PB82-231325
Technical Assistance in Support of Permitting
Activities for the Thermal Destruction of PCBs
CCA Corp.
Bedford, MA
Prepared for
Industrial Environmental Research Lab.
Research Triangle Park, UC
Oct 31
^
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United Slates
Environmental Protection
Agency
EPA-600/2-81-240
October 1981
TECHNICAL ASSISTANCE IN SUPPORT
OF PERMITTING ACTIVITIES FOR THE
THERMAL DESTRUCTION OF PCBS
Office of Toxic Substances
Industrial Environmental Research
Laboratory
Research Triangle Park NC 27711
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RESEARCH REPORTING SERIES
Research reports of the Office of I .esearch _od Development. U S Environmental
Protection Agency, have been grouped into nine series These nine broad cate-
gories were established to facilitate further development and application of en-
vironmental technology Elimination of traditional grouping was consciously
planned to foster technology transfer and a maximum interface in related fields
The nine series are
1 • Environmental Health Effects Research
2. Environmental Protection Technology
3 Ecological Research
4. Environmental Monitoring
5 Socioeconomic Environmental Studies
€. Scientific and Technical Assessment Reports (STAR)
7. Interagency Energy-Environment Research and Development
6 "Special" Reports
9 Miscellaneous Reports
This report has been assignnd »o the ENVIRONMENTAL PROTECTION TECH-
NOLOGY series This series describes research performed to develop arc dem-
onstrate instru.—"ntation. equipment, and methodology to repair or prevent en-
vironmc:iial degracition from point and non-point sources of pollution. This work
provides the new or ,-nproved technology required for the control and treatment
of pollution sources to neet environmental quality standards
EPA REVIEW NOTICE
This report has been reviewed by the U S Environmental Protection Agency, and
approved for publication. Approval does not signify that the contents necessarily
reflect the views and policy of the Agency, nor does mention of trade names or
commercial products constitute endorsemeni or recommendation for use
This document is available to the public through the National Technical Informa-
tion Service. Springfield. Virginia 22161.
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BIBLIOGRAPHIC INFORMATION
HB82-231325
Technical Assistance in Support of Permitting Activities for
the Thermal Destruction of PCBs.
Oct 31
Robert G. Mclnnes.
PERFORMER: GCA Corp., Bedford, MA. GCA Technology Div.
Contract EPA-68-07-3158
SPONSOR: Industrial Environmental Research Lab., Research
Triangle Park, NC.
EPA-600/281-240
Final --ept.
T'ne report describes phased efforts to identify, evaluate,
and provide technical permitting assistance to utility
boilers considering thermally destroying PCB-contaminated
mineral oil. The project also required tha'_ State and Local
Governments be provided information needed to aid permitting
of a PCB verification burn.
KEYWORDS: "Incinerators, "Polychlorinated biphenyls,
"Liquid waste disposal.
Available from the National Technical Information Service,
Springfield, Va. 22161
PRICE CODE: PC AC5/MF A01
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ABSTRACT
The report describes phased efforts Lo identify, evaluate, and provide
technical permitting assistance to utility boilers considering thermally
destroying PCB-contarrurated mineral oil. Identification initially
concentrated on identifying ideal PCS destruction sites using size, age,
location, and fuel use criteria to evaluate available boilers. This effort
then extended to directly contacting U.S. EPA Regional Offices to identify
ulilitv boilers that had expressed An interest in the PCB disposal program.
Regular bimonthly contacts were initiated with the Regional Offices and the
status of all regional PCB activities was tracked. This contact produced
three potential PCB burn sites operated by: (I) Consolidated Eaison of New
York, (2) Northeast Utilities, and (3) Pennsylvania Power and Light. Test
plans were received from the first two and were reviewed and found
acceptable: these facilities, however, subsequently withdrew their
involvement with the PCB destruction verification burn program due to local
community opposition. The Pennsylvania Power and Light Company site remains
under active consideration. By the end of Che technical performance period of
this work assignment a candidate site has not been identified nor approved fcr
testing. Appendices to this report detail the utility boiler site selection
methodology, the status of PCB activities in EPA Regional Offices as of Hay I,
IS81 and the test plan evaluations for the Consolidated Edison and Northeast
Utilities facilities.
The project also required that State and Local Governmenta be provided
information needed to aid permitting of a PCB verification burn. Under this
phase of the project a PCB "White paper" was prepared which summarized
background technical information used in writing the PCB regulation (40 CFR
761). A second paper was prepared summarizing comments delivered at j public
meeting entitled "What Should We Be Doirg About PCB?" Both of these papers
are provided as appendices to the report:.
This report was submitted in fulfillment of Contract 68-02-3168, Work
Assignment No. 12 by CCA/Technology Division under the sponsorship of the U.S.
Environmental Protection Agency. This report covers the period of March 13,
1980 .o April 15, 19&1, and work was complied as of April 15, 1981.
ii
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EPA-600/2-81-240
October, 1981
TECHNICAL ASSISTANCE
IN SUPPORT OF PERMITTING
ACTIVITIES POK THE THERMAL
DESTRUCTION OF PCBs
by
Robert G. Mclnnes
'7CA CORPORATION
GCA/'IECHNOLOCY DIVISION
Bedford, Massachusetts 01730
Cort:-a>:l Ko. 68-02-3168
Work Assignment Mo. 12
EPA Project Officer
David C. Sanchez
Industrial Envirnmental Reseatch Laboratory
Office o£ Environmental EngineerinR and Technology
Research Triangle Park, North Carolina 27711
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Research and Development
Washington, D.C. 2046C
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DISCLAIMER
This KinaL Report was furnished to the U.S. Environmental Protection
Agency bv CCA Corporation, CCA/Techno logy Division, Bedford, Massachusetts
01730, In partial fulfillment of Coi.'ract No. 68-02-3168, Work Assignment
Mo. 12. The opinions, findi
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CONTENTS
Abstract ii
1. Documentation of Contract Efforts 1
Introduction I
Identification and evaluation of candidate sites 2
Provide information needed by State and local governments
for permitting of a burn 8
References 11
Appendices
A. PCB Destruction in Utility Boilers—Site Selection for a
Verification Burn 12
B. [rapLamentation of PCB Rules 17
C. EPA Regional Status Update as of May 1, 1981 21
I). Evaluation of a Utility Boiler for a PCB Destruction
Verification Burn, Astoria, New York. July 25, 1980 33
E. Evaluation ot PCB/Utility Incineratio-.i: Northeast Utilities
August 1980 47
F. PCB White Paper 52
G. Public Meeting Middle ton, Conn. December I960 61
ill
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DOCUMENTATION OF CONTRACT EFFORTS
INTRODUCTION
In promulgating final rules for the disposal of polychiorinated biphenyls
(PCBs) (40 CFH. 761), the U.S. Environmental Protection Agency (EPA) recognized
that high efficiency industrial and utility bailers could provide an
environmentally safe alternative Cor burning dielectric fluids contaminated
with from 50 to 500 parts per million (ppm) of PCBs. While select boilers did
burn PCB contaminated oil prior to the adoption of the PCS rules, the
operating and emission, characteriseics of these units were not rigorously
documented. To insure that future PCB destruction efficiency "burns" will
take Cull advantage of past PCA disposal experiences, to document the validity
of the boiler equipment and performance requirements stated in EPA's final PCB
rule, and to add to Che public body of information in this area, EPA has
sponsored comprehensive testing programs at a limited number of industrial and
utility sites. Under this program, .in oil-fired indusl.rial boiler was tested
at Bay City, Michigan in May 1930 and a coal-fired utility will be tested for
PCB destruction efficiency in the summer of 1981 in Alabama. Efforts to
locate and test an additional high efficiency utility boiler continue.
This Task Report will document salient work efforts conducted by
CCA/Technology Division for the project "Documentation of PCB Destruction
Efficiencies in a High Efficiency Boiler." This project had the following
objectives:
• Identification and evaluation of PCB test burn candidate sites
a Provision of technical assistance to stats and local government in
considering pfcrait applications
• Stack and ambient sampling, field find laboratory analysis, process
monitoring, and data analysis and for of Che candidate verification
burn site(s) selected.
The sequential nature of these three phases required that a verification
burn site be identified and assisted through the regulatory process before
actual sampling could be conducted. Through the end of the technical
performance period of this work assignment (April 198L) such a candidate
site has not been identified nor approved for testing. Consequently, only
tasks conducted and rope ting the first two objectives are sm.iarized here.
This project report will detail GCA/Technology Division's efforts in this
regard fron 13 March 1'JSQ through I April L981.
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IDENTIFICATION AND EVALUATION OF CANDIDATE SITES
CCA1s initial actions in this program phase were directed toward
identifying the number and location of utility boilers which met predetermined
verification burn program criteria. Utility boilers were researched since all
utilities are significant generators of PCB's and must dispose of
PCB-containinated waste oils in the 50-500 ppm concentration range. Faced witii
this disposal problem, it is anticipated that many utilities will take
advantage of this program by utilizing their boilers for PCS waste oil
disposal. In addition, as an industrial boiler has been successfully tested
for PCB destruction efficiency (at Bay City, Michigan),1 tests on a utility
Boiler would serve to complement this test series. Initially, potential
utility candidate sites wer« to be selected on tine basis of equipment criteria
developed by GCA. These criteria were more restrictive L'.ian Federal Register
requirements (40 CFR 761) in an attempt to find an ideal boiler whose PCB
destruction efficiency results would be representative for the entire utility
boiler population. For this initial boiler identification effort, the
following criteria and rationale were used:
• 100 percent oil fired—since a coal-fired utility boiler (owned and
operated by the Tennessee Valley Authority) has been previously
identified for a test burn; testing of an oil-fired unit would serve
to characterize additional segment of the boiler population; also
oil firing would minimize potential fuel-related problems.
9 Unit size—boilers with capacities in excess of 100 MW were desired
as these larger units have more installed process flow measurement
devices to thoroughly monitor operating conditions during a
verification burn.
• Age—units less than 20 years old would tend to minimize corrosion
and air leakage problems.
• Location—boilers outside metropolitan areas were to be selected in
an attempt to minimise potential political and community opposition.
These criteria represented an "idealized" set of conditions that could be
applied to the utility boiler population without physical onaite inspections.
