United States
                                 Environmental Protection
                                  Industrial Environmental Research
                                  Research Triangle Park NC 27711
                                 Research and Development
                                  EPA-600/S2-82-068  Apr. 1983
Project  Summary
                                 Preliminary Operations
                                 Plan and  Guidelines for the
                                 At-Sea  Incineration of
                                 Liquid  PCB Wastes
                                  L. L. Scinto
                                   This document is a preliminary oper-
                                  ations plan and guidelines report for
                                  the disposal of polychlorinated bi-
                                  phenyl (PCB) wastes by at-sea inciner-
                                  ation. The effort on this study  was
                                  divided into two subtasks. In Subtask
                                  A, an inventory of government-owned
                                  PCB wastes suitable for at-sea incin-
                                  eration was developed. Approximately
                                  1.3 million  gallons of government-
                                  owned liquid PCB wastes were identi-
                                  fied in Subtask A, 425,000 gallons of
                                  which were considered immediately
                                  available for disposal by at-sea incin-
                                  eration. In Subtask B, operating plans
                                  and a schedule for an EPA-coordinated
                                  project to dispose  of these wastes
                                  were developed. The operations  plan
                                  addresses both land-based and at-sea
                                  operations. Land-based operations in-
                                  clude  waste collection and prepar-
                                  ation, transportation to a processing
                                  facility, processing of wastes  and
                                  containers, interim storage of  bulk
                                  liquids, transportation to a ship loading
                                  site on the Gulf of Mexico, and  ship
                                  loading. Incineration  site selection,
                                  permit requirements, incineration pro-
                                  cedures, and cargo tank decontami-
                                  nation are addressed for at-sea
                                  operations. The preliminary schedule
                                  for the disposal project shows a dura-
                                  tion of 10 months from decision to
                                  proceed with the project to completion
                                  of disposal operations.
                                   This Project Summary was devel-
                                  oped by EPA's Industrial Environmen-
                                  tal Research Laboratory, Research
                                  Triangle Park. NC, to announce key
                                  findings of the research project that is
                                  fully documented in a separate report
                                  of the same title (see Project Report
                                  ordering information at back).

                                   The problem of disposing of wastes
                                  containing polychlorinated biphenyls
                                  (PCBs) is not unique to the private sector.
                                  Various Federal, state, and local govern-
                                  ment organizations have accumulated
                                  these wastes in the course of operations
                                  and must dispose of these wastes in
                                  accordance with applicable regulations.
                                  Alternatives for  the disposal of PCB
                                  wastes include  land-based thermal or
                                  non-thermal treatment and at-sea inci n-
                                   The feasibility of disposing of govern-
                                  ment-owned PCBs  by at-sea inciner-
                                  ation was investigated.  Government-
                                  owned stocks of PCB wastes have been
                                  inventoried and a conceptual plan
                                  developed for disposal of these wastes
                                  onboard the chemical waste incinerator
                                  ship M/T Vulcanus. This project sum-
                                  mary highlights the results of the PCB
                                  inventory and operations plan.

 Summary and Conclusions
   An  inventory of government-owned
 PCB wastes suitable for at-sea incinera-
 tion was developed. The first step in
 compiling the inventory of PCB wastes
 was to  define the list of government
 organizations to be contacted. This list
 consisted originally of four organiza-
 tions, defined by EPA, from whom the
 Agency had received requests for dis-
 posal  assistance.  After initial contacts
 with these organizations, it was deter-
 mined that the quantity of wastes was
 less than the minimum amount neces-
 sary to  make at-sea incineration eco-
 nomically feasible. Therefore, the list of
 contacts was expanded at EPA's request
 to include other government and private
 industry sources.  In all cases. Regional
 EPA offices were  contacted for assis-
 tance  in locating government-owned
 stocks of PCB wastes.
   Government-owned PCB  wastes in
 the inventory were grouped as available
 and potentially available.  Available
 stocks  included those wastes which
 were  (1) liquids incinerable  on the
 Vulcanus; (2) currently stored and ready
 for transport and disposal; and (3) owned
 by an organization which expressed a
 positive interest in participating in an
 EPA-coordinated test burn, and which
 was willing to pay all disposal costs.*
 The type,  quantity, and  location of
 approximately 1.3 million gallons of
 PCBs  under government  ownership
 were identified. Of this total, only about
 425,000 gallons were considered im-
 mediately  available  for at-sea incin-
   Potentially available stocks included
 wastes  which were identified in the
 inventory but which did not meet all of

