train, and the percent of recovery of the collected sample
must also be submitted for the PCB testing procedure.
157
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Chevrolet Motor Division
November 16, 1977
Page 4
21. An analysis of the PCB material that was being burned when the PCB test
was conducted.
22. A description of how the organic halide emissions will be monitored and
recorded on a continuous basis.
23. A description of the expected impact that the burning of the PCB ma-
terials will have on the particulate and opacity emissions from the
boilers.
Thank you for your cooperation. If you have any questions or if you
would like to meet to discuss the items in this letter, please call me at
(517) 373-8630.
Very truly yours,
Gerald L. Avery, Engineer
Permit Unit
Air Quality Division
GLA:jv
cc: Ben White
158
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RETYPED FOR CLARIFICATION
RE-EVALUATION OF MODELING BASED ON WINTER CONDITIONS
Due to the change of seasons in which the PCB destruction testing will
be performed, a re-evaluation of the possible "worst case" air quality impact
was performed to ensure that meteorological conditions occurring during the
winter tests 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.
Maximum Concentrations
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" Stability (slightly
unstable) and long-term mean concentrations based upon 10 hours of "D" (neutral)
Stability.
Tables 1 and 2 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.
PCB Deposition
Using the approach described in the previous (summer) analysis, the PCB
deposition per unit area of ground was computed for a "neutral" plume. These
deposition notes are presented in Table 3. Note that the resulting winter
deposition will be much smaller than the estimates for the summer.
Downwind Concentrations
Table 4 presents the hourly average ground level ambient concentrations
during the conditions that will produce the deposition reported in Table 3
above.
Time-Averaged Maximum Concentration
The concentration resulting from a 2-minute release of PCB was determined
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 yg/m3.
159
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RETYPED FOR CLARIFICATION
TABLE 1. 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 10~" 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 Period = 0.63
No PCB Destruction 0.048 ug/m3
99.9% PCB Destruction 4.8 x 10""* ug/m3
TABLE 2. 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 x 10~3 yg/m3
10 Hour Measurement Concentration will be the same.
160
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RETYPED FOR CLARIFICATION
TABLE 3. PCB DEPOSITION/AREA (WINTER)
Plume sector
(Km)
0 - 0.25
0.25 - 0.50
0.50 - 0.75
0.75 - 1.0
1.0 - 5.0
5.0 - 20.0
10.0 - 50.0
50.0 - 100.0
0 - 100
TABLE 4.
Plume depletion Sector area Deposition
% Grams (102 m2) (ug/m2)
4.0 37.0
2.0 18.5
1.5 13.8
1.5 13.9
11.0 101.7
5.0 46.2
14.0 129.5
8.0 73.9
47.0 434.5
SHORT-TERM PCB GROUND
0.0102 3519.0
0.0274 675.0
0.0462 299.0
0.0666 209.0
3.075
8.6000
224.675
623.500
860.000
33.1
5.37
0.576
0.119
0.505
LEVEL CONCENTRATIONS
AT PLUME SECTOR CUTOFFS (WINTER)
Downwind
distance
(m)
250
500
750
1,000
5,000
10,000
50,000
100,000
PCB concentration
no destruction
(yg/m3)
0.34
0.34
0.23
0.18
0.021
0.0082
0.00088
0.00033
PCB concentration
99.9% destruction
(yg/m3)
4.9 x 10
3.4 x 10
2.3 x 10
1.8 x 10
2.1 x 10
8.2 x 10
8.8 x 10
3.3 x 10
-4
-i*
-4
~"
-5
- 6
- 7
- 7
161
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MICHIGAN ATR POI^tfriOM CONTROL CONS-IIS.
REGARDING THE PCB TEST BURN AT
aiLVROLET-BAY CITY
NOVEMBER 20, 1979
General Motors appreciates the opportunity to speak before the
Michigan Air Pollution Control ComriisGion regarding the PCB test burn
at Chevrolet-Bay City. To start, we would like to make the following
points: 1) We would not support any program that would be dangerous
tc the health of the workers or the community. 2) We believe what we
are proposing is not a health hazard. 3) We are taking steps to
insure that the health of our workers will be protected. 4) And we
are here today seeking a delay so that we can nore clearly explain
this test burn program to the people of Bay City.
In order to give you son? background on why Chevrolet became
involved in this project, it might be helpful if w
-------
~2
on April 9, 1977, did require authorization from the Deportment of
Natural Resources before burning of oils containing 100 ppm of PCB
or nore could occur. Since March of 1977, Chevrolet-Bay City has
not burned any waste oils containing PCBs and has been collecting
these waste oils to the point where 38,000 gallons arc now stored
on its property.
On February 17, 1978, the United States Environmental Protection
Agency promulgated regulations which restricted the disposal of
mixtures containing 500 ppn or more of PCBs. Then on June 7, 1978
the United States Environmental Protection Agency proposed regulations
which governed the manufacturing, processing, distribution in com-
ncrce, and use of ICBs. The proposed regulations changed the defini-
tion of PCB mixture from 500 ppn to 50 ppm and applied this definition
to the narking and disposal requirements promulgated on February 17,
1978.
Or. April 6, 1979, the United States Environmontal Protection
Agency contacted General ftotors and asked if we would be interested in
supplying an industrial boiler which could be used to measure the
destruction efficiency of PCB contaminated oil having concentrations
between 50 and 500 ppm. The reason for this request was that EPA w£is
163
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soon to promulgate regulations (on toy 31, 1979) xvhich would allow
KB contaminated oils with concentrations between 50 and 500 ppm
to be disposed in cither an EPA approved incinerator, an EPA
approved chemical waste landfill or an EPA approved high efficiency
boiler.
Knowing that Chevrolet-Bay City had the appropriate boilers and
quantities of low level PCB waste oil, the Corporation asked Chev-
rolet-Iiay City if it was interested in working with the United States
Environmental Protection Agency. Chevrolet-Boy City agreed, and for
the past several months has been working closely with the Environ-
mental Protection Agency and the Air Ouality Division of the Depart-
ment of Natural Resources to develop a permit application which would
be acceptable to the Michigan Air Pollution Control Conmission and
the residents of Bay City. Towards this end and pursuant to requests
mauc by employes, Chevrolet-Bay City has provided physical exami-
nations, including blood analyses, for all powerhouse boiler operators
who worked in the powerhouse during the previous burning of PCB
contaminated oil.
164
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Although the United States Environmental Protection Agency had approved
and endorsed this test burn program, and the Air Quality Division had indicated
preliminary approval, some citizens from Bay City, along with the Bay City
Commission, and the Bay County Commissioners, have expressed their concern
about the test burn program. Because of this concern and the importance of
this program to the disposal of this persistent substance, General Motors
would like an opportunity to try to answer the citizens' concerns and more
clearly explain why we believe this test burn program presents a more environ-
mentally acceptable method to dispose of this substance than either temporary
storage or landfilling.
Since there are no EPA approved incinerators to dispose of PCB contami-
nated oils with concentrations between 50 and 500 ppm, General Motors' other
alternatives are to either continue to temporarily store the PCB contaminated
waste oil until an incinerator is approved or send this waste oil to a chemical
waste landfill. General Motors, including the management at Chevrolet-Bay
City, strongly believes that this test burn program offers the best technology
with the least risks to dispose of PCB contaminated waste oil. For the above
reasons we would like to ask you to delay action on Chevrolet's permit appli-
cation until the December, 1979 meeting.
165
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PCB - PCB - BAY CITY - November *«, |979
*
QUESTIONS AND ANSWERS;
Question: Despite the fact that all the people you tested seen to be
within the allowable limits, how do you explain why the
powerhouse group ranged higher in PCBs than the non-powerhouse
group?
Answer: We feel that there is enough correlation between PCB blood
levels and high blood fat levels to explain the differences,
especially for the relatively higher readings.
Question: You said you would be doing more blood tests. Will you wait
until you have those in hand before you proceed with the permit
request from the state :or a PCB verification burn?
Answer: No. The additional tests will expand the data base, and provide
reassurance for our other employes.
Question: How many more employes will be given blood tests?
Answer: About 80 people have already volunteered and we feel that is
an adequate nuaber.
Question: You had two laboratories conduct the tests on split samples of
blood. Were the results the same?
166
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QUESTIONS AXD ANSWL.
Page 2 (cont'd.)
,'uiswer: The results we are using are fron the state heclth department
lab, but allowing for calibration variances, the other lab
results closely parallel these. '.\~-.en we do the further tests,
we expect to use only the state lab for the PC3 vcrk.
Question: Do you have any plans nc-v to do fatty tissue sarples?
.Answer: Probably not. We had planned to test fatty tissue satiples
if we found nigh readings aoong cha explores, but since they
are in the "background level" range, ve do not feel the fatty
tissue tests are necessary, unless certain employes request
them.
167
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MICHIGAN DEPARTMENT OF NATURAL RESOURCES
AIR QUALITY DIVISION
STAFF ACTIVITY REPORT
November 20, 1979
Applicant
Chevrolet Motor Division
General Motors Corporation
100 Fitzgerald Street
Bay City, Michigan 48706
Permit to Install No. 484-79
Addendum to October 16. 1979. Staff Activity Report
On June 29, 1979, the staff of the Air Quality Division received from Chevrolet
Motor Division, Bay City Plant, an application for a permit to install equipment
necessary for burning waste oil containing polychlorinated biphenyls (PCS)
1n their exlsltng oil-fired industrial boiler. Based on the data in the appli-
cation, Identified as No. 484-79, and subsequent meetings with the applicant
and other concerned parties, staff had anticipated making a recommendation
to the Commission for approval of this permit application at the October 16,
1979, Commission meeting.
Staff held public hearing 1n Bay City on October 11, 1979, and in Muskegon
on October 16, 1979, in regard to this applicalton. Because of a number of
questions raised at this hearing that could not be Immediately resolved and
because of a request for additional time for review by the Bay City Commission,
staff decided to delay recommendation of this application at the October 16,
1979, Commission meeting until all questions could be resolved.
A list of representative questions have been compiled from the two hearings.
Attached 1s the 11st of these questions and appropriate responses.
Staff intends to discuss this proposal with the Bay City Commission on November 12,
1979. Additionally, this staff report addendum and the attached summary of
the public hearing concerns 1s being sent to all of the people that have expressed
an interest in this application. Based upon staff's October 16, 1979, staff
report and the attached responses, staff intends to recommend approval of
this permit for the verification burn only to the Michigan A1r Pollution Control
Commission on November 20, 1979, subject to the attached revised special condi-
tions, unless new information is presented at the Bay City Commission meeting
or the November 20, 1979, Commission meeting.
Submitted by: John Vial
November 8, 1979
JV:mah
Attachments (2)
168
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BECAUSE OF ILLEGIBLE ORIGINAL, THIS
PAGE HAS BEEN RETYPED FOR CLARIFICATION
Environmental Activities Staff
General Motors Corporation
General Motors Technical Center
Warren, Michigan 48090
November 26, 1979
Mr. Del Rector, Chief
Air Quality Division
Michigan Department of Natural Resources
P.O. Box 30028
Lansing, MI 48909
Dear Mr. Rector:
Re: Response to October 17, 1979 Letter to
Mr. Del Rector from Mr. Morton Sterling, Concerning
the PCB Test Burn at Chevrolet - Bay City
In this letter, we would like to respond to the thirteen questions posed in
the October 17, 1979 correspondence from Mr. Morton Sterling.
1. What effect, if any, will Public Act 64, PA of 1979 (Hazardous Waste
Management Act) have on this application.
Response: It is difficult to define exactly what impact the regulations
pursuant to Act 64, Public Acts of 1979 (Hazardous Waste Management Act)
will have because these regulations are only in the draft stage. Since
it will probably be sometime before these regulations are finalized, we
would not expect any effect on the installation permit for the test burn.
Further, Act 64 will not become effective until 1980.
2. Insufficient information is provided on the intended storage of PCB and
subsequent mixing with fuel oil. How is the ten to one firing ratio
assured? Will there be emission controls fitted on the PCB storage tank
vents? No mention is made of control in the PCB storage area due to
runoffs and leaks.
Response: The ten to one firing ratio will be assured by mixing the
contaminated PCB oil with new oil in a separate batch tank before the
mixture is fed to the boiler. If a throughput of 60,000 gallons of 500
ppm PCB waste oil per year is assumed (actual throughput is expected to
be between 12,000 and 24,000 gallons per year), total vented emissions
will not exceed .65 mg per year. Since this emission rate is extremely
small, we feel that there is no need to control the PCB storage tank
vents. The PCB contaminated oil will be stored in tanks which are
either properly dyked or adequately equipped with sumps so that any
runoffs due to a spill or a leak would be contained.
169
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BECAUSE OF ILLEGIBLE ORIGINAL, THIS
PAGE HAS BEEN RETYPED FOR CLARIFICATION
Mr. Del Rector -2- November 26, 1979
3. Union representatives indicated the PCB waste oils partially originate
from the in-plant sewer system, then are skimmed off at their central
processing facility. Will excessive amounts of PCB's be discharged in-
to the general treatment system and beyond?
Response: The plant's wastewater discharge has been monitored for PCB's.
No problem levels have been detected.
4. Since temperature is considered to be one of the key operating parameters
to assure effective destruction of the PCB, it would seem prudent to in-
clude a continuous monitor for this parameter.
