UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
MAY 2 8 1991
MEMORANDUM
SUBJECT: Rel
FROM:
TO:
f Pilot Study
Assistant
Office of
inistrator
esticides am
n R. Clay
sistant Adm
Office of Sol
bstances (TS-788)
6
or
and Emergency Response (OS-100)
Regional Administrators
The Office of Pesticides and Toxic Substances (OPTS) and the
Office of Solid Waste and Emergency Response (OSWER) have
released the "Fluff Pilot Study" (attached). The I-i_ot Study was
initiated in 1988 to determine the extent of PCB, lead and
cadmium contamination in appliance and auto shredder residue,
commonly known as "fluff."
The results of the pilot study indicate that shredders may
generate waste contaminated at levels above regulatory concern.
However, differences in raw materials, shredding operations, and
the presence of conflicting data suggest that not all shredders
are generators of regulated waste materials. Information
obtained to date indicates that the levels of constituents of
concern associated with the generation of fluff are not uniform.
The potential risk depends on the constituent makeup of the fluff
and the characteristics of the sites at which the fluff is
generated or disposed.
EPA supports metal recycling activities when conducted in an
environmentally sound manner. As such, both OPTS and OSWER have
identified a need to evaluate the current disposal requirements
as they relate to fluff. OPTS will be publishing an Advanced
Notice of Proposed Rulemaking to solicit public comment on an
amendment to the PCB regulations, which could authorize
alternative methods of disposal for fluff. The fluff issue may
also be discussed during RCRA reauthorization.
-------
In the interim, because shredding operations that are well
managed and conducted in an environmentally sound manner provide
valuable environmental benefits, OPTS and OSWER are recommending
that enforcement*be focused on shredding facilities which pose
significant environmental problems. Such operations could
•include ir.prcpcr use of fluff as fill material in wetlands or
other environmentally sensitive areas, or in residential
settings. Other criteria to evaluate sites that generate fluff
include location (e.g., sites in 100-year floodplains, near
surface water or surface water discharge, over a drinking water
aquifer or wellhead protection areas); and operation (e.g., the
absence of activities designed to address blowing fluff piles,
the absence of worker protection measures, the absence of run-
on/run-off controls, and leachate generation).
This list is intended only as a guide to indicate when
shredding operations and fluff disposal may warrant enforcement.
It is not an exhaustive list of situations where enforcement may
be appropriate. Further guidance to assist the regions in
determining where to focus enforcement will be developed by.the
Office of Compliance Monitoring and the Office of Solid Haste and
Emergency Response.
Attachment
-------
PROJECT SUMMARY
PCB, Lead, and Cadmium Levels in Shredder
Waste Materials: A Pilot Study
Authors and Research Team
Principal authors included Dan Reinftan. John Scalera, Brad Schultz. Cindy Siroup. and AY
Breen of ihe Exposure Evaluation Division, Office of Toxic Substances. Ttiis project
summary was abstracted from a report on the Fluff Pilot Study written hy Wesiat.
«
Field work was conducted hy Westat. Midwest Research Institute, and Battelle Columbus
Laboratories. Chemical analyses were performed at Midwest Research Imtiiuie. EPA '.v
National Enforcement Investigation Center, and EPA's Environmental Systems Laboratory
1/1 Las Vegas. Nevada.
EPA's Office of Solid Waste. Characterization and Assessment Division co-sponsored ihe
ejfon and provided deiiim. sampling, and analysis consultation for lead and cadmium
portion of the pilot study. Alexander McBride was the principal contributor.
Summary
Prior to this pilol study, ihe United Slates
Environmental Protection Agency (EPA)
received information from stale and local
environmental agencies which indicated the
shredding of automobiles and other pro-
duels Tor metal recycling may produce
waste-materials contaminated with poly-
chlorinated hiphcnyls (PCBs). lead, and
cadmium. The inlormulion available was
insufficient to establish the sources and
extent of the contamination or what regu-
latory action, if any. Mould he approriate.
Consequently. EPA's Olfkc of Toxic Sub-
stances and Office of Solid Waste planned
aad conducted this Mudy to gain more
knowledge about .«hrci(
-------
The results of this study allow EPA to
make a preliminary assessment of
potential PCB. lead, and cadmium
contamination and to provide* valu-
able information Tor the design of
future studies. It is important to
acknowledge thai this was a pilot
study and the study results may not
necessarily be representative of the
shredder recycling industry as a whole.
Only seven shredder sites were
included in the study, and some
numerical estimates are based on a
limited number of samples. For
practical reasons, some restrictions
were imposed on the random selec-
tion of sites, although EPA has no
reason to believe that bias was
introduced by the sampling plan.
INTRODUCTION
The United Stales Metal Shredding
Industry generates approximately 12
to 14 million tons of steel scrap for
recycling each year. About W3- of
the steel output is from the 8 to 10
million cars, trucks, and vans which
are disposed of every year. The
remaining steel salvage results from
the recycling of several million
discarded household appliances and a
variety of other industrial.
commercial, and household scrap.