This enabled GCA to identify potential verification burn sites front existing
published information. It was felt that hollers meeting the additional
criteria would have fewer technical and political problems in obtaining
regulatory approval and successfully destroying the PCBs. To identify these
utility boilers, GCA obtained a computerized printout of all utility plants in
the country with capacities in excess of 750 MW from the Energy Data System of
the EPA Office of Air Quality Planning and Standards. Since boiler fuel was
not listed on this printout, annual fuel consumption was obtained separately
from a U.S. Department of Cnergy Report entitled "Cost and Quality of Fuels
for Electric Utility Plants—1978," FPC Form No. 423. These tvio sources of
information were combined and those facilities which met the size, age, and
oil-firing criteria were extracted. This process resulted in a list of 14
boilers at eight utility plants. This limited number of boilers were
considered restricting, therefore the 100 percer>h oil-fired criteria was
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modified to include boilers which used fuel oil for at least 80 percent of
their energy needs. This modification produced an additional nine boilers at
five plants, for a total listing of 23 units at 13 separate sites. Appendix A
describes this selection process together with the potential candidate
boilers. This list was then sent to the Project Officer for dissemination to
the EPA Regional Offices. These offices were asked to contact GCA should one
of the "ideal" boiler sites notify the EPA of their intention to burn. It
soon became evident, however, that none of the ideal sites was considering a
PCB burn and that defining the ideal site would not in itself bring forth a
cooperative utility, willing to voluntarily participate in the verification
burn program.
The PCB regulations team of the Office of Pesticides and loxic Substances
(OPTS) included the candidate list in a survey questionnaire sent to each EPA
Regional Toxic Substances Coordinator. This survey made Regional Coordinators
aware of the GCA program, while soliciting information on all Regional PCB
activities. It also served to introduce GCA to Regional personnel in
preparation for further GCA contact. The Regional response to the OPTS survey
was mixed, with some regional offices giving detailed summaries, while others
did not respond at all. Overall, the survey did not adequately resolve the
current status of PCB activities, nor did it identify a likely verification
burn site. A copy of the survey questionnaire together with the introductory
letter is included as Appendix B of this report.
The inadequate survey response, the continuing search for a verification
burn site and the ongoing need to keep abreast of EPA R-°ional Office PCB
activities led to the establishment of a bimonthly contocr: between GCA and
Regional Office personnel. This cintact was initiated in August 1980 and
served to identify key Regional peiconnel involved with implementation of the
PCB rules Js well as to constantly update the status of industry interest with
these regulations. While the nature of these contacts focused on utility
boiler PCB burn applications, industrial sites with PCB disposal plans were
also noted. A list of the CPA Regional contacts, PCB burn applications and
the current (] May 1981) status of Regional PCB activity is presented in
Appendix C. The Appendix C listing also includes additional sources, found in
the literature, which were known to have disposed of liquid PCB solutions in
the past.
As Appendix C points out, PCB activity in certain EPA regions has been
substantial while in others very little is being done. Regional staffing for
PCBs also varies, reflecting these activity levels. Calendar year 1980 saw a
substantial increase in routine inquiries from utilities concerning the PCB
regulations and in the number of formal 30-day notifications given to regional
offices in anticipation of a PCB test burn. Utilities which were known to
have burned PCB waste oil in 1980 and 1981 included Hiddletown Station
(Connecticut) of Northeas'. Utilities, Train Station (Maryland) of Baltimore
Gas & Electric, Morgantown Station (Maryland) of Polemic Electric Power,
Cities Services Company of San Antonio (Texas), San Bertron Station (Texas) of
Houston Lighting and Power, Union Electric Company of St. Louis (Missouri),
and Washington Water & Power of Spokane (Washington). Industrial activity in
PCfl disposal has similarly shown a marked increase in 1980-19&1 with Region VI
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receiving Che largest number of industrial applications, including chose for
commercial hazardous waste incinerators At Deer Park, Texas and El Dorjdo,
Arkansas. These two applications were subsequently approved.- Based .0a
this recent interest in PCB disposal, "t is expected that applications in .his
area will increase in the near future.
Contact between GCA, OPTS, and the EPA Regional Office personnel
uncovered the first potential verification burn site in early 1980; the
Ravenswood lacility of Consolidated Edison (Con-Ld) Company of New York. With
50,000 gallons of PCB-containinated oil stored onsite at this facility, Con-Ed
proposed to burn this oil in accordance with the PCIJ Regulations (40 CFR
761)3 while it conducted stack sampling to measure PCB emissions. The
Ravensuood plant is located in the Astoria section oE New York City and
contains two identical oil-fired boilers each rated at 345 MW. The units were
erected in 1962 and are of the tangentially-fire
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mineral ovl dielectric fluid is not fed into the boiler unless
the boiler is operating at ita normal operating temperature (this
prohibits feeding these fluids during either start-up or shut-down
operations)>
• The owner operator of the boiler monitors and records, at least once
per hour, the carbon monoxide concentration and excess oxygen
percentage in Che stack gas while b ding mineral oil dielectric
fluid. If either measurement falls . slow the levels specified, :he
flow of mineral oil dielecLtu: fluid <.•• the boiler shall be
immediately stopped.
• The primary fuel feed rates, mineral oil dielectric fluid feed
rates, and total quantities of both primary fuel and mineral oil
dielectric fluid fed to the boile- are measured and recorded at
regular intervals of no longer than 15 minutes while burning mineral
oil dielectric fluid.
Con-Ed's test plan satisfactorily addressed these criteria. CCA then
addressed such additional items as:
• An operating schedule for the overall PCB burn,
a The layout of the PCB piping network and the ability to discontinue
PCB feed without boiler disruption,
• Thermal efficiency of the boiler at different loads,
o The number, type and position of oil burners,
e The heat release rate(s), furnace temparatureCs), and furnace
volumeCsJ, as they relate to fuel residence time(s),
e Materials of construction of all surfaces exposed to PCB
contaminated oil and combustion products as they relate to potential
chloride corrosion problems,
• The type and efficiency of any installed pollution control equipment,
* Th; proposed operating schedule of the boiler when burning PCBs,
including the total quantity of PCG oil to be destroyed,
• Any anomalies about the boiler that would preclude the use of
collected PCB destruction efficiency data for other utility boilers,
and
• Existence of a spill prevention and control program.
In concert with this review was an evaluation of Cor.-Ex!:s test plan for
sampling and analysis. This evaluation addressed additional items, induing:
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» Suitability of Che proposed test method to collect and measure stack
gas PCBs,
• Suitability of the proposed test method to collect and measure stack
gas particulflte emissions and PCS incomplete combustion products,
including chlorinated dioxins and dibenzofurans,
• Quality control measures f> be employed during laboratory analysis
of samples,
o Acceptability of continuous flue gas monitoring equipment,
• Accessibility of scmpling locations,
• The total sampling time required to collect 10 ug of PC3 for
laboratory analysis,
• Provision, if any, for workplace monitoring, including employee
breathing zone tests and boiler operator blood testing, and
• Technique and sampling methodology for boiler residue sampling.
GCA's evaluation of t-he Con-Ed facility and test protocol was written up as a
report and presented to the EPA TasV. Officer. A copy of this evaluation is
presented as Appendix D.
Overall, the Ravenswood faciiil.y submittal was sufficiently detailed co
be acceptable. Information that was- not initially subin.tted, such as ths
total furnace volume was solicited directly from Con-iid Th
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A second potential verification burn site was identified in June 1980;
the Middletown, Connecticut facility of Northeast Utilities. Noitheast
Utilities gave a formal 30 day notification of its intent to burn "CB
contaminated dielectric fluid to the EPA Region I Office on June 17, 1980. A
copy of the submitcal was also tent to the Connecticut Department of
Environmental Protection (D£P). The proposed site was unit No. 3 at
Middletown Station, an oil fired boiler rated at 233 Megawatts. CCA received
a copy of the entire submittal on June 24, 1980 and initiated an evaluation.
The submittal by Northeast Utilities was detailed, comprehensive and
addressed each PCB Regulations criteria in an orderly, systematic fashion.
Most of the additional review criteria previously listed in this report for
the Con-Ed submittal were also discussed. Specifically, the submittal
included:
• A standard operating procedure for mineral cil burn period,
• A schematic of the mineral oil feed system,
0 A dispersion modeling analysis indicating predicted worst case
ground level PCB concentrations,
« An environmental evaluation of burni-ig PCB mineral oil at Middletown
Station, including the source and quantity of mineral oil, the
disposal alternatives available, the transportation of the oil to
Middletown Station and spill prevention measures.
GCA's evaluation of the Northeast Utilities submittal, including an
estimate of the sampling time required to obtain n viable PCB stack sample,
was sent to the EPA Task Officer. A copy of this evaluation is provided as
Appendix E.
The reaction of EPA Region I personnel and Connecticut DEP personnel to
the submittal was also favorable, and the submittal was approved by Region I
on September 4, 1980.
Northeast Utilities was initially willing to participate in the voluntary
verification burn program, barring any unfnrseen problems. Such a problem
came to light before a test burn coi^d be scheduled when the Town of
Middletown obtained a court injunction barring any PCB burns at Middletown
Station. The town's objections concerned potential public heaith problems of
FCB emissions, and the lack of town involvement in the review and approval
process. In an attempt to satisfy the town's objections, Northeast Utilities
conducted several public hearings in the Middletown area, culminating in a
public meeting held at Wesleyan University on 12 December 1980. A synopsis of
this meeting will be subsequently discussed in this report. The court suit
was resolved in favor of Northeast Utilities in February 1981. A trial burn
was run at Middletown Station on February 10, 1981 to test all PCB delivery
systems, with dielectric fluids containing 33 ppn of PCBs. A full scale burn,
utilizing waste oil with PCB concentration in excess of 50 pptn, was originally
scheduled for February 18, 1981 but not conducted. Due to the adverse
publicity their proposed PCB burn had received, Northeast Utilities reversed
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their earlier position And declined to participate in the verification burn
program once the court suit had been resolved. They reserved the right to
change their minds -again at a later date.
A third potential verification burn site was identified in January 1981:
Montour Station of Pennsylvania Power and Light Company (PP&L). The proposed
boiler it a pulverized coal unit rated at 750 NW and equipped with
electrostatic precipitators for particulate emission control. This utility
had contacted DPA Region IH and the Pennsylvania Department of Environmental
Resources (DEK) in January to informally inquire about the PCB program. PPAL
was proceeding cautiously with their actual PCB hum application as they
wanted to ascertain public opinion on this matter before making a full-fledged
commitment. In this regard a public meeting was held by PP&L near the Montour
facility site on 9 March 1981 with representatives of both EPA and
Pennsylvania HER present. PP&L plans additional meetings in the future and
has initiated a regular contact with a concerned citizens group in the Montour
Station area. When informed by GCA of the verification burn program, PP&L
expressed, interest, but avoided full commitment at this time. GCA has
subsequently visited PP&L of.ices to explain, in detail, the entire PCB
program. Since PP&L remains interested, a regular contact between them and
CCA has been initiated.
