PB83-181834
Preliminary Operations Plan and
Guidelines for the At-Sea Incineration of
Liquid PCB (Polychlorinated biphenyl) Wastes
TRW, Inc.
Redondo Beach, CA
Prepared for
Industrial Environmental Research Lab,
Research Triangle Park, NC
Apr 82
U.S. DEPARTMENT OF COMMERCE
National Technical Information Service
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April 1982
PB83-181334
PRELIMINARY
OPERATIONS PLAN AND GUIDELINES
FOR THE AT-SEA INCINERATION
OF LIQUID PCB WASTES
by
L.L. Scinto, P.A. Painter, A.M. Takata, and T.J. Hennings
TRW, Inc.
Environmental Division
One Space Park
Redondo Beach, CA 90278
Contract No. 68-02-3174
Work Assignment No. 55
EPA Project Officer: D.C. Sanchez
Industrial Environmental Research Laboratory
Office of Environmental Engineering and Technology
Research Triangle Park, N.C. 27711
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Research and Development
Washington, D.C. 20406
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TECHNICAL REPORT DATA
(Please read Instructions on the reverie before completing)
REPORT NO.
EPA-600/2-82-068
2.
ORD Report
3 RECIPIENT'S ACCESSION-NO.
P53 3 1 8 1 8 3
4 TITLE AND SUBTITLE
Preliminary Operations Plan and Guidelines for the
At-sea Incineration of Liquid PCB Wastes
S. REPORT DATE
April 1982
t. PERFORMING ORGANIZATION CODE
AUTHOR(S)
T. J. Hennings, P. A. Painter, L.L.Scinto, and
A. M. Takata
8 PERFORMING ORGANIZATION REPORT NO.
PERFORMING ORGANIZATION NAME AND ADDRESS
TRW, Inc.
One Space Park
Redondo Beach, California 90278
1O. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3174, Task 55
12. SPONSORING AGENCV NAME AND ADDRESS
EPA, Office of Research and Development
Industrial Environmental Research Laboratory
Research Triangle Park, NC 27711
13. TVPE OP REPORT AND PE
Task Final; 1-4/81
PERIOD COVERED
14. SPONSORING AGENCY CODE
EPA/600/13
15. SUPPLEMENTARY NOTES T£RL-RTP project officer is David C. Sanchez, Mail Drop 63,
919/541-2547.
16. ABSTRACT
The report is a preliminary operations plan and guidelines report for the
disposal of polychlorinated biphenyl (PCB) wastes by at-sea incineration. The study
was divided into two subtasks: Subtask A was the development of an inventory of
government-owned PCB wastes suitable for at-sea incineration; and Subtask B was
the development of operating plans and a schedule for an EPA-coordinated project
to dispose of these wastes. Approximately 1.3 million gallons of government-owned
liquid PCB wastes were identified, 425,000 gallons of wl ich were considered to be
immediately available for at-sea incineration. 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 require-
ments, incineration 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 oper-
ations.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lOENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Pollution
Chlorine Aromatic
Compounds
Biphenyl
Liquids
Waste Disposal
Incinerators
Waste Treatment
Transportation
Bulk Storage
De contam ination
Pollution Control
Stationary Sources
Polychlorinated Bi-
phenyls
At-sea Incineration
Waste Collection
13B
07C
07D
15E
14G
13 DISTRIBUTION STATEMENT
Release to Public
19 SECURITY CLASS IThuReport)
Unclassified
21. NO. OF PAGES
121
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
SPA form 2220-1 (9-73)
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NOTICE
THIS DOCUMENT HAS BEEN REPRODUCED
FROM THE BEST COPY FURNISHED US BY
THE SPONSORING AGENCY. ALTHOUGH IT
IS RECOGNIZED THAT CERTAIN PORTIONS
ARE ILLEGIBLE, IT IS BEING RELEASED
IN THE INTEREST OF MAKING AVAILABLE
AS MUCH INFORMATION AS POSSIBLE.
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NOTICE
This document has been reviewed in accordance with
U.S. Environmental Protection Agency policy and
approved for publication. Mention of trade names
or commercial products does not constitute endorse-
ment or recommendation for use.
11
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ABSTRACT
This document is a preliminary operations plan and guidelines report for
the disposal of polychlorinated biphenyl (PCB) wastes by at-sea incineration.
The effort on this study was divided into two subtasks. In Subtask A, an
inventory of government-owned PCB wastes suitable for at-sea incineration was
developed. Approximately 1.3 million gallons of government-owned liquid PCB
wastes were identified in Subtask A, 425,000 gallons of which were considered
immediately available for disposal by at-sea incineration. In Subtask B,
operating plans and a schedule for an EPA-coordinated project to dispose of
these wastes were developed. The operations plan addresses both land-based
and at-sea operations. Land-based operations 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, incineration procedures, and cargo tank de-
contamination are addressed for at-sea operations. The preliminary schedule
for the disposal project shows a duration of 10 months from decision to pro-
ceed with the project to completion of disposal operations.
This report was submitted in fulfillment of Contract No. 68-02-3174,
Work Assignment 55, by the Environmental Division of TRW, Inc., under spon-
sorship of the U.S. Environmental Protection Agency. This report covers the
period 21 January 1981 to 12 June 1981, and work was completed as of 12 June
1981.
iii
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CONTENTS
Abstract ii
1. Introduction 1
1.1 Background 1
1.2 Purpose and Scope 3
1.3 Organization 3
2. Inventory of PCB Waste Stocks 5
2.1 Organizations Contacted 5
2.2 Quantities and Locations of Waste Stocks 6
2.3 Detailed Description of Waste Stocks 6
3. Land-Based Operations 11
3.1 Collection and Preparation of PCB Wastes 11
3.2 Transportation to Processing Facility 16
3.3 Criteria for Selecting Processing Facility Locations. ... 21
3.4 Processing of Wastes and Containers 22
3.5 Interim Storage of Bulk Liquids 34
3.6 Transportation to the Ship Loading Site 36
3.7 Ship Loading 41
3.8 Public Notification and Participation 45
4. At-Sea Operations 47
4.1 Incineration Site Selection 47
4.2 Permit Requirements 49
4.3 Incineration Operations 56
4.4 Cargo Tank Decontamination 74
5. Logic Network and Schedule 77
5.1 Critical Path Model 77
5.2 Schedule 79
References 81
Appendices
A. Inventory of PCB Stocks 84
B. Safety Plan for Incineration of Liquid PCBs Onboard the M/T
Vulcanus 97
iv
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1. INTRODUCTION
1.1 BACKGROUND
Polychlorinated biphenyls (PCBs) are synthetic chlorinated organic com-
pounds which have extremely high thermal and chemical stability. They have
excellent electrical insulating properties, low volatilities, and high flash
points. These characteristics make PCBs useful in numerous commercial appli-
cations, particularly as dielectric fluids in transformers and capacitors.
Commercial mixtures of PCBs are very complex, each containing many of
the 209 possible PCB isomers and often organic solvents. Most individual PCB
isomers are solids at room temperature, but commercial mixtures vary in
consistency from mobile oils to viscous liquids. Common trade names for these
mixtures include Arochlor, Inerteen, Kanechlor, and Pyranol.
PCBs are moderately acute toxicants. They are similar in their biological
activity to the pesticide dichloro-diphenyl-trichlorethane (DDT). These
chemicals are metabolized slowly and accumulate in fatty tissues of animals
and humans. The known toxic effects of PCBs in humans include chloracne, skin
pigmentation, swelling of the eyelids and excessive eye discharge. Animal
reproduction is also known to be impaired by PCBs, and malformations have been
reported. PCBs have exhibited carcinogenic effects in some animal species.
The resistance of PCBs to degradation contributes to their persistence in the
environment and enhances their availability for uptake by plants and animals,
thereby causing them to enter the food chain.
Recognizing the environmental problems associated with the widespread use
of chemicals such as PCBs, Congress, in 1976, passed the Toxic Substances
Control Act (TSCA). Section 6(e) of TSCA required the Environmental Protection
Agency (EPA) to regulate the marking and disposal of PCBs. It also provided
for a ban on the manufacture and use of PCBs in other than a totally enclosed
manner by 1 January 1978, a complete ban on manufacture by 2 July 1979, and a
complete ban on distribution in commerce and processing by 1 July 1979. EPA
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was, however, authorized to grant exceptions to the ban rules under certain
conditions.
On 31 May 1979, EPA promulgated the final rule ("PCB Regulations") under
the authority of Section 6(e) of TSCA: Polychlorinated Biphenyls (PCBs)
Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions
(40 CFR 761). This rule: 1) prohibits all manufacturing of PCBs after
2 July 1979; 2) prohibits processing, distribution in commerce, and use of
PCBs except in a totally enclosed manner after 1 July 1979; and 3) authorizes
certain exemptions. The PCB Regulations do not require removal of PCBs and
PCB Items from service and disposal earlier than would normally be required.
But, when PCBs and PCB Items are removed from service, disposal must be in
accordance with the PCB Regulations. The PCB Regulations generally apply to
any substance, mixture, or item containing greater than 50 ppm PCBs. However,
a recent court decision on the 50 ppm rule may have the effect of requiring
that substances containing less than 50 ppm of PCBs be regulated. This would
increase the amount of PCBs which would eventually require disposal.
One of the methods for PCB disposal permitted in the PCB Regulations is
incineration. Incineration is the preferred method for disposal of a number
of chlorinated organic wastes because it is capable of essentially complete
destruction of the toxic or hazardous constituents of the wastes, and is thus
an ultimate disposal technology. Recently EPA tested and approved two land-
based incinerators for the disposal of PCBs. However, it is not expected that
the shortfall in PCB disposal capacity predicted by the Electric Power Research
Institute (1) will be alleviated fully by these units.
Another method of disposing of PCB fluids is by non-thermal degradation
methods. Recently some EPA Regions have approved one such non-thermal method,
the PCBX process, for disposal of certain liquid PCB wastes.
An alternative to land-based incineration or non-thermal treatment is
incineration at sea. At-sea incineration of organochlorine liquids has
been practiced successfully in Europe for a number of years. In the U.S.,
organocholorine wastes were incinerated in the Gulf of Mexico on board the
M/T Vulcanus in late 1974 (2) and again in early 1977 (3). Subsequently,
stocks of U.S. Air Force Herbicide Orange were burned on the Vulcanus in the
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Pacific Ocean (4, 5, 6, 7, 8). All U.S. burns were closely monitored by EPA.
Monitoring results provided the technical basis for concluding that at-sea
incineration is an environmentally acceptable alternative to land-based in-
cineration for organochlorine wastes.
At-sea incineration is a technology which has the potential to increase
PCB disposal capacity nationally, thereby relieving some of the expected
shortfall in capacity. Although at-sea incineration is a proven technology,
no attempts have yet been made to demonstrate that PCBs can be effectively
disposed of in this manner.
EPA has received requests from various state and Federal agencies for
assistance in disposal of government-owned PCB wastes. In addition, many
organizations in the private sector are storing PCB wastes for disposal. At-
sea incineration is being considered as a disposal method for these wastes.
Any person desiring to incinerate wastes at sea must first obtain a
permit to do so as required by regulations under the Marine Protection,
Research and Sanctuaries Act (MPRSA). An application for a permit to in-
cinerate PCBs was submitted to EPA by the owners of the Vulcanus, and a permit
was recently granted. Disposal of government-owned as well as private
industry stocks of PCBs can be accomplished under the t&rnis of this per-
mit. Successful incineration of PCBs on the Vulcanus would not only serve
to dispose of government stocks of PCBs; it would add at-sea incineration to
the list of disposal options available to the owners of PCB wastes.
1.2 PURPOSE AND SCOPE
This resource document identifies government-owned stocks of PCB wastes
which are available for disposal and presents a conceptual plan for destruc-
tion of these wastes by at-sea incineration. The document describes admini-
strative, legal, and technical considerations which must be incorporated into
the program planning. Based on these considerations, criteria and guidelines
have been defined for functional tasks. When appropriate within the scope
of this effort, specific operating plans have been described or recommended.
Complete definition of some program elements cannot be made at this time
because of lack of information, possible or anticipated changes in the regula-
tory structure, or uncertainties in regards to the logistics of the disposal
3
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action. In these cases, guidelines and criteria for task definition are
presented and discussed, and assumptions are made in order to better concep-
tualize functional tasks.
1.3 ORGANIZATION
Operations planning for this disposal action has been divided into four
major areas as follows:
i Inventory of PCB waste stocks (Section 2)
• Land-based operations (Section 3)
• At-sea operations (Section 4)
• Logic network and schedule (Section 5)
Appendices are included to provide added detail to discussions in the
text. They include a detailed inventory of PCB wastes (Appendix A) and a
safety plan (Appendix B).
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2. INVENTORY OF PCB WASTES
2.1 ORGANIZATIONS CONTACTED
The first step in compiling the inventory of PCB wastes was to define the
list of government organizations to be contacted. This list consisted origin-
ally of four organizations, defined by EPA, from whom the Agency had received
requests for disposal assistance. After initial contacts with these organiza-
tions, it was determined that the quantity of wastes was less than the minimum
amount necessary to make at-sea incineration economically feasible. There-
fore, the list of contacts was expanded at EPA's request to include other
government and private industry sources. In all cases, Regional EPA offices
were contacted for assistance in locating government-owned stocks of PCB
wastes.
The individual in each organization responsible for PCB disposal was
identified and asked specific questions regarding waste stocks under his juris-
diction. These questions related to the following:
• Waste volume and chemical composition information
- Total volume and/or weight of liquid PCB wastes
- Size, type, and condition of storage/shipping containers
- Amount of waste in each container
- Proportion of waste which is pumpable
- PCB content and carrier for each waste
- Volume of each "container type/fluid type/PCB content"
combination
- Information on waste compatibility
• Transportation information
- Location of wastes in storage
- Applicable transport modes (rail, truck, barge)
- Suitability of storage and transportation facilities for
handling toxic wastes
- Applicable state and local transportation regulations (which
may be more stringent than Federal regulations)
- Special loading requirements
- Incidents which have occurred in the past which might impact
future transportation of PCB wastes
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Information obtained was often general in nature because, for example, specific
analyses had not been performed on the wastes.
2.2 QUANTITIES AND LOCATIONS OF WASTE STOCKS
Government-owned PCB wastes in the inventory were grouped as available
and potentially available. Available stocks included those wastes which were
(1) liquids incinerable on the Vulcanus; (2) currently stored and ready for
transport and disposal; and (3) owned by an organization which expressed a
positive interest in participating in an EPA-coordinated test burn, and which
was willing to pay all disposal costs.* The type, quantity, and location of
approximately 1.3 million gallons of PCBs under government ownership were
identified. Of this total, only about 425,000 gallons were considered
immediately available for at-sea incineration.
Potentially available stocks included wastes which were identified in
the inventory but which did not meet all of the three above criteria. About
843,000 gallons of PCB wastes were identified as potentially available. They
consisted primarily of PCB fluids in transformers, lubricating systems, and
hydraulic systems which did not meet criterion 2. About 17% of the potentially
available PCBs were not considered available because criterion 3 was not met.
A cursory survey of several industrial sources indicated that an additional
836,000 gallons of PCB fluids were also available from those sources.
Figure 1 shows the volume percentage of available government-owned PCBs
located in each state. Tennessee, with 51%, has the largest volume. Most
of the available PCBs (about 85%) are located in the four states of Tennessee,
Texas, Ohio, and Alabama. About 75% of the potentially available PCB stocks
are located in the states of Ohio, Tennessee, and Kentucky.
2.3 DETAILED DESCRIPTION OF WASTE STOCKS
For the purposes of this inventory, available government-owned liquid
PCB waste stocks have been divided into two categories as follows:
"Criterion 3 was slightly modified for the final inventory from an original
criterion that a positive interest was expressed and only transportation
costs would be paid by the waste owner. The change was made to ensure that
stocks could be considered available, even if EPA could not reimburse each
organization for the costs of waste processing and incineration. Such reim-
bursement had been assumed when compilation of the inventory began.
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.4HD.C.)
Figure i. Percentage of Available PCB Wastes Located in Each State
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• Category A wastes consist of organic liquids with PCB content
of 500 ppm or greater
• Category B wastes consist of organic liquids with PCB content
less than 500 ppm
Table 1 summarizes information on ownership, volume, PCB content, and
location of available PCB wastes. Several assumptions were made in compiling
the data in this table in cases where information from owners was insufficient.
If owners indicated that both transformer fluid and capacitor fluid was avail-
able, but did not know how much of each was present, equal volumes were
assumed. For transformer fluid and capacitor fluid, PCB contents of 70% and
100% were assumed, based on information from Reference 1. This assumption
probably overestimates the PCB content of transformer fluids, because many of
these units (e.g., RGB-contaminated transformers) contain much less than 70%
PCB. Another assumption was made regarding the specific gravity of PCB stocks
owned by government organization #4. This organization reported quantities in
pounds, and gave a range of estimated specific gravities. Estimation of the
specific gravity for these stocks may have resulted in an error of ±20% in
volume calculations.
Based on the data in Table 1, an average PCB content for stocks in each
category (A and B) was calculated. This average, calculated as the volume-
weighted sum of concentrations in Table 1, represents an estimate of what the
concentration of Category A and Category B wastes would be if each were
blended separately. Results of these calculations are presented in Table 2.
The average PCB content of Category A wastes is 39% and of Category B wastes
70 ppm. The overall average PCB content of all waste, that is, the PCB con-
centration if all wastes were blended together, is 24%.
Approximately 121,000 gallons, or 30% of the available PCBs are stored
in 55-gallon metal drums. The remaining 70% are stored in bulk. Processing
requirements for drummed waste are detailed in Section 3.
Truck transport is applicable to all available PCB stocks, and rail
transport is applicable to over 70% of all stocks (by volume).
Appendix A contains more detailed information on all aspects of the PCB
inventory.
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TABLE 1. GOVERNMENT-OWNED PCBS AVAILABLE FOR AT-SEA INCINERATION
Government
Organization
1
1
2
2
3
4*
4
4
4
4
4
4
4
4
5
5
5
6
6
Volume,
gallons
8,500
1,500
20,000
1,500
20,000
42,300
11,200
12,000
20,000
6,000
8,000
10,600
160,000
2,000
35,000
5,500
1,200
3,800
56,200
PCB
Category*
A
B
A
A
A
A
A
A
A
A
A
A
B
B
A
A
A
A
A
PCB
Concentration7
(70%)
(50 ppm)
(70%)
(70%)
(70%)
(70%)
70%
(70%)
2500 ppm
1000 ppm
700 ppm
(500 ppm)
70 ppm
(50 ppm)
40%
(70%)
(70%)
35%
500 ppm
Location
Washington, DC area
Washington, DC area
Al abama
New York
Alabama
Ohio
Kentucky
Tennessee
Tennessee
Tennessee
Tennessee
Tennessee
Tennessee
Tennessee
Missouri
New Mexico
Colorado
Texas
Texas
PCBs were categorized as follows: A = ^500 ppm PCB (organic); B = <500
PCB (organic). These categories were based on the regulatory 500 ppm/50 ppm
cutoffs and combustion considerations.
Concentrations in parenthesis are TRW estimates based on the following:
transformer fluid - 70% PCB; capacitor fluid - 100% PCB; rinsate - 50 ppm
PCB. Otherwise concentrations are based on data obtained from waste owners.
Proportions of transformer fluid, capacitor fluid, and rinsate are TRW
estimates, unless data were available from owners. Rinsate volume is assumed
to be 15% of the total volume, if present. Equal amounts of transformer and
capacitor fluid are assumed, if both are present.
^Estimation of specific gravities for these stocks may have resulted in ±20%
error in volume calculations.
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TABLE 2. SUMMARY OF GOVERNMENT-OWNED PCBs AVAILABLE BY CATEGORY
Average PCB Content*
Category Volume Available (Estimate)
A
B
(^500 ppm
(<500 ppm
TOTAL
PCB)
PCB)
261
163
425
,800
,500
,300
gal.
gal.
gal.
39"?
70 ppm
Overal 1
avg =
24%
Average PCB content for each waste category Is obtained by taking a
volume-weighted sum of the PCB concentration data In Table 1.
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3. LAND-BASED OPERATIONS
Land-based operations in the PCB disposal action include collection,
preparation, transport to a land-based processing facility, processing and
interim storage, transport to ship loading site, and ship loading. The
obkective of the land-based operations plan is to identify and plan in logi-
cal sequence all necessary activities prior to at-sea operations. This plan
is developed in terms of the sequential flow of activities and decision
points needed to carry out this phase of the disposal action in an effective
manner with due consideration to constraints imposed for public safety and
environmental protection.
Preliminary plans for collection and transportation of PCB wastes are
based on the assumption that a land-based processing facility near a port on
the Gulf of Mexico will be used. A Gulf Coast location was chosen mainly
because it is close to available PCB stocks and an EPA-designated ocean in-
cineration site.
3.1 COLLECTION AND PREPARATION OF PCB WASTES
PCB wastes to be disposed of by at-sea incineration must be collected
and orepared for transport to the land-based processing facility. Currently
all of the available PCBs are being stored in bulk or in 55-gallon metal
drums. Preparation for transport of these wastes must be in accordance with
prescribed procedures and regulatory requirements.
3.1.1 Legal and Administrative Requirements
The preparation, collection and transport of PCBs designated for destruc-
tion will involve certain legal and institutional policies and procedures
which must be considered. The following sections describe the significant
Federal, state and local rules and regulations governing PCB handling and
transport which are applicable to this phase of the disposal operation.
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3.1.1.1 Federal Rules and Regulations—
The U.S. Department of Transportation (DOT) is responsible for publish-
ing and maintaining regulations controlling the transport of all hazardous
materials within the U.S. These regulations apply to the surface and rail
transport of PCBs. The regulations are under Title 49, Code of Federal
Regulations (CFR). The pertinent parts are as follows:
Part 171 General information, regulations and definitions
Part 172 Hazardous materials table and communications regulations
Part 173 Shippers-general requirements for shipments and packagings
Part 174 Carriage by rail
Part 177 Carriage by public highway
Part 178 Shipping container specifications
Part 179 Specifications for tank cars
A hazardous material is defines in Title 49 as "any substance which has
been determined to be capable of imposing an unreasonable risk to person or
property." Title 49 also states that "no person may offer or accept a hazard-
ous material for transport in commerce within the United States unless that
material is properly classed, described, packaged, marked, labeled and in
good condition for shipment."
Also, the regulations state that "it is the duty of each person who
offers a hazardous material for transportation to instruct each of his offi-
cers, agents and employees having any responsibility for preparing hazardous
materials for shipment as to the applicable regulations."
Proper shipping name—The hazard class of a hazardous material is the
key to determining the "proper shipping name." The Hazardous Materials
Table in 40 CFR 172.101 indicates that the hazard class for polychlorinated
biphenyls is Other Regulated Materials-E (ORM-E). The proper shipping name
is polychlorinated biphenyls (RQ-10/4.54).
Label ing/markings—Label ing procedures are not delineated per DOT regu-
lations for PCBs. Some specific packaging requirements for ORM-E are indi-
cated in Section 173.510. Regulations under the Toxic Substances Control
Act (TSCA) address marking of PCBs and PCB Items (40 CFR Part 761.20 of the
12
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PCB Regulations). Proper marking of the PCBs is described in part 761.44,
Marking Formats.
Documentation (shipping papers)—Under DOT regulations, each shipment
must be accompanied by the appropriate documents, with information entered
in the exact format described in 49 CFR 172.200-204. For rail and surface
this can be a single document describing the hazardous material by name,
hazard, labels and quantity. In addition, the shipping papers must include
a statement verifying the contents, and that the shipment is in proper con-
dition for transport.