EPA recognizes the major environ-
mental benefits of recycling as a
national environmental policy and
wrongly fosters and supports all
recycling efforts which are environ-
mentally sound. Metal recycling
results in a two-thirds to three-
quarters reduction in the volume of
space required in landfills to deposit
waste automobiles awl appliances, a
substantial reduction in energy
required to recycle metal instead of
producing it from raw ores, and a
reduction in air pollution associated
with metal production. The commer-
cial value of recycled metal, over S1.S
billion per year, is considerable.
In addition to recycled metal, shred-
der operations produce 3 million
tons of non-metallic waste material
each year. This non-metallic waste is
usually referred to as "fluff" or "auto
shredder residue* (ASR). The shred-
ding of a car. for example, produces
about 5(X) pounds of fluff on average.
Ruff is typically composed of a
variety of materials, including
plastics, rubber, foam, fabric, wood.
insulation, glass, road dirt, and small
metal fragments. Little, if any. of
this material is presently recycled.
Most fluff is disposed of in municipal
landfills.
Preliminary and anecdotal informa-
tion received by the EPA before this
study indicated thai PCBs. lead, and
cadmium arc dispersed during the
shredding of various scrap materials.
resulting in the contamination of
fluff by these substances. Some of
the reported contamination levels
exceeded the Federal regulatory
levels set under the Toxic Substances
Control Act (TSCA) and the
Resource Conservation and Recovery
Act (RCRA). Shredder wastes which
contain these contaminants in con-
centrations exceeding prescribed
TSCA and RCRA regulatory levels
must, under Federal regulations, be
managed in approved disposal sites.
This would result in considerably
greater cost to the rccycler (shredder
operator). In addition, the TSCA
landfill capacity would quickly be
filled il j large proportion of
shredder llulf proved to be PC&-
contaminated. Similar capacity
concerns exist lor RCRA disposal'
facilities.
Since PCBs were commonly used as '
dielectric fluids in electrical
transformers and capacitors, many
scrap metal shredder operators
assumed that capacitors in moiori/cd
consumer appliances (called 'white
goods") were the primary source of
PCB contamination in shredder Huff.
These operators, therefore, stopped
accepting appliances for recycling.
This decision not to accept and pro-
cess "while goods* created a solid
waste disposal predicament in several
slates when refrigerators, stoves, wash-
ing machines, and other appliances
frequently were abandoned and began
accumulating along streets or in
vacant lots.
Due to the lack of general knowledge
about shredder operations and conclu-
sive information regarding contami-
nation sources, the EPA's Office of
Toxic Substances (OTS) and Office of
Solid Waste (OSW) undertook this
pilot study. Of specific interest was
the examination of PCB. lead, and
cadmium levels in shredder output
streams; the teachability ol these sub-
stances: and the identification of con-
tamination sources, if possible. The
results of the pilot study will be used
to evaluate the need lor additional
Agency action and 10 design future
studies if they are required.
OBJECTIVE
The specific objectives ol the study
were:
• To estimate ranees ol PCB. lead.
and cadmium levels in Hull, the
metallic outputs, and in soil
collected from where llulf Is
stored by the shredder:
• To determine how rcadilv PCBs.
lead, and cadmium will leach itr
dissolve oui bv percolation) Iroir
fluff to pose a poicnu.il threat
to human hcalih and the environ
ment:
-------
• To examine the relationship be-
tween shredder input materials
and levels or PCBs. lead, and
cadmium in the resulting fluff
output; and
• To develop and lest procedures
for field sampling, sample prep-
aration, and laboratory analysis
which yield more precise and
accurate measurement of PCB.
lead, and cadmium levels in
shredder output materials.
PROJECT
METHODS ANI) DESIGN
Site Selection and Description
Based on statistical and cost con-
siderations. EPA decided thai seven
shredder sites from geographically
diverse regions of the continental
United States would he included in
the Fluff Pilot Study. Because of the
lime and expense required to relocate
a sampling crew in the event that a
shredder operator would not or could
not participate in the program (e.g.
due to breakdown), it was essential
that EPA prearrange conveniently
located alternate shredder sites prior
to the commencement of sampling.
To implement random procedures for
site selection, to the extent possible.
and to have substitute sites readily
available. EPA began the process of
selecting the seven sites to be
included in the pilot study by first
identifying clusters of shredder sites
throughout the country. Each of the
seven geographic clusters chosen for
the pilot study consisted of three or
more sites and all sites, within each
cluster, were within about 100 miles
of one another. Each cluster of sites
was located in a separate EPA region
(there arc ten EPA regions). From
within each geographic cluster, one
primary and two alternate sues were
randomly selected.
EPA sent advance letters to the
owner/operators of selected shredder
sites, asking for their cooperation
with the Pilot Study, promising them
anonymity if they participated. In
addition, the metal recycling trade
association, the Institute of Scrap
Recycling Industries (ISRI). provided
the sampling teams with letters
endorsing the study and soliciting
cooperation from its members. (All
shredder sites visited were ISRI
members.) The field sampling team
gave these letters to site owners/
operators at the beginning of sam-
pling visits.
Four of the seven primary sites parti-
cipated in the study, while three sites
were unable or unwilling to take part
and were replaced with alternate sites
from the same geographic cluster as
the primary site. While the site se-
lection process imposed some restric-
tion on the random selection of
shredder sites. EPA has no indication
that bias was introduced by this sam-
pling plan.
