v°/EPA
United States
Environmental Protection
Agency
Industrial Environmental Research
Laboratory
Research Triangle Park NC 2771 1
Research and Development
EPA-600/S2-81-033 Dec 1981
Project Summary
Applying for a Permit to
Destroy PCB Waste Oil:
Volumes I and II
S. G. Zelenski, Joanna Hall, and S. E. Haupt
The complete Project Report, which
is summarized here, documents the
permitting process followed by the
State of Michigan before allowing a
trial destruction burn of polychlori-
nated biphenyls (PCBs) at the General
Motors (GM) Chevrolet Bay City
plant. The report is in 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 lists
who requested and who responded to
each need for additional information.
An analysis is given of the significance
of interactions, including interagency
communications, private sector-
public communication, and the flow
and quality of information developed.
Finally, recommendations are made,
based on this permit application
process, that might facilitate subse-
quent permit applications for burns of
hazardous materials.
Volume II of the full report contains
the relevant documents summarized
in Volume I.
This Project Summary was develop-
ed by EPA's Industrial Environmental
Research Laboratory, Research Tri-
angle Park, NC, to announce key find-
ings of the research project that is fully
documented in a separate report of the
same title (see Project Report ordering
information at back).
Introduction
Before the enactment of the Toxic
Substances Control Act (TSCA) in
October 1976, EPA's authority covering
polychlormated biphenyls (PCBs) was
limited to the regulation of contamina-
ted water from point sources. Under the
Clean Water Act of February 2, 1977,
Section 307 (a) (42FR6532-6556), the
EPA promulgated a rule banning the
discharge of PCBs into navigable waters
by electrical transformer and capacitor
manufacturers.
On February 17, 1978, (43FR7150-
7164), acting under TSCA, the EPA
promulgated a rule regulating the dis-
posal of PCBs and requiring that special
warning labels be applied to large
capacitors, transformers, and other PCB
items This Disposal and Marking Rule
covered liquid PCBs as well as other
material and equipment components
containing or having contained PCBs in
concentrations greater than 500 ppm
This rule was further clarified by
amendments published on August 2,
1978, (43FR33918)
The Final PCB Ban Rule appeared in
the Federal Register on May 31,1979,
(44CFR761 31514-31568), and took
effect on July 2, 1979 This rule inte-
grates the February 17, 1978, PCB
Disposal and Marking Rule with the
Production Ban Rule; therefore, the
Final Ban Rule provides the total scope
of PCB regulations through July 2,
1979, its effective date These regula-
tions led to the accumulation of large
volumes of PCB-contammated fluids
while sources attempt to develop and
use acceptable means of disposal as
provided by Subpart B of the PCB
regulations.
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One source of PCB-contaminated
fluids is the contamination of process
machinery oils by PCB residuals. PCBs
had been used previously in cutting oils
because of their flame retardant proper-
ties, which provided greater machine
operator safety. Because of the tenacity
of PCBs to surfaces, each time machin-
ery is flushed with oil free from PCBs,
the flushings are contaminated by PCB
residues in the machinery
The EPA has established that, if the
PCB concentration of these fluids is in
the range of 50 to 500 ppm, the waste
oil may be destroyed by incineration in
an industrial boiler The Federal regula-
tion (40CFR761) stipulates that.
(1) The boiler must be rated at least at
50 million Btu/hour
(2) The PCB-contaminated waste
must constitute no more than 10
percent of the total volume of fuel
(3) The waste must not be added to
the boiler during startup or
shutdown
(4) Certain combustion and fuel feed
conditions must be monitored
during the burn.
(5) The regional EPA administrator
must be given 30 days notice of
the proposed burn.
(6) The burn cannot take place
without the approval of the EPA
regional administrator
The facility at Bay City, Ml, run by the
Chevrolet Division of General Motors
(GM), is presented with the problem
described above, having accumulated
approximately 60,000 gal of hydraulic
fluids contaminated with PCBs in the
concentration range of 50 to 500 ppm.
This facility has the following basis for
disposing of its wastes by incineration.
• It possesses two boilers in the size
range required by EPA for inciner-
ation of waste oil
• It possesses a large volume of
PCB-contaminated oil in the
concentration range allowed by
EPA for industrial incinerator
destruction.
• It had previously burned PCBs m
its boilers, and its tests showed
excellent destruction efficiencies
• After being notified by Mr. Potter,
GM's Vice President for Environ-
mental Activity, EPA had con-
tacted GM and asked if they would
be willing to conduct the test.
In addition to notifying the EPA
regional administrator, Michigan air
quality regulations require that GM
obtain a permit from the State Air
Quality Division under Michigan Act No.
438, Rule No 21 This regulation pro-
vides that any source of contamination
to the air needs a permit to operate
Thus, a permit is necessary for any con-
struction, reconstruction, and alterna-
tion of any process, fuel burning equip-
ment, or refuse burning equipment that
is a potential source of air contami-
nants. No specific procedure for obtain-
ing the permit is out ined in the
regulation, and public comment period,
at staff discretion, is used only in signifi-
cant or controversial cases.
