PCB WHITE PAPER
: GCA
GCA CORPORATION
Technology Division
213 Burlington Road
Bedford, Mass. 0)730
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Prepared for
U.S. Environmental Protection Agency
Industrial Environmental Research Laboratory
Research Triangle Park, NC 27711
EPA Project Officer
David Sanchez
Contract No. 68-02-3168
Work Assignment No. 12
PCB WttlTE PAPER
October 3, 1980
Paul F. Fennelly
Project Manager
GCA CORPORATION
GCA/TECHNOLOGY DIVISION
Bedford, Massachusetts
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EXECUTIVE SUMMARY
Widespread interest in the environmental significance of PCBs has led
to intensive research into the hazards and distribution of these pollutants.
Review of the conclusions from these investigations led to the promulgation
of regulations controlling the manufacture, distribution, use, and disposal
of PCBs. This document has been prepared in an effort to briefly summarize
pertinent federal regulatory actions and the technical justifications and
economic analysis performed prior to the promulgation of the regulations.
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INTRODUCTION
The PCB materials are polychlorinated biphenyls and terphenyls containing
a mixture of compounds and isomers in which the chlorine content can range
from 18 to 79 percent by weight. The mean percentage for chlorine content is
controlled to give the required chemical and physical properties as determined
by the application to be met.
The world's largest producer, and the sole producer in the U.S., has been
the Monsanto Company. Commercial production began in 1930 and cummulative
world production since then is generally estimated to be on the order of 1
to 1.2 million tons.
It is a combination of highly desirable properties that has led to wide-
spread use of PCBs. They are liquid over a wide temperature range, have
low vapor pressure (high boiling temperatures), are excellent dielectric
materials, and exhibit very high thermal and chemical stability. They have
found use in a variety of applications including dielectric fluids, carbon-
less carbon paper, heat transfer fluids, hydraulic fluids, and cutting oils.
Cases of PCB poisoning were reported first in the manufacturing industry
during the 1930's. This occupational disease was characterized by aneiform
and occasional impairment of the liver. Beginning in 1953 cases were
reported in Japanese industries manufacturing condensers. The acute toxic
effects of PCBs were brought to the forefront of the public's attention in
1968 after PCB-contaminated cooking oil caused widespread poisoning in
Japan. Other incidents of PCB food contamination in the U.S. have brought
increased attention to PCB uses and the related dissemination into the
environment. Since 1966 many studies have shown distribution in the environ-
ment to be extensive.
An estimated 500 thousand tons of PCBs have entered dumps and landfills
where they in all likelihood are chemically stable but subject to slow
release. A list follows for the major routes by which PCBs enter the
environment:
• By leaching, dust transport, burning of wastes, seepage,
and erosion from landfills holding PCB wastes and PCB-
containing wastes.
• From dumpsites of convenience (back lots, woods, roadsides,
swamps, idle land, etc.) by the same mechanisms as from
officially designated landfills.
• Direct discharge of PCB wastes and waste-containing products
into streams, rivers, and other waterways.
• Recycling of PCB-containing paper.
• Discharge into sewage system.
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• Runoffs of insecticides in which PCBs were used to extend
the kill-life.
• Industrial smoke from inadvertent incineration of PCB-
containing materials.
As industry and government became increasingly aware of the hazards and
environmental degradation associated with the use of PCBs, their sale was
restricted and regulations appeared to control their manufacturing and dis-
posal.
As documented by the World Health Organization, "the serious outbreaks
of poisoning in man and domestic animals from the ingestion of food accidently
contaminated with PCBs have stimulated investigations into the toxic effects
of PCBs in animals and on nutritional food chains." As a result in 1973-the
U.S. Food and Drug Administration (FDA) established temporary limitations
of PCBs in food. Need for this action was further confirmed by an FDA
surveillance and inspection program which identified numerous lots of contam-
inated foods.
REGULATION OF PCBs
From July 1969 to August 1971, nine incidents of PCB contamination of food
were reported. No record of human PCB poisoning in the U.S. has occurred,
but near disasters have resulted in regulatory action. In 1973, the FDA
established temporary limitations of PCBs in food. A surveillance and
inspection program by the FDA detected numerous lots of contaminated
foods.
