DRAFT GUIDELINES
FOR
PERMIT APPLICATIONS AND DEMONSTRATION TEST PLANS
FOR
PCB INCINERATORS
MAY 28, 1986
U.S. Environmental Protection Agency
Office of Toxic Substances
Chemical Regulation Branch
TS-798
Washington, D.C. 20460
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TABLE OF CONTENTS
Preface 11
List of Figures v
List of Tables vi
Abbreviations vii
Glossary x
1.0 Introduction 1
2.0 Summary of 40 CFR 761 Regulations and Guidance 2
2.1 General 2
2.2 Approval Authority 2
2.3 §761.70 Incinerators 2
3.0 Office of Toxic Substances (OTS) Permitting Procedures. . . 9
3.1 Establish Communications with the EPA Permit
Writer 9
3.2 Apply for an R&O Permit (Optional) 9
3.3 Submit Operating Permit Application and
Demonstration Test Plan to DO/EED 13
3.4 EPA/OTS Review of Permit Application and
Demonstration Test Plan 14
3.5 EPA/OTS Issues Demonstration Test Permit 14
3.6 Conduct Demonstration Test 14
3.7 Submit Demonstration Test Report to DD/EED. ... 15
3.8 EPA/OTS Review of the Demonstration Test Report . 15
3.9 DD/EED Issues an Operating Permit 15
4.0 Permit Application Format 16
4.1 Permit Application Cover 16
4.2 Section I - Summary 16
4.3 Section II - Project Organization 16
4.4 Section III - Waste Description 19
4.5 Section IV - Process Engineering Description. . . 19
4.6 Section V - Monitoring Plan 22
4.7 Section VI - Monitoring Procedures 25
4.8 Section VII - Data Reporting/Recordkeeping. ... 25
4.9 Section VIII - Inspection Procedures 26
4.10 Section IX - Spill Prevention Control and
Counter-measures Plan 27
4.11 Section X - Safety Plan 27
4.12 Section XI - Training Plan 27
4.13 Section XII - Plans for a Demonstration
(Trial Burn) 27
4.14 Section XIII - Test Data or Engineering
Performance Calculations 28
111
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TABLE OF CONTENTS (continued)
4.15 Section XIV - Other Permits/Approvals 28
4.16 Section XV - Schedule of Pre-Operation Events- . . 28
4.17 Section XVI - Quality Assurance Plan 28
4.18 Section XVII - Standard Operating Procedures. . . 29
4.19 Section XVIII - Closure Plan 30
5.0 Demonstration Test Plans 31
5.1 General 31
5.2 Contents of a Demonstration Test Plan 31
6.0 Conducting and Monitoring a Demonstration Test 44
6.1 Start-up 44
6.2 PCB Waste Destruction 45
6.3 Shutdown 45
7.0 Demonstration Test Report 46
7.1 Format and Contents 46
7.2 Review 52
7.3 Approval 52
8.0 References 53
Appendix A - Checklists for Completeness of Submittal A-l
Appendix B - Monitoring, Sampling, and Analysis Procedures B-l
Appendix C - OTS Guidance on Frequently Asked Questions C-l
Appendix D - Addresses for Headquarters and Regional Offices D-l
Appendix E - Annotated Bibliography E-l
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List of Figures
Figure
1
2
3
4
5
6
7
Title
Major steps in the OTS operating permit process ......
Process to obtain an operating permit from OTS
Research permitting process
Example permit application cover
Schematic of sampling and monitoring points for an
incinerator
Cover for the Demonstration Test Plan
Demonstration Test Report cover
Page
, . 10
. . 11
12
. . 18
. . 23
. . 33
. . 48
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List of Tables
Table Title Page
1 Outline of Major Sections of 40 CFR 761 : . . 3
2 Disposal Options by PCB Waste Categories 4
3 Summary of Permit Approval Authority 5
4 Format for Permit Applications for PCB Incinerators 17
5 Example Summary of Monitoring Plan for a Mobile
Incinerator 24
6 Format of Demonstration Test Plan for Incinerators 32
7 Example Summary of Anticipated Test Parameters for an
Incinerator 36
8 PCDD and PCDF Reporting Format 38
9 Example: Proposed Schedule for Trial Burn 42
10 Format for the Demonstration Test Report 47
12 Example Demonstration Test Results Summary 49
VI
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ABBREVIATIONS
AA: Assistant Administrator for Pesticides and Toxic Substances. .
acm: Actual cubic meters.
acfm: Actual cubic feet per minute.
BTU: British thermal unit.
°C: Degrees Celsius.
CE: Combustion efficiency.
CFR: Code of Federal Regulations.
CO: Carbon monoxide.
C02: Carbon dioxide.
CWA: Clean Water Act. See 40 CFR 129.
CEMS: Continuous emissions monitoring system.
DD/EED: Division Director, Exposure Evaluation Division.
ORE: Destruction and removal efficiency.
dscf: Dry standard cubic feet.
dscm: Dry standard cubic meters.
DVE: Data variance estimate.
ECD: Electron capture detector.
EIMS: Electron impact mass spectrometry (low resolution).
EPA: U.S. Environmental Protection Agency.
ESP: Electrostatic precipitator.
°F: Degrees Fahrenheit.
FR : Flow rate of gas in the stack. Also termed Q or ER by some authors.
5 S S
g: Grams.
gal.: Gallons.
GC: Gas chromatography.
vii
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GC/ECD: Gas chromatography with electron capture detection.
GC/MS: Gas chromatography/mass spectrometry.
GPC: Gel permeation chromatography.
gpm: Gallons per minute.
gr: Grains
h: Hours.
HC1: Hydrochloric acid.
HECD: Hall electron capture detector.
H20: Water.
HRGC: High resolution GC, also termed capillary GC.
in.: Inch(es).
kg: Kilograms.
Ib: Pounds.
mg: Milligrams.
min: Minutes.
MS: Mass spectrometry.
NEPA: National Environmental Policy Act.
NO : Oxides of nitrogen.
NPDES: National Pollutant Discharge Elimination System.
02: Oxygen.
OPTS: Office of Pesticides and Toxic Substances.
OSHA: Occupational Safety and Health Act. See 29 CFR 1910.1.
OTS: Office of Toxic Substances, a suborganization of OPTS.
PCB: Polychlorinated biphenyl(s).
PCDD: Polychlorinated dibenzo-p_-dioxin.
PCDF: Polychlorinated dibenzofuran.
PGC: Packed column gas chromatography.
vi ii
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pH: Measure of acidity or alkalinity.
ppm: Parts per million.
psi: Pounds per square inch.
QA: Quality assurance.
QC: Quality control.
RA: Regional Administrator.
RC1: Total chlorinated organics.
RCRA: Resource Conservation and Recovery Act. See 40 CFR 122-124 and
260-265.
sec: Seconds.
TCDD: Tetrachl orodi benzo-p_-di oxi n.
TCDF: Tetrachlorodibenzofuran.
TSCA: Toxic Substances Control Act, PL 94-469 (1976). See 40 CFR Part 761.
ix
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GLOSSARY
Air: Includes ambient air and stack gases unless otherwise specified.
Analyte: Chemical compound or element which is the subject of an analysis.
Aroclor: Commercial mixture of PCBs previously manufactured by Monsanto.
Authorized use: Any PCB use or servicing which can be conducted in accordance
with 40 CFR 761.30.
Combustion efficiency (CE): CE = 100[C02] T [C02+C0].
Continuous emissions monitoring system (CEMS): An emissions measurement sys-
tem which is in continuous operation except for system breakdowns, repairs,
calibration checks, and zero and span adjustments. See 40 CFR Parts 60.2
and 60.13 and Part 60, Appendix B for additional details.
Data variance estimate (DVE): Either a numerical value such as a standard
deviation, or a qualitative evaluation such as "good."
Destruction and removal efficiency (ORE): A measure of an incinerator's
performance in removing or destroying PCBs (or another compound). ORE
is expressed as percent efficiency:
u - w
"in out x 100
Win
where: W. = Mass feed rate of PCB in the waste stream feeding the
incinerator, and
W . = Mass emission rate of PCB present in exhaust emis-
sions prior to release to the atmosphere.
Demonstration Test: A test to demonstrate system performance, commonly
called a trial burn.
Electron impact mass spectrometry (EIMS): Low resolution mass spectrometry
operated in the electron impact ionization mode.
High resolution gas chromatography (HRGC): Gas-liquid chromatography per-
formed using a capillary column, typically 10-50 m long x 0.2 mm ID, coated
on the interior with a liquid phase.
Isomer: Any compound which has the same molecular formula, but different
positional substitutions. For example, for PCBs, 2,2'-dichlorobiphenyl and
2,3-dichlorobiphenyl are isomeric; 4-chlorobiphenyl and 2,3,4-trichlorobiphenyl
are not.
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Liquid: A substance is a liquid if its melting point is less than 20°C and
does not pass the structural integrity test (> 15% free liquid
content) (Weller 1982).
Method: A series of techniques or procedures which form a specific, well-
defined destruction, sampling, chemical analysis, or other procedure for
a specified compound(s)/matrix(ces) combination.
Polychlorinated biphenyl (PCB): One of 209 individual compounds having
the molecular formula C12H C110 , where n = 0-9. This definition includes
monochlorobiphenyls.
Polychlorinated dibenzo-p_-dioxin (PCDD): One of 75 individual compounds
having the molecular formula Ci2H C18 02, where n = 0-7. This definition
incl udes monochlorodibenzo-p_-dioxins.
Polychlorinated dibenzofuran (PCDF): One of 135 individual compounds having
the molecular formula C12H C18 0, where n = 0-7. This definition includes
monochlorodi benzofurans.
Packed column gas chromatography (PGC): gas-liquid chromatography performed
using a column, typically 180 cm long x 2 mm ID, packed with a liquid phase
on a granular solid support material.
Part per million (ppm): One part in 106. For gaseous mixtures, a volume/
volume (v/v) basis is typically used and:
RT
ppm = mg/m3 x ^
where RT = 22.4 liter/g-mole at 0°C and 1 atm
= 24.5 liter/g-mole at 25°C and 1 atm
and MW = molecular weight of compound, i.e., g/g-mole
For low concentration aqueous samples, a weight:volume (w/v) basis is most
commonly used and 1 ppm = 1 mg/liter (1 mg/kg for liquids with density 1).
For nonaqueous liquids and solid materials, a weight:weight (w/w) basis is
most commonly used and 1 ppm = 1 mg/kg.
Quality assurance (QA): The total integrated program for assuring the relia-
bility of monitoring and measurement data. A system for integrating the
quality planning, quality assessment, and quality improvement efforts to
meet user requirements.
Quality control (QC): The routine application of procedures for obtaining
prescribed standards of performance in the monitoring and measurement
process.
QC blank: A sample processed and analyzed to obtain background concentrations
of the analytes.
XI
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QC control: A sample containing a known amount of analyte which is processed
with sample batches to monitor recoveries.
Residence time: The time that the flue gas spends in the destruction zone
(area of combustion chamber with the temperature equal or above that re-
quired by the regulations); calculated by dividing the zone volume by the
volumetric flow rate at the exit (actual pressure and temperature
conditions).
Semi volatile organics: Organic compounds which are analyzed by an extraction/
gas chromatographic procedure. This excludes volatile compounds such as
chloroform which would be lost in an evaporation concentration step and non-
volatiles such as humic acids which will not elute from a gas chromatograph.
Solid: A substance is a solid if its melting point is greater than 20°C
and it passes the structural integrity test (Weller 1982).
Tetrachlorodibenzo-p_-dioxin (TCDD): One of 22 isomers with molecular formula
Ci2H4Cl402. Often colloquially used to refer specifically to 2,3,7,8-TCDD.
Tetrachlorodibenzofuran (TCDF): One of 38 isomers with the molecular formula
C12H4C140.
Technique: Specific destruction, laboratory, or sampling operation usually
conducted as part of a method. GC/EIMS and Soxhlet extraction are
techniques.
Trial burn: A demonstration of a thermal destruction system's performance
("Demonstration Test").
XII
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1.0 INTRODUCTION
The Code of Federal Regulations, Title 40, Part 761 (40 CFR 761)
establishes rules on the disposal of PCBs and PCB items. Under these rules,
organizations or persons wishing to dispose of PCBs are required to use ap-
proved methods and must obtain a permit.
This document provides guidance for persons applying to the Office
of Toxic Substances of the U.S. EPA for approval of PCB disposal by incinera-
tion (§761.70). This document presents and discusses the format, content, and
level of detail required for permit applications, demonstration test plans,
and demonstration test reports.
Note that these guidelines address only permit requirements for the
disposal of PCBs as regulated under TSCA. Other laws such as RCRA, CWA, and
OSHA regulations may apply to PCB disposal methods and may have different or
additional permit requirements.
Section 2.0 provides a brief summary of pertinent EPA procedural re-
quirements and guidance as well as a summary of pertinent Part 761 regulations.
Section 3.0 describes the EPA Office of Toxic Substances (OTS) permitting
procedures. Sections 4.0 and 5.0 provide guidance regarding preparation and
submission of permit applications and demonstration test plans, respectively.
Section 6.0 briefly discusses conducting a demonstration test. Section 7.0
provides guidance regarding preparation of a demonstration test report. Sec-
tion 8.0 lists the references for this document. Appendix A provides check-
lists for the applicant to use in determining if all pertinent areas have been
addressed prior to submittal to the Agency. Appendix B is a summary listing
of sampling/analytical methods for PCB, PCDD, and PCDF. Appendix C provides
guidance to the applicant in the form of answers to some frequently asked
questions. Appendix D lists the addresses for OTS Headquarters and for the
10 Regional Offices. Appendix E is an annotated bibliography of sources of
related information.
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2.0 SUMMARY OF 40 CFR 761 REGULATIONS AND GUIDANCE
This section summarizes pertinent provisions of Title 40. of the Code
of Federal Regulations, Part 761, (40 CFR 761) related to the disposal of PCBs.
Part 761 establishes prohibitions of and requirements for the manufacture,
processing, distribution in commerce, use, disposal, storage, and marking of
PCBs and PCB items in the United States. These regulations were promulgated
under authority of the Toxic Substances Control Act (TSCA, PL 94-469).
40 CFR 761 was promulgated May 31, 1979 (44 FR 31514). All references in this
document refer to the revised 40 CFR 761 as of July 1, 1985.
2.1 General
The major sections of 40 CFR 761 are outlined in Table 1. The stor-
age and disposal of PCBs are addressed in 40 CFR 761, Subpart D. In Subpart D,
Section 761.60, disposal requirements are differentiated according to waste
type and PCB concentration; Table 2 summarizes the disposal requirements of
§761.60.
This guideline document is intended to provide guidance only for
approval of PCB incinerators (§761.70) which may require approval by the
Division Director of the Exposure Evaluation Division, Office of Toxic Sub-
stances (DD/EED). Disposal by chemical waste landfills (§761.75) or high
efficiency boilers (§761.60(a)(2),(3)) is not addressed, since their disposal
methods are approved by the appropriate Regional Administrator (RA). Also,
storage of PCBs for disposal (§761.65) or decontamination (§761.79) is not
addressed.
2.2 Approval Authority
Approval authority for PCB disposal facilities is stipulated in Sec-
tion 761.60(i). Typically, the RA for the EPA region in which the facility
will be operated has approval authority. However, in specific situations,
the DD/EED has approval authority, in lieu of the RA. Table 3 summarizes EPA
approval authority for PCB disposal facilities. Addresses for EPA headquarters
and the regional offices are provided in Appendix D.
2.3 §761.70 Incinerators
Performance standards for PCB incinerators are described in §761.70.
To be approved, incinerators must meet specific requirements. Requirements
for destruction of liquid and nonliquid PCBs are provided in the regulation,
§761.70(a) and §761.70(b), respectively. Paragraph 761.70(c) establishes re-
quirements for maintaining records and §761.70(d) establishes requirements
for obtaining approval of incinerators. Each of these paragraphs is discussed
below.
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Table 1. Outline of Major Sections of 40 CFR 761a
Subpart A - General
761.1 Applicability
761.3 Definitions
761.19 References
Subpart B - Manufacturing, Processing, Distribution in Commerce,
and Use of PCBs and PCB Items
761.20 Prohibitions
761.30 Authorizations
Subpart C - Marking of PCBs and PCB Items
761.4 Marking requirements
761.45 Marking formats
Subpart D - Storage and Disposal
761.60 Disposal Requirements
(a) PCBs
(b) PCB Articles
(c) PCB Containers
(d) Spills
(e) Alternative Methods
(f) Written Notice
(g) Testing Procedures for PCB Concentration
(h) Export/Import for Disposal
(i) Approval Authority for Disposal Methods
761.65 Storage for Disposal
761.70 Incineration
(a) Liquid PCBs
(b) Nonliquid PCBs
(c) Maintenance of Data and Records
(d) Approval of Incinerators
761.75 Chemical Waste Landfills
761.79 Decontamination
Subpart E - Exemptions
Subparts F to I - [Reserved]
Subpart J - Records and Reports
761.180 Records and Monitoring
aNote: Some subparts are outlined in greater detail than others.
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Table 2. Disposal Options by PCB Waste Categories (USEPA 1985)
PCB waste category
Mineral oil dielectric
fluid
Other liquids
Nonllqulds (soil, rags,
debris)
Dredged materials and
municipal sewage sludge
PCB transformers (drained
and flushed)
PCB capacitors
PCB capacitors
PCB hydraulic machines
PCB contaminated elec-
trical equipment (except
capacitors)
Other PCB articles
Other PCB articles
PCB containers
PCB containers
All other PCBs
CFR section
761.60[a][2]
761.60[a][3]
761.60[a)[4]
761.60[a][5]
761.60[b][l]
761.60[b)[2]
761.60[b][4]
761.60[b][3]
761.60[b][4]
761.60[b][5]
761:60[b][5]
761.60[c]
761.60[cJ
761.60[a]
Disposal method
Chemical High
PCB waste efficiency Alternative
concentration Incinerator landfill boiler method
(ppm) (§761.70) (§761.75) (§761.60) (§761.60(e))
50-500 x xxx
50-500 x xxx
2 50 x x
2 50 x x
NS* x x
2 500 x
50-500 x x
2 50
2 500f x x9
50-500
2 500f x xd
< 500
2 50 x x
Drain,
Method dispose
approved as solid Decon-
by region waste lamination
x
xc>d
xe
xe
xh
x" xh
"Not specified.
Exemptions for some small capacitors.
•jMust also be flushed If hydraulic fluid contains > 1,000 ppm PCBs and flushing solvent disposed of In accordance with §761.60(a).
Drained liquid must be disposed of In accordance with §761.60(a).
Must be drained of all free-flowing liquid. The disposal of the drained electrical equipment and other PCB articles Is not regulated by 40 CFR 761.
All liquids must be disposed of In accordance with paragraph (a)(2) or (3) of §761.60 [1n an Incinerator (§761.70), chemical waste landfill
.(§761.75), high efficiency boiler, or by an alternative method (§761.60(e))].
Due to a typographical error, 40 CFR 761 [July 1, 1985, p. 163] erroneously states this value as 50 ppm; refer to Federal Register, 44, 31514-31568
(May 3, 1979).
^Drained of any free-flowing liquid and liquid Incinerated in §761.70 Incinerator.
Decontaminated In compliance with §761.79.
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Table 3. Summary of Permit Approval Authority
Approval permit
Type facility authority
Mobile incinerators or portable or stationary Assistant Administra-
incinerators of identical design to be used tor for Pesticides and
in more than one EPA Region Toxic Substances (AA)*
Research and development methods disposing of AAa
> 500 Ib PCB-containing material
Research and development methods disposing of Regional Administra-
£ 500 Ib PCB-containing material tors (RAs)
Site-specific stationary incinerators to be RAs
used in any one EPA Region
Site-specific high efficiency boilers RAs
Delegated authority to the Division Director of the Exposure Evaluation
Division, Office of Toxic Substances (DD/EED).
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include:
2.3.1 Liquid PCBs (§760.70(a))
For destruction of liquid PCBs, the incineration requirements
A 2-sec dwell time at £ 1200°C (± 100°C) and £ 3% excess oxy-
gen or 1.5-sec dwell time at * 1600°C (± 100°C) and £ 2% excess
oxygen in the stack gas;
A system to automatically stop the PCB feed whenever the tem-
perature or excess oxygen drops below the minimum levels spe-
cified above;
A combustion efficiency (CE) of at least 99.9%, where:
[CO,]
CE =
[C02] + [CO]
where [C02] = concentration of carbon dioxide, and
[CO] = concentration of carbon monoxide;
NOTE: This equation is rewritten from the published equation,
CE = [C02]/[C02] + [CO] x 100, which appears to be in error
mathematically.