Shredder Operation
Shredder operations invariably have
several important features in
common (see Figures 1 and 2).
Automobiles, appliances, and other
objects are fed to a hammermill
which shreds them into Fist-sized
pieces. Powerful magnets and
conveyor belts then separate the
ferrous (iron-containing) metals from
non-ferrous components. Next, using
either air cyriimc or water 'flotation* •
separation, metallic components are •
segregated from the. generally less
dense, (lull. In this way. all shredder ,
output is divided into piles of ferrous
metal, non-ferrous metal, and fluff.
EPA developed standard procedures
for collecting specified quantities of
shredder output (fluff* ferrous, and
non-ferrous metal, etc.) before the
start of sampling.
Input Kuns
One of the objectives of the pilot
study was to investigate the relation-
ships between the input materials
being shredded and the concentra-
tions of PCBs. lead, and cadmium
measured in the shredder output
streams. In order to investigate this
relationship, shredder operators
segregated their input materials into
three groups and made separate 'runs'
of the shredder, by material upe. lor
the sampling team. Each "run" con-
sisted of the shredding of a predeter-
mined quantity of scrap material from
one of three categories of input.
The three categories of input material
were:
• Automobiles, including trucks and
vans;
• White Gixxls. which included
refrigerators, washing machines.
and other similar appliances; and
• Mixed Inputs, which included a
variety of mixed scrap materials.
such as those which come Irom
demolition sites and may have
contained parts or all of some
automobiles or white goods.
What consumed a 'run* depended on
the category ol input maienul being
processed. For example, the shred-
ding of two cars was delmeil as one
"run" for automobiles, whereas eicht
home appliances equaled .1 "run* lor
white goods. One 5-i!.illi'n bucket
(sample) ol Hull" »;is norm.illv col-
lected alter each "run" usmu the
sample collection pmiiH.nl developed
for the studv (described N.l<«* i
-------
•r •»«•»• 2
oer SM«cooiif6 srsTcn
Figure 2
Schematic illustration of the Shredding Process
•ir eytlor*
«tMl
-------
Sample Collection
Because of the heterogeneous nature
of ihc (luff ouipul stream, consider-
able effort was devoted in this study
lit the development of methods for
sampling fluff. Standard procedures
Tor collecting specified quantities of
fluff and other shredder output
(ferrous or non-ferrous metal, etc)
were carefully developed prior to the
commencement of sampling. For
fresh duff sampling, a front-end
loader caught the fluff ouipul stream
as it tumbled off the end of a
conveyor belt or dropped from an air
cyclone funnel. The sampling team
spread this fluff over a tarp to create
a r deep 9* x 9' square pile. This pile
was subdivided into a nine square grid
of 3' by .V squares. A five gallon
sample of the fluff was collected by
compositing a roughly equal poriion
of fluff from near the center of each
of the nine squares.
F developed other sampling proce-
dures for piles of stored fluff, fluff
that spilled off conveyor bells (spill-
over), and soil from the vicinity of
fluff piles. Descriptions of all
sampling protocols are detailed in the
full report.
The following types of samples were
collected at each shredder site:
• Fresh fluff One sample of "fresh"
fluff, fluff as it was produced by
•"" the shredder, was collected from
each run of the shredder. De-
pending on what type(s) of input
material were processed, there
were generally between eight and
twelve runs at each site.
• Ferrous metals Two ferrous meiai
output samples were collected
from each site, one Irom each of
two input runs.
• Non-ferrous metals Two non-
ferrous metal samples were col-
lected Irom each site, one from
each of two input runs.
• Spillover Ruff which fell or blew
off conveyor belts during process-
ing and accumulated on the
ground around shredding machin-
ery and conveyor belts was sam-
pled. Two samples of this spill-
over fluff were collected from
each site.
• Stored Fluff Five of the seven
shredder sites visited had piles of
stored fluff that had accumulated
during normal operation prior to
the arrival of ihe sampling team.
At each of these sites, the sam-
pling team collected four samples
of stored fluff.
• Soil The sampling team collected
four soil samples from each site
from locations where fluff typi-
cally accumulated. These samples
were used to investigate the po-
tential for migration of contami-
nants from fluff to soil. These
samples were also taken from be-
neath stored fluff piles, if they
were present.
Sample Analyses
Sample Preparation
Before analysis, each five gallon
(.sample) bucket of fluff was divided
into approximately eight to ten 450
to 5(K) gram "representative sub-
samples" fur chemical analysis.
These subsamptes were carefully
constructed such that every
suhsamplc contained all the basic
physical components of fluff (glass.
foam, plastics, fabrics, dirt, etc) in
proportions nearly identical to those
found in the original sample. The
goal was to create suhsamplcs which.
in their nhvsical composition, were
very similar to the other suhsamplcs
(from the same bucket) and to the
original sample. The actual steps
involved in the creation of the
"representative suhsamplcs* arc
described in the full report.