The first phase portion of this contract has therefore had mixed
results. Positive accomplishments included the establishment of a bi-monthly
contact with EPA Regional officials and the identification of key regional
personnel responsible fur monitoring and approving regional PCB activities.
This contact was. especially timely since utility interest in the PCB waste oil
disposal program has increased significantly in the past 12 months. In
addition, the history of PCB destruction in each region has been identified,
to the best knowledge of the regional personnel. H-wever, a verification burn
site has yec to be found. Several potential facilities were identified and
monitored far several months each before they eventually declined the use of
their facilities.
The problem encountered by these facilities with political and community
opposition to PCB burns raised significant questions as to the potential
widespread use of utility boilers for PCB conramination dielectric fluid
disposal. The need for a comprehensive public information program in this
area was clearly demonstrated. Increased media attention to the generation
and disposal of all hazardous wastes requires that the costs to society of all
disposal options be clearly delineated so that the public can make rational
choices. Utility officials indicated that continued widespread public
opposition to the use of utility boilers for PCB waste oil disposal would
force them co return to the previous practice of drumming this oil and
chipping it to secure landfills located in some cases hundreds of miles away.
PROVIDE INFORMATION NEEDED BY STATE AND LOCAL GOVERNMENTS FOR
PERMITTING OF A BURN
The second phase of GCA's contract involved providing information as
needed by state and local governments for permitting of a burn. This effort
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consisted of two distinct parts; assembling background information relative to
PCBs in a report format and answering specific questions from EPA aad state
'officials concerning technical aspects of a source application.
CCA prepared a "white paper" on the background technical information
utilized in writing the current PCS regulations. This paper briefly
summarized pertinent federal regulatory actions and the technical
justifications and economic analysis performed prior to the promulgation of
the regulations. Areas covered in the white paper included:
• major routes by which PCB's enter the environment
o federal regulations pertaining to PCBs
« a synopsis of PCS destruction efforts in high efficiency boilers and
incinerators
• economic analyses for the final PCB rule
« curret'.t sampling and analysis techniques
The white paper is intended us an overview document on PCBs for Federal,
State and local regulatory officials, although it can be also used to inform
the general public of the rationale behind the PCB regulations. A copy of the
white paper ie included as Appendix F.
A second PCB itvformatinal package assembled by GCA was the minutes of a
public nesting held in Middletuun, Connecticut concerning a utility boiler 1'CB
burn in that town. Entitled "Vlhat Should We Be Doing About PCB?"; the meeting
was an open forum bringing together speakers on various aspects of the PCB
disposal problems. The program presented included the following topics:
0 The Industrial Use of PCB and Alternatives
o the Public Health Concerns Arising from Exposure to PCB
e The Regulation of PCB Disposal and the Environment
• Public Concerns Regarding PCB Disposal
o Regional Concerns in Handling PCB
• The Responsibilities of Municipalities in Relation to PCB Disposal
While the meeting was held relative to the specific proposal by Northeast
Utilities to use their Middle town Station for a PCB waste oil burn, the issues
discussed have widespread significance. The interrelationships of Federal,
State and local governments, business, academia, environmental interests and
the public health sectors of our society in addressing the hazardous waste
disposal issue were brought out at thin meeting. Given the intense political
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debate thar has arisen in this country over hazardous waste disposal, forums,
such as tKat held in MvddVetown should prove to be a useful tool in
stimula.ing a p oductive, open dialog among all concerned parties. The
minutes of the Middletown meeting are presented in Appendix C.
Additional work conducted ircluded answering questions from Federal and
State environmental personnel on specific PCB-reUted topics. In this regard,
questions pertaining to tlie temperature-time relationship of the Con-Edison
Ravenswood boiler and the status of three specific PCB burn si'.es were
iimneditely answered. This technical assistance effort was typified by
specific questions and short response time. It was provided on an "as-needed"
basis.
Overall, work efforts conducted under this contract provided the
framework for future activities in this area. The interest expressed by
utilities and industry in thermally destroying their low ( 500 ppra)
concentration PCB waste has risen dramatically since this contract was begun.
A format foe monitoring and reporting this interest has been developed.
Select background information that can be used by regulatory officials at all
levels of government has been assembled. While a utility boiler PCB
verification burn site has yet to be conclusively identified and tested, the
framework for identifying potential candidate sites has been established and
will hopefully result in the conduct of a fully documented PCB destruction
efficiency test in the near future.
10
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REFERENCES
1. Hall, J., F. Record, P. Wolf, G. Hunt, and S. Zelenski, Evaluation of PCB
Destruction Efficiency in an INdustrial Boiler. EPA-600/2-81-055a.
Office of Research and Development, U.S. Environmental Protection Agency,
Washington, D.C. April 1981.
2. CPA Region VI Approvals of Annex I Incinerators: Rollins Environmental
Services in Deer Park, Texas, January 23, 1981; and Engineering Systems
Company (ENSCO) in Eldorado, Arkansas, January 23, 1981.
3. 40 CFR 761 "Polychlorinated Biphenyls (PCBs), Manufacturing, Processing,
Distribution in Commerce and Use Prohibitions." Federal Resistor, Vol.
44, No. 106, Thursday, May 31, 1979. pp. 31514-31568.
11
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APPENDIX A
i'c.it DHsriiiJciii)1: i\ UTILITY r.oiii
Tr su.K.ci ION '-'OK ,\ vr.KincAmv.-:
Tiu- disposal of 1VB- l.nk'ii u.i -t.- I r.itmforawr oil i cpri!nts> .' bit-ill ric..inL
was to di-jpos.il pivbltvi I l.-ctric utilities. l.and disposal is effectivolv
prohibited by govern nont. rt:£iiLai.u>n4 and high tompcratxirc incineration sys-
tems for gi.-ncr.il ut.c ii.ivi- \ot tv ri-tulvu PPA approval. One disposal ir.ethor oil. I'nJer llu ovcr:ill l.?\ uLility ?C3-tost
progr.in, a J L'-.t nf r.in.l i .l.itc iin r«i will IK- o.-^tpblishcil, tlic opcrntots <>f Lht-
uplts ccnticLi-tl, |. c rn !•:•.! on inr usi of their facilltv o'ltainc.d, and a test
bum conducCLc!. Dunn-.1, l!:i , tL":t hum, Lno i'CI'-l.iJon ofl woiilii bo ir.uiorgi!
iti:.o the bnilc-r futl .hllu a -.ti \-. I tJnoouc t-t.n-k omi-mli-'n last is condm t«..l
ro n-jccrcai.i die |>rciincv of P( i1.1 • in t'lc c-<;i msf RSIS strcaT. The eo.il rf
i he proi-r.im is to o:,t i!>l n.li t'ir .iiiilicv m" utility hoiltrs t.) i!nscvo> the
iCB's. firs iipori will dcr.iLl ii''"%1'? c-ffnrcs In esrabi Itliinc the lisr of
li(.-r-; tli.it '.Jill bi •• .M.i u! HO - inr tliis tobt !'jrn
',!:.: 4 (uMl ".\,\
A lii.t •-•! lllol/ i.nsliM • inclii'ito^ ni"-,r h<: \t \ '•.<•<' ^a .1 Si-t of proiifitcr
I'sncd criteria. Tor tills r-fiJfir.m, this u:iits LCdroJ li.ul to he "rcprL-sont
.. that tiiu CCPC rt-s'ilt'; ci-l:M be c oimldi-rcit to havu wi-Jiisproad anplir at
\ sot of critC'Vi.: ilcflr>inu this "io;irL", ent.Tt Lvc" unit u.is cstnbl ls>ictl by
ihcst crttL-rla mclnHo:
Oil rirliij; - As Pi H oil is to ho ir,utt?rcd in prcc'
r.Tto-- Into rhc holn'i 'IK-!, the .scluiLlon ol only oll-firei!
bnJlrrs was considurcil important. I'se of these units
facilltaioi the notorin^ 01 PCfi oil wlthouC concorn to how
t!:c fuel It. .ito-ilzi'i! .nul disncr^od in the hoil^r furnjcu.
Thyse units also nJnini:e potential diol rcl.itod problcmb
biich as the effects of v.jrylnj; fuel quality and t!ie possible
adsorption OL I'CB's o.ito cj.il as»ls.
Unit Sl?c - flCA scU-ctod only tho.sc boilers with a capacity
In excels rjf 100 Mojiavatts (>W) . Thcso larger units
typically have noro runplctc ror.trol flysconis and will allow
the burnin;-. of .1 wider ram'.e ol I'i'.B iced r.icis, thn-s provid-
ing for t<_"!t cotulitlun flexibility.
12
-------
A)-o - uilts iiisiii! lrJ sim..- ] 'I'ifl v,-ii' -.eU-uii-J. These
n<_-vcr units will In- lf,s liki?Jy Lo havo nalnti n.i:ic.t:
piulilori-. (i.e., .11 r K-.il:,i ;..) , li.iw -note sophist. U.iteil
i:>.•> r..il)\ havi.- bettor rhcriul
nff li tu.irli.") i!i. in .'I.lui- (!>r.2-l'}t>l>) nulls.
l.oc.'itluu - Units lof.iltd ouLhiiSt- ni-tropol I^jii .m-a:, wrc
prefurrrsi] to nmial/i1 j>njitj!iition t!Xpi'5iir-<> 10 Jiiv !'CH
cnii.slon -iho'ild pri'liK- s iicrur ilurlnft I lit- t«-t>t t'arn.
crlrurii won1 osr.)l>li'-;!ii J hy CCA to miiumizr or^iipnorl anJ fuu! v,n i-
ablus In ••( test burn. Thc-y »iri- not Jnucnded lo reflect on the ^blllf, of .m-J
specific utility boiler 10 vlu.i-ossful ly i«urn ITB-jadon oil. In fact, rei-enr
published d.ira .-.uf'i'csLc. tli.it i.o.tl -t 1 rt-J unit*, in,«y !io hotter units Lo u;.u for
Itmfi-terra FCB tlitmal Jo-^trnr tion Juc to thu jbillty of tliuir boiler mbos l~i
wltliriCanrl hlgliL-r flue t;.is u'lloriilo concent rations. 'Jhusc- ciiLt-rl.i .ire sub-
jective and din, be altered s'toi !d canULJ.tti' units not bo available nor
interested In partition!. Ir.r. In tliis test [)roi;r.in.