Measurement and recording (at intervals no longer than 15 min)
of the rate and quantity of PCBs fed;
Continuously measuring and recording the temperature of the
incineration process (combustion chamber);
Monitoring and recording the concentrations of 02 (continuously),
CO (continuously), and C02 (periodically at a frequency speci-
fied by the OD/OTS or RA) in the stack emissions whenever PCBs
are burned;
A system to automatically stop the PCB feed whenever the moni-
toring operations specified for 02, C02, and CO fail;
Monitoring stack emissions for 02, CO, C02, NO , HC1, total
chlorinated organics (RC1), PCBs, and total parficulate matter
when the incinerator is first used for the disposal of PCBs or
when the incinerator has been modified in a manner which may
affect emissions; and
Using water scrubbers to control HC1. Alternative methods for
HC1 control may be used if approved by the DD/EED or RA. For
approval, EPA/OTS requires that the HC1 removal system demon-
strate a removal efficiency of 99%.
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include:
OTS policy also requires:
Demonstrating that mass air emissions from the incinerator are
no greater than 0.001 g PCB/kg of the PCB introduced to obtain
a ORE of at least 99.9999% (six nines);
Measurement of the stack emissions for chlorinated dibenzo-
dioxins and dibenzofurans;
Particulate matter emission levels of S 180 mg/dscm
(0.08 gr/dscf) when corrected to 7% oxygen; and
Total PCB concentrations in scrubber water,* fly ash (if
applicable), and bottom ash (if applicable) of g 2. ppm.
2.3.2 Nonliquid PCBs (§761.70(b))
For destruction of nonliquid PCBs, the incineration requirements
Demonstrating that mass air emissions from the incinerator are
no greater than 0.001 g PCB/kg of the PCB introduced to obtain
a DRE of at least 99.9999% (six nines); and
All requirements for liquid PCB incinerators, except for the
dwell time, temperature, and excess oxygen requirements [first
bullet in 2.3.1 above] and the automatic feed shutoff require-
ment for inadequate temperature or oxygen levels [second bullet
in 2.3.1 above].
OTS policy also requires:
Measurement of the stack emissions for chlorinated dibenzo-
dioxins and dibenzofurans;
Particulate matter emission levels of ^ 180 mg/dscm
(0.08 gr/dscf) when corrected to 7% oxygen; and
Total PCB concentrations in scrubber water,* fly ash (if
applicable), and bottom ash (if applicable) of £ 2 ppm.
2.3.3 Maintenance of Data and Records (§761.70(0)
%
Paragraph 761.70(c) establishes requirements for maintenance of data
and records for PCB incinerators. Records must be maintained according to
the provisions established in §761.180. The records required are discussed
in more detail in Section 4.0 of this report.
*Federal NPDES or state or local regulations may require more stringent
control of PCBs (i.e., lower concentrations) in water discharged from
the facility.
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2.3.4 Other Requirements
Paragraph 761.70(d) establishes requirements for obtaining approval
of PCB incinerators. These requirements include submitting an application
for approval, submitting a trial burn plan (if a trial burn is required by
the approving authority), and conducting a trial burn (if required). The
required contents of a permit application and of a trial burn plan are pre-
sented and discussed in detail in Sections 4.0 and 5.0 of this document,
respectively.
8
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3.0 OFFICE OF TOXIC SUBSTANCES (OTS) PERMITTING PROCEDURES
The Code of Federal Regulations, Title 40, Part 761 (40 CFR 761)
specifies that the Assistant Administrator (AA) for Pesticides and Toxic Sub-
stances has approval authority for certain PCB disposal facilities [approval
authority has since been delegated to the Division Director, Expo'sure Evalua-
tion Division of the Office of Toxic Substances (DD/EED) on January 23, 1984];
Regional Administrators (RAs) have approval authority for other facilities.
Facilities for which the DD/EED has approval authority include PCB inciner-
ators that are mobile or of identical design and intended to be used in more
than one EPA region. Also included are certain research and development (R&D)
methods that dispose of more than a total of 500 Ib PCBs or PCB-contaminated
material. RAs retain approval authority for site-specific facilities such as
landfills, stationary incinerators, high-efficiency boilers, and research and
development into PCB methods involving a total of 500 Ib or less of PCB
materials.
This section describes the process used by EPA/OTS to issue an oper-
ating permit and an R&D permit to the PCB incinerator applicant. Figure 1
shows the major steps in the operating permit process. Figure 2 gives a more
detailed process diagram which includes the loops at various points in the
operating permit process when additional information is required. Figure 3
shows the process for obtaining an R&D permit from OTS.
3.1 Establish Communications With the EPA Permit Writer
The permit applicant can facilitate the permitting process by estab-
lishing good communications with the EPA permit writer as early as possible.
Good communication will minimize requests for additional information as well
as submission of unnecessary information. Early in the process, the applicant
and permit writer can discuss any special circumstances and also the necessity
for submitting optional information discussed in these guidelines. In addi-
tion, advance notice of submissions will allow the permit writer to schedule
the review in an orderly fashion.
3.2 Apply for an R&D Permit (Optional)
The purpose of a research and development (R&D) permit is to assist
the facility operator in bringing the destruction process from conception to
commercial operation. R&D permits can be issued for bench-scale operations,
for pilot-scale systems, and for full-scale commercial systems. First-time
applicants who do not have experience operating their systems, or who have
not yet used their systems to destroy PCBs, are encouraged by EPA to obtain
an R&D permit for "shakedown" of the process by conducting studies on a lim-
ited quantity of PCBs, prior to the commercial demonstration test.
An R&D permit application should consist of all of the applicable
elements described in Table 4 in Section 4.0 (except as noted). The R&D ap-
plication need not contain the detail required for an operating permit, but
must be sufficient to demonstrate that the R&D activity will not present an
unreasonable risk of injury to health or the environment. The applicant
should also supply information on the specific objectives of the R&D activity.
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Establish Communications with
EPA/OTS Permit Writer
Submit Complete Operating
Permit Application to DD/EED
Submit Complete Demonstration
Test Plan to DD/EED
EPA/OTS Review and Approval
I
EPA/OTS Issues Demonstration
Test Permit
Conduct Demonstration Test
I
Submit Demonstration Test Report
to DD/EED
EPA/OTS Review and Approval
DD/EED Issues Operating Permit
Figure 1. Major steps in the OTS operating permit process.
10
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Operating Permit Application
Received by OD/EED
Test Plan
Requested
byDD/EED
Demonctratlon Test
Plan Received by
DD/EED
Test Plan
Revised by
Applicant
Hot Demomtration
Test Plan Reviewed
Test Plan
Complete
end
Acceptable
Demonstration
Permit issued
and OTS Notified
Acceptable to OTS
OTS Recommendi
Applicant Submit
R & 0 Permit
Application in Lieu
of Operating
Permit Application
r
OTS Requires
Operating. Design,
Sampling/Analysis
Deficiencies
to be Corrected
Facility Corrects
Minor Deficiencies
and Requests New
Test Date
Demonstration
Test Completed
I
.J
OTS Requests
Correction of
•Deficiencies
end Another
Demonstration Test
I Demonstration
Test Results
Submitted
Results
by OTS
.
Additional Data/
Information Requested
Figure 2. Process to obtain an operating permit from OTS.
11
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R & D Permit
Application
Received by
DD/EED
I
Application
Reviewed
Revised
Application
Submitted
1
IT
I
i
Application
Complete
r~
i
i
i
t
R &D
Permit
Denied
1
r
R&D
Permit
Issued
Deficiencies
Noted and
Returned to
Applicant
OTS Recommends
Applicant Submit
Operating Permit
Application in
Lieu of R & D
Permit
Figure 3. Research permitting process.
12
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The R&D activity should provide process information and operating experience
needed for application for an operating permit. The R&D results should be
used for planning a full-scale demonstration such that there is a high prob-
ability of a successful demonstration. The R&D results may be appropriate
for inclusion in the application for the operating permit.
R&D permits can be issued by the appropriate EPA Regional Adminis-
trator for the destruction of a total of 500 Ib or less of PCB-contaminated
material, or by the Division Director, Exposure Evaluation Division, Office
of Toxic Substances (DD/EED), for the destruction of more than 500 Ib of PCB-
contaminated material. R&D permit applications can be submitted at any time,
even if an application for a permit to operate commercially has already been
submitted.
Upon receipt of an R&D permit application, EPA will review the docu-
ment. If the application is incomplete or contains deficiencies, a notice of
deficiencies will be sent to the applicant, who must then revise and resubmit
the application. In some cases, EPA/OTS may recommend that the applicant sub-
mit an operating permit application in lieu of the R&D permit application,
depending upon the circumstances involved. When a complete R&D permit appli-
cation is approved by EPA/OTS, an R&D permit is issued.
According to 40 CFR 761.60(f), before commencing R&D work, a 30-day
notice must be given to EPA regional, state, and local officials. After com-
pletion of the R&D activities, a report giving the results of the activities
and test results must be submitted to EPA.
3.3 Submit Operating Permit Application and Demonstration Test Plan
to DD/EED
The permit applicant must submit both an operating permit applica-
tion and a demonstration test plan to DD/EED in order to receive a demonstra-
tion permit. Generally, the permit application and demonstration test plan
should be separate, complete documents.
The permit application should be submitted as early as possible.
Partial submissions are acceptable if the submission clearly indicates the
portions of the application to be submitted later, and if the applicant and
EPA permit writer agree that a preliminary review of a partial submission will
be productive. The demonstration test plan may be submitted with or after
the permit application. In any event, both the application and demonstration
test plan must be determined by EPA to be complete before a demonstration
permit can be issued.
Paragraph 761.70(d)(l) establishes the contents required in an ap-
plication for a permit to operate a PCB incinerator. The suggested format
for an incinerator permit application is presented in Table 4 in Section 4.0
of this document. A complete application must address each topic in the for-
mat given in Table 4. As an aid to the applicant in determining if all re-
quirements for an application have been addressed, a checklist is provided in
Appendix A.
13
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A Demonstration Test Plan is a document prepared specifically for
the demonstration tests and provides details of how the test will be conducted.
A complete plan must include all the required information given in Table Sin
Section 5.0 of this document. Appendix A provides a checklist to aid the ap-
plicant in determining whether all required items have been addressed.
3.4 EPA/OTS Review of Permit Application and Demonstration Test Plan
EPA/OTS reviews the permit application and demonstration test plan
for completeness, accuracy, clarity, and technical viability. If either docu-
ment is unacceptable to EPA, a notice of deficiencies will be sent to the ap-
plicant. The deficiencies must be corrected in a revised application or test
plan, and the revised document(s) must be submitted to the DD/EED. In some
cases, this process may need to be repeated more than once.
3.5 EPA/OTS Issues Demonstration Test Permit
After the EPA approves the permit application and demonstration test
plan, the DD/EED will issue a demonstration permit. A demonstration permit
is required prior to destroying any PCBs in a process demonstration. The
demonstration permit will specify a limited amount of PCB-containing material
which can be destroyed during the demonstration and other conditions based on
the applicants permit application and demonstration test plan. The time
period for which the demonstration permit is valid also will be limited.
3.6 Conduct Demonstration Test
A demonstration test (trial burn) is scheduled at a date agreeable
to both the applicant and EPA/OTS. It is desirable that EPA/OTS have at least
60-days1 notice prior to the test; 30 days' notice is required.
If any modifications to the test plan are required prior to the
demonstration test, EPA/OTS (permit writer) should be notified in writing at
least 14 days prior to the test. Also, if events require that the plan be
significantly modified during the test demonstration, then the permit writer
should be contacted immediately to discuss the implications of any modifica-
tions. As with normal operation, any significant deviations from or altera-
tions in the test plan must be documented in writing to EPA/OTS (permit writer)
within 10 days after the event. Throughout the test demonstration, an "event
log" should be maintained. This log should be submitted as part of the demon-
stration test report.
The test should be conducted under conditions simulating normal com-
mercial operations. Operating permit requirements usually reflect the systems'
operating conditions during the demonstration test, and conditions used in
the tests become conditions allowed in the operating permit. Therefore, the
applicant should give very careful consideration to the design and conduct of
the demonstration test.
If the demonstration test is initiated, but cannot be completed for
some reason, EPA/OTS can exercise several options. The first option is to
deny the operating permit without further consideration, which is rarely done.
14
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A second option is to recommend that the applicant submit an R&D permit appli-
cation in order to have a chance to correct operating deficiencies prior to
another demonstration. The third option is to reschedule the test, which is
usually done when minor deficiencies in the operating process cause the prob-
lem. A fourth option is to require that the application or test plan be re-
vised and resubmitted before issuing another demonstration permit'; this option
is usually used when major design changes must be made or major operating
deficiencies must be corrected before another demonstration test can be
performed.
3.7 Submit Demonstration Test Report to DD/EED
After a complete demonstration test has been performed, a report of
the results must be made and submitted to the DD/EED. The format and required
contents of the report are shown in Table 10 in Section 7.0 of this document.
The test report must contain all the information described in Section 7.0 of
this document.
3.8 EPA/OTS Review of the Demonstration Test Report
Upon receipt, EPA/OTS will review the demonstration test report
submitted by the applicant. If the report is incomplete or unclear, EPA will
request that the applicant submit any additional information or data needed.
If the results of the test are unacceptable, EPA may deny the operating per-
mit, request that another demonstration test plan be submitted for approval
prior to conducting another demonstration test, or require that a revised
permit application be submitted for approval. If the test results are ac-
ceptable, EPA/OTS can issue an operating permit to the applicant.
3.9 DD/EED Issues an Operating Permit
An operating permit allows the operator to commercially operate.
After acceptance of the permit application and demonstration test results,
the DD/EED will issue a final operating permit. Generally, the final oper-
ating permit will specify the matrix(ces) which can be incinerated, an upper
limit on PCB concentration in the feed, and an effective period of up to
3 years from the date of issuance.
For a renewal approval, additional information and/or testing of
the process may be required. In order to continue the effectiveness of a
permit pending EPA action on reissuance of the permit, the operator must sub-
mit a renewal request letter to EPA at least 90 days, but not more than 180
days, prior to the expiration date of the permit.
15
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4.0 PERMIT APPLICATION FORMAT
Paragraph 761.70(d)(l) establishes the contents required in an ap-
plication for a permit to operate a PCB incinerator. The suggested format
for the permit application for incineration or other thermal destruction sys-
tems is presented in Table 4. Each major item presented in the permit format
is discussed in the following sections. A checklist is provided in Appendix A
to aid the applicant in determining, prior to submittal, if all requirements
for an application to operate a PCB incinerator have been addressed.
Research and development permit applications should follow the same
format as operating permit applications although less detail is generally
required.
4.1 Permit Application Cover
Each submission must have a permit application cover. The application
cover format is presented in Figure 4. If the application or the appendices
must be bound separately (i.e., multiple volumes), number each volume of the
submission in order in the upper right hand corner of the cover ("Volume m of
n)". The cover of each volume should have the full cover information. The
principal manager is the person identified by the applicant as the primary
contact for written or verbal communications from the EPA permit writer.
4.2 Section I - Summary
The applicant is encouraged to begin the permit application with a
short summary presenting the document organization and any pertinent back-
ground information.
4.3 Section II - Project Organization
Briefly describe the organization for operating the facility. Pro-
vide an organization chart identifying key individuals (position titles and
actual personnel, if known). The organizational chart should primarily ad-
dress those personnel directly involved in the project. The corporate struc-
ture (e.g., relationship of company officers) is only necessary if it impacts
on the chain of command for the PCB destruction facility. Personnel who
should be identified include:
Person(s) responsible for obtaining permit;
Project manager;
Facility manager;
Operations supervisor;
Reviewing engineer;
Maintenance supervisor;
Quality assurance officer;
Safety officer;
Laboratory personnel;
Person(s) responsible for training;
Person(s) responsible for demonstration test;
Person responsible for operation of monitoring system; and
Person responsible for record keeping and reporting.
16
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Table 4. Format for Permit Applications for PCB Incinerators
i Permit Application Cover
ii Table of Contents
I. Summary
II. Project Organization
III. Waste Description
IV. Process Engineering Description
V. Monitoring Plan
VI. Monitoring Procedures
VII. Data Reporting/Recordkeeping
VIII. Inspection Procedures
IX. Spill Prevention Control and Countermeasures Plan
X. Safety Plan
XI. Training Plan
XII. Plans for a Demonstration (Trial Burn)3
XIII. Test Data or Engineering Performance Calculations
XIV. Other Permits/Approvals
XV. Schedule of Pre-operation Events
XVI. Quality Assurance Plan
XVII. Standard Operating Procedures
XVIII. Closure Plan
aFor a research and development permit, this section would present the
planned research activities.
17
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Volume m of n
(PRELIMINARY) PERMIT APPLICATION
PCB DESTRUCTION UNIT
[Type and location]
[Test site for mobile units]
Submission date:
Submission number [sequential numbering, beginning with 1]
Submitted by: Submitted to:
[Company name and address]
[Principal manager and phone no.]
Division Director, Exposure Evaluation
Division
c/o Document Control Officer (TS-790)
Office of Toxic Substances
U.S. Environmental Protection Agency
Room E-201
401 M Street S.W.
Washington, DC 20460
Figure 4. Example permit application cover.
18
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4.4 Section III - Waste Description
A description of the waste(s) intended to be destroyed in the unit
should be provided. As a minimum provide the following information:
The type (liquid or solid) of waste to be destroyed;
The proposed total waste and PCB feed rates; and
The matrix and composition of the waste, including major and
minor constituents, and expected PCB concentration. Heating
value, viscosity, Cl, ash, water content, and other charac-
teristics of the waste material should be included, if appro-
priate.
4.5 Section IV - Process Engineering Description
The agency needs sufficient information about a PCB destruction
process to be able to evaluate the permit application. This information will
include detailed descriptions of the facility site, PCB and PCB-item handling,
process design and operation, pollution control equipment, and anticipated
performance. To this end, a list of parameters to be described in the plan
is presented below for guidance. The list is not necessarily inclusive.
Permit applicants should provide additional information where appropriate.
The following process design information should be provided for
thermal destruction systems. If a category is not applicable, so state.
4.5.1 General
Facility location including site map;
Layout diagram and description of the plant or mobile unit;
Detailed engineering drawings;
Process flow diagram (schematic diagram of the system) and
description;
Intended location of the mobile unit or facility; and
Intended location of where the unit will be stored when not in
use (if mobile unit).
4.5.2 Waste Feed System
«
Narrative description of the waste feed system (e.g., equipment
and procedures for unloading, storage, and transfer of the PCB
materials, etc.). Discussion of provisions to prevent leakage;
Description of the waste preparation system if applicable
(e.g., filtration, blending, crushing, preheating, etc.);
Waste feed storage capacity and average waste feed stored at
this location (in gallons, number of days' supply, etc.);
Volume of waste expected to be handled at this facility per
month or other time period; and
Description of waste feed rate measurement method [additional
information on measurement methods is available in (Beard and
Schaum 1978)].
19
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4.5.3 Waste Feed Cutoff System
Describe the automatic cutoff system for PCB feed, including the
time-delay system used before shutoff. Discuss the system operation
for shutoff when:
Combustion chamber temperature is less than allowable;
Excess 02 value is lower than allowable;
Retention time is lower than allowable;
Burner flameout occurs;
CO and C02 concentration in exhaust gases are different from
ranges allowed in permit; and
Other specific process conditions are different from those re-
quired by the permit (e.g., scrubber water flow rate is less
than allowable).
4.5.4 Destruction System
Detailed narrative description of the thermal destruction unit
including engineering data (such as chamber volume), tempera-
ture, flow rates, etc.;
Engineering diagrams;
Design capacity of the system;
Description of how combustion chamber volume is derived;
Heating values for waste feed and auxiliary fuel;
Feed rate for waste feed and auxiliary fuel;
Exit temperature of gases;
Calculations showing the retention time at a temperature re-
quired by the regulation [additional information is available
in (Beard and Schaum 1978)];
Description of how flow rates are regulated so that the speci-
fied retention time is maintained;
Normal operating values and acceptable ranges for the essential
operating parameters (e.g., chamber temperature, chamber pres-
sure, volume flow rate, waste feed rate, retention time, 02,
CO, C02) being measured; and
Expected destruction efficiency of this unit, based on design
criteria, or pilot tests.