Additional transport documentation is required under Resource Conserva-
tion and Recovery Act (RCRA) regulations 40 CFR Part 263 - Standard Applic-
able to Transporters of Hazardous Waste. Subpart B of this section describes
the manifest system whereby a transporter may not accept hazardous waste from
a generator unless it is accompanied by a manifest signed by the generator
and in accordance with the provisions of 40 CFR Part 262. Although RCRA
regulations do not apply directly to PCBs, it is recommended that a RCRA-
type manifest system be employed.
Mode of Transport—There may be additional regulations or tariffs that
pertain to mode of transportation. Each of these is bastd primarily on
safety considerations as would apply to the particular mode of transport.
Surface transport is covered under DOT regulations, 49 CFR 172.500. Other
parts of the regulation which should be consulted are 177, Carriage by public
highway. Regulations pertaining to carriage by rail are covered under
Part 174, Carriage by rail, and Part 179, Specifications for tank cars.
Temporary Storage—A critical safety factor is proper storage prior to,
during and after shipment. Materials of the same hazard class should be
stored together, provided they can employ the same retardants in case of in-
cident. Additional requirements may be necessary. Temporary storage is also
addressed in the PCB Regulations (.40 CFR 761).
Incident Reporting—Title 49, 171.15-16 requires each carrier transport-
ing hazardous material to complete a transportation incident report (DOT
Form F-5800-1) in the event of the following:
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• Death
• Injury requiring hospitalization
• Carrier damage exceeding $5,000 (or property damage of $50,000)
• Fire, breakage, spillage or suspected radioactive contamination
• A situation that the carrier believes should be reported.
Spill Reporting—DOT regulations (40 CFR 177, Subpart D) address acci-
dents involving vehicles and shipments in transit. Spill reporting proce-
dures for PCBs are also addressed in the PCB Regulations (40 CFR Part 761).
Emergency procedures have been addressed in this report under Section 3.2.7.
Additional spill reporting and emergency procedures may apply, such as pro-
visions, of the National or Regional Contingency Plans.
Safety Requirements—Additional safety procedures may be required in
pertinent federal rules and regulations. It is the sole responsibility of the
waste owner and his designated carrier to be aware of and follow all rules
and regulations required for the safe transport of PCB wastes to the process-
ing facility. Recommended safety procedures over and above requlatory require-
ments are described elsewhere in Section 3.
3.1.1.2 State and Local Rules and Regulations—
EPA Regional Offices should be aware of State regulations concerning the
preparation and transport of PCB wastes. If a Regional Office does not have
this information, then the State agency responsible for regulating transport
in and through the state should be contacted. Also, State agencies may be
able to assist with local agency coordination.
It is the responsibility of the waste generator to comply with state and
local rules and regulations concerning the transport of his PCB wastes to
the processing facility. States will have to comply with federal rules and
regulations governing hazardous waste transport. In some cases, the state
or local authorities will have enacted legislation or regulations more strin-
gent than or in addition to the federal requirements. For example, Alabama
requires all hazardous material carriers to register with the Public Service
Commission. The Alabama Health Department requires the issuance of a hazard-
ous waste manifest. The state of Missouri requires that all hazardous mat-
erial transporters be licensed by the Department of Natural Resources. This
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department also requires a manifest. In Pennsylvania, the Pennsylvania
Turnpike Commission requires all hazardous material transporters to be per-
mitted. Other requirements may exist and these must be determined prior to
shipment of the PCB wastes.
3.1.2 Waste Collection and Preparation Procedures
Upon notification of waste availability for incineration, detailed plans
for collection, preparation and transport will be initiated. PCB wastes at
each site should be sufficiently characterized to provide the experimental
evidence needed to determine the type of waste (i.e., PCB content and carrier),
net heating value, compatibility with other wastes, and any special safety
precautions or decontamination procedures that may be required in the subse-
quent handling of the waste. Some wastes may need further characterization
or filtration in preparation for shipment. Processing requirements and
capabilities of the land-based facility may influence the degree of prepara-
tion necessary at the storage site.
A definitized handling sequence plan should be generated by each owner
of PCB waste using the DOT and spill regulations, the location and physical
conditions of the waste, waste category, and specific chemical analyses.
Wastes in each category should be segregated and marked or shipped separately.
The corrosiveness, volatility, flammability, and general toxicity should be
used to determine if special containers for waste transfer are required.
Similarly, any exposure/handling precautions should be identified.
An inspection should be made of all containers prior to loading with the
waste. This inspection will verify that the approved type of containers a-e
being used, that integrity requirements are met, and that proper seals, iden-
tity labels, and materials for containing spillage during loading are avail-
able.
The actual waste loading should be followed by an inspection for leaks
and external contamination. Equipment used for transferring the waste to
the containers that has come in contact with PCB should be decontaminated
on-site.
Firm commitments for transfer of the approved waste containers should
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be obtained by the owners of the waste. This commitment should include
methods of transport, schedules, waste code identifications, routes, desti-
nations, liability, and authority transfer requirements. Written instruc-
tions should be provided for actions in case of spillage, fire, or need for
in-transit transfer from one vehicle to another.
3.2 TRANSPORTATION TO PROCESSING FACILITY
PCB wastes will be transported to the land-based processing facility
by the method chosen by the owner of the waste which is consistent with public
safety, protection of the environment and the desires of the processing
facility owner. Alternative transportation modes are a significant factor
in the safe movement of the wastes from one location to another. Monitoring
during transport will minimize public risk. A detailed contingency plan
should be prepared and implemented for the selected transport mode.
3.2.1 Alternative Means of Transport
The transport modes considered for the movement of PCB wastes are truck
and rail. Based on a survey of owners of available government-owned PCBs
(Section 2), truck transport is applicable to all stocks, and rail transport
is applicable to about 70% of all stocks (by volume).
There are several areas in which the two can be compared:
• Load Size. The train will carry the larger load.
• Material Transfers. Spills during transfer of hazardous
materials from one container to another, from one part of
a storage site to another, from one vehicle to another, or
during vehicle loading and unloading operations are normally
small. Truck transport would require the fewest material
transfers. Regardless of mode selected, it is likely that
significant amounts of trucking will be necessary.
t Material Storage. Depending upon the size of the load to be
carried, hazardous material may have to be stored while
enough accumulates for a full shipment. Trucks would require
virtually no interim storage, while trains would certainly
require some storage, during which time an incident could
occur that might well be serious if storage were close to
areas of environmental sensitivity.
• Accident Risk. Although it is generally concluded that the
accident frequency for trucks is higher than for trains, the
risk of a major spill by train is greater than by truck.
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3.2.2 Ground Transport Shipping Methods
There are various ground vehicles in which the PCB wastes may be trans-
ported safely from one location to another. These may be categorized into
bulk shipment and containerized shipment methods. Another consideration is
whether dedicated or common carriers should be used.
3.2.2.1 Bulk Shipment-
Tank trucks, which have good access to PCB storage locations and low risk
of spillage during transfer of liquid PCB from storage drums to tank truck,
can be used. These trucks could make several stops to accumulate a full load
(5,000-6,500 gallons), although the first stop should provide at least 1,000
gallons to ensure sufficient stability for the partially filled truck. Spe-
cialized tank trucks would not have low-level valves, and they could include
vacuum suction and discharge units, a sludge pump, special internal lining,
insultation, placarding, etc.
Railway tank cars would hold 10,000-11,000 gallons and in most instances
would require transfer of liquids to them by truck. They would sometimes re-
quire storage of liquids temporarily while awaiting arrival of a freight
train. Specially outfitted tank cars for carrying hazardous materials are
also available.
Piggyback transport of liquids would involve placing the trailers of tank
trucks directly on railroad flat-cars for transport to the disposal- site.
This combination would minimize material transfers, handling, and storage
prior to rail shipment and decrease the likelihood of hazardous spills during
transport.
3.2.2.2 Containerized Shipment-
Containers of hazardous waste, carried on a flatbed truck would not nor-
mally be stacked, but should be arranged in such a way as to allow periodic
inspection. The truck should be equipped to contain any liquid leakage on
the bed of the truck. In case of an accident, a flatbed would allow greater
dispersal of materials than would a van-type truck.
Containers shipped in a large van should not be stacked. Loading and
unloading operations would provid; a greater chance for a minor spill than if
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a flatbed were used since the van floor is normally higher off the ground. A
van is also somewhat less stable than a flatbed due to its higher center of
gravity. In case of an accident, knowledge of the concentration of spilled
materials would be desirable.
3.2.2.2 Dedicated vs. Common Carriers—
The question of whether a dedicated or a common carrier be assigned all
PCB transport is complex. The dedicated carrier normally specializes in the
transport of specific materials and has drivers trained in the characteristics
and handling of those materials. The common carrier may have long experience
in the handling of bulk chemicals, has better availability of transport vehi-
cles, and is generally able to carry higher levels of insurance due to its
greater asset value, higher income, and broader scope of operations.
Because training in the characteristics of one hazardous substance may
vary somewhat from that required for the care and handling of another sub-
stance, there is no guarantee that previous driver training would be entirely
transferable. However, the dedicated carrier's specialization and past
driver training could be expected to give some advantage over the common
carrier with regard to protection of the public and the environment.
It is most important that whatever type of carrier is used, there should
be someone in the transport vehicle who has been specially trained in the
characteristics and handling of PCB and response to various PCB spills, unless:
• The transport vehicle is accompanied by an escort vehicle
t The shipment is small, i.e., no greater than ten drums or
the equivalent
3.2.3 Monitoring During Transport
Visual monitoring will be employed during PCB waste loading, transport
and unloading. All incidents of leakage will be handled as described in
Section 3.2.5 (Contingency Planning).
Monitoring of tank trucks or tank cars during loading will be performed
in compliance with DOT regulations, 49 CFR 173.31(b)l and 174.8 through
174.10, respectively. Valving will be observed uncapped during filling to
detect leakage; uncapped leakage through valving greater than a drip will
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preclude transport use until such leaks are repaired. Similarly, any leakage
through rivets, seams, or couplings will preclude acceptance for transport
use until appropriate repairs are performed.
Personnel should be designated for observation of tank trucks or tank
cars during transport. Monitoring enroute could be performed from adjacent
vehicles or vantage points or by periodically halting the transport vehicle
for examination, as is appropriate.
3.2.4 Public Risk
The extent of public risk during bulk transportation of PCB waste to the
land-based facility is largely dependent upon the mode of transport selected
and the proximity of the waste generation facility to the processing facility.
At some point in the transport of the PCB wastes from the generator to the
processing facility transport in a truck will likely be necessary. It is also
likely that these trucks will need to use public roadways.
In the event that transport on or near public thoroughfares is required
the extent of public risk will be dependent upon the traffic and routing.
Risks would be minimized by transport through areas of lowest habitation.
Although public risk during transport is difficult to assess it can be mini-
mized by proper routing and appropriate monitoring and contingency planning.
3.2.5 Contingency Planning
Prevention of spills of hazardous materials is far superior to cleanup.
The transporter of the PCB wastes should have a spill contingency plan iden-
tifying procedures for containment, cleanup, and disposal of spilled materials,
as well as manpower, equipment, and material resources to be committed in
the event of a hazardous material spill. Documentation must be kept concern-
ing the cause and location of the spill, estimated volume spilled, bodies of
water threatened, response action taken, any further action proposed, and
measures taken to avoid similar future spills.
3.2.6 Preparedness and Prevention
Preparedness and prevention, as they apply to bulk transport operations,
should include leak checks of all transport equipment, maintenance of replace-
ment equipment, provision for emeigency containment and cleanup equipment,
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and notification of local agencies prior to initiation of transport opera-
tions. Although transport may be by rail tank car or tank truck, the approach
employed will be similar regardless of the selected mode.
Transport equipment should be leak checked prior to initiation of trans-
port operations. Tank cars and tank trucks should be pressure tested before
use. Additionally, valving will be observed uncapped during filling to detect
leakage. Leakage through uncapped valving greater than a drip will preclude
transport use until such leaks are repaired. Leakage through rivets, seams,
or couplings will preclude acceptance for transport use until appropriate
repairs have been performed. Pipeline integrity should be verified consis-
tent with American Society of Mechanical Engineers and DOT requirements.
Small leaks detected during operations should be contained in buckets
or drums until all contents can be safely pumped to an alternate transport
vehicle or a holding tank. Large leaks should be contained in diked areas
lined with fiberglass reinforced plastic until safe transfer can be performed.
The filling of any leaking equipment should be immediately terminated and
its contents be transferred to an alternate unit.
Vapor pollution can be controlled be minimizing open handling of PCB
wastes and equipping all transport equipment vents with activated carbon ad-
sorbers. Open handling of PCBs should be limited to drip containment during
coupling and uncoupling operations and leak or spill containment.
Bags of absorbent materials and emergency equipment such as shovels,
brooms, squeegees, pails, sandbags, and sheeting of fiberglass reinforced
plastic should be available in transport or accompanying vehicles for use in
emergency spill containment.
3.2.7 Emergency Procedures
During transportation of PCBs and PCB-contaminated materials to disposal
facilities, accidental spillage or leakage can occur. To control surface
transportation of hazardous materials, the Department of Transportation pub-
lished 49 CFR 170-178. All the regulations are designed to prevent spills
from occurring and to protect life and property. An EPA document entitled
"Manual for the Control of Hazardous Materials Spills: Volume 1 - Spill
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Assessment and Water Treatment Techniques" lists information regarding all
the activities that are necessary. Spill prevention procedures have also
been listed in the PCB Regulations (40 CFR 761).
If spills do occur and a good faith attempt is not made to clean up the
spill, then this constitutes improper disposal of PCBs and is a violation of
the Toxic Substances Control Act and PCB Regulations. Violations may result
in civil and criminal penalties. Federal regulations require that non-liquid
PCB-contaminated materials such as rags and sorbent materials (e.g., sawdust
or imbiber beads that have been used to absorb spilled fluids) be packed in
drums before shipment to appropriate disposal sites. Liquid wastes including
cleanup solvents such as kerosene and fuel oil must be packed in steel drums
of appropriate wall thickness and then must be put into secured storage areas
until disposal can be arranged. It is recommended that protective clothing
be used by the personnel during the cleanup operation.
It is advisable that cleanup personnel use some kind of self-contained
breathing apparatus because PCB fumes can be easily inhaled during this pro-
cess. A comprehensive inventory of other protective clothing appropriate for
spill cleanup is available in the U.S. Government Printing Office publication
"A Survey of Personnel Protective Equipment and Respiratory Apparatus for Use
by Coast Guard Personnel in Response to Discharge of Hazardous Chemicals".
3.3 CRITERIA FOR SELECTING PROCESSING FACILITY LOCATIONS
Major considerations in the selection of a potential site (or sites) for
the processing and storage of polychlorinated biphenyls are public safety and
protection of the environment. The site should meet the general criteria
listed below. It should be:
• Close to available PCB waste stocks
• Close to the designated ocean incineration site
t Close to suitable port facilities
• Located in a sparsely populated area (it could be located
in an industrial area)
• Secure, fenced, and have gates which provide controlled,
limited access
• Neither in a fault area nor in a 100-year flood plain
(this is a requirement unH°r RCRA regulations)
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t Located so as to minimize transportation time and distance
to the ship loading dock and the at-sea incineration site
• In compliance with all pertinent Federal, state and local
regulations
• Downwind of the nearest populated area
Due mainly to the first two listed considerations, the major site options
for the location of the PCB waste processing facility were on the Gulf of
Mexico or the mid-Atlantic Coast. A Gulf Coast location was chosen for the
following reasons:
• The Gulf Ocean Incineration Site has been officially designated,
whereas the Atlantic Ocean Incineration Site has not.
• A large proportion of the available PCBs are located in relatively
close proximity to the Gulf Coast.
• The option of having the Vulcanus make a stop at both a mid-Atlantic
Coast and Gulf Coast port was rejected because it did not appear
logistically or economically feasible and would have posed no fewer
problems from the standpoint of environmental harm or public safety.
• There are a number of ports in the Gulf Coast area capable of hand-
ling hazardous materials.
Suitable port facilities on the Gulf Coast include, for example, Houston,
Texas and Mobile, Alabama. The land-based processing facility could be
located in or near these ports.
3.4 PROCESSING OF WASTES AND CONTAINERS
Liquid PCB wastes slated for disposal by at-sea incineration must first
be removed from their shipping containers and processed for disposal. Waste
processing will include segregation of liquid PCBs according to the PCB con-
centration and the type of solvent present in the waste, removal of waste
from the shipping containers, decontamination of containers, and preparation
of containers for disposal. The most convenient facility for these operations
would be a waterfront processing facility consisting of storage tanks, waste
processing and handling equipment, a laboratory for waste analysis, and a
cargo transfer terminal. However, inland processing facilities would also
be suitable.
3.4.1 Processing Facility
The purposes of the processing facility are the following:
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• To receive liquid PCB wastes;
• To analyze, blend, and containerize the materials as appropriate
for incineration at sea;
• To load the waste aboard ship in a safe and efficient manner.
The ideal site for the facility would be located where potential environ-
mental impact is minimal, transportation time from the storage site and to
the ship loading dock minimal, and topography is convenient. Structural
standards must be carefully followed, and these are normally defined by the
Uniform Building Code and additional location-specific building regulations.
The design must also meet safety, health, and environmental criteria,
which include provisions for facility monitoring, personnel safety, and con-
tingency planning in the event of both major or minor releases of chemical
wastes that have the potential to reach soil, water, or air. In general,
these criteria are specified by federal regulations.
Federal regulations under RCRA require the owner/operator of a land-
based facility handling hazardous wastes which supports an at-sea incinera-
tion vessel to obtain a permit. The facility chosen to support the Vulcanus
should either:
• Have RCRA interim status, i.e., comply with the filing require-
ments of 40 CFR 122.22 and meet the applicable standards set
forth in 40 CFR 265, or
» Have a RCRA permit and meet the applicable standards set forth
in 40 CFR 264, or
• Have interim status or a final permit under an authorized state
RCRA hazardous waste program.
The processing facility must be designed to prevent emissions of hazard-
ous materials, contain spills, leaks and other accidents, and minimize harm
to personnel in the event of accidents. Planned measures might include the
following:
• Collection and disposal systems for vapors from waste transfer
• Detailed material balance audits
t Dry break valves which prevent spillage during disconnecting
• Above-ground plumbing and convenient access to fittings
• Use of corrosion resistant materials
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• Pipes sloped away from points of potential discharge
t Complete fire prevention and control systems
• Security provisions including guards and continuous fencing
around facility
• Special training in hazardous wastes for personnel
• Effluent and media monitoring in and around facility
• Dikes around liquid storage areas
A preliminary design for a waterfront waste processing facility has been
developed and described in a Report of the Interagency Ad Hoc Work Group for
the Chemical Waste Incinerator Ship Program (9). The general features of
this design will be applicable to the land-based processing facility selected
for processing PCB liquids.
3.4.2 Dedrumming Operations
Some of the PCBs to be disposed of by at-sea incineration will arrive
at the processing facility in 55-gallon metal drums from which they must be
removed prior to incineration. Overall dedrumming operations will include
draining the PCBs and rinsing the drums to render them safe for disposal.
Upon receipt at the processing facility, drums will be visually inspected
for damage and to insure that the contents are as indicated on the shipping
papers. There will be a preliminary segregation of wastes into two cate-
gories:
A = £500 ppm PCBs in organic solvent
B = <500 ppm PCBs in organic solvent
3.4.2.1 Applicable Regulations-
Annex III of the PCB Regulations, 40 CFR 761.42, specifies that no item
of movable equipment used for handling PCBs and PCB Items in the storage faci-
lities that comes in direct contact with PCBs shall be removed from the stor-
age facility area unless it has been decontaminated as specified in Annex
IV, Section 761.43. Annex IV requires that any PCB Container be decontami-
nated by flushing the internal surfaces of the container three times with a
solvent containing less than 50 ppm PCB. The solubility of PCBs in the
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solvent must be 5% or more by weight. Each rinse shall use a volume of the
normal diluent equal to approximately 10% of the PCB container capacity. The
solvent may be reused for decontamination until it contains 50 ppm PCB.
Empty drums must be disposed of in accordance with provisions of Section
761.10 of the PCB Regulations. Annex II (Section 761.41) specifies the lo-
cation, design, and operating requirements for chemical waste landfills suit-
able for disposal of PCBs and PCB Items.
3.4.2.2 Drum Handling—
A system developed to empty and rinse drums containing hazardous liquids
was used and evaluated in the case of dedrumming Herbicide Orange prior to
its thermal destruction onboard the M/T Vulcanus in 1977 00)- This, system,
which is described below, may be adapted for dedrumming liquid PCB wastes.
The 1.5 million gallons of Orange Herbicide stored on Johnston Island
represented approximately 25,000 drums of 55-gallon capacity. These were
stored in rows stacked three high in an area of about 3.5 acres on the north-
west corner of the island. A dedrum facility was modified* to allow transfer
of the material from drums to bulk carriers or pipeline for transport to the
ship. The facility and operation basically consisted of a covered concrete
pad and two fabricated metal racks upon which full drums were placed in four
groups of 12 each. Drums were transported from the drum yard in sets of four
using fork lifts equipped with specially designed clamps. Each set of 12
drums was handled independently by the dedrumming crew. Once the drums were
on the rack and the fork lift had withdrawn, a crew member would punch one
hole near the top of each drum to allow the crew's supervisory personnel *o
check the contents of the drum for Orange Herbicide. Any suspicious drums
were removed from the line and held for further testing prior to loading.
Three closely spaced holes were then punched in the bottom of each drum and
the fluid allowed to drain. A set drain period of 5 minutes was. determined
prior to testing to give the most rapid throughput of drums and still achieve
good drainage.
The facility had originally been installed for redrumming of leaking drums.
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Following the 5-minute drain, the inside of each of the drums was rinsed
with 1 gallon of diesel fuel using a spray wand. Operators were instructed
on the proper technique for covering the entire drum interior. After drain-
ing for 2 minutes, a second one-gallon spray rinse was initiated and 2 minutes
were allowed for draining herbicide and rinse into a trough which flowed into
a sump equipped with pumps to transfer the material to a tank truck. Studies
on the rinsing efficiency of Herbicide Orange from the drums showed that the
first and second rinses yielded the same efficiency of approximately 68 per-
cent removal each (total of 90% removal vs. 85% triple rinse).
It is essential for operation of the processing facility that the con-
tents and level of PCBs in the drums is known prior to dedrumming. Testing
should be done prior to processing to determine the concentration of PCBs in
cases where this unknown. The two waste types - PCB transformer and capacitor
fluids (PCB concentration £.500 ppm), and PCB-contaminated mineral oil and
other organic liquids (PCB concentration 50-500 ppm) - should be processed
and stored separately. Each type of waste should be stored and processed with
other wastes of the same type upon receipt at the facility and throughout
processing, interim storage, and ship loading.
Rinsate from drum decontamination which contains less than 50 ppm PCB,
should be stored in a tank separate from the PCB liquid wastes and reused for
additional rinsing. Rinsate that becomes contaminated with more than 50 ppm
PCB could be blended with type B wastes. Appropriate solvents for rinsing
include kerosene, xylene, toluene or other solvents in which PCBs are readily
soluble. The number of rinses required and the quantity of solvent to be
used per rinse are specified in Annex IV of the PCB regulations and were dis-
cussed in Section 3.4.2.1. Since a volume equal to 10% of the container
capacity is required for each of the three required rinses, the quantity of
solvent needed will range from 10 to 30% of the container capacity depending
on how often it can be reused before reaching a concentration of 50 ppm PCB.
Alternate procedures for rinsing may be used if they can be shown to be equi-
valent to a triple rinse.
PCBs arriving in tank cars or trucks should also be tested before pump-
ing to the appropriate storage tank if the contents are unknown. The tank
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cars will be decontaminated as specified 1n Annex IV. The rinsate solvent
will be reused until it contains 50 ppm PCB.