SELECTION HHlMOUOLOCy
CCA hc-i-an itss c.mdid.Ut- si-K-ction iirocL:,s with a list uf nil utility
plants having capacitiu-. in i.W- This computuri ^ed prititom
was obtaiiwd by .icc^-ini'. Luc TncrRy luta «!>sti-w (i-llS) of the F.HA Offlco of
\i r Qu.ility I'lannint; n:iil SLj'id.irds and Is .iri.aclitjl ns Appendix A. The print-
•••:C listed narari and lot.ilidn of piuer pljrc and Lndividuil boiler nunbnr,
•ii-^e (^W), -md vcat ni srart-i:t). KoLler fu^t use t.'as not specified. This
,J--t.T vis obtained si^wrnt ely rrtiulrfnn>nts could also bo potential test-burn
candidates. Tliese units typically use njtural gas when It Is readily avail-
able (In the svnmitjr) , hut burn oil the remainder of the year. While thc-,e
units could not be tested wh^ic on natural tja-,, they would he accept.ibl"
for the majority of the yc.ir. The DOi: tcport was again checked and :ir aildl-
tlonal nine boilers at five plants added to the candlil.-iLe list. Tho pro]>o->'-'d
list therefore constitute--. ?i boilers at 13 utility plants, J* Is sho»n on
the enclosed table.
13
-------
ITITRI:
Jn order co in.iint.aln a viable list of 20 to 25 candid.ite boilers, the
crltt'fla tnus»t be kept at a mlnlrain. One .\dditionnl factor, however, that
will vary .iinon;; thoKC unitt! alreadv on li: from published reports. The ElJS must ba :icceased to obtjH
tills control dcvlci; dat.i. Onr.e tliB data nre obtained, a decision muut be
rc-nclied on how to apply tnoin, i.e., should one unit wl tli each device be
tcBLud11, should only those units witii clcctroscattc pt cclpliators (the most
efficient: control), 01 no control al all l>e tested? U'hllo thp control device
lype Is not expected to affect the ability of. the boiler to successfully
destroy PCKs, the question of how this vjriance between units will affect
their "icprascr.rativcncss" anil therefore, the usefulness and applicability
of tlu*ir test i mu.-,t he addressed.
Additional nriterij Tucli as stack test data .irtd the number and type of
oil burners were not Included at this tine to ensure the candidate list is
sufficiently larj-.o. These ciiterla mav be dpnlled at some later date, 3huul>i
a choice be requirrd between several available test sites.
-------
TABLE 1. Initial lint of utility boilers v.-'iic'.i s^-jt Liic following criteria for PC3 destruction verifi-
cation: 13 Unit on Oil-Firing Only, 2) Lr.it Installed since 1960 and, 3) Unit Si.'.c Crc-atur
than 100 :iU.
Plant Naait:
L-ocaLJ.cn
Boiler "r>.
Yc.ir Installed
Arthur Kill (U)
Asturln (U)
Bow I i ic
Bravcon Point
Ldj'.csioorc
Indian Point
Middlctown
Mystic (U)
Now iioston (U)
Northport
Possum Point
Ravenswoori (U)
Rose ton
New York, MY
New York, NY
Orsnge/Rockl.ind, N'Y
Masbachustt t4?
DcJnware
Hudson Val ley. NY
Connecticut
Boston, Mn.ss.
Boston, Mass.
l.onti Island, NY
Virginia
New York, M
CtrnErnl Hudson, NY
30
iO
>0
1
-'
-
-4
J
li
12
3
6
7
1
2
t
^
J
i
10
20
30
1
2
1169
1961
IVfil
I1.1 72
197;
107i
L"56
1973
1962
l'J62
W6ft
195
1974
10"'"
335
357
33 7
621
62j
650
150
-09
273
275
2 "•
!3S
•^h5.>
380
3 SO
3-5
J75
375
239
400
400
1026
621
621
(IF) - :ocaL.i! IR lirh.iii
-------
TABLE 2. Addicior.nl util lev bolJcrs which burn oil ^r
limo.
IJI.TI 50"'. of the tirac, but IOL ItiQ*. of tlic
Plant N.ine
Ormond Beach
Ritchie
Sanford
Wilson
Location
California
Arkansas
Horidj
Mississippi
Vi-ir
Boilc: M* Canacitv
1
•>
1
2
Z
5
J
O
1971
1973
1961
1967
1972
1973
1966
1971
806
806
353
5A3
436
-',36
543
VS3
Yorktown
Virginia
882
-------
,ii°"v, APPENDIX B
*o-
I.
7 3 UNITED STATES LNVIRONMENTAL PROTCCTIO1J AGCNCY
,•^r-.'llii*j WASHINGTON. D.C. 20/160
H • V
OFFICl tjr ^LSllCICi^S AMJ 1OX 1C SUUSl AflCLS
MEHpKAKDUM
SUBJECT: ImiJleacntation. of PCB Rules
j&^2fc<«.^-^
FROM: XT/ V/illicm Gu'ntcr, PCB Regulations Team Leader
i/
TO: Regional Toxic Substances Coordinators
The 1JCB Regulations Team has several ideas for improving
communications on implementation of the I'CU rule, especially with
respect to xnfor:natio:i useful in evaluating potential disposal
facilities. We would like to establish ourselves as the clearing
house for such iufor.~.jt ioi. generated in the Regions as well as in
the various !»&D tnns of EPA. The attached survey is to determine
the extent of ini^lciiientation of the PCU rules throughout the
country. Please feel free to add your suggestions and comments
at the enJ of the survey form.
Utilizing contractb managed by Dave Sanchez at IBRL, we have
begun a series of verification burns to document the ability of
boilcrr. ."ml incinerators t« destroy TCils. This has bean done
with an indurtrial hiyh efficiency boiler at Bay City,
Michigan. The results ohoitlJ be available in Augu&t. TX'h is
working with us to plan a similar tost of a large coal-fired
utility boiler in Alabama. We are looking for a suitable oil
fired utility boiler to test. Attached is a stumnary of utility
boilers whicn have been identified as potential PCB verification
burn candidates in each Region. In addition, a questionnaire is
enclosed to help identify other utilities or industries which you
believe may be considering destruction of PCBs in boilers,
incinerators or other devices.
IERL has distributed the draft "Guidelines For Evaluating Thermal
Destruction Methods" to you for comment. We also want to
distribute copies of all test burn information va have which will
help you evaluate PCB disposal facilities.
In other PCB rule areas, we are preparing lists, by region, of
firms which have applied for exemptions from tlia processing and
distribution in connurce rule. These will be distributed to
facilitate inspections. I am enclosing a list of the people on
Reproduced .3""
bc-n available copv_
-------
the PCB team and their areas of specialination so that you may
c«ill on us for help. Our survey includes a page Cor you to
update our list of the key PCB people in your Region. We also
solicit thtsir comments, and su-jgestions.
Please send youi: responses to Glenn KuiU x. (TS-794) as soon as
possible. Thank you Cor your holp.
List of Addressees:
I W HeCfernan
II R Jar sen t^- 1b4- it"*-*
ill C Sapp ziv-ltl -aosf
IV R Jennings 4 a*- Mi-rf*4
V K Br«ner si7-a**-t*»
VI L Thomas Z»4 - 7fe.-i - z-)*,4
VII V< Brandner f\±- 374- fcsw
VIII D Gillam 303 -
IX G Gavin 4i-5-
X J Everts Zofc-
IliRL D Sanchez
18
-------
SUMMARY OF UTILITY PCB VERIFICATION BURNS
CANDIDATES BY EPA REGION
In establishing a list of candidate units for the test burn
program, our contractor, GCA, conducted a preliminary survey
based on the following criteria;
"Oil-fired.
'Boiler capacity greater than 100 MW.
"Boiler less than 20 years old
"Boiler not located in highly populated urban area.
Based on facility data provided by the Energy Data System (EDS)
of the EPA Office of Air Quality Planning and fuel use data
provided by the U.S. Department of Energy, Energy Data Report
entitled "Cost and Quality of Fuels for Electric Utility Plants
in 1978," a "first-cut" list of 14 boilers, utilizing oil
exclusively, was obtained':
EPA
Region
I
II
Plant
Name
Brayton Point
Middleton
Bowline
Indian Point
Northport
Roseton
Edgemoore
Location
Massachusetts
Connecticut
Oranqe/Rockland, NY
Hudson Valley, NY
Long Island, NY
Central Hudson, NY
Delaware
Boiler
No.
4
3
1
2
11
12
1
2
3
1
2
4
5
Year
Installed
J974
1964
1972
1974
1962
1962
1967
1968
1972
1974
1974
1966
1973
Capaci
(MW)
450
239
621
621
275
275
375
375
375
621
621
150
409
Possum Point Virginia
1962
239
A "second cut" screening produce ° additional boilers. These units
utilized oil for a minimum of 80% of their energy requirements and
could also be potential test candidates:
19
-------
EPA
•Region
Plant
Name
Il'I Yorktown
IV Sanford
Wilson
Location
Virginia
Florida
Mississippi
Boiler Year Capacity
No. Installed (MW)
1974
882
4
5
1
2
1
2
1
2
1972
1973
1966
1971
1961
1967
1971
1973
436
436
545
783
359
545
806
806
VI Ritchie Arkansas
IX Ormond Beach California
The proposed listing therefore consists of a total of 23 boilers at 13
utility plants. Dr. Steve Zelenski, the PCB verification burn project
manager at GCA Corporation, may be calling you to gather information
about high efficiency boilers in your region.
HQ PCB TEAM AHEAS OF RESPONSIBILITY
Bill Gunter - Team Leader FTS-755-0920
Para Moore - Import/Export, Section 21 Petitions FTS-755-1188
Peg Velie - Food & Feed Regulations, Ham Radios, Weeping Transformers
FTS-755-1138
*Tom Barber - Manufacturing Exemptions, PCB
Analytical Methods, Containerization, Storage
FTS-755-1188
Glenn Kuntz - Disposal, Processing & Distribution Exemptions
FTS-755-0920
*Tom will be leaving in July and will be replaced by Jim Huemmer at the
end of August.
20
-------
APPENDIX C
EPA REGIONAL STATUS UPDATE—MAY 1, 1981
REGION 1
Regional Toxic Coordinator:
Regional PCS Coordinator:
Regional PCB Contact for Enforcement:
Additional Contacts for PCB Incineration:
Paul Heffernan
(617) 223-0585
Air & Hazardous Mat'l. Div.
Pesticides & Toxic Subst. Branch
Steven Kradkoff
(617) 223-2007
Enforcement Division
Air Compliance Section
Jim Okurv-
(617) 223-2006
Enforcement Division
Rich Cagivnero
(617) 223-5610
Permits Branch
Thomas Michel
(617) 223-5610
Enforcement Division
Applicants for PCB-Burns:
Unit
Application
Rec'd. App'd.
Middletown Station, CT 6/19/80
Northeast Utilities
Merrimac Station No. 1 2/6/80
N.H., Public Service
Company of New Hampshire
Salem Harbor Station, MA 10/K/80
New England Power
9/4/80
3/3/80
Comments
Trial burn conducted 2/10/81.