Response: Since flame temperature profile will be measured and verified
prior to the PCB burns while the boiler is operating at a fuel feed rate
of 4 gpm (50% load) and since the 4 gpm fuel feed rate is an operating
condition of the permit, this same temperature profile should exist dur-
ing the PCB burns. As a result, no continuous monitor for temperature
should be needed as long as the other continuous monitoring instruments
are indicating and controlling for optimum boiler combustion conditions.
However, we are looking into the possibility of securing an optical pyro-
meter for the test burn.
5. Will you be requiring any redundancies with respect to key continuous
monitors and the instrumentation panel? It would seem appropriate to do
so.
Response: The boiler combustion parameters will be monitored and con-
trolled. The parameters monitored will be carbon monoxide, excess oxygen,
and opacity, which are all indicators of combustion efficiency. If any
one combustion parameter is violated, the flow of PCB oil to the furnace
will be shut off. In addition, flame conditions will be monitored. If
the flame begins to decay, the flow of PCB contaminated oil to the fur-
nace will be shut off.
The valves which control the flow of PCB contaminated oil to the boiler
are fail safe. The burner solenoid valves will close, shutting off oil
flow, in the event of a loss of control voltage. The pneumatic (air
operated) oil flow control valve will close, shutting off oil flow, in
the event of a loss of compressed air. All of the aforementioned con-
trols are in addition to the other existing furnace controls presently
installed on the boiler.
6. The staff report compared modeled PCB ambient air concentrations with
relation to the TLV. The TLV, I believe, does not consider the carcino-
genicity or mutagenicity effects of the contaminant.
170
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BECAUSE OF ILLEGIBLE ORIGINAL, THIS
PAGE HAS BEEN RETYPED FOR CLARIFICATION
Mr. Del Rector -3- November 26, 1979
Response: The TLV which was the basis for the currently enforceable
Occupational Safety and Health Administration (OSHA) PCB exposure limita-
tions does not take into account the carcinogenic or mutagenic effects
of this contaminant. However, the recommended NIOSH PCB standard of 1
Mg/m did take into account these effects.
7. The staff report indicates that in the previously rejected application
for this project, concern was expressed about hydrogen chloride emissions.
No mention is made in the current application evaluation, and some expla-
nation is necessary as to why these emissions are no longer of concern.
Response: Updated calculations indicate that hydrogen chloride concentra-
tions will be low enough that control will not be necessary. The OSHA
TLV for hydrogen chloride is 5 ppm and the amount being generated by this
test is .8 ppm, calculated as an in-stack concentration.
8. The consultant's test program was planned for mid-August. All of the
modeling undertaken assumed meteorological parameters for this time period.
Since the tests will apparently be undertaken in the winter, should there
be some re-evaluation as to the effects of the changes in meteorological
conditions on the calculated results?
Response: It will not be necessary to re-evaluate the dispersion estimate
based on changes in meteorological conditions during the verification burn.
The analysis conducted by the DNR staff assumes worst case meteorological
conditions, regardless of time or season of the year.
9. In Appendix A, the modeling was undertaken at design operating loads.
The plume rise was almost as great as the actual stack height. General
Motors indicates that the boiler may at times be operated at one-quarter
load; this would ostensibly reduce the plume rise and could cause in-
creases in ground level impacts. Should the consultant be requested to
consider this factor in his evaluation?
Response: The modeling was not done at design operating loads. The
modeling and test procedures are based upon the furnace load correspond-
ing to a fuel oil flow rate of four gallons per minute (50% of full load).
10. In Appendix A, page 32, the consultant indicates the TLV includes carci-
nogenic effects. I believe this is an error.
Response: The TLV for PCB's does not include carcinogenic or mutagenic
effects.
11. In Appendix A, the consultant gives perfunctory consideration to highly
toxic dibenzofurans. The assumption is made that combustion would be
complete, whereas in all other aspects of the permit application, worst
171
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BECAUSE OF ILLEGIBLE ORIGINAL, THIS
PAGE HAS BEEN RETYPED FOR CLARIFICATION
Mr. Del Rector -4- November 26, 1979
case estimates were made. Will dibenzofurans be emitted to partial com-
bustion in any amounts of concern?
Response: The amount of dibenzofurans generated will depend on combus-
tion conditions. Significant amounts of dibenzofurans could be gen-
erated under poor combustion conditions. Maximum theoretical in-stack
concentrations assuming 100% conversion of PCB's to dibenzofurans, are
estimated to be below one part per million. However, since dibenzofurans
are very unstable once they are formed at temperatures above 1,500°F and
since PCB destruction is expected to be at least 99.9%, we project the
in-stack concentrations to be significantly less than one part per bil-
lion. Additionally, the test procedures will quantify the stack con-
centration of dibenzofuran if it is present.
12. There is no mention of requiring a management and waste record-keeping
system. This certainly should be part of the permit requirements.
Response; At this time, the DNR and the public know how much PCB waste
oil is stored and the quantity of PCB's which will be used in the test
burn. When it comes time to apply for a permit-to-operate, Chevrolet-
Bay City will propose a type of management and waste record-keeping
system which would be appropriate.
13. In any final consideration of a permit to install and operate, it would
seem appropriate to have an automatic expiration of the operating permit
after some stipulated period of time; say, six months. At the end of
this period, the results of the experience of the prevous six months
should be reviewed by an outside expert group to assure the agency that
all the expected results are acceptable and to consider desirable modi-
fications to any continuing operating permit.
Response: General Motors would support a DNR sponsored audit of past PCB
burns at any frequency which is deemed reasonable and appropriate. How-
ever, we do not feel that it is necessary to have an automatic expira-
tion of an operating permit since the DNR or the Commission has the
power to revoke any operating permit if a permit condition is not being
met or a Commission rule is being violated.
If you have any further requestions regarding the above response, please con-
tact the writer at 313-575-8609.
Anthony Fisher, Ph.D.
Plant Environment
»
6ARF/1115/D
cc: N. C. Kachman - GM Environmental Activities Staff
D. R. Koenig - Chevrolet - Bay City
M. Sterling - Michigan Air Pollution Control Commission
172
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BECAUSE OF ILLEGIBLE ORIGINAL, THIS
PAGE HAS BEEN RETYPED FOR CLARIFICATION
Environmental Activities Staff
General Motors Corporation
General Motors Technical Center
Warren, Michigan 48090
November 28, 1979
Mr. D. C. Sanchez
MD-62
U.S. Environmental Protection Agency
Research Triangle Park, N. C.
27711
Re: PCB Test Burn at Chevrolet-Bay City
Dear Mr. Sanchez:
As the result of the 30-day permit action delay that was granted General
Motors on November 20, 1979, by the Michigan Air Pollution Control Commission,
the PCB test burn will have to be conducted after the first of the year. This
delay was requested so that we could have the time to address the concerns
of the people and the elected officials in Bay City and Bay County relating
to this test burn.
The EPA has been very supportive through its help and the contracted involve-
ment of GCA Technology in putting together this program for Chevrolet-Bay
City and we would appreciate your continued moral and financial support after
the first of the year when, hopefully, the test burn will take place.
General Motors believes that burning of low level PCBs in high efficiency
boilers would be a positive affordable alternative in dealing with these
wastes. Also, General Motors feels that this approach presents a more en-
vironmentally acceptable method to dispose of this chemical than either tem-
porary storage or landfill.
Again, we would like to express our thanks for EPA's support for the test
burn program during 1979, and we look forward to working with you during 1980.
Sincerely,
Anthony Fisher, Ph.D.
mlj
cc: Mr. J. W. Gunter, EPA-Washington
Mr. D. R. Koenig, Chevrolet-Bay City
173
-------
Bey City PUnt
n
y
December 11, J979
Del Rector, Chief
Air Quality Division
Michigan Dcpt. of Natural
Resources
P.O. Box 30021
Lansing. MI
Dear Mr. Rector:
We would like to request th»t Agenda Item 16 relating to
consideration for obtaining *n installation permit for ft PCD
test burn at the Chevrolet Plant in Bay City not be la Ice n up
at the December 18, 1979 meeting of the Michigan Air
Pollution Control Commission.
Vi'e v/ould appreciate it if this item could be scheduled for
• he February 1980 Commission meeting. In order to save
the Commi.'.r.ion's time for other agenda items, General
Motors docs not plan to present a statement at the: December
meeting relating to the proposed PCD test burn.
Thank you for your patience and support in this matter.
Very t nil y your 'j ,
ft
D. R. KoeMi;;
Plant Engine-e
174
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STATE OF MICHIGAN
j. MMuncct COMMWWON -^jg-f •» POUimoM coirmoi. COMWMMM
WILLIAM Q MH.LIKEN. Oowrnor
DEPARTMENT OF NATURAL RESOURCES ^ u,^
MMUIV M *Mmti HOWAM) A lAIINtn. DlMkltK t*«.« J «•*, > »D
JtlAM t WtHFfe »r»»"—~ *. .. _ »..._^
OHM«.f I O TOUMOtOVt
December 11. 1979 , .
NOTICE OF CANCELLATION
SUBJECT: Chevrolet Motor Division, Bay City. Permit to Install No. 484-79
The Michigan Air Pollution Control Commission had scheduled consideration
of the subject permit application for 11:00 a.m. on Tuesday, December 18,
1979, In Lansing, Michigan; and a copy of that agenda was previously
mailed to all citizens who have expressed an Interest in that permit
application.
Chevrolet Motor Division has been granted their request to be removed
from the Conmission's December agenda, and this matter will tentatively
be scheduled for the Comnission's February 19, 1980, meeting to be
held at Long's Convention Center in Lansing. We will send you a notice
when this matter is rescheduled for Conm1ss1on consideration.
In the meantime, if you have any questions, please feel free to contact
Mr. John V1al or Mr. Gerald Avery 1n this office at (517) 322-1333.
Sincerely,
AIR POLLUTION CONTROL COMMISSION
Delbert Rector
Executive Secretary
DR:mah
175
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CHEVROLET MOTOR DIVISION
General Motors Corporation
fl»y City
100 Fitzgerald
Bay City. Michigan
December 14, 1979
Del Rector, Chief
Ait Quality Division
Michignii Deportment 01
Natural Resources
P.O. Box 30028
Lansing, Michigan 48909
Dear Mr. Rector:
Please find attached, a copy of our Chevrolet Public Relations preen
release of Wednesday, December 12, 1979, concerning our rcquc.st
for a 60-c!ay delay from the Michigan Air Pollution Control Commission
for the PCD test burn permit.
The press release contains the details of our planned program for
the next. 60 days and may be used by you to keep the MAPCC and MDNR
Staff current on this project.
Again, thank you for your patience and support in this matter.
Very truly yours,
D.R. Kounig
Pl
R. KtH>nig /y
DK'tC/t:..-,
end .
176
-------
RESPONSE TO NEWS INQUIRIES CONCERNING PCB BLOOD TEST RESULTS AT
CHEVROLET - BAY CITY
Results of blood tests conducted on 23 employes at Chevrolet - Bay City
indicate that PCB levels for all employes tested are within the range
considered average by the Michigan State Health Department.
Dr. Thomas A. Hockman, the plant's medical director, called the results
"reassuring".
The state health department has -indicated that PCB blood levels for
Michigan citizens can be expected to range between five and AO parts per
billion. (A part per billion can be compared to an ounce of liquid in
7,812,500 gallons of liquid, or about one drop in a tank truck full.
The PCB blood levels for all the Bay City employes tested ranged from
six to 36 parts per billion.
For the 13 employes in the test group who work in the plant's powerhouse,
the range of PCB levels was from seven to 36 parts per billion. For a
group of 10 non-powerhouse employes, the range was from six to 15 parts
per billion.
177
-------
Dr. Hocktnan also said he had observed a "suggestive correlation" between
levels of dietary fats in the blood and blood levels of PCS. He added,
however, that he did not see a conclusive relationship between ?C3 levels
of persons who did and did not eat fish from Sagir.av Bay, but that larger
samples might reveal nore significant correlation with both blood fat and
fish-eating factors.
The plant plans to conduct further blood tests on a wider sa~ple of
employes who have volunteered to be tested.
"We expect the additional tests will further confirm that Chevrolet -
Bay City employes do not have higher ?C3 blood levels than are found in
the Michigan population at large," Hocknan said.
J. Jf }\ J. Jt J..' Ji j: .'i ;; .. ,. ;. ..
r ;; :t it v •> r ;; :• ]/•:,-1; • r ','
178
-------
BECAUSE OF ILLEGIBLE ORIGINAL, THIS
PAGE HAS BEEN RETYPED FOR CLARIFICATION
Prepared by: J. D. Hudgens
Chevrolet
Public Relations
FOR RELEASE: Wednesday, December 12, 1979
Bay City (December 12) — Chevrolet - Bay City has asked the Michigan Air
Pollution Control Commission to postpone until February a decision on the
permit to allow the plant to conduct a test burn of waste oil containing
small amounts of PCBs.
The request was contained in a letter to Del Rector, Chief of the Air Quality
Division of the Department of Natural Resources, from Donald R. Koenig, Plant
Engineer at the Bay City facility, The letter noted that no General Motors
representative would speak on the issue at the Commission's December 18 meeting
as previously scheduled,
In additional comments, Koenig said: "We are aware there are widespread mis-
conceptions about what we are proposing to do. We would like to proceed with
as much support as possible — from our employees, city and county government,
the news media and the public at large, and to do that we need more time,"
Koenig added that in January, plant officials would:
1, Conduct further meetings with plant employees to explain and discuss
the PCB situation at the plant.
2. Hold briefings at the plant for city and county elected officials
and the news media.