4.5.5 Pollution Control System (PCS)
A complete description of the type of pollution control system
should be provided. In addition to providing diagrams of the system, infor-
mation on the major design parameters also should be included such as:
Total exhaust gas flow rate (dscm or dscf);
Pressure drop across the system (Pascal or in. H20);
Exhaust gas temperature (°C or °F) in the stack;
Type and concentration of pollutants (control system inlet and
outlet) if available; and
Design removal efficiency (provide calculation for basis).
20
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Discuss the fate of associated waste streams (e.g., ESP ash,
scrubber liquid). Also provide a description of the warning system, if any,
used to signal PCS malfunction.
Provide information on the normal operating values and acceptable
ranges for significant operating variables of the scrubber, fabric filter,
ESP, or other device as described below. If information is available in the
form of vendor performance specifications, it may be substituted.
1. Scrubber
Scrubber liquid flow rate (gpm);
Pressure drop across mist eliminator (in. H20);.
Makeup liquid flow rate (gpm);
Nozzle operating pressure (psi);
pH of scrubbing liquid;
Liquid discharge rate (gpm);
Lime or other conditioning agent feed rate;
Liquid/gas flow rate (gpm/acfm); and
Any other information on significant operating variables not
mentioned here.
2. Fabric Filter
Differential static pressure (in. H20) between clean and dirty
side;
Dew point of gases;
Description of temperature protection device or fabric filter
bypass system;
Air/cloth ratio;
Bag material (resistant to chemical and physical properties of
.the stack gas);
Description of bag cleaning system;
System for ash removal; and
Any other information on significant operating variables not
mentioned here.
3. ESP
No. of fields;
No. of Transformer-Rectifier (T.R.) sets;
Total plate area;
Primary voltage;
Primary current;
ESP voltage (secondary);
ESP current (secondary);
Spark rate;
Description of rapper system;
System for ash removal;
Dust level in hopper indicator; and
Any other information on significant operating variables not
mentioned here.
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4.5.6 Summary of Process Operating Parameters
A summary should be provided which lists target values as well as
upper and lower boundaries for all measured operating parameters, instrument
settings, and control equipment parameters. All values must be.reported in
common, consistent units. The application must also describe the action to
be taken whenever a parameter deviates outside the boundary value. These ac-
tions may include adjusting the operating conditions, stopping the PCB feed,
shutting down the process, etc. The time allowable for corrective action be-
fore shut-down or other action must also be specified.
4.6 Section V - Monitoring Plan
This section of the application provides an overview of the moni-
toring to be conducted; specifics of the monitoring equipment and procedures
are presented in Section VI of the Permit Application.
The application must include a monitoring plan, i.e., a summary of
the strategy to be followed in monitoring the operating and emission param-
eters. The monitoring objective should be to obtain results which are repre-
sentative. In cases where representative samples are not obtainable, a worst
case result should be obtained. In cases where problems can be anticipated
(e.g., instrument failure), contingencies should be included in the plan.
The monitoring plan should include:
Monitoring locations;
Parameters to be monitored;
Monitoring methods; and
Monitoring frequency.
A schematic diagram can be used to illustrate the monitoring points;
Figure 5 is an example. The specific location of the sampling point should
be discussed briefly in the narrative; e.g., the liquid waste sample will be
taken from the feed line just prior to the injection nozzle. Other important
parameters of the monitoring plan can be concisely presented in a tabular
format; Table 5 is an example monitoring plan summary.
Thermal destruction of PCBs by incineration must follow the guide-
lines established in §761.70(a). At a minimum, monitoring and recording of
combustion products and incineration operations shall be conducted for the
following parameters whenever the incinerator is incinerating PCBs: (i) 02;
(ii) CO; and (iii) C02. The 02 and CO measurements must be continuous. (It
is recommended that a measurement value be taken at least every 15 sec and a
value recorded at least every minute.) If these minimum requirements cannot
be met, then justification should be provided for why less frequent measure-
ment/recording times are acceptable. The C02 measurements, defined as peri-
odic, must be made at least every 15 min. Operating parameters that must be
monitored include waste feed rates, combustion temperature, and residence time.
Acceptable operating ranges for these parameters must be specified in the pro-
cess engineering information, as described in Section 4.5.6, above.
22
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Waste Feed
Bulk Storage
Tank
Make-Up
Discharge
Figure 5. Schematic of sampling and monitoring points for an incinerator.
23
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Table 5. Example Summary of Monitoring Plan for a Mobile Incinerator
ro
Parameter
A.
B.
C.
D.
E.
F.
G.
H.
I.
J.
K.
L.
M.
N.
0.
Oxygen
Carbon monoxide
Carbon dioxide
Combustion temperature
Incinerator pressure
Waste feed rate
Residence time
Combustion efficiency
Venturi Pressure drop
Venturi scrubber li-
quid flow
Spray tower liquid
flow
Quench water discharge
Scrubber liquid dis-
charge
Quench water makeup
Scrubber liquid make-
up
Method
Extractive Continuous
Emissions Monitor (CEM)
Extractive CEM
Extractive CEM
Shielded thermocouple
Pressure transducer
Volumetric flow meter
Gas Velocity (Annubar®)
Automated calculation
Pressure transducer
Rotameter
Rotameter
Volumetric flow meter
Volumetric flow meter
Volumetric flow meter
Volumetric flow meter
Frequency
Continuously
Continuously
Continuously
Continuously
Continuously
Continuously
Continuously
Continuously
Continuously
Continuously
Continuously
Continuously
Continuously
Continuously
Continuously
Location3
1
1
1
2, 3
2, 3
4
5, 6
-
7
8
9
10
11
12
13
Contingency
Stop Operations/Repair
System (SORS)
SORS
SORS
Second System
SORS
SORS
SORS
Manual calculation
SORS
SORS
SORS
SORS
SORS
SORS
.SORS
Refers to Figure 2.
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According to §761.70, when an incinerator is first used to-destroy
PCBs, sampling of the stack emissions products must be conducted and must in-
clude measurement of: 02, CO, C02, NO , HC1, RC1, PCBs, and total particulate
matter. The measurement of these parameters is discussed in Section 5.0
(Demonstration Test Plans) of this document.
4.7 Section VI - Monitoring Procedures
This section of the permit application should provide a detailed
discussion of the monitoring methods which will be used. The discussion for
each parameter to be monitored should include:
Monitor manufacturer;
Model number;
Principle of operation;
Instrument range and accuracy;
Operating temperature range of monitor, if monitor is i_n situ
type;
Description of the system for removal of the sample if the
monitor is extractive, including sample conditioning system;
Location of the sample point(s) and an explanation of why
chosen and why the point(s) is representative;
Description of the calibration procedure and frequency;
Description of the maintenance procedures and frequency;
Description of the data recording and storage system;
Description of the system for triggering automatic feed shutoff,
if applicable;
Contingency for monitor failure; e.g., install and calibrate
second monitor; and
Description of routine maintenance procedures.
Evidence that the monitoring method will generate suitable data
(e.g., performance data from a non-PCB burn of the system).
4.8 Section VII - Data Reporting/Recordkeeping
The permit application shall explicitly state what data are to be
recorded (including units) and how the data records are to be maintained.
Include example calculations, units of measurements, and example record re-
porting forms. Paragraphs 761.180(b), and 761.180(c) establish the minimum
25
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data record requirements for thermal destruction units. Minimum records in-
clude a summary report for the previous calendar year which contains:
Date PCBs and PCB items were received and from whom;
Date PCBs and PCB items (including process waste which has not
been demonstrated to be free of PCB contamination) were dis-
posed of or transferred;
Summary of the total weight (kg) of PCBs and PCB articles in
containers and PCBs in transformers which have been received,
transferred to other facilities, and retained at the facility;
and
Summary of the total number of PCB articles or PCB equipment
not in containers which have been received, transferred to
other facilities, and retained at the facility.
The following information also must be maintained on site:
For periods when PCBs are being incinerated, the rate and
quantity of PCBs fed, the temperature of the combustion
process, and the 02, CO, and C02 emission levels;
The demonstration test (trial burn) results;
The total weight (kg) of solid residues generated;
The total weight (kg) of solid residues disposed of in chemical
waste landfills;
The total weight (kg) of solid residues remaining on site; and
The date, time, and duration of any suspension of incineration
operations due to automatic shutoff of feed or any other reason
for shutdown other than routine maintenance or moving to another
disposal site [pursuant to §761.70(a)(8)], as well as an expla-
nation of the circumstances causing suspension of operation.
(Note: This information must be sent to the RA within 30 days
of the event.)
Additional information as specified by the- RA or DD/EED.
4.9 Section VIII - Inspection Procedures
The permit application shall identify the routine inspection proce-
dures used to identify problems (e.g., waste feed leak) and malfunctions (e.g.,
broken bags in the baghouse) associated with the facility. The frequency of
inspections also should be addressed. Inspection procedures should be iden-
tified for items such as:
26
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Waste feed system;
Destruction system;
Waste feed cutoff system;
Pollution control system;
Process alarms; and
Fire extinguisher system
4.10 Section IX - Spill Prevention Control and Countermeasures Plan
Describe the procedures (including system design) which will be used
to prevent spills of PCBs. Also describe the procedures which will be fol-
lowed should a spill occur. Coast Guard regulations specifying spill preven-
tion control and countermeasure plans (40 CFR 112.7) can be used as an example
for the type of information which should be addressed; however, the plan pro-
vided in the permit application need not be in the format or detail specified
in 40 CFR 112.7.
4.11 Section X - Safety Plan
This section addresses the safety program which will be initiated
to protect workers and other humans from PCB exposure or other health hazards.
Identify specific items (e.g., protective clothing) of the program for ensur-
ing safe routine operations. Procedures for preventing worker/population ex-
posure in the case of an equipment malfunction also should be addressed; pro-
cedures for stopping waste feed, shutting down the process, and controlling
emissions in the event of a malfunction should be addressed. Provisions for
prevention and control of fires, explosions, electrical outages, etc., also
should be addressed.
4.12 Section XI - Training Plan
The permit application should present a description of the training
program which will be initiated to assure workers are trained in items appro-
priate to their jobs including:
Equipment operation (in accordance with standard operating
procedures);
Emergency shut-down procedures;
Use of protective clothing;
Waste handling;
Spill prevention/control;
Fire control; and
Hazards of PCBs.
4.13 Section XII - Plans for a Demonstration (Trial Burn)
This section of the permit should briefly summarize the applicant's
plans for conducting a demonstration test; a separate detailed plan is re-
quired prior to conducting a demonstration test (see Section 5.0 of this
document). However, summary information which should be presented in this
section includes:
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Tentative date (month/year) for the test;
Tentative location for the test;
Parameters to be tested;
Type waste to be used; and
Expected date for submittal of test demonstration plan.
If the applicant feels a test demonstration may not be needed for
this facility, the applicant should present a rationale for not conducting a
demonstration. (It is rare than a demonstration test will not be required.
One of the few reasons for not requiring a trial burn is that an identical
unit has been previously tested and permitted.)
4.14 Section XIII - Test Data or Engineering Performance Calculations
The applicant should present a summary of any relevant test data
from R&D activities, non-PCB burns, or other sources, or any engineering
calculations which support the ability of the thermal destruction system to
destroy PCBs. Detailed test results need not be presented in this section,
but instead may be provided as an appendix, or referenced if already on file
with the Office of Toxic Substances.
4.15 Section XIV - Other Permits/Approvals
List other permits/approvals which have been obtained or are being
sought for this unit; identify the permitting agency and the person to contact
for additional information (permit writer). Relevant permits include PCB re-
search and development permits, operating permits issued by an RA, state or
local permits to operate, RCRA permits, NPDES permits, and DOT permits.
4.16 Section XV - Schedule of Pre-Operation Events
Provide a proposed schedule (month and year) for complying with the
regulatory requirements associated with approval of the facility. Scheduled
items to be addressed include: beginning construction date, construction com-
pletion date, submittal of demonstration test plan, equipment shakedown period,
initiation of demonstration test, submittal of demonstration test results,
and initial operating date.
4.17 Section XVI - Quality Assurance Plan
Each permit application must include a Quality Assurance (QA) Plan.
Note that the QA Plan must address all data-generating activities (e.g., pro-
cess monitors and controllers, not just chemical laboratory analysis). This
plan should conform to the specifications established in "Interim Guidelines
and Specifications for Preparing Quality Assurance Project Plans" (USEPA,
1980) and must address all measurement (i.e., monitoring) parameters. Addi-
tional guidance in the preparation of QA project plans is available in "Qual-
ity Assurance Program Plan for the Office of Toxic Substances" (USEPA 1983b).
The purpose of the Quality Assurance Plan is to establish a specific
program to: (a) help assure that the monitoring data meet specific quality
objectives, and (b) routinely assess the quality of the monitoring data. Ap-
propriate QA is imperative. If the data (physical or chemical measurement)
28
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are of unknown quality, the data are unacceptable and cannot be used to show
a facility is operating within permit requirements. Data of poor quality, as
long as the quality is known, may be acceptable depending on whether or not
the parameter is critical to PCB destruction.
The Quality Assurance Plan should address the following items:
Organization and responsibility for QA;
Quality assurance objectives for each measurement parameter
(e.g., CO, C02, 02 combustion temperature in terms of accuracy,
precision, completeness, representativeness, and compatibility);
Monitoring procedures (brief description);
Specific calibration procedures and frequency;
Procedures for data reduction, validation, and reporting;
Specific internal quality control checks and frequency;
Audit procedures and frequency;
Preventative maintenance procedures and frequency;
Specific routine procedures to assess accuracy, precision, and
completeness;
Procedures for corrective action; and
Quality assurance reports to management.
Each of these items is discussed in "Interim Guidelines and Specifi-
cations for Preparing Quality Assurance Plans"; the applicant is advised to
follow this document.
4.18 Section XVII - Standard Operating Procedures
A summary of the standard operating procedures (SOP) should be in-
cluded in this chapter. The SOP should consist of the procedures available to
the facility operators for use in plant operations. The complete SOP should
be included as an appendix. Applicants may submit a copy of the process oper-
ating manual to satisfy this requirement.
Applicants should be required to develop a SOP and submit it to EPA
two weeks prior to the demonstration. The SOP:
Assures that applicants have reviewed the operations in detail;
Gives EPA opportunity to review and become familiar with the
operations prior to the on-site audit; and
May be used as a tool for training new employees, which gives
some assurance that the employees have received a minimum of
training.
An SOP should be a step-by-step procedure; however, details of pro-
cedures such as the use of equipment (e.g., Modified Method 5) may be omitted
but must be referenced. Divergence from the SOP during trials or commercial
runs should be documented and significant modifications should be submitted
to EPA. For convenience of use, lab procedures should be separate from system
operational procedures.
29
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The SOP should be part of the training plan. Each new employee
should sign and date a statement indicating that the employee has read and
understood the SOP.
4.19 Section XVIII - Closure Plan
The closure plan for the facility should address two situations:
For mobile units, closure of the facility at each site prior
to moving to a new site. Closure must address items such as
decontamination of the equipment, placarding any contaminated
equipment, and disposal of any wastes generated from decontam-
ination or cleanup activities; and
For both mobile and stationary facilities, permanent closure
(i.e., removal from service).
The closure plan(s) should address:
Responsible personnel;
Disposal of by-product wastes on a routine basis;
Disposal of equipment; and
Financial responsibility of the company.
30
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5.0 DEMONSTRATION TEST PLANS
This section presents the suggested format for a Demonstration Test
(Trial Burn) Plan and briefly discusses the major items of information which
must be submitted in the plan.
A Demonstration Test Plan is a document prepared specifically for
the demonstration tests and provides details of how the test will be conducted.
This includes details of: when and where the demonstration will be conducted
and by whom; process/pollution control operating parameters to be maintained
during the test; waste feed quantity and type; parameters to be monitored/
sampled; sampling/monitoring locations, frequency, and methods; sample analysis
methods; equations for calculating results; and quality assurance procedures.
5.1 General
The minimum contents required in the trial burn plan are specified
in §761.70(d)(2) as follows:
Date of trial burn;
Quantity and type of PCBs and PCB items to be incinerated;
Parameters to be monitored and location of sampling points;
Sampling frequency and methods and schedules for sample
analyses;
Date and location of analyses; and
Name, address, and qualifications of persons who will review
analytical results and other pertinent data, and who will per-
form a technical evaluation of the effectiveness of the trial
burn.
5.2 Contents of a Demonstration Test Plan
The Demonstration Test Plan must contain all the required informa-
tion as described in this document. Table 6 presents the format for a Demon-
stration Test Plan. Contents of the Demonstration Test Plan, prepared accord-
ing to the recommended format, are discussed in the following paragraphs.
Appendix A provides a checklist to aid the applicant in determining whether
all required items have been addressed.
5.2.1 Test Demonstration Plan Cover
A cover must be provided for the Demonstration Te-st Plan. Figure 6
presents the cover format to be used. If multiple volumes are submitted, pro-
vide a cover for each volume and number each volume in the upper right hand
corner, "Volume m of n."
5.2.2 Section I - Summary
The applicant should begin the plan with a short summary of the docu-
ment. The summary should indicate when, where, and by whom the test will be
conducted. A brief background discussion on the unit to be tested also is use-
ful (e.g; type of unit, intended use, summary of previous tests or operations).
31
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Table 6. Format of Demonstration Test Plan for Incinerators
i Test Plan Cover
ii Table of Contents
I. Summary
II. Project Organization
III. Process Engineering Information (new information to application)
IV. Process Operation
V. Sampling and Monitoring Plan
VI. Sampling and Analysis Procedures
VII. Monitoring Procedures
VIII. Data Reporting
IX. Miscellaneous Tests
X. Test Schedule
XI. QA Plan (addenda to Permit QA Plan)
XII. Standard Operating Procedures (addenda to Permit SOP)
32
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Volume m of n
(PRELIMINARY) DEMONSTRATION TEST PLAN
PCB DESTRUCTION UNIT
[Type and location]
[Test site for mobile units]
Proposed test dates:
Submission date:
Submission number [in sequence with permit application submissions]
Submitted by: Submitted to:
[Company name and address]
[Principal manager and phone no.]
Division Director, Exposure
Evaluation Division
c/o Document Control Officer (TS-790)
Office of Toxic Substances
U.S. Environmental Protection Agency
Room E-201
Washington, DC 20460
Figure 6. Cover for the Demonstration Test Plan.
33
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5.2.3 Section II - Project Organization
Provide an organizational chart and narrative description, as neces-
sary, to identify the key personnel for the project. Identify personnel who
have overall authority/responsibility for conducting the demonstration test
and their relationship to key personnel having overall authority/responsibil-
ity for the project. It is not necessary to repeat detailed information on
overall project authority/responsibility that has previously been submitted
in the permit application. However, a consolidated organizational chart is
generally advisable so that lines of authority can be identified. Key areas
of responsibility which should be identified include:
Overall project responsibility;
Facilities manager;
Test demonstration coordinator/manager;
Operations manager;
Sampling crew chief;
Monitoring systems operator;
Analytical manager/key analyst;
Quality assurance officer;
Safety officer; and
Operators and laboratory technicians.
Qualifications of the key individuals who will be operating the
system and conducting the sampling, monitoring, and analysis are to be pro-
vided with the Demonstration Test Plan.
5.2.4 Section III - Process Engineering Information
This section provides a general overview of the process, including
a simplified flow diagram. Detailed information about the process should be
in the permit application and may be referenced. However, if modifications
have been made to the system since the permit application, these modifications
should be addressed. Similarly, if any modifications to the normal process
systems will be required during the demonstration, these should be addressed;
for example, if waste will be pumped from 55-gal. drums during the demonstra-
tion, in lieu of using a bulk feed storage tank which will be used during
normal operation, this deviation must be noted and explained.
5.2.5 Section IV - Process Operation Test Parameters
This section presents the operating parameters to be maintained dur-
ing the Demonstration Test. Information which should be presented includes:
Operational plan;
Process operating parameters;
Anticipated emission levels; and
PCBs or PCB items to be fed as waste.
A brief operational plan should be provided. This plan may take
the form of a detailed schedule of events. In the operational plan explain
the operating parameters which will be maintained while bringing the unit on-
line, while conducting the demonstration and while taking the unit off-line.