No future burns scheduled at
this time.
Test burn has not been
scheduled.
EPA approval imminent; awaiting
state action.
21
-------
REGION I (continued)
M.I.T., Cambridge, MA Informal inquiry made to EPA
office; formal notification has
not been received.
General Electric 8/19/80 Rotary kiln incinerator;
Pittsfield, HA permission to burn material «ith
500 ppra PCS denied.
Permission to burn dielectric
fluid with 50 to 500 ppra of
PCB's approved. No test burn
conducted to date*
22
-------
REGION II
Regional Toxic Coordinator:
Regional PCB Coordinator:
Regional PCB Contact for Enforcement:
Additional Contacts for PCB Incin. ration:
Applicants for PCB-Burns:
Unit
Alcoa, Messina, NY
Application
Rec'd. App'd.
Ravenswood, Con-Edison, 1-80
NY
Atlantic Electric, NJ
2-81
Ralph Larsen
(21z) 264-1925
Management Division
Patrick Harvey
(212) 264-9895
Enforcement Division
Cathy Masimino
(212) 264-0545
Enforcement Division
Ernie Regna
George Pavlov
(212) 264-0504
Water Division
Solid Waste Branc'.i
John Frisco
Hazardous Waste Engineer
(212) 264-4668
Comments
Utility withdrew application
after substantial interaction
with N.Y. HER and EPA Region II.
Informally inquired about
regulations in mid-1980. No
formal application made.
Submitted 30 day notice for
one time PCB burn. No burn
date scheduled.
23
-------
REGION III
Regional Toxic Coordinator:
Regional PCS Coordinator:
Regional PCB Contact for Enforcement:
Additional Contacts for FCB Incineration:
Applicants for PCB-Burns:
Unit
Continental Can Company,
Hopewell, VA
Train Station,
Baltimore Gas & Electric
Morgantown Station
Potomic Electric Power
Montour Station,
Pennsylvania Power &
Chuck Sapp
(215) 597-4058
Air & Hazardous Material Division
Bill Scbremp
(215) 597-0982
Air & Hazardous Material Division
Hazardous Material Branch
Ralph Siskind
(215) 594-8915
Attorney
Enforcement Division
K. K. Wu
Engineer
(215) 597-4058
Ed Cohen
Engineer
(215) 5*7-7668
Application
Rec'd. App' d.
Comments
EPA conducted emission testing
on lime kiln and power boilers
in 1976.
Burned PCBs for a short time in
1980—ceased burning d-^e to
State of Maryland ord:r
Informal inquiry made to State
DER and EPA Region II 1/81.
Public meeting held 3/9/81.
Formal notification awaiting
further public interaction.
-------
REGION IV
Regional Toxic Coordinator:
Regional PCB Coordinator:
Regional PCB Contact for Enforcement:
Additional Contacts for PCB Incineration:
Applicants for PCB-Burns:
Unit
Ralph Jennings
(404) 881-3864
Air & Hazardous Material Division
Pesticides & Toxic Substances
Section
Same as above
Ms. Constance Allison
(404) 881-3864
Pesticides & Toxic Substances
Section
John Herman
(404) 881-3016
Air & Hazardous Material Division
Residuals Management Branch
Application
Rec'd. App'd.
Sanford Station, Florida
Power & Light
Tennessee Eastman
Company
Widow's Creek Station,
Tennessee Valley
Authority
Comments
Conducted test burn on 5/26/76
on oil fired boiler. Results
indicated 99.99% destruction
efficiency 4
Test conducted on coal fired
boiler on 11-6/7/8/9-79.
Test burn on coal fired boiler
Scheduled 7/81.
25
-------
REGION V
Regional Toxic Coordinator:
Karl Brcmer
(312) 353-2291
Air & Hazardous Material Division
Regional PCS Coordinator:
Regional PCB Contact for Enforcement.
Additional Contacts for PCB Incineration:
Applicants for PCB-Burns:
Unit
Peerless Cement Company
Detroit, MI
General Motors
Bay City, MI
Baldwin Station 6/80
Illinois Power Company
Application
Rec'd. App'd.
Dr. Sheldon Simon
(312) 35J-2291
Air & Hazardous Material Division
Ken Fenner
(312) 353-2L13
Water & Hazardous Material Division
Program Manager
Y. J. Kim
(312) 886-6140
Air & Hazardous Material Division
Hazardous Waste Management Section
Comnppts
Applied for PCB oil burn in
cement kiln in 1980 then
withdrew application. EPA
sponsored destruction test in
rotary kiln conducted in 1978.
Conducted PCB destruction
efficiency test on oil fired
boiler in May 1980. Results
indicated D.E. >99.99%.
Application under review by
Region V.
26
-------
REGION VI
Regional Toxic Coordinator:
Larry Thomas
(214) 767-2734
Air & Hazardous Material Division
Regional _'CB Coordinator:
Regional PCB Contact for Enforcement:
Additional Contacts for PCB Incineration:
Applicants for PCB-Burns:
EL Paso Products
City Services
San Antonio
Kaiser Aluminum, LA
San BertroTi Station
Houston Lighting &
Power
Ensco, El Dorado, AK
Rollins, Deer Park, TX
Dow Chemical
-LA Division,
Plaquemine, LA
Application
Rec'd. APp'd.
'79
Jim Sales
(214; 767-8941
Air & Hazardous Material Division
Solid Waste Branch
Dave Olshowsky
(214) 767-3274
Technical Contact-Enforcement Civ.
Kirk Smith
(214) 767-2760
Legal Contact — Enforcement Div.
Phil Schwindt
(214) 767-2727
Surveillance & Analysis Division
CorreiHints
125 gallons of oil burned on
10/11/79.
Initial burn conducted 1/13/81.
Installing CO, 02 monitors,
no test burn scheduled.
Test burn held 12/9/80.
Incinerators approved by EPA
Region VI, 2/ai.
incinerator—trial
burn scheduled 1/80.
27
-------
REGION VI (continued)
-TX Division, Freeport,
TX
-Oyster Creek Division,
Freeport, TX
Vulcan Materials,
Ceismar, IA
PPG Industries, Lake
Charles, LA
Diamond Shamrock, Deer
Park, TX
Industrial incinerator—trial
burn scheduled 5/80.
Industrial incinerator—trial
burn scheduled 9/80.
Industrial incinerator—trial
burn scheduled 1/81.
Industrial incinerator—trial
burn scheduled 3/81.
Industrial incinerator—trial
burn scheduled 4/81.
28
-------
REGION VII
Regional Toxic Coordinator:
Regional PCB Coordinator:
Regional PCB Contact for Enforcement:
Additional Contacts for PC3 Incineration:
Applicants for PCB-Burns:
UnU
Lehigh Portland Cement
Company, Mason City, IA
Union Electric,
St. Louis
Alcoa, Davenport, IA
Kansas City Power &
Light
U.S. Gypsum
Columbus and Southern
Ohio Edison
Application
Rec'd. App'd.
Wolfgang Brandner
(816) 374-6538
Air & Hazardous Material Division
Toxic & Pesticides IJranch
Marvin Frye
(816) 374-6538
Air & Hazardous Material Division
Toxic & Pesticides Branch
Scott Pemberton
(816) 374-2186
Attorney
Enforcement Division
Steve Bush
(816) 374-6534
Air & Hazardous Material Division
Hazardous Waste Material Branch
Comments
EPA sponsored destruction test
in rotary kiln conducted in 1978
Trial burn held 2/81.
Trial burn scheduled 9/80.
Informal inquiry made 2/81.
30 lu-y t ification given for
a one t. ^ burn. Burn
sc' edu cd 4/81.
Informal inquiry made 5/80.
29
-------
REGION VIII
Regional Toxic Coordinator:
Regional PCB Coordinator:
Regional PCB Contact Cor Enforcerrenr:
Dean Gillam
(303) 837-3926
Air & Hazardous Material Division
Toxic Substances Branch
Steve Farrow
(303) 837-3926
Air & Hazardous Material Division
Toxic Substances Branch
Ford Blackwell
(303) 837-2361
Enforcement Division
Additional Contacts for PCB Incineration: Martin Byrne
(303) 837-4261
Surveillance & Analysis Division
Applicants for PCB-Burns:
Unit
Rocky Flats Nuclear
Weapons Plant, CO
Utah Power & Light
Application
Rec'd. App'd.
Commenta
Approved 2/81. No test burn
scheduled.
Informal inquiry made 2/31.
30
-------
REGION IX
Regional Toxic Coordinator:
Regional PCB Coordinator:
Regional PCB Contact for Enforcement:
Gerry Gavin
(415) 556-4606
Air & Hazardous Material Division
Hazardous Material Branch
See above
Ray Seid
(415) 556-3450
Enforcement Division
Permits Branch
Additional Contacts for PCB Incineration: Susan Jackson
(H15) 556-9868
Applicants for PCB-Burns:
Unit
No known activity
Jim Sulirer
(415) 556-4606
Air & Hazardous Material Division
Hazardous Material Branch
Application
Rec'd. Apu'd.
Comments
31
-------
REGION X
Regional Toxic Coordinator: Jim Everts
(206) 442-5560
Air & Hazerdous Material Division
Toxic & Pesticides Section
Regional PCB Coordinator: Roger Fuentes
(206) 442-2850
Air & Hazardous Material Division
Solid Waste Management Branch
Regional PCB Contact for Enforcement: Dennis Stefani
(206) 442-1369
Enforcement Division
Additional Contacts for PCB Incineration: Chuck Rice
(206) 399-5562
Applicants for PCB-Burns:
Application
Unit Rec'd. App'd. Garments
Washington Water & Power 1/81 Notification given, initial test
Spokane, WA held 2/18/81.
32
-------
APPENDIX D
EVALUATION OF A UTILITY BOILER FOR A PCB
DESTRUCTION VERIFICATION BURN ASTOt'IA, NEW YORK
July 25, 1980
Prepared by:
S. G. Zelinski
J. M. Hall
R. G. Mclnnes
GCA CORPORATION
CCA/TECHNOLOGY DIVISION
Bedford, Massachusetts 01730
Contract No. 68-02-3168
Work Assignment No. 12
Project Officer: David C. Sanchez
Industrial Environmental Research Laboratory
Environmental Protection Agency
Research Triangle Park, NC 27711
33
-------
CONTENTS
1. Introduction 35
2. Criteria for Boiler Evaluation 36
3. Evaluation of the Consolidated Edison Facility and Test Protocol. ... 37
Source description 37
Feasibility evaluations 37
A. Evaluation of the Consolidated Edison Test Protocol Sampling and
Analysis Plan ..... 40
Sampling considerations 40
Analysis considerations. ......... ..... 42
5. Recommendations for Changes to Provide a More Suitable Site 4*
Operating procedures 44
Workplace monitoring 44
PCB handling and disposal. 44
0. Conclusions 46
-------
SECTION 1
INTRODUCTION
In promulgating final rules for the disposal of PCBs (40 CKR Part 761),
the Environmental Protection Agency (EPA) recognized tliat power generation
facilities could provide an environmentally safe alternative for burning PCB
contaminated mineral oil. Provided certain boiler design and operating
criteria were met, the EPA concluded that "disposing of PCB contaminated mineral
oil containing 50 to SCO ppro PCB in hlfch efficiency boilers does not present an
unreasonable risk to human health or the environment."