'Criterion 3 was slightly modified for the final inven-
 tory  from an  original criterion that a positive
 interest was expressed and only transportation
 costs would be paid by the waste owner. The
 change was made to ensure that stocks could be
 considered available, even if EPA could not reim-
 burse each organization for the costs of waste
 processing and incineration. Such reimbursement
 had been assumed when compilation of the inven-
 tory began
the three above criteria. About 843,000
gallons of PCB wastes were identified
as potentially available. They consisted
primarily of PCB fluids in transformers,
lubricating systems, and hydraulic sys-
tems which did not meet criterion 2.
About 17% of the potentially available
PCBs were  not considered available
because  criterion  3 was not met. A
cursory survey of  several  industrial
sources  indicated that an additional
836,000 gallons of PCB fluids were also
available from those sources.

  Figure 1 shows the volume percentage
of available  government-owned PCBs
located in each state. Tennessee, with
51%, has the  largest volume.  Most of
the available  PCBs (about 85%)  are
located in the four states of Tennessee,
Texas, Ohio, and Alabama. About 64%
of the available PCB stocks are located
in the states of Ohio, Tennessee,  and

  For the purposes  of the  inventory,
available government-owned liquid PCB
Figure 1.     Percentage of available PCB wastes located in each state.


waste  stocks were divided  into two

  •  Category A wastes consist  of
     organic liquids with PCB content
     of 500 ppm or greater.
  •  Category B wastes consist  of
     organic liquids with PCB content
     less than 500 ppm.

  Table 1 summarizes information on
ownership,  volume, PCB  content, and
location of available PCB wastes. Based
on the data in Table 1, an average PCB
content for stocks in each category (A
and B) was calculated. This average,
calculated as the volume-weighted sum
                            of concentrations in Table 1, represents
                            an estimate of what the concentration
                            of Category A and Category B wastes
                            would be if each  were blended sepa-
                            rately. The average PCB content of
                            Category A  wastes is 39% and of
                            Category B wastes 70 ppm. The overall
                            average PCB  content of all waste (i.e.,
                            the PCB concentration if all wastes
                            were blended together) is 24%.
                              Approximately 121,000 gallons, or
                            30% of the available PCBs, are stored in
                            55-gallon metal drums. The remaining
                            70% are stored in  bulk. Truck transport
                            is applicable to all available PCB stocks,
                            and rail transport  is applicable to over
                            70% of all stocks (by volume). Appendix
Table 1.
Government-Owned PCBs Available for At-Sea Incineration
Category*   Concentration*




170%)       Washington, DC. area
(50 ppm)    Washington, DC, area

New York

4 42,300
4 1 1,200
4 12,000
4 20,000
4 6,000
4 8,000
4 10,600
4 160,000
4 2,000
5 35,000
5 5,500
5 1,200
6 3,800
6 56,200
2500 ppm
1000 ppm
700 ppm
(500 ppm)
70 ppm
(50 ppm)
500 ppm
New Mexico
"PCB categories are: A-> 500 ppm PCB (organic); B = < 500 PCB (organic). These
 categories are based on the regulatory 500 ppm/50 ppm cutoffs and combustion
"Concentrations in parentheses are TRW estimates based on the following: trans-
 former fluid - 70% PCB; capacitor fluid -100% PCB; rinsate - 50 ppm PCB. Otherwise
 concentrations are based on data obtained from  waste owners. Proportions of
 transformer fluid, capacitor fluid, and rinsate are TRW estimates, unless data were
 available from owners. Rinsate volume is assumed to be 15% of the total volume, if
 present. Equal amounts of transformer and capacitor fluid are assumed, if both are
A of the full report contains more
detailed  information on all aspects of
the PCB inventory.
  Technical effort under the PCB dis-
posal project will consist of the follow-
ing tasks:

  •   Collection and preparation  of
      waste stocks prior to transport.
  •   Transportation of wastes to  a
      land-based processing facility.
  •   Processing at the land-based facil-
      ity (including dedrumming, blend-
      ing, and container disposal).
  •   Transportation of blended wastes
      to the ship loading site and ship
  •   Incineration  at sea.