3. Conduct further health examination on a group of about 50 employee
volunteers who have not had in-plant exposure to oils containing
PCBs. The testing program will be conducted with the assistance of
the Michigan Department of Health Laboratory.
179
-------
BECAUSE OF ILLEGIBLE ORIGINAL, THIS
PAGE HAS BEEN RETYPED FOR CLARIFICATION
4. Explore the feasibility of meetings with interested outside groups
in the Bay City area, such as service clubs and conservation groups.
Koenig said that the plant still agrees with the EPA that waste oil contain-
ing low levels of PCBs can be burned safely and effectively in high-efficiency
industrial boilers.
"We are convinced that burning the PCBs offers the best way to get rid of
them for all time with minimum risk to everyone concerned. It is a socially
responsible thing to do. We do not want to leave this problem for future
generations," Koenig said.
180
-------
APPENDIX C - PRESS COVERAGE OF PERMIT APPLICATION PROCESS
BAY CITY TIMES
12-13-79
73
• JLi \i
Chevrolet-Bay City
asks state 10
test-burn decson
Hy Jriinn I.ins!r\
Chevrolet-Bay City official., say thcv need more time toconv nice resi-
dents and jjou-i nnienl.il oiiicials of the fo.iMijility of lulling I'fB-
conlaiinii.itod uas.;c nil. a"d are asklni; tt'.u sl.tlc to ticlas ilM!ui:-ii>-.! un
tlic proposed Ic.st until I'rhr.ury.
"1 here arc w nlr«pic.i'1 n ^conceptions i-lxnit what we an |>rnp.i>lni;
to du." sji'l Chevy I'l.iiil M,in,i;:cr lA')i,;il-i !t Koeiii;; "Uc vviv.iid i:kc lo
proceed wilh ;is much s;i|ip')it ;is pus'-'bic (roi'i our cniplir. eo. frum
cit\ i\\A cnti:il\ ti(T.ci!u; c"t ami from ttiMirv. > i>-t!iin v\;is rxpeclcd to
. in, ike a tiiuil decision on !!if tol burn, in A Int.! .linn;! -l.J'i L'.i.'lnn.s of the
oil «(>.ild 1 1" incisvr.iiod . .<.'. its ni'.n!hl\ p'.ri.'tn, > i c \lTiiL-- fJ.iy
Ihi^ il tin- 'ocu;ul (ii'i;i\ !/c;;cr,il "\i >;>..:.•) lia:. rc'f;i:C" tctl. 1 lie fii^t fli
Irtv ,il',o « ;is ;r-'>H'f( f'» lliu ,'Urpo-e of
i-liMi in-; ii[> \Ui,il tin1 c'"i;:p.!ii\ ".ilK'd MUM '•;:.oplif;i!i. ;ilicmt I lie tc^t
«l?if) jtin;;1. tin f(Msil)lll!> of (ii.'.slro.1. ii..i 1'C II ,'!) j'lllll.ll C.IFi. !!.(i(;r,'i .Hid
S'.i^jirckd ti'iiiKin c.
llif COM1| any ;,Nn ;,,i\;, i! •.• ji,|s nimc |i'\c tu conduct fllll'iiM' incdl-
C.il I' si; of |.l.i;it rmplu... i-s ffi !'( Ill \t N
McdlC, ll iL'^Li fl.illi- l'i Url..!'r.t- ,,:;.! \,,- i ', •!), . f'll :,) V.filk'TS n. U jtl'CJ
tli. 1 1 i M, i >:,.;, '\s \\hj v. ,i, i.^,; ri ihc [,;,,•': -, i-^it ,- .-r.^ni. ui^-ro i't i' has
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181
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THE BAY CITYTIMKS S
WEDNESDAY, OCTOBER 3,1579 SLO10NII
00
ators label boiler unsafe for burnin
B\ h-nnn I imicv
Oi1 -ircci turrets nt Bny City Chevrolet which could
"r'on licgtn burning contaminated waste oil are in
{'"[.TtoraUnjjcofifJitlon and inadequate to burn the tox-
i", flame rclardaiit, several operators of the burners
have charged
In a Icltrr to the state Department of Natural Rc-
'nurrcs one boiler operator says the on-site burners
nrcr! -•- J97P to burn some contaminated oil became so
f !">rrrtl wllh residue and debris lli.it .111 explosion al-
Ch'-.rolcl ha^ been granted preliminary approval
fi o.n the DNR lo conduct a "test burn" of the waste
•Ml
The operator, Aiid^c Day, and six other boiler opera-
!r>rs have vrlttca letters ol protest to the DNR and to
\ nifeci Auto Workers Local 3f>2 alleging health risks
miv irsull from b'-rning the PCB-rout ami jKilcd oil.
11": nmpan;. \\i/,ld burn about 430 gallons of oil
.I'll ntg I he l<*~l. If !'i? to si burn is successful, Chevrolet
• r.'jl'i Incinerate t'.ic remainder of the waste oil, left
n\er when ccinpaj v offirlals "purced" the plant of all
In flnrlic oil corlaii-mg PCB
The I Cn-cont uinng oil was remc\cd from the plant
in !! r r-.rlj J3/Ps, ujjcn health rf-ks of I'CU \vtirc un-
f-^vrrc'l
Sn-nc of tlic T! plrc^dy has been burned, while the
"•"U is stored at Chevrolet's wn^tcwalcr treatment
'"f i'Ky, on the plant citr>
JVljrnlor'iiak'l tiphcnyl, or PCE, is a hcal-
i '•'•i^l.Tii1 chemical used in clcrttical equipment as in-
r"',i( -m !' ;s K'tijf, n in cau'.c cancer in animals onxt is
.' •]')".' icJ ,aro -i^'.cn inhuman',
r '"• i,-i>i »:c J I'CB IP hydraulic oil to keep it from
in his I' tier to .h« DNR, Day, a boiler operator at the
i'i\ r-l) plant for lri -, ears, nit! v hen the ci! was
1"'rr'"i i» i(176, before slnct fedcrr.l and slate stand-
-> <'*. m pcrj v "rii into effect, hcavv dainarc to the
i ,,rf,-^rc UILC(; - ],-. (jair.a^c lui not been rcpaucd,
• rri'l •-jto r5.i\ s'cllcr
v, ir1' ' s Ji.'i.^ c'c^ni'd the boiler by '•pr.iyinr sol-
' r>; ui) cr.n; 01 o'lts, then vT'liiri it flown with v ,1-
"This water gets or the worker's clolhlnp. leaks all
over the Moor, tliLr goes into the public sewer
system," Day said
U.iy said certain components of the bofler had lo he
cleaned every two to three days because of residue
plugging them The equipment normally Would have
to be cleaned every six months, he said
"Breaching*;.'' which arc part ot the burner's emis-
sions Mark between the boiler and the outside of the
build in;', bnvc drlciiornUH] 'o badly horn tlic burning
Iti I9?(, Hint heavy fumes coutd (cnk from the bi earn-
ings Into the boiler room, which workers would
breathe, Day's letter says. '
"After the (I97C) test, we tried throughout the year
different ways of burning this waste oil...and it stltl
touted the equipment until we almost had an explosion
and I refused to accept the waste oil for burning," the
Jcltersnys
Day snJd (he burners, which supply process steam to
the plant, arc not intended for Incineration of sub-
stances that like POH require very high heat levels be-
fore thry arc destroyed
"These boilers cannot attain the 2,000 doqrr-c hrat
required lo bum this nil," Day said In addition, the
boiler J-; Imvip.iMt* of maintaining the oil inside lonfj
* enough tod'"Uruy it, he- sild
Chevrolet off'clals firot applied for a permit to burn
the oil In 10(7 intler new state regulations clamping
down on the chemical The company had burned the
waste oil tor about t wo years prior to that
But Chevrolet's application for n permit tinder the
new rules was rejected by the DNIl because the boiler
did not meet specifications in the law for burning.
Although DNR officials now say the boiler meets
requirements, Day and the other operators claim the
burner is In worse condition than It was when the first
permit was denied
.Tohn Vial, DNR air quality engineer, said company
officials have n^urcd htm the burncis arc capable ol
destroying Die TCI5
"We have had a number of meetings with Chevrolet
officldls and they never Indicated there were any opcr-
ationai problems with the boilers," Via! said
Vial said he also Inspected the toiler, and it ap-
peared tobe In "very good condition "
"We're putting very strict limitations on the opera-
tion of the boilers to make sure the combustion effi-
ciency is maintained," he said.
When the first permit was denied, Chevrolet had not
met refinements for temperature and "dwell time,"
or the length of time the oil is in the boiler, he said
'I hose requirements have been met now
Vial said c'.ii licr that special equipment capable of
mcasuilni' minute quantities of, PCB would be In-
stalled on the boiler, but William Gunter, of the Envi-
ronmental Pi election Agency's toxic :,ubstanccs office
in Washington D C , said there is no real way to moni-
tor directly for the chemical.
Oct. 11 Bay City hearing on PCB burning
The Department of Natiir.iJ Resources fm
decided at (he last niimitc lo hold a hi.1 ring
Oct. 11 in !?a> Citv ol\ the proposed burning of
PfJJ-cofiianiinated ivasle 01! !;v Chci rnlrl.
St.ite Hip. lames A. B.ircia, D-Ba> Citv.
icporicdlv confuted Hie an pollution conirol
comini'i'.io'i 1 'tc 1,'st ivcrU In a-jU ^hv only ,nt
Oit. U» liv.iriiL'. :n Mtisls('i,on lkM;1iis, «js
1 he commission then agreed to schedule the
B,n City hearing.
The Jicarnif: oripifjnJIy Has .scheduled for
Muskmon llci|;lils because thai is Hie localion
lur t'le ,nr poll ill ion conl rol com mission's rcRu-
lu i)HTin)«, ,s,iir] John Vi.il, DNK (jua)ity cnci-
n.'ir. I h.it iK-aTiHK sl ill will lie held, he s-ud.
"It's kind of hard to monitor foi PC'B, Lut \\ e u->e oth-
er indicators to measure how \\cll !s It's being
burned," Gunter said.
He said the Chevrolet test-bum .s ore of cnfy two
such experiments in the country being dist-ii^ctl by
the EPA.
The other one, a proposed incinciation i^pmmcnt
In Sanford, Fla., is only in the tlisrusMrn ^t-ifc1;, he
said i,
Final approval of the tcr,t hv (lie Altchipnt! \ir Pollu-
tion Control Commission, part of t(K UfVKMiL quaiity
division, hlnpcs on n. public coilihicui pc: to't, «md pub-
lic hearings In Bay City Oct. 11, iind Muskcjion HcigMs
Oct. 16.
Manufacture of PCB has bcl!i\ banned t;ot*i at the
state and federal levels, and boln have placed mu! i ols
on use, distribution and disport o( cxisUnp PC11 m an
effort to phase it out completely
The chemical, used In many tyrrs of flcclrlcal
equipment, also Is used In paints fmd pi^nrnl*;
Waste oil containing tlic chcnilc.il has lu,^n i scd as a
sealant, herbicide carrier and dust control nj:enl on
roads, but those uses have been h.mivd h> 1'ie 'JTA
LPA officials arc more wary ot PCB-cnoi i.nnt i'cd
waste oil because they arc notasccr'c!ls rc\v is
conducting an experimental buhi of electrical trans-
former fluid containing PCB, he sa id
But Chevrolet's incineration test \\ ill be the first us-
ing waste oil, if the similar project tcmy d'.v^jssed in
Florida isn't started first, he said
General Motors spokesman David Hurl^cns M-d fhc
amounts of PCB mtlicoil arc so .small lint tl:cu- incin-
eration shouldn't cause concern
Uc said Uic burner should rcn-ovc T.nr: Unn 3T p:r-
cent of Liic chemical from the oil, nrd (,-tit n\\\y trrcr*
ritr,ounir.p;o':ablY"'i)l escape 'n'o '1 < -ur
-------
CONT-.C7: J-B- H
313-766-1565
10-9-79
BACKGROUND-- PROPOSED BURN Or ?C3 COSTAXIN'ATID Oil,
AT CHEVROLET SAY CITY
Chevrolet Motor Division, Cer.eral Motors Corporation, is ceope:=tinj
with the U.S. Environmental Protection Agency (EPA) in a test rrogras to
confira that waste oil containing snail anoints of the toxic fire retardant
chenical, polychlorinated biphenyl (PCS) can be burned effective'/ and
safely in high efficiency industrial boilers.
At the request of the EPA, the Chevrolet Bay City plan: applied in
June to the Michigan Department of Natural Resources (DXR) fcr s. permit to
conduct a verification burn of the wa-^te oil.
The PCBs in the oil . ~e residual arcunts fro- prior years, vhei the
plant used the chenical in its hydraulic systexs. The chenical has r.ot
been used'in plant operations since 19"4, when all plant systens containing
PCB were purged.
Other test results and scientific analysis indicate that under :he proper
conditions more than 99.9 percent of the PCB in the oil will be destroyed in
the burning process.
Government officials and industry leaders are anxious to confirm that PCB
can be disposed of safely in industrial boilers. If the tests at Chevrolet
Bay City are successful, PCB contaninated oil could be burned safely in other
areas of the country, limiting the amounts of the toxic chemical to be buried
in landfills. In addition, burning the waste oil would mean that less precious
"new oil" would be used.
-nore-
184
-------
Chevrolet's permit request was prepared with the help of the EPA, the DN'R
and GCA Technology Corporation, Bedford, :'-£ss., an EPA Contractor. GCA
actually" will conduct and monitor the test bum, with the assistance of
plant personnel and engineers from the EFA and ?!."?..