Because of the regulatory require-
ments, certain engineering and
operating protocols were established by
GM and EPA's contractor, GCA Corpor-
ation, in support of anticipated technical
needs The Appendix to the full report
describes the analytical sampling and
analysis support developed by GCA
Corporation In addition, ihe Appendix
gives the preliminary environmental
analysis, including dispersion modeling
and relevant health and ecological
standards considered important for
evaluating the proposed burn.
Chronicle of Events
To provide an understanding of the
path taken by the permit application
process to date, a chronology of events
is included in Volume I of the full report.
Copies of all available documentation of
events cited in this chronology are
presented in Volume II of the full report
The chronology shows three phases
governing the incineration disposal of
PCBs at the GM-Bay City plant The first,
or preregulatory phase, was between
1974 and Fall 1977 when PCBs were
incinerated at the plant without restric-
tions This period occurred before any
GCA involvement
The second, or regulatory phase, was
initiated by state-applied restrictions on
PCB incineration. Regulatory action
was intensified when EPA issued PCB
regulations Duringthisphase,from Fall
1977 to mid-1979, the structure of the
PCB incineration permit and permitting
process was gradually developing as the
control agencies gained implementa-
tion experience.
Failure to supply sufficient data to
meet Federal combustion criteria for
PCB disposal was cited m 1978 by the
DNR as the reason for GM permit appli-
cation denial It was apparent that GM
would require technical assistance in
obtaining the incineration permit The
commercial availability of PCB incinera-
tion facilities had become an EPA waste
management goal; thus, in the interest
of that goal, EPA contracted with GCA/
Technology to provide active assistance
to GM m the permit process. GCA's
initial involvement was to gather
technical information to support GM's
permit application.
The third phase was characterized by
the interactions of the press and public
m the already complicated permitting
process. This period was replete with
public hearings, agency inquiries, GCA
responses, incineration disposal sup-
port/condemnation statements, and
decision delays. GCA's role was broad-
ening as areas of concern expanded
from combustion details to estimating
human and environmental impact of
PCB incineration
Press Coverage of Permit *
Application Process I
The Michigan press had already
influenced this permit application
process because of coverage of the
Peerless Cement Permit Application, 2
years before. The press had been the
major source of public information at
that time, and the emotionalism associ-
ated with the Peerless permit had
certainly not dissipated by the time of
the GM permit application.
Public objection was the major prob-
lem the Chevrolet Bay City Plant en-
countered when applying for this permit
to burn waste oil containing PCBs. As
the application process proceeded,
various public interest groups received
their information primarily from the
press and made value judgments based
on this information. The Bay City Times
and newspapers from neighboring
cities covered the matter extensively.
The coverage in itself may have influ-
enced public opinion, which, when
aroused, delayed the permit process
Conclusions and
Recommendations
Perusal of the events detailed in the
full report describing the permit applica- ,
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tion process can present a confusing
picture. However, certain conclusions
can be drawn based on the progression
and documentation of events Although
each permit application process is
unique, these conclusions may be
representative of the difficulties that
could be encountered in any similar
process
• The public, either directly or
through elected representatives,
was not informed of the proposed
permit application during the
early planning stages
• Special interest groups (e g., the
Michigan Lung Association, the
Michigan Branch of the American
Cancer Association, and the
United Auto Workers) were not in-
formed of the proposed permit
application during early planning
stages.
• The GM personnel, to be involved
in the test resulting from approval
of the permit application, were
apparently not initially informed
of the perm it application, but were
informed only when queried by
the press
• The public has, by legislation, an
important influence on the
permitting process
• Previous incidents in the state,
such as the Peerless Cement Co
permit application for PCB incin-
erations and a PBB spill, had
already formed much of the
public's attitude toward hazard-
ous waste disposal.
• GM-Chevrolet Bay City did not
adequately anticipate the public's
and special interest groups' needs
for information
• Information finally provided to the
public and special interest groups
by nonmedia sources, such as
presentations at public hearings,
was apparently too technical
• There was apparently a lack of
adequate communication and of
clearly delineated responsibility
assignments between partici-
pants in the permit application
process
Although these are certainly not the
only conclusions that may be drawn
from the available documentation, they
do represent a composite of a distilla-
tion of the documentation, and the
problems cited most by participants in
the permitting process during informal
interviews
If these conclusions accurately reflect
the incidents that occurred as part of the
permitting process, certain recommen-
dations to facilitate the process in the
future are
(1) Identify all groups that play im-
portant roles in future permitting
processes
(2) Contact these groups by letter or
personally
(3) Develop a relationship of coopera-
tion with these groups
(4) Determine the level of support
required for the proposed action,
and determine the necessary
course of action based on that
level of support
(5) If warranted, proceed with formal
permit applications
S G. Zelenski, Joanna Hall, andS E. Haupt are with GCA/Technology Division,
Burlington Road, Bedford, MA 01730.
David C. Sanchet is the EPA Project Officer (see below) t
The complete report is in two volumes, entitled "Applying for a Permit to Destroy
PCB Waste Oil"
Volume I. Summary (Order No. PB 81-173 346; Cost: $9.5O)
Volume II. Documentation (Order No. PB 81-234 874, Cost: $17 00)
will be available only from: (prices subject to change)
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
Telephone 703-487-4650
The EPA Project Officer can be contacted at:
Industrial Environmental Research Laboratory
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
US GOVERNMENT PRINTING OFFICE 1981 559017 7404
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Environmental Protection
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