3.4.2.3 Vapor Disposal —
Control and disposal of vapors released during PCB dedrumming is essen-
tial for protection of personnel and the environment. Under the provisions
of 29 CFR 1910,1, the Occupational Safety and Health Administration (OSHA)
TWA* (air) for Aroclor 1242 is 1 mg/m3 and the TWA (air) for Aroclor 1254 is
0.5 mg/m . In September 1977, the National Institute for Occupational Safety
and Health (NIOSH) recommended a time-weighted average for all PCBs of 1.0
ug/m (18). However, this is a recommendation and is not legally binding.
The OSHA standard has not yet been changed. The current threshold limit
value (TLV) for PCBs as established by the American Conference of Governmental
Industrial Hygienists (ACGIH) is 0.5 mg/m3.
The solvent kerosene, which may be used in drum rinsing, is sufficiently
volatile that the maximum allowable time weighted average concentration of 15
ppmv may be exceeded in an enclosed structure if vapors are not controlled.
The preferred method for disposing of vapors from the dedrumming operation is
by incineration. Facility air exhaust could be piped directly to an on-site
incinerator as part of combustion air feed. A second method of vapor control
is venting through activated charcoal absorbers before reaching the atmosphere.
This procedure was utilized during Herbicide Orange dedrumming operations at
Gulfport, Mississippi. Negative pressure maintained within an enclosed de-
drumming facility by the ventilation system would minimize fugitive emissions.
3.4.2.4 Facility Monitoring—
Monitoring of the processing facility: 1) aids in the detection of
spills and leaks or vapor buildup from equipment malfunction; 2) ensures
adequate industrial hygiene; and 3) provides a measure of environmental
impact concurrent with facility operations. Hence, multimedia monitoring
should be an integral part of the dedrumming operation. A basic approach
to air quality monitoring for chlorinated hydrocarbons has been discussed
*TWA = Time-Weighted Average, the concentration to which a worker can be
exposed for 8-hour days and 40-hour weeks indefinitely without ad-
verse effects.
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in the operations plan for at-sea incineration of liquid silvex (11) and is
anticipated to be applicable to liquid PCB wastes. Basically, this consists
of collecting samples in an absorption tube filled with a solid polymeric
adsorotion medium. An alternative is the use of continuous hydrocarbon moni-
tors such as flame ionization detectors.
3.4.2.5 Water, Soil, and Sediment Monitoring--
Water quality monitoring should be concentrated on fresh water drainages
in close proximity to the processing facility and on any effluents from the
facility. All process water outfalls whether originating from direct equip-
ment contact (i.e., pump seal flush water, cleanup water, etc.) or secondary
contact facilities (i.e., laundry facility effluents) should be included.
Composite samplers should be utilized where appropriate and aliquots collected
daily for analysis. In addition to analysis for PCBs, analyses for dissolved
oxygen, temperature, and pH should be determined daily. Water quality moni-
toring should commence about three days prior to facility operations and con-
tinue for about three days following facility shutdown.
Sediment samples should be obtained at all locations selected for water
quality monitoring during pre- and post-operational monitoring. Additional
sediment samples may be obtained during dedrumming operations as indicated
by water quality monitors.
Soil samples should be collected from areas subject to the highest concen-
trations of PCBs. At a minimum, soil samples should be collected from loca-
tions downwind of the processing facility, directly adjacent to the process-
ing facility, at any PCB transfer or storage areas for which concrete pads
are not provided, and in the vicinity of any known spills. Soil samples
should be obtained during pre- and post-operational monitoring. Additional
soil samples may be obtained during dedrumming operations based upon indica-
tions from operations, air, or water quality data.
3.4.2.6 Drum Disposal-
Drums will be rendered suitable for disposal following decontamination.
Handling of drums for disposal could be expedited by crushing prior to trans-
port to the disposal site. Spray shields should be used around the crusher
to trap any residual oils or solvents which are released on imoact. Crushed
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drums should be bundled and stored for disposal in such a manner that there
is no danger of rainwater washing any residuals into the surrounding environ-
ment. Drums could be scrapped, recycled, or disposed of in landfills that
meet the criteria set forth in Annex II of the PCB Regulations.
3.4.2.7 Personnel Safety-
Maintenance of personnel safety requires implementation of an effective
personnel hygiene program and appropriate safety procedures. Workers may be
exposed to PCBs as a consequence of equipment malfunction or breakdown, leaks,
spills, and various accidents.
There are three routes by which a toxic agent can enter the body: inges-
tion, inhalation and skin absorption. Ingestion or swallowing of industrial
products is sometimes encountered when workers eat or smoke without washing
or when foods or cigarettes are stored near where toxic materials are used.
Skin absorption is a more insidious or hazardous route of entry into the body
than ingestion because it is not easily noticeable. It generally occurs dur-
ing transfer and handling of products or chemicals. Inhalation is a more
general hazard than ingestion or skin absorption because no visible physical
contact between the worker and the compound is required. Airborne particu-
lates, gases, and vapors not only contaminate the work space, but due to trans-
portation by air, currents also contaminate the surrounding areas.
It is difficult to differentiate between industrial exposure by inhala-
tion and dermal absorption. Animal studies do indicate that animals exposed
to PCB aerosols show rapid increases in liver PCB levels. Airborne exposure
to Pyranol A200 for 15 minutes was reported to have resulted in the accumu1a-
tion in the liver of 50 percent of the PCBs accumulated after two hours (12).
The lung appears to be a good site of absorption, and certain occupational
environments contain significant levels of airborne PCBs. The National
Institute of Occupational Safety and Health has recently proposed an occupa-
tional exposure limit of 1.0 yg/m on a time weighted average 10-hour day,
40-hour week basis (Natl. Inst. Occup. Safety Health, 1977). Assuming a
tidal air volume of 10 m in an eight hour day and 100 percent absorption,
the resulting dose at this exposure level would be 10 wg/day.
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The comprehensive health and safety olan developed for protection of
shipboard personnel during the Incineration of Herbicide Orange (13) can be
adapted for use In the PCB processing facility. The safety plan is discussed
in detail in Appendix B. The concept of isolation of contaminated areas and
preservation of "clean" areas should be utilized during dedrumming operations.
An interface area should be maintained which will ensure the integrity of the
clean area and the safety of personnel therein while isolating contaminated
areas. Adherence to this concept will prevent PCB contamination of facilities
suitable for eating, drinking, smoking, and final clothing changes prior to
departure from the facility. The routes by which personnel move should be
arranged so that the entrance to the working area and exits from the working
area are separate, thereby preventing possible confusion and subsequent con-
tamination of clean changing facilities.
Basic requirements for effective personnel hygiene during dedrurming
operations are:
• Protection of personnel from vapor and liquid contact in the
contaminated areas by source control and protective gear.
• Provision for contaminated clothing collection facilities at
the interface region between the contaminated and clean areas.
• Provision for shower, hand, face, and eye-washing facilities
at the interface region.
• Provision for clean work clothing and footwear at the boundary
of the interface region between the contaminated and clean areas.
• Instruction in the use of cleaning equipment and protective equip-
ment and in the methods of personal cleansing.
t Mandatory and enforced use of the above facilities and concepts.
Equipment utilized during the Herbicide Orange decanning operations and
which are applicable to PCB dedrumming operations are as follows:
• Clean or disposable coveralls which should be provided prior to
admission to the work area.
• Impervious footwear which should be provided prior to admission
to the work area and worn at all times therein.
• NIOSH approved gas respirators which should be worn at all times
when working in the vicinity of open PCBs or other areas of
potentially high vapor concentrations.
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• Rubberized splash aprons which should be worn when working in
the vicinity of open PCBs.
• Rubber gloves which should be worn when handling PCB drums or
equipment subject to direct PCB contact.
• Face shields which should be worn when working with any dedrunming
or transfer equipment requiring open handling of PCBs or the un-
coupling of equipment which has been in direct contact with PCBs.
0 Safety goggles which should be worn in the vicinity of any PCB
dedrurming or transfer equipment which is in service.
Designation of specific safety equipment for use during PCB dedrumming
operations will be made by health and safety representatives of the selected
facility contractors). Considerations influencing equipment selection in-
clude facility design and the efficiency, comfort, and ease of operations of
safety equipment. All personnel working in contaminated areas should be
given complete pre- and post-operational medical examinations.
3.4.2.8 Spill Prevention and Control-
Prevention of spills of hazardous materials is far superior to cleanup.
An established safety procedure is mandatory under the Clean Water Act for
safe spill control and prevention. A spill coordinator should be assigned
for each PCB processing facility. He should be thoroughly familiar with es-
tablished safety and reporting procedures. All other psrsonnel likely to be
confronted with a PCB spill should also be aware of the proper reporting pro-
cedures prior to any actual spill.
Reportable quantities for substances designated as hazardous under
Section 311(b)(2)(A) of the Clean Water Act and requirements for notification
in the event of such discharges have been established by EPA [40 CFR Part
117]. The regulation applies to quantities greater than or equal to the
reportable quantity when discharged into or upon navigable waters of the
United States, adjoining shorelines, into or upon the contiguous zone or be-
yond the contiguous zone. The reportable quantity for polychlorinated bi-
phenyls has been set at 10 pounds (4.54 kg) (20).
In addition to the requirements of National and Regional Contingency
Plans, any State reporting requirements must also be met. U.S. Coast Guard
Regulations require that spills of hazardous substances that may affect water
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sources should be reported to the National Spill Response Center. Appropri-
ate methodology for the control of PCB spills and reporting procedures is
addressed In the EPA documents, "Manual for the Control of Hazardous Material
Spills," EPA-600/2-77-227 (14,22).
3.4.2.9 Public Risk—
The extent of public risk during dedrumming operations is limited to
potential contamination due to vapor escape and spills or discharges which
could contaminate adjacent aquifers. The approach to dedrumming liquid PCBs
and maintenance of attendant industrial health and environmental monitoring
programs described herein are modeled after some of the approaches and pro-
grams successfully utilized by the U.S. Air Force during the Herbicide Orange
disposal program. Hence, public risk associated with dedrumming operations
following the procedures presented above should be low.
3.4.2.10 Contingencies and Emergency Procedures—
Key elements of a contingency plan include preparedness, prevention,
notification, and emergency procedures. Perhaps the most important factor
in reducing risks during dedrumming as well as in all other phases of this
disposal action, is proper training of involved personnel. Additionally,
clear definition of responsibilities of all participating organizations and
the preparation of and adherence to detailed operating procedures will lead
to minimized risk to personnel and the environment. Personnel involved in
dedrumming operations (and in all other program phases) will receive compre-
hensive briefings on operations and will have to demonstrate adequate under-
standing of detailed operating procedures. Of all program tasks, dedrumming
operations pose the greatest risk of exposure of personnel to PCBs. Dry runs
of dedrumming as a part of training should be required.
The entire dedrumming-storage facility will be surrounded by a trench
or diking to effect spill containment 1n the event of failure of dedrumming
or bulk storage equipment. Bags of absorbent material will be situated
throughout the processing facility for use in the event of spills. Emergency
equipment such as shovels, brooms, squeegees, pails, sandbags, and sheeting
of fiberglass reinforced plastic will be prominently situated and available
for use in containment of any soills. On-site personnel will be trained in
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the use of the emergency equipment prior to initiation of dedrumming opera-
tions.
In the event of an incident, rapid notification of the appropriate agen-
cies and implementation of corrective measures are of utmost importance. A
release of any quantity of PCBs that either reaches or has the potential of
reaching soil, water, or air will be reported to the facility emergency coor-
dinator by the first individual on the scene. Notification will be made by
the fastest means of communication available. Minor spills, leaks, or other
discharges of small quantities of PCBs will be handled at the discretion of
the facility emergency coordinator.
All incidents must be carefully documented with respect to time, location,
severity, cause, type of pollutant, etc. The recommended notification format
is the U.S. Air Force Pollution Incident Notification Format, AFR 19-1, Items
1 through 12. Incidents which are judged major by the facility emergency
coordinator additionally require immediate notification of the project direc-
tor and the following:
t EPA Regional Administrator or his designee
• Emergency Response Division, Office of Hazardous Emergency
Response, EPA, Washington, D.C. (duty hour operation)
• U.S. Coast Guard (USCG) National Response Center (NRC),
Washington, D.C. (24-hour operation)
• Director, Center for Disease Control, U.S. Public Health
Service, Atlanta, GA.
For incidents that occur during non-duty hours, the NRC will use a list
of on-call personnel from the Emergency Response Division of EPA to implement
notification.
Incidents which have the potential for reaching coastal waters are under
U.S. Coast Guard jurisdiction. In those cases, initial spill notification
will be made to the appropriate USCG District Headquarters. Previously listed
notifications will be made immediately following Coast Guard notification.
In the event that notifying personnel are unable to contact an above-
listed agency, the next listed agency will be contacted immediately. Follow-
ing initial completion of the above scheme, contacting personnel will again
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attempt to contact any missed agencies. This procedure will continue until
all agencies have been contacted.
Detailed emergency procedures should be prepared consistent with the
selected processing operations and facility. Spend absorbent and contamin-
ated sheeting and sandbags should be placed in separate storage drums,
properly marked, and stored for future disposal. Decontamination, subsequent
to containment, should include clearly marking affected land areas for pene-
tration tests. Upon determining the extent of penetration, affected soil
should be removed, placed in empty drums, properly marked, and stored for
future disposal. To the extent that it is feasible, contaminated waters
should be collected for subsequent disposal.
3.5 INTERIM STORAGE OF BULK LIQUIDS
Any interim storage of dedrummed PCB liquids should be in tanks at the
processing facility. OSHA has prepared comprehensive tank specifications
[29 CFR Part 1910.106] based on standards developed by the American Society
of Mechanical Engineers and the American Petroleum Institute. With liquids
which have a specific gravity greater than 1.0, such as some PCB fluids, pre-
cautions must be taken to insure that an adequate factor of safety exists
when evaluating the structural strength of the tanks due to the heavier stress
put upon tanks by liquids with higher specific gravities.
The PCB Regulations contain specific requirements for temporary storage
of PCBs and PCB Items which are designated for disposal. These are outlined
in Annex III, Section 761.42.
Facilities for the storage of PCBs and PCB Items designated for disposal
must, at a minimum, meet the following criteria [40 CFR 761.42(b)(l)]:
• Adequate roof and walls to prevent rain water from reaching the
stored PCBs and PCB Items;
• An adequate floor which has continuous curbing with a minimum six
inch high curb. The floor and curbing must provide a containment
volume equal to at least two times the internal volume of the
largest PCB Article or PCB Container stored therein or 25 percent
of the total internal volume of all PCB Articles or PCB Containers
stored therein, whichever is greater;
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• No drain valves, floor drains, expansion joints, sewer lines,
or other openings that would permit liquids to flow from the
curbed area;
• Floors and curbing constructed of continuous smooth and Imper-
vious materials, such as Portland cement contrete or steel, to
prevent or minimize penetration of RGBs; and
• Not located at a site that is below the 100-year flood water
elevation.
In addition to the 761.42(b)(l) criteria, the following guidelines should
be considered in evaluating the storage facilities:
• Storage capacity should be adequate to accept all incoming waste
shipments and should slightly exceed the maximum desired inventory.
t Incompatible corrosive or reactive wastes should be segregated in
the storage area.
• Materials used in construction of storage tanks for PCBs should
be compatible with the physical and chemical form of the waste
contained.
• PCBs should not be stored in an unwashed tank which previously
contained incompatible materials.
t If underground storage tanks are used, provisions for gaging,
pumping, and leak detection should be such as to minimize the
possibility of a PCB release. Above-ground storage is preferred.
• Provisions for drainage of diked areas should assure that un-
controlled discharge to storm drains or surface waters does not
occur. This may necessitate pumping stormwater drainage to an
on-site pond or treatment system and pumping spilled wastes to
alternate storage tanks.
• Spill cleanup equipment and supplies should be available to con-
tain spills.
• Personnel safety equipment and procedures should be used as
needed.
Temporary storage in an area that does not meet the 761.42(b)(l) cri-
teria is allowed for up to thirty days in some cases, provided the date of
removal from service is attached to the PCB Item or PCB Container. Tempor-
ary storage is allowed for PCB Containers containing non-liquid PCBs such
as contaminated soil, rags, and debris; and for PCB Containers containing
liquid PCBs at a concentration between 50 and 500 ppm, provided a Spill
Prevention, Control and Countermeasure Plan has been prepared for the tem-
porary storage area in accordance with 40 CFR 112. In addition, each con-
tainer must bear a notation that indicates that the liquids in the drum do
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not exceed 500 ppm PCB. Temporary storage is not allowed for high concentra-
tion PCB liquids (£500 ppm).
3.6 TRANSPORTATION TO THE SHIP LOADING SITE
The anticipated location for the ship loading site is on the Gulf Coast.
Based on a preliminary survey of terminal facilities capable of serving an
at-sea incineration ship (21), adequate facilities are available at Houston,
Texas and Mobile, Alabama to handle liquid PCB wastes.
Liquid PCBs and rinsate from the dedrumming and cleaning operations will
be transported to the ship loading site by the available method considered
to be most consistent with public safety and protection of the environment.
Alternative transportation modes are a significant factor in selecting both
the dedrumming facility and ship loading sites. Monitoring during transport
will minimize public risk. A detailed contingency plan should be prepared
and implemented for the transportation mode selected.
3.6.1 Administrative and Legal Constraints
Transportation of hazardous material is regulated by the U.S. Environ-
mental Protection Agency under RCRA regulations, 40 CFR 250.22 to 250.24.
These standards are coordinated closely with and incorporate by reference
applicable U.S. Department of Transportation regulations for identification
and transporting of hazardous materials, 49 CFR Parts 171-173 and 179.
3.6.2 Criteria for Selecting Loading Sites
Existing port facilities will be utilized for loading of PCBs onboard
the incinerator ship. Site selection criteria include:
• Adequacy of port facilities for safe harboring and loading of
the incinerator vessel.
• Minimizing transportation time and distance from the processing
facility.
• Minimizing transport time to and from the selected incineration
site.
Controlled access to the ship loading dock must be maintained from the
start of loading operations until ship departure from port. Required port
facilities include emergency equipment and personnel. Loading and spill con-
trol operations onboard the ship will be performed by the ship's crew under
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procedures discussed in Section 3.7.2. Land-based loading and spill control
operations will be performed by personnel from the processing facility as
discussed in Section 3.7.2. Monitoring of ship loading will be conducted as
described in Section 3.7.4.
3.6.3 Transportation Modes
Alternative means of transporting the PCB waste from the processing faci-
lity to the ship loading site are by pipeline, rail tank car, and tank truck.
All of these options may not be available at the selected dedrumming and dock-
ing sites.
A direct pipeline for transporting hazardous liquids from the dedrumming
site to the loading dock will present minimal public risk. However, this mode
would be economically feasible only if an existing pipeline is available be-
tween the port and a suitable processing facility. Decontamination of the
pipeline by rinsing will be required after all of the PCB liquids have been
transferred to the ship.
PCB liquids should be transferred to the ship in decreasing order of con-
centration, the most concentrated wastes being pumped first, to minimize the
quantity of rinsate required as much as possible. Pipeline rinsate can also
be loaded onboard ship for incineration.
Rail tank cars are the next choice for transporting bulk PCBs. This mode
was utilized for Herbicide Orange transfer from the drum handling facility
at Gulfport, Mississippi to the ship loading dock (15,16). Cars were moved
the short distance to the dock at a low speed (about 5 km per hour) with
guards at all rail crossings and absorbent materials present nearby to con-
tain potential spills. Current DOT regulations (49 CFR 179) limit rail tank
cars to 130 m in volume. Tank trucks may also be used, preferably by pri-
vate roadways. Use of public roadways presents the risk of accidents and
potential spills.
Tank cars or tank trucks can be decontaminated effectively by employing
a triple rinse approach and spraying the interior of holding vessels with
the rinse liquid. Details of the decontamination procedures will be con-
sistent with the recommended procedures for decontamination of PCB Containers,
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40 CFR 761.43. Because the rinsing solvent may be reused for decontamination
until it contains 50 ppm PCB, rinsing the tank cars/trucks which contained
low concentration wastes first may allow the solvent to be reused to a greater
extent, thereby decreasing the total quantity of solvent needed.
3.6.4 Monitoring During Transport
Visual monitoring will be employed during PCB loading, transport, and
unloading. In the event of pipeline transport, seams, rivets, and fittings
will be periodically examined for signs of leakage. All incidents of leak-
age will be handled as described in the contingency plan, Section 3.7.6.
Monitoring of tank trucks or tank cars during loading will be performed
in compliance with DOT regulations, 49 CFR 173.31(b)(l) and 174.8 through
174.10, respectively. Valves, rivets, seams, and couplings will be observed
during filling to detect leakage. Any leakage will preclude acceptance for
transport use until repairs are performed.
Personnel should be designated for observation of tank trucks or tank
cars during transport. Monitoring en route can be performed from adjacent
vehicles or vantage points or by periodically halting the transport vehicle
for examination, as is appropriate.
Air quality monitoring should be performed in the vicinity of loading and
unloading areas to detect vapor escape and spills. Monitor locations and
sampling frequency will be specified by the on-site safety director. It is
anticipated that one ambient air monitor will be located at the loading area
and one will be located at the unloading area.
3.6.5 Public Risk
The degree of public risk during bulk transport of liquid PCBs to the
loading site will depend upon the transportation method selected and the
proximity of the processing facility to the loading site. In general, public
risk due to potential spills or vapor escape will be minimized when the de-
drumming and ship loading facilities are coterminous. Pipeline transport
eliminates the risks associated with collision or derailment. In the case of
tank trucks, facilities which are mutually accessible by private roadways
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would reduce public risk since they obviate the need for transport on or near
public roadways.
In the event that transport on or near public thoroughfares is required,
the extent of public risk will be dependent upon the traffic and routing.
Risks would be minimized by transport through areas of lowest habitation and
along routes on which other traffic has been suspended. Although public
risk during transport is difficult to assess, it will be minimized by proper
routing and appropriate monitoring and contingency planning.
3.6.6 Contingencies
The key elements of contingency planning: preparedness, prevention, noti-
fication, and emergency procedures, will be generally discussed in the follow-
ing sections. A detailed contingency plan will be prepared in accordance with
RCRA regulations in 40 CFR 250,43-3 and Section 311 of the Clean Water Act
upon selection of processing and docking facilities, bulk transport modes, and
principal program participants.
3.6.6.1 Preparedness and Prevention—
Preparedness and prevention, as they apply to bulk transport operations,
will include leak checks of all transport equipment, maintenance of replace-
ment equipment, provision for emergency containment ana cleanup equipment, and
notification of local.agencies prior to initiation of transport operations.
Although transport may be by rail tank car, tank truck, or pipeline, the ap-
proach employed will be similar regardless of the selected mode.
Transport equipment will be leak checked prior to initiation of trans-
port operations. Tank cars and tank trucks will be pressure tested before
use. Additionally, valving will be observed uncapped during filling to de-
tect leakage. Any leakage greater than a drip will preclude transport use
until such leaks are repaired. Similarly, any leakage through rivets, seams,
or couplings must be repaired prior to transport. Pipeline integrity will
be verified consistent with American Society of Mechanical Engineers and
DOT requirements.
Small leaks detected during operations should be contained in buckets
or drums until all the contents can be safely pumped to an alternate
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transport vehicle or a holding tank. Large leaks should be contained in
diked areas lined with fiberglass reinforced plastic until safe transfer can
be performed. The filling of any leaking equipment will be immediately termi-
nated and its contents will be transferred to an alternate unit.
Vapor pollution can be controlled by minimizing open handling of the
wastes and equipping all transport equipment vents with activated carbon ad-
sorbers. Open handling of PCBs will be limited to drip containment during
coupling and uncoupling operations, and leak or spill containment.
