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.
t

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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
t
120
t
*
t
t
t
121
t
t
t
t
t
t
t
t
*

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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
t
t
122
t
t
t
t
4-
i
128
130
t
t
t
t
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.
                                14

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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
                                  16

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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
                                   20

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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
                               21

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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

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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

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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

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/-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

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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

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                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

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                                            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

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                                  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

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            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

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    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

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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

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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

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              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

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                                          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

-------
                                              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

-------
         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

-------
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

-------
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

-------
                                 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

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                                 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

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                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.

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                                                \
                                        XKETENTION  PONDS
                                                WASTE WATER
                                                   FACIUIT Y
Figure 11.  Dispersal  of plume in aerodynamic
            wake  of  building.
                        67

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     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

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   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

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 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

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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

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 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

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 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

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                                                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 ,£$
-------
     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

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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

-------
         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

-------
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

-------
     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

-------
     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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            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.
                                    155

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                  PAGE HAS BEEN RETYPED FOR CLARIFICATION

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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                    PAGE HAS BEEN RETYPED FOR CLARIFICATION
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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                    PAGE HAS BEEN RETYPED FOR CLARIFICATION
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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              BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGE HAS BEEN
                         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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BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGE HAS BEEN
            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
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                                ~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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  BECAUSE OF ILLEGIBLE ORIGINAL, THIS PAGE HAS BEEN RETYPED FOR CLARIFICATION
     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

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     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

-------
                                        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

-------
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

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                     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
        Ijc.'nlMiii •••! in '.!".• pa:.t l.j'l : (Sn-r it.-; (Ud !li" c linniciil in II i n ,'jlooJ
        r.utth:l.'\cl  '>•<  U> .'••(... -i r>i, ,'''•]•'!  a\c: r,c ' !A tdo ^l;-^.
         hoen/; -ai-J .u!;.',v., i, ,; IP  ,':, (| ti -.is ,\ :          :
         "\\c an  c.i-n I:K '•(! I1'
                          ,            .  >    •>
        V. ilh 111111:11, ::;i i i  ,. tni v.-i vc-i.- cijI'-'C". O'-il " Ki'i n>.' s;i!(J
         '1 IT pni;.n cd  !>•.,(  is |, ,;i^ I'liiifliKlci. to r'l |, ! iiil'H- uin'l;rr l.ir;'/
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        trsn' !!,,':,i!r

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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

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                                                        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

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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

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          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

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                    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

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        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.

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           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.

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   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
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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

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   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

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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

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 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'
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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

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                                                                                                                    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.

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       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

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      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

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    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." -        --

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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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