Guidelines for the proposed test specify stringent a?.d comprehensive controls
for the verification bum, including a 10:1 ratio of new oil t waste oil, and
continuous monitoring of the conbustioa process and of fuel flow. The boiler
to be used in the test—boiler -12— will be equipped with sophisticated safety
systems, including fail-safe capabilities.
185
-------
BAY CITY TIMES 10-10-79
• 1 .'. Q Gc-norrll .'o'lccs
ATTENTION
ALL U A V,'.
/,', E V. L>E k S
: HELP
!. PROTECT
YC'Jf I"-"*1'."' f '.•)-• re
fr.oi L :T
P C !i IK rr.'r.g
Ai Dae <• ny
I Chcvrcitt
IS Kf.'O.VN
: CANCER
I IMP ATS
AMD IS
ASUSPf.CTEO
HUMAN
CARCINOOCM
I
Day Counly
U.AV/.
i Cornr.iunily Aclicn
Proc)r^rn Council
STRCrx'GLY
URGE
REQUEST
THAT YOU AMD YOUR
I-A/.'.ILY /.',AKC CVCHY
poss.ir.ic CFKO;''UMlT Y
CCUTIIR
186
-------
TODAY
TOMORROW
TOGETHER
October 10, 1979
Jan Turner, Editor, Ext. 229
Specia] Issue
The following Information IB being provided to
Chevrolet-Bay City employes as a background on a subject
which has recently received local att'entlon
SUBJECT: PROPOSED BURN, OF PCB CONTAMINATED OIL AT CHEVROLET-BAY CITY
Chevrolet Motor Division, General Motors Corporation, is cooperating with
the U.S. Environmental Protection Agency (EPA) in a test program to confirm
that waste oil containing small amounts of the toxic fire rctardant chcmic.il,
polychlorinated biphenyl (PCB) can be burned effectively and safely in high
efficiency industrial boilers.
At the request of the EPA, the Chevrolet-Bay City plant applied Lr. J'--.e
to the Michigan Department of Natural Resources (DNR) for a permit to con-
duct a verification burn of the waste oil.
The PCBs in the oil are residual amounts from prior years, when the plant
used the chemical in its hydraulic systems. The chemical has not been used
in plant operations since 197-1, when all plant systems containing PCB were
purged.
Other test results and scientific analysis indicate that uiulcr the proper
conditions more than 99.9 percent of the PCB in the oil will be destroyed in
the burning process.
Government officials and industry leaders are anxious to confirm that PCB
can be disposed of safely in industrial boilers. If the tests at Chevrolet-
Bay City are successful, PCB contaminated oil could be burned safely in other
areas of the country, limiting the amounts of the toxic chemical to be buried
in landfills. In addition, burning the waste oil would mean that 1'ess precio
"new oil" would be used.
Chevrolet's permit request was prepared with the help of the EPA, the DNR
and GCA Technology Corporation, Bedford, Mass., and EPA Contractor. GCA
actually will conduct and monitor the test burn, with the assistance of plant
personnel and engineers from the EPA and DNR.
Guidelines for the proposed test specify stringent and comprehensive conti
for the verification burn, including a 10:1 ratio of new oil to waste oil, ai
continuous monitoring of the combustion process and fuel flow. The boiler ti
be used in the test--boiler /f3-- will be equipped with sophist ica ted safety
systems, including fail-safe capabilities.
187
-------
local
THEBAYClTYTlMES
THURSDAY, OCTOBER II, 1979
SECTION B
Hearing today on Chevrolet request to burn PCB
The state Department o( Natural
Resources will hold a public hear-
ing tonight on an experimental Ui-
H- clncratlon of PCB-contamlnatod
Oo waste oil at Bay City Chevrolet.
00 The hearing will be at 7 30 p m.
In the county building, North Madi-
son and Center avenues
The Environmental Protection
Agency is backing General Motors
Corp '1 request lor state permis-
sion to burn the toxic heat-resistant
chemical.
Chevrolet officials have received
preliminary approval from the
Michigan Air Pollution Control
Commission and the regional EPA
office In Chicago to conduct a
"test-burn" of about 430 gallons of
hydraulic waste oil containing
PCB, or polychlortnated blphenyl
If the commission approves the
request, the Bay City plant would
be the only sit* In the Midwest and
one of only two such experiments
being discussed by the EPA
A CM spokesman said an EPA of-
ficial suggested In April that the
company dispose of the chemical
by Incinerating It in an Industrial
boiler capable of reaching high
temperatures.
EPA officials have said they In-
tend to use the Bay City-plant as a
pilot project to prove the feasibility
of burning hundreds of millions of
pounds of the chemical now In stor-
age around the country.
There are about 40.000 gallons of
PCB-conUmlnated oil now being
stored on the plant site It was re-
moved from plant operations when
of adverse health effects were re-
vealed elsewhere In the early 1970s.
PCB has been linked to birth de-
focts. neurological disorders, skin
diseases and cancer It has been
used as a coolant In electrical
transformers and In oil to keep It
from overheating
Chevrolet's Incineration, if ap-
proved, will be the first using waste
oil, if a similar project hi Florida
Isn't started first, said EPA spokes-
man William Guntcr
The only other facility burning
the chemical Is a General Electric
plant In Lynn, Mass, which is in-
cinerating electric transformer flu-
id
However, the EPA is more wary
of waste oil, and has placed stricter
requirements on its disposal
-------
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-------
The Flint Journal, Thursday, October 11, 1979
EPA backs request
n
to burn toxic PC
LANSING (UPl) — The Err. iron-
menial Protection Acency is bacUng
Gercral Motors' recast lor slate
permission to burn tr.e toxic fire
reiardant chemical PCB at its
Chevrolet plant in Bay City.
The state A;r Pollution Control
Commission w,!l hold a public
hearing on the request tonight in Bay
City. It is expected ;o vote on the
issue during its t«o-dcy meeting in
Muskegon beginning Monday.
I' the commission approves the
request, the Bay City plant would be
the only site in tie Midwest and one
of only four in the country authorized
to burn PCB — polychlonnated
biphenyl.
A GM spokesman said an EPA
official suggested in April that the
automaker dispose of the chemical
by incinerating it in an industrial
boiler capable of reaching high
temperatures.
EPA officials have said they
intend to use the Bay City plant as a
pilot project to prove the feasibility
of burning hundreds of millions of
pounds of the chemical now in
storage around the country.
There are 38,000 gallons of waste
oil containing between 50 and 500
parts of PCB per million stored in
tanks on the Chevrolet plant grounds.
The chemical is similar to PBB, the
fire rctsrdant responsible for
Michigan's ;r.Hle feed disaster.
PCB, certified ar- harmful to
humans and virtually .ndestructible
in nature, in the past was used as a
coolant and fire retardant. The EPA
banned the use of the chemical
earlier this year.
PCB has been linked to birth
defects, neurological disorders, skin
diseases and cancer.
Although GM and the EPA are
ready to go ahead with the
incineration project, many Chevrolet
workers and residents around the
plant are prepared to oppose it
John Vial, an air quality
engineeer with the state Department
of Natural Resources, said closely
mor.itored "test burns" would be
cere c-er 2 '..'ree-day penod at tie
Ha;. C:~> p.an: if trie commiLiion
app.-O'.es
The :c-5is "O'jld be conducted by
a pr.vste ;es:.r:g firm under the
super. :s.:n c' ::.e EPA and trie DNR,
a CM sp:Kes-an said. If the tests
sho» tan at least 99.9 percent of the
chemical is destroyed, GM would
then ask tie commission for a
long-term
190
-------
1 .SIM Y, OCTOBER 16, 1979
delayed
The Michigan Air Pollution Con-
liol C'ommission will delay a dcci-
MMI on a proposed test incineration
by Bay City Chevrolet of the cancer-
causing chemical PCIi until Nov. 20
t,- r;m ,f of questions raised at a
heating in Bay City Oct. 11, commis-
sion nieinher John Vial said today.
The commission had intended to
make a final decision on whether to
piant a permit for the experiment
after its monthly meeting today in
Mu^kcgon Heights
But Vial said qu< slinns raised at
last week's hearing have forced
commission members to consider
changing the permit process to allow
more public input
The commission originally had
planned to allow Chevrolet to con-
duct an initial test-burn of waste oil
containing the toxic heat resistant
chemical polyclilormatctl hiphenyl,
then decide whether to let the com-
pany burn additional waste oil, with-
out necessarily hnk.'mg public hear-
ings in between.
But now the commission probably
will hold more public hearings after
the test burn, Vinl said.
"It was our intvnt when we issued
this permit to analyze the results of
the test burn ourselves, but now the
results of the test will he subject to
another public comment period,"
Vial said.
About 100 jirrsons attended the
Bay City hearing on the incineration
proposal.
Chevrolet applied in July for ji per-
mit to incinerate about-10,000 gallons
of PCB-eoiit.imip.ated waste, oil. The
test burn will dispose of about !30
gallons of tho oil. The rest is being
stored on the plant site.
191
-------
1C7C
--•-
LANSING - (U?l; - -a::cn :f cc-duc:;d Any ccrtinucus FC3
A rrcpcsed s'.i'.e perr.:t trcperl},' the £5so:.3- burr.irc operat;:a
clicu'.r.g Genera! Meters 'uc^ ss:d. "ihc-!d be 'Juder an e^-
to burn highly tcx:cPC3 Ho^evsr. it sa-.c, tie v.reiy separate permit,"
tt :;$ Chevrolet :!c^; 12 prc/c-tc :>ern:t "t'.lc-'S thes^ociiiicnf^ii
Eiy City v.-as cr:tic^:ed ;';.- cczii^uous PC3 PC3 is a clerical fire
yesterday by the A^eri- v.aste i-:n:cg en £n recreant cc- jo^Iy
c£nLur.gAsso-::£-jon. c'e:.:.? risis a'ter the used as an izsuleti-g
The stcte Air Pollu- \er:f::it.:a burn uncer f.u:c :n beavy-cut)' eiec-
t.cn Control Cc~.r.:s- c£r:;:i ::2d;:i:r.£." trie:! equipr.ert
s:cn v, a? to s:jcv the
„-,.-, in-1'" ~'\'" - ' f- ' -
... t. t , »i LC1- J_> U o . ..^ * . - u
decision is ex;p-:c;ec fcr
several \veeks
• The cssociatic.n said ;:
supports the concept of a
limited "\er:f:catior.
burn" of PCB-coDtar.:-
r.ated oils, but believes
the proposed perau cor.-
tains too few safeguards.
"V)'e believe that c
limited short-term veri-
fication burn of PCB
waste oils wouldn't pose
a threat to the health
and safety of Bay City
residents and it would
yield much, useful infor-
192
-------
MICHIGAN PRESS READING SERVICE
11-7-79
Dilution experts to field test question
i,- Michigan Air Pollution Con-
Commibsion will attend Mon-
', I ity Commission meeting to
' ,-i- uliesttoris from elected offl-
\ and fiti7,ens about a planned
r". meratlim of waste oil con-
iin.Ueil with PCB at the Bay
i rnevrolctpiant
- in Vial. • ommi5siQnjut_rubeC>
said the commission is attending
the meeting because of concern
raised by city officials last month
about the uff?cts of the incineration
on local residents
The Bay City Commission re-
quested that the air pollution con-
trol comm.-ssion. a branch of the
Department of Natural Resource:,.
delay any final decision on the burn
until at least riid-November.
The air pollution commission is
scheduled to make its decision at
Its monthly meeting Nov 20
- Bay City Chevrolet has applied
for a permit to burn about 4:iu gal-
lons of the oil in a special tes-t to see
if it can be safely incinerated
10-9-79
PAIR COMMISSION "
'TO HEAR PCB
INCINERATION 'PROPOSAL
LaiinlnH — TVttimom liom t\'o
.1-1 bhc hun inns i>n a pi 'jx ^tcl PC1'
inriiici riuou piojcct -uill hi1 co.is.d-
cjii'tl by tllr Midi.fim Air Pollution
Jng Us monthly mcctinc at Holly's
nl tile Inn, 34M Hoyl Stu.'t, Jlus-
kiwn Hi.i;hts Tlu' --i-,-™- M il
b •!.„ .it 7 'O p:r Oi!f,',,"i n sin.l
conti'iu" the lull. \ "n .: iv bij1 n-
i' r-r.ill'l'i i ri 11; --
I ''.! I .• ;,".;, l.i .