A communications system will be used immediately by monitoring personnel
and transport vehicle operators to report any unusual incident. All thorough-
fares or rail crossings will be manned in an effort to minimize the potential
for collisions, if feasible. All transport vehicles will travel at speeds
consistent with safe practice for dangerous cargo.
Bags of absorbent materials and emergency equipment such as shovels,
brooms, squeegees, pails, sandbags, and sheeting of fiberglass reinforced plas-
tic should be prominently situated along the transport route or available in
accompanying vehicles for use in emergency spill containment. Adequate per-
sonnel should be available at appropriate stations during transport to effect
rapid emergency spill containment.
3.6.6.2 Emergency Procedures—
Detailed emergency procedures should be prepared consistent with the
selected transport modes, routings, and facility locations. Spent adsorbent
and contaminated sheeting and sandbags should be placed in separate storage
drums, properly marked, and stored for future disposal. Decontamination sub-
sequent to containment, will include clearly marking affected land areas for
penetration tests. Upon determining the extent of penetration, affected soil
should be removed, placed in empty drums, properly marked and stored for fu-
ture disposal. To the extent that it is feasible, contaminated waters should
be collected for subsequent disposal.
Emergency notification procedures are identical to those detailed in Sec-
tion 3.4.2.10 with the added provision that all notifications required by lo-
cal regulations will be carried out.
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3.7 SHIP LOADING
Loading of PCBs onboard the incinerator vessel can be conducted using
procedures adapted from those developed for Herbicide Orange operations (16,
17). Monitoring of ship loading should be performed to ensure personnel
safety. A detailed contingency plan should be developed including spill pro-
tection and emergency procedures. Wastes loaded onboard the ship must have
a chlorine content not greater than 30 to 40% and a net heating value of at
least 6300 Btu/lb, i.e., they must be able to support combustion without
auxiliary fuel.
3.7.1 Administrative and Legal Constraints
Federal regulations controlling the entrance of toxic pollutants into
U.S. waters are applicable to ship loading of PCBs at U.S. ports. They in-
clude:
• Resource Conservation and Recovery Act
• Hazardous Materials Transportation Act
t Ports and Waterways Safety Act
t Clean Water Act
The National Oil and Hazardous Substances Pollution Contingency Plan also
defines responsibilities and notification procedures for controlling spills
of hazardous materials into U.S. Coastal waters. In addition, each port faci-
lity may impose local requirements on loading procedures and spill prevention
measures. Pilots may also be required onboard to direct movement of the in-
cinerator vessel while entering and leaving port.
3.7.2 Loading Procedure
There are two distinct areas of responsibility in shiploading operations:
shipboard and land-based. Using the Vulcanus as an example, the ship has de-
tailed procedures for shipboard activities: connecting the loading hose to
the loading manifold, operating valves to load the various tanks, gauging the
tanks, and monitoring for shipboard leakage. The ship's procedures do not
cover, for example, operating the land-based pumping system and connecting the
pumping system to the PCB transportation vehicle, pipeline, or dockside tank.
The responsibility for obtaining an adequate pumping system and preparing
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land-based procedures for ship loading should rest with the dedrumming con-
tractor and the ship owner. Close coordination between EPA, the dedrumming
contractor, the monitoring contractor, the ship, and other parties, such as
the U.S. Coast Guard (USCG), will be necessary.
The risk of environmental contamination from a potential spill can be
minimized by isolating the land-based pumpCs) within a basin constructed with
sandbags and lined with impermeable plastic. Flexible transfer hose should
be used, with containers and absorbent material positioned to catch possible
leaks at connections.
3.7.3 Personnel Safety
Appropriate protective clothing will be the chief means of assuring per-
sonnel safety during loading. Personnel who make connections to the transport
vehicle and the pumping system and who tend the pumping system will be pro-
vided with impervious boots and aprons, fresh coveralls daily, goggle-type
safety glasses, and heavy rubber gloves. Respiratory protection will be em-
ployed as required, consistent with the specific transfer operations performed.
At shift change, boots, aprons, and gloves should be hosed off and stored at
the loading site. Pump operators should shower and change into clean clothing
in facilities located as close as possible to the loading site. Used cover-
alls will be laundered after each use. Precautions should be taken to avoid
discharge of contaminated wash water.
Once the exact location of the loading facilities have been determined, a
more detailed safety plan will be written. The boundary isolation concept
used onboard the ship to maintain clean areas should be adapted to loading op-
erations. Essentially, the area around the transport vehicle-pump system-ship
interfaces will be defined as contaminated. All other areas will be designated
as clean. Showers, fresh clothing, and used clothing should be available right
at the dock, if possible. If this is impossible, however, boots, aprons, and
gloves should be left at the dock. Fresh coveralls should be donned before
leaving the dock, if possible.
If donning fresh coveralls at the dock is impossible, the vehicle return-
ing personnel will be designated as contaminated. Personnel will shower at
the processing facility prior to leaving the plant. Fresh coveralls will be
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donned at the processing facility by personnel going on shift for pumping
duties.
3.7.4 Monitoring
The chief means of monitoring during loading operations will be visual.
The ship's engineers are in attendance continuously during loading, checking
for leaks and monitoring tank filling. Onshore pump operators will maintain
continuous surveillance of all connections, joints, etc. in the pumping system
during pumping operations.
The likelihood of release of measurable quantities of liquid PCBs to the
air is considered quite low. Thus, use of a single monitoring instrument at
dockside should be sufficient.
3.7.5 Public Risk
Public risk is low during ship loading operations. The population around
docks is small. If the ship loading dock is a private one dedicated to waste
handling, the possible exposed population will be very small. The only situa-
tion that could give rise to substantial risk would be extreme fire damage to
the ship, which could result in releasing substantial toxic cargo into the
port area. Potential spills resulting from leaks or broken fittings or joints
in the pump system would be small because operators will be in continuous atten-
dance.
3.7.6 Contingencies
A more detailed contingency plan will be developed once the ship loading
site and other factors have been defined. This section describes some fea-
ture which may be included in such a contingency plan.
3.7.6.1 Control of the Ship—
The U.S. Coast Guard (USCG) Captain of the Port will control the movement
of the ship in the harbor and exercise all necessary actions to prevent acci-
dental collision in the harbor, including restricting the movement of other
vessels. The EPA Program Director will notify the USCG Marine Safety Office
of the date ship loading is expected to start and the estimated date and time
of departure. The USCG will make a safety broadcast Notice to Mariners
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advising ship traffic to exercise caution in the vicinity of the harbor.
Ship loading operation hours need to be defined, but may be limited to
daylight hours. Upon departure, tugs may be necessary to assist the loaded
vessel. The USCG, in coordination with the Port Authority, will escort the
vessel from the port to the open sea.
3.7.6.2 Problems in the Harbor-
Any incident involving the ship or loading operations will be reported as
soon as possible to the EPA On-Site Director (EPA-OSD). The time and nature
of the problem, the impact on cargo and ship loading, and requirements for
assistance must be reported. A detailed log of problems will be maintained
by the ship's Master and by the EPA-OSD.
Actions taken will depend on the nature of the problem. The goal is
zero release of PCBs to the environment. If the problem does not pose a
threat of cargo spill, all normal maritime casualty procedures will be fol-
lowed. If the Port Captain determines that the cargo must be removed prior
to moving the vessel, he will advise the EPA-OSD who will arrange for removal.
The charterers of the vessel will arrange for towing and effect repairs satis-
factory for Coast Guard clearance. During such repairs, the EPA-OSD, in coor-
dination with USCG, will take all reasonable measures to maintain the inte-
grity of the cargo and environment.
3.7.6.3 Spills in the Harbor-
Containment equipment should be available to mitigate spills. In the
event of a spill in the harbor, the EPA-OSD and/or the ship's Master will
notify immediately the appropriate EPA Regional Office, the USCG's National
Response Center, and EPA's Emergency Response Division, Office of Hazardous
Emergency Response.
The EPA-OSD and ship's Master will also take action to prevent further
loss of PCB waste. Such actions might include: 1) isolation of the spill
source by discontinuing pumping operations; or 2) pumping cargo from the
faulty container, tank car, or vessel cargo tank to an empty, prepositioned
tank truck or tank car on site.
The responsibility for initiating cleanup action resides with the EPA-
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OSD. His decisions will be based on the amount of waste spilled, the location
of the spill, accessibility or depth of water, and reasonable prospects of re-
covery. Small spills, drips, or leaks can be contained using "oil-sorb".
Large spills on land may be pumped into a prepositioned tank truck or rail
car.
3.8 PUBLIC NOTIFICATION AND PARTICIPATION
The PCB Regulations do not explicitly discuss public notification or
participation in the disposal process. However, there is ample evidence of
local public concern about and opposition to hazardous waste transport and
disposal operations. Thus, local support for the PCB disposal action will be
very helpful, if not essential. This section will describe steps that can be
taken to enhance public support by providing for an informed public. It will
also describe some pitfalls to be avoided.
EPA recently published a proposed policy on public participation in
Agency decision-making and rulemaking (45 FR 28911). To ensure effective
public participation, EPA defined five basic tasks to be performed. These
are described briefly below.
• Identification. Those groups or members of the public who may
be interested in or affected by the action should be identified.
• Outreach. Information about the PCB disposal action must be
conveyed to the public through mailings, personal communica-
tions, public service announcements, media briefings or ads,
and other means. The information must include background, time-
tables, summaries of technical material, and, if possible, a
description of social, economic, and environmental consequences.
• Dialogue. The responsible official and interested or affected
members of the public must be able to exchange views and explore
issues. The dialogue may take several forms: meetings, work-
shops, hearings, or correspondence. Timely dissemination of in-
formation is crucial.
• Assimilation. The results of the "outreach" and "dialogue" tasks
must be assimilated into the final decision, and the responsible
official must demonstrate that he has understood and considered
public concerns.
• Feedback. The responsible official must provide feedback to
interested parties concerning the outcome of the public's
participation. This feedback must state the action that was
taken and indicate the effect that public participation had
on the action.
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Public concern caused considerable delays in performing a PCB destruc-
tion test in an industrial boiler at General Motors' Chevrolet plant in Bay
City, Michigan. Zelenski, Hall, and Haupt (23) reported on deficiencies in
the public participation process. The major deficiencies were:
• The public was not informed of the proposed permit application
in the early planning stages.
t Special interest groups were not informed of the proposed permit
application in the early planning stages.
• Plant personnel were not informed in the early planning stages.
t Information needs of the public and special interest groups were
not adequately anticipated.
• Information supplied was perceived as too technical.
t There was a lack of communication, coordination, and clearly
defined responsibilities between participants in the permit
approval process.
Zelenski, Hall, and Haupt (23) made a number of recommendations, several
of which are basically the same as defined in EPA's proposed policy on public
participation:
• Identify the concerned public and groups.
• Communicate with the concerned public and groups.
9 Develop a relationship of cooperation with the public and
groups.
• Determine the level of support and incorporate that in plans
for the proposed action.
It is recommended that a public participation work plan be developed for
the PCB disposal action. Such a plan should consider potential public con-
cerns which may arise from the following:
• Transportation of PCBs from and through areas of high population
density
a Processing and storage of PCBs at a land-based facility
• Incineration of PCB wastes at-sea.
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4. AT-SEA OPERATIONS
This section describes the at-sea operations of the PCB disposal program,
including incineration and ship cargo tank decontamination procedures. Also
described are criteria and procedures for selecting an at-sea incineration
site and obtaining an ocean dumping permit.
4.1 INCINERATION SITE SELECTION
The Marine Protection, Research and Sanctuaries Act (MPRSA) gives the
EPA authority to regulate at-sea incineration. Pursuant to MPRSA, EPA has
promulgated regulations and criteria for ocean dumping, which include incin-
eration at sea (40 CFR 220-229). Ocean incineration sites are designated by
EPA using criteria set forth in 40 CFR 228, based on environmental studies of
the site and adjacent regions.
Two ocean incineration sites were the prime candidate sites for incinera-
tion of liquid PCBs at sea. They were:
• Gulf Ocean Incineration Site (GOIS), located off the Louisiana
coast in the Gulf of Mexico, Reference 24.
• Atlantic Ocean Incineration Site (AOIS), off the coast of New
Jersey in the Atlantic Ocean, now being considered for designa-
tion, Reference 25.
The Gulf Ocean Incineration Site was selected for incineration of PCB wastes.
Factors considered in selecting this site are outlined below.
4.1.1 Legal Considerations
The major legal consideration distinguishing the two incineration sites
mentioned above is that the GOIS has already been designated by EPA for use
as an ocean incineration site for organochlorine wastes (24), but the AOIS
has not yet been designated (25). A final environmental impact statement
for the AOIS is in preparation, and the site may be designated officially
by the end of 1981. However, for program planning purposes, the GOIS was
chosen to avoid delaying the project should designation of the AOIS be held
up.
47
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Another major legal consideration is that the Gulf Ocean Incineration
Site designation expired 15 September 1981 (40 CFR 228.12 (b)(l)). Current
estimates of the PCB disposal schedule (Section 5) put at-sea incineration
well beyond this date. Therefore, the period of use of the GOIS must be
extended.
4.1.2 Technical Considerations
Perhaps the major technical considerations in selecting an incineration
site will be the suitability of the associated land-based facilities. Suit-
ability will be determined by:
• Proximity of land-based support facility
• Presence of adequate and safe means for conveying liquid PCBs from
the land-based facility to the incinerator ship
• Physical configuration of port facilities
Other technical considerations concern strictly at-sea operations. For ex-
ample, weather at sea may be a concern. Winter weather in the AOIS would be
considerably harsher than in the GOIS and would make sampling onboard the
ship much more difficult.
4.1.3 Other Considerations
Socio-political considerations arising from the aforementioned legal
considerations could be as important for timely project completion as legal
or technical constraints. Public opinion in the coastal areas near any pro-
posed ocean burn zone should be carefully considered. Public reaction may
prove quite negative toward any special designation of an incineration site
off the New Jersey coast prior to completion of the official site designa-
tion process unless an adequate public participation work plan (Section 3.8)
is prepared and implemented.
The extent of public risk during at-sea operations is generally limited
to exposure to PCBs accidentally spilled during loading or steaming to the
incineration site. Public risk during normal incineration operations is
expected to be quite low since the remoteness of any EPA designated incinera-
tion site will preclude impingement of the incinerator plume on populated
areas. Public risk considerations might make a small port in a sparsely
48
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populated area more desirable than a major port in a metropolitan area. How-
ever, a major port facility would more likely be better equipped to handle
normal project operations as well as emergencies which could occur.
4.2 PERMIT REQUIREMENTS
A party desiring to incinerate at sea must apply for a permit to do so
in accordance with procedures outlined in EPA's Ocean Dumping Regulations,
40 CFR 220-229. The Ocean Dumping Regulations set forth procedures for filing
and criteria for evaluating permit applications, define the steps in the per-
mit approval process, and state certain requirements as to the content of
permits. In addition to the requirements of the Ocean Dumping Regulations,
the permit to incinerate PCBs at sea must meet the requirements of the "Con-
vention on the Prevention of Marine Pollution by Dumping of Wastes and Other
Matters" (London Dumping Convention), to which the United States is a sig-
nator. Protocols arising from the London Dumping Convention are administered
by the Intergovernmental Maritime Consultative Organization (IMCO). At the
Third Consultative Meeting of the contracting parties to the London Dumping
Convention in October 1978, IMCO adopted mandatory regulations for the control
of incineration at sea which were incorporated in the Convention. Recommended
technical guidelines on at-sea incineration were also adopted but are not yet
mandatory. In March 1979, these IMCO regulations went into effect in the
United States. Furthermore, some provisions of RCRA apply to acquisition of
a permit for at-sea incineration. This section will discuss the administra-
tive procedures and requirements necessary to obtain and comply with an ocean
dumping permit.
4.2.1 Ocean Dumping Permit Requirements
The Ocean Dumping Regulations prescribe certain steps in order to obtain
a permit. The process is described below. The process is initiated with the
filing of a written permit application. (A decision is needed as to whether
the Administrator or the appropriate Regional Administrator will issue the
permit.)
• Section 222.1 specifies that final action on any permit
application will, to the extent possible, be taken within
180 days from the date a complete application is filed.
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• Section 222.2(a) specifies that, within 30 days of the
receipt of the initial application, the applicant will
be issued notification of whether his application is
complete and what, if any, additional information is
required. (Sections 221.1 - 221.4 describe the information
required.)
• Section 222.2(b) specifies that, within 30 days of receipt
of a completed application, the Administrator or the
Regional Administrator will publish notice of the applica-
tion including a tentative determination with respect to
issuance or denial of the permit.
• Section 222.3 describes and specifies the contents of such
notices.
• Section 222.3 (a) (3) requires a brief description of the
procedures set forth in Section 222.5 for requesting a
public hearing.
• Section 222.5 states that the Administrator or Regional
Administrator may determine to hold a public hearing
without waiting for a request, procedures for which are
specified in Section 222.4.
• Section 222.3 (c) specifies to whom (individuals and
agencies) notifications of Section 222.3 are to be
sent. This section also states that failure to send
Section 222.3 (c) notices to certain parties will not
invalidate subsequent proceedings and that failure
of consulted agencies to respond within 30 days of
notice is taken as approval of the action.
• Section 222.6 and 222.7 describe the Presiding Officer
and the conduct of the hearing. (The Administrator or
Regional Administrator must designate the Presiding
Officer.)
• Section 222.8 prescribes that, within 30 days following
adjournment of the public hearing, the Presiding Officer
will forward to the Administrator or Regional Administrator
written recommendations relating to the issuance or denial
of the permit.
• Section 222.9 (a) prescribes that, within 30 days after
receipt of the Presiding Officer's recommendations, the
Administrator or Regional Administrator will make a
determination with respect to the issuance or denial of
the permit. He will also notify the applicant and all
persons who attended the hearing of his determination and
the basis for the determination.
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• Section 222.9 (b) specifies that the determination to issue
or deny the permit cannot take effect sooner than
- 10 days after such notice in Section 222.9 (a).
- 20 days after such notice in Section 222.9 (a) if
a request for an adjucatory hearing is filed in
accordance with Section 222.10 (a) and if the
Administrator or Regional Administrator denies the
request in accordance with Section 222.10 (c).
- The date on which a final determination has been
made following an adjucatory hearing held pursuant
to Section 222.11.
• Section 222.9 (b) requires that a copy of the permit be sent to
the appropriate U.S. Coast Guard District Office.
As part of the permit application, information must be included concern-
ing the organizations involved in the disposal, the waste to be incinerated,
and the details of the disposal operation. In addition, a statement of the
need for at-sea incineration, an evaluation of alternative disposal methods,
and an assessment of the environmental impacts of the proposed action must be
included. Thus, an environmental impact assessment for the project may need
to be prepared.*
General criteria for approval of ocean dumping permit applications are
described in 40 CFR 227. These criteria consider 1) the need for and alter-
natives to the proposed action, 2) the effects of the action on the environ-
ment, and 3) the effects on esthetic, recreational, and economic values and
other uses of the ocean.
Until specific criteria to regulate at-sea incineration systems are
promulgated by EPA, permits granted for incineration at sea will be either
research permits, special permits, or interim permits. Agency policy in
* It should be noted that, in general. EPA ts exempted from preparing an
environmental impact statement (EIS) on actions it sponsors. The courts have
found EPA to be exempt from the EIS requirements for regulatory actions under
certain Acts, including MPRSA, because EPA actions under these statutes are
undertaken with sufficient safeguards to ensure a functionally equivalent
analysis of National Environmental Policy Act requirements (See Maryland v.
Train, 415 F. Supp. 116, District Court, Maryland, 1976).
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the past has been to grant a research permit for the first burn of a parti-
cular waste, and a special permit for subsequent burns. Technical require-
ments for at-sea incineration operations are not specifically detailed in the
Ocean Dumping Regulations. They are established on a case-by-case basis. Ad-
ministrative requirements stated in the Ocean Dumping Regulations include the
following:
• The material to be incinerated must be adequately described
in the permit, and only that material may be burned.
• The precise times and locations of incineration must be
specified.
A number of technical conditions were included in permits issued for the
at-sea incineration of Herbicide Orange (26). These conditions were deter-
mined based on the unique properties of the herbicide. For example, the re-
search permit specified both maximum and minimum waste feed rates. It also
required collection of marine water and plankton samples from the incinera-
tion site before and after incineration of waste. Other requirements speci-
fied in these permits were as follows:
• The Permittees are authorized to heat up incinerators with
fuel oil while en route to the site but may not incinerate
the described wastes except at the site which is defined in
the permit.
• During start-up, waste shall not be fed into the incinerators
until a flame temperature of 1280°C has been reached in the
furnace, and only one burner at a time shall be changed over
to the waste. The start-up temperature of 1280°C must be
reached before the next burner is changed over to waste.
• Monitoring of the furnaces for temperature and for completeness
of combustion shall be in effect during the change-over. A
record of temperature shall also be maintained during this time.
• The incinerator flame temperature shall be greater than 1250°C
when burning waste.
• An automatic shut-off device shall be in operation on both
furnaces set to turn off the flow of waste if the flame tem-
perature drops below 1250°C.
• Incineration shall take place in the presence of sufficient
excess air to ensure a 3 mole percent minimum oxygen content
in the combustion product gas.
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• The combustion efficiency of the incineration and destruction
efficiency during the incineration will be at least
99.9 percent complete. If the efficiency level falls below
99.9 percent, the incinerators will be shut down immediately
until corrective measures which assure 99.9 percent combustion
and destruction efficiency are applied.
• A manual log shall be kept and the following information recorded
at 1-hour intervals:
a) Time, date
b) Controller temperature reading
c) Waste feed rates
d) Switching of waste tanks
e) Wind speed and direction
f) Location
• A device for the addition of ammonia to make a visible plume will
be installed.
• Permittees shall ensure their position during transport and within
the discharge site at all times by on-board navigational aids and
shall maintain documentation of position.
t Permittees shall have installed and in operating condition a
radio or other communications devices which are capable of voice
transmission to the mainland from the vessel when en route to
the incineration site, and during the incineration of the waste
in the designated site. The frequency of reporting and informa-
tion to be transmitted shall be set forth in a Contingency Plan,
included as appendix to the permit.
0 During the burns the Permittees shall transmit the following
information to EPA Headquarters every 24 hours:
a) Operating temperatures
b) Average combustion efficiency
c) Significant malfunctions/incidents
• The Permittees shall monitor for carbon monoxide, carbon dio-
xide, oxygen, and other parameters in accordance with
the monitoring plan contained in an appendix to the permit.
• The Permittees shall comply with all provisions of the compre-
hensive safety plan set forth in an appendix to the permit.
The above conditions illustrate some of the technical requirements which were
included in previous permits for at-sea incineration of a highly toxic waste.
Some of these precedents may be applicable for incineration of PCBs. However,
the nature of the waste will be the determining factor in setting conditions
for PCB incineration.
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4.2.2 IMCO Requirements
IMCO has developed regulations and technical guidelines for at-sea in-
cineration. Some IMCO regulatory requirements would be satisfied by adhering
to the requirements listed in Section 4.2.1 which applied to the incineration
of Herbicide Orange. For instance, IMCO requires an adequate characterization
of the waste to be burned, a minimum flame temperature of 1250°C,* combustion
and destruction efficiencies in excess of 99.9 percent, automatic waste shut-
off devices, and monitoring of carbon monoxide and carbon dioxide in the stack
gas. Additional requirements imposed by IMCO regulations include the following:
• No black smoke or flame extension is allowed above the exit
plane of the stack.
t Replies to radio calls must be made promptly during incinera-
tion operations.