Each 450 to SOU gram subsamplc was
placed into a I-gallon large mouth
glass jar for storage. Depending upon
the quantity of sample material
required for chemical extraction/
analysis, the suhsamplcs were split
further, sieved and/or milled. Addi-
tional details describing sample
preparation for each type of chemical
extraction/analysis can be found in the
full report.
Development of PCB (extraction
Procedures
Solvent Extraction
Existing laboratory procedures for the
preparation and chemical analysis ol
fluff samples for PCBs were judged to
be deficient. The conventional pro-
cedure for measuring PCB concentra-
tions prescribes that a relatively small
quantity of material (ofien 20 grams
or less) be subjected to solvent ex-
traction before instrument analysis.
Using such a small quantity of a
heterogeneous material (such us fluff)
has historically resulted in high
measurement variability between
subsamples from the same sample, as
reported by many state and indepen-
dent laboratories. In practical terms.
this means that the actual estimate of
the PCB concentration for any sample
depends to a great extent on the
specific aliquol of flulf used for
extraction and analysis. Diilerent
portions of fluff from the same sam-
ple often produce \cr> dillerent
results which make overall estimates
1 for each sample highly variable and
potentially inaccurate.
-------
Two methods were developed in the
pilot program to reduce this source of
sampling error: (I) the technique for
creating "Representative Subsamplcs"
from the initial 5-gallon buckets, and
(2) the quantity cif the suhsample
material subjected to chemical extrac-
tion/analysis was greatly increased.
Two innovative procedures Tor
increasing the quantity of material
subjected to hcxane/acctonc extraction
were developed, tested, and compared
for the Pilot Study. These techniques
were (I) a tumbler (slurry) extraction
using an agitation apparatus, and (2)
a large-volume Soxhlet (500 cc Soxh-
ict) capable of extracting PCBs from
up to 100 grams of fluff.
A systematic comparison of measure-
ments from matched subsamples ana-
lyzed by the two procedures was con-
ducted. On the basis of this com-
parbon. the tumbler (slurry) proce-
dure was selected on the basis of its
overall superior' }nro he used as the
standard extraction method for the
remainder of the PCB analyses. This
new technique allowed extraction of
fluff samples weighing between 450
to 500 grams, as opposed to 20 gram
samples used in the conventional
soxhlet. or the 100 gram samples used
with the large Soxhlet.
Water Extraction (PCB teachability)
In order to evaluate the teachability
ofl'CBs from fluff using water as the
solvent, two additional extraction
techniques were developed. One
technique for room temperature water
used a slurry extraction apparatus and
the other technique for "hot" water
extraction used a Soxhlet extractor.
The fluff samples used in the "hot"
water extraction were milled to 9.5
mm. A portion of the non-millable
fraction of the Huff was included in
each sample, the quantity added being
based upon the appropriate weight
fraction of non-millable versus
millable portions (from the original
sample).
For the room temperature extraction
(22°C). 80 grams of Huff (particle size
£ 9.5 mm) was placed with 2 liters
of high purity water into the slurry
extraction apparatus (described
previously) and tumbled for eight
continuous days. For the hot water
extraction (65°C). a similar 80 gram
sample was placed in a large Soxhlet
extractor and extracted over a period
of eight days with high purity water
at a temperature of 65°C Alter
eight days, the extract from each of
the two procedures was filtered and
analyzed for PCBs.
Chemical Analyses
All chemical analyses were based on
EPA methodology. The inorganic
analyses were done using Methods
213.1 or 7131 for Cd and 239.1 or
7421 for Ph.
Unless otherwise stated. PCB
analyses were performed using a
modified gas chromatography/
electron capture detector (GC/ECD)
EPA Method 8080.
The modified analytical method as
well as all other analytical methods
used in the Pilot Study can be found
in the Appendix section of the full
report. Summaries are provided
here.
• Total PCB Concentration The
total concentration of PCBs in
each of the subsamptes analyzed
was determined by extraction,
using a hcxancfacctcmc solution..
then analysis using a gas chroma- •
tography/clcctron capture
detection (GC/ECD) method.
The sample particle si7.es were
not reduced for any of the
tumbler (slurry) extractions.
however the samples undergoing
Soxhlct extraction were milled to
< 9.5 mm.
PCB Concentrations in Individual
Ruff Components Flulf subsam-
ples were divided into their physi-
cal components (glass, plastics.
fabrics, etc.). Each component was
individually analyxcd for total PCB
concentration by EPA's National
Enforcement Investigation Center
(NEIC) in Denver. Colorado. The
analytical method employed was
EPA Method 600 The Determi-
nation of Polychlorinatcd
Biphenyls in Oil. Soil and Surface
Samples". This analysis was
conducted to determine whether
PCB contamination was more
closely associated with specific
components of fluff.
PCB Leachahilitv EPA measured
the extent to which PCBs leach
from fluff, using water as a solvent.
to estimate how likely they arc 10
be released from shredder wastes
into the environment. To repre-
sent a "worst case" scenario. EPA
performed a hot water extraction
of size-reduced fluff in a Soxhlet
extractor. Samples were also
subjected to a nxrni-icmpcrature
water extraction, to represent
something closer to a "real world*
scenario. These samples were
extracted using a slurry extraction
apparatus. The extracts from both
techniques were analyzed using the
GC/ECD method.