•,>n .in.l •-.> i h l!i. •.,
H i;nik Mot-ir H"
Flint, .iiul t'.f M i.-
tin-M.iiitUa Cmpui.- tu. i, M i'ii',i •
IlliT'L' cont|i,ip.n"; .i;«' ^_il\nv^ ex-
tensions (d Mllplll.J illllMlll' CO'Il-
iili,iii(,r ])M ^i .i.ns Ii -un tin- t :)in
iri.s-i'm N'itth"in Mi tnL''n I'l''<--[
luc f'no;-i'iali\" ol r,o\,ii' Cil\ i-
r
10-16-79
l ?•< disposal
•. \ ,ivr, (UPT. .— The
"'\,in Luny A&-'jcintiori
IH , I'i.in Mondav .cntiei7-
,. in npn^'-ii -,r,ilc p( rrnit
, in,' (• .'n-'- 11 M t>!oi s
. |,i liii. n hi.Mlv lii\K
•; ;-. ; l-i ., .il. ' 'i -. -...n
! Ill li,i\ ( ,l\
- : i! e Xil l'i)l!ut ion Con-
v 'i ,1 m ISM.M 'Ca-. 10 studv
"i.,i ITT i ues-ri.T v but no
' II-CIM-IM \. as e \pected at
, i -ne
...>soi i.ition s-nid it sup-
' n.. c i.r.cf;)) nf a limited
i 'li'-.itinn burn' 01 h'CB
' i -M i ,1 T t ed oi\ *, hut
.•, ihe pioposed permit
.,;' - 'no fi>-.v ^.itegll.lrds
lO-lb-79
ALA against PCB burn
7-V' '•'' '
!.'\NMNl' UIPII — Th» American l.iuiu Association
of Michigan Monday criliciml a proposed state permit
!,lli,-imi Ceneral Moloi-, Corp lo bum highly toxic
\\ li.it 'lUiChevinlel division planl in H.ivCily
I V 1 ' •
'lll<
llllllll
lni< 1
si ill' Air Pollution Conln
Hi., in.it'.i-i Tiie.d iv 'ml
led it lli.il lime
•is'.ix i.ilion said it sup|x
,1 "vend' .iti'iii liurn" ot P
elieves (he proposed per
I c oimnissioii was lo
m final dei ision was
rls the (onccpl ol a
Tt colil'imiii.lled oil >,
nil conlains loo few
S''"\Veah"lipve thai a hmiled shoil-terni verification
Imin of PCI1 waste oils wouldn't pose a tno-al lo Uie
Ivillh -in.! vilely of liay City n-,i
-------
THE BAY CITY TIMES
«-A WEDNESDAY, OCTOBER 17, 1919
Bay City 'show'
gets results
on PCB plan
Bay tlty pot
iiniiii (fmt ifliiiui tu^pm irtai IHKHHHIII
t itaMardaAhlcli cam later. Tl»
lcft4H|N4pBUi6jM
'
.
feve MMtd Me «r p*
•the commission «alh/ intended to make * decision on Its own aft-
tr tne MM u to wmdier Cocnotet i^HM be aurrad to bun tb. «U « a
«mUnuou« Baste.
MK alter a public hearing In timtegon Heighti Tuesday.
' "Tbis )« necesaary . They're going to have to go back and find answers
to some of these questions," said Lyle Miller, diairmah of tbe United
3uto Workers bargaining committee at Chevrolet.
MilleV, woo attended both public hearing*, aald he plans, to file a peti-
tion to intervene in the commission's permit proceeding because he
ttetott waMlone illegally.
Miner s*ys the commission's original scheduling of the bearing out-
(Me Bay City was Improper under state administrative procedures
taws. The commission at first set the oMy bearing tot Muskegon
Heights.
The commission'* mgatk-kng delay also will give Bay City officials
time to think overttM proposal to burn the chemical
• 'Our concern has beaHhat Bay Ctty not become a regional burn slU
for these oils," said Ctty Manager pa vid Barnes.
EPA officials said it is not their intent to use tbe Chevy plant as a re-
gional Incineration sit*, but to see If the disposal method works here,
and if it does, other Industrial plants with PCs-contaminated oil ac-
cumulated at their fadiitlas can begin to dlspoee of It.
Gerald Avery, a member of (be pollution commission, said, "I sus-
pect that we'll be recommending approval" of the test burn, but that the
commission will first have to be assured by tb* company that workers
will not be exposed to high levels of PCB, and tnat there will be continu-
ous monitoring of tbe temperature Mljde tbe boilers. PCB is a heat-
resistant chemical and thus requires Sigh temperatures for destruc-
tion.
Avery said after the test burn, the commission wID conduct more pub-
lic hearings and possibly require Chevrolet to submit a new application
to bum the rest of tbe oil on the site. There are about 40,000 gallons of
contaminated waste oil on the site which must be disposed of
Jones, who says he's been to many public hearings In the past, thinks
it's unusual that the commission changed the permit proceeding
' "They never expected that kind of response from the public," he said
194
-------
MICHIGAN PHESS
RIDING SERVICE
Bc handles tt and
its potential ns'tto t_vie cuniiuumty."
/'Bio-accumulation" moans that the
'human body cannot nd tbclf tit the
chemical alter exuosure, Avery ex'
plained Cor,i*qiJ«fU!>, continued ex-
posure causes the t-heinic.il to bii'ld up,
hebaid
.ep'..
-itu'(.in*je! I'JH, the commission
r KI\! to it up t':e burning because
ulcdse ut PCBs mtn the air Since
, 'nrmsaifn older, GM has stored
,'illf-rii of contaminated oil at the
Lij> jppheo for a pemu' to conduct
-i\-t, *ur twt burns at the Hay City
1 'ie company wauls to burn the
i MICHIGAN PRESS
_ READING SERVICE
p cTiox 11,Williaratw, Mxh. *8895.
DETROIT, Ml
NEWS ' •
E-633,708, S-826.Hl/y>
OCT-17
statedelayslest-burning of PCB
NfUSKEGOV HEIGHTS - (AP) — The problem of
PCS buildup in humans "must be addressed" be-
fore cil contaminated by the suspected cancer
caustr cap be burned, a state official said yester-
Several questions must be answered before the
Vich^na Air pollution Control.Commission will
cpprcve a test burn by General Motors Corp. at its
Bay City plant, said Delbert Rector, the commis-
sion's executive secretary
"We donl have all the answers yet," Rector said
at a public hearing in Musfcegon Heights, "but we
hope to have these issues resolved by next month's
meeting
"We have to answer in a better farhion the bio-
accumulation of PCB We have to leara how the
body handles it and its potential risi to the cos-..
munit}"
"Bicwccumulation" means that the humujbody
cannot nd itself of the chemical after **v°*"*
IConsequenOy, continued exposure cajso t_e
PCS, or polychlorinated b!pher.yl, is a highly
toxic chemical used in heat insulation systems. It
is kcown to cause cancer in laboratory ammals
and is suspected of causing cancer in humans.
Insulation in transformers and other equipment
of the Bay City Chevrolet Motors Division plant
contain PCB Oil circulated through that equip-
ment became contaminated and for approximately
two years, the oil was burned in a boiler at the
plant.
In September, 1977. the commission ordered GM
to stop the burning because of the release of PCB's
in'.o the air Since the commission order, GU hu
stored 38,000 gallons of contaminated oil at the
site.
GM has applied for a permit to condnct three six-
hour test burns at the Bay City plant The company
wants to burn the contaminated oil after it has
been diluted with fuel oil
Currently, oil and other material contaminated
by PCE has to be buned in landfills or burned in a
195
-------
') 30* H,Willi,..!is;on, Mien 46
ST. JOSEPH, Ml .
HERALD PALLADIUM
E-35,791 •
OCT-17-7?
Answers
Is Burned
TyBKI-VNTUCKEK
•-•.-.oUdiWi I*Tf>i VV'ritiT
lU.KLGON HEIGHTS
' i, \P) — Before slate of-
;•> wiil allow tne burning
'. B-cunlarrJiiat*"d oil, the
iiem of the suspected
,-r causer's buildup in
i > i.is must be
. ' v^ed, a state official
M-rru questions still face
\r,iiu^an Air Pollution
. v'l x-oinmi^Wrt^hicfi ;s
-'flr'iifie an application for
-' bun bv General Motors
at its Bav Cit> plant
1 Tl- Iber! R?L'!ur, the com-
•- M-) a executive secretary
"We don't have at! (he
answers yet," Rector said at a
public heani'g Tuesday in
Muskegon Heights, but we
hope to hav e these issues
resolved by next month's
meeting "
PCB or poK chlorinated
biphenvl, is a highly toxic
chemical used in heat insula-
tion s>stems It is known to
cause cancer in laboratory
animals and is suspected *.o
cause cancer in humans, ac-
cotdmg to Jerr>' Avery of the
Department of Natural
Resources dir quality division
Insulation in transformers
and other equipment of the
Bay Citj Chevrolet Motors
Division plant contain PCB
Oil circulated througn that
equipment became con-
taminated and for
approximately two >ears, the
oil was burned in a toiler at
the plant
In September 1977, the
commission ordered DM to
stop the burning because of
the release of PCBsrmto the
air S:r.ce the cuni/niasii»n
order, GM has stored 38,000
gallons 01 contaminated oil at
the sue
GM has applied for a perrr.it
to conduct three six-hour test
burns at the Bay Cit> plant
The company wants to burn
the contaminated oil after it
has been diluted with fuel oil
The PCB levels of the oil and
the resulting emissions from
the boiler's stack would be
carefu!l> monitored, one GM
official said
"All we're, trying to do is
come up with a sa/e and more
cost effective alternative to
handle PCB," said Anthony
Fisher, a scientist in GM's air
pollution control department
Current!), oil and other
material contaminated by
PCB has to be buried in land-
fills or burned in a special in-
cinerator Both methods are
extremelj costly. Fisher said
"I don't want to see that
plant closed down," said Lyle
Miller, chairman of the United
Auto Workers bargaining
committee at the plant "That
plant is a living for close to
-1,000 people We just want to
know whether or not destruc-
tion (of the PCBs) "ill be 99 9
percent, like the state wants "
"We are facing several is-
sues that we need to take a
look at before next month's
meeting,",Rector said "We
need to know what tempera-
ture the boiler is able to
maintain, and what will be
done with the waste inside,
whether residuals would stay
in the boiler that workers will
be exposed to.
"But w* have to answer in a
better fashion the bio-ac-
cumulation of PCB We have
to learn how the body handles
it and its potential risk to the
community" -
"Bio-accumulation" means
that the human body cannot
nd itself of the chemical after
exposure, Avery explained.
Consequently, continued ex-
posure causes i!if chemical to
build up, he said
MICHIGAN PRESS -
READING SERVICE
PO Box ll.WiMwmston. Mtth. 48895
GRAND RAPIDS, Ml
PRESS
M 25,669;
OCT-17-T9
PCB Buildup
At Issue in GM
Bid to Burn Oil
~
MUSKEGON HEIGHTS (AP) —
Before state officials will allow the
turning of P<~B-contaminated oil, the
problem of the suspected cancer
causer's buildup in humans "must be
addressed," a state official says. , ,
Several questions still face Uie
Mictugan Air Pollution Control Com-
mission, wnicti is considering an ap-
plication for a test burn by General
Motors Corp. at Its Bay City plaat,
said Deibert Rector, the comm!*, ',
sion's executive secretary. -:"„* .
"We don't have all the answers
yet," Rector said at a public heariagj
Tuesday in Muskegon Heights, "but ;
we hope to have these issues resolved]
by next month's meeting." 55^
PCB, or polychlorinated blpheny
is a highly toxic chemical used- 1
Seat insulation systems. It is know
cause cancer in laboratory anm
and is suspected to cause cancel
humans, according to Jerry Avert
the Department of Natural
sources air quality division.
Insulation in transformers and I
er equipment of the Bay City Chel
let Motors Division plant conl
PCB. Oil circulated through
equipment became contamlnd
and for approximately two years. I
oil was burned in a boiler «t the pij
In September 1977. the cornj
sion ordered GM to stop M"™
because of the release of £
the air. Since the commission ora««.
GM has stored 38.000 gallons of con-
taminated oil at the site. - /
GM has applied for a permit to co»
duct three six-hour test buna O. U*
Bay City plant
196
-------
Thursday, November 1, 1979 - THE DETROIT NEUS
PCB's Are Not Easy To Dump
, By TED DOUGLAS
N«wi Editorial Wriur
Members of tfce Michigan Air
Pollution Control Commission
(MAPCC) face a serious technical
and moral dilemma: how to safely
dispose of PCB materials stored at a
Bay City plant of General Motors.
The commissioners are not to be
envied the decision they face.
PCB's (poly-
chlorinated bi-
pbenyls) are used
as an additive for
coolant oils used
in electrical trans-
formers and
machinery
hydraulic fluids,
where heat is a
problem.
PCB's have been
in use for & Rood Douglas
many years and were thought to be
innocent However, science now tells
us that the the chemical causes can-
cer in laboratory animals, and may
cause cancer in humans.
Further, PCB's have a tendency to
"cling." A hydraulic system can be
purged of PCB-laden oil and refilled
with fresh oil several times, yet
traces of PCB can still be found. The
stuff is difficult to flush.
ARE DANGERS in stor-
ing the material. Over time, barrels
may corrode and leak; or containers
might be broached in a natural disas-
ter. Federal law seeks to prevent the
latter event by stipulating that
storage must be on ground above the
100-year flood plane.
The Environmental Pr tection Ag-
ency (EPA), which has t reputation
for toughness in these matters,
recommends three disposal methods:
I. Burial in a toxic chemical dispos-
al site.
1 Incineration in a high-efficiency
industrial boiler if the content is be-
tween SO and 500 parts per million in
oil.
3. Burning in an expensive special
incinerator if the concentration is
greater than 500 parts per million.
Michigan has no such incinerator.
GM applied for a permit for three
six-hour test burns in if high effi-
ciency boiler, which meets the re-
quirements of the EPA: TV- material
would burn at 2,912 degrees Fahren-
heit, with no less than 3 percent
excess oxygen in the stack to
guarantee full oxidation of the
material.
The fluids containing PCB would
be diluted with the fuel oil that is fed
to the boiler. Using this method, the
EPA says, 99.9 percent of the chemi-
cal would be destroyed, in the GM
case.