• Records must be kept on
- temperature of incineration (continuous)
- vessel position, course, and speed
- fuel and waste feed rates (continuous for liquids)
- date and time of incineration and a record of waste
being burned
IMCO Regulation 4 sets requirements which may be subject to interpreta-
tion for the PCB disposal project. Regulation 4 requires that special studies
be conducted for wastes meeting either of the following criteria:
• Those for which doubt exists as to their thermal destructa-
bility (such wastes are listed in IMCO Technical Guidelines),
in which case pilot tests must be undertaken.
• Those for which doubt exists as to the efficiency of combus-
tion, in which case extensive stack monitoring is required.
PCBs may meet these two criteria. Some doubt exists as to whether pilot
tests on land would be required on PCBs. However, because sufficient data
exist on thermal destruction of PCBs, these tests will probably not be
* Unless adequate destruction at lower temperatures is substantial by test
results.
54
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required. The extensive stack monitoring referred to would include, in addi-
tion to those requirements already mentioned, the following:
• Total organic chlorine
• Total hydrocarbons
Such additional stack gas monitoring may be required for a research permit.
IMCO Technical Guidelines will be considered in the permitting process.
Some or all of these Guidelines may be included in the permit, however, in-
clusion is not mandatory. Some of the Guidelines would be satisfied by com-
plying with the above requirements. Other relevant technical guidelines
set forth by IMCO are the following:
• Tank washings and contaminated bilge water should be incinerated
at sea.
• Incineration locations and schedules should be known to relevant
maritime authorities.
• Regular radio warnings should be broadcast during incineration
operations.
t Incinerator ships should carry a valid IMCO Certificate of
Fitness, and comply with U.S. Coast Guard design, construction
and operation requirements.
• Tanks from which waste is taken for incineration should be
recorded during incineration.
• Meteorological conditions should be recorded during incineration.
• If possible, information on the chemical and physical transforma-
tions of the waste after incineration should be known, particularly
in regard to formation of new compounds and composition of ashes
or burned residues.
• Air feed rate should be recorded.
• Temperature controls should be based on wall temperature measure-
ment, using 3 or more thermocouples per incinerator.
• A wall temperature should be defined below which waste flow should
be automatically shutoff. This temperature should be 1200°C,
unless test results on the incinerator demonstrate that required
combustion and destruction efficiencies can be achieved at a lower
temperature.
• Residence time on the order of 1 second or longer at 1250°C under
normal operation should be maintained.
• Automatic shut-off systems, including flame sensors for each
burner, should be used to stop flow to that burner in the event
of flameout.
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4.2.2 RCRA Permit by Rule Requirements
Owners or operators of at-sea incineration vessels do not have to submit
RCRA permit applications. Such a person is deemed to have a RCRA permit (a
permit by rule) if he
• has a valid ocean dumping permit,
• complies with the terms of that permit, and
• complies with the following RCRA manifest, recordkeeping
and reporting requirements.
- 40 CFR 264.11, Identification nymber
- 40 CFR 264.71, Use of manifest system
- 40 CFR 264.72, Manifest discrepancies
- 40 CFR 264.73 Ca) and (b) (1), Operation record
- 40 CFR 264.75, Annual report and
- 40 CFR 264.76, Unmanifested waste report
4.3 INCINERATION OPERATIONS
Incineration operations shall include all shipboard activities related to
the thermal destruction of PCBs. Requirements for these procedures will be
included in the at-sea incineration permit. Descriptions of an incinerator
vessel and plans required for incineration operations are presented in the
following sections.
4.3.1 Administrative and Legal Constraints
At-sea incineration operations will be conducted in accordance with an
EPA approved ocean dumping permit. This permit will cover transportation of
wastes from the docking facility and incineration operations within the desig-
nated incineration site. Requirements for minimum incineration temperatures,
monitoring, and efficiencies will be specified in the permit (Section 4.2).
4.3.2 Permit Data Requirements
The permit will include requirements for data necessary to confirm that
efficient PCB destruction is maintained throughout the burn. At a minimum,
monitoring should be performed for the following parameters:
• Incinerator temperature
• Waste feed rate
56
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• 02, CO, COp and PCB in the combustion gases
Combustion efficiency, based upon CO and C0~ measurements will be speci-
fied in the incineration permit. Minimum Og levels may also be specified.
Automatic shutoff devices will terminate waste flow if incinerator tempera-
tures fall below a predetermined limit. Other recordkeeping requirements
which could be imposed as permit conditions were discussed in Section 4.2.
4.3.3 Description of the M/T Vulcanus
4.3.3.1 General Specifications—
The M/T Vulcanus, originally a cargo ship, was converted in 1972 to a
chemical tanker fitted with two large incinerators located at the stern. The
vessel meets all applicable IMCO requirements concerning transport of danger-
ous cargo by tanker. The ship is operated by the Chemical Waste Management
subsidiary of Waste Management, Inc., Oak Brook, Illinois.
The ship has an overall length of 102 meters, a beam of 14.4 meters, and
a maximum draft of 7.4 meters. It is able to operate worldwide. Two diesel
engines drive a single propeller to give cruising speeds of 10 to 13 knots.
Her crew numbers 18; 12 to operate the vessel and 6 to operate the two incin-
erators.
4.3.3.2 Tanks and Pumps—
The Vulcanus is a double-hull, double-bottom vessel. Waste is carried
3
in 15 cargo tanks which range in size from 115 to 574 m with an overall
capacity of 3503 m . There are 5 large center tanks and 5 smaller tanks each
on the port and starboard. Tanks are filled through a manifold on deck using
a dockside loading pump. During normal operation the waste tanks can be
discharged only through the incinerator feed system. Provisions exist, how-
ever, for discharging the cargo into the ocean if an emergency arises. Piping
system construction makes it possible for any tank to be connected to either
incinerator and for cargo to be transferred from one tank to another.
The space between the two hulls is used for ballast. Ballast tanks are
filled with seawater and emptied independently as required to trim and balance
the ship. Fuel oil is carried in tanks under and in the engine room. The
engine room is separated from the cargo tanks by double bulkheads. The pump
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TABLE 3. SPECIFICATIONS OF THE M/T VULCANUS
Length overall
Breadth
Draft, maximum
Deadweight (OUT)
Speed
Tank capacity
Nunber of tanks
Tank coating
Loading equipment
Hose connection
Safety equipment
Waste to be processed
Incinerators
Per Incinerator:
Overall height
Combustion chamber
00
ID
Stack (top) -
OD
ID
Haste feed (max)
Combustion air (max)
Burners (Vortex type)
Volume
Residence time
101.95 meters
14.40 meters
7.40 meters
4,768 metric tons
10-13 knots
3,503 cubic meters (cu m)
15, ranging In size from 115 cu m to
574 cu m
No coating In tanks, pipes, pumps, etc.
All equipment consists of low carbon
steel
Not available, but can be placed on
board. If required
10.2, 15.2. and 20.3 centimeters
(4.6, 8 1nches)1n diameter
Specially designed for th:s task and in
accordance with latest regulations of
IMCO, Scheepvaart-Inspectle (The Hague)
Must be liquid andpumpable. Nay con-
tain solid substances In pieces up to
5 centimeters In size. Must not attack
mild steel
10.45 m
5.5 m
4.8 m
3.8 m
3.4 m
12.5 metric tons/hour
90.000 m3/hour
3
120 m3
1.0 sec at 1500 "C (calculated)
58
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room and generator room are situated between the engine room and the waste
tanks.
4.3.3.3 Incinerator System—
Waste is burned in two identical refractory-lined furnaces located at
the stern. Each incinerator consists of two main sections, a combustion
chamber and a stack, through which burning gases pass sequentially (Figure
2). This dual chamber configuration, which is characteristic of most high
intensity combustion systems, uses the first chamber for internal mixing and
the second for adequate residence time. Table 3 lists characteristics of the
incinerators.
Combustion air is supplied by large fixed speed blowers having a rated
3
maximum capacity of 90,000 m per hour for each incinerator. Adjustable
4:6 M
1
1.<
I
10.45 M
i
)M
3.5 M
I
1
/
M
I.D.
\
* 4 8 M *
I.D.
4
STACK
\
COMB
CHA
Figure 2. Ir.^tnerator Configuration
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vanes are incorporated In the combustion air supply system. When they are
deflected, the system pressure drop is increased and the flow rate is re-
duced. Although no instrumentation is installed to monitor air flow rate,
normal operation is stated by the ship's chief engineer to be between 75,000
and 80,000 m per hour at ambient conditions.
Liquid wastes are fed to the combustion system by means of electrically
driven pumps. Upstream of each burner supply pump is a device (Gorator) for
reducing the solids in the waste to a pumpable slurry. The Gorator also acts
as a mixing pump by recirculating tbe waste through the waste tank. Power
for the blowers, pumps, and other parts of the incinerator system is supplied
by two diesel generators with a total capacity of 750 kW at 440 volts and 60
hertz.
Three burners of the vortex type are located at the same level on the
periphery and near the base of each incinerator. The burners are of a rotat-
ing cup, concentric design and deliver waste or fuel oil through a central
tube to an atomization nozzle, where it meets high velocity air delivered
through an annul us. The burners are positioned as shown in Figure 3. Typical-
ly, burners of this type have a turndown ratio of 5:1.
Three-way valves are utilized on each burner to provide either waste feed,
fuel oil feed, or a shutoff condition. Waste and fuel oil cannot be valved
into a burner simultaneously; however, alternate burners can be operated with
fuel and waste to achieve higher or lower combustion temperatures if necessary,
depending on the relative heat contents of the fuel oil and waste.
Periodically the burners require cleaning. They are normally cleaned one
at a time with the remaining two firing waste. Cleaning is easily accomplish-
ed because the burners are readily accessible. Each burner has a vertical
pivot so that it can be swung out of the furnace. The opening left by this
operation is temporarily closed by a cover. The burners are cleaned by a
metal tool which is pushed through the burner.
4.3.3.4 Recording and Control Equipment—
Waste flow measurement—Sounding the depth of waste in each tank with a
tape is the usual method of determining burn rate. This method is only use-
ful in port or in calm seas (i.e., minimum ship roll). During the actual
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BURNER 6
BUHNER 5
THERMOCOUPLE INDICATORS
(BLACK-BOX AND CONTROL PANEL)
(STARBOARD F URN ACS;
THERMOCOUPLE FOR STARBOARD
FURNACE AUTOMAUC SHUT-Of F
BURNER 4
BURNER 3
BURNER 1
THERMOCOUPLE FOR PORT
FURNACE AUTOMATIC SHUT-OfF
THERMOCOUPLE INDICATORS
(BLACK BOX AND CONTROL PANEL)
(PORT FURNACE)
BURNER 2
Figure 3. Incineration system - burner and thermocouple locations.
burns, the total tine is recorded for emptying each tank and a time average
waste feed rate is determined.
Reference 27 described testing of several continuous waste flow measure-
ment devices onboard the M/T Vulcanus. These instruments were an ultrasonic
flow meter, affixed to the outside of waste carrying pipes, and a vortex
shedding flow meter, the sensing element of which was installed inside waste
carrying pipes. The sensor packages were in the incinerator room; the elec-
tronic packages were installed in a cabin. Both units functioned well over
a period of several months. The ultrasonic unit is preferable because it
mounts on the outside of waste flow pipes and is thus unsusceptible to clog-
ging or erosion by the waste.
Regulations recently adopted under the London Dumping Convention require
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capability for continuous waste flow measurement. While incinerator ships,
such as the Vulcanus, which were operating before 1 January 1979 are exempt
from this regulation, it is recommended that this capability be installed and
used for this incineration project.
Mall temperature measurements—Temperatures during operation of the in-
cinerators are measured by three platinum/platinum-10% rhodium thermocouples
in each incinerator. Two are located in a well opposite one of the burners
[Figure 3). One thermocouple is located approximately 1.3 cm from the inside
surface of the refractory lining. This thermocouple provides temperature
information to the automatic waste shut-off system and is called the controller
thermocouple. The second thermocouple, approximately 4 cm from the inner
surface of the firebrick, is referred to as the "indicator" because it pro-
vides temperature information to a panel located in the incinerator control
room and to a panel located on the bridge. The third thermocouple is mounted
in each stack about 1 foot above the junction of the conical section with the
vertical section. Temperatures indicated by the stack thermocouples are also
displayed on the bridge.
The thermocouples used to activate the automatic waste shut-off system
and the recording equipment have been quite reliable and durable according to
personnel of the M/T Vulcanus.
4.3.3.5 Emergency Automatic Waste Shut-off—
The following description of the automatic waste shut-off system utilized
by the M/T Vulcanus is based upon verbal description of the system by the
ship's engineering staff.
The waste shut-off system consists of a number of different components
which can effect the closing of spring-loaded solenoid valves which terminate
waste flow to each burner while simultaneously shutting off power to the
waste pumps. These spring-loaded solenoid valves are normally closed. During
incineration, the valves are held open by an electrically-induced magnetic
field. The waste flows through the solenoid valves until the electrical cur-
rent is interrupted by a malfunction in the incineration system. Once inter-
rupted, the malfunction must be repaired and restart procedures implemented
before incineration can continue. These restart procedures require fuel oil
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start-up If the Incinerator has dropped below a specified minimum temperature.
The automatic shut-off system will stop waste flow (or fuel oil flow)
to the affected burner(s) and shut off power to the waste pumps when any one
of the following malfunctions occur:
• waste pump overload.
• Combustion air fan motor overload.
• Burner pump overload.
• Steering air (directs and shapes burner flames) or combustion
air failure to reach an incinerator burner.
• Open burner: A mechanical switch interrupts the electrical
current when the burner swings open or away from the incinerator
wall (usually opened to remove residue during burner cleaning).
• Flame out: A light sensing resistor is located directly above
each burner to monitor the flame. This resistor operates by
viewing the flame and amplifying and conditioning the signal.
Output of the sensor opens and closes several sets of contacts,
half of which are normally closed and half normally open (under
no flame condition). The normally closed contacts are not used
in this system. Wires which conduct the electrical current used
to induce the magnetic field for the waste shut-off valve are
connected to the normally open position. During stable incinera-
tion, the contacts are closed and the electrical current flows
through the contacts. This completes the circuit which produces
the magnetic field holding the waste shut-off valve open. Upon
flame blockage or electrical failure, the contacts connected
will return to a normally open position, breaking the electrical
current and removing the magnetic field from the waste valve,
which in turn shuts by spring action.
• Temperature drops below minimum acceptable temperature: A
thermocouple-controlled sensor interrupts the waste shut-off
valve electrical current when the incinerator temperature drops
below a preselected minimum temperature. The system used is
the Plastomatic 2000 (supplied by Withoff-Phillips, Bremen,
West Germany), previously discussed in Reference 27.
Once the flow has been stopped by the automatic shut-off system, any
malfunctions are repaired, and the following restart procedures are imple-
mented :
• Manully restart waste pumps (or start fuel oil pumps if in-
cinerator temperatures are low enough to require fuel oil
start-up).
• Depress ignitor button to provide ignition flame.
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• Manually open emergency shut-off valve to Initiate waste
(or fuel oil) flow to burner.
• After stable combustion Is attained, deactivate manual over-
ride of the emergency shut-off valves to return to automatic
shut-off control condition.
4.3.3.6 Special Equipment-
Certain equipment has been installed on the Vulcanus because of its par-
ticular type of operation. These items of equipment are:
• Loran and Decca Navigational Systems; This equipment is
needed in American (Loran) and European (Decca) waters in
order to locate the ship precisely at all times. Celestial
navigation has also been used to locate and keep the Vulcanus
in the designated burn zone.
0 Anemometer: This equipment measures the velocity and force
of the wind. It is, therefore, useful in selecting an atti-
tude of the ship during various wind conditions such that
the plume produced may be directed away from the ship and
its personnel.
• Radio Communication; The Vulcanus is equipped with SSB
(single side band) and DSB (double size band) radio fo*- voice
and continuous wave communication; MF (medium frequency) and
SW (short wave) telegraphy; Marifoon (VHP) (all channels) for
close-in voice communication; and Semafoon (a private tele-
phone communication system). For this program, a Hagenuck
Synthesized Transceiver should be installed to permit voice
communication over all marine frequencies. A radio is also
located on the bridge so that the watch officer can hear marine
broadcasts at all times.
• Optical Pyrometer; A portable optical pyrometer has been used
during previous test programs to measure incinerator flame
temperature. These measurements were taken daily using a
Leeds and Northrup optical pyrometer operating in the 6500 angstrom
range.
4.3.4 Recommended Monitoring, Sampling and Analysis Plan
The combustion product effluent stream from the incineration of liquid
PCBs onboard the Vulcanus will be sampled utilizing three probes. Two cera-
mic probes (one in each stack) will be installed to divert the gases to an
on-line monitoring system comprised of CO, CO*, and 02 analyzers; heated
sample lines; and a gas conditioner. For a more comprehensive characteri-
zation of the combustion effluent, a water-cooled probe capable of traversing
the starboard incinerator will divert a representative portion of the effluent
64
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stream to a benzene impinger train. The train will be used to acquire samples
for onboard PCB analyses.
In addition to these monitoring and sampling activities, a variety of
air, liquid, and solid samples will be taken. These samples include:
• Work space air samples
• Ambient air samples
• Wipe samples
» Miscellaneous samples of the fuel, waste feed, burner head
residue, ship's water, and any other samples deemed necessary
for completeness.
These samples will be analyzed as required by permit conditions and the safety
plan.
It is recommended that a quality assurance plan be developed to supple-
ment the monitoring, sampling, and analysis plan required by the ocean dump-
ing permit.
The following sections describe the recommended monitoring, sampling and
analysis plan in greater detail.
4.3.4.1 Monitoring Plan-
On-line monitoring of the concentration levels of CO, COg and 0~ in both
incinerator effluents may be accomplished by two complete duplicate systems,
one primary and one spare. These gas levels will serve as indices of the
effectiveness of the thermal destruction process. The on-line monitors will
use one ceramic probe in each stack with heated line delivery systems. The
manifold system is designed so that either a complete bank of instruments
or one instrument can be operated, depending on the operational readiness of
any given instrument.
Stack gas parameters to be monitored and appropriate instrumentation are
given in Table 4. Instrumentation systems of this type have been used success-
fully in four different test programs on the Vulcanus.
On-line monitoring will be conducted for the duration of every stack
sampling test and on days when stack sampling is not performed.
65
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If monitoring of total hydrocarbons is required by permit conditions, an
on-line instrument such as a Beckman Model 402 hydrocarbon analyzer with a
flame ionization detector could be added to the monitoring system. This in-
strument has eight ranges, and can measure hydrocarbon concentrations from
0.05 ppm to 10%.
Monitoring of combustion temperature and waste feed rate will be per-
formed as specified in Section 4.3.3.
TABLE 4. MONITORING PARAMETERS AND INSTRUMENTATION
Species..
Analyzed
Mfg. and
Model
Analyzer
Tyoe
Instrument
Range
Carbon Monoxide
(CO)
Carbon Dioxide
Beckman 865
Beckman 864
NDIR
NDIR
0 - 200 ppm,
0 - 2000 ppm.
0-2%
0 - 4%, 0 - 8%,
(co2)
Oxygen
(oj
Beckman 742 Electro-
magnetic
Taylor 0247A Paramagnetic
0
0
0
0
0
- 15%
- 5%, 0 - 10%
- 25%
- 5%, 0 - 10%,
- 25%
4.3.4.2 Sampling Plan--
Samples will be obtained during incineration of PCBs as follows:
• Stack samples - A benzene impinger train (Figure 4) equipped
with water-cooled probe and heat traced Teflon line will sample
stack gases from the starboard incinerator. Three one-hour
samples will be collected during each stack test. Sampling
will begin after steady-state incineration conditions have been
attained.
• Uork space air samples - Personal monitors fitted with Chromo-
sorb 102 absorption tubes will be placed at several positions
on the ship to monitor personnel exposure to atmospheric toxic
materials.
• Air samples - Ambient air samples will be taken at specific loca-
tions using a gas syringe.
66
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FCML WRAPPED
THERMOMETER
HEAT TRACED
LINE
COARSE FRITS
BENZENE
NAOH SILICA
CHARCOAL GEL
DRY GAS
METER
Figure 4. Schematic of benzene Iropinger sampling train.
-------
• Wipe samples - Whatman 41 filter paper will be used to wipe
selected areas of the ship.
• Miscellaneous sampling - Samples of the fuel, composite waste
feed, burner head residue, ship's water, and any other sample
deemed necessary for completeness will be taken as needed.
Samples will be split for onboard and land-based confirmatory analyses.
A background test with the incinerators firing only fuel oil should be
performed to validate the sampling activities. Sufficient blank samples
should also be prepared in accordance with a written quality assurance plan.
4.3.4.3 Analysis Plan—
Onboard analysis—A containerized assembly can be prepared and secured
to the ship's deck for monitoring the test burns. A standard shipping con-
tainer was modified to house the on-line monitoring instrumentation and to
serve as laboratory and operations room for the sampling team on the Herbi-
cide Orange project. Its overall dimensions were 2.4 x 6.0 x 2.4 meters.
One end had a full width double door with heavy hinges, truck type locking
mechanism, and ample weather stripping. A gas conditioning unit was mounted
on this door, but ingress and egress were not hindered. A standard 0.8-m
door was situated on the inboard side which provided the main entrance and
exit. On the same side and in the middle of the container, there was a
window which could serve as an emergency exit. The total weight of the equip-
ment and container was about 9,100 kg. The container could be forklifted
or hoisted by slings and was structually sound for stacking. The equipment
container was stacked above an identical container which was used for storage
of supplies and spares.
Onboard analysis of samples for PCB will be performed using a gas
chromatograph (GC) with electron capture detector (ECD). A detection limit
of approximately 0.2 mg PCB/m for stack samples, and 0.1 mg/m for ambient
air samples is expected. These detection limits should be adequate from both
a technical and a safety standpoint (See Appendix B for detection limit de-
terminations).
Because PCB wastes are composed of a mixture of PCB isomers, specific
procedures for quantitating PCB concentration should be developed. It is
68
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recommended that chromatogram peak areas corresponding to selected PCB iso-
mers be determined by an onboard peak integrator. The total area, or the
areas of selected major peaks, could then be translated into a PCB concen-
tration (for ambient air), or could be compared to the peak pattern of' the
waste being burned (to determine destruction efficiency). Onboard PCB analy-
ses will be performed on all samples listed in Section 4.3.4.2.
If permit conditions require onboard analysis for total organic chlorine,
a GC with Hall electroconductivity detector should be used. Some GC instru-
ments can be equipped with both the ECD detector (for PCBs) and the Hall de-
tector (for chlorinated organics). If chlorinated organics are to be mea-
sured, special studies should be undertaken to adapt the GC/Hall detector
technique to at-sea analyses.
Land-Based analyses—Land-based analysis of samples obtained during the
incineration of PCBs should be used to confirm the validity of onboard analy-
ses and to characterize more completely incinerator emissions. High resolu-
tion gas chromatography/mass spectrometry (GC/MS) techniques are applicable to
determination of PCBs and other toxic combustion products. Limited analyses
for chlorinated dioxins and dibenzofurans should be considered, because these
extremely toxic compounds may be formed from the combustion of PCB wastes
containing chlorobenzenes (see Section 4.3.7).
4.3.5 Personnel Safety
Appendix B is a detailed plan for ensuring the health and safety of
shipboard personnel during the incineration of liquid PCBs. This plan was
adapted from that used onboard the Vulcanus during the incineration of Herbi-
cide Orange (28). This section summarizes Appendix B. In essence, the health
and safety plan uses the boundary isolation concept to control the spread of
PCB-contaminated wastes. Certain areas (e.g., dining room, galley, living
quarters) are designated as clean areas. Other areas (e.g., pump room, main
deck, incinerator room) are designated as contaminated. Boundaries are estab-
lished between these areas, and means of removing contamination are provided
at the boundaries to prevent clean areas from becoming contaminated. Proce-
dures are established in the plan to ensure that the plan is being followed.