34
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For example, will the unit be brought on line and its operation first be
demonstrated using auxiliary fuel? Will a non-PCB "waste feed" first be used
to demonstrate safe operation?
The process operating conditions and anticipated emissions can be
summarized in a tabular format. Table 7 is an example "test parameter sum-
mary" for an incineration system. Note that control limits (i.e. acceptable
ranges) are presented for key operating parameters.
Identify the waste feed which will be used during the demonstration
test. State the type of feed, physical state, heat content, and composition
including anticipated PCB concentration. State the total quantity of feed to
be used during the demonstration. Explain how the waste feed used for the
demonstration compares to the waste which will normally be processed during
routine operation; i.e., the same, worst case condition, mixture of antici-
pated wastes. Explain the provisions established for storage of the wastes
prior to and during the demonstration, if different from normal.
5.2.6 Section V - Sampling and Monitoring Plan
This section presents the sampling and monitoring plan for the demon-
stration test. The plan should be detailed and specific to the demonstration.
The plan should address all sampling and monitoring which will be conducted
during the demonstration; i.e., both sampling/monitoring which will be rou-
tinely conducted during normal operation and sampling/monitoring which will
be conducted only during the demonstration test. A tabular format, with nar-
rative explanation, as necessary, can be used to summarize the sampling and
monitoring plan. The sampling/monitoring plan should include the following
elements:
A description of the system or process being sampled or moni-
tored (including sampling location) and breakdown of the pro-
cess into discrete sampling units (stack emissions, liquid
waste, ash, etc.).
The number of tests to be conducted and the schedule.
Generally, three tests are conducted on successive days
for incinerators.
The objective of the sampling or monitoring for each unit (e.g.,
collect a "representative" sample; follow an EPA test protocol;
or collect a "worst case" sample).
The parameters to be tested: List the compounds, physical
measurements and media.
The sampling or monitoring methods: List the methods to be
used. Detailed description of the methods may be presented in
this section or an appendix.
The sample analysis method: List the analytical methods to be
used. Detailed description of the methods may be presented in
this section or an appendix.
35
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Table 7. Example Summary of Anticipated Test Parameters
for an Incinerator
Parameter
Fuel /Waste Feed
Waste feed rate (kg/hr)
PCB concentration in feed (g/kg)
Total chlorine in feed (g/kg)
PCB feed rate (kg/hr)
Chlorine feed rate (kg/hr)
Auxiliary fuel feed rate (kg/hr)
Total thermal duty (106 BTU/hr)
Combustion Conditions
Combustion air flow rate (acm/min)
Residence time (sec)
Destruction temperature (°C)
Combustion gas oxygen (%)
Combustion gas carbon dioxide (%)
Combustion gas carbon monoxide (ppm)
Combustion efficiency (%)
Emissions
Combustion gas NO (ppm)
HC1 removal (%) x
Parti cul ate concentration (mg/dscm)
PCB ORE (%)
Pollution Control
Scrubber water flow (gpm)
Scrubber water (pH)
Venturi water flow (gpm)
Venturi pressure drop (in. H20)
Anticipated
value
100
350
250
35
250
15
4.5
60
2.2
1,250
5
12
20
99.98
40
99.95
< 180
> 99.9999
100
8.5
75
25
Control
limits
85-115
NA
NA
NA
NA
NA
< 5.0
< 65
< 2
1,150-1,350
< 4
NA
< 100
> 99.9
NA
NA
NA
NA
> 85
8.0-10.0
60-100
> 20
Required
value
a
NAa
NA
NA
NA
NA
NA
NA
< 65
2
1,200 ± 100
3
NA
NA
99.9
NA
> 99.9
< 180
> 99.9999
NA
NA
NA
NA
NA (not applicable)
36
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The sampling or monitoring design for each unit. This may re-
quire a mathematical sampling design or simply a reference to
a standard protocol (e.g., EPA Reference Method 3, 40 CFR 60--
Appendix A). The frequency (e.g., every 15 min), size (e.g.,
10 m3), timing (e.g., any time after reaching steady-state),
number of replicates (e.g., 10% of the samples or 2 samples,
whichever is greater, collected in triplicate), number of
surrogate-spiked samples, and total number of samples should
be listed for each sample type. The sample size is usually
dictated either by the amount of sample required to detect the
analyte or by convenience (e.g., 1 liter for water).
An estimate of sample representativeness. This may be based
on data (e.g., historical data on replicates) or scientific/
engineering judgment (e.g., a sample from an actively mixed
feed tank might be characterized as representative).
Contingencies for action if samples cannot be collected ac-
cording to the plan (e.g., alternative sites or times, an
entirely new sampling plan, or repeat tests).
The parameters which typically should be included in the sampling/
monitoring plan for an incinerator are discussed below.
Paragraph 761.70 states that "monitoring of stack emission products
shall be conducted [during a test burn]... for the following parameters:
(a) 02, (b) CO, (c) C02, (d) oxides of nitrogen (NO ), (e) hydrochloric acid
(HC1), (f) total chlorinated organics (RC1), (g) PCBs, and (h) total particu-
late matter [at a minimum]."
Parameters which must be monitored as part of normal operation
(hence, also during the demonstration test) include:
Rate and quantity of waste feed;
Combustion temperature;
Oxygen concentration; and
Combustion efficiency (C02 and CO concentration).
In addition to those required by 40 CFR 761.70, and as part of the
normal operation, EPA has determined that the following parameters be moni-
tored for certain destruction tests:
Total PCB content of the waste feed in order to calculate the
ORE;
PCDD and PCDF (tetra- through octachloro homologs, 2,3,7,8-
tetrachlorodibenzodioxi n, and 2,3,7,8-tetrachlorobidenzofuran)
in the stack emissions; and
PCB, PCDD, and PCDF concentrations (see Table 8) in any solid
or liquid wastes generated.
Appropriate operating parameters of the pollution control system
also should be monitored and the data recorded during the demonstration test
37
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Table 8. PCDD and PCDF Reporting Format3
PCDDs Concentration PCDFs Concentration
2,3,7,8-tetra CDD 2,3,7,8-tetra CDF
Total tetra CDD Total tetra CDF
Total penta CDD Total penta CDF
Total hexa CDD Total hexa CDF
Total hepta CDD ' Total hepta CDF
Total octa CDD Total octa CDF
Total PCDDs Total PCDFs
aLimit of quantisation must be S 10 ng/m3/congener for air samples and
.S 1.0 ng/g/congener for solid and liquid wastes.
ng/m3 for air emissions; ng/g for solid and liquid wastes.
38
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(e.g., scrubber water flow rate and pressure drop). The parameters to be
monitored should be included in the sampling/monitoring plan.
5,2.7 Section VI - Sampling and Analysis Procedures
Specific details of the sampling and analysis procedures which will
be used during the demonstration test must be included in the Demonstration
Test Plan. When "standard methods" will be used, they may be referenced and
included as an appendix. However, any deviations from standard procedures
must be noted. Any modifications to the published procedures or selection
from a number of options given in a procedure should be documented. Further-
more, when the standard method allows different procedural variations to be
used, the applicant must be specific as to the procedures which will be fol-
lowed (e.g., for the measurement of 02 and C02 concentrations in the stack
gas by EPA Method 3, will multipoint integrated sampling or single point grab
sampling be used?).
The discussion of sampling and analysis methods should include:
Sampling equipment;
Sampling equipment calibration;
Sampling procedures;
Sample recovery, storage, and preservation;
Sample transport and custody;
Analytical equipment;
Reagents;
Reagents preparation (e.g., XAD resin preparation);
Calibration standards;
Calibration procedures; and
Sample method blanks.
Appendix B to this document provides guidance on sampling and ana-
lytical methods.
5.2.8 Section VII - Monitoring Procedures
Specific details of the monitoring procedures to be used during the
demonstration test must be included in the Demonstration Test Plan. If these
procedures have been completely described in the permit application and have
not changed, the permit application may be referenced. The following infor-
mation must be included:
Type of instrumentation;
Manufacturer, model number;
Sample conditioning system, if applicable;
Calibration standards; and
Calibration procedures.
Brief descriptions of some monitoring procedures which typically
have been used for PCB destruction systems are presented in Appendix B to this
report.
39
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5.2.9 Section VIII - Data Reporting
Present a summary of the data to be obtained during the demonstra-
tion test and to be presented in the final test report. Example calculations
and reporting units should be presented. Include information for process data,
pollution control system operating data, waste feed, effluent waste, product
streams, and emissions.
All chemical analytical values must be reported as concentrations,
expressed as:
Percent for 0? and C02;
Part per million for trace gases in air (e.g., CO);
Micrograms per cubic meter for organics in air (e.g., PCBs);
Micrograms per liter for water; and
Micrograms per gram for nonaqueous liquids or solids.
To calculate destruction efficiency, PCB values in stack gas and
waste feed are to be reported as "total PCB" (a sum of all 209 congeners).
A breakdown of the total PCB value by homolog or congener may be useful for
certain destruction tests. PCB values in product oil, liquid waste, solid
waste, and other streams must be reported in micrograms per gram (ug/g) per
resolvable chromatographic peak. The analytical results may not be reported
in terms of Aroclor (or other mixture) concentrations, even if an Aroclor is
used to calibrate the instrument (as in the waste feed) unless EPA gives prior
approval.
PCDDs and PCDFs are to be reported by homolog (i.e., total octa-
chlorodibenzofurans, etc.) for the tetra- through octachloro homologs and
summed to give total PCDD and PCDF values as a minimum. Separate values
should be reported for 2,3,7,8-TCDD and 2,3,7,8-TCDF (see Table 8, p. 38).
Any other compounds detected should be reported as quantitated, but
only if the sampling and analytical methods are valid for the subject compound.
5.2.10 Section IX - Miscellaneous Tests
The proper operation of the automatic waste-feed cut-off and other
emergency systems must be demonstrated. Describe the procedures to be used
during the demonstration test to check operation of alarm and emergency sys-
tems, including:
Waste feed cut-off system;
Alarm systems (e.g., high temperature); and
Fire extinguisher system.
These tests must be included on the schedule (see below). They may
be conducted at the conclusion of testing to minimize downtime in PCB
processing.
40
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5.2.11 Section X - Test Schedule
Provide a detailed schedule of the proposed demonstration test
period. The schedule should be of sufficient detail to determine what activi-
ties are planned for each day. Table 9 is an example demonstration test
schedule. The schedule should be realistic in the sense of including suffi-
cient time to address problems which can be expected to occur in operating a
new process.
5.2.12 Section XI—Quality Assurance Plan
Each Demonstration Test Plan must include a Quality Assurance Proj-
ect Plan. If an adequate Quality Assurance Project Plan has been submitted
with the permit application, then only addenda to the QA plan specific to ad-
ditional sampling, monitoring, and analysis for the test demonstration, need
be submitted with the Test Demonstration Plan. Those portions of the QA plan
which apply to normal operations and those which apply only to the demonstra-
tion test must be clearly identified. In any event, the QA plan, with addenda,
must address all measurement parameters (e.g., CO emissions, combustion chamber
temperature), not merely PCB sampling and analysis.
The QA plan must conform to the specifications established in
"Interim Guideline and Specifications for Preparing Quality Assurance Project
Plans" (USEPA, 1980). A QA plan prepared according to these specifications
will address the following items:
Organization and responsibility for QA;
QA objectives for each measurement parameter (precision, ac-
curacy, completeness, representativeness, and compatibility);
Sampling and monitoring procedures;
Sample custody;
Calibration procedures and frequency;
Analytical procedures;
Data reduction, validation, and reporting;
Internal quality control checks and frequency;
Performance and system audits and frequency
Preventive maintenance procedures and schedules
Specific routine procedures to assess data precision, accuracy,
and completeness;
Corrective action; and
QA reports to management.
Additional guidance in the preparation of QA project plans is available in
"Quality Assurance Program Plan for the Office of Toxic Substances" (USEPA
1983b).
For most sampling and analysis plans, a minimum of 10% or 2, which-
ever is greater, of the samples must be collected in triplicate; a minimum of
10% or 2 of the samples, whichever is greater, must be QC controls; and a
minimum of 10% or 2 of the samples, whichever is greater, must be QC blanks.
41
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Table 9. Example: Proposed Schedule for Trial Burn
Day
Tentative
date
Activity
-5
-4
-3
-2
-1
0
xx/yy/zz
2
3
AM
AM/PM
AM/PM
AM/PM
AM/PM
PM
AM/PM
AM/PM
AM/PM
AM
PM
AM
PM
AM/PM
AM/PM
Inventory waste feed
Begin system shakedown using
auxiliary fuel
Continue system -shakedown
Calibrate continuous emis-
sion monitoring system
Continue system shakedown
Check emergency alarm/cut-
off systems
Continue system shakedown
Continue system shakedown
Continue system shakedown3
Test crew arrives on site
Test equipment set-up
Begin PCB destruction
Emission test No. 1
Emission test No. 2b
Emission test No. 3
Shut unit down at comple-
tion of test according
to closure plan
System shakedown should continue until system is able to operate without
significant downtime (e.g., a minimum 24 h of operating time without
.significant downtime is recommended).
Unit will be returned to auxiliary feed at end of each emission test; unit
will be switched to PCB waste in early AM.
42
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5.2.13 Section XII - Standard Operating Procedures
Provide any addenda to the Standard Operating Procedures submitted
with the permit application, if necessary.
43
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6.0 CONDUCTING AND MONITORING A DEMONSTRATION TEST
Once the Agency has determined that the Demonstration Test Plan Is
complete, a demonstration will be scheduled at a date agreeable to both the
applicant and the agency. Before the demonstration can commence,, the Agency
will issue an approval for a demonstration, i.e., a demonstration permit.
The approval will contain certain conditions, including advance 30-day noti-
fication of the demonstration to other appropriate authorities (i.e., Regional
Administrator, state and local offices), PCB-containing material(s) to be
treated, sampling, analysis, waste disposal, QA, site security, recordkeeping,
and reporting requirements. A copy of the demonstration permit must be on
site and adhered to during the demonstration.
If any modifications to the test plan are required prior to the
demonstration test, the Agency (permit writer) should be notified in writing
within 14 days prior to the test. Also, if events require that the plan be
significantly modified during the test demonstration, then the permit writer
should be contacted immediately to discuss the implications of any modifica-
tions. As with normal operation, any significant deviations from or altera-
tions in the standard operating procedure must be documented in writing to
the Agency (permit writer) within 10 days of the event. Throughout the test
demonstration, an "event log" should be maintained. This log should be sub-
mitted as part of the demonstration test report.
Provided that other local, state, and federal regulations allow it,
one or more pre-tests may be conducted using a non-PCB feed to shake down the
facility. For example, if permitted, a test of an HC1 scrubber on an incinera-
tor could be conducted using a chloroform-containing feed to simulate the HC1
produced by the burning of PCBs. Furthermore, an R&D permit may be advisable
to allow the applicant to test the facility with PCBs in the field prior to a
full scale process demonstration (see Section 4.1). EPA encourages applicants
to thoroughly shake down their processes before the demonstration tests. The
EPA may approve shakedown on a limited quantity of PCBs under an R&D permit.
Prior to the test, the facility must be prepared. All instruments,
controls, devices, etc., must be in working order and calibrated. Sufficient
supplies of PCB waste, fuel, reagents, etc., must be on hand. The facility
should be cleaned (remove all waste, purge scrubbers, etc.) to prevent contami-
nation from previous tests or other use.
The test should be conducted under conditions simulating normal com-
mercial operations. Permit requirements usually reflect the systems' operat-
ing conditions during the demonstration test, and conditions used in the tests
become conditions allowed in the permit. Therefore, the applicant should give
very careful consideration to the design and conduct of the demonstration test.
Each demonstration usually consists of the following three steps:
6.1 Start-up
The incinerator is brought up to steady state with no PCBs in the
system. As soon as steady-state conditions are reached during the start-up
phase of the test, conditions should be noted and samples collected to charac-
terize background conditions. When the monitoring equipment is ready for
44
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collecting the next set of samples, the PCB waste should be Introduced into
the incinerator.
6.2 PCB Waste Destruction
The PCB waste is introduced into the incinerator at expected normal
feed rates and expected maximum PCB concentrations. During the test, samples
should be collected and records kept of the readings of the continuous moni-
tors. Visual observation of the effluent should also be made, where appro-
priate. The test should only be as long as necessary to collect samples for
analysis. A 3- to 4-hr emission test is normal for incinerators; three test
runs are normally conducted on successive days.
For stack emission testing, the probe should usually be inserted
into the stack about 30 min after starting the PCB waste feed. This allows
sufficient time for volatilization and destruction of PCBs in the combustion
chamber(s) and for sampling of representative combustion gas emissions during
PCB incineration.
6.3 Shutdown
Waste feed is terminated and the incinerator is then shut down per
normal procedures or kept running on non-PCB fuel at the discretion of the
operator.
45
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7.0 DEMONSTRATION TEST REPORT
After the demonstration test has been performed, a report of the
results must be prepared and submitted to the DD/EED. The format and the
required contents of the test report are presented in this section.
7.1 Format and Contents
Table 10 presents the format for the demonstration test report. The
following paragraphs briefly describe the report contents. The test report
must contain all of the required information as described in this document.
7.1.1 Demonstration Test Report Cover
Figure 7 is the specified format for the report cover.
If the report or the appendices must be bound separately, number
each part of the submission in order (Volume m of n). The covers of each
volume should have the full cover information a~s described above.
7.1.2 Certification Letter
This letter, signed by an authorized official, must certify on behal'f
of the applicant that the test was carried out in accordance with the approved
test plan and the results of all determinations are submitted in the report.
7.1.3 Section I - Summary
The report should begin with a short summary. The summary contains
table(s) summarizing the pertinent test results. Table 11 is an example sum-
mary table for an incinerator demonstration test. A brief narrative should
summarize whether or not the facility met all performance requirements. Major
problems encountered and major deviations from the test plan should be men-
tioned.
7.1.4 Section II - Process Operation
7.1.4.1 General
Provide a general overview of the process using simplified flow
diagrams and*• brief narrative. Detailed information on the process should
be in the perjilt application and may be referenced.
7.1.4.2 Operation During the Test
Summarize the operating parameters of the process during the
destruction test. Include physical characteristics of the feed, PCB content
of the feed, feed rates, total feed quantity, temperatures, pressures, efflu-
ent stream flow rates and volumes, pollution control system operating param-
eters, and combustion gas composition (CO, C02, 0,, excess oxygen). A tabular
format with explanatory narrative, as necessary, is preferred. Detailed data
such as tables of 15-min temperature readings and the process operator's log
should be relegated to an appendix.
46
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Table 10. Format for the Demonstration Test Report
i Report Cover
ii Table of Contents
iii Certification Letter
I. Summary
II. Process Operation
III. Sampling and Monitoring Procedures
IV. Analytical Procedures
V. Test Results
VI. QA Summary
VII. Visits and Audits
VIII. Closure
IX. Waste Disposal Manifests
Appendices
47
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Volume m of n
DEMONSTRATION TEST REPORT
PCB DESTRUCTION UNIT
[Type and location]
[Test site for mobile units]
Test dates :
Submission date:
Submission number [in sequence with permit application and test plan submissions]
Submitted by: Submitted to:
[Company name and address] Division Director, Exposure Evaluation
[Principal manager and phone no.] Division
c/o Document Control Officer (TS-790)
Office of Toxic Substances
U.S. Environmental Protection Agency
Room E-201
401 M Street, S.W.
Washington, DC 20460
Figure 7. Demonstration Test Report cover.
48
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Table 11. Example Demonstration Test Results Summary
Test Test Test
1 23
Date
Time test begun
Time test ended
Operating parameters:
Waste feed rate (kg/h)
PCS concentration (g/kg)
PCB feed rate (kg/h)
Auxiliary fuel feed rate (kg/h)
Total thermal load (106 BTU/h)
Avg. calculated residence time3 (sec)
Avg. combustion air flow (acm/min)
Avg. oxygen (%)
Avg. carbon dioxide (%)
Avg. carbon monoxide (ppm)
Combustion efficiency (%)
Avg. scrubber water flow (gpm)
Avg. scrubber water (pH)
Avg. venturi water flow (gpm)
Avg. venturi pressure drop (in. H20)
Particulate/HCl emissions:
Total sample time (min)
Total sample volume (dscm)
Stack gas flow rate (dscm/min) b
Particulate concentration (mg/dscm)
Chlorine (g/min)
HC1 removal (%)
PCB emissions:
Total sample time (min)
Total sample volume (dscm)
PCB feed rate (g/min)
PCB output rate (g/min)
PCB DRE (%)
PCDD/PCDF emissions:
Total sample time (min)
Total sample volume (dscm)
Total PCDD emissions (ng/dscm)
Total PCDF emissions (ng/dscm)
^Calculated from stack gas volumetric measurements.
