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.
                                     21

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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:
                                     27

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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

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                                                      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

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                                                      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


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                 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.
                                     B-7

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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.
                                     B-8

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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.


                                     B-ll

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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.
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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).
                                     B-13

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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.
                                     C-2

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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.
                                     C-4

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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.
                                     C-5

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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.
                                     E-2

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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]
                                     E-3

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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


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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
                                     E-10

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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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