The Clean Water Act of 1977 contains the first regulation by the Environ-
mental Protection Agency (EPA) regarding PCBs. Under Section 307(a), manu-
facturers of electrical transformers and capacitors were prohibited from dis-
charging PCBs into waterways (Federal Register, Vol. 42, February 2, 1977,
pp. 6532-6556). These regulations stipulated February 2, 1978, as the dead-
line for compliance, allowing affected manufacturers 1 year to take the neces-
sary steps (e.g., use of substitute materials and equipment or process
changes) to eliminate PCBs from their effluents.
On March 26, 1976, as work was being performed on promulgation of regulations
for toxic effluents under the Clean Water Act, Senator Gaylord Nelson of
Wisconsin introduced an amendment to the Toxic Substances Control Act (TSCA)
for the phasing out of PCBs in manufacturing processes in the U.S. The TSCA
was promulgated on October 11, 1976, and contained this amendment as Section
6(e). Section 6(e) requires the EPA to control the manufacture, processing,
distribution, use, and disposal and marking of PCBs.
The disposal and marking rule for PCBs, Section 6(e)(l), was promulgated
by the EPA on February 17, 1978 (Federal Register, Vol. 43, No. 34, pp.
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7150-7164), and clarified in an addendum of August. 2, 1978 (Federal Register,
Vol. 43, No. 149, pp. 33918-33920). EPA published the proposed rules for
Sections 6(e)(2) and 6(e)(3), which regulated PCB use, on June 7, 1978
(Federal Register, Vol. 43, pp. 24802-24817). These rules were supported by
documentation, voluntary environmental impact statements and numerous public
hearings. On November 1, 1978, EPA published interim rules for Section 6(e)
(3)(B) establishing procedures for persons to petition the Administrator
of EPA for exemptions from prohibitions to manufacture, process, or distribute
in commerce PCBs. The final rule, promulgated on May 31, 1979 (Federal Reg-
ister, Vol. 44, No. 106, pp. 31514-31568) declares the prohibition of pro-
cessing, manufacturing, and distributing of PCBs after July 1, 1979, unless
specifically exempted by EPA. The final rule became effective July 2, 1979.
TECHNICAL JUSTIFICATION FOR THE FINAL RULE
Destruction in High Efficiency Oil-Fired Boilers
Prior to the finalization of the PCB rule, both theoretical calculations
and field data were available which offered convincing evidence of the
ability of an oil-fired boiler to destroy various concentrations of PCBs.
In October of 1976, Monsanto Research Corporation published a theoretical
study on PCB emissions from stationary sources.1 This report not only
addressed the potential of formation of PCBs during the combustion of fossil
fuels, but also the destruction of PCBs. The conclusion reached was that
under thermodynamically controlled situations the "chlorinated biphenyls would
react to essentially extinction."1
Prior to the publication of the Monsanto study, in May 1976, Florida
Power and Light Company had reported on the results of a PCB burn conducted
at their Sanford Unit No. 4. The stack sampling and analysis for PCBs was
conducted by a private contractor. The results of this test in which PCB-
contaminated oil was fired along with No. 6 fuel oil revealed no detectable
amount of PCBs in the stack gas. The Method 5 particulate train was used for
sampling, and Aroclor pattern matching by gas chromatograph-electron capture
detection (GC-ECD) was used for analysis.2
In October of 1976 the EPA published a report detailing the emission
testing at the Continental Can Company in Hopewell, Virginia, during PCB
burning. This investigation reached the conclusion that the power boilers
tested achieved greater than 99 percent destruction efficiency of the PCB
present in the fuel.3
In December of 1977 the University of Dayton Research Institute under
contract to the EPA published a report on the laboratory evaluation of high-
temperature destruction of PCBs and related compounds. This evaluation
established that PCBs could be destroyed at greater than 99.995 percent
molecular destruction at a residence time of 1 second and a temperature of
1000°C.'t
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Destruction in Incineration Systems
Prior to the finalization of the PCB rule, incineration tests of high
concentrations of PCBs had been conducted. In December 1976 the rotary
kiln installation at Rollins Environmental Services, Inc., was tested for
its ability to destroy PCBs.5 The FCBs were introduced to the rotary kiln
in the form of contaminated whole capacitors and contaminated hammermilled
capacitors. Calculated PCB destruction efficiencies for whole capacitors
were'99.5 percent and for hammermilled capacitors, greater than 99.999 percent.
The gas residence time in this system is on the order of 2 to 3 seconds with
a flame temperature of about 1500 C.