Corrected to 12% C02.
49
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7.1.4.3 Deviations from Test Plan
Any events such as upsets, shutdowns, or other deviations from
normal operations, along with the corrective actions taken must be described.
These deviations should have been previously reported to the permit writer,
verbally during the test and as a separate written incident report within 14
days of the incident. These incident reports should be presented in an ap-
pendix. This section should summarize the incidents, discuss their effect on
the test results, and discuss their effect on the overall ability of the
system to routinely operate within permit conditions.
Also describe non-incident-related changes such as site loca-
tion, amount of PCBs treated, and use of an independent laboratory for analy-
sis. The purpose or reasons for these types of changes should be explained
in this section.
7.1.5 Section III - Sampling and Monitoring Procedures
Describe the sampling and monitoring procedures used. Standard pro-
cedures may be referenced, but any deviations or modifications from referenced
methods must be described. Lengthy method descriptions should be placed in
the appendix.
Summarize the type, location, time, volume, and number of samples
collected. Any significant deviations from the Demonstration Test Plan must
be noted and the potential effects on the results discussed.
Summarize the type, location, and time period of all monitoring.
Any significant deviations from the Demonstration Test Plan must be noted and
the potential effects on the results discussed.
7.1.6 Section IV - Analytical Procedures
Describe the analytical procedures used for each parameter (e.g.,
PCBs in water). Standard procedures may be referenced, but any deviations or
modifications from referenced methods must be described. Identify deviations
from the Demonstration Test Plan. Lengthy descriptions should be placed in
an appendix.
7.1.7 Section V - Test Results
Prefawnt concise summaries for all pertinent parameters such as:
Stack emissions (NO , HC1, RC1, participate, PCB, PCDD, PCDF);
Influent and effluent stream analyses;
Stack gas monitoring (CO, C02, 02); and
Performance results (DRE, combustion efficiency).
Discuss the test and QC results and analysis system performance as necessary.
All results should be traceable to the original test data. As a minimum,
identify how the results were calculated (formulae and data used). Detailed
sample calculations should be presented in the appendix and referenced. For
50
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example, for calculation of the ORE, the equation used should be shown or
referenced:
ORE = 1n ' W°ut x 100
"in
The values for W. and W . used in the calculation should be clearly iden-
tified (i.e., the Table or page number where they appear in the report) along
with the calculated result, so that the ORE calculation nay be confirmed.
Identify and discuss any anomalies in the system operation, sampling,
monitoring, or analyses that may have significant impact on the test results.
Raw data and raw analytical results (e.g., chromatograms, mass mea-
surements) also should be presented in the appendices.
7.1.8 Section VI - Quality Assurance Summary
Summarize the QA results (blanks, replicates, audit results). Iden-
tify any serious problems (e.g., unacceptable audit results, failure to cali-
brate instrumentation) or deviations from QA protocol. A separate QA report
must be presented, authored and signed by the QA officer. The QA report
should address all the QA objectives, including whether or not precision and
accuracy objectives were met, as well as results of quality control samples,
performance audit samples, and systems audits.
7.1.9 Section VII - Visits and Audits
This section should contain a list of visitors and auditors and the
affiliation, address, and phone number of those who were on site during the
demonstration. The list should include all visitors or auditors from state,
local, or federal agencies, their contractors, applicant management, QA per-
sonnel, and independent consultants. Where possible, the purpose of these
visits and any significant results should be summarized. If audit reports,
engineering certifications, etc., were issued by any visitors, they should be
appended to the demonstration test report.
7.1.10 Section VIII - Closure
The applicant should summarize the facility closure after the demon-
stration. My deviations from the closure plan should be discussed. Appli-
cant should provide documentation (copies of manifest) to show that all wastes
generated during the process test were properly disposed according to TSCA
and RCRA regulations. Applicant should be aware that all the waste generated
during the test should be disposed of by incineration and not landfill ing,
unless compliance with the landfill restrictions can be demonstrated.
7.1.11 Appendices
Supporting information (e.g., detailed procedures, analytical re-
sults, sample calculations, QA report) should be presented in the appendices.
51
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Include the chronological demonstration test events log and any incident
reports.
7.2 Review
The permit writer will review the report to determine if it contains
all necessary elements and if the demonstration has met the objectives of the
test.
7.3 Approval
Upon acceptance of the process demonstration test report and a de-
termination that the process operates within all of the pertinent requirements
of 40 CFR 761 and the conditions of the demonstration permit, the DD/EED shall
issue a final permit to operate commercially. The operating permit will con-
tain certain conditions, including matrices to be treated, maximum PCB concen-
trations to be treated, waste disposal, site security, recordkeeping, report-
ing, and closure requirements. A permit will normally be issued for 3 years'
operation. A copy of this approval should be on site and adhered to during
all operations.
52
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8.0 REFERENCES
Beard, J. H., III, and J. Schaum, "Sampling Methods and Analytical Procedures
Manual for PCB Disposal: Interim Report, Revision 0," Office of Solid Waste,
U.S. Environmental Protection Agency, Washington, DC (February 10, 1978).
U.S. Environmental Protection Agency, "Polychlorinated Biphenyls (PCBs) Manu-
facturing, Processing, Distribution in Commerce, and Use Prohibitions," Fed-
eral Register. 44, 31514-31568 (May 31, 1979).
U.S. Environmental Protection Agency, "Guidelines and Specifications for Pre-
paring Quality Assurance Project Plans," Office of Monitoring Systems and
Quality Assurance, QAMS-005/80, December 27, 1980.
U.S. Environmental Protection Agency, 40 CFR Part 761, "Procedural Amendment
of the Approval Authority for PCB Disposal Facilities and Guidance for Obtain-
ing Approval," Federal Register. 48, 13181-13186 (1983a) [has been superseded
by USEPA (1985)J
U.S. Environmental Protection Agency, "Quality Assurance Program Plan for
the Office of Toxic Substance," Office of Pesticides and Toxic Substances,
Washington, D.C., September 30, 1983b.
U.S. Environmental Protection Agency, 1985a, Code of Federal Regulations,
Title 40, Part 60 (40 CFR 60) "Standards of Performance for New Stationary
Sources, Appendix A -- Reference Methods".
U.S. Environmental Protection Agency, 1985b, Code of Federal Regulations,
Title 40, Part 761 (40 CFR 761), "Polychlorinated Biphenyls (PCBs) Manufactur-
ing, Processing, Distribution in Commerce, and Use Prohibitions."
Weller, P. J., J. Andis, and S. Baig, "Preliminary Study Regarding Alternative
Definitions of PCB Solid/Liquid Wastes," dated October 1981, Appendix H in
R. G. Mclnnes and R. J. Johnson, "Provision of Technical Assistance to Support
Regional Office Implementation of the PCB Regulations—East and West," Draft
Project Summary Report by GCA Corporation, New Bedford, MA, and TRW, Inc.,
Redondo Beach, CA, on EPA Contract No. 68-02-3168, Work Assignment No. 45, and
Contract No. 68-02-3174, Work Assignment No. 68, for David C. Sanchez, USEPA,
Office of Research and Development, IERL, Research Triangle Park, NC, 1982,
186 pp.
53
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APPENDIX A
CHECKLISTS FOR COMPLETENESS OF SUBMITTAL
A-l
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APPENDIX A.I
PERMIT APPLICATION CHECKLIST FOR INCINERATORS
To Be
Submitted Not
Submitted At Later Date1 Applicable
1. Permit Cover
2. Summary (Section I)
3. Project Organization (Section II)
A. Chart
B. Text
4. Waste Description (Section III)
A. Type
B. Total Amount/Feed Rate
C. Physical/Chemical
Description
5. Process Engineering (Section IV)
A. General Overview
• Description
• Flow Diagram
Location
• Site Maps
B. Waste Feed System
C. Waste Feed Shut Off System
D. Destruction System
E. Pollution Control System
F. Operating Parameters
6. Monitoring Plan (Section V)
A. Parameter List
(see attached supplemental
checklist)
B. Monitoring Frequency
C. Monitoring Plan Design
D. Methods
7. Monitoring Procedures
(Section VI)
A. Appropriate Methods
B. Written Protocols
C. Apparatus
D. Data Reduction
E. Data Storage/Logging
F. Calibration
G. Maintenance
A-2
-------
To Be
Submitted Not
Submitted At Later Date1 Applicable
8. Data Reporting (Section VII)
A. Format
B. Example Calculations
C. Units
9. Inspection Procedures
(Section VIII)
A. Waste Feed System
B. Destruction System
C. Waste Feed Cut-Off System
D. Pollution Control System
E. Alarms
F. Fire Extinguisher Systems
10. Spill Prevention Control
(Section IX)
11. Safety Plan (Section X)
12. Training Plan (Section XI)
13. Trial Burn Plans (Section XII)
14. Test Data or Engineering Per-
formance Calculations (Sec-
tion XIII)
15. Other Permits or Approvals
(Section XIV)
A. Regional R&D
B. Regional Full-Scale
C. RCRA
D. State or Local
E. DOT
16. Schedule (Section XV)
*r
17. QA Plan (Section XVI)
A. FonMt
B. Organization and
Responsibility
C. QA Objectives
1. Precision
2. Accuracy
3. Completeness
4. Representativeness
5. Comparability
A-3
-------
To Be
Submitted Not
Submitted At Later Date1 Applicable
D. Monitoring Procedures
E. Calibration Procedures and
Frequency
F. Data Reduction, Validation
and Reporting
G. Internal Quality Control
Checks
H. Audits
1. Performance
2. System
I. Preventive Maintenance
J. Specific Routine Procedures
Used to Assess Data Pre-
cision, Accuracy and
Completeness
K. Corrective Action
L. Quality Assurance Reports
to Management
18. Standard Operating Procedures
(Section XVII)
19. Closure Plan (Section XVIII)
A. Site-to-Site
B. Permanent
Section of the permit should be reserved for revised submittal and the
deficiency should be noted in the application.
A-4
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APPENDIX A.2
MONITORING PARAMETER SUPPLEMENT FOR INCINERATORS
5 g,
^ fr 2
> c o
s-/ O) C +J
•o §• •? iC
£ £ S §
O LL. Q .,-
** P« ™ *J e Q)
•^- O> O) (J O O
CCC in 3 -^ C
,2 T **" 3 "° ** *
Z i- «- 4->«iac
OO"DiDC£(.ai
flJ*-»*JOt. JS^
CD '^ t- ja n 19 *i~ c
C C *J Q. 4-> r— -^
a. PCBs in Waste Feed
b. Feed Composition
c. Waste Feed Rate
d. 02
e. CO
f. C02
g. NOX
h. Combustion Efficiency
i. Residence Time
j. Destruction Temperature
k. Other
1. Other
m. Other
A-5
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APPENDIX A.3
CHECKLIST FOR INCINERATOR DEMONSTRATION TEST PLAN
To Be
Submitted Not
Submitted At Later Date1 Applicable
1. Test Plan Cover
2. Summary (Section I)
3. Project Organization (Section II)
A. Key Personnel Identified
B. Organization Chart
4. Process Engineering Information
(Section III; new information
from Permit Applications)
5. Process Operation Test
Parameters (Section IV)
A. Operational Plan
B. Process Operating Parameters
C. Anticipated Emission Levels
D. Waste Feed Description/
Quantity
6. Sampling and Monitoring Plan
Design (Section V)
A. Number of Tests
B. Parameters to be Monitored2
C. Parameters to be Sampled2
D. Sampling/Monitoring Locations
E. Number/Frequency of Samples
F. Sampling Methods
G. Monitoring Methods
H. Analysis Method
7. Sampling/Analysis Procedures2
(Section VI)
A. Methods
B. Written Protocol
C. Equipment
D. Calibration
A-6
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To Be
Submitted Not
Submitted At Later Date1 Applicable
8. Monitoring Procedures2
(Section VII)
A. Written Protocol
B. Equipment
C. Calibration
9. Data Reporting (Section VIII)
A. Data to be Reported, Units
B. Example Calculations
10. Miscellaneous Tests (Section IX)
A. Waste Feed Cut-Off
B. Alarm Systems
C. Fire System
11. Test Schedule (Section X)
12. Addenda to QA Plan (Section XI)
13. Addenda to Standard Operating
Procedures (Section XII)
Section of the permit should be reserved for revised submlttal and the
deficiency should be noted In the application.
See supplemental checklist.
A-7
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APPENDIX A.4
SAMPLING AND MONITORING PARAMETERS DEMONSTRATION TEST PLAN SUPPLEMENT FOR INCINERATORS
a.
b.
c.
e.
f.
g.
h.
i.
j.
k.
1.
m.
n.
0.
p.
q.
r.
s.
t.
u.
V.
W.
X.
y
PCBs in Waste Feed
Feed Composition
Waste Feed Rate
CO
C02
N0x
Combustion Efficiency
Residence Time
Destruction Temperature
Excess 02
HC1 Removal Efficiency
Stack Gas Flow Rate
PCB Feed Rate
PCB Output Rate
DRE
Parti cul ate
RC1 (volatile)
RC1 (semivolatlle)
PCDDs/PCDFs
Semi volatile Organic
Screen
Pollution Control System
Operation
Ash Composition
Wastewater
Other
V.
W
W
00
o
—
^™~
—
^^^^
MMW
^^.
To Be Monitored (Y/N;
~"
^H^M
^^^^
^•M*
£
3
^
W
0)
«^»
i
10
CO
—
—
—
^^^^
^MW
u
1
^•d
O)
c
T
c
O)
e
1
(0
00
—
^™~
—
^M«M»
•^•M
^M^M
4J
W ^3
•s i J
y *^ *^ c o
O 3 fltf O C
2LU C 4J §> 4J
*V t— O 0 (0 U
a. «» «o •»- 3 u o
3 0 4J -0 0 Q.
•g£££S(g£«£
IS 1 '"5 S 5 5 5
>*ka.ciaio(a(o
X3B<
-------
APPENDIX B
MONITORING. SAMPLING. AND ANALYSIS PROCEDURES
B-l
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1.0 MONITORING METHODS
Monitoring of gaseous components is specifically required by §761.70
for thermal destruction systems. Carbon dioxide (C02) must be monitored
periodically at intervals of no longer than 15 min. Oxygen and carbon mon-
oxide must be monitored continuously. "Continuously" is not defined by the
regulation; OTS recommends an instrumental system which completes a minimum
of one cycle of sampling and analyzing at least once every 15 sec and records
data at least once every minute.
Information related to continuous emission monitoring systems, in
general, can be found in "Continuous Air Pollution Source Monitoring Systems"
(USEPA 1979).
2.0 SAMPLING PLANS
Sampling plans are often slighted in the rush to get a test under-
way. Poor planning of the sampling can ruin an otherwise acceptable test and
is often the weakest portion of an application. The applicant and permit re-
viewer must work together to develop a detailed sampling plan which will pro-
duce the desired information. In some cases, a "typical" sample may be de-
sired, while in others a "worst case" sample may be desired. The objective
must be clearly spelled out.
PCB destruction facilities are, unfortunately, not ideal sampling
sites. Events do not always occur according to plan, especially during the
shake-down periods in which the destruction test is generally held. The sam-
pling plan must reflect the realities of the destruction unit and make every
attempt to meet the stated objectives. In cases where a sampling plan is
compromised, the demonstration test report should present an explanation.
Several examples of approaches (not full sampling plans) to sampling
situations are presented below.
1. Stack testing generally is conducted over the duration of a test
burn (e.g., 4 h). In the EPA Method 5 protocol, the probe is traversed across
the stack in a prescribed, nonrandom manner to get a sample representative of
all of the stack gases.
2. The waste feed must be sampled from a pipe throughout a test
burn. Ideally, a pump would be used to continuously draw off a portion of
the feed to obtain an Integrated sample. If use of a pump 1s impractical be-
cause of the valve design or feed stock viscosity, manual integration may be
an alternative. At measured time intervals (e.g., every 15 min) the valve is
opened and a measured amount added to the sample. Thus, over the burn, a
sample is collected, which 1s an integration of the feed at 15-min intervals.
3. An ash bin would Ideally be sampled in a random fashion, where
every part of the bin has a finite, known probability of being sampled. How-
ever, access ports are not randomly placed. A plan may specify that the sam-
pling be randomized within the access area available (perhaps similar to the
feed sampling).
B-2
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4. A field of waste drums is to be sampled. The drums could be
randomly sampled. If the drums are known to be from several sources and are
Identifiable, the sampling design should include stratification of the sub-
sets.
5. The plan stipulates that if a bung on a drum is frozen, the
sampler is to move to the nearest drum to the north. If more than half of
the bungs are frozen or if the bungs on an apparent set of drums (in one area
or with similar markings) are all frozen, the representativeness of the sam-
pling may be compromised (these may all contain a corrosive liquid which has
frozen the drums shut) and additional efforts at opening the drums should be
employed. These would include freeing the frozen bungs or cutting a new hole
in the drum.
3.0 EXAMPLES OF SAMPLE COLLECTION TECHNIQUES
Additional guidance on sample collection techniques is available in
"Samplers and Sampling Procedures for Hazardous Waste Streams" (USEPA 1980) and
in "Sampling and Analysis Methods for Hazardous Waste Combustion" (USEPA 1983).
3.1 Liquids
Liquids may be collected by grab or integrative techniques. Grab
sampling may include filling a jar from a spigot or dipper collection of water
from a lagoon. Frequency of sampling and amount to be collected during each
test must be stated in the sampling plan and recorded when the samples are
collected. Integrative sampling requires a pump on an interval timer, a slow
flow from a valve, manually timed interval sampling, or other device. Addi-
tional guidance is available (Berg 1982).
3.2 Solids
Solid sampling techniques vary with the nature of the solid. Free-
flowing powders may behave like a liquid, while other solids may require spe-
cial equipment to remove a portion. The equipment to be used (trowel, auger,
grain thief, etc.) and procedures for its use must be adequately described.
3.3 Mixed Phase Samples
Mixed phase samples represent a challenge to the sample collector.
In tanks and/other static systems, a phase separation during sampling is
preferable, provided that the total volume or weight of each phase is mea-
sured. Phases collected separately must be analyzed separately. Proportions
of each phase in the system (e.g., a holding tank) shall be measured volumet-
rically. Examples including skimming solids off liquids and drawing off oil
and water layers from a tank. Where phase separation is impractical, such as
a suspended solid, the whole must be mixed to assure that the sample is repre-
sentative. In a flowing pipe, collecting a representative sample of a solid/
oil/water mixture may be impossible, since the valve position is fixed. In
this situation the oil phase would probably contain more PCBs than the water
and would represent a maximum (worst case for waste, best case for feed).
The representativeness or lack thereof should be noted.
B-3
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3.4 Participate Matter In Stack Gas Emissions
EPA Method 5 (40 CFR 60) is used to collect a particulate matter
sample.
3.5 Organic Stack Gas Emissions
The modified Method 5 (MM5) train is generally used for sampling
organic emissions from PCB destruction systems. The configuration presented
by ASME (1984) or Stanley et al. (1982) should be followed unless an alternate
configuration is approved by the EPA. The ASME method is still in draft form,
but is available from OTS. The stack gas is withdrawn isokinetically using a
sample train. PCBs, PCDDs, PCDFs, and similar compounds are trapped on an
adsorbent tube. The sampling time and amount of gas to be sampled must be-
stated. Other sampling methods may be used if demonstrated to be satisfactory
for the objectives of the test and approved by the EPA. Note that separate
sampling trains are recommended for collecting the particulate and the organic
emissions. The reason for recommending separate sampling trains is that PCBs
and other semivolatile organics may be lost during drying and desiccation of
the probe wash/filter catch, as required in Method 5.
3.6 HC1 Stack Gas Emissions
Modified Method 5 is usually used to quantify HC1 emissions; caustic
solution is used in one or more of the impingers to collect the clorides.
3.7 NOX Stack Gas Emissions
Nitrogen oxides (NO ) in stack gases are determined according to
EPA Method 7 (40 CFR 60). Alternate methods, such as instrumental analyzers
may be used if approved by the EPA.
3.8 RCJ
Total chlorinated organics (RC1) must be sampled during the initial
destruction test. No specific method was mandated by the Agency in the rules.