The Michigan commission must de-
cide whether a test burn is to be al-
lowed. It balked at its last meeting
and an official said there are still
questions that must be answered: like
the specific and sustained operating
temperature of GM's boiler, as well M
some medical information on bio-
accumulation; and rates of buildup of
the chemical in humans.
Even if EPA is satisfied with boiler
incineration, the commission has lin-
gering and persistent doubts.
GM, sensitive to this, has not asked
to dispose of all 38,000 gallons at once
but, rather, for a test burn that can
be strictly monitored and the results
reviewed.
The alternative is to mix the PCB-
laden fluids with soils (they tend to
cling to dirt) and bury them in a pit
with the right kind of bottom and
sides, preferably impermeable hard
pan clay. Even with the utmost care,
it is difficult to guarantee that the
material will never, ever get into the
water table.
TH1 ISSUE comes dewn to tvro
choices: do nothing or try something.
There are risks in both. Long-term
storage can result in accidents. Pit
disposal and incineration carry no
100 percent guarantee that 100 per-
cent of the chemical will disappear
forever.
The commission must try some-
thing, or the problem will never be
solved. Boiler incineration seems to
offer the best technology with the
least risk. One small test burn, care-
fully monitored, will disclose pretty
quickly whether the scientists who
favor the method are right and
whether it is safe to go further.
197
-------
BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGE HAS BEEN
RETYPED FOR CLARIFICATION
November 1, 1979
RESPONSE TO NEWS MEDIA INQUIRIES ON THE MEDICAL EXAMINATIONS OF EMPLOYES AT
CHEVROLET'S BAY CITY PLANT. SITE OF THE PROPOSED PCS TEST BURN
In connection with the proposed test burning of waste oil contaminated with
small amounts of the chemical PCB (polychlorinated biphenyl), the Chevrolet Bay
City plant is performing medical examinations on 20 plant employes this week.
The Michigan Department of Health believes that most people in the state carry
minute levels of PCBs. There are many sources of PCBs. They are found in fish
from Saginaw Bay for example, and in water supplies. The purpose of the medical
exams, which are being conducted at the employes' request, is to establish what
levels, if any, of PCB they may be carrying.
Thirteen of the employes being tested comprise the workforce in the plant's
powerhouse, where the proposed test burn would take place. The other seven
employes will be a "control group" and were chosen from elsewhere in the plant.
The test group includes both hourly and salaried employes.
Prior to the tests, all involved employes were briefed on the nature of the
examination, and advised that their participation is voluntary.
The examinations are being performed by Dr. Thomas A. Hockman, M.D., the plant's
medical director, who is an internist. The exams include a medical history, and
a complete physical examination, an electrocardiogram, pulmonary function test,
and an 18-phase serum chemistry analysis. The general blood analysis will be
performed by a private laboratory. The analysis for possible PCB content will
be performed by an independent medical laboratory and by the Michigan Department
of Health Laboratory.
Results of the tests are expected to be available prior to the November 20th
meeting in Lansing of the Michigan Air Pollution Control Commission, where the
proposed test-burn permit application will be reviewed.
198
-------
BECAUSE OF ILLEGIBLE ORIGINAL, THIS
PAGE HAS BEEN RETYPED FOR CLARIFICATION
Q & A
1. What about testing area citizens for PCBs?
Answer: Members of the plant's control group are residents of the
Bay City area. Their tests will establish background levels,
so additional tests are not believed necessary.
2. Why aren't you doing fat biopsies on the employes?
Answer: If no PCBs are found, there will be no need for fat biopsies.
If we find PCB in the blood analysis, we are prepared to have
fat biopsies done on employes who are willing. Such tests, if
required, will involve minor surgery and would be performed
with the assistance of an outside surgical clinic.
3. Will you do a second set of physical exams after a PCB oil test burn?
Answer: it is our conviction, and that of the EPA and the DNR, that
the sophisticated instrumentation to be used during a test
burn will demonstrate emission of nearly unmeasurable levels
of PCB, so follow-up medical tests are not planned at this
time.
4. Is this the first time GM employes have been given such medical tests?
Answer: No. GM maintains outstanding industrial hygiene and preven-
tive medical resources. Tests have been given from time to
time in other GM plant locations where workers have been ex-
posed to material such as lead, asbestos and beryllium.
#############//#######
Prepared by: J. D. Hudgens, Chevrolet Public Relations, 8-446-1565
Reviewed by: Robert Phillips, Anthony Fisher, Dr. R. Miller, Robert Clark,
Eugene Hartwig, Fred Fromm
199
-------
THE BAY CTTYTTMES
BAY CITY, MICHIGAN
FRIDAY, NOVEMBER 2,1979
O
o
Bay City Chevrolet to test workers for PCB poisoning
•jr Jean Linsley
Workers who three year* ago
bmed large quantities of waste oil
contaminated with PCB at the Bay
Ctjr Chevrolet plant will be tested
tor the presence of the heat-resistant
chemical in their bodies. General
Motors officials said,
David Hudgens, GM spokesman,
MM the company will supervise and
pay for the tests.
"We're doing this to put (the work-
Mrs') minds at ease," Hudgens said.
"We don't expect there will be any
alarming findings."
PCB, polychlorlnated blphenyl, is
kjwwn to cause cancer in laboratory
ttattials and is thought to cause can-
cer in humans.
The chemical was used widely In
artistry as an agent to prevent over-
heating In Industrial oUs and electric
equipment Its use was banned by
the Environmental Protection Agen-
cy earlier this year, but large quan-
tities of waste oil containing the
compound were incinerated at the
Chevrolet plant before the standards
went Into effect.
GM officials and the EPA are
planning an experimental "test-
burn" of the remaining oil sometime
before the end of the year.
Hudgens said 13 of the workers to
be tested will be from crews which
participated in the previous inciner-
ation, and seven "control" workers,
from other parts of the plant will be
used as a comparison.
The tests, being done at the re-
quest of the workers, will Include a
complete medical history and physi-
cal examination, an electrocardio-
gram, analyses of pulmonary (unc-
tions and blood tests.
Blood samples will be analyzed by
Independent laboratories in Wiscon-
sin and Oregon, and by the Michigan
Department of Public Health, Hud-
gens said.
If the tests reveal unusually high
PCB levels, he said, the company
will run more extensive tests to con-
firm the presence of the chemical.
' Andre Day, one of the plant's boil-
er operators, said be Is satisfied with
the company's decision to
perform the tests, "but I'm still
opposed to the test-burn."
"There's still a lot of unanswered
questions. They really don't know
what the tolerance level is. My big-
gest concern Is about the effects on
unborn children."
He said workers "are going to de-
mand" that GM run more medical
tests after the proposed experimen-
tal burn to see If the Incineration
resulted in any further contamina-
tion.
Hudgens said GM does not plan to
conduct tests after the experimental
burn.
"We feel that the sophisticated in-
strumentation (on special burners in
the plant) will keep PCB levels very
low," be said ,
At two public hearings on the test-
burn last month, several individuals
questioned the EPA and the Mich-
igan Air Pollution Control Commis-
sion about methods they will use to
monitor amounts of PCB going into
the air after combustion. EPA offi-
cials claim that levels of PCB escap-
ing Into the air will be less than one
percent.
A final decision on the test-burn
will be made by the state at air pollu-
tion commission at a special meet-
Ing In Lansing on Nov. 20.
-------
local
THE BAY CITYTIMES
MONDAY, NOVEMBER 5,1979
r-o
o
Canadian officials to view Bay City Chevrolet's PCB burn
By Jeann Linsley
The Canadian government Is Interested in a pro-
posed test-burn of PCB at Bay City Chevrolet, and
may send environmental officials to observe the incin-
eration, according to a spokesman for Canada's feder-
al Environmental Protection Service
The government's interest in the Bay City experi-
ment has more to do with public acceptance of PCB
disposal than with any advanced technology, said Pet-
er Mazerolle, of the EPS's waste management divi-
sion m Ottawa
"There is a need in Canada as well as in the United
States to get around the public acceptance problem If
success is achieved In one area, it will be that much
easier to dispose of PCB in other areas," Mazerolle
said
Ironically, the Canadian government already has
demonstrated what it believes is a successful method
of burning PCB, Mazerolle said, but the public hasn't
accepted It.
The government and a private cement manufactur-
er conducted a test Incineration of fluids contaminated
with PCB, or polychlorlnated biphenyl, about five
years ago, he said
While Mazerolle said the test, conducted in the ce-
ment plant In a suburb of Toronto, was successful in
destroying the chemical contaminant, "there was a
great public outcry," and subsequent public hearings
were "a disaster "
Bay City Chevrolet plans to burn about 430 gallons of
hydraulic waste oil containing PCB, In a special test to
see if the compound can be destroyed.
The contaminated oil will be diluted during the test
so PCB levels do not exceed Environmental Protection
Agency standards of 500 parts per million, and tem-
peratures inside the boilers will be high enough to des-
troy all but a tiny fraction of the chemical, officials
claim
Several questions have been raised, however, about
methods GM plans to use to monitor amounts of PCB
going into the air, and how It will measure PCB levels
in the oil before It is incinerated. PCB has caused birth
defects and cancer in laboratory animals, and is
thought to cause cancer and skin and liver ailments in
humans. Its use as a cooling agent In electrical trans-
forming equipment and hydraulic oils has been so
widespread that private manufacturers and the gov-
ernment have been at a loss to dispose of it safely since
its adverse health effects have been revealed
The EPA was forced to lower Its standards for burn-
Ing the chemical because Industry said it would be too
costly
But even'under present EPA regulations, it is es-
timated it will cost electnc utilities between S3 and $17
million a year to dispose of PCB-contaminated miner-
al oil In transformers and capacitors
"There is no known technological problem," Maze-
roHe said "The problem is the uncertainty of the peo-
ple They don't want it transported in the their neigh-
borhood and they don't want it burned in their neigh-
borhood "
A final decision on GM test-burn is expected on Nov
20, at a meeting of the Michigan Air Pollution Control
Commission.
-------
BAY CITY TIMES
Saturday, 11-10-79
PCB f es£ bum shoizkl concern else ccmiimmity
People of 1'ay City and surround-
ing areas:
I'm sure everyone Is aware of the
PC15 test IJLII ii I'.ny City Chevrolet is
planninn lc> carry out, hut is anyone
alarmed by thh piojeet? I am. and
I'm willlr.f! to lot rny feelings he
heard at a City Commission meet-
Ins;. Will you do thf s.unc?
I have'called city officials, offices
and commissioners on tlic subject. It
was satisfied \V|HMI promised infor-
mation from the l)ep:n Imoat of
Natural Kcsnurres research on the
PC15 chemical and a No data Irom
certain public officials. It has b^cu
several weeks und no Information
lias been f.ent.
1 Know I'CH is proven U) Lo
canrpr-cnuslnR in milmals. It Is sus-
pected to cause t)irt>. defects In hti-
mans! .Susijected? If this suspicion
is proven correct after the chcmiral
is hurr.td and released In our air.
Bay City and area residents may
then ice thrir children and nrand-
children inflicled with hlrtli defects.
and mav wish they would h.ive
banned the prorjrnm from tho start.
'I'his is the "Start," Hay Cityl lx:t's
stop it now!!
Anotlur problem which eould t)C-
come reality is Hie transporting of
this chemical. If tins test burn Is
done hero. Industry from miles
around \\ill send their I'CK w.islo
here by trucks and perhaps railroad
cars'. If this cliemie.il sho'ild leak or
the transporting veh'^les overturn,
think of the dani'or to our Immediate
environment and health!
Tlicro v\;il l>e an informal mectmr;
at the ('onimi'.sion jnf-etsni; Monday
at 7:30 p.m. at the (.orr.mui.lly (.'en-
ter. Let's all take part in KKJ wclf'iro
of our own bodies and that of our fu-
ture rj'.'iiorations.
Th
-------
Chevy waste oil burn opposed
Continued from Page 1-A
Several opponents questioned why
the oil bad to be burned.
CommJMkner Gary f. Julian,' 9th
Ward, a committeetnan for Chevro-
let Metal Casting, Sagtaaw, noted
the contaminated waste oil used at
the plant where he works Is snipped
to Onto and burled.
Susan Ma}e«ke, 214 1/2 S. DeWitt,
questioned If the burning could lead
to birth detect*, but Avery said there
is no data available to answer the
question.
"I do not want to be a guinea pig
for General Motors," she said. "Wny
not ship It to Otto?"
Edward A. Dronare, 1785 Kuhl-
kort, a boiler operator at Chevrolet,
said he opposed the test burn.
He also suggested that if GM offi-
cials are convincted UK test is safe,
Glf should post a $90 million "good
bond as a
guarantee. The
audience broke into apflause.
Seven boiler operators at Chevro-
let recently wrote letters to the DNR
and to Untod Auto Workers Local
SB alfegtag kMHh risk* may result
from bunting the contaminated oil.
Andre Day, 4*16 Lakeside Drive,
PlDcOQoing, a boiler operator at
CherroM far IS raw*. MM tte oil
was buiMd at OH pUat In am, be-
fore strict federal and state stand-
ards on PCB went Into effect.
Several boles In toe bolter stacks
were recently welded, after Day and
other operators complained PCB
emissions would escape through the
holes and contaminate workers.
"I'm totally against the burn,"
Day said.
Donald' Koenig, Chevrolet plant
engineer, noted the EPA approached
Chevy and proposed the test burn.
"We're trying to come of with an
alternative for taking care of the
low-level contaminated waste oil,"
be said.