Total Lead and Cadmium Concen-
trations The total concentrations
of lead and cadmium were deter-
mined by digesting the sample in
acid and analyzing the dieesuie by
Flame Atomic Adsorption Spec-
troscopy (FLAA). Samples \\ith
lead or cadmium concentrations so
low that they could nm be de-
tected bv the FLAA nuMhml were
-------
analyzed by Graphite Furnace
Atomic Adsorption Spectroscnpy
(GFAA). The sample particle size
used Tor the digestion and analysis
was < 9.5 mm.
• Lead and Cadmium teachability
EPA Method 1310 Extraction Pro-
ccdurc Toxicily Test (EPTOX)
was used to measure how readily
lead and cadmium will leach from
fluff to estimate the potential
release of these substances from
shredder wastes into the
environment. The EPTOX
extracts were analyzed for lead
and cadmium concentrations using
the FLAA und GFAA methods.
The sample size requirements
were that the particle size be
< 9.5 mm and/or have a surface
area to weight ratio of > 3.1 cm
squared per gram.
• PCBs in Ferrous and Non-fer-
rous Metal Metal samples were
analyzed for total PCB cor • .ra-
tion by extraction followed by
analysis with the GC/ECD meth-
od. Subsamplcs of metal samples
were also analyzed for quality
assurance purposes and archived.
• Analysis of Soil Sample Soil
samples were analyzed for total
PCB concentration. PCB composi-
tion, and total lead and cadmium
concentrations. Subsamples of
soil samples were analyzed in
accordance with the quality
assurance program and others
were archived.
Quality Assurance
The Quality Assurance Project Plan
(QAPjP) presents the features of the
quality assurance design for the pilot
study. The QAPjP was developed in
three phases: Phase l-Field Sampling.
Phase Il-Chcmical Analysis and Phase
Ill-Statistical Data Processing and
Analysis. A more detailed
description of what each phase
included follows.
Field Sampling As previously
described, a grid-type sampling
scheme was employed to increase the
likclihixKl of obtaining representative
samples. A standard operating pro-
cedure (SOP) was also developed for
the sampling of piles of stored fluff.
The QAPjP also stated specific
details for the tracking of field
samples including the use of log
books for sampling details and diain-
of-cus tody sheets for sample tracking.
Duplicate .samples were taken in
order to assess field sampling
variability.
Chemical Analysis Before the
laboratory analysis of any samples.
chemical analysis methods were
carefully reviewed Tor their adequacy
in meeting the project's data quality
objectives (DQOs). The DQO for
accuracy was equal to or greater than
60% recovery for spiked samples.
The DQO for precision was + or -
50',7 relative standard deviation for
replicate samples. The measurement
of the experimental accuracy and
precision was done through labora-
tory quality control samples which
included method blanks, replicate
samples. Held duplicates, and matrix
spike samples. All standards used for
spiking were traceable to their manu-
facturing source. The data quality
objectives were met for all hut a few
samples. Spins were obtained from
UW ol the samples, the .splits being
sent to an external laboratory for
analysis (F.PA Environmental Moni-
toring Svstems Laboratory - Las
Vegasj (EMSL-LV).
Statistical Data Processing und
Analysis A treat deal of effort was
expended in order to assure that the
data generated by the laboratory vtcrc
correctly transferred to the contractor
conducting the statistical analysis of
the data. The correctness of data
values generated by the laboratory was
cross checked by the contractor
conducting the statistical analyses
once they were keyed into a matrix
file.
One other important aspect of the
project's quality assurance program
was the use of audits. Three types of
audits were conducted during the
project: system audits to assure
standard operating procedures were
being followed, performance audits
using performance audit samples so
that the laboratory could demonstrate
its ability to accurately analy/c for the
analytc(s) of interest, and data audits
which reviewed portions of the data
for error.
RESULTS
The results of the Pilot Study provide
a preliminary evaluation ol the waste
characteristics of fluff and valuable
information for the design of future
studies. Caution must be exercised
when generalizing from these findings.
As noted earlier, the Pilot Study
results are based on limited data and
do not necessarily represent the metal
shredding industry as a whole.
Total I'CH Concentrations in Huff.
Metuls and Soil
PCBs were detected in all -hreddcr
output materials analv/cd Over w;
of PCBs arc estimated to end up in
the fluff waste stream. f'CR lonecn-
trations in both the lerrou* and
nonlerrous metals were ver\
(means of 0.21 ppm tor the
1 metal and 0.90 ppm lor iiu non-
ferrous metal). The nu..m IH B u«n-
ccntralion for all IrcNh Hull w.i- 4*
-------
ppm. Using a bootstrap resampling
procedure, an approximate 95%
confidence interval for this mean was
calculated to he 22 ppm to 120 ppm.
Table I displays the average PCB
concentration in parts pur million
along with the standard deviation Tor
each category or sampled material.
Also presented are median, minimum.
and maximum concentrations and the
number or samples and sites upon
which these statistics are based.