Safety procedures to protect workers
and the public from  exposure to PCBs
will be observed. These procedures will
be consistent with applicable regula-
tions and accepted practices for protec-
tion of human health and the environ-
ment. Safety  precautions will be
implemented  when handling  PCBs
including use of protective  equipment,
maintenance of clean and contaminated
areas, and  monitoring. Standards and
guidelines for worker exposure to PCBs
will be observed.  Finally, contingency
plans will be in effect which will define
steps taken to prepare for .and prevent
emergency situations and to deal with
these situations should they arise.
  Wastes will first  be collected and
prepared for transportation by the waste
owners. Currently all of the available
PCBs are stored in  bulk or 55-gallon
metal drums. Owners will  be respon-
sible  for ensuring  that wastes are
properly packaged, marked, and shipped
in accordance with Department of Trans-
portation (DOT) regulations (49 CFR
171 -179) and provisions of EPA's Toxic
Substances Control Act (TSCA) regula-
tions  (40 CFR 761). The DOT  hazard
class  is  the key  to  determining the
proper shipping name and  packaging
requirements for PCB wastes. The
hazard class for PCBs (40 CFR 172.101)
is Other Regulated Materials-E (ORM-E)
and the proper shipping name is poly-
chlorinated biphenyls (RQ-10/4.54).
Specific  packaging  requirements for
ORM-E are indicated in 40 CFR 173.510.
Marking  requirements for  PCBs are
defined by TSCA regulations in 40 CFR
761.20 and 40 CFR 761.44. Preparation
procedures include obtaining analytical
data on the waste sufficient to provide
information on  PCB  content,  diluent

and/or rinse solvent, heating value, and
other information (e.g., sludge content)
needed  to determine whether special
handling, processing, or safety proce-
dures are needed prior to incineration.
Shipping containers will be inspected
before,  during, and after  loading for
  The waste owner will select the trans-
portation mode (rail or truck) he deems
most suitable and which is acceptable to
the disposal contractor. Shipping papers
must accompany each PCB waste ship-
ment. The format should be as described
in DOT  regulations (40 CFR  172.200-
204). Alternatively, a manifest system
may be employed as described in EPA's
Resource Conservation and  Recovery
Act (RCRA) regulations (40 CFR 263,
Subpart B). State and local regulations
may also apply to transportation of PCBs,
and may be more stringent than Federal
regulations. Regulatory aspects of waste
shipments  should  be coordinated
through EPA Regional Offices and the
responsible  state or local regulatory
authorities. Firm commitments for trans-
port of PCB wastes should be obtained
by waste owners. These commitments
should  include  method of transport,
schedules, shipping papers or manifests,
routes,  destinations,  liability, and au-
thority transfer requirements. Written
instructions (contingency plans) should
be provided in case of spillage, fire, or
need for in-transit transfer  from  one
vehicle to another,  consistent  with
applicable DOT and EPA regulations (40
CFR 177 and 40 CFR 761, respectively)
and provisions of the National or Region-
al Contingency Plans.
  Wastes will be transported to a land-
based facility  for processing prior to
incineration. The land-based processing
facility was assumed to be located near
a port on the Gulf of Mexico, because
this  location is close to available PCB
stocks and an  EPA-designated at-sea
incineration site. Federal  regulations
under RCRA require the owner/operator
of a facility handling hazardous wastes
which supports an at-sea  incineration
vessel to  obtain a permit. The land-
based processing facility should either
(a) have RCRA interim  status  (i.e.,
comply  with the filing requirements of
40 CFR  122.22 and meet the applicable
standards set forth in 40 CFR 265), or (b)
have a RCRA permit  and  meet the
applicable standards set forth in 40 CFR
264, or (c) have interim status or a final
permit under an authorized state RCRA
hazardous waste program. The facility
should be designed to prevent emissions
of hazardous materials, contain spills,
leaks, and other accidents, and minimize
harm to personnel in  the event of
accidents. It must  be  capable of (a)
analyzing incoming wastes to determine
processing requirements, (b) processing
wastes and drums (e.g., solids removal
and emptying, rinsing, and disposing of
drums), (c) blending wastes to obtain a
suitable mixture for burning in the
shipboard incinerator, and (d) tempor-
arily storing wastes prior to ship loading.
TSCA regulations (40 CFR 761) dictate
rinsing requirements (triple rinse with a
suitable  solvent, equivalent to about
85% removal of PCB residuals), storage
requirements (approved containers),
and drum disposal requirements (Annex
II chemical waste landfills or approved
incinerators). Blended wastes must be
able to support combustion without
auxiliary fuel. In general, this require-
ment will be met if the wastes contain
less than 30-40 percent chlorine and
have a net heating value of at least 6300
Btu per pound.
  Blended PCB wastes will be trans-
ported to the incinerator ship by pipeline,
rail, or truck. Pipeline transport is the
preferred method, but is only applicable
if an existing pipeline can be used or if
the processing facility is located near
the ship loading dock. Transportation by
rail and truck is subject to the DOT and
EPA regulations noted above for waste
shipments to the land-based processing
facility. Ship loading operations encom-
pass two distinct areas of responsibility:
land-based and shipboard. Land-based
responsibilities include, for example,
operating the waste pumping system,
connecting the pumping system to the
PCB transportation vehicle, pipeline, or
docksidetank, and visual monitoring for
leaks from pumps and  piping connec-
tions. Shipboard responsibilities include
connecting  the loading  hose  to the
loading manifold, operating valves to
load various tanks,  gauging the tanks,
and monitoring for  shipboard leakage.
At the end of the loading operation, all
equipment which has come into contact
with PCBs must be decontaminated by
rinsing as per Annex IV of the TSCA PCB
Regulations, 40 CFR 761.43.
   At-sea  incineration  operations  are
subject to a number of Federal and
international regulations.  EPA regula-
tions  (40 CFR 220-229)  under the
Marine Protection, Research, and Sanc-
tuaries Act (MPRSA) and Intergovern-
mental Maritime Consultative Organi-
zation (IMCO) regulations and guidelines
under the London Dumping Convention
apply to  at-sea incineration of PCBs.
Some provisions of RCRA regulations
also apply. MPRSA regulations require
that the material to be burned must be
adequately described in the ocean dump-
ing permit and that the precise times
and locations of incineration must be
specified. Technical requirements are
not detailed in MPRSA regulations, but
are established on a case-by-case basis.
IMCO regulations do specify technical
requirements such as operating condi-
tions  and  monitoring requirements.
These regulations specify a minimum
flame temperature of 1250°C,*  com-
bustion and destruction efficiencies  in
excess of 99.9 percent, automatic waste
shut-off devices, and monitoring of CO
and C02 in  the stack gas. Additional
IMCO requirements forbid black smoke
or flame extension above the exit plane
of the  stack, require prompt reply  to
radio calls  during  incineration, and
prescribe certain recordkeeping require-
ments. Incineration under  terms of a
research permit** also requires moni-
toring of total organic chlorine and total
hydrocarbons in the stack gas. A RCRA
permit application need not be filed by
the owner/operator of the incineration
vessel because such a person isdeemed
to have a RCRA permit by rule if he has a
valid ocean dumping permit, complies
with the terms of that permit,  and
complies with certain RCRA manifest,
recordkeeping,  and reporting require-
ments under 40 CFR 264.
  Shipboard monitoring, sampling, and
analysis  of combustion product gases
must be performed to comply with the
terms of the ocean  dumping permit.
Existing  equipment on the Vulcanus
may be  used  for monitoring flame
temperature (by  using  a  correlation
based on furnace wall temperature
measured by thermocouple) and COz
and CO in the stack gas (by continuous
monitors). Additional monitors for oxy-
gen and total hydrocarbons could  be
easily installed, if required.  Onboard
analysis for total organic chlorine and
PCB in the  stack gas can  be accom-
plished  by sampling with  a benzene
impinger train equipped with water-
cooled  probe and analysis  of samples
obtained from this train by onboard gas
'Unless adequate destruction at a lower tempera-
 ture is substantiated by test results.
"EPA policy has been to grant research permits for
  the first burn of a particular waste, and special
  permits for subsequent burns