Burning of PCB laden oil in a utility boiler involves metering this oil
into the boiler fuel line In prescribed concentrations and allowing the PCB
to be exposed to the elevated furnjcc temperatures. Complete destruction of
the PCB is insured by monitoring flue gas conditions including oxygen and
carbon monoxide concentrations and temperature. The initial PCB test "burn"
at a facility may also involve the collection of resldu.il PCB which exists
in the effluent gas stream in order to determine the absolute PCB stack con-
centration and hence, the PCB destruction efficiency of the boiler.
Utility boilers which are candidates for PCB burns must be evaluated
retarding the probability of
-------
SECTION 2
CRITERIA FOR BOILER EVALUATION
A candidate boiler must, at a minimum, meet the following estJbltahed
criteria (44 PR 31545):
« Boiler is rated at a minimum of 50 million Btu per hour.
• If the boiler uses natural f,ns or oil, the cnrbon monoxide concentration
of the stack is 5& ppm or less,and the excess oxygen is at least
three percent when F'CBs are being burned.
• The mineral oil dielectric fluid does not comprise more than 10 percent
(on a volume basis) of the total fuel feed rate.
• The mineral oil dielectric fluid is not fed into the boiler unless
the boiler is operating at its normal operating temperature (this
prohibits feeding these fluids during either start-up or shut-down
operations).
• The owner or operator of the boiler moniiors and records at least
once per hour the carbon monoxide concentration and excess oxygen
'percentage in. the stack gas while burning mineral oil dielectric
fluid. If either measurement falls below the levels specified, the
flow of mineral oil dielectric fluid to the boiler shaH be Immediately
stopped.
• The primary fuel feed rates, mineral oil dielectric fluid feed rates,
and total quantities ot both primary fuel and mineral oil dielectric
fluid fed to the boiler are measured and recorded at regular intervals
of no longer than 15 minutes while burning mineral oil dielectric fluid.
To insure these criteria will be met during the actual burn of PCB con-
taminated mineral oil, the cjndld.itc boiler should he checked for the following
key items before the test is begun:
• The PCB feed system must provide accurate flow control and the
ability to discontinue PCB feed without boiler disruption.
• D3C.T must be available on the boiler regarding: heat input; age;
stedia temperature and pressure; thermal efficiency; the number, type
and position of burners: heat release rate; construction materials of
-, • furnace, boiler types, economizer, and air heater; and specifications
01 /equIreJ fuel type.
• Similarly, data is required on the type and flow rate of the air
heater; and on the tvpe, construction material and design efficiency
of air pollution control equipment.
a Ability for continuous iionitorinp of the following parameters is
required: fuel, combustion air, and steam flow rates; flame, furnace
exit, air heater inlet, and stack temperatures, furnace, economizer
outlet, Jnd stack oxygen concentration and stack carbon monoxide con-
cent rat ions.
The above items .should be considered relative to the type and amount of
material to bo burned and the duration of the proposed burn period.
36
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SECTION 3
EVALUATION OF THE CONSOLIDATED EllISON FACILITY
AND TEST PROTOCOL
SOURCE DESCRIPTION
The Consolidated Edison Company of New York, Astoria Generation Station
is located In Astoria, New York. The Astoria 40 and 50 units are tangentially
corner-fired, balanced-draft, tvin-furnace steam generation units manufactured
by Combustion Engineering. Erected in 1962, these units were originally con-
structed for coal ojoration but were designed to burn either coal, oil, or
natural gas. These boilers currently operate exclusively on oil at sustained
loads. Use of natural gas is limited to pilot ignition and low load operations.
There are 16 burners per furnace in each of two furnaces (four burners per level,
four levels per furnace). The heat input at maximum operating capacity is
3,600 x 10b Btu/hr. Design conditions for 2.4 x 10€ Ib/hr sterna flow are
2,100 psig throttle pressure, 566°C main steam tenperature, 538°C reheat
temperature, and 2
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these tangentially fired units, aubstantial fuel/air turbulence is
recommended to avoid channel' ig or bypassing of the PCBs. However,
this need not, in itself, be a deterrent to use of the boilers for
a PCB destruction verification bLrn.
» Unit 50 w.is designed for coal firinp and therefore, its boilor
tubes were probably constructed of chloride-resistent materials.
Chlorides generated by PCB incineration should not present an
operational problem with regards to boiler tube corrosion.
a This unit, with two furnaces, two stacks, etc., is somewhat of a
rarity; data collected here may not be icadily extrapolated to
other utility boilers with regard to their .'bility to efficiently
incinerate I'CBs. In addition, without actr.;il test data which de-
monstrates thpre is no difference between t.ie stacks with regards to
particulate and gaseous stratification and/or velocity profiles,
at least one test would have to be run on both stacks simultaneously
during a PCB burn. Homogeneous flow in both stacks cannot be implied
by an examination of the stacks induced draft fans associated
ductwork. This potential requirement for dual stack sampling could
present problems related to equipment availability for sampling.
• No air pollution control equipment is currently in place oa these
boilers. This will permit evaluation of the destruction efficiency
of the boiler without the intervention of a control device.
Suitability of Mineral Oil as a Boiler Fuel
It appears that mineral oil is very suitable as a boiler fuel based on
the degree of irascibility with No. 6 fuel oil and their similarities in physical
and combustion characteristic:;. The use of mineral oil and No. 6 fuel oil
minimizes the concern for fuel atoraization, fuel quality, and other fuel-
related problems. However, before actual firing occurs, the mi.ieral oil
dielectric should be mixed and tested for physical compatibility with the
particular batch of Ho. 6 fuel oil being used. Further chemical analyses of
the mineral oil are probably not required.
38
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Estimated Destruction Efficiency
The residence time of the PCBs in the furnace combustion zone Is a con-
sideration in the determination of the suitability of the site ofr PCB destruc-
tion. At a waste feed race of 10 gpm, the actual volumetric flow rate of com-
bustion gases through the 154,443 cubic foot furnace volume is 4.18 x 10r' acfm,
yielding a residence time of 2.2 seconds. The residence tine and combustion
zone temperature are adequate to ensure a high probability of achieving 99.9
percent PCB destruction with the low PCB concentrations to be utilized hire.
tn addition, burner efficiencies and the c.ise of atomization of the mineral
oil and the primary fuel oil are also In favor of good destruction at this
boiler.
Dielectric Fluid Feed Rate and Boiler Load Changes
Con Edison '.mends to use a 10 gpm constant displacement pump Co inject
the PCB feed. At minimum load levels, this flow rate ensures that the 10
percent maximum feed rate is not exceeded. To ensure that the PCBs are fed and
burned under relatively steady-state conditions independent of load variations,
it is recomnended that the boiler be operated under manual mode.
Onstrcam Instrumentation
Online monitors are available to measure CO and 0_ concentrations. These
measurements will be continuously recorded during each sflmpling run. In addi-
tion, fuel, combustion air, and steam flow rates, air hearer inlet, boiler,
and exhaust stack temperatures, and other operating conditions of the boiler
wij1 be monitored.
39
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SECTION 4
EVALUATION OF THE CONSOLIDATED F.DISON TCST PROTOCOL
SAMPLING AND ANALYSIS PUN
SAMPLING CONSIDEKAT10NS
The overall test plan submitted l>y Consolidated Edison appears adequate
for the pruposes sf.rcd in its Introduction. The test method cited in the
Con Ed Test Protocol, is similar to the EPA method proposed by Mitchell (1976)
in "A Preliminary Procedure for Measuring the 1'CIJ Emissions from Stationary
Sources," U.S. Environmental Protection Agency, August 26, 1976, in the urii
ization of florisil ns stack collection medium for PCB. The variations which
were noted include a discrepancy between the test protocol impinger system and
the EPA method, specifically whether impinger 2 is a tlpless or plate impinger
type. It is recommended that impinger 2 be of the plate impinger type to conform
with the EPA method. Also, the use of a nylon Imse to connect the probe-filter
to the Impingers is a questionable modification since the system should be
all glass.
Instrumentation
Continuous monitoring for CO by Method 10 is suitable and the Beckman
0, analyzer would be suitable f«r 0_ determination. A possible variatlor from
the PCB regulation (44 FR 31519) is noted in that no provision for suspension
of fuel feed is noted if the CO level exceeds regulation levels of 50 ppm.
This provision must be added. In addition, it is recommended that the flame
l.emperature in each furnace be measured and recorded.
Assessibility for Sampling
The sampling locations cannot be placed at the required distance down-
stream from the sr.ream disturbance because of physical constraints. To com-
Densate for this, the test plan includes the maximum number of sampling points.
This problem was noted in the Boiler Emission Test Report and is unavoidable.
'Ine absence of cyclonic flow (null = 1 ) would indicate this location is
acceptable for sampling.
Load Considerations
The sampling program for PCB testing does not -specify the load require-
ments for the test burn. The test plan specifies and operating range between
75 to 345 MW. The choice of operating range will affect the sampling time
.md will also establish the load limit lor any future PCB burns. All three
Iests should he conducted at the same and near maximum load in order to esta-
blish the burn load limits.
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Sample Recovery
Sample recovery as noted In the test plan is reoson.iblc except that the
recovery procedure requires 30 ml each of the^acctone and hexane for each
rinse. The method proposed by Mitchell requires 100 ml each of acetone and
liexane. The efficiency of removal for a 30 ml rinse is questionable and
maintaining the 100 ml rinse is recommended.
Sampling Time
The sampling time necessary to yield ]0|if,PCD for analysis given a detec-
tion Unit in the stack gas of 1 uE/m is 548 minutes as demonstrated in the
following calculation:
Boiler Conditions
Load: 337 MW
Fuel Feed: 22,210 gallons ptr hour
PCB Concentration in mineral oil: 300 ppm
Maximum mineral oil concentration: 10 percent.
Flue Gas Flow Hate: 3,851,903 Ib/hr
Stack Temp: 254°F (7H°R)
Stack Pressure: +0.08 in. Hg.