Table I shows that fresh fluff from
mixed inputs had higher PCB concen-
trations than fresh fluff resulting from
white g(xxJs or automobiles, and this
difference is statistically significant
PCB concentrations in the non-
ferrous waste metals were roughly 50
times lower than those in Ruff. PCB
concentrations in ferrous waste
streams were approximately 2UO limes
lower than those in fluff. No samples
from the ferrous and non-ferrous
metal streams had PCB concentra-
tions anywhere approaching the EPA
TSCA disposal threshold of 50 ppm.
(The highest PCB concentration for
ferrous metal was 0.42 ppm and for
non-ferrous metal. 2.6 ppm.) It Is
notable that ferrous metal output is
very "clean.* In contrast to non-
ferrous metal which cannot be sepa-
rated primarily with magnets, ferrous
metal output contains practically no
fluff. The non-ferrous metal typically
contains much higher proportions of
ndh-metallic waste (fluff), which may
explain the somewhat higher PCB
levels in the non-ferrous output
PCB concentrations in soils were in
the same range as those in stored
fluff. Some soil samples had PCB
concentrations exceeding the 50 ppm
EPA disposal threshold, but. soil
samples had PCB concentrations, on
the average, slightly below the
disposal threshold. How PCBs got
into the soil is unclear. The PCB
concentrations found in these soil
samples may reflect the migration of
PCBs from fluff which regularly
accumulated nearby, or'soil* samples
may contain a substantial amount of
fluff material which had become
mixed with the soil over time. The
soil sampling protocol prescribed
that if the demarkation between soil
and fluff residues was not distinct.
"sort" samples should contain a
minimum of 50% soil. From the
accounts of sampling crew members.
the distinction between soil and fluff
sometimes was unclear. Soil samples
collected in accordance with the
sampling protocol may often have
contained some portion of fluff.
PCB Composition In Huff
The fluff samples were analyzed for
the specific concentrations of PCB
Aroclors 1242. 1254. and 1260. to
explore the possibility that sources of
PCI? ,/ntaminaiion could be identi-
fied by PCB composition. This
approach was considered feasible
because different PCB Aroclors were
developed for specific uses. This
analysis for specific PCB Aroclors
revealed that Aroclor 1242 was domi-
nant in almost every sample, making
up more than half of the PCBs in
each sample category. While this
part of the pilot study yielded some
general information on the propor-
tions of the three most commonly
used Aroclor mixtures, it produced
no definite information on sources of
PCB utciaminauon.
PCR Concentrations In Individual
Huff Components
Suhsamples from four fresh fluff
samples (two resulting from
automobile shredding, one resulting
from the shredding of white gtxids.
and one resulting from the shredding
of mixed inputs) were divided into the
following components*
• Metals, wire and glass;
• Soft plastics, foams, stilt rubber.
and vinyl;
• Fabrics, paper and wood:
• Hard materials, hard plastics, and
hard rubber;
• Rnc materials too small to
classify, dirt, and dust: and
• Other, not classifiable, materials.
All components, except for the
"Other, not classifiable" materials were
analyzed separately for total PCB
content. Table 2 shows the percent
by weight, of each component in the
four samples, and the PCB
concentrations found in each
component
Total PCB concentrations in Iresh
fluff samples, as well as the rclamc
concentrations of the PCBs in dif-
ferent components, varied with input
material. They also varied between
the two samples produced Irom the
same input material (i.e. automobile).
In one sample from automobile in-
puts, the highest PCB concentration
occurred in materials in the "Soft
plastics, foams, soft rubber and vinyl"
category. In the oihcr (matching)
automobile sample, the hichcst PCB
concentrations were in materials in
the "Fine materials too small tit
classify, dirt, and dusi" category
The highest PCB concentrations in
fluff from white goods were also inund
in materials in the "Fine materials too
small to clussif). din. and dust"
category, while Hull Irom mixed inputs
1 showed the highest PC'B tonicmra-
tions in the "metals, wire .uid "l.ivs"
category.
-------
Table 1. Summary of Total PCS Concentrations (ppn) by Sample Type
Sample Input
Type Type
Fresh fluff Auto
Fresh .fluff White Goods
Fresh fluff Mixed input
Stored fluff
Spillover
Ferrous
Non-ferrous
Soil
Mean
32
80
180
68
28
0.2
1
44
Standard
Deviation
43
190
170
43
25
0.11
1.1
36
Median
13
21
88
52
28
0.21
0.9
32
Minimum
1.7
0.67
12
16
4
0.1
0.13
0.13
Number
of
Maximum Samples
210
760
500
ISO
65
0.42
2.6
100
28
IS
9
10
5
8
5
8
Number
of
Sites
7
5
3
5
5
6
3
4
Table 2. Total PCB Concentrations (ppm) in Five Fluff Components
Input Material
Automobile
Samole 1
Concentration
Component
Metals, tare,
and glass
Soft plastics.
foams, soft
rubber, vinyl
Fabrics, paper,
and wood
Hard materials.