City Manager-David D. Banes
said be opposed the test.
"Let somebody else be the guinea
pig," be said, adding that be be-
lieved the test should be conducted
In a less populated area.
Barnes also warned that if \be tact
proves successful. Bay Ctty ceuld
become a dumpf '.ground for dis-
posing of the oil.
Commissioner rimotl / 4. Sul-
livan, 1st Ward, said a report by the
DNR stated toe best alternative for
disposing of the oil is for the state to
build an Incinerator.
Allowing Chevrolet to dispose of
the oil is merely the least expensive
method, be said.
Sullivan also complained city resi-
dents weren't given enough advance
information about the *^^rt"if on
the test burn.
The City Commission received
about a week's notice beter* the Oct.
11 bearing in the Bay County Build-
Ing.
He noted the city received no for-
mal notice about a public bearing on
the issue Oct. 1C in Muskegon. Sul-
livan said be dbjected to the location,
since It was Inconvenient for resi-
dents here to attend.
Avery said the DNR was only re-
quired to conduct the bearing in
Muskegon, but It decided to conduct
a hearing in Bay City because a
number of residents favored a hear-
ing here.
Commissioner Ward W. VanDer-
will, 2nd Ward, was the only com-
missioner to vote against the resolu-
tion .
"It's very easy for us to climb on
the wagon and support protest Is-
sues," he said.
But VanDerwllI said shipping the
waste oH-to Ohio passes the problem
to residents in another area, when
the test burn could lead to a better
alternative for illsjiinlni of the
waste product.
203
-------
THEJBAYUITYliMliS
WEDNESDAY, NOVEMBER 14,1979 SECTION B
County board opposes
Chevy's PCB test burn
Following the lead of the City
Commission, the county commis-
sion Tuesday went on record oppos-
'ing the "burning of PCB-
contamir.ated waste oil at Bay City
Chevrolet.
Commissioner Bernard Brunett,
D-20th, was author of a resolution
asking automaker to refrain the
from test burning the chemical un-
til it is determined safe .
The resolution also asks that the
Health Department investigate anci
return tothe commission with a fuii
report.
"All we're saying with this is that
before anything is burned into the
air of Bay City, we want to make
sure it is safe," Brunett said
The Chevrolet parts plant has ap-
plied to the Michigan Air Pollution
Commission for a permit to test-
burn about 430 gallons gallons of
rndraulic waste oil containing the
fire-resistant chemical poly-
chlorinated biphenyl, or PCB.
About 38.000 gallons of PCB. a sus-
pected cancer-causing agent, now
are stored at Chevrolet.
Officials say a decision may be
made at a Tuesday meeting in Lan-
sing.
- Virgil Suchodolski, "D-5th, ques-
tioned whether the matter should
be left up to the state Department
of Natural Resources.
"I just wonder whether we're
hamstringing General Motors
here." he said.
Brunett said not burning the oil
would not hamstring the giant com-
pany.
The City Commission voted Mon-
day to oppose the test burn.
204
-------
BAY CITY TIMES Wednesday, November 14, 1979
County board opposes
Chevy's PCB test burn
Following the lead of the City burn about fin gallons gallons of
Commission, the county eommis- hydraulic waste oil containing the
sion Tuesday went on record oppos- fire-resistant chemical poly-
ing the burning of PCB- chlorinated blphenyl, or PCB
contaminated waste oil at Bay City About 38,000 gallons of PCB, a sus-
Chevrolet. pected cancer-causing agent, now
Commissioner Bernard Brunett, are stored at Chevrolet.
D-20th, was author of a resolution Officials say a decision may be
asking automaker to refrain the made at a Tuesday meeting in Lan-
from test burning the chemical un- sing.
til it Is determined safe. Virgil Suchodolski, D-5th, ques-
The resolution also asks that the tioned whether the matter should
Health Department investigate and be left up to the state Department
return tothe commission with a full of Natural Resources
report. "I just wonder whether we're
"All we're saying with this is that hamstringing General Motors
before anything is burned into the here." be said.
air of Bay City, we want to make Brunett said not burning the oil
sure it is safe," Brunett said. would not hamstring the giant com-
The Chevrolet parts plant has ap- pany
plied to the Michigan Air Pollution The City Commission voted Mon-
Commission for a permit to test- day to oppose the test burn.
Factories still discharging
chemicals into Pine River
Two abandoned factories in central Michigan are still discharging
toxic chemicals tnta nearby rivers, and the Department of Natural Re-
sources wants the state attorney general to do something about It.
Jack Bails, director of the DNR's enforcement division, said Tuesday
the1 abandoned Hoppers Co. plant at Reed City and the Velsicol Co. plant
at St. Louis are continuing to pollute the Hersey and Pine Rivers respec-
tively.
The Pine River empties into the Tittabawassee River, which flows
into the Saginaw River.
Bails said the abandoned Koppers plant near Reed City is discharging
creosote, a tarlike weatherproofer tor wood, and possibly PCB. into the
nearby Hersey River. He said the Velsicol plant is discharging PBB.
Tris. DDT and oil into the Pine River outside St. Louis
The state has filed suit against Velsicol as a result of PBB contamina-
tion of cattle after the chemical was accidentally mixed with feed in
1973. The plant closed in September, 1978. and the firm has agreed to
raze the plant as part of a multi-million dollar cleanup effort
The state also is seeking about $200 million from Velsicol as repay-
ment for its efforts to compensate victims of the PBB accident, and for
various health studies conducted by the state. That case is now awaiting
trial, said assistant Attorney General Stuart Freeman, a spokesman for
the attorney general's office.
Freeman said the state could file another action against Velsicol if it
was shown the company was not adequately cleaning up or containing
wastes on the site.,
"If the DNR has solid evidence (of additional contamination) I as-
sume we'll do something," Freeman said.
Recent heavy rains in central Michigan created a greater runoff than
usual at the Velsicol plant, causing a large fish die-off, said Susan
Sylvester, a DNR enforcement officer.
Bails said groundwater Is being affected by continued soil contamina-
tion around the site.
PBB, polychlorinated biphenyl, is a Ore retardant, and known
cancer-causing agent. Tris also is a fire retardant which was used until
1976 in children's clothing.
At Reed City, Bails said the DNR originally found only creosote, a
wood preservative, leaking into the Hersey River. .But further tests
have indicated the presence of .polychlorinated biphenyl. or PCB. an
electrical transformer coolant and fire retardant which also is suspect-
ed of causing cancer in humans
The Koppers plant, which treated railroad ties with creosote, was
closed in 1949, and the operation moved to Pittsburgh.
205
-------
BAY CITY TIMES
FRIDAY, NOVEMBER 16, 1979
month's delay
burn here
to the lull ll-member cofen(iias»oo A
the meeting Tuesday in Lanatog.
, GM baa expected to receive re-
suite. Iran the .Wood tests before
David
•WttP
of
l'
-------
BAY CITY TIMES TUESDAY, NOVEMBER 20, 1979
Belay expected
m decision on
PS.—1 *> 1
(^B burn
The Michigan Air Pollution Con-
trol Commission today uas expect-
ed lo ciela\ until at least Dec. IK a
derision on a proposer! test-burn of
I'CB-conlammatt'il oil at Hay City
Chevrolet.
Otlicials of General Motors have
requested UK: delay because they
haven't received results ol medical
tests on plant workers who in-
clneialed the waste oil prior to
1970
CM officialsaUe say t!;o\ want to
clear up "misundei standings" on
the part ol Ba\ City oliiei.il.s about
the test, in v.huh about 4.in gallons
of v-a-tc oil would be burned
Arthur Illoonvr, of the Michigan
Dep.'iruiiont ol I'nli'ic Health, said
results of the nii-dical tesls should
be available this week CiM also is
awaiting medical lab tests from
pri\alc labs in NViscunMn ;;iid Ore-
gon.
207
-------
THEBAYClTYTlMES
WEDNESDAY, NOVEMBER 21,1»79 6 A
PCB TEST-BURN PROPOSAL:
GM gets month to sell city on plan Bay environmental office favors it
O LANSING, Mich. (AP) - Representatives'from
00 General Motors Cotp will get another month to try to
sell Bay City area residents on their planned test-burn
of oil contaminated with the toxic chemical PCB
Michigan's Ah- Pollution Control Commission Tues-
day postponed until Its next meeting a decision on
whether to allow GM to test-burn the oil, tainted with
Insulating chemical polychlorinated blpnenyl as It
passes through electrical transformers GM wants to
burn the oil In a boiler at its Chevrolet Division plant In
Bay City
The auto Industry giant has the support of the Mich-
igan United Conservation Clubs - but opposition from
plant workers.
' "Let's not tool around and take tests in a populated
area, a big wildlife area, a fish area." said worker
Frank Burns
Many plant employees have already been exposed to
the suspected cancer-causer and are worried about
the possible cumulative effect of new exposure, Burns
said
But GM spokesmen stressed they do not think the
tests pose any threat to the community health or safe-
ty. They said they're awaiting final results of blood
tests of workers who may have bun exposed to PCB In
the past.
The 18-hour test-burn. In which the tainted oil would
be diluted with regular fuel oil, has been requested by
the federal Environmental Protection Agency. GM re-
presentatives said. The only other known methods of
disposing of such tainted oil art placement In landfills
and destruction In special Incinerators.
Some auto workers presented the commission with a
Canadian study they said gave reasons to. oppose the
test-burning.
And Bay City Commissioner John Howard, a United
Auto Workers repre»ent»tl«, Mtd he was angry that
the commission would pursue (he permit request after
the Bay City Gmrm^sloo took a stance against It.
About 38.000 gaJtons of PCB-eontamlnated oil have
accumulated at the plant ataee the commlMM or-
dered an end to Its burning there In 1*77. The oil bid
been burned for two years.
Wayne Schmidt, i
Conservation Clubs, and Mmi
the American Lang Association •
» supported the test bum U i
maintained.
By Store BeH
The Bay County Health Department's Division of
Environmental Health has come out In favor of the
teat-burn of PCB-eontamlnated waste oil at Bay City
Chevrolet.
The company wants to burn about 430 gallons of the
oil In Industrial burners to determine whether It Is fea-
sible to destroy larger quantities of oils containing
PCB, a suspected cancer producing agent.
Both city and' county commissions have come out
against such a teat-burn. They have argued that it
could threaten the safety of area residents
The Health Department's opinion was sought by
both the county commission and County Executive
GaryMaJeske
County Environmental Health Division Director Ed-
ward Gdson said that until Chevrolet and the Depart-
ment of Natural Resources try a teat-burn, no deci-
sion can be made whether larger quantities can be
burned.
About 31,000 gallons of the oil Is stored at Chevrolet,
y officials have reported
IMttan independent firm familiar with boiler
• (be boiler to be used la the
g
were
tta effldBncy.
tarn takes place, an agreement should be
made between the city, county and Chevrolet that no
other oils beyond the 38,000 presently stored there be
burned, Golson said.
Golaon noted that the oils were being Incinerated for
several years before anyone knew that PCB was a tox-
ic substance.
"This department, of course, does have concerns as
far as a toxic substance being disseminated into the at-
mosphere told possibly affecting the population of Bay
City." Golson said.
"We do not, however, feel that enough data Is pre-
sent currently to make a judgment on the efficiency of
burning such waste
• "It is for this reason that the Bay County Health
Department's Division of Environmental Health takes
the position that the test burn be made, that the
Department of Natural Resources closely monitor
that burn, and collect the necessary data to make a
Judgment as to whether or not these oils can be han-
dled effectively In Bay City Chevrolet's boiler
system "
PCB is a heat-resistant chemical used In electrical
transformers It has been found to cause cancer In
laboratory animals.
The Environmental Protection Agency banned the
manufacture of PCB in May and has Imposed strict
controls on Its disposal.
-------
Bay City Times - 11-27-79
By Jcann Linsli-v - ' •
General Motors officials vvill meet this week with city commissioners
to try to gain their acceptance of a GM plan to burn PCB-coiitaminatcd
waste oil at Bay City Chevrolet.
GM spokesman David Hud.ucns said the firm will arrange a meeting
and possibly a tour of the facility's boiler room, where -Uu yallons ol the
waste oil would he incinerated.
'Although citv commissioners have taken no forma I-act ion banning
the test. the> have the indirect power to do so. according to City Clerk
Walter Wozmak
\Vozniak said if the cily fire marsh.'! determined tli.it the hum would
be detrimental to residents, and Gei'i ral .Motors appealed the detei mi-
nation, the city commission would h.n " [he final saj on the appeal.
However, the situation has nc\ er c me up. Wo/nlak pointed out.
Commissioners did pass a resolution r>ppriMHKthe test-burn, however.
. Skepticism on the part of city offie; ds was at leas! one reason GM
asked the Michigan Air Pollution Control Commission la.st week for a
one-month delay in their decision 0:1 UK lest.
"We're trying to work out a form..! -..here we can discuss tlie mat-
ter," Hud^cns said "If it would he lielpiul for the commission to look at
the boilers. \vc t; tie more than wiiiiiv^ii.tin that "
Several plant boiler operators ha\e !,.be!ed the boilers inadequate to
meet the KPA's guidelines for incme-.itum ol 1VB, or pnlvchlnnnatcd
biphcnv I, a lire-resistant chemical pi o\ c n to c.uise cancer in laboratory
animals.