In January 1976 PCB destruction tests were conducted at the St. Lawrence
Cement Co. The destruction efficiency of PCBs was calculated to be 99.986
percent. The kiln was maintained at 1450 C with an approximate residence
time of 3 seconds.
In another test in 1976 at the Continental Can Company, PCBs in waste oil
were fired into a rotary lime kiln maintained at 1260°C during the tests.3
Destruction efficiency at this site was found to be 95.4 percent.
In a test in Sweden conducted by the Swedish Water and Air Pollution
Research Institute a rotary cement kiln achieved a 99.9998 percent destruction
efficiency of PCBs.7
These data for both high efficiency boilers and rotary-type kiln incinera-
tors provided a convincing argument for the ability of these units to achieve
high destruction efficiency of PCBs.
ECONOMIC ANALYSES FOR THE FINAL RULE
Prior to the promulgation of the final rule, economic analyses were con-
ducted to assess the impact of the proposed rule. Versar, Inc., of Spring-
field, Virginia, prepared two documents for EPA: Microeconomic Impacts of
the Proposed Marking and Disposal Regulations for PCBs (April 1977) and
Microeconomic Impacts of the Proposed "PCB Ban Regulations" (May 1978).
Versar revised these documents upon the request of EPA prior to the
promulgation of the final rule. The final report is entitled PCB
Manufacturing Processing, Distribution in Commerce, and Use Ban Regulation:
Economic Impact Analysis, March 30, 1979.
Versar concluded that the proposed marking and disposal regulation would
cost an estimated $62.2 million the first year. The cost would include new
incinerators, new storage facilities, operating costs, chemical waste land-
fill charges, disposal transportation costs, recordkeeping for marking, and
maintenance of storage facilities. The major economic impacts would apply to:
utilities owning and using large high voltage capacitors; owners and users
of high intensity discharge lighting capacitors, small capacitors, large
low voltage capacitors, or equipment containing such capacitors; manufacturers
of equipment containing PCB articles; and manufacturers of large low
voltage capacitors, small capacitors and fluorescent light ballasts.
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The analysis of economic impacts for the PCB ban regulation was divided
into transitional and long-term cost impacts. The transitional costs are
those costs necessary to eliminate all existing PCB-containing equipment from
service. For example, the total cost of the ban on sales of PCB capacitors
and equipment after July 1, 1979, including inspection and rework costs,
could easily exceed $1 billion. The long-term costs will be continuing
costs and will have a long-term economic impact. Examples include the
increased cost of non-PCB transformers and power factor capacitors.
SAMPLING AND ANALYSIS
As a support document to the final rule PGB regulations of May 31, 1979,
EPA published an interim sampling and analysis manual for PCB Disposal.8
This manual provides guidance on several key aspects of PCB monitoring.
These include the following.
• Spill contamination levels - Surface and subsurface sam-
ples of the entire suspected contamination area must
be taken and analyzed for PCB content using the air dried,
10 percent moisture added SOXHLET extraction procedure.
• Monitoring feed rate - For liquids, any conventional
commercially available flow meter is acceptable.
Instruments which provide real-time measurement in a
visual display are recommended. For solid PCB materials,
load weights should be determined by weighing several
representative loads and averaging them.
• Monitoring incinceration operations and combustion pro-
ducts - Combustion temperature must be monitored to insure:
• a 1.5 second dwell time at 1600°C and 3 percent excess oxygen.
I Specifications for instrumentation to monitor flue gas
temperature (thermocouples), carbon monoxide and carbon
dioxide (nondispersive infrared (NDIR) analyzers) and excess
oxygen (paramagnetic or electrochemical devices) are given.
Flue gas temperature and scrubber water monitoring locations
are recommended and a method for calculating dwell time
is presented.
• Conducting and monitoring a test burn - Pretest equipment
checks and safety procedures are established. The following
non-continuous stack monitoring procedures for combustion
products are specified.
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CO, C02, 02 —
Total particulate —
NOX -
HC1 —
EPA Method 3
EPA Method 5 . .
EPA Method 7
Collected with an impinger filled
with caustic. Analyzed for chloride
I ion using the Mercuric Nitrate
Method (as described in Standard
Methods for the Examination of
Water and Wastewater).