chromatograph. An  electron capture
detector could be used for PCB deter-
minations (in both waste feed and stack
gas) and a Hall electroconductivity de-
tector could be adapted for determining
total organic chlorine. Onboard analysis
of samples of ambient (personnel breath-
ing zone)  air for  PCB should be per-
formed in accordance with  a  written
health and safety plan. Other samples,
such as wipe samples of ship surfaces
and drinking water supplies,  should be
taken for possible analysis if PCB con-
tamination is indicated by ambient air
samples. Land-based analysis using gas
chromatography/mass  spectrometry
(GC/MS) techniques  should be used to
confirm onboard  PCB determinations.
Limited analyses for chlorinated dioxins
anddibenzofurans using GC/MS should
be considered, beca use these extremely
toxic compounds  may be formed from
combustion  of PCB wastes containing
  Serial rinsing of the ship's tanks using
successively lower concentration PCB
wastes is  the recommended procedure
for cargo tank decontamination. That is,
after the tankful of high concentration
PCB liquids  has been incinerated, the
tank should  be filled  again with lower
concentration  PCB liquids which are
then incinerated. This procedure should
provide sufficient removal of residual
PCBs.  Full decontamination using a
triple rinse or equivalent procedure is
unnecessary because PCB residues
remaining in the tanks will be greatly
diluted by subsequent waste cargoes
and destroyed  during ensuing  burns.
Normally,  the tanks on the Vulcanus are
not cleaned between  burns of different
wastes, because no humans are exposed
to waste  residues inside the  empty
tanks. However, if entry into the cargo
tanks is required after PCBs are burned,
a more rigorous tank decontamination
procedure should be employed. The
decontamination procedure  employed
should be tailored to the specific situa-
tion using the  most  applicable  equip-
ment and procedures. Acceptable levels
of PCBs in tank residuals should also be
determined  based on the situation.
Because TSCA regulations have set the
lower limit concentration for regulating
PCBs at 50 ppm, verification of residual
PCB levels in the ship's tanks of less
than  50  ppm  should be required.*
However,  health and  safety considera-