hard plastics,
hard rubber
Fines too small
to classify,
dirt, dust
Other, not
analyzed
Total sample
weight (gm)
% of
Total
Sample
(by weight)
11%
17%
17%
9%
40%
6%
1090
PCB
Concen-
tration
(PP«)
13
66
37
11
43
Automobile
Sample 2
% Of PCB
Total Concen-
Sample tration
(by weight) (ppm)
2% 9.9
14% 7
28% 12
2% 24
38% 29
16%
1260
White Goods
% of
Total
Sdfflplo
(by weight)
3%
8%
9%
10%
65%
5%
859
PCS
Concen-
tration
(PP»>
0.6
35
24
5.5
£2
*
Mixed In
% of
Total
Sample
(by weight)
2%
17%
26%
5%
45%
5%
1080
DUtS
PCB
(ppm)
390
260
63
46
140
-------
10
TCB Kxtractnbilily From FlufT
Suhsamplcs from seven different fresh
Duff samples found to have high total
PCB concentrations were extracted.
using hoi water as solvent, to estimate
how readily PCBs migrate from the
fluff waste stream to the surrounding
environment. The hoi water (65°C)
extraction provides a theoretical
'worst case" estimate of PCB
cxtraciahility. An average of 0.0073%
of the PCBs in the samples was
extracted using the hot water
extraction described earlier.
Using other suhsamples from lite
same seven high PCB fluff samples,
an average of 0.0050% of the PCBs in
the samples was extracted using a
room temperature (22°C) water
extraction. These results suggest that
PCBs are less likely to leach (dissolve
out hy percolation) from fluff than
from a wide range of soils.
Total Lead And Cadmium
Concentrations In Huff and Soil
Total lead concentrations in most
flutf samples ranged trom 1.0UO to
10.000 ppm. Total cadmium con-
centrations in most fluff samples were
substantially lower, falling between 10
and I(X) ppm.
Table 3 presents total lead concen-
trations for each type of fluff and soil
sample" analy/ed. The Table shows
the mean, standard deviation, median.
minimum, and maximum lead
concentration values, as well as the
numbers' of samples and sites on
which the results were based. The
total lead concentration data for fresh
fluff from automobiles, white goods
and mixed inputs were combined to
produce an average for all fresh fluff
which was then compared with
spillover and stored fluff. The mean
total lead concentration in all types of
fresh fluff (combined) is 2.800 ppm.
The approximate 95% (bootstrap)
confidence interval for this mean is
1.800 ppm to 4.100 ppm. Total lead
concentrations in spillover fluff are
greater than in stored fluff, which in
turn are greater than in all types of
fresh fluff combined. These differ-
ences arc statistically significant
Lead concentrations in soil are statis-
tically significantly lower than in all
types of fluff combined.
Table 4 presents the total cadmium
concentrations in each type of fluff
and soil. It gives the mean, standard
deviation, median, minimum, and
maximum lead cunccairatioa values.
as well as the numbers of samples
and sites on which the results were
based.
The data for fresh fluff from auto-
mobiles, white goods, and mixed in-
puts were combined to compare total
cadmium concentrations in fretfs.
spillover, and stored fluff. The tnw*.i
cadmium concentration for all types
of fresh fluff combined is 47 ppm.
The approximate 95% (bootstrap)
confidence interval for this mean is
31 ppm to 65 ppm. Differences
between cadmium concentrations in
the different types of fluff are not
statistically significant. Total
cadmium concentrations in soil arc
statistically significantly lower than in
all types of fluff combined.
IjtaA and Cadmium teachability
From Ruff
Of considerably greater interest.
environmentally, than total lead and
cadmium concentrations is how
readily lead and cadmium leach from
fluff to contaminate the environment.
Lead and cadmium concentrations in
Icachate were measured using the
EPTOX procedure lor samples from
all categories of fluff.
The EPTOX procedure was ihe
standard EPA mcituxl for deter-
mining leachability at the time these
lead and cadmium analvscs were
conducted. In March Two. EPA
replaced the EPTOX wiih the TCLP
(Toxicity Characteristic Leaching
Procedure) as the standard method for
determining leachuhility. EPA
comparison analyses have shown little
difference between the results of the
EPTOX and TCLP methods.
Table 5 summarizes the results for
lead in Icachate from the EPTOX
extraction. The Table presents the
mean, standard deviation, median.
minimum and maximum concentra-
tion of lead in the EPTOX extract for
fresh fluff from automobiles, white
goods and mixed input: as well as for
stored and spillover fluff. Table ft also
presents the number of samples and
sites represented in the calculation of
each statistic.
Lead concentration values in the
EPTOX extract ranged from 0.8 to
220 ppm. with an average ol uhove 6
ppm for every type of fluff. While the
highest EPTOX lead concentrations
were associated with stored fluff, fresh
fluff from mixed input and *pilli«vcr
fluff, the differences between avenue
concentrations as presented in the
Table are not statistically MemUcani.
The mean EPTOX lead concentration
for all types of fresh fluff combined is
7.2 ppm. The approximate l>5r-
(boot-strap) confidence intcnul lor
this mean is 4.8 ppm to 13 ppm.