PCB In
(22,210 gal/hrM-3-^™--)(-^~^)(0.10) = 2.52 x 10 mg/hr PCB
gill 1.
PCB Oul
At 99.9 percent destruction efficiency (DE) = 2.52 x 10 mg/hr
2
At 99.9 percent destruction efficiency (DE) = 2.52 x 10 rag/hr
Stack Flow
o
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Cunc I unions and Recommendations
The Consolidated Edison sampling plan dppears adequate for its stated
purpose, which is the measurement of PCB destruction efficiency. However,
the plan does not provide additional baseline data for future correlation
between PCB tluHtruction efficiency and emission levels or operating parameters
of boiler performance. Neither does the pLan esAim
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• pretest iji, checks on resins, reagents, and solvents for
field use,
• pretest QC checks on renftents/solvunts for laboratory use,
a pretest verification of precision and accuracy of
analytical methods at stated detection limits, and
9 Addition of a duplicate analysis of the proposed CC/MS
confirmation of PCB or, at lea^L une- unpcrchlorinatcd
extract.
Add t tiona1 Analyses
To determine iht; mfcc-t of burning PCBs on inc production of othtT poten-
tially hazardous cir^nnLi..?, an additional samplini; train ib rt-commentlcd. Toe
various stages of this train should be analysed for:
• analysis of parctculacr filter, probe rifi&c-s, ana resir
extracts from Method 5 train with a;i XAD-2 resin cartridge
for: chlorinated dLhfu^ofurans, dioxins, and FA1I by
c.ipillary CC/MS; tot.iJ i_f.romatogrjphable organin!, by GC/FIO
and nonvolatile ordain::; by gravimetry
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SECTION 5
RECOMMENDATIONS 1-OR CHANCES TO PROVIDE A
MORE SUITABLE SITE
OPERATING PROCEDURES
A detailed work plan describing the operating procedures, employee assign-
menta, health protection, and t'CB handling and containment procedures must be
written and evaluated prior to the verification burn.
The operating procedures should include the organizational structure
delineating the specific Individuals who will be responsible for boiler opera-
tion, safety, boiler monitoring, sampling analysis, and workplace monitoring.
In addition, day-to-tlny scheduling, instrumentation, security provisions, and
emergency provisions for the burn must be provided.
WORKPLACE MONITORING
Employee breathing zone l£sts can be conducted during the verification
burn to determine the extent oT boiler operator exposure to PCB. The sampling
and analytical techniques whicn will be used for the employee breathing zone
teat ft should follow the reromn.endat ions of the NIOSH Manual of Analytical
Methods, .Method P and CAM-253 for PCBs in Air.
Samples ot the reside from within the boiler should also be taken, if
posulblc, .md analyzed to determine the extent to which boilerhouse operators
could be exposed during cleaning of the boiler.
PCB HANDLING AND DISPOSAL
Spill Prevention w Control
A upill prevention program should be established for chi> mineral oil, fuel,
and other 'Hazardous materials. Cleanup procedures and containment of accidental
discharges should be provided.
Wgatc- Hand I in,-, and Disposal
A tc-nporary dike must be set u^ around the transfer area, sized to retain
up to 10 percent of storage c.ipacity. This c.in be nade up of sandbags and
polyethylene sheet.
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Transfer pumps, hoses, .ind power connections must be provided. Tl>e trans-
fer pumi> should ha^e an adequate gpm capacity to prevent any unnecessary
holdup time for the canker.
PCU-coiilaralnatcd materials such as oil drippings, absorbents, rags, feloves,
clothing, boiler residue, etc., should be collected and deposited in seaLtiblc
55~gallon containers. The containers will be identified as containing PCB and
will be serialized and logged. Full containers will lie sealed, checked, and
transported directly to the secured PCB storage area to await proper disposal.
Employee Training
Tlio work plan should be reviewed wirh each operator who will be directly
involved with the verification burn.
ENVIRONMENTAL. IMPACT
The following are optional items viliicn may be useful ir. establishing the
overall safc-ty of the verification burn:
a provision of an environmental impact assessment predicting
the potential maximum ambient concentrations under "worst-
cose" meteorological conditions, and
e addition of ambient monitoring network if the rodelinc a°d
stack gas measurements suggest a potential airbient impact.
Th» ambient monitoring would be designed to asses? PCB
background levels and potential population exnosure.
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SECTION 6
CONCLUSIONS
The c:on Ed site aL Astoria presents the following advantages and disadvan-
tages for use In a trial PCB destruction burn:
• Advantages
Con Ed is willing and able to conduct the burn
and has good sampling and analysis support
facilities,
a sufficient .i.nount of PCB-contaminar.ed transformer
oil is .ivail.'tbK' for a burn, and
- the procedure:, for evaluating a request for a permit
in New York St.if.c prevent tho "valuation period from
exceeding 90 days once the Con Ed replication is complete.
9 Uisadvantiiges
the site doe.«j not appear to be representative of
many other utility boilers,
the site is located in a highly populated area, and
the configuration of the boilers and stacks may
present a problem in accomplishing a cost-effective
sampling and analysis program.
46
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APPENDIX E
EVALUATION OF PCB/UTILITY BOILER
INCINERATION: NORTHEAST UTILITIES
AUGUST 1980
Prepared by:
R. C. Kclnnes
S. C. Zelinski
CCA CORPORATION
GCA/TECHMOLOGY DIVISION
Bedford, Massachusetts 01730
Contract No. 68-02-3168
Work Assignment No. 12
Project Officer: David C. Sanches
Industrial Environmental. Research Laboratory
Environmental Protection Agency
Research Triangle Park, NC 27711
47
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PQJ/H .'.if iwi I.J:R i M'i STRATI w
Northeast U:iHtii-: !:ubm:nv.i to i"(..\ in-r lelt.r v-f V/2C/80 - Midd 1 "Uiwi Stitlon.
Unit. 3.
COMMENTS 0\ Si'KMI'.TAI,:
Boiler Ciltu-rfn (14 I'K li.iV>)
« BIr >5GMM BH'/HK?
-Yes, I'nit J rated at 2.J=- x 1 ()'' i;rU/!IH (2jriNW)
o :'.lr CO Emission -501VI ;md 02 -'j'^
- Yes, I'nit fstod «'M April 22, 1930 dt 2J.IMW (full lo.id), 205M'..' (87T. !,>:ul),
and l«nx>x' (/.'v lo.ni). .M) tiifts i-idic.Ttt-d 7.uro (0) percent CO. nnJ n.
r.nnir.r from 3.t»": (.jr 2'1^W> to 3.6/. t-ir 18n>r...').
a MintT.il oil Joos tioi M.- "it i ,(.- norr- r'mii 10 pi-iconi of rr«r.M fuel fi^oi1.
- A: {.•;»«•• "tim luvcj-- VL-. .•-r. \W'.i .mil ''MM... I'uil J ro-i^uaw". l>otwi..."t
1^0 ('..il/-'!!! .mti ^'j(J ''n/'-iin. The dosivr. -.riiioiil \---d r.uc i F 1^ (", 1'v'Sn.
• Tii--- bnil-.-i :-n.st i.i- .it iu".' •! opor.u iui', tcr i.'r.iti.rc lu'iWo iriui-ril oil m.»y
be fed to s t.
- Plant [Tocvduriif. b-'ixiry lu.nL iiinurjl oil will oil;- be ft-J .it boiler lfVfl: tlii-i .-I'.MMi-* noiTinl O|IIT.T. i:ig tcinpor.iturc.
« CO ard Up levels rust l;c -'u:iJtorecl .it least oncij/h«niv ana the hi'ilor uj 11 bo
stoppt'd if rho re.icliii. •. T.ill onti-ldi1 spcrif ic-t! ranuL1?.
- CO and Ci^wiJL bo na.isur^d rnnciniiouslv and recorded every halC-houi. Tlie
Instruraonf? till he calibrated before and after die burn.
• Botn primary fuel nntl nLiu-r.il oil must be measured jud rccordfJ .it lo:ist
every 15 minutus «Juriiii, tlic- hurn.
- This is inrlinled wi'.ii the plant oper.it In •. procedure for mineral oil burns.
ABDUTONAL ITI'HS THAT ARE PROVIDED.
• .Schematic of linuiMl oil ''tf.'d svsLem, InrludinK all valves and ir.aiii I'ncl
!iock-up. 43
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• St aivlard n; if. ruins pro.-eilm .•, incUidtn". c!iucV 1 isc lor mineial oil
burn period!,.
• sl.nko and m-uii-l dt l>uth l.'O and 04i inst IIII.H'MLS.
0 Ki-su! ti: >>r a il i i u^f.l en modeling analysis which prudlctt (.•
i-.round li*v«.-l coitrcntr.it Ifnis of 1'CB .mil !ICt assuming n tlc.-;ti isr i iun
r-f 1'ici.cn^v (DM of rInK >>iul they Intend to contlruously monitor).
ADrU1IUN,\i, lNmr>!ATIOX nU" Kll.l. AID EVALUATION:
9 IJcst>-.n Inrorr.n''.Jon an the toiler inrludlny. ito.im tcri|icr.»tv.irc and pros •sur*1
thorn..! off Lclcm-y, Opo. nunbui . and po'-itit-nnf oil l>urnos, ronstnu. t loa
raiiti-'riaJs for this furn.icc, p.'Ononi^cr din! air heater ( Li they liavw oil?},
design fuel, typo ol' .iir pollution control t!t-vlcu and crricic-ni-\ (if out-
is insUil U'J).
• Ability o! tl1.1 unit to t:oiiLinuon«lv raonltor crcibiistion ;ilr and steam
flow, lunv»,:o nu! "si.ick ti-i|»fit iturc-.
o St.'ick tt.-'.r loi.ition. .":o •••'.ahilj ty, «inv i>rfv i.>ti<- part ictit.im "st.icl: test
result1?.
CKM11KAL COMMV.::'1-:
p Sulvaltti.-il :•• very duMOod, covar.-i .ill n.nor points, includes a detailed
opcr.itini; prrico.luro Jui Chi- burning period and estimates -»orsc case ground
l«:ve' rone tnt rai ions.
• Thin site appears to be- an excellent one with regards, to conducting a
simultaneous «rack tost by iICA, should tlir test location prove to be
acceptable. 49
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Hie sampling tin-- :io.-c-: .jrv to yfe!d ?0 p/. 1'CB for analysis rLven a iJftuction
limit Lr. the st.ii.k .-.TC of '> . j;m/n' is |?')l) 1,1.' iiuf"? js (li'noii-.rr-itcd In tlio
BoiJor Condicion-
LoaJ: 235MVJ
Fuel i'cc'i: 13,000 ('..-.lion* per l.oiu
PCB Concentration wltn Miner.il Oil: 200rr.M
Maximiun MineraJ Ull Cnncontr.Uioi<: 6 pi-rui-nt (900 H'H)
Sperlfic Gravic,' of MJnc-ral djl: 0.9
Flue Oas Flow KJCC: 311 .i:P/.«=cc.