*A recent court decision on the 50 ppm limit
 (described in the May 20,1981, Federal Register)
 may affect this criterion.
tions may require  a more  stringent
  A preliminary schedule for a project to
dispose of government-owned PCB
wastes is presented in Figure 2. Several
assumptions were made in constructing
the project schedule. These assump-
tions involve estimating durations and
assuming  certain logical relationships
between tasks. The  major logical as-
sumptions were:
  •  EPA  would coordinate  collection
     and transportation of PCB wastes
     to a central land-based processing
     facility, requiring contracts with
     individual waste owners.
  •  The ship owner would also operate
     the land-based processing facility,
     so that a  single contract could be
     awarded  for land-based and at-
     sea operations.
  •  An incinerator ship  would  be
     certified, in U.S.  waters, and
     available to incinerate PCBs when
  •  No permits other than  an  at-sea
     dumping permit would be re-
  •  A designated at-sea incineration
     site would be  available for the
*"An ocean  dumping permit for incineration of
  PCBs onboard the M/T Vulcanus in  the Gulf
  Ocean Incineration Site was recently awarded.
Because  monitoring activities on land
and at sea were not anticipated to be
critical schedule items, they were not
included  in the preliminary schedule.
Planning and performance of these tasks
are, however, essential from a project
  Two key milestones are important in
performance of this project, in light of
the preliminary schedule for incinera-
tion. The first  is the expiration of. the
designation of the Gulf Ocean Incinera-
tion Site. Designation of this site expired
on September  15, 1981. Because this
at-sea incineration site has been identi-
fied as the site for at-sea incineration of
PCBs, redesignation of this site will be
required. The second  important mile-
stone is the expiration of the seaworthi-
ness  certificate of  the Vulcanus
(September 1982). No incineration can
take place on the Vulcanus  after this
date unless  the ship's certification is
extended temporarily or  the  ship is
  Based on the current assumptions for
project logic and duration, it is possible
for EPA to coordinate an at-sea incin-
eration project for disposal of govern-
ment-owned PCBs on the Vulcanus
under the existing ocean dumping per-
mit before the ship's certificate expires.
To do this, a decision  to proceed with
Decision to proceed with disposal '
Obtain additional data on wastes i
Prepare public participation work plan
Finalize operations plan
Obtain ocean dumping permit
Begin waste shipments to land-based
Receive and analyze wastes
Dedrum wastes as required
Blend and temporarily store wastes
Transport wastes to loading dock and
load ship
Burn wastes
i— «






Figure 2.    Project schedule.

disposal had to be made by December
1980. An alternative scenario which
might further compress the project
schedule would be for individual waste
owners to contract directly with the ship
owner for disposal services. In either
case, the need for obtaining an ocean
dumping permit (activity 4-6 in Figure 2)
would be negated, because a permit
already exists. Otherwise, government-
owned PCB wastes could not be incin-
erated  at sea until (a) another at-sea
incineration vessel becomes available,
and (b) another ocean dumping permit is
applied for and approved. This alterna-
tive would delay substantially the dis-
posal project. This  would  result in
additional costs being incurred  by a
number of government organizations
for storing PCB wastes. Such a  delay
might force many of these organizations
to abandon at-sea incineration for other
disposal methods as a means of destroy-
ing their liquid PCB wastes.
L. L. Scinto is with TRW Inc., Redondo Beach, CA 90278.
David C. Sanchez is the EPA Project Officer (see below).
The complete report, entitled "Preliminary Operations Plan and Guidelines for the
  At-Sea Incineration of Liquid PCB Wastes," (Order No. PB 83-181 834; Cost:
  $13.00, subject to change) will be available only from:
        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
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