As a result, many sampling techniques have been used to measure RC1. Strictly
speaking, RC1 must measure volatile, semivolatile, and nonvolatile compounds
since the collection and analysis techniques for these three categories may
differ. It appears that the volatile halocarbons (e.g., methyl chloride) con-
stitute most of the RC1. These compounds can be sampled using the volatile
organic sampling train (VOST) (Bergman 1984; Hansen 1984). . Semivolatile RC1
can be determined from the sample collected in the MM5 train. Analysis is by
GC/MS, GC/ECD, or GC/HECO (see Appendix C, Section 4.4.2).
4.0 SAMPLE ANALYSIS METHODS
4.1 Methods for PCBS
OTS does not specify analytical methods for PCBs; however, this
section presents certain guidelines on methods which OTS has reason to believe
B-4
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will provide acceptable data. Methods for feed materials, stack gas, ash,
and scrubber water are presented. Methods other than those presented here may
be proposed by permit applicants, provided that the proposed methods meet the
OTS data quality objectives (e.g., analysis for all PCBs In samples with de-
tection limits adequate to meet permit requirements). Analytical methods for
PCBs have been reviewed recently (Erickson 1985; Erickson and Stanley 1982;
Erickson et al. 1982, 1985a, 1985b). Applicants should review these guide-
lines and propose complete, specific methods in their test plan. Many methods,
including some of those discussed in this section, present one or more options
to the analyst. The applicant must state which option is to be used. If se-
lection of options is dependent on samples, or on other factors which cannot
be predicted, the selection criteria must be presented in the test plan.
PCBs are a complex set of 209 individual chemical compounds. The
commercial mixtures for commonly found in the feed material generally contain
from 20 to 80 of these 209 PCB congeners. In most cases for effluent samples,
however, it can be anticipated that the PCB pattern will be qualitatively
different from that in the feed, unless the PCBs were transmitted through the
system without any chemical alteration by the destruction process. For efflu-
ent samples, the analytical method must identify and quantitate all of the
PCBs present in each sample, not just the Aroclor present in the feed.
4.1.1 Feed Materials
As long as the feed material contains PCBs which qualitatively re-
semble one of the commercial mixtures, such as the Aroclors, the traditional
analytical methods which use Aroclor mixtures for GC calibration are acceptable.
These methods are discussed below.
If the PCB composition in the feed material does not resemble a com-
mercial mixture, the samples should be analyzed using the methods recommended
for the effluent samples, as discussed below.
4.1.1.1 Oils
The EPA procedure for analysis of PCBs in transformer oils and
waste oils (USEPA 1981, Bellar and Lichtenberg 1981) provides a generalized ap-
proach with respect to sample preparation and instrumental analysis. Several
cleanup techniques are provided as optional approaches in this procedure. For
the instrumental analysis, GC with halogen specific, electron capture, or mass
spectrometry detectors are all allowed, provided appropriate limits of detec-
tion can be achieved. A strong quality control program including control
samples, dally quality control check samples, blanks, standard additions,
accuracy and "precision records, and instrumental and chromatographic perfor-
mance criteria Is required to support all data generated by the method.
The ASTM (1983) procedure for mineral insulating oils utilizes
solvent dilution and a Florisil slurry cleanup prior to PGC/ECD determination.
The procedure assumes that the composition of the PCBs present in transformer
or capacitor oils closely resembles that of the Aroclor standards. It notes
that the sensitivity of the ECD is reduced by mineral oil and Instructs the
analyst to make the amount of oil in the standard and sample equivalent to
minimize the effects of the oil Interference on the quantitative results.
B-5
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4.1.1.2 Soils. Sludges, and Solid Wastes
A variety of standard methods are available for these matrices.
Several EPA methods utilize dichloromethane extraction, fol-
lowed by cleanup and GC determination with different detectors. -Soil and
other solid wastes may be analyzed by EPA's SW-846 methods (USEPA 1984a).
Method 8080 is the packed column GC/ECD method; 8250 is the packed column
GC/EIMS method; and 8270 is the capillary column GC/EIMS method. All three
methods have a stated limit of detection of 1 pg/g. Some options are pre-
sented in these methods and the quantisation procedure is not well-defined
for PCBs; therefore, applicants must supply additional details on the planned
analysis.
The sludge method EPA 625-S (Haile and Lopez-Avila 1984) gives
optional Florisil, silica gel, and GPC cleanups and stipulates electron im-
pact mass spectrometry as the GC detector. Quantisation is by total areas
compared to total areas of Aroclor standards.
ASTM Method 03304-74 (ASTM 1981b) utilizes a hexane/water/
acetonitrile extraction for soil samples. Several optional cleanups are
presented. Samples are analyzed by packed column GC/ECD and quantitated using
the total areas of Aroclor standards.
4.1.1.3 Capacitors and Other Solids
No standard methods exist specifically for these matrices.
The sample should be physically prepared by shredding or grinding and then
extracted with an appropriate solvent (e.g., benzene or hexane), preferably
with a Soxhlet apparatus over multiple cycles. Cleanup and analysis can then
follow one of the methods given above.
4.1.2 Stack Gas Samples
Stack gas samples collected by modified Method 5 trains (see Section
3.5) are extracted, cleaned up, and analyzed by gas chromatography. The fil-
ter and the sorbent cartridge (e.g., XAD-2) are generally extracted together
with a nonpolar solvent such as hexane, benzene, toluene, or petroleum ether.
The extraction is generally done in a Soxhlet extractor to give prolonged and
repeated contact with clean solvent. The ASME (1984) toluene extraction and
the EPA (Erickson 1984a) hexane extraction are acceptable examples.
GC/EIMS is recommended for the instrumental determination. An EPA
perch!orination GC/ECD method (Haile and Baladi 1977, Beard and Schaum 1978)
is inappropriate for these complex samples, since perch!orination of non-PCB
molecules (e.g., biphenyl) can lead to artifacts in the analysis. An EPA
GC/EIMS method (Erickson 1984a) provides guidance on the GC/EIMS analysis and
also provides a detailed quantitation method.
The EPA procedures for PCB spills and incinerators (Beard and Schaum
1978) are part of a manual for PCB disposal, primarily focusing on incineration
methods. Although this interim report is badly flawed and incomplete, it has
B-6
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been widely used as the guidance document by the EPA Regional Administrators
for testing incinerators. These methods have never been updated and are cur-
rently superseded by other methods. Therefore, OTS does not recommend their
use by permit applicants.
The stack gas is sampled using the modified EPA Method 5 technique
developed by Haile and Baladi (1977). PCBs are extracted from the sorbent
material in a Soxhlet extractor using both pentane and methanol. The GC/MS
analysis is taken from a tentative procedure for PCBs in water (Dudenbostel
1978). Samples may be chromatographed on columns packed with 3% Dexsil 300,
OV-1, or OV-101 and may be detected using either electron impact or chemical
ionization mass spectrometry.
Part of EPA's manual for PCB disposal, the "Tentative Method for
Testing of Polychlorinated Biphenyls (PCBs) in Spilled Material" (Attachment A,
Beard and Schaum 1978), directs the analyst to air-dry the sample (matrix is
not further specified), grind it, and then extract a 100-g subsample in a
Soxhlet extractor with hexane-acetone (1:1). The procedure then patches into
an unreferenced industrial effluent method, which first specifies a PGC/ECD
screen. If necessary, various cleanup techniques are specified. An aceto-
nitrile partition is used to remove fats and oils. A Florisil column cleanup
fractionates out some pesticides by eluting with 6%, 15%, and 50% ethyl ether/
petroleum ether. Two alternate silica gel microcolumn cleanups are presented,*
one of which provides for sulfur removal with mercury. As noted for the stack
gas samples, above, this old method has never been updated and is not recom-
mended by OTS for use by permit applicants.
4.1.3 Ash
Ash and other solid effluent samples can be analyzed by EPA's SW-846
methods (USEPA 1984a) only if the Aroclor pattern remains intact after the
incineration process. Method 8080 is the packed column GC/ECD method; 8250
is the packed column GC/EIMS method; and 8270 is the capillary column GC/EIMS
method. All three methods have a stated limit of detection of 1 pg/g. Some
options are presented in these methods and the quantitation is not well-
defined for PCBs; therefore, applicants must supply additional details on the
planned analysis.
ASTM Method D3304-74 (ASTM 1981b) utilizes a hexane/water/acetonitrile
extraction for soil samples and may be adapted for use with ash samples. Sev-
eral optional cleanups are presented. Samples are analyzed by packed column
GC/ECD and quantitated using the total areas of Aroclor standards. Applicants
must supply details on the planned analysis.
If the Aroclor pattern is significantly altered by the destruction
process, or if other PCBs (e.g., partially dechlorinated homologs) are observed
in the samples, then the above methods are not appropriate for the analysis.
An EPA method for by-product PCBs in commercial products and product wastes
(Erickson 1984c) may be used with GC/MS as the instrumental method. This
method presents several options, so permit applicants must stipulate which
options are to be used.
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If the applicant chooses to use GC/ECD as the instrumental method,
a mixture of 10 PCB congeners (one each for the various degrees of chlorina-
tion) may be used for the calibration. This mixture was determined by the
Dry Color Manufacturers Association (OCMA) to give an average ECD response
for each homolog (DCMA 1982). No specific published method is available for
analysis of ash samples using the OCMA quantisation mixture. Sample prepara-
tion (extraction, cleanup, etc.) can be done according to EPA's SW-846 (USEPA
1984a) or the EPA by-product method (Erickson 1984c). Instrumental analysis
can be done according to EPA Method 608 (USEPA 1984b). To quantitate the
samples, the following protocol (Midwest Research Institute 1985) may be used:
a. Determine the retention windows. Note: This is an arbi-
trary demarcation and results in misidentification of some congeners as either
a higher or lower homolog. However, since the ECD cannot discriminate by
homologs, this is the best approach to partitioning the peaks.
(1) Record the retention time for each congener in the
standard on a data sheet.
(2) For the mono-, the window extends from the retention
time of the standard, which is the first eluting PCB, to the midpoint between
the mono- and di- standards. Start the window sufficiently ahead of the stan-
dard elution time (e.g., 0.1 min) to allow for retention time drift.
(3) The windows for di- through nona- are the midpoints
between the retention times of the standards.
(4) For the deca-, which has only one isomer, the window
is the retention time of the standard, allowing appropriate time (e.g.,
±0.1 min) for retention time drift.
b. Calculate a linear regression curve for each homolog. The
minimum correlation coefficient (e.g., 0.99) should be specified in the QA
Plan. If this required correlation is not obtained, either rerun the standard
curve or perform corrective action as given in the QA Plan.
c. Quantitate the samples. Obtain the concentration in micro-
grams per milliliter of each peak in the sample (as injected on the gas chro-
ma tograph) from the regression equations calculated above. For most samples,
only peaks equal to or greater than 1 ug/g need be reported. Those peaks much
less than this value do not need to be calculated. Where it appears that the
peaks will be below the cutoff, calculate the area counts necessary for 2 ug/g
and then visually compare these with the sample data. This shortcut can speed
up the data reduction process by eliminating unnecessary calculations.
d. Multiply the concentration obtained by the dilution factor
and divide by the original sample weight (or volume) to obtain the concentra-
tion in ug/g (or ug/mL) of the original sample. Record this value on the data
sheet for each peak greater than or equal to 2 ug/g.
e. Automated quantitation routines incorporating the above
principles may be substituted.
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4.1.4 Aqueous Samples
Scrubber water and other aqueous samples can be analyzed by EPA
Method 608 (USEPA 1984b) or 625 (USEPA 1984d) or ASTM method D3534-80 (ASTM
1981a) only if the Aroclor pattern remains intact after the incineration.
If the Aroclor pattern is significantly altered by the destruction
process, or if other PCBs (e.g., partially dechlorinated homologs) are observed
in the samples, then the above methods are not appropriate for the analysis.
An EPA method for by-product PCBs in water (Erickson 1984b) may be used with
GC/MS as the instrumental method. This method presents several options, so
permit applicants must stipulate which options are to be used.
If the applicant chooses to use GC/ECD as the instrumental method,
the DCMA (1982) quantitation discussed above may be used. No specific pub-
lished method is available for analysis of ash samples using the DCMA quanti-
tation mixture. Sample preparation (extraction, cleanup, etc.) can be done
according to EPA Method 608 (USEPA 1984b) or 625 (USEPA 1984d) or the EPA
by-product method (Erickson 1984b). Instrumental analysis can be done ac-
cording to EPA Method 608 (USEPA 1984b). To quantitate the samples, the
protocol presented in Section 4.1.3 may be used.
4.2 Methods for PCDDs and PCDFs
Because of their extreme toxicity, PCDDs and PCDFs are of environ-
mental concern even at very low levels. Applicants must be able to detect
PCDDs and PCDFs at levels of i 10 ng/m3/congener as given in Table 8. There-
fore, analytical methods must not only be extremely sensitive but also generate
highly reliable results. For these reasons, only a few instrumental techiques
have been accepted for use in PCDD and PCDF analysis. Probably the most common
is high resolution gas chromatography/electron impact mass spectrometry
(HRGC/EIMS), operated in the selected ion monitoring mode. More advanced
techniques are available and may be used for confirmation. These would
include HRGC/high resolution EIMS.
The method used must be capable of quantitating total PCDDs, total
PCDFs, total TCDD congeners, and total TCDF congeners, in addition to 2,3,7,8-
TCDD and 2,3,7,8-TCDF. While a certain identification is not required, any
tentative identifications must be quantitated as PCDD or PCDF compounds.
Since a false positive could adversely affect the permit approval process, it
is advisable to employ the best possible analytical methods.
The method must employ GC/EIMS with GC/high resolution EIMS confir-'
mation. EPA Priority Pollutant Method 613 (USEPA 1984c) describes analysis of
2,3,7,8-tetrachlorodibenzodioxin (2,3,7,8-TCDD) in wastewater. The analysis
of all PCDDs and PCDFs in water and solids (e.g., fly ash and the XAD-2 traps
from a Method 5 train), have been described (Stanley et al. 1982). Surrogate
[e.g., (13C) 2,3,7,8-TCDD and (13C) octachlorodibenzo-p_-dioxin] must be added
to the resin cartridge before extraction to measure recoveries.
B-9
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4.3 Total Organic Chlorine (RC1)
4.3.1 Volatile RC1
Volatile total organic chlorine, collected on a VOST train as de-
scribed above, is analyzed by thermal desorption/GC/EIMS (Bergman-1984; Hansen
1984).
4.3.2 Semi volatile RC1
Semi volatile total organic chlorine (TOC1 or RC1) or total organic
halide (TOX) has been monitored using a very short column (2.5 cm long)
PGC/HECD method (Stanley et al. 1982; Haile et al. 1983; Nulton et al. 1984)
or extraction and GC/EIMS method (Beard and Schaum 1978). Both employ a •
Soxhlet extraction of the XAD-2 resin from the Modified Method 5 train (EPA
1977; Haile and Baladi 1977). It should be noted that these methods do not
in fact measure total chlorinated organics, but rather semi volatile, gas
chromatographable, chlorinated organics. The GC/HECD TOX measurement was
applied to background air particulate, stack gas paniculate, and ash samples
from a municipal incinerator and a cofired power plant (Haile et al. 1983a,
1983b; Nulton et al. 1984). Values ranged from 0.9 to 46,000 ng/g. In water
samples they ranged from 100 to 1,000 ng/L.
Two techniques for total chlorinated organics in water may be adapt-
able to RC1 in stack gas. Both involve concentration of the organic halides
on a sorbent trap and reduction to HC1 at 950°C. In one system, the HC1 gas
is detected by electrolytic conductivity (Model 610 Total Organic Halogen Ana-
lyzer, O.I. Corporation, College Station, Texas). In the other system, the
HC1 gas is detected by micro-coulometry (Model DX-20 Total Organic Halide Ana-
lyzer, Dohrmann Xertex, Santa Clara, California). Both techniques have the
advantage over previously used methods in that volatile, semi volatile, and
nonvolatile organic chlorides can be detected. The extract!on/GC methods de-
tect only the semivolatile organic chlorides. Neither technique has been
validated for use in stack sampling. The instruments have been designed for
water analysis applications. No instrumental modifications appear to be nec-
essary for stack gas application.
5.0 REFERENCES
American Society of Mechanical Engineers, "Test Protocol: Sampling for the
Determination of Chlorinated Organic Compounds in Stack Emissions" (1984).
Unpublished report from Environmental Standards Workshop.
American Society for Testing and Materials. "Standard Method for Polychlori-
nated Biphenyls (PCBs) in Water, ANSI/ASTM D 3534-80," in Annual Book of ASTM
Standards Part 31, Philadelphia, Pennsylvania (1981a), pp. 816-833.
American Society for Testing and Materials. "Standard Method for Analysis of
Environmental Materials for Polychlorinated Biphenyls, ANSI/ASTM D 3304-77,"
in Annual Book of ASTM Standards Part 31, Philadelphia, Pennsylvania (1981b),
pp. 877-885.
B-10
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American Society for Testing and Materials, "Standard Method for Analysis of
Polychlorinated Biphenyls in Mineral Insulating Oils by Gas Chromatography,"
ANSI/ASTM D 4059-83, in Annual Book of ASTM Standards. Part 40, Philadelphia,
Pennsylvania (1983), pp. 542-550.
Beard, J. H., III, and J. Schaum, "Sampling Methods and Analytical Procedures
Manual for PCB Disposal: Interim Report, Revision 0,". Office of Solid
Waste, U.S. Environmental Protection Agency, Washington, D.C.
(February 10, 1978).
Bellar, T. A., and J. J. Lichtenberg, "The Determination of Polychlorinated
Biphenyls in Transformer Fluid and Waste Oils," prepared for U.S. .Environmen-
tal Protection Agency, EPA-600/4-81-045 (1981).
Berg, E. L., "Handbook for Sampling and Sample Preservation of Water and Waste-
water," U.S. Environmental Protection Agency, Report No. EPA-600/4-82-029
(September 1982), 416 pp.
Bergman, F. J., "Volatile Organic Sampling Train (VOST) Development at MRI,"
presented at the 4th Annual National Symposium on Recent Advances in Pollut-
ant Monitoring of Ambient Air and Stationary Sources, EMSL, USEPA, Raleigh,
North Carolina, May 1984.
Dry Color Manufacturers Association, "An Analytical Procedure for the Deter-
mination of Polychlorinated Biphenyls in Dry Phthalocyanine Blue, Phthalo-
cyanine Green, and Diarylide Yellow Pigments," Arlington, Virginia (1982).
Dudenbostel, B. F. "Tentative Method of Test for Polychlorinated Biphenyls
in Water," Attachment B in "Sampling Methods and Analytical Procedures Manual
for PCB Disposal: Interim Report," J. H. Beard, III, and J. Schaum, Office
of Solid Waste, U.S. Environmental Protection Agency, Washington, DC
(February 10, 1978).
Erickson, M. D., "Analytical Method: The Analysis of By-Product Chlorinated
Biphenyls in Air, Revision 2," U.S. Environmental Protection Agency, Office of
Toxic Substances, Washington, D.C., EPA 560/5-85-011 (1984a).
Erickson, M. D., "Analytical Method: The Analysis of By-Product Chlorinated
Biphenyls in Water, Revision 2," U.S. Environmental Protection Agency, Office
of Toxic Substances, Washington, D.C., EPA 560/5-85-012 (1984b).
Erickson, M. D., "Analytical Method: The Analysis of By-Product Chlorinated
Biphenyls in Commercial Products and Product Wastes, Revision 2," U.S. Environ-
mental Protection Agency, Office of Toxic Substances, Washington, DC, EPA
560/5-85-010 (1984c).
Erickson, M. D., "Analytical Chemistry of PCBs," Boston: Butterworth Pub-
lishers (1985).
Erickson, M. D., and J. S. Stanley, "Methods of Analysis for By-Product PCBs—
Literature Review and Preliminary Recommendations," Interim Report No. 1, Of-
fice of Toxic Substances, U.S. Environmental Protection Agency, Washington,
D.C., EPA-560/5-82-005, October 1982, 135 pp.
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Erickson, M. D., J. S. Stanley, K. Turman, G. Radolovich, K. Bauer, J. Onstot,
D. Rose, and M. Wickham, "Analytical Methods for By-Product RGBs—Preliminary
Validation and Interim Methods," Interim Report No. 4, Office of Toxic Sub-
stances, U.S. Environmental Protection Agency, Washington, D.C., EPA-560/
5-82-006 (1982), 243 pp. [NTIS No. PB 83 127696].