Stack To-np: Unknown - ,\0suno 310° !•' (770°!0
Stack Pressure rn!»"own: .'-»,un.o 0
I'Cr. In;
(U85')
(15,000 Cal/Hr) ( f.,ii" }(?.«'0 m.../n (i.i.-M (O.W,) = f,l3,l/0 »r,/lir PCI1.
at 99.9 percent dc"tn:i-cJon cfLi.Licn.-v - 61J.17 iv/hr PCI.
Stack
(RUS dcnsitv) r-i Mi.i.inl enntiiiioiih = O.oJ'tVi r.h/ft3 corL-crtlng for stack
condition.-. (31t)°K) = ft.O/.'.ll x T~-~-.~ - 0.0516 ch/ft?.
Q stack = ill. 4 nVs«T
=> 10,93';. j ftVs.n-
= 39.562 x JO6 ft'/hr.
At 99.9^35 percent HE, .stock cor. *entrat:.on:
15. 49 x 10~f' ra;:/ftj
50
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To i.olLoct 1 UK I'CB, we
15.4
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APPENDIX F
PCB WHITE PAPER
June 12, 1980
Prepared by:
S. C. Zelinski
J. M. Hall
CCA CORPORATION1
CCA/TECHNOLOGY DIVISION
Bedford, Massachusetts 01730
Contract No. 68-02-3168
Work Assignment No. 12
Project Officer: David C. Sanchez
Industrial Environmental Research Laboratory
Environmental Protection Agency
Research Triangle Park, NC 27711
52
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EXECUTIVE SUMMARY
Widespread interest in the environmental significance of PCBs has led
to Intensive research into the hazards and distribution of these pollutants.
Review of the conclusions from these investigations led to the promulgation
of regulations controlling the manufacture, distribution, use, and disposal
of PCBs. Tills document has been prepared in on effort to briefly summarize
pertinent federal regulatory actions and the technical justifications and
economic analysis performed prior to the promulgation of the regulations.
53
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INTRODUCTION
The polychlorlnaced biphenyls (PCBs) are derivatives of the compound
biphenyl in which from one Co ten of the hydrogen atoms have been replaced
with chlorine atoms. The PCBs which have been synthesized for commercial
use are mixtures of isomers with different average chlorine contents. The
chlorine content can range from 18 to 79 percent by weight.
One of the najor producers of PCBs was <"6nsanto Corporation. Their
materials were called Aroclors and were codcj so fiat an Aroclor 1262
represent fid a PCB mixture that had a uhlorlr.e content, rf approximately 42
percent by weight.
The advantage of the PCBs lies in their excellent chemical and thermal
stability. This led to their u-e in a variety of commercial applications,
including dielectric fluids in capacitors and transformers, plasticizers,
carbonless copying paper, hydraulic fluids f>nd cutting oils. Such wide use
and the lack of recognition of die potential hazard of the PCBs led to their
being ubiquitously distributed in the environment.
The acute toxic effects of t'CBs were brought to the forefront of public
attention in 1968 after PCB-contnrainated cooking oil caused widespread
poisoning in Japan. Other IRC3aunts of PCB contamination within the U.S.
brought attention to the methods employed for PCB disposal and the related
dissemination into the environrieiit. The release of PCBs into the environment
was generally not controlled until the early 1970's. Up to 1977, approximately
1.25 billion pounds of PCBs had ^eeii purchased by industry in the United
States. Of this anount, an estlnated 60 percent is still in use; 4.4 percent
has been destroyed by incineration or environmental degradation; and the
remaining 35.6 percent (approximately 500 million pounds) is present in the
environment. An estimated 65 percent of the PC3s in the environment Is
located in landfills or dumps. These reservoirs have temporarily incaobilized
the PCBs, but can potentially allow the release of the PCBs to add to the
remaining 35 percent of PCBs that are free in the environment.
The following is a list of the major routes by which PCBs enter the
environment:
• Landfill leaching from plastics and resins.
• Direct contamination into soils and rivers from leakage
of hea^ transfer fluid or oils.
• Direct disposal of waste oils, waxes, and paints from
industrial or other sources into rivers and other
waterways.
o Recycling of PCB-containing paper and the release of
washings into municipal sewage systems.
-------
o Insecticide runoffs cf FCBs which are used to extend the
kill-life of aldrln, dicldrin and chlordane.
o Industrial smoke from the inadvertent incineration of PCB-
containing materials as few facilities provide the required
decomposition temperature and residence time.
As Industry and government became increasingly aware of the hazards and
environmental degradation associated with the use of PCBs, their sale was
restricted and regulations appeared to control their manufactur ng and
disposal.
REGULATION OF PCBs
From July 1969 to August 1971, nine Incidents of PCB contamination of
food were reported. No record of human PCB poisoning in the U.S. has
occurred, but near disasters have resulted in regulatory action. In 1973,
the U.S. Food and Drug Administration (FDA) established temporary limitations
of PCBs in food. A surveillance and inspection program by the FDA detected
numerous lots of contaminated foods.
The Clean Water Act of 1977 contains the first regulation by the Environ-
mental Protection Agency regarding PCBs. Under Section 307(a), manufacturers
of electrical transformers and capacitors were prohibited from discharging
PCBs into waterways (Federal Register, Vol. 42, February 2, 1977, pp. 6532-
6556). These regulations stipulated February 2, 1978, as the deadline for
compliance, allowing affected manufacturers 1 year to take the necessary
steps (e.g., use of substitute materials and equipment or process changes)
to eliminate PCBs from their effluents.
On March 26, 1976, as work was being performed on promulgating regula-
tions for toxic effluents under the Clean Water Act,, Senator Caylord Nelson
of Wisconsin introduced an amendment to the Toxic Substances Control Ace (TSCA)
for the phasing out of PCBs in manufacturing processes in the U.S. The
TSCA was promulgated on October 11, 1976, and contained this amendment
as Section 6(e). Section 6(e) requires the Environmental Protection Agency
(EPA) to control the manufacture, processing, distribution in commerce,
use, disposal and marking of PCBs.
The disposal and marking rule for PCBs, Section 6(e)(l), was promulgated
by the EPA O'i Feburary 17, 1978, (Federal Register, Vol. 43, No. 34, pp.
7150-7164), and clarified in an addendum of August 2, 1978, (Federal
Register, Vol. 43, No. 149, pp. 33918-33920). EPA published the proposed
rules for Sections 6(e)(2) and 6(e)(3), which regulated PCB use, on June 7,
1978 (Federal Register, Vol. 43. pp. 24802-24B17). These rules were
supported by documentation, voluntary environmental impact statements and
numerous public hearings. On November 1, 1978, EPA published interim rules
for Section 6(e)(3)(B) establishing procedures for persons to petition the
Administration of F.PA for exemptions from prohibitions to manufacture,
process, or distribute in commerce PCBs. The final rule, promulgated on
55
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May 31, 1979, (Federal Register, Vol. 44, No. 106, pp. 31514-31568) declares
the prohibition of processing, manufacturing, and distributing of PCBs after
July 1, 1979, unless specifically exempted by EPA. The final rule becaae
effective July 2, 1979.
TECHNICAL JUSTIFICATION FOR THE FINAL RULE
Destruction in High Efficiency Oil-Fired Boilers
Prior to the finalIzation of the PCE rule both theoretical calculations
and field data were available which offered convincing evidence of the
ability of an oil-fired boiler to destroy various concentrations of PCBs.
In October of 1476, Monsanto Research Corporation published a theoretical
study on PCB emissions from stationary sources.1 This report not only addressed
the potential of formation of PCBs during the combustion of fossil fuels, but
also the destruction of PCBs. The conclusion reached was that under thermo-
dynamically controlled situations the "chlorinated biphenyls would react
to essentially extinction."1
Prior to the publication of the Monsanto study, In May 1976, Florida
Power and Light Company had reported on the results of a PCB burn conducted
at their Sanford Unit No. 4. The stack sampling and analysis for PCBs was
conducted by a private contractor. The results of this test in which PCB-
contaoinatcd oil was fired along with No. 6 fuel oil revealed no detectable
amount of PCBs in the stack gas. The Method 5 particulate train was used
for sampling, and Aroclor pattern matching by gas chromatograph-electron
capture detection (CC-ECD) was used for analysis.*
In October of 1976 the EPA published a report detailing the emission
testing at the Continental Can Company in Hopewell, Virginia, during PCB
burning. This investigation reached the conclusion that the power boilers
tested achieved greater than 99 percent destruction efficiency of the PCB
present in the fuel.3
In December of 1977 the University of Dayton Research Institute under
contract to the EPA published a report on the laboratory evaluation of high-
temperature destruction of PCBs and related compounds. This evaluation
established that PCBs could be destroyed at greater than 99.995 percent
molecular destruction at a residence time of 1 second and a temperature of
1000'C.'*
Destruction in Incineration Svstems
Prior to'the ftnalizivlon of the PCB rule, incineration tests of high
concentrations of PCBs had been conducted. In December 1976 the rotary kiln
installation at Rollins Environmental Services, Inc. was tested for its
ability to destroy PCBs.5 The PCBs were introduced to the rotary kiln in
the form of contaminated whole capacitors and contaminated hanunermilled
56
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capacitors. Calculated PCB destruction efficiencies for whole capacitors
was 99.5 percent and for haiumennilled capacitors, greater than 99.999 percent.
The gas residence time in this system is of the order of 2 to 3 seconds with
a flame temperature of about 1500°C.
In January 1976 PCB destruction tests were conducted at the St. Lawrence
Cement Co.* The destruction efficiency of PCBs was calculated to be 99.986
percent. The kiln was maintained at ]450°C with an approximate residence
time of 30 seconds.
In another test in 1976 at the Continental Can Company, PCBs in waste oil
were fired into a rotary line kiln maintained at 1260°C during the tests.J
Destruction efficiency at this site was found to be 95.4 percent.
In a test in Sweden conducted by the Swedish Water and Air Pollution
Research Institute a rotary cement kiln achieved a 99.9998 percent destruction
efficiency of PCBs.7
These data for both high efficiency boilers and rotary-type kiln incinera-
tors provided a convincing argument for the ability of these units to achieve
high destruction efficiency ot PCBs.
ECONOMIC ANALYSES FOR THE FIMAL RULE
Prior to the promulgation 01 the final rule, economic analyses were con-
ducted to assess the impact ot" the propored rule, v'ersar. Inc. of Springfield,
Virginia, prepