United States
Environmental Protection
Agency
Industrial Environmental Research
Laboratory
Research Triangle Park NC 27711
Research and Development
EPA-600/S2-82-068 Apr. 1983
xvEPA
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).
Introduction
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-
eration.
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.
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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-
eration.
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
Kentucky.
For the purposes of the inventory,
available government-owned liquid PCB
Figure 1. Percentage of available PCB wastes located in each state.
2
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waste stocks were divided into two
categories:
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
Government
Organization
Volume,
Gallons
PCB
PCB
Category* Concentration*
Location
1
1
2
2
8,500
1,500
20,000
1,500
20,000
A
B
A
A
170%) Washington, DC. area
(50 ppm) Washington, DC, area
(70%)
(70%)
(70%)
Alabama
New York
Alabama
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
A
A
A
A
A
A
A
B
B
A
A
A
A
A
(70%)
(70%)
(70%)
2500 ppm
1000 ppm
700 ppm
(500 ppm)
70 ppm
(50 ppm)
40%
(70%)
(70%)
35%
500 ppm
Ohio
Kentucky
Tennessee
Tennessee
Tennessee
Tennessee
Tennessee
Tennessee
Tennessee
Missouri
New Mexico
Colorado
Texas
Texas
"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
considerations.
"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
present.
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
loading.
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
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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
transport.
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
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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
chlorobenzenes.
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
criterion.
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
required.
No permits other than an at-sea
dumping permit would be re-
quired.**
A designated at-sea incineration
site would be available for the
project.
*"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
standpoint.
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
recertified.
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
Activities
Description
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
facility
Receive and analyze wastes
Dedrum wastes as required
Blend and temporarily store wastes
Transport wastes to loading dock and
load ship
Burn wastes
Months
1
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i
L
2
r
3
-
4
'
5
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6
r
J
i
7
\
A.
8
*
-*7
t
9
7
*-«
I
10
W-*7
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Figure 2. Project schedule.
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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
&U. S. GOVERNMENT PRINTING Off ICE: 1983/659-095/1932
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Environmental Protection Information Environmental
Agency Cincinnati OH 45268 Protection
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5s s Tio" AGENC₯
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