Erickson, M. D., J. S. Stanley, J. K. Turman, and G. Radolovich, "Analytical
Method: The Analysis of Chlorinated Biphenyls in Liquids and Solids,"
U.S. Environmental Protection Agency, Office of Toxic Substances, Washington,
D.C., EPA-560/5-85-023 (February 1985a).
Erickson, M. D., J. S. Stanley, J. K. Turman, J. E. Going, D. P. Redford, and
D. T. Heggem, "Determination of By-Product PCBs in Commercial Products and
Wastes by High Resolution GC/EIMS," Environ. Sci. Techno!, (submitted) (1985b).
Haile, C. L. and E. Baladi, "Methods for Determining the Total Polychlorinated
Biphenyl Emissions from Incineration and Capacitor and Transformer Filling
Plants," U.S. Environmental Protection Agency, EPA-600/4-77-048, NTIS No. PB-
276 745/7G1 (November 1977), 90 pp.
Haile, C. L., and V. Lopez-Avila, "Development of Analytical Test Procedures
for the Measurement of Organic Priority Pollutants—Project Summary," U.S.
Environmental Protection Agency, Environmental Monitoring and Support Labora-
tory, Cincinnati, Ohio, EPA-600/S4-84-001; (Full Report available as NTIS No.
PB 84-129 048) (1984).
Haile, C., J. Stanley, R. M. Lucas, D. Melroy, C. Nulton and W. Yauger, Jr.,
"Comprehensive Assessment of Specific Compounds Present in Combustion
Processes. Vol. 1-Pilot Study of Combustion Emissions Variability," Office
of Toxic Substance, U.S. Environmental Protection Agency, Washington, D.C.,
EPA-560/5-83-004 (June 1983a).
Haile, C.L., J. S. Stanley, T. Walker, G. R. Cobb and B. A. Boomer, "Compre-
hensive Assessment of the Specific Compounds Present in Combustion Processes,
Volume 3, National Survey of Organic Emissions from Coal Fired Utility Boiler
Plants," Office of Pesticides and Toxic Substances, U.S. Environmental
Protection Agency, Washington, D.C., EPA-560/5-83-006 (1983b).
Hansen, E. M., "Protocol for the Collection and Analysis of Volatile POHCs
(Principal Organic Hazardous Constituents) Using VOST (Volatile Organic Sam-
pling Train), U.S. Environmental Protection Agency, EPA-600/8-84-007 (1984).
Midwest Research Institute, "Operating Procedure - Analysis of Samples for
PCBs by GC/ECD," EPA Contract No. 68-02-3938, MRI Project No. 8501-A6,
December 1985.
B-12
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Nulton, C. P., C. L. Haile and D. P. Redford, "Determination of Total Organic
Halogen in Environmental Extracts by Gas Chromatography with Hall Detection,"
Anal. Chem. 56:598-599 (1984).
Stanley, J., C. Haile, A. Small, and E. Olson, "Sampling and Analysis Proce-
dures for Assessing Organic Emissions from Stationary Combustion Sources for
Exposure Evaluation Division Studies. Methods Manual," U.S. Environmental
Protection Agency, EPA-560/5-82-014 (1982).
U.S. Environmental Protection Agency, "40 CFR Part 60 - Standards of Performance
for New Stationary Sources," Fed. Regist.. 42, 41754-41789 (August 18, 1977).
U.S. Environmental Protection Agency, "Continuous Air Pollution Source Moni-
toring Systems," EPA-625/6-79-005 (June 1979).
U.S. Environmental Protection Agency, "Samplers and Sampling Procedures for
Hazardous Waste Streams," Report No. EPA-600/2-80-018 (January 1980).
U.S. Environmental Protection Agency, "The Analysis of Polychlorinated Biphenyls
in Transformer Fluid and Waste Oils," Office of Research and Development, Envi-
ronmental Monitoring and Support Laboratory, Cincinnati, Ohio (February 1981).
U.S. Environmental Protection Agency, "Sampling and Analysis Methods for Haz- .
ardous Waste Combustion (First Edition)," prepared by A. D. Little, Inc.
(December 1983).
U.S. Environmental Protection Agency, "Test Methods for Evaluating Solid Waste-
Physical/Chemical Methods, SW-846, 2nd Edition, Revised," Office of Solid Waste
and Emergency Response, Washington, DC (April 1984a).
U.S. Environmental Protection Agency, "Organochlorine Pesticides and PCBs--
Method 608," Fed. Regist.. 49(209), 89-104 (October 26, 1984b).
U.S. Environmental Protection Agency, "2,3,7,8-Tetrachlorodibenzo-p_-dioxin -
Method 613," Fed. Regist.. 49, 136-141 (October 26, 1984c).
U.S. Environmental Protection Agency, "Base/Neutrals, Acids, and Pesticides--
Method 625," Fed. Regist.. 49, 153-174 (October 26, 1984d).
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APPENDIX C
OTS GUIDANCE ON FREQUENTLY ASKED QUESTIONS
June 1986
C-l
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PREFACE
This Appendix presents answers to frequently asked questions related
to permitting of incinerator facilities. The answers represent OTS guidance,
as of June 1986.
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Conditions Which May Be Included In Permits
Question 1: Is "blend-down" of PCB fluids authorized?
Answer: Blending and/or spiking is allowed only for the purpose of achiev-
ing a particular treatment concentration during process demonstra-
tions. However, during commercial operation no material which ex-
ceeds the concentration level demonstrated and authorized bv the
permit, may be diluted or blended.
Demonstration Test Protocol
Question 2: Are applicants required to test stack gases, ash (including bot-
tom ash), and scrubber water for PCBs, dioxins and furans during
incinerator demonstrations?
Answer: Demonstration tests of incinerators must include sampling of stack
gases and ash, including bottom ash, for PCBs, dioxins and furans.
EPA reserves the right to request similar testing of scrubber water,1
if available information and data indicate that such testing is
needed.
Question 3: What are the testing requirements for dioxins and furans during
process demonstrations?
Answer: For incineration, OTS requires stack testing for chlorinated dibenzo-
dioxins and chlorinated dibenzofurans. The analytical detection
limits should be no greater than 10 ng/resolvable isomer peak. Test-
ing should be conducted for individual 2,3,7,8 tetrachloro isomers
for both dibenzodioxins (2,3,7,8-TCDD) and dibenzofurans (2,3,7,8-
TCDF), total tetrachloro homologs of both dibenzodioxins (TCOD) and
dibenzofurans (TCDF) and total chlorinated dibenzodioxins (PCDD)
and chlorinated dibenzofurans (PCDF).
Question 4: How many successful test runs are required during an incineration
trial burn?
Answer: For thermal treatment processes, a minimum of three 4-hour test runs
are required. However, more than three test runs may be required
if the operator desires to demonstrate performance under more than
one operating condition. For example, the operator may desire to
demonstrate compliance under two distinct operating conditions as
follows: (a) multiple waste feed systems (e.g., solids and liquids);
and (b) liquid waste feed stream only at a higher feed rate than
when solids also are fed.
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Question 5: What are the minimum requirements for decontaminating an incin-
erator following a PCB burn?
Answer: As a minimum, the following decontamination steps should be taken:
(1) if applicable, the waste feed tank should be flushed with a
non-PCB fluid (e.g., diesel fuel) and the flushing liquid inciner-
ated; and (2) the incinerator should burn a volume of non-PCB fluid
equivalent to one-half the total volume of the incinerator combus-
tion chamber(s).
Question 6: What PCB standards are recommended for analytical testing?
Answer: The PCB standard chosen depends on the PCB composition in the sam-
ples and the purpose of the data.
a. If a waste feed sample is being assayed for initial PCB con-
centration, and if it consists of an identifiable Aroclor (or
other commercial mixture) or combination of Aroclors, the in-
strument may be calibrated using the appropriate Aroclor or
combination of Aroclors. The standard concentrations must be
within the working range of the instrument and must bracket
the concentration of the sample dilutions.
b. If the sample does not contain a PCB mixture similar to the
Aroclors or other commercial mixtures, the applicant must
demonstrate that all PCBs are being measured. The stack gas
and other effluent samples from an incinerator are in this
category. For the stack gas samples, the required limit of
detection to demonstrate 99.9999% destruction efficiency de-
pends on the feed concentration.
The PCB elution window is defined by the retention times on a
gas chromatograph between 2-chlorobiphenyl and decachlorobi-
phenyl. The calibration mixture is generally a solution con-
taining one each of the 10 PCB homologs (i.e., mono-, di-,
tri-, ... decachlorobiphenyl; e.g., the "DCMA" solution avail-
able from chromatography supply companies).
As with the Aroclor calibration, the standard concentrations
must be within the working range of the instrument and must
bracket the concentration of the samples.
Any peaks within the PCB retention window must be calculated
as PCBs unless the analyst can demonstrate through use of
blanks, confirmatory techniques, or other methods that the
peak(s) in question is not a PCB.
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Question 7:
Preparations for a Demonstration
Is an R&O program, or some other demonstration of the ability to
operate, required prior to scheduling an official test demonstra-
tion?
Answer: For previously unpermitted facilities OTS recommends either a pre-
liminary R&D program with PCBs or use of a PCB substitute for shake-
down of the unit. An R&D permit will not be issued for more than
three total batches. It should be stressed that once the applicant
proceeds with a demonstration test, if the demonstration schedule
is not adhered to, OTS will reserve the right to rescind the permit
while on-site or leave the demonstration before it is completed.
Another demonstration cannot be rescheduled for a minimum period of
three months.
Question 8: Will applicant preparedness be screened prior to demonstration?
Answer: OTS will work with applicants to ensure that the process is ready
prior to the demonstration. This may include evidence of success-
ful operations under similar conditions. For facilities where im-
mediate on-site analyses of product is required as part of the
demonstration, successful analysis of QA samples may be required
before the demonstration as a method of screening out unprepared
applicants.
Question 9:
Test Demonstrations
What criteria will be used to make an on-site determination to
discontinue a demonstration?
Answer: For incinerators, a maximum of two interruptions will be allowed
during a stack sampling run. Additional interruptions automatically
invalidate the run's results. Inability to complete an acceptable
run on the first day is cause for departure by EPA representatives.
If the demonstration schedule is not adhered to, OTS will reserve
the right to rescind the permit while on-site or leave the demon-
stration before it is completed. Another demonstration cannot be
rescheduled for a minimum period of three months.
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APPENDIX D
ADDRESSES FOR HEADQUARTERS AND REGIONAL OFFICES
D-l
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Addresses follow for U.S. EPA Headquarters and Regions. Headquarters will
supply the names of Regional PCB Coordinators upon request.
Headquarters
Director of the Office of Toxic Substances (TS-792)
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Region 1
(Connecticut, Maine, Massachusetts,
New Hampshire, Rhode Island, Vermont)
Regional Administrator
Environmental Protection Agency
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Region 2
(New Jersey, New York)
Regional Administrator
Environmental Protection Agency
26 Federal Plaza
New York, New York 10278
Region 3
(Delaware, District of Columbia,
Maryland, Pennsylvania, Virginia,
West Virginia)
Regional Administrator
Environmental Protection Agency
841 Chestnut Street
Philadelphia, Pennsylvania 19107
Region 4
(Alabama, Florida, Georgia, Kentucky,
Mississippi, North Carolina, South
Carolina, Tennessee)
Regional Administrator
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
D-2
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Region 5
(Illinois, Indiana, Michigan, Minnesota
Ohio, Wisconsin)
Regional Administrator
Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois 60604
Region 6
(Arkansas, Louisiana, New Mexico,
Oklahoma, Texas)
Regional Administrator
Environmental Protection Agency
First International Building
1201 Elm Street
Dallas, Texas 75270
Region 7
(Iowa, Kansas, Missouri, Nebraska)
Regional Administrator
Environmental Protection Agency
726 Minnesota Avenue
Kansas City, Kansas 66101
Region 8
(Colorado, Montana, North Dakota,
South Dakota, Utah, Wyoming)
Regional Administrator
Environmental Protection Agency
One Denver Place
999 18th Street, Suite 1300
Denver, Colorado 80202-2413
Region 9
(Arizona, California, Hawaii, Nevada)
Regional Administrator
Environmental Protection Agency
215 Fremont Street
San Francisco, California 94105
Region 10
(Alaska, Idaho, Oregon, Washington)
Regional Administrator
Environmental Protection Agency
1200 6th Avenue
Seattle, Washington 98101
D-3
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APPENDIX E
ANNOTATED BIBLIOGRAPHY
E-l
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D. G. Ackennan, L. L. Scinto, P. S. Bakshi, R. G. Oelumyea, R. J. Johnson,
G. Richard, and A. M. Takata, "Guidelines for the Disposal of PCBs and PCB
Items by Thermal Destruction," Report by TRW, Inc., Redondo Beach, CA, to
David C. Sanchez, USEPA, IERL, Research Triangle Park, NC, EPA-600/2-81-022,
February 1981, 317 pp.
Guidance - Thermal
This report is a resource and guidelines document intended to aid U.S.
Environmental Protection Agency Regional Offices in interpreting and applying
the PCB Disposal Regulations to thermal destruction of PCBs.
As background material, this document describes fundamental processes of
combustion, thermal destruction systems, sampling and analysis methodology,
and flame chemistry relative to PCB incineration. Administrative considera-
tions, including public involvement, are discussed. Detailed guidelines on
evaluation of Annex I incinerators, high efficiency boilers, and the several
stages of the approval process are presented and discussed, [authors' abstract]
D. G. Ackerman, L. L. Scinto, P. S. Bakshi, R. G. Delumyea, R. J. Johnson, G.
Richard, A. M. Takata, and E. M. Sworzyn, "Destruction and Disposal of PCBs
by Thermal and Non-Thermal Methods," Noyes Data Corporation, Park Ridge, NJ,
1983, 417 pp.
Guidance - Thermal and Non-Thermal
This is a verbatim combination of two EPA reports:
1. Sworzyn and Ackerman (1982) [EPA-600/2-82-069], and
2. Ackerman et al., (1981) [EPA-600/2-81-022].
American Society of Mechanical Engineers, "Test Protocol: Sampling for the
Determination of Chlorinated Organic Compounds in Stack Emissions," 1984,
24 pp. Unpublished report from Environmental Standards Workshop.
Sampling Methods
A sampling train using XAD-2 resin as the adsorbent is designed so that
only the total amount of each chlorinated organic compound in the stack gases
sampled may be determined; that is, sampling to determine the partitioning of
the chlorinated organic compounds between the solid and gaseous phases is not
attempted. All of the compounds of interest are assumed to be collected by
the resin. Since this assumption has not been validated in the presence of
HC1, high organic load, and other components present, appropriate quality
control steps are recommended until the method has been validated. The
sampling method is intended for use with analysis by gas chromatography/mass
spectroscopy.
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American Society of Mechanical Engineers, "Analytical Protocol: Analytical
Procedures to Assay Stack Effluent Samples and Residual Combustion Products
for Polychlorinated Dibenzo-p-dioxins (PCDD) and Polychlorinated Dibenzofurans
(PCDF)," 1984, 26 pp. Unpublished report from Environmental Standards Workshop.
Analytical Methods
The title methods, which are also applicable to residual combustion
products such as bottom and precipitator ash, entail addition of isotopically
labeled internal standards to all samples in known quantities, extraction of
the sample with appropriate organic solvents, preliminary fractionation and
cleanup of the extracts using a sequence of liquid chromatography columns,
and analysis of the extract for PCOD and PCOF using gas chromatography/mass
spectrometry. Performance criteria are specified which the analytical data
must satisfy for quality assurance purposes. The method is designed to indi-
cate the total concentration of each group of isomers, that is, the total of
each group of tetra-, penta-, hexa-, hepta-, and octachlorinated diebenzo-£-
dioxins and dibenzofurans. However, the method does allow quantisation of
2,3,7,8-tetrachlorodibenzo-£-dioxin (TCDD) and 2,3,7,8-tetrachlorodibenzofuran
(TCDF). The method is intended to be applicable for determining PCDD/PCDF in
combustion products at the parts-per-trillion to parts-per-million level.
[adapted from the introduction]
Anonymous, "Ocean Incineration of Hazardous Waste—Permit Writer's Manual,"
undated, 226 pp.
Guidance
The incineration of hazardous and other wastes by ocean-going vessels on
the high seas (hereafter "ocean incineration1) offers an attractive alternative
to land-based disposal, provided that adequate environmental and other safe-
guards are taken. National and international regulations and guidelines for
ocean incineration have been developed and are recognized by most major indus-
trialized countries. Both international and United States regulations require
a permit for ocean incineration. This Manual summarizes existing administra-
tive procedures of the U.S. Environmental Protection Agency (hereafter "EPA")
for issuance of such permits and provides technical guidance for evaluating
permit applications and for drafting permits. Such guidance relies heavily
on documents developed by EPA for permitting land-based hazardous waste incin-
eration facilities under its RCRA program, [author's introduction]
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J. H. Beard, III, and J. Schaum, "Sampling Methods and Analytical Procedures
Manual for PCB Disposal: Interim Report," Draft Report by Office of Solid
Waste, U.S. Environmental Protection Agency, Washington, DC, February 10, 1978.
GUI' dance/Samp 11 ng/Analyti cal Methods
This manual is a compendium of sampling methods and analytical procedures
which may be referred to and used by the PCB disposal facility owner/operators
to assist them with any sampling and analytical testing which may be required
under 40 CFR Part 761, Polychlorinated Biphenyls. However, due to the short
time period in which this manual was prepared, the U.S. Environmental Protec-
tion Agency is issuing this manual as an interim document. (The U.S. EPA be-
lieves that a sampling methods and analytical procedures manual has to be
available to PCB disposal facility owner/operators at the time the regulation
is finally promulgated to successfully implement the site approval process
under 40 CFR Part 761, Polychlorinated Biphenyls.) A final version of this
manual is expected to be issued, after undergoing further review within the
U.S. EPA, by early spring of 1978. [authors' preface]
Department of Health, Education, and Welfare, Public Health Service, Center
for Disease Control, National Institute for Occupational Safety and Health, .
"Criteria for a Recommended Standard...Occupational Exposure to Polychlorinated
Biphenyls (PCBs)," September 1977, 224 pp. (available from U.S. Government
Printing Office, Washington, DC).
Worker Safety and Health
The National Institute for Occupational Safety and Health (NIOSH) recom-
mends that employee exposure to polychlorinated biphenyls (PCBs) in the work-
place be controlled by adherence to the following sections. The standard is
designed to protect the health and provide for the safety of employees for up
to a 10-hour workday, 40-hour workweek, over a normal working lifetime. The
standard is measurable by techniques that are valid, reproducible, and avail-
able to industry and governmental agencies. Compliance with the standard
should substantially reduce any risk of reproductive or tumorigenic effects
of PCBs and prevent other adverse effects of exposure in the workplace. Em-
ployees should regard the recommended workplace environmental limit as the
upper boundary for exposure and make every effort to keep exposure as low as
possible.
Evidence indicates adverse reproductive and tumorigenic effects in exper-
imental animals exposed to certain commercial PCB preparations. Currently
available information is not adequate to demonstrate that other commercial
PCB preparations do not have these effects. Should sufficent information be-
come available to indicate that the standard offers greater or lesser protec-
tion from some chlorobi'phenyl isomers or commercial preparations than is needed,
it will be considered for revision, [from Recommendations section of report]
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R. L. Durfee, G. Contos, F. D. Whitmore, J. D. Barden, E. E. Hackman, III,
and R. A. Westln, "PCBs in the United States - Industrial Use and Environmental
Distributions," U.S. Environmental Protection Agency, Office of Toxic Sub-
stances, Washington, DC, Report No. EPA 560/676-005 [NTIS No. PB-252012], 1976,
488 pp.
Review of Disposal and Destruction Methods
This document presents the current state of knowledge about the produc-
tion, usage, and distribution of polychlorinated biphenyls (PCBs) in the
United States. The information presented is derived from detailed studies on
the production and first tier user industries, the past and present genera-
tion and disposition of PCB-containing wastes, environmental transport and
cumulative loads, potential alternatives to PCBs usage, inadvertent losses to
and potential formation in the environment, and current regulatory authorities
for PCBs control. These results indicated that, although PCBs content of in-
dustrial wastes can be reduced through various approaches (treatment, substi-
tution, etc.), there exists a potentially severe future hazard in the form of
large amounts of PCBs currently contained in land disposal sites. Further
definition of this and other aspects of the PCBs problem, and determination
of ways to minimize the hazard, are recommended, [author's abstract]
Environmental Protection Agency, "40 CFR Part 761, Polychlorinated Biphenyls
(PCBs) Manufacturing, Processing, Distribution in Commerce, and Use Prohibi-
tions," Federal Register. 44, 31514-31568, May 31, 1979.