Total chorinated
organic content
and PCB — Collected on a solid sorbent trap such
as XAD-2 amberlite resin, which is
located in the sampling train down-
stream of the heated filter and up-
stream of the first impinger. The
sample is then removed from the trap
via a 24-hour SOXHLET extraction with
both pentanol and methanol. Extracts
are dried with sodium sulfate and
concentrated to 10 ml. Finally the
sample is analyzed for PCB and RCL
content by Gas Chromatography - Mass
Spectroscopy.
The manual includes as attachments, details of analysis methods cited and
should be referenced for specific sampling and analysis questions.
CONCLUSION
The intent of environmental legislative action is to protect the public
health and welfare. This is accomplished by setting standards; establishing
agencies capable of enforcing these standards; and actually implementing tech-
nical and administrative mechanisms for the effective enforcement of pollution
controls. Another function of statutory law is to establish conservation and
development programs to enhance the quality of the environment. The promulga-
tion of these regulations pursuant to Section 6(e) of TSCA exemplifies this
intent.
The regulations as finally implemented serve as an excellent guide to the
future use, storage and disposal of PCBs. However, the potential for exposure
will remain until all PCBs have been adequately contained or destroyed as
specified in the regulations.
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REFERENCES
1. Knieriem, H., Jr. PCB Emissions From Stationary Sources: A
Theoretical Study. Monsanto Research Corporation, Dayton, Ohio.
Prepared for U.S. Environmental Protection Agency, Washington, B.C.
EPA-600/7-76-028. October 1976.
2. Report on PCB Emissions From Sanford Unit No. 4, Florida Power and
Light Company. Environmental Science and Engineering, Inc.,
Gainesville, Florida. May 1976.
3. Emission Testing at Continental Can Company, Hopewell, Virgina,
July 14-23, 1976. Environmental Protection Agency, Office of
Enforcement. EPA-330/2-76-030. October 1976.
4. Duvall, D. S. and W. A. Rubey. Laboratory Evaluation of High-Temperature
Destruction of Polychlorinated Biphenyls and Related Compounds.
University of Dayton Research Institute, Dayton, Ohio. Prepared for
U.S. Environmental Protection Agency, Municipal Environmental Research
Laboratory, Cincinnati, Ohio. EPA-600/2-77-228. December 27.
5. Haile, C. F. and E. Baladi. Methods for Determining the Polychlorinated
Biphenyl from Incineration and Capacitor and Transformer Filling Plants.
EPA-600/4-77-048. November 1977.
6. MacDonald, L. P., D. J. Skinner, F. J. Hopton, and G. H. Thomas. Burning
Waste Chlorinated Hydrocarbons in a Cement Kiln. Report to Fisheries
and Environment Canada. Report No. EPS 4-WP-77-2. March 1977.
7. Ahling, B. Destruction of Chlorinated Hydrocarbons in a Cement Kiln.
Environ. Sci & Tech., 13:1377, 1979.
8. Beard, J. H. and J. Schaum. Sampling Methods and Analytical Procedures Man-
ual for PCB Disposal: Interim Report. U.S. Environmental Protection
Agency, Office of Solid Waste, Washington, D.C. February 1978.
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ADDITIONAL READING
Federal Register, Vol. 43, No. 34, Friday, February 17, 1978, pp. 7150-7164.
Federal Register, Vol. 43, No. 149, Wednesday, August 2, 1978, pp. 33918-33920.
Federal Register, Vol. 44, No. 106, Thursday, May 31, 1977, pp. 31514-31568.
Federal Register, Vol. 44, No. 183, Wednesday, September 19, 1979, pp.
54296-54297.
Federal Register, Vol. 45, No. 62, Friday, March 28, 1980, pp. 20473-20475.
PCB Marking and Disposal Regulations - Support Document (40 CFR Part 761).
U.S. Environmental Protection Agency (OTS-068005), undated.
PCB Marking and Disposal Regulations Final Action - Support Document
(40 CFR Part 761). U.S. Environmental Protection Agency.
Support Document/Voluntary Environmental Impact Statement and PCB Manufacturing,
Processing, Distribution in Commerce, and Use Ban Regulation: Economic
Impact Analyses. U.S. Environmental Protection Agency, Office of Toxic
Substances, Washington, D.C., April 1979.
Environmental Research Brief, Thermal Degradation of-PCBs. U.S. Environmental
Protection Agency, Municipal Environmental Research Laboratory,
Cincinnati, Ohio, October 1978.
Polychlorinated Biphenyls. National Academy of Science, Washington, D.C.,
1979.
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