A Safety Director for at-sea incineration operations will be designated
69
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to assist In establishing and maintaining safety procedures and routines. He
will be a member of the sampling and monitoring team and his duties will in-
clude: 1) safety procedure briefing of all team and ship's personnel; 2)
monitoring the implementation of this safety plan; and 3) advising the Team
Leader, and ship's Master regarding corrective action for unsafe conditions
or incidents.
The Team Leader, acting on behalf of the EPA, shall retain the authority
to interrupt and/or initiate incineration. The criteria that will be used
by the Team Leader to measure safe shipboard operations are:
• Plume impingement
• PCB spills
• Combustion efficiency
• Onboard determination of PCBs in stack gas
• Onboard determination of ambient levels of PCB
These criteria will only be used as guidelines. In addition to the Team
Leader, authority to interrupt or terminate any individual incineration test
will also rest with the captain of the Vulcanus. The shore-based Test Direc-
tor will normally be consulted prior to interruption of a burn.
All personnel will be furnished with safety equipment and issued dispos-
able coveralls to be worn during set-up, operation, and cleanup of all samp-
ing and/or monitoring equipment.
PCBs in the work environment can enter the body through the mouth, through
the skin, or through the nose and eyes. Thus, eating, drinking, and smoking
in working areas; wearing contaminated clothes, leaving liquids on the skin;
failure to shower frequently, especially immediately after exposure; and
breathing contaminated air must be avoided.
Good personel hygiene practices are of prime importance in preventing
exposure of personnel to materials containing PCB. Of comparable importance
is the establishment of "clean" areas. The basic requirements for effective
personnel hygiene are:
• Protection of personnel from vapor and liquid contact in the
contaminated areas by source control and protection gear
70
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• Provision of disposable clothing and foot covers
• Provision of disposal facilities at the interface region
between the contaminated and clean areas
• Provision for shower, hand, face, and eye-washing facilities
at the interface region
• Provision of clean clothing and foot covering at the boundary
of the clean area upon return to working areas
• Instruction in the use of the cleaning equipment and pro-
tective equipment and in methods of personal cleansing
• Mandatory and enforced use of the above facilities and
concepts
A monitoring system for ensuring the cleanliness of areas such as the
galley, mess room, living quarters, bridge, toilets, and passageways, should
be put into effect on a firm basis. A schedule of inspection of the clean
areas should be established and the results made known to the ship's Master.
The safety of all shipboard personnel will have top priority during the in-
cineration of liquid PCBs onboard the Vulcanus.
4.3.6 Contingencies
The ship's Master is in complete command of the vessel at sea. His ac-
tions will be consistent with good seamanship and safe navigational practices
and in accordance with permit requirements. Operational control should rest
with the appropriate Coast Guard District in conjunction with EPA.
4.3.6.1 Notification—
The ship's Master will notify immediately the appropriate government
agencies in the event of a casualty or spill. The appropriate Coast Guard
District and EPA Regional Office also will be notified. Additionally, the
ship's Master will file a report of any incident affecting the ability of
the ship to maintain its scheduled course, speed, or location.
The notification and report will provide sufficient information to give
interested parties a good understanding of the situation, e.g., nature of
casualty, extent of damage or personal injury immediately apparent, course,
extent to which operation is impaired, any action being taken to correct or
alleviate the situation, and any assistance required.
71
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4.3.6.2 Counter-measures and Assistance—
In the event of fire, collision, grounding, substantial weather damage,
or machinery failure, assistance will be initiated and provided in accordance
with the National Search and Rescue Plan (NSRP). If necessary, EPA and Coast
Guard will obtain salvage services and assist in any other way possible.
The ship's Master will submit situation casualty reports are required
until the casualty is corrected. These reports will be addressed to the
agencies/parties receiving the intital report.
In emergency situations when immediate removal of the cargo is necessary
to save the crew and/or the ship, consistent with the Master's usual author-
ity, he will take action he deems appropriate, including burning or jettison-
ing. If time and circumstances permit, this action should be coordinated
with the appropriate authorities.
In the event of a spill, the ship's Master is responsible for initiating
standard damage control measures. He will attempt to contain or limit the
extent of the spill using all resources available onboard the vessel.
In non-emergency situations, spill containment, prevention, and clean-
up counter-measures described in the Health and Safety Plan (Appendix B) will
be followed.
4.3.7 Special Considerations for Incineration of PCBs
4.3.7.1 Regulatory Considerations--
While authority to regulate at-sea incineration is delegated to EPA
under the authority of MPRSA and the London Dumping Convention, other stat-
utes and regulations are applicable to incineration of hazardous and toxic
wastes. PCB Regulations under TSCA and hazardous waste regulations under
RCRA also prescribe requirements for incineration. The TSCA and RCRA require-
ments, specifically for destruction efficiency, are more stringent than IMCO
requirements. Even though the IMCO/MPRSA regulations supercede the TSCA and
RCRA regulations for incineration operations at sea, TSCA and RCRA require-
ments may be considered in the permitting process. In this regard, it is
important to note that previous experience with incineration of toxic wastes
72
-------
on the Vulcanus has demonstrated that destruction efficiencies well above
those required by IMCO are routinely attained.
4.3.7.2 Technical and Safety Considerations—
Formation of toxic combustion by-products—Incomplete combustion of PCB
wastes can give rise to extremely toxic chlorinated organic compounds. Chlor-
inated dibenzofurans can be formed from PCBs, and chlorinated dioxins can be
formed from chlorobenzenes (which are often present in PCB transformer fluids)
(29). The at-sea sampling and land-based analysis plans for this project
should provide for quantitation of these compounds in a limited number of
stack and ambient samples. Such sampling and analysis is necessary so that
an adequate assessment can be made of the safety of at-sea incineration of
PCBs.
Waste feed rates—Waste feed rate is a critical parameter in at-sea in-
cineration operations. Maximum and sometimes minimum waste feed rates have
been specified in previous ocean dumping permits. Three major factors which
can act as constraints to waste feed rates are:
• Burner specifications
• Safety considerations
• Waste heating value and PCB content
Ultimately, the waste feed rate determines the duration of the burn. There-
fore, waste is fired at the highest rate possible consistent with regulatory,
technical, and safety considerations.
For incineration of PCBs on the Vulcanus, burner specifications limit
the range of feed rates to between about 5 metric tons (mt) per hour (based
on a 5:1 turndown ratio, Section 4.3.3.3) and 25 mt/hr. Safety considera-
tions based on calculations presented in Appendix B will dictate a maximum
feed rate of PCBs. Finally, waste heating value must be known to establish
the maximum feed rate which does not degrade refractories in the combustor
and the minimum feed rate needed to sustain stable combustion at the required
temperature.
In Appendix B, calculations were performed to determine a maximum PCB
feed rate which was consistent with maintaining safe working levels of PCB
73
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in the air aboard ship. Conservative assumptions were made as to PCB destruc-
tion efficiency (99.9 percent) and combustion effluent flow rate (70,000 m /
hr). A maximum allowable PCB concentration in the stack of 5 mg/m was as-
sumed, based on the fact that combustion gases would be diluted at least
1000:1 and result in a PCB concentration on deck of less than one-hundreth
of the Threshold Limit Value (TLV). Maximum allowable feed rate of PCB (not
PCB fluids) was calculated to be 0.70 mt/hr (both incinerators). Actual
waste feed rate (r ) would be related to the average weight percent of PCB in
W
the waste (f) by the following expression:
P . 0,70 x 100
W I
Using the minimum r . in the above equation would enable calculation of a maxi-
W
mum allowable PCB concentration in the waste. The minimum r based on burner
W
specifications is 5 mt/hr, therefore, the maximum allowable PCB content of the
waste is 14%.
Several caveats are necessary in interpreting the results of this calcu-
lation. First, it is assumed that the Vulcanus burners can turn down to a
5 mt/hr feed rate and still achieve stable combustion conditions above 1250°C.
Second, the assumptions used to calculate the maximum PCB feed rate, parti-
cularly the destruction efficiency assumed, have a tremendous bearing on the
result. Should destruction efficiencies greatly exceed 99.9 percent, as ex-
pected, safety considerations may not be significant in determining waste
feed rates. Finally, the available PCBs are not sufficiently characterized
in terms of heat content an'd PCB concentration to accurately determine accept-
able waste feed rates.
4.4 CARGO TANK DECONTAMINATION
Two cargo tank decontamination procedures are described in this section.
The first is a recommended procedure in which the level of residual PCBs in
the cargo tanks is reduced by incinerating wastes in a particular sequence
based on their PCB content. A special procedure is also described as a con-
tingency in the event of a casualty or other occurance requiring manual
repairs inside the cargo tanks.
74
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4.4.1 Recommended Procedure
Serial rinsing of the ship's tanks using successively lower concentra-
tion PCB wastes is the recommended procedure for cargo tank decontamination.
That is, after a tankful of high concentration PCB liquids has been incinera-
ted, the tank should be filled again with lower concentration PCB liquids
which are then incinerated. This procedure should provide sufficient removal
of residual PCBs. Full decontamination using a triple rinse or equivalent
procedure is unnecessary because PCB residues remaining in the tanks will be
greatly diluted by subsequent waste cargoes and destroyed during ensuing
burns.
During this cleaning operation, no monitoring in addition to that per-
formed during normal incineration operations is necessary. After all PCBs
have been incinerated, samples of the main deck surfaces should be taken
and analyzed for PCB content. This1 was one o'f the procedures used to examine
the Vulcanus after Herbicide Orange incineration. Acquisition of samples of
tank residuals and rust may be considered if these samples can be obtained
without undue exposure of the sampling crew to PCBs.
Tank decontamination operations impose no personnel health and safety
requirements above those presented in Appendix B and summarized in Section
4.3.5. The health and safety plan will remain in effect during tank decon-
tamination operations to ensure, for example, that no PCBs are tracked into
the clean areas of the ship.
4.4.2 Special Decontamination Procedures
Normally, the tanks on the Vulcanus are not cleaned between burns of
different wastes, because no humans are exposed to waste residues inside the
empty tanks. However, if entry into the cargo tanks is required after PCBs
are burned, a tank decontamination procedure more rigorous than that recom-
mended in Section 4.4.1 should be employed.
A situation such as this arose after incineration of Herbicide Orange.
Immediately after-the Herbicide Orange burns, the Vulcanus was scheduled for
dry dock maintenance. This maintenance required that personnel enter the
cargo tanks and perform welding operations. Because the tanks contained
75
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residual herbicide, thorough decontamination of the tanks was required before
the ship could enter port. Agreements were made between the U.S. and other
governments regarding acceptable limits in tank residuals of the dioxin con-
taminant in the herbicide. EPA-approved procedures were utilized to decon-
taminate the ship's tanks at sea.
Tank decontamination procedures and acceptable PCB concentrations in
tank residues should be stated in contingency plans. The decontamination pro-
cedure employed should be tailored to the specific situation using the most
applicable equipment and procedures. Acceptable levels of PCBs in tank resi-
duals should also be determined based on the situation. Because TSCA regula-
tions have set the lower limit concentration for regulating PCBs at 50 ppm,
verification of residual PCB levels in the ship's tanks of less than 50 ppm
should be required.* However, health and safety considerations may require a
more stringent criterion. For example, if welding or cutting torches must be
used on the tanks, consideration should be given to the possible thermal for-
mation of noxious compounds from heating residual PCBs in the tanks.
* A recent court decision on the 50 ppm limit (described in the May 20, 1981
Federal Register) may affect this criterion.
76
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5. LOGIC NETWORK AND SCHEDULE
A preliminary logic network and schedule for a project to dispose of
government-owned PCB wastes are presented in this section. Several assump-
tions have been made in constructing the logic network and project schedule.
These assumptions involve estimating durations and assuming certain logical
relationships between tasks. The major logical assumptions were as follows:
• EPA would coordinate collection and transportation of PCB wastes
to a central land-based processing facility, requiring contracts
with individual waste owners.
• The ship owner would also operate the land-based processing
facility, so that a single contract could be awarded for land-
based and at-sea operations.
• An incinerator ship would be certified, in U.S. waters, and avail-
able to incinerate PCBs when required.
• No permits other than an ocean dumping permit would be required.
• A designated ocean incineration site would be available for the
project.
Because monitoring activities on land and at sea were not anticipated to be
critical schedule items, they were not included in the preliminary schedule.
Planning and performance of these tasks are, however, essential from a pro-
ject standpoint.
5.1 CRITICAL PATH MODEL
Figure 5 is a critical path model, or logic network, for the PCB disposal
project. This skeleton network shows major program tasks, their logical inter-
relationships, and approximate durations as they are currently envisioned.
Results of the critical path analysis indicate a total project duration, from
decision to proceed with disposal to incineration at sea, of about 10 months.
Activities along the critical path are as follows:
• Obtain contracts with ship owner and waste owners
• Ship wastes to land based facility
• Receive and analyze wastes at land-based facility
77
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DECISION TO
PROCEED..
WITHP
DISPOSAL
Prepare Public
Participation
Work Plan
1 Month
2 Months
Finalize Operations i
Plan
2 Months
Contract with Ship Owner
6 Months
Contracts with Waste Owners
Obtain
Ocean Dumping
Permit
6 Months
Ship Wastes to Land-
based Facility
Receive and Analyze
Transport
Blend «"««to
and Store Ship. Load
Wastes Ship. Burn
1 Month
END OF
PROJECT
I— LEGEND.-
o
Activity
Duration (Months)
o
Figure 5. Skeleton logic network for PCB disposal program.
-------
• Blend and temporarily store wastes
• Transport wastes to ship loading dock and load ship
• Incinerate wastes at sea
5.2 SCHEDULE
Logic and schedule information from the critical path model have been
incorporated into a bar chart project schedule, Figure 6. The major critical
path activities are related to contracts between EPA and the ship owner for
disposal services and between EPA and individual waste owners concerning
waste transportation (including liability).
Two key milestones are important in performance of this project, in
light of the preliminary schedule for incineration. The first is the expira-
tion of the designation of the Gulf Ocean Incineration Site. Designation of
this site expired on 15 September 1981. Because this ocean incineration site
has been identified as the site for at-sea incineration of PCBs, redesigna-
tion of this site will be required. The second important milestone is the
expiration of the seaworthiness certificate of the Vulcanus (September 1982).
No incineration could take place on the Vulcanus after this date unless the
ship's certification were extended temporarily or the ship were recertified.
Based on the current assumptions for project logic and duration, it is
possible for EPA to coordinate an at-sea incineration project for disposal
of government-owned PCBs on the Vulcanus under the existing ocean dumping per-
mit before the ship's certificate expires. To do this, a decision to proceed
with disposal must be made by December 1980. An alternative scenario which
might further compress the project schedule would be for individual waste
owners to contract directly with the ship owner for disposal services. In
either case, the need for obtaining an ocean dumping permit (activity 4-6)
would be negated, because a permit already exists. Otherwise, government-
owned PCB wastes could not be incinerated at sea until (a) another at-sea
incineration vessel becomes available, and (b) another ocean dumping permit
is applied for and approved. This alternative would delay substantially the
disposal project. This would result in additional costs being incurred by
a number of government organizations for storing PCB wastes. Such a delay
might force many of these organizations to abandon at-sea incineration for
other disposal methods as a means of destroying their liquid PCB wastes.
79
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00
o
ID"
1
1 *2
3*4
2*4
4*6
1 * 6
1 * 5
6
6*8
7*8
8*9
9 * 10
9 * 10
ACTIVITIES
DESCRIPTION
DECISION TO PROCEED WITH DISPOSAL i
OBTAIN ADDITIONAL DATA ON WASTES L
PREPARE PUBLIC PARTICIPATION WORK PLAN
FINALIZE OPERATIONS PLAN
OBTAIN OCEAN DUMPING PERMIT
CONTRACT WITH SHIP OWNER ,
CONTRACTS WITH WASTE OWNERS 2
BEGIN WASTE SHIPMENTS TO LAND-BASED FACILITY
RECEIVE AND ANALYZE WASTES
DEDRUM WASTES AS REQUIRED
BLEND AND TEMPORARILY STORE WASTES
TRANSPORT WASTES TO LOADING DOCK AND LOAD SHIP
BURN WASTES
MONTHS
1
i
I-J
i
2
f
*•—
•A
3
—J,
V
4
r
y
5
V
6
w
X
i
4
7
k
.
A-
8
r
-*7
i
9
7
*— *
i
10
T
*-*7
A*
* Refers to activity numbers on logic network
Figure 6. Project schedule.
-------
REFERENCES
1. Electric Power Research Institute, "Disposal of Polychlorinated
Biphenyls (PCBs) and PCB-Contaminated Materials", EPRI Report No.
FP-1207, Vol. 1, October 1979.
2. Wastler, T.A., C.K. Offutt, C.K. Fitzsimmons, and P.E. DesRosiers,
"Disposal of Organochlorine Wastes by Incineration At Sea", EPA-430/
9-75-014, July 1975.
3. Clausen, J.F., H.J. Fisher, R.J. Johnson, E.L. Moon, C. C. Shih, R.F.
Tobias, and C.A. Zee, "At-Sea Incineration of Organochlorine Wastes
Onboard the M/T. Vulcanus", EPA-600/2-77-196, September 1977.
4. Ackerman, D.G., H.J. Fisher, R.J. Johnson, R.F. Maddalone, B.J. Matthews,
E.L. Moon, K.H. Scheyer, C.C. Shih, and R.F. Tobias, "At-Sea Incineration
of Herbicide Orange Onboard the M/T. Vulcanus", EPA-600/2-78-086, April
1978.
5. Ackerman, D.G., "Destruction Efficiencies for TCDD During At-Sea
Incineration of Herbicide Orange", EPA Contract No. 68-02-2660,
March 1979.
6. Thomas, T.J., D.P. Brown, J. Harrington, T. Stanford, L. Taft, and
B.W. Vigon, "Land-Based Environmental Monitoring at Johnston Island -
Disposal of Herbicide Orange", Report to U.S. Air Force Occupational
and Environmental Health Laboratory, Brooks AFB, TX, No. OEHL TR-78-87,
September 1978.
7. Young, A.L., J.A. Calcagni, C.E. Thalken, and J.W. Tremblay, "The
Toxicology, Environmental Fate, and Human Risk of Herbicide Orange and
its Associated Dioxin", Report from U.S. Air Force Occupational and
Environmental Health Laboratory, Brooks AFB, TX, No. OEHL TR-78-92.
October 1978.
8. Kiefer, I.G. and R.H. Wyer, "Disposal of Herbicide Orange", EPA Draft
Report, April 1979.
81
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9. Report of the Interagency Ad Hoc Work Group for the Chemical Waste
Incinerator Ship Program, U.S. EPA, U.S. Dept. Commerce, U.S. DOT,
Sept., 1980.
10. Thomas, T.J., et al. Land-Based Environmental Monitoring at Johnston
Island-Disposal of Herbicide Orange. Prepared for U.S. Air Force
Occupational and Environmental Health Laboratory by Battelle Columbus
Laboratories, Columbus, Ohio, Sept., 1978.
11. Ackerman, D.G., et al. Operations Plan and Guidelines for the At-Sea
Incineration of Liquid Silvex. Prepared by TRW for U.S. EPA, March
1980.
12. Polychlorinated Biphenyls-Ambient Water Quality Criteria. Criteria and
Standards Division, Office of Water Planning and Standards, U.S.
Environmental Protection Agency, Washington, D.C., NTIS #PB 296803.
13. Ackerman, D.G., et al. At-Sea Incineration of Herbicide Orange Onboard
the M/T Vulcanus. EPA-600/2-78-086. April 1978.
14. Huibregtse, K.R., et al. Manual for the Control of Hazardous Material
Spills, Vol. I. Spill Assessment and Water Treatment Techniques.
EPA-600/2-77-277, November 1977.
15. U.S. Dept. of the Air Force, Final Environmental Impact Statement,
Disposition of Orange Herbicide by Incineration, November 1974.
16. U.S. Air Force Logistics Command, Contingency Plan for Ocean Incineration
of Herbicide Orange. San Antonio ALC, April 1977.
17. Air Force Logistics Command, Programming Plan 75-19 for the Disposal of
Orange Herbicide. San Antonio ALC, April 1977.
18. U.S. Dept. of Health and Human Services, 1979 Registry of Toxic Effects
of Chemical Substances, R.J. Lewis and R.L. Tatken, eds. Sept. 1980.
19. Ackerman, D.G., et al. Guidelines for the Disposal of PCBs and PCB
Items by Thermal Destruction. Draft report prepared by TRW for U.S.
EPA, May 1980.
20. Federal Register 44(169);50766-50786. August 29, 1979.
21. Preliminary Survey of Existing Maritime Terminal Facilities on Continen-
tal United States Atlantic, Gulf and West Coasts which have Capabilities
of Serving an At-Sea Incineration Ship. TRW, 1980.
22. Electric Power Research Institute. Disposal of Polychlorinated Biphenyls
(PCBs) and RGB-Contaminated Materials. Volume 2: Suggested Procedures
for Development of PCB Spill Prevention Control and Counter-measure Plans,
EPRI FP-1207, Vol. 2, Oct. 1979.
82
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23. Zelenski, S.G., J. Hall, and S.E. Haupt. Applying for a Permit to
Destroy PCB Waste Oil, Volume I, Summary. EPA-600/2-81-033a, March 1981.
24. U.S. Environmental Protection Agency, Final Environmental Impact State-
ment, "Designation of a Site in the Gulf of Mexico for Incineration of
Chemical Wastes", July 1976.
25. U.S. Environmental Protection Agency, Draft Environmental Impact State-
ment on the North Atlantic Incineration Site, 1979.
26. U.S. Environmental Protection Agency, Ocean Dumping Regulations, Research
Permit No. 770DH001R and Special Permit No. 770DH001S.
27. Ackerman, D.G., R.J. Johnson, E.L. Moon, A.E. Samsonov, and K.H.
Scheyer, "At-Sea Incineration" Evaluation of Waste Flow and Combustion
Gas Monitoring Instrumentation Onboard the M/T. Vulcanus", EPA-600/
2-79-137, July 1979.
28. "Safety Plan for Incineration of Herbicide Orange Onboard the M/T
Vulcanus", TRW Report to EPA, May 1977.
29. Rappe, C. and H.R. Buser, "Formation and Degradation of Polychlorinated
Dibenzo-p-dioxins (PCDDs) and Dibenzofurans (PCDFs) by Thermal Processes",
paper presented at 178th National American Chemical Society Meeting,
Washington, D.C., September 9-14, 1979.
83
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APPENDIX A
INVENTORY OF PCB STOCKS
This appendix contains specific Information obtained from Individuals
responsible for the disposal of government-owned PCB wastes (Sections A-l
through A-7). This Information supplements data presented In Section 2 of
this report. Additional information from three private industry contacts is
presented in Sections A-8 through A-10. Quantities, locations, and descrip-
tions of available and potentially available PCB stocks are included.*
Disposal cost and timing are two of the key variables which determine
the amount of PCBs in this inventory which will actually be available for at-
sea incineration. For several organizations, willingness to use at-sea
incineration (as opposed to land-based alternatives) will depend on the total
cost of disposal. Other organizations are investigating land-based disposal
methods for both cost and timing considerations.
For incineration of PCB fluids, total disposal cost consists of two
elements: transportation cost and incineration cost. Transportation costs
for hazardous wastes (by truck) are approximately $3.00 per mile plus a 15
to 19 percent fuel surcharge (1). Costs for land-based incineration of PCBs
vary widely, depending on the nature of the waste (e.g., sludge content). A
recently published price list from one land-based incineration firm quotes
the following prices for disposal of PCB liquids containing less than 5%
sludge (2): $0.50 per pound for materials in bulk (greater than 20,000
pounds) and $500 per drum (greater than 25 drums). Costs for at-sea incinera-
tion of PCBs are difficult to estimate, because these types of waste have
never been disposed of in this manner. However, for organochlorine liquids
in general, it has been estimated that at-sea incineration is less expensive
than land-based incineration (3).