Several delects in the boilers wire repaired only after the workers
protested to the Department of Natu1.'! liesourccs. and an article!
detailing the problems was published 1:1'! ne Times Uet. :i
G.M also is awaitmt; results of medical tests of workers v. tin wore in-
volved in incineration of IVB-cuntamin.iled oil three ve.irs a,no, beioie
'federal standr.rds on disposal took elii\ t
The Michigan Air Pollution Control Coinv.ussion has held three puljlic
hearings on GM s request to oonducl the test-burn, and is expected to
make a decision at its Dec IS mcetinu
GM would have io reapply to thecopini1 • ion alter the lest lor approv-
al to burn thereat ot the contaminated ii.l b' 1:11; slored on th-1 |>lant site.
About 40.000gallons ol the oil arebciii^Mt :•.•(! at the Bay Citv plant.
209
-------
BAY CITY TIMES
SATURDAY, DECEMBER 1, 1979
'lioto
Local Chevy workers PCS levels
s bet within 'average' range
Bv
Linslcj
Powerhouse operators at Bay City
Chevrolet \vl.o participated "in a
burning of PCH contaminated waste
oil thice \eai-, ,r;o have brrli'T Ic v-
els of K'B in their blood tlian other
pluiit cn,nlu\ocs •- l)iit their 1TH
levels arc sidl \vjttnn .the- ran^i-
heal' :i offi-. ;;• N say is "average."
Tests run by the Michigan Depart-
ment cf Il'-aith and two private
laboratories {.ibcioSL'c! those findings
Fnd,.\ lo 2.', workers who volun-
teered t'-r the kits.
Trmtu'.'i i>f those tested were pow-
erhouse operators. The other 10
\.crc a cor/iol croup of nnpli^yi-L-s
wliodidn'i work in the powerhouse.
General Motors spokesman David
lludgcio and iiay Cit\ Chevrolet's
mediea! dnettoi. Thomas A Jlook-
niaii, eaiiod tlie resuitb "reai.sur-
The tests were run
er CM asked the M
lion Control Conim
sion to conduct a t
•I.in gallons ol PCI;.
GM wants !hr I;
mine if about Jo.on
stored at Bin Cits
burned safeU Tlie u
mi v-ion has tli'lavi d
the ((.'((iiest until !)<"-;
Te-ls on the VMM
tieip.ited in the car,:
ofti' lals said, won!1'
ers, the public and ."„
that there likely v.t
(.ant health ha/ard fr
waste oil.
Levels of PCH )•
averaged between
per billion, accord i ir.
suits. Iludgcnssaid
Although there !••
01 federal standard I:
on woikers aft- human beings, the state health
nljj.in AlrPolIu- department has indicati d that PC'I'.
>. MMI lor permis- blood levels for Michigan residents
st-burn of about ranije from five to -in parts per I) I-
>! polvchlomuil- hon
Lev els of PCH in !!)<• conli ol group
l-l'urn to deter- of ID employ res who did no,! v.nrk m
".illons of PCM the pounhoiiM' ranu'ed from •-'ix to
':••• vi(ilct enn be Imparts per billion, llud^ens.said
r pollution com- 'A pait per billion can he com-
i ,r decision on p.ui d to about nne drop of li(|'i:d and
•nil.'er ,i lank ti uck full." HndLicns s.ili!
.irs who par- PCH was used widely in electrical
r burning G.M tiansfonners and prevent ovcrhc.it-
n .i:-viin' work- WJ. of hydraulic oil.
!y 1'ity olficinls H^ nianufactuK- vva> banned by
! lni burning the cv in l!)7d. and a total ban on its u.-e
and transport was announced in July
the '^.i workers ofthisjear
\ and lid parts I'CIJ N known to cause cancer in
I to the test ic- iaK and is thought to cause cancer
in humans, although no definite stu-
•i (it Unite stale dies have linked il to human ail-
•i I'CH levels ill inent.s.
210
-------
focal
THE BAY CITY TIMES
SATURDAY, DECEMBER 1,1979
5-A
Laws regulating toxic chemicals are riddled with loopholes
For vast majority of chemicals, 'we don't know what health risks are,' environmental official says
By Jeann Linslo
The foremost environmental Issue In the next 15
years will be regulating toxic chemicals, tut I
laws are riddled with loopholes, says V"1"— '
member of the Michigan Envln
, said al'
though about 70.000 organic chemicals are known car-
cinogens (cancer-producing), "for the vast majority
of the compounds we don't really know what the health
risks are "
And though the Environmental Protection Agency Is
attempting to regulate hazardous substances, loop-
holes both m guidelines set by that agency and other
legal loopholes have allowed many dangerous sub-
stances to go unchecked, said Cooper, a biology
professor at Michigan State University.
For example, he said, while the LVA has clamped
down on a pesticide known as Mirex. a chemical with
the same chemical structure Is being used In the
automobile industry as a flame retardant.
"It's not regulated because It's not registered as a
licensed Insecticide," Cooper said The EPA presently
has no mandate to regulate the chemical tor uses other
than in pesticides, he observed
Chemical manufacturers have been able to squeak
by toxic chemical disposal laws through small sub-
sldlariM which can simply "fold up and walk away"
when there Is pressure to clean up their operations, he
said.
Hooker Chemical Co., a subsidiary of the giant Occi-
dental Petroleum Co., and MlcM»ao«betrucal Co.. a
subsidiary of the larger Northweat Industries, are ex-
amples, be said.
Hooker Chemical, of Montague, last month agreed
to an out-of- court settlement 3 a state lawsuit calling
for the firm to undertake a mum-million dollar clean-
up of an area around Montague, which was con-
taminated with more than 100 chemicals .
Michigan Chemical, now catted Velatcol Chemical
Co . formerly of St. Loins, to tan tied up In a lawsuit
with the state stemming from the a accidental mixing
of PBB with animal feed In 1973.
Both firms have vacated their manufacturing opera-
tions.
Another loophole In regulations regarding chemical
discharges Into municipal sewer systems probably is
resulting In numerous dangerous chemicals being
dumped Into sewers, Cooper said.
If an Industry wants to set up an operation In a par-
ticular city, be said, tt must Ust all the chemicals It
will discharge Into public sewer systems
But the city Itself Is not required to list the com-
pounds going Into the system, he said.
"The vast ma]< .....--.
And federal stanaardstor toxic chemicals In food
aren't much better, he said.
"It's somewhere between a OuIJa Board and black
magic, that's the state of the art right now."
The Food and Drug Administration's maximum
standards for things like mercury. PBB. and PCB. are
often arbitrary, he said, and are subject to the whims
of pressure groups.
"One of the biggest lobbies against setting higher
standards for mercury In fish was Weight Watchers
They didn't want their fish taken away from them."
Cooper said
"You have to take (the standards) with a grain of
salt"
Cooper criticized the state Department of Natural
Resources for not forcing chemical companies to com-
ply with the law
"The laws are there What's not there is the guts to
Implement them "
Cooper predict!
Incineration ol I
great mat the Environmental Review Board \
Federal standards for toxic chemicals in
food are "somewhere between a Ouija board
and black magic, that's the state of the art
right now."
—William Cooper.
forced to do an environmental impact statement on •
the proposal
General Motors is awaiting state approval to con-.
duct an experimental incineration 01 pete-
contaminated waste on in industrial toilers at the
plant. The firm wants to destroy the rest of abouT4Q.-
TMtr^ltons being stored at the plant, ana I wnetnerlt is
allowed to do so depends on the results of the test
Cooper said "TnaTwill in.-
destroying large quan-
"The issue Isn't he test,
yolve very small amounts But
tities Is very different
The board has no legal or legislative powers, he
said. J'but we nave the power to ask questions and pub-
licly embarrass someone If they don't come up with
IMalUweH." - --
-------
6-A THE BAY CITY TIMES FRIDAY, OCTOBER U, 1979
Union workers protest PCB test burn
By Jeann Linsley
About loo peraom turned out at a fubllc hearing
Thursday to protest a proposed experimental Inclner
atlon of PCB-containlnated waste oil by Bay City
Chevrolet
The touMUJd-a-half hour hearing was conducted by
the Michigan Air Pollution Control Commission, which
hu granted Chevrolet preliminary approval to con-
duct a "test-bum" of about 430 gallons of hydraulic
wafte oil containing the fire-resistant chemical poly-
chlorinated blphenyl.
PCB Is known to came cancer in laboratory animals
and Is a suspected human carcinogen.
Several members of the United Auto Workers, re-
presenting operators of the industrial boilers in which
the oil will be Incinerated, questioned commission
staff about long-term health risks to the community as
a result of the burning.
One union representative said he will Hie a petition
to Intervene In the commission's permit proceeding
and will request that he be provided Information on
correspondence between the commission, General
Motors Corp. and the Environmental Protection Agen-
Lyle Miller, ol UAW Local 3ft, said he will challenge
the legality of a public hearing scheduled for Oct. U in
Muskegon Heights
The Muskegon Heights Hearing was originally the
only one scheduled by the ale pollution control com-
mission Last night's hearing at the county building
»as scheduled only after prompting by Slate Rep Jim
Barcla, D-BayClty
Miller said he also will request information from
GM and the EPA on the efficiency of the hollers at the
plant, and the exact methods of monitoring which will
be used.
City Commissioner Timothy Sullivan protested to
the commission staff that city officials were not in-
formed of the proposed test, and that they should be
glvn more time to review the proposal
"As far as I know, none of the other commissioners
were aware of this before Monday," Sullivan said
beneral Motors plans to conduct three separate six-
hour test-burns of the oil. The EPA says the company
has assured them the condition ol the boner meets all
state and federal guidelines for disposal of PCB, but
questions still remain about how levels emitted from
the burner stacks will be monitored.
"How do we know what concentrations we're going
to get?" asked one union representative .
"Is the EPA or the DNR going to guarantee that this
Isnt going to *tve us cancer' "
Audience IMeisn stale air poHitkw experts airf EPA officials explain proposed lest incineration •
Commission member Gerald Avery said there will
be "some PCB molecules coming out of the stack, but
that's a very difficult question to answer "
Commission members and EPA staff have admitted
there Is no real method to monitor directly for PCB
emissions Equipment will be Installed In the burner
stacks which will remove smoke samples, but It will
take several weeks to analyze the samples for PCB
content, according to commission members
During the actual burning, different "indicators" of
how much PCB Is being destroyed will be used to as-
sure maximum destruction of the compound
Thou Indicators Include carbon monoxide, carbon
dioxide and excess oxygen levels, which are Indicative
of the combustion efficiency of the boiler.
The "destruction efficiency" of the boiler, however,
hasn't been proven. The purpose of the test burn, ac-
cording to the commission, is to measure the boiler's
efficiency.
The commission's public comment document
(which is required hi the permit process) states that
the results-of the test-burn "are expected to reveal
minimum destruction efficiencies of greater than 99.9
percent based on other stack test results and Informa-
tion contained in scientific literature.''
H. Michael Jones, of the local office of UK. American
Cancer Society, expressed concern about worker con-
tamination levels from previous burning of the waste
oil before the EPA and DNR formulated standards on
Incineration of the chemical
Jones called on the commission and the EPA to con-
sider health risks as part of Its permit proceeding
"I would seriously question the competence of any
study that doesn't take into account the health effects
Ion workers and citizens)" Jones said "What do we
know about long-term exposure to airborne PCS'"
Hal Snyder, of the EPA in Washington D C , said the
PCB coming out of the stacks at GM will be very low
"There Is very little direct Information" about
specific health effects of airborne PCB, Snyder said
Donald Koenlg, manager of the Bay City Chevrolet
plant, said the boilers at the site were Inspected by the
state last week after boiler operators raised concerns
about the condition of the burners
Koenlg said the, burners passed the Inspection
Several boles in the boiler stacks have been welded
since last week, when boiler operators expressed fears
that PCB emissions would escape through the holes
and contaminate workers, according to boiler opera-
tor Andre Day.
If allowed to go, the test-burn will be the first of Its
kind In the Midwest, and one of only two in the United
States
GM sources say the test amounts to an "expert-
Hal SmJer. Times Photos
menl" by the EPA to see if the process will work, and
if it does, the agency can begin to get rid of massive
quantities of PCB-contaminated oils and electric flu-
ids being stored In landfills and at industrial sites
around the country
But the EPA contends it is nearly certain the incin-
eration will work, and that the GM boilers meet all the
agency's disposal criteria.
GM has about 40,000 gallons of waste oil on-site.
Some of the oil was burned before 1977
The EPA has downgraded Its standards for burning
PCB since its original rules were handed down in 1977
because several industries said adhering to the strict
regulations would be too costly
The pollution control commission will hold one more
hearing Oct 16 in Muskegon Heights, then decide
whether to grant a permit for the test
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-600/2-81-033b
2.
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Applying for a Permit to Destroy PCB Waste Oil;
Vol. II. Documentation
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 PERIOD COVERED
Task Final; 5-12/79
14. SPONSORING AGENCY CODE
EPA/600/13
15.SUPPLEMENTARY NOTES IERL-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 polychlorinated 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.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
c. COS AT I Field/Group
Pollution
Chlorine Aromatic
Compounds
Biphenyl
Insulating Oil
Combustion
Incinerators
Waste Disposal
Boilers
Licenses
Toxicity
Communicating
Pollution Control
Stationary Sources
Polychlorinated Biphe-
nyls (PCBs)
Permitting Process
Waste Oil
13 B
07 C
11H
21B
13A
05D
06T
15E
18. DISTRIBUTION STATEMENT
Release to Public
19. SECURITY CLASS (THU Report)
Unclassified
21. NO. OF PAGES
216
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
213
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