Table 6 summarizes the results ol the
EPTOX cadmium extraction. Thi-»
Table gives the mean, approximate
95*? confidence interval lor the mean.
standard deviation, median, minimum.
and maximum concentrations lor the
different types ol Hull: a* »ell .1* the
numbers of sample*, .md Mies
represented by these NI.HIMH>
-------
II
Table 3. Summary of Total Lead Concentrations (ppm) by Sample Type
Sample
Type
Fresh fluff
Fresh fluff
Fresh fluff
Stored fluff
Spillover
soil
Input
Type
Auto
White Goods
Mixed input
Table 4. Sumnary of Total
Sample
Type
Fresh fluff
Fresh fluff
Fresh fluff
Stored fluff
Spillover
Soil
Input
Type
Auto
White Goods
Mixed input
Table 5. Summary of EPTDX
Sample
Type
Fresh fluff
Fresh, fluff
Fresh fluff
Stored fluff
Spillover
Input
Type
Auto
White Goods
Mixed input
Mean
2.700
3.100
4,600
3.900
6.100
2.200
Standard
Deviation
2,200
3.200
3,500
3.500
5.600
3.900
•
Cadmium Concentrations
Mean
47
48
46
35
32
22
Standard
Deviation
36
19
14
13
11
24
Median
2.400
1.800
3,600
2,600
4,300
1.100
(ppn) by
Median
40
47
46
35
33
18
Minimum
570
1.300
1.100
1.300
2.800
8.1
Sample Type
Minimum I
14
23
29
16
18
10
Maximum
12.000
14.000
12.000
13.000
21,000
16,000
Maximum
200
87
70
59
59
100
of
Samples
28
IS
13
20
9
16
Number
of
Samples
28
IS
12
20
9
16
Of
Sites
7
5
3
4
5
5
Number
of
Sites
7
5
3
5
5
4
Lead Concentrations (ppn) by Sample Type
Mean
6.9
6.1
23
22
IB
Standard
Deviation
5.5
5.0
24
47
12
Median
5
3 2
U
9 5
20
Minimum
.8
1.6
1
1 6
1.7
Maximum
21
14
78
220
Number
of
Samples
28
IS
12
20
9
NunbBr
of
Sites
7
5
3
5
5
-------
12
Table 6. Summary of EFTQK Cadmium Concentrations (ppm) by Sample Type
Sample
Type
Fresh fluff
Fresh fluff
Fresh fluff
Stored fluff
Spillover
Input
Type
AutO
White Goods
Mixed input
Mean
0.81
1.3
1
0.73
0.45
Standard
Deviation
0.67
0.77
0.27
0.41
0.26
Median
0.7
1.3
1
0.61
0.3
Minimum
0.35
0.45
0.48
0.2
0.18
Maximum
4
1.3
1.4
2
0.81
Number
of
Samples
28
15
12
20
9
Number
of
Sices
7
s
3
5
S
The mean EPTOX cadmium concen-
tration Tor all types of fresh fluff
combined is O.H4 ppm. The approxi-
mate 95% (bootstrap) confidence
interval for this mean is 0.53 ppm to
1.2 ppm.
CONCLUSIONS
In this pilot study. EPA's research
team:
• Determined that PCBs were pre-
sent in all sampled materials ai all
seven pilot study sites and that
over 98% of the PCBs in all
shredder output were associated
with fluff: PCB concentrations in
fluff ranged from 0.67 to 760 ppm.
• Determined that in the "worst
case* scenario of teachability, a
^- Hot water extraction, only .0073%
of the PCBs present leached from
the sample on average. In a
situation more closely resembling
'real world* conditions, room
temperature water extraction
leached .0050% of the PCBs. on
average, from the fluff. In both
cases, the observed Icachabiliry of
PCBs from fluff was lower than
usually found in a wide range of
soils;
Could not conclude thai any
particular input material was the
source of the PCBs. lead and
cadmium found in shredder out-
puts. Cross-contamination of
samples within sites may have
masked the relationship between
input material and contamination
of resulting output materials.
For example, if PCBs were
released onto shredder surfaces
during the shredding of PCB-
containing items, fluff produced
for some time after the initial
release may haw been contami-
nated as it came into contact with
pans of the shredder apparatus.
although no PCBs existed in the
input material associated with
this fluff:
Found that lead and cadmium
leachatc concentrations in fluff, as
determined by the EP TOX.
ranged Irom O.X to 220 ppm and
O.JX eo 4 ppm. respectively.
Developed and tested field sam-
pling and sample preparation
procedures to obtain represen- •
talive samples and subsamples of
fluff, ferrous and non-ferrous ,
metals and soil from shredder
sites: and
Developed and tested laboratory
protocols to analyze very large
fluff samples (S(X) grams) for PCB
content. This technique reduced
the sampling variability associated
with conventional PCB extraction
and analysis of fluff, and resulted
in more reliable estimates of PCB
concentration.
Determined that '><: limned size of
the sample pr«.;.iudcs using the
analytical results from this Pilot
Study to characterize the shredder
industry as a whole: also identified
the need to collect and evaluate
additional analytical data gene-
rated by State agencies and indus-
try sources subsequent to comple-
tion of the Pilot Study. Care will
be taken to review sampling proce-
dures and analytical methods used
in collecting data.
Identified the need to obtain a bet-
ter understanding ol the economic
viability of the shredder industry
and to assess ihc economic
impacts, if any. rcMiliim: irom
various approaches lo residual
waste management.
------- |