*See Section 2 of this report for a definition of the terms "available" and
"potentially available" as they are used in this report.
84
-------
Timing is also considered important for many of the organizations con-
tacted for this inventory. In some cases, organizations interested in at-sea
incineration could not continue storing wastes for such a project if it would
not be accomplished until late 1981. These organizations contracted for land-
based disposal services, and their wastes are not reported in the inventory.
Other organizations, while still considering at-sea incineration as a dis-
posal method, have initiated inquiries to and/or negotiations with land-based
disposal firms. Wastes from these organizations are reported in the inventory
as available, but availability is contingent on timely inception of an at-sea
incineration project.
The following sections present data on PCB waste stocks obtained from
verbal and written contacts with responsible individuals in each organization.
These data are current as of approximately September 1981.
A-l. GOVERNMENT ORGANIZATION #1
This organization has available 10,000 gallons of PCBs in three ware-
houses in the Washington, D.C. area. An additional 55,000 gallons of PCB
fluids are potentially available through this organization from accelerated
transfer of fluids from transformers and from other Federal agencies in the
Washington area. Substantially more PCB transformer fluids are still in ser-
vice than are out of service. The total quantity is about 250,000 gallons
which will be removed over the next 10-20 years. Approximately 3,000 gallons
of PCB fluids from this organization were disposed of by land-based incinera-
tion (no price given), but at-sea incineration is still being considered for
disposal of remaining waste stocks. Table A-l shows site locations, waste com-
position, and applicable transportation modes for these wastes. This organi-
zation does not have a regular transportation contractor. The contact person
indicated that one would be selected on a competitive basis.
A-2. GOVERNMENT ORGANIZATION #2
This organization is responsible for disposal of 21,500 gallons of PCB
fluids which are considered available. No potentially available stocks were
identified. The location and composition of the available stocks are shown
in Table A-2. The PCBs in Alabama may be incinerated on land, but a schedule
85
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TABLE A-l. PCB STOCKS FROM GOVERNMENT ORGANIZATION #1
Storage site
locations
Stock descriptions
Storage container
descriptions
Transportation
information
Washington, D.C.
Area #1
o> Washington, D.C.
04 Area #2
Washington, D.C.
Area #3
Amount: Approximately 4,000 gallons.
Description: Transformer fluids,
some kerosene and Varsol rinsate.
No sludge, small amount of water
cover 1n a few of the barrels.
100% pumpable.
Amount: Approximately 3,000 gallons.
Description: Same as above.
Amount: Approximately 3,000 gallons.
Description: Same as above.
All stocks stored 1n
55 gallon drums. None
are leaking, some are
overpacked.
Same as above.
Same as above.
Truck transport
only.
Truck transport
only.
Truck and rail trans-
port available.
-------
TABLE A-2. PCB STOCKS FROM GOVERNMENT ORGANIZATIONS #2
Storage site
locations
Stock descriptions
Storage container
descriptions
Transportation
information
Alabama
New York
Amount: Approximately 20,000 gallons.
Description: Transformer oil,
100% pumpable.
Amount: Approximately 2,000 gallons.
Description: Arochlor 1260 in sludge
with activated carbon and kerosene.
75% pumpable.
All stocks stored In
6E and 17E 55 gallon
drums, good to
excellent condition.
Same as above.
Rail and truck trans-
port available.
Truck transport
only.
00
-------
for this is highly uncertain. Until this schedule is defined and funding is
obtained, at-sea incineration is still being considered as a disposal method.
A-3. GOVERNMENT ORGANIZATION #3
This organization owns 20,000 gallons of PCS fluids which are considered
available for at-sea incineration. No potentially available PCBs were identi-
fied. The contact person was very willing to help locate additional PCB
wastes from private- and publicly-owned utilities. The available PCBs are
stored in Alabama. They consist of a mixture of transformer fluid, pure PCB,
and rinsates (solvents, mineral spirits). Concentrations of PCB range from
50% to 100%. Little or no water is present in the stocks. They are nearly
100% pumpable (very little sludge). All stocks are stored in 55-gallon drums
(477 drums total). Truck and rail transport are applicable. An estimate of
$500 per drum was quoted to the responsible official in this organization by
a representative of a land-based incineration firm for disposal of these PCBs.
A-4. GOVERNMENT ORGANIZATION #4
The total quantity of available PCB fluids from this organization is
271,800 gallons. An additional 628,000 gallons are still in transformers,
hydraulic systems, and lubricating systems and are considered potentially
available. Site locations and waste compositions are shown in Table A-3.
Some volumes reported in the table were obtained by assuming an approximate
density of 13 pounds per gallon for transformer fluids and 10 pounds per
gallon for waste oils. These approximations were obtained from a contact
within this organization.
A-5. GOVERNMENT ORGANIZATION #5
PCB stocks owned by this organization are stored at three GOCO (govern-
ment-owned, contractor operated) facilities. The total quantity of available
PCB fluids from all three facilities is 41,700 gallons. Potentially available
PCB fluids total about 24,000 gallons. Because of the nature of the owner-
ship of these wastes, responsible officials at two of the GOCO facilities were
especially concerned as to their liability in any EPA sponsored disposal pro-
ject, once wastes had left their facility.
88.
-------
TABLE A-3. PCB STOCKS FROM GOVERNMENT ORGANIZATION #4
co
vo
Storage site
locations
Tennessee #1
Stock descriptions
Bulk storage. Amount: Approximately
160,000 gallons. Description: 70 ppm
PCB 1n mineral oil.
Bulk storage. Amount: Approximately
8,000 gallons. Description: 700 ppm
PCB in waste oils.
Bulk storage. Amount: Approximately
6,000 gallons. Description: 1,000 ppm
PCB in waste oils.
Bulk storage. Amount: Approximately
20,000 gallons. Description: 2,500
ppm PCB in waste oils.
Transformers. Amount: 55,550 gallons.
Description: Fluids not yet removed
from transformers.
Hydraulic systems. Amount: 1,300
Storage container
descriptions
One 120,000 gallon
storage tank, two 20,000
gallon storage tanks.
One storage tank.
One storage tank.
One storage tank.
92 units.
6 units.
Transportation
information
Truck and rail trans
port available.
Same as above.
Same as above.
Same as above.
Same as above.
Same as above.
Tennessee #2
gallons. Description: PCB concentra-
tion ranges from 125 to 16,000 ppm.
Fluids are not yet removed from the
hydraulic systems.
Drum storage. Amount: Approximately
10,600 gallons. Description: Waste
oils, kerosene rinsate, and other
unspecified wastes. PCB concentra-
tion >500 ppm.
Stored in 55 gallon
drums.
Truck and rail trans-
port available.
(continued)
-------
TABLE A-3. CONTINUED
Storage site
locations
Stock descriptions
Storage container
descriptions
Transportation
information
Tennessee #3
Kentucky
Drum storage. Amount: Approximately
2,000 gallons. Description: Waste
oils, kerosene rinsate, and other
unspecified wastes. PCB concentra-
tion >50 ppm.
Bulk storage. Amount: Approximately
12,000 gallons. Description: Trans-
former fluids.
Transformers. Amount: Approximately
119,000 gallons. Description: Fluids
not yet removed from transformers.
Transformers. Amount: Approximately
6,000 gallons. Description: Fluids
not yet removed from transformers.
Hydraulic systems. Amount: Approxi-
mately 7,300 gallons. Description:
Fluids not removed from systems.
PCB concentration ranges from 90-300
ppm.
Bulk storage. Amount: Approximately
11,200 gallons. Description: Trans-
former fluids.
Transformers. Amount: Approximately
105,000 gallons. Description: Fluids
not yet removed from transformers.
Stored in 55 gallon
drums.
Stored in two storage
tanks.
84 units.
15 units.
4 units.
Two storage tanks.
90 units.
Same as above.
Same as ahove.
Same as above.
Truck transport only.
Same as above.
Truck and rail trans-
port available.
Same as above.
(continued)
-------
TABLE A-3. CONTINUED
Storage site
locations
Stock descriptions
Storage container
descriptions
Transportation
information
Ohio
Lubricating systems. Amount: Approxl- 1 unit.
mately 23,000 gallons. Description:
Lubricating oil not yet removed from
systems. PCB concentration 75 ppm.
Hydraulic systems. Amount: 500 gal-
lons. Description: 1.5-5.0% PCB.
Drum storage. Amount: Approximately
100 gallons. Description: Waste
oils, PCB concentration >500 ppm.
Bulk and drum storage. Amount:
Approximately 42,300 gallons.
Description: Transformer fluid
(Pyranol).
Transformers. Amount: Approximately
161,000 gallons. Description: Fluids
not yet removed from transformers.
Lubricating systems. Amount:
Approximately 150,000 gallons.
Description: Lubricating oil not yet
removed from systems. PCB concen-
tration ranges from 80 to 250 ppm.
5 units.
Stored in 55 gallon
drums.
Two storage tanks and
approximately 200 drums.
133 units.
8 units.
Same as above.
Same as above.
Rail and truck trans-
port available.
Same as ahove
Same as above.
Same as above.
-------
Table A-4 summarizes the location and composition information obtained
for these stocks. Disposal of the stocks in New Mexico and Colorado by land-
based incineration is being considered, however, at-sea incineration has not
been ruled out. The responsible official at the New Mexico facility quoted
a rough estimate for land-based incineration of these stocks at $750 per
drum, not including transportation. Only the 60CO organization in Missouri
has a regular transportation contractor for waste shipments.
A-6. GOVERNMENT ORGANIZATION #6
This organization is the operator of a publicly-owned municipal utility.
The total volume of available PCB fluids from this organization is approxi-
mately 60,000 gallons. No potentially available stocks were identified.
Available stocks consist of 70 55-gallon drums of transformer fluid (30-40%
PCB), and a 30,000 gallon tank of PCB-contaminated #6 (Bunker C) fuel oil.
The fuel oil contains 1000 ppm PCB. It is very viscous and would be cut with
#2 fuel oil in order to facilitate pumping. With dilution the total volume
of both transformer fluid and fuel oil would be about 60,000 gallons.
Cost is the prime consideration in determining availability of these
stocks. If the cost to the utility of at-sea incineration would be com-
petitive with land-based disposal alternatives, these wastes would be avail-
able. Current estimates for land-based incineration costs range from $200,000
to $300,000, including transportation. A proposal is being evaluated for
non-thermal destruction of the PCBs in the contaminated fuel oil. A feasi-
bility study and conceptual design for a non-thermal destruction system has
been proposed.
A-7. GOVERNMENT ORGANIZATION #7
This organization has approximately 100,000 gallons of PCB transformer
fluids plus about 40,000 gallons of rinsate for a total of 140,000 gallons
of waste stocks. Site locations are nationwide. All stocks are 100% pump-
able (no sludge). However, the contact person did not appear to be interested
in at-sea incineration as a disposal method for these PCBs. These stocks are
therefore considered only potentially available for at-sea incineration. The
organization is planning to dispose of their stocks via commercial land-based
facilities, and has issued a request for proposals for incineration of at
92
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TABLE A-4. PCB STOCKS FROM GOVERNMENT ORGANIZATION 05
Storage site
locations
Stock descriptions
Storage container
descriptions
Transportation
information
Missouri
New Mexico
VO
CO
Colorado
Amount: Approximately 35,000 gallons.
Description: 40% PCB in Therminol.
Drum storage.
5,500 gallons.
former fluids.
Amount: Approximately
Description: Trans-
Available)
Drum storage. Amount: Approximately
4,600 gallons. Description: Trans-
former fluids. (Potentially available)
Transformers. Amount: Approximately
11,000 gallons. Description: Fluids
not yet removed from transformers.
Drum storage.
1,200 gallons.
former fluids.
Transformers.
Amount: Approximately
Description: Trans-
Amount: Approximately
Description: Fluids
8,800 gallons
not yet removed from transformers.
55-gallon drums, excel-
lent condition, DOT
approved. Some overpac ked.
55-gallon drums.
55-gallon drums.
Number of units not
available.
55-gallon drums.
20 units.
Truck transport
only.
Truck transport
only.
Same as above.
Same as above.
Truck transport
only.
Same as above.
-------
least one-third of the total national stocks. In general, the contact In
this organization has been reluctant to provide information.
A-8. PRIVATE INDUSTRY CONTACT #1
The total quantity of PCBs available for at-sea incineration from this
source is up to 750,000 gallons. Some of these wastes may be Incinerated
under the current ocean dumping permit. This firm handles PCB waste storage
and disposal operations for industrial clients. Wastes are currently avail-
able from clients in four states: Michigan, Maryland, Pennsylvania, and New
Jersey. These wastes are all askarel (transformer fluid) concentrates.
Much of the waste is stored in drums. These wastes could be loaded and
shipped within 180 days of notification to proceed.
Cost is the major factor in determining the availability of these
stocks. The cost to this firm (and/or its customers) would have to be less
than or equal to the costs of land-based incineration for these stocks to be
available.
A-9. PRIVATE INDUSTRY 'CONTACT §2
This firm is storing 40,000 gallons of transformer and capacitor fluids
(average 30-40% PCB) for its customers. Another 80,000 gallons is potentially
available from other customers; however, the firm is not currently accepting
additional PCBs for storage. The storage site is -ocated in the Canadian
province of Ontario.
Because there is currently no way for this firm to dispose of its PCBs
in Canada, they are interested in participating in this project. However,
a major problem exists because the U.S.-Canada border is now closed to ship-
ment of PCBs in either direction. If the border were opened for shipment of
these wastes, they would be considered available.
A-10. PRIVATE INDUSTRY CONTACT #3
This firm is storing approximately 840 55-gallon drums (46,000 gallons)
of liquid PCBs for industrial clients in the Canadian province of Alberta.
The wastes could be shipped to the Gulf coast by truck if the U.S.-Canada
border were opened (see private industry contact #2). This firm is still
94
-------
accepting PCBs from clients, so that by early 1982 the amount of available
PCBs could easily double.
95
-------
REFERENCES FOR APPENDIX A
1. Special Report: Competition for PCB Disposal Dollars, New Processes
Create New Industries, Prompt a Weighing of Costs, BNA Chemical Regula-
tion Reporter, 5 June 1981, pp 216-218.
2. Price List - Liquid PCBs, Rollins Environmental Services (TX) Inc.,
17 February 1981.
3. Shih, C. C., et al. Comparative Cost Analysis and Environmental Assess-
ment for Disposal of Organochlorine Wastes. EPA-600/2-78-190. Prepared
for U.S. Environmental Protection Agency by TRW Inc., Redondo Beach,
California, August 1978.
96
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APPENDIX B
SAFETY PLAN FOR INCINERATION OF LIQUID PCBs
ONBOARD THE M/T VULCANUS
B.I PURPOSE AND SCOPE
The purpose of this appendix is to define a plan to insure the health and
safety of personnel participating in the incineration of liquid PCBs onboard
the M/T Vulcanus. All monitoring and ship personnel will adhere to the pro-
visions of this plan during all phases of the incineration. The monitoring
leader will brief officers and crew members of the M/T Vulcanus with this safety
plan data and procedures. This is particularly important with regard to per-
sonal hygiene, equipment malfunctions, spills, and criteria for terminating a
given burn. Because of the inherent confinement while at sea and required
interaction of the monitoring team and Vulcanus personnel, a thorough under-
standing of the contents of this document is mandatory on the part of all
concerned.
This Safety Plan has been adapted from the plan used for shipboard oper-
ations during the at-sea incineration of Herbicide Orange onboard the M/T
Vulcanus. The scope of the health and safety plan is limited to shipboard in-
cineration operations. Specifically excluded are the safety requirements for
transportation and ship loading operations, which are covered by contractor
and M/T Vulcanus procedures.
To assist in establishing and maintaining health and safety procedures
and routines, a Safety Director for at-sea incineration operations will be
designated. This individual will be a member of the sampling and monitoring
team. His duties will include: safety procedure briefing of all ship's
personnel; monitoring the implementation of this safety olan; and advising
the monitoring team leader, ship's master, and other appropriate personnel
regarding corrective action for unsafe conditions or incidents.
B.2 POTENTIAL HAZARDS
Polychlorinated biphenyls (PCBs) are derivatives of the compound biphenyl
in which from one to ten of the hyuiogen atoms have been replaced with chlorine
97
-------
atoms. PCBs synthesized for commercial use are mixtures of isomers. They are
not naturally occurring compounds.
PCBs have extremely high thermal and chemical stability. They are of low
volatility (decreases with increasing chlorine content), are relatively non-
flammable, and have excellent electrical insulating characteristics. Commercial
mixtures are liquids at room temperature. They are insoluble in water, have a
low degree of hygroscopicity, and are soluble in most common organic solvents.
Although PCBs have low acute toxicities (Table B-l), other adverse effects
have been found in humans, laboratory animals, and other oganisms (3). A
summary of toxicological and epidemiological data on the effects of PCBs, adapted
from Reference 3 is given below. More detailed discussions are given in Refer-
ences 2 and 3. PCBs appear to cause tumors in laboratory animals. There are
limited human epidemiological data, but excess carcinogenic effects have been
observed in several large groups of people exposed to PCBs. Several studies in
animals have shown that PCBs cause fetal resorption, birth defects, and high off-
spring mortality rates at levels of 1-5 ing/kg body weight. There is evidence
that PCBs produce immunosuppressive effects in laboratory animals. PCBs have
been observed to cause liver damage. PCBs have caused chloracne in workers
occupationally exposed to air levels as low as 0.1 mg/m .
Adverse effects observed in laboratory tests also occur in wild animals.
PCBs are known to bioaccumulate and to biomagnify. Effects noted in mink fed
PCB contaminated fish include reproductive failure, reduced weight gain,
increased mortality, and enlargement of liver, kidneys, and heart.
PCB mixtures are extremely toxic to several species of aquatic invertebrates
and fish. Aroclor 1254 is toxic to several shrimp species at levels of about
1 ppb. Increased mortality of sheepshead minnows was observed in water containing
0.16 ppb of Aroclor 1254. Concentrations of Aroclor 1242, 1016, and 1254 as low as
0.1 ppb have been demonstrated to depress photosynthetic activity in phytoplankton.
The Occupational Safety and Health Administration (OSHA), established by
the Occupational Safety and Health Act, has set the following standards for
occupational exposure to PCBs (4):
98
-------
TABLE B-l TOXICITIES OF SELECTED PCB FORMULATIONS
PCB
Formulations
Aroclor 1221
1232
1242
1248
1254
1260
1262
1268
2565
4465
Rat, Oral LDcn,
mg/kg b°
3980
4470
4250
11,000
1295
1315
11,300
10,900
6310
16,000
Rabbit, Skin LD. .,
mg/kg L0
3169
2000
--
1269
—
2000
3160
2500
3160
3160
• Chlorodiphenyl (42% chlorine) - TWA of 1 mg/m3 and STEL of
2 mg/mj.
• Chlorodiphenyl (54X chlorine) - TWA of 0.5 mg/m3 and STEL
of 1 mg/m3.
The TWA (Time Weighted Average) is a concentration to which a worker can
be exposed for 8-hour days and 40-hour weeks indefinitely without adverse
effects. The STEL (Short Term Exposure Limit) is a level to which a worker
may not be exposed for more than 15 minutes without suffering adverse effects.
The National Institute of Occupational Safety and Health has proposed an
occupational exposure limit to PCBs of 1.0 yg/m on a time weighted average 10-
hour day, 40-hour week basis (Natl. Inst. Occup. Safety Health, 1977). Assuming
a tidal air volume of 10 m in an eight-hour day and 100 percent absorption, the
resulting dose at this exposure level would be 10 yg/day. However, this is a
recommendation and is not legally binding. The current legal threshold limit
value (TLV) for PCBs as established by the American Conference of Governmental
Industrial Hygienists (ACGIH) is 500 yg/m3 (0.5 mg/m3).
99
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B.3 CRITERIA FOR INTERRUPTION OF A BURN
The monitoring Team Leader acting on behalf of the U.S. Environmental
Protection Agency, shall retain the authority to interrupt incineration
operations while the sampling, monitoring team members are onboard the M/T
Vulcanus. Furthermore, the Team Leader shall also retain the authority to
withdraw team participation in the project at any time during the project if,
in his judgement, the conduct of shipboard operations does not meet the safety
standards outlined in this plan. The criteria that will be used by the Team
Leader to measure safe shipboard operation are summarized in Table B-2 and
discussed in the following sections. These criteria will only be used as
guidelines, and the final decision for temporary or permanent interruption
of any individual incineration test, portion of a particular test, or monitor-
ing participation in the project rests with and is the responsibility of the
monitoring Team Leader. It should also be recognized that the decision to
terminate any individual incineration test is not the sole responsibility
of the monitoring Team Leader. The authority to interrupt any individual in-
cineration test shall also rest with the captain of the M/T Vulcanus. Land-
based project personnel will normally be consulted prior to termination of
a burn.
B.3.1 Plume Impingement
The plume arising from the incinerator stacks will be injected with
ammonia as required to make it visible for tracking. The monitoring Team
Leader will direct temporary interruption of an individual burn of liquid
PCBs and withdrawal of shipboard personnel to a safe area if, at any time
during the test, the plume is observed to have a high probability of descend-
ing onto and remaining on the deck of the M/T Vulcanus.
At the temporary interruption of incineration of liquid PCBs, the feed-
stock to the incinerators will be switched to fuel oil until safe conditions
can again be met. If, however, prolonged contact of the plume with the
M/T Vulcanus becomes apparent, the furnaces will be shut down until the meter-
ological conditions become more favorable or corrective action has been taken
by proper vectoring of the M/T Vulcanus with respect to the wind direction.
100
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TABLE B-2. CRITERIA FOR INTERRUPTION OF INCINERATION
OF LIQUID PCBs
Observation/
Measurement
Decision Criteria
Action To Be Taken
Plume impingement
Liquid PCB spills
Combustion
temperature
Combustion
efficiency
Oxygen
Monitoring/recording
devices for CO, C07.
02. or PCB
Onboard determina-
tion of PCBs 1n
stack gas
Onboard determina-
tion of ambient
level of PCBs
Determination of
PCBs after each burn
Physical examination
of shipboard personnel
Plume is observed to have a
high probability of descending
onto and remaining on the deck
of the M/T Vulcanus.
Large spills that cannot be
readily contained.
Temperature drops below the
minimum allowable temperature
for thermal destruction
Combustion efficiency less
than 99.9%.
Excess QZ falls below the
required percentage
Malfunction of device.
PCB concentration in excess of
5 mg/m3 in the stack gas.
Ambient (personnel breathing
zone) level of PCBs in excess
of 0.5 mg/m3 over 8 hr.
Average destruction efficiency
of PCB less than 99.9%.
Excess PCB exposure in the
judgement of the physician.
Direct temporary termination of
incineration of liquid PCBs and
withdrawal of shipboard personnel
to a safe area.
Direct termination of incineration
of liquid PCBs and withdrawal of
shipboard personnel to a safe area.
Cut-off of waste flow to the
burners.
Direct termination of incineration
of liquid PCBs.
Cut-off of waste flow to the
burners.
Cut-off of waste flow to the
burners.
Direct termination of incineration
of liquid PCBs.
Direct termination of incineration
of liquid PCBs and/or immediate
withdrawal of shipboard personnel.
Direct withdrawal of monitoring
participation and recommend
against subsequent burns unless
corrective action can be taken.
Direct withdrawal of affected
personnel. Evaluate corrective
actions if possible to permit
continued incineration.