TSCA Rules
This final rule implements provisions of the Toxic Substances Control
Act (TSCA) prohibiting the manufacture, processing, distribution in commerce,
and use of polychlorinated biphenyls (PCBs). Specifically, this rule:
(1) Prohibits all manufacturing of PCBs after July 2, 1979, unless spe-
cifically exempted by the Environmental Protection Agency (EPA);
(2) Prohibits the processing, distribution in commerce, and use of PCBs
except in a totally enclosed manner after July 2, 1979;
(3) Authorizes certain processing, distribution in commerce, and use of
PCBs in a non-totally enclosed manner (which would otherwise be subject to
the prohibition described above);
(4) Prohibits all processing and distribution in commerce of PCBs after
July 1, 1979, unless specifically exempted by EPA. [author's summary]
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Environmental Protection Agency, "Region V Strategy for Permitting PCB Dis-
posal Sites," Process Evaluation Unit, Technical, Permits and Compliance Sec-
tion, Waste Management Branch, Waste Management Division, Region V, U.S. En-
vironmental Protection Agency, Chicago, IL, undated, 68 pp.
Guidance
This document describes the permitting experiments by repeating the appli-
cable CRF Sections and providing examples of approval and consent letters.
Participant programs (public hearings) procedures and a checklist for evaluat-
ing applications are appended.
Environmental Protection Agency, "40 CFR Part 761, Polychlorinated Biphenyls
(PCBs) Manufacturing, Processing, Distribution in Commerce and Use Prohibitions;
Recodification," Federal Register. 47, 19526-19527, May 6, 1982.
TSCA Rules
This action recodifies 40 CFR Part 761 which deals with polychlorinated
biphenyls (PCBs). The recodification provides for a more orderly organization
of the material. No substantive changes are involved, [author's summary]
Environmental Protection Agency, "40 CFR Part 761—Polychlorinated Biphenyls
(PCBs)--Procedural Amendment of the Approval Authority for PCB Disposal Facili-
ties and Guidance for Obtaining Approval," Federal Register. 48, 13181-13186
(1983).
TSCA Rules
This procedural rule change gives the Assistant Administrator for Pesti-
cides and Toxic Substances (Assistant Administrator) authority to approve cer-
tain PCB disposal facilities which have previously been subject to approval
by each Regional Administrator. The Assistant Administrator will be the ap-
proval authority for facilities which are operated in more than one region.
The Regional Administrators will continue to have the authority to approve
all unique, site-specific facilities such as landfills, stationary incinera-
tors, and research and development into PCB disposal methods. This amendment
does not change any standards for approving PCB disposal activities and should
provide better responsiveness to the needs of the public and industry. In "
addition, EPA is providing supplemental guidance to assist persons applying
for approval of PCB disposal technologies that are alternatives to incinera-
tors and high efficiency boilers, [author's summary]
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M. p. Erickson, Analytical Chemistry of PCBs. Butterworth Publishers,
Stoneham, Massachusetts, 1985, 528 pp.
Sampling and Analytical Methods
The book defines and discusses sampling, extraction, cleanup, determina-
tion by chromatographic and nonchromatographic methods, data reduction, and
quality assurance as six discrete steps in the analysis of PCBs. The final
chapter provides a discussion on collaborative testing. The comprehensive
bibliography includes more than 1200 references. Five appendices detail PCB
nomenclature, physical properties, compositions of commercial mixtures, mass
spectra characteristics, and PGC/ECD chromatograms. The book includes exten-
sive critical reviews of the primary literature.
M. D. Erickson and J. S. Stanley, "Methods of Analysis for By-Product PCBs—
Literature Review and Preliminary Recommendations," Report by Midwest Research
Institute, Kansas City, MO, to David P. Redford, U.S. Environmental Protection
Agency, Office of Toxic Substances, Field Studies Branch, Washington, DC,
EPA-560/5-82-005, 1982, 135 pp.
Sampling and Analytical Methods
A review of the literature on polychlorinated biphenyl (PCB) analysis and
recommendations for methods to determine by-product PCBs in commercial prod-
ucts and other matrices are presented. This report was prepared to assist EPA
in formulating a rule regulating by-product PCBs. The published literature on
PCB analysis is critically reviewed. Several hundred references are cited in
a bibliography. The review is subdivided into extraction, cleanup, determina-
tion, data reduction, confirmation, screening, quality assurance, and by-
product analysis sections. The determination section includes TLC, HPLC, GC
(PGC and CGC), GC detectors (ECD, FID, HECD, EIMS, and other MS), and non-
chromatographic analytical methods (NMR, IR, electrochemistry, NAA, and RIA).
Techniques applicable to analysis of commercial products, air, and water for
by-product PCBs are discussed. The final section of this report presents a
recommended overall primary analytical scheme, [authors' abstract]
M. D. Erickson, J. S. Stanley, G. Radolovich, K. Turman, K. Bauer, J. Onstot,
D. Rose, and M. Wickham, "Analytical Methods for By-Product PCBs—Initial Vali-
dation and Interim Protocols," Report by Midwest Research Institute, Kansas City,
MO, to David P. Redford, U.S. Environmental Protection Agency, Office of Toxic
Substances, Field Studies Branch, Washington, DC, EPA-560/5-82-006, 1982, 243 pp.
Sampling and Analytical Methods
This document presents proposed analytical methods for analysis of by-
product PCBs in commercial products, product waste streams, wastewaters, and
air. The analytical method for commercial products and product waste streams
consists of a flexible approach for extraction and cleanup of particular ma-
trices. The 13C-labeled PCB surrogates are added as part of a strong quality
E-7
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assurance program to determine levels of recovery. The wastewater method Is
based on EPA Methods 608 and 625 with revisions to include use of the 13C-
labeled PCB surrogates. The air method is a revision of a proposed EPA method
for the collection and analysis of PCBs in air and flue gas emissions. Capil-
lary or packed column gas chromatography/electron impact ionizatipn mass spec-
trometry is proposed as the primary instrumental method. Response factors
and retention times of 77 PCB congeners relative to tetrachlorobiphenyl-d6
are presented in addition to statistical analysis to project validity of the
data and extrapolation of relative response factors to all 209 possible con-
geners. Preliminary studies using the 13C-labeled surrogates to validate
specific cleanup procedures and to analyze several commercial products and
product wastes indicate that the proposed analytical methods are both feasible
and practical, [authors' abstract]
L. Fradkin and S. Barisas, "Technologies for Treatment, Reuse, and Disposal
of Polychlorinated Biphenyl Wastes," Report by Argonne National Laboratory for
U.S. Department of Energy, ANL/EES-TM-168, 1982, 47 pp. (NTIS No. DE82013715).
Review of Disposal and Destruction Methods
Several technologies being developed by private industry and government .
to meet U.S. Environmental Protection Agency regulations for PCBs were assessed
to assist in the selection of the best process for a particular application.
Methods evaluated include a sodium naphtha!ide system, a sodium-amine method,
the NaPEG® process, plasma-arc technology, ultraviolet-ozone treatment,
catalyzed wet oxidation, hydrothermal dechlorination, light-activated reduc-
tion, and EPAC filters as well as the approved methods of land disposal and
incineration.
C. L. Haile and E. Baladi, "Methods for Determining the Polychlorinated Bi-
phenyl Emissions from Incineration and Capacitor and Transformer Filling
Plants," Report by Midwest Research Institute, Kansas City, MO, to Environ-
mental Monitoring and Support Laboratory, Office of Research and Development,
U.S. Environmental Protection Agency, Research Triangle Park, NC, EPA-600/4-
77-048, 1977, 90 pp. (NTIS No. PB-276 745/7G1).
Sampling and Analytical Methods
Described are methods to measure the polychldrinated biphenyl (PCB) emis-
sions from the stacks of municipal waste, industrial waste, and sewage sludge
incinerators and from capacitor and transformer filling plants. The PCB emis-
sions from the incineration plants are collected by impingement in water and
adsorption on Florisil. The samples are extracted with hexane, concentrated
through evaporation of the solvent, perchlorinated, and the polychlorinated
biphenyl content measured as the decachlorinated isomer using a gas chromato-
graph equipped with a flame ionization detector. The PCB emissions from the
capacitor and transformer filling plants are collected directly on Florisil,
extracted with hexane, and quantified against the appropriate Aroclor using a
gas chromatograph.
E-8
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The methods were developed from laboratory studies and field tested at
nine Incineration plants and two transformer filling plants.
[authors' abstract]
J. C. Harris, D. J. Larsen, C. E. Rechsteiner, and K. E. Thrun, "Sampling and
Analysis Methods for Hazardous Waste Incineration (First Edition)," Report by
Arthur D. Little, Inc., Cambridge, MA, to Larry D. Johnson, Technical Support
Staff, U.S. Environmental Protection Agency, IERL, Research Triangle Park, NC,
EPA Contract NO. 68-02-3111, Technical Directive No. 124, February 1982, 400 pp.
Guidance - RCRA
As part of the Resource Conservation and Recovery Act, the U.S. Environ-
mental Protection Agency has proposed regulations for the owners/operators of
facilities which treat hazardous wastes by incineration to ensure that these
incinerators are operated in an environmentally responsible manner. In sup-
port of these regulations, this document has been prepared as a reference
document which describes the sampling and analysis methodologies appropriate
to the measurement of the principal organic hazardous constituents in both
influent and effluent streams at these facilities. The sampling and analysis
methods for these principal organic hazardous constituents (POHCs) are de- •
scribed in the text. Also included are concise summary sheets for all of the
recommended methods, stating the method name and number, the types of samples
and specific analytes to which the method applies, a brief description of the
method, instrument and operating conditions, and a reference to a more de-
tailed description of the procedure. Technician-level protocols are thus in-
corporated by reference rather than reproduced in this document. In addition
to specific methods for the sampling and analysis activities at these facili-
ties, information concerning general strategies and guidelines for reporting
and documentation are discussed.
Appendix A provides basic information (structure, CAS Registry Number,
molecular weight, melting point, boiling point, and heat of combustion, when
available) for all compounds listed in Appendix VIII of the May 20, 1981,
Federal Register. Additional appendices list specific Appendix VIII compounds
with the appropriate sampling and analysis methods. Mass spectral analytical
Ions for compounds analyzed by GC/MS are tabulated in Appendix E. [authors'
abstract] [revision of Rechsteiner et al.]
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T. J. Hennings, P. A. Painter, L. L. Scinto, and A. M. Takata, "Preliminary
Operations Plan and Guidelines for the At-sea Incineration of Liquid PCB
Wastes," Report by TRW, Inc., Redondo Beach, California, for the U.S. Environ-
mental Protection Agency, Office of Research and Development, Industrial
Environmental Research Laboratory, Research Triangle Park, EPA-600/2-82-068,
1982, 121 pp. (NTIS No. PB83-181834).
Guidance
The report is a preliminary operations plan and guidelines report for
the disposal of PCB wastes by at-sea incineration. An inventory of government-
owned PCB wastes suitable for at-sea incineration and operating plans and a
schedule for an EPA-coordinated disposal project were developed. Of the ap-
proximately 1.3 million gal. of government-owned liquid PCB wastes identified,
425,000 gal. were considered to be immediately available for at-sea incinera-
tion. The operations plan addresses both land-based and at-sea operations.
Land-based operations include waste collection and preparation, 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, incinera-
tion procedures, and cargo tank decontamination are addressed for at-sea
operations. The preliminary schedule for the disposal project shows 10 months
from the decision to proceed with the project to completion of disposal opera-.
tions. [adapted from authors' project summary]
R. G. Mclnnes, "Technical Assistance in Support of Permitting Activities for
the Thermal Destruction of PCBs," USEPA, Office of Research and Development,
IERL, Research Triangle Park, NC, EPA 600/2-81-240, 1982, 70 pp. (NTIS No.
PB82 231 325).
Guidance - Thermal
This report describes phased efforts to identify, evaluate, and provide
technical permitting assistance to utility boiler owners considering thermally
destroying PCB-contaminated mineral oil. Identification initially concentrated
on identifying ideal PCB destruction sites using size, age, location, and fuel
use criteria to evaluate available boilers. This effort then extended to di-
rectly contacting USEPA Regional Offices to identify utility boiler owners who
had expressed an interest in the PCB disposal program. Regular bimonthly
contacts were Initiated with the Regional Offices and the status of all re-
gional PCB activities was tracked. This contact produced three potential PCB
burn sites operated by: (1) Consolidated Edison of New York, (2) Northeast
Utilities, and (3) Pennsylvania Power and Light. Test plans were received
from the first two and were reviewed and found acceptable; these facilities,
however, subsequently withdrew their involvement with the PCB destruction
verification burn program due to local community opposition. The Pennsylvania
Power and Light Company site remains under active consideration. By the end
of the technical performance period of this work assignment, a candidate site
had not been identified or approved for testing. Appendices to this report
detail the utility boiler site selection methodology, the status of PCB
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activities in EPA Regional Offices as of May 1, 1981, and the test plan
evaluations for the Consolidated Edison and Northeast Utilities facilities.
The project also required that state and local governments be provided
information needed to aid permitting of a PCB verification burn. Under this
phase of the project a PCB "white paper" was prepared which summarized back-
ground technical information used in writing the PCB regulation (40 CFR 761).
A second paper was prepared summarizing comments delivered at a public meeting
entitled "What Should We Be Doing About PCBs?" Both of these papers are pro-
vided as appendices to the report, [author's project summary]
R. G. Mclnnes and R. J. Johnson, "Provision of Technical Assistance to Support
Regional Office Implementation of the PCB Regulations—East and West," Draft
Project Summary Report by GCA Corporation, New Bedford, MA, and TRW, Inc.,
Redondo Beach, CA, on EPA Contract No. 68-02-3168, Work Assignment No. 45,
and Contract No. 68-02-3174, Work Assignment No. 68, for David C. Sanchez,
USEPA, Office of Research and Development, IERL, Research Triangle Park, NC,
1982, 186 pp.
Guidance - Thermal
To assist EPA headquarters, laboratory and regional office personnel with
the implementation of the PCB regulations, GCA/Technology Division and TRW,
Inc., Environmental Division, were retained. GCA was assigned to provide tech-
nical assistance to the Eastern EPA Regions (I-V), and TRW performed the iden-
tical function in the West (Regions VI-X). These contracts had a twofold direc-
tion: to establish a regular bimonthly liaison with the EPA regional offices
and to provide technical and coordinative assistance to these offices on an
as-needed basis. The bimonthly contact resulted in a regular bimonthly news-
letter which was mailed to the EPA personnel in all 10 regions who are directly
involved with the implementation of the PCB regulations. The technical assis-
tance effort produced a series of individual facility evaluations as well as
a separate study regarding alternative definitions of PCB solid/ liquid wastes.
This project report documents the work efforts conducted by GCA/Technology
Division and TRW Environmental Division in providing technical assistance to
support regional office implementation of the PCB regulations. The salient
points of the two project tasks are discussed in the body of the report and a
copy of the latest bimonthly report and all facility evaluations is included
in the appendices. This report covers the period of April 28 to December 15,
1981, and work was completed as of December 31, 1981. [from authors' introduc-
tion]
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Navy, "PCB Compliance, Assessment, and Spill Control Guide," Naval Energy and
Environmental Support Activity, Fort Hueneme, CA, Report No. NEESA-20.2-028A
[NTIS No. AD-A121 329/7] August 1982, 105 pp.
Guidance
Polychlorinated biphenyls (PCB) are toxic belonging to the well-known
chlorinated hydrocarbon family. Because of their low flammability and high
stability, PCBs have been extensively used as coolants and insulators in elec-
trical equipment. However, due to the known environmental and health problems
occurring from improper use and handling, the Environmental Protection Agency
has promulgated stringent regulatory controls concerning use, storage, trans-
port and disposal of PCBs leading to a total ban on use of PCBs. This guide
was designed to assist Navy activities in complying with these complex and
intricate regulations, [author's abstract]
C. Rechsteiner, J. C. Harris, K. E. Thrun, D. J. Sorlin, and V. Grady,
"Sampling and Analysis Methods for Hazardous Waste Incineration," Draft
Report by Arthur D. Little, Inc., Cambridge, MA, to Larry D. Johnson, Process
Measurements Branch, U.S. Environmental Protection Agency, IERL, Research
Triangle Park, NC, EPA Contract No. 68-02-3111, Technical Directive No. 124, '
July 1981, 324 pp.
Guidance - RCRA
As part of the Resource Conservation and Recovery Act, the U.S. Environ-
mental Protection Agency has proposed regulations for the owners/operators of
facilities which treat hazardous wastes by incineration to ensure that these
incinerators are operated in an environmentally responsible manner. In sup-
port of these regulations, this document has been prepared as a reference
document which describes the sampling and analysis methodologies appropriate
to the measurement of the priority organic hazardous constituents in influent
and effluent streams at these facilities. In addition to specific methods for
the sampling and analysis activities at these facilities, strategic informa-
tion concerning such activities and guidelines for reporting and documentation
are discussed, [authors' summary] [Revised to Harris et al.]
J. Stanley, C. Haile, A. Small, and E. Olson, "Sampling and Analysis Procedures
for Assessing Organic Emissions from Stationary Combustion Sources for EED
Studies. Methods Manual," Report by Midwest Research Insitute, Kansas City,
MO, to Exposure Evaluation Division, Office of Pesticides and Toxic Substances,
Washington, DC, EPA-560/5-82-014, 1981, 34 pp.
Sampling and Analytical Methods
The sampling and analysis methods described in this report were specific-
ally designed for use in an ongoing nationwide survey of emissions of organic
pollutants from stationary combustion sources. The primary focus of this
E-12
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survey is on polynuclear aromatic hydrocarbons (PAHs) and polychlorinated
aromatic hydrocarbons including polychlorinated biphenyls (PCBs), polychlori-
nated dibenzo-p_-dioxins (PCDDs), and polychlorinated dibenzofurans (PCDFs).
To date, these procedures have been used by Midwest Research Institute (MRI)
to survey emissions from coal-fired utility boilers, a co-fired (coal +
refuse-derived fuel) utility boiler, and a municipal refuse incinerator.
This document was prepared by MRI as a guideline for laboratories who may
participate in this study, and for other researchers who wish to use these
methods, [authors' abstract]
G. Vogel, K. Brooks, I. Frankel, S. Haus, and W. Jacobsen, "Guidance Manual
for Evaluating Permit Applications for the Operation of Incinerator Units,"
Report by The Mitre Corporation, McLean, VA, to U.S. Environmental Protection
Agency, Contract No. 68-01-6092, December 31, 1980, 221 pp.
Guidance - RCRA
An EPA or state permit writer is offered guidance for evaluating permit
applications submitted by owners or operators of incinerator facilities as
required under mandate of the Resource Conservation and Recovery Act of 1976.
The subject areas requiring evaluation are identified and information that
should be contained in an application to ensure a thorough evaluation is
listed. Data typical of current, acceptable incineration practices and ex-
amples of computations are offered to assist the permit writer.
[authors' abstract]
J. V. Zbozinek, T. J. Chang, J. R. Marsh, P. K. McCormick, and J. E. McCourt,
"PCB Disposal Manual," Report by SCS Engineers, Inc., Long Beach, California,
for the Electric Power Research Institute, Palo Alto, California, CS-4098,
1985.
Review of Disposal and Destruction Methods
The objective of this report is to present an update of the information
presented in FP-1207, Volume 1, published in 1979. There have been signifi-
cant changes both to the regulations and the technology in the intervening
period. This report emphasizes those areas which were subject to the greatest
change, as well as new areas that were not considered when the previous volume
was published.' Among the various areas of PCB disposal which are addressed
in this report are PCB materials and their distribution in the utility indus-
try, regulations, thermal destruction technology, land disposal, treatment
technologies, disposal capacity and demand, and a PCB management program. It
is intended that this manual provide sufficient detail to be useful in utility
decision processes, even with the realization that regulations are once again
in a state of change, as are the available processes and disposal capacities.
[authors' abstract]
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