The monitoring Team Leader will consult with the ship's Master and the U.S. EPA before
taking any action to direct termination of a PCB burn. If appropriate, fuel oil may be
substituted as a fuel while corrective action 1s being taken.
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B.3.2 Liquid PCB Spills
The monitoring Team Leader will direct termination of any individual
burn with liquid PCBs if a spill occurs onboard the M/T Vulcanus that cannot
be readily contained.
B.3.3 Combustion Efficiency
The CO and CO- levels determined at or near the exit plane of the incin-
erator stacks will be used as an indication of overall combustion efficiency
using the following equation:
% Combustion Efficiency = C02 concentration
COp concentration + CO concentration
Combustion efficiencies in excess of 99.9 percent are deemed necessary as an
indication that high destruction efficiencies for the liquid PCB constituents
may be anticipated. The 99.9 percent combustion efficiency corresponds to
approximately 100 ppm CO in the combustion product gas. The high combustion
efficiency is required because of the toxic and persistent nature of PCBs.
The detection of large amounts of CO in the stack gas (and hence lower com-
bustion efficiency) is a good indication that incomplete mixing is taking
place in the incinerator. The monitoring Team Leader will direct termination
of any individual burn if the combustion efficiency falls below 99.9 percent
and this situation cannot be corrected.
B.3.4 Onboard Determination Of Stack Emissions Of Constituents
In addition to monitoring the CO and COp levels in the stack gas, grab
samples collected from the benzene impinger will also be directly injected
into a gas chromatograph (GC) equipped with an electron capture detector
(ECD). The GC/ECD combination provides a lower detection limit of approx-
imately 0.2 mg/M for PCBs in the stack gas. For onboard safety requirements,
the allowable limit for PCB concentration in the stack gas will be 5 mg/M .
The TLV for Aroclor 1254 is 0.5 mg/M3. The 5 mg/M3 limit is selected on the
basis that, with atmospheric dispersion, an emission concentration equal to
10 times the TLV would lead to an ambient level concentration of less than
0.01 TLV. For chronic 24-hour exposures of the sampling and ship personnel
to PCBs in ambient air, the 0.01 TLV level is considered to be safe.
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Assuming 99.9 percent destruction efficiency, a combustion effluent flow
rate of 70,000 m /hr (dry, 20°C), and a maximum allowable PCB concentration in
the stack gas, the maximum PCB input rate per incinerator is:
1 Kv*
v kg „ ,n6 mg „ n nm mg PCB in Stack „ - , _ 5 mg PCB in Stack
Y HF x 10 kg x °-001 mg PCB in Feed x 70,000 m3 ~ m3
Y = 350 or 0.35 ~ (750 kg/hr for both incinerators)
This represents input rate in terms of mass of PCB, not fluid containing PCB.
With dispersion in the atmosphere, the levels of (unburned) PCBs in the living/
working areas of the ship should be well below 0.01 TLV (0.005 mg/m ).
The monitoring Team Leader should consider interrupting any individual
3
burn if the PCB concentration in the stack gas is in excess of 5 mg/M .
B.3.5 Onboard Determination Of Ambient Level Of Liquid PCB Constituents
Ambient PCB concentrations result from atmospheric disperson of stack
emissions as well as any fugitive emissions onboard the M/T Vulcanus. The
monitoring Team Leader will alert shipboard personnel and direct the location
and elimination of emission sources if the ambient (personnel breathing zone)
level of PCBs in excess of 1.0 mg/M . The monitoring Team Leader should con-
sider interrupting any individual burn and/or immediately withdrawing ship-
board personnel from a contaminated area if the ambient (personnel breathing
zone) level of PCB is in excess of 0.5 mg/M over an 8-hour period.
B.3.6 Determination Of PCB Levels
At completion of each burn, the grab samples collected during the in-
cineration of liquid PCB and the personal monitoring devices will be analyzed
for PCB content. The monitoring Team Leader will direct withdrawl of team
participation and recommend against subsequent burns if the results of the
analysis indicate any of the following: 1) the average destruction effi-
ciency for PCBs with the M/T Vulcanus incinerators is less than 99.9 percent;
2) the average ambient level onboard the M/T Vulcanus is in excess of 0.5
mg/M3.
At 99.9 percent PCB destruction efficiency, the total amount of PCB emit-
ted is expected to be 700 kg/hr from both incinerators at a total mass feed
rate of PCB (not PCB fluid) of 700 Kg/hr. With atmosoheric dispersion,
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this level of PCB emission at the stack would lead to a maximum ambient PCB
level of about 0.005 mg/m , well below the TLV.
B.3.7 Physical Examinations
Because of the potential health hazard related to the incineration of
liquid PCBs onboard the M/T Vulcanus, complete physical examinations will be
performed on all monitoring team personnel involved in the sampling and
monitoring effort. These physical examinations will be conducted on the
employee just prior to his initial participation in the project (baseline),
at any time the monitoring team may desire during the project (periodic),
and immediately after completing his last task in the project (follow up).
Specific medical tests will be performed in accordance with the best currently
available medical/scientific information on the effects of PCBs. The monitor-
ing Team Leader may direct withdrawl of monitoring team participation in the
project and recommend termination of project if the results of these physical
examinations indicate excess PCB exposure in any one of the shipboard personnel
B.4 PERSONNEL PROTECTIVE EQUIPMENT
Because of the potential health hazard relating to the sampling and
monitoring of the incineration of liquid PCBs onboard the M/T Vulcanus, special
safety requirements have been established to minimize hazards to monitoring
personnel. Personnel must be protected against any contact with the liquid
PCBs or possible hazardous combustion products.
To ensure adequate protection, disposable coveralls and shoe covers will
be worn by all personnel working in areas of the ship designated as contam-
inated: pump room, incinerator room, and main deck. Monitoring team per-
sonnel performing sample recovery will wear protective gloves. All person-
nel will wear safety shoes. Hard hats will be required for all personnel
in the test area.
In addition to the normal equipment used in this type of activity, the
following items will be provided by the monitoring team unless otherwise
stated.
1) Gas masks with canisters suitable for use with liquid PCBs,
phosgene, or HC1 (MSA Rocket Propellant Masks No. EP-86847;
canister type GMC-S, P/N 05-84908).
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2) MSA Model 1 monitoring kits, Universal Tester (P/N 05-83500)
with phosgene gas sampling tubes (P/N 89890).
3) Portable personal monitors, MSA Model G or S pumps fitted with
sample tubes containing Chromosorb 102.
4) Fire Extinguishers
Ansul - Model CD-5
Sentry - Model Sy-1012
5) Fire Fighter Entry Suits
6) Scott Air Pak
7) Portable Emergency Eye Baths
All monitoring team personnel who will be onboard the M/T Vulcanus during in-
cineration of the liquid PCBs will be duly trained on the proper use and
operation of the above equipment.
Other general safety requirements that will be adhered to are the fol-
1owi ng:
1) All personnel within the incinerator area and/or sampling area
during the incineration of liquid PCBs will have an approved
gas mask and canister attached to their persons and available
for immediate use.
2) If an emergency condition is detected by the monitoring team,
personnel in remote locations will be notified to don masks
and to evacuate a given area. Simultaneously, team personnel
will notify the ship's Master of the imminent danger. Con-
versely, if the ship's crew detect an emergency condition,
they will immediately notify all other personnel onboard the
vessel.
3) Personnel working in the incinerator area (changing the sampling
probes, making connections to the sampling equipment, probe
positioning, etc.) will wear entry suits.
4) Confirmed or suspected spills will be reported to the ship's
Master for proper clean up.
5) Personal monitors will be located in appropriate areas of the
ship.
6) During testing selected locations will be monitored for the
presence of HC1 gas with the Universal Tester. Monitoring
will be conducted in the following locations: bridge, main
deck, stern and combustion deck. Monitoring team personnel
will be reponsible for these monitoring activities.
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B.5 PERSONAL HYGIENE
Available data indicate that compounds may enter the human system
through the skin. Other means of introduction include ingestion, inhala-
tion, and contact with the eyes. Symptoms reported in persons suffering
systemic PCB intoxication include chloracne, nausea, vomiting, weight loss,
jaundice edema, and abdominal pain.
The concept of isolation of contaminated areas and preservation of
"clean" areas will be utilized during incineration operations. An inter-
face area will be maintained which will ensure the integrity of the clean
area and the safety of personnel therein while isolating contaminated areas.
Adherence to this concept will prevent PCB contamination of facilities suit-
able for eating, drinking, smoking, and sleeping. The routes by which per-
sonnel move should be so arranged that the entrance to the working areas
and exits from the working area are separate, thereby preventing possible
confusion and subsequent contamination of clean facilities.
The basic requirements for effective personal hygiene against PCB-con-
taining materials are:
• Protection of personnel from vapor and liquid contact in the
contaminated areas by source control and protective gear.
• Provision of disposable clothing and foot covers.
• Provision of disposal facilities at the interface region be-
tween the contaminated and clean areas.
• Provision for shower, hand, face and eye-washing facilities
at the interface region.
• Provision of clean clothing and foot covering at the boundary
of the clean area upon return to working areas.
• Instruction in the use of the cleaning and protective equipment
and in methods of personal cleansing.
• Mandatory and enforced use of the above facilities and concepts.
A monitoring system for ensuring the cleanliness of areas such as the
galley, mess room, living quarters, bridge, toilets, and passageways, should
be developed and put into effect on a firm basis. A schedule of inspection
of the clean areas should be established, and the results of the monitoring
made known to the ship's Master. Activities such as eating, drinking and
smoking must be limited to clean areas.
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Finally, all working personnel should be made aware of the need for good
personal hygiene and of the consequences to themselves and others of poor
personal cleanliness and poor housekeeping. A training program should be
developed and personnel should be trained in personal hygiene practices. The
effectiveness of the program will depend on the degree to which personnel
accept the training, willingly put the principles to use, and cooperate in
preventing exposures. Personnel who are unwilling or unable to accept and
apply the personal hygiene procedures should be excluded from contact with
and entry to the working area by direction of the ship's Master.
B.6 SAFETY PROCEDURES AND MONITORING
The safety of all shipboard personnel will have top priority during the
incineration of liquid PCBs onboard the M/T Vulcanus. As a minimum, the
following safety precautions must be considered as they apply before, during,
and after burn operations. Many of these safety precautions are adapted from
procedures used on the Herbicide Orange project. They are grouped by parti-
cipating organizations to define and emphasize areas of responsibility.
B.6.1 M/T Vulcanus
1) After loading of the waste, all waste tank openings and viewing
ports shall be closed. A closed system shall be maintained
such that vapors do not escape into the atmosphere for the dur-
ation of the operation, except if required for tank soundings.
2) Any liquid PCB spills, leaks, or residuals detected during
and following loading operations shall be contained and decon-
taminated before the ship leaves port.
3) The system for measuring the tankage contents shall be sealed,
if possible. A schedule of tank content measurement and rate
of depletion shall be established.
4) The cause of apparently random and often severe vibrations from
the incinerators at frequent intervals during previous waste
burns shall be identified. Steps to eliminate this condition
shall be identified and implemented.
5) Fugitive liquid PCB emissions from the waste pumping room or
any other source shall be eliminated.
6) An automatic shut-off device shall be in operation on both
furnaces, set to turn off the flow of liquid PCBs if the
flame temperature drops below 1250°C.
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7) The furnaces may be brought up to operating temperature at a
rate consistent with ship's practice and experience using
fuel oil. When a flame temperature of 1280°C has been reached
in the furnace (using correlated thermocouple or optical pyro-
meter measurements) the feed stock may be switched over to
liquid PCB. The practice of converting to liquid PCB feed by
putting furnaces on stream successively should be followed. The
temperature of the furnace as read at the control panel should
not be allowed to drop more than 20°C at this time must be
restored to at least the original level before the next burner
is changed over to liquid PCB.
8) Monitoring of the furnaces for temperature and completeness
of combustion shall be in effect during the changeover. The
continuous record of temperature shall also be maintained during
this time.
9) The operational controls and monitoring panels shall be manned
at all times by a responsible individual to insure the incinera-
tors are operating within desired combustion parameters.
10) A device for addition of ammonia to make a visible plume shall
be installed and operable.
11) The speed and direction of the M/T Vulcanus during waste incin-
eration shall be controlled in such a manner that the incinera-
tor plume does not contact any part of the ship at any time
because of wind (eddys) or any other reason. The M/T Vulcanus
shall stay under the main propulsion all the time so that plume
impingement on the ship may be avoided by proper vectoring of
the ship with respect to wind direction changes. Additionally,
if the ship must assume a course and speed to stay in the burn
area and if that course and speed result in undesirable plume
conditions for safe operation, then the incinerators shall be
temporarily shut down or revert to fuel oil until safe condi-
tions can again be met.
12) The Vulcanus should demonstrate the ability to remain in con-
stant 24-hour communication with the on shore Test Director
by voice and by code, using frequencies and channels appropri-
ate to the area and to the conditions of transmission and re-
ception. This requirement supplements but is not intended
to supersede nor replace the existing communication equipment.
Daily communication with the on shore Test Director shall be
required reporting test progress and conditions. Emergency
conditions shall be reported as soon as possible.
13) Personnel of the M/T Vulcanus shall brief all sampling and
monitoring personnel regarding ship safety procedures and
regulations. This shall include, but not be limited to, the
assignment of lifeboat seating positions and at least one
lifeboat drill.
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14) The M/T Vulcanus shall comply with all applicable U.S. Coast
Guard rules and regulations governing a ship of this class and
specification.
B.6.2 Monitoring Team
1) Personal ambient air monitors shall be furnished by monitoring
crew. These monitoring units shall be analyzed for PCB as
requ i red.
2) Appropriate first aid and medical supplies and trained medical
personnel shall be available at operations headquarters to
respond to emergency situations onboard the M/T Vulcanus. Such
facilities shall also be available to all shipboard personnel
while at the docking facility.
3) The M/T Vulcanus crew and any other personnel boarding the M/T
Vulcanus shall be briefed by the monitoring Team Leader or his
designate about safety precautions and the potential hazards
of liquid PCBs.
4) Monitoring of the incinerator stacks for C0/C02 concentrations
shall be carried out by the sampling/monitoring team. The CO/
C02 determinations shall be used to assure that the desired
degree of combustion efficiency (99.9%) is achieved during the
incineration of liquid PCBs.
5) Sampling of the incinerator stacks for the determination of PCB
emissions, if any, shall be carried out by the monitoring crew.
The PCB levels in the incinerator stacks shall be determined
onboard the M/T Vulcanus by the sampling/monitoring crew with
the use of a benzene sampling train and a gas chromatograph.
The maximum allowable PCB levels in the incinerator stacks
shall be 5 mg/M3.
6) An onboard ambient air monitoring system shall be used by the
sampling/monitoring crew to monitor the PCB level in the crews
quarters, the combustion room, and the deck areas to assure
that the atmosphere does not contain materials at or above a
prohibited level of concentration. These measurements shall
not be limited to only the times when sampling is taking
place. Measurements indicating the presence of PCB levels
above 0.5 mg/M3 shall be immediately reported and steps
shall be taken by the M/T Vulcanus personnel to correct the
situation.
B.7 FIRST AID
The first aid instructions in the event of chemical poisoning, as given
in J.B. Bailey and J.E. Swift "Pesticide Information and Safety Manual"
(University of California, Division of Agricultural Sciences, July 1968),
are reproduced on the next three pages. These first aid instructions are
applicable to chemical poisoning by liquid PCB formulations.
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FIRST AID IN THE EVENT OF CHEMICAL POISONING
If you are along with the victim...
First - See that the victim is breathing; if not, give
artificial respiration.
Second - Decontaminate him immediately i.e., wash him off
thoroughly. Speed is essential!
Third - Call your physician.
NOTE: Do not substitute first aid for professional
treatment. First aid is only to relieve the
patient before medical help is reached.
If another person is with you and the victim...
Speed is essential; one person should begin first aid treat-
ment while the other calls a physician.
The physician will give you instructions. He will very likely
tell you to get the victim to the emergency room of a hospital. The
equipment needed for proper treatment is there. Only if this is impos-
sible should the physician be called to the site of the accident.
General
1. Give mouth-to-mouth artificial respiration if breathing has
stopped or is labored.
2. Stop exposure to the poison and if poison is on skin cleanse
the person, including hair and fingernails. If swallowed,
induce vomiting.
3. Save the pesticide container and material in it if any remains;
get readable label or name of chemical(s) for the physician.
If the poison is not known, save a sample of the vomitus.
Specific
Poison on Skin
• Drench skin and clothing with water (shower, hose, faucet).
• Remove clothing
• Cleanse skin and hair thoroughly with soap and water; rapidity
in washing is most important in reducing extent of injury.
• Dry and wrap in blanket.
Poison in Eye
• Hold eyelids open, wash eyes with gentle stream of clean
running water immediately. Use copious amounts. Delay of
a few seconds greatly increases extent of injury-
no
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• Continue washing for 15 minutes or more.
• Do not use chemicals or drugs in wash water. They may
increase the extent of injury.
Inhaled Poisons (dusts, vapors, gases)
• If victim is in enclosed space, do not go in after him without
air-supplied respirator.
t Carry patient (do not let him walk) to fresh air immediately.
• Open all doors and windows, if any.
• Loosen all tight clothing.
• Apply artificial respiration if breathing has stopped or is
irregular.
• Call a physician.
• Prevent chilling (wrap patient in blankets but don't overheat
him).
• Keep patient as quiet as possible.
t If patient is convulsing, watch his breathing and protect him
from falling and striking his head on the floor or wall. Keep
his chin up so his air passage will remain free for breathing.
• Do not give alcohol in any form.
Swallowed Poisons
t CALL A PHYSICIAN IMMEDIATELY
t DO NOT induce vomiting vf:
1) Patient is in a coma or unconscious.
2) Patient is in convulsions
3) Patient has swallowed petroleum products (that is,
kerosene, gasoline, lighter fluid).
4) Patient has swallowed a corrosive poison (strong acid or
alkaline products); symptoms: severe pain, burning sen-
sation in mouth and throat.
• If patient can swallow after ingesting a corrosive poison,
give the following substances by mouth. A corrosive substance
is any material which in contact with living tissue will cause
destruction of tissue by chemical action such as lye, acids,
Lysol, etc.
For acids: milk, water, or milk of magnesia (1
tablespoon to 1 cup of water).
For alkali: milk or water; for patients 1-5 years old,
1 to 2 cups; for patients 5 years and older,
up to 1 quart.
Ill
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IF POSSIBLE INDUCE VOMITING WHEN NON-CORROSIVE SUBSTANCE HAS BEEN
SWALLOWED
t Give milk or water (for patient 1-5 years old--! to 2 cups;
for patients over 5 years—up to 1 quart).
• Induce vomiting by placing the blunt end of a spoon not the
handle, or your finger at the back of the patient's throat,
or by use of this emetic—2 tablespoons of salt in a glass
of warm water.
• When retching and vomiting begin, place patient face down
with head lowered, thus preventing vomitus from entering the
lungs and causing further damage. Do not let him lie on his
back.
• Do not waste excessive time in including vomiting if the
hospital is a long distance away. It is better to spend
the time getting the patient to the hospital where drugs
can be administered to induce vomiting and/or stomach pumps
are available.
0 Clean vomitus from person. Collect some in case physician
needs it for chemical tests.
Chemical Burns of Skin
• Wash with large quantities of running water.
0 Remove contaminated clothing.
• Immediately cover with loosely applied clean cloth, any kind
will do, depending on the size of the area burned.
• Avoid use of ointments, greases, powders and other drugs in
first aid treatment of burns.
• Treat shock by keeping patient flat, keeping him warm, and
reassuring him until arrival of physician.
B.8 ANALYTICAL PROCEDURES FOR THE DETERMINATION OF PCBs
ONBOARD THE M/T VULCANUS
B.8.1 Introduction
It is necessary to analyze stack, ambient air, and other samples for
PCBs onboard Vulcanus to assure safe operation and as a first-cut verifica-
tion of adequate destruction efficiency while incinerating.
The maximum allowable stack concentration of PCBs is 5 mg/m . The maxi-
mum allowable ambient concentration of PCBs is 0.5 mg/m (8-hour average).
The onboard analyses for PCBs in the stack and the personnel breathing
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zone will be performed by gas chroma tog raphy using electron capture detec-
tors. Stack samples will be taken by a benzene impinger stack sampling
train. Ambient air will be sampled by grab samples.
B.8.2 Instrumentation
The stack will be sampled with a benzene impinger train. The sampling
train consists of three serial benzene impingers (approximately 1050 ml of
benzene) followed by two activiated charcoal traps and one silica gel trap.
The stack sampling rate is 2 liters per minute for 1 hour, or 0.12 m .
A gas chromatograph equipped with electron capture detectors will be
employed for the shipboard analyses. Under ideal conditions, a detection
limit of 0.02 ng is expected. For shipboard operation, a detection limit of
0.1 ng is assumed. Assuming that 5 yl of liquid is the maximum sample size
that can be accommodated by the instrument, the minimum detectable quantity
translates into a minimum detectable stack concentration of 0.2 mg/m (5 mg/
o
m required). That is,
l = Q J8 3
5 x lO"1 ml 0.12 rr
assuming no evaporation of benzene from the impingers.
For an ambient air sample of 1 ml and an absolute detection limit of
0.1 ng, the minimum detectable quantity of PCBs in air is
0-] x 10"9
1 ml
The foregoing calculations indicate that gas chromatography with elec-
tron capture detection is adequate for detection of PCBs in the stack and
ambient air at the given levels of concern.
B.8.3 Procedures
The onboard gas chromatograph will be a temperature programmable dual
column instrument with electron capture detectors. One injection port will
be used for liquid samples, and the second injection port will be used for
analyzing ambient air samples.
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The benzene impinger samples will be analyzed for PCBs in order to
obtain rapid, preliminary destruction efficiency data. Ambient air samples
will be analyzed to determine whether the ship's personnel are being exposed
to hazardous levels of unburned PCBs. Both analysis techniques will be
tested with standard solutions of PCBs before placing the GC on the ship and
during analysis of field samples.
Because of the high hazard potential and the absolute need for rapid
analytical data, a backup identical chromatograph will be provided for use
onboard the Vulcanus. Both instruments will be thoroughly tested and cali-
brated in the laboratory before installation on the Vulcanus. Both units
will be tested and calibrated after installation and prior to actual incin-
eration. Since the chromatographs will be operated at maximum sensitivity,
an isolation transformer will be provided for each gas chromatograph to
reduce electronic noise.
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REFERENCES FOR APPENDIX B
1. NIOSH Registry of Toxic Effects of Chemical Substances. U.S.
Department of Health, Education and Welfare. Richard J. Lewis
Editor. 1978 edition. January 1979.
2. Fuller, B., J. Gordon and M. Kornreich, "Environmental Assessment
of PCBs in the Atmosphere", Mitre Corp. Technical Report MTR-7210,
Rev. 1, 1976.
3. U.S. EPA, Office of Toxic Substances, "Support Document/Voluntary
Environmental Impact Statement and PCB Manufacturing, Processing,
Distribution in Commerce, and Use Ban Regulation: Economic Impact
Analysis", April 1975.
4. "TLVs Threshold Limit Values for Chemical Substances and Physical
Agents in the Workroom Environment with Intended Changes for 1979",
American Conference of Governmental Industrial Hygienists, 1979.
5. Young, A.L., J.A. Calcagni, C.E. Thalken and J.W. Tremblay. The
Toxicity, Environmental Fate, and Human Risk of Herbicide Orange and
Its Associated Dioxin. USAF OEHL Technical Report TR-78-92 prepared
for The Surgeon General, USAF. October 1978.
6. Sax, N.I., Dangerous Properties of Industrial Materials, Fourth
Edition, Vas Nostrand Reinhold Co., N.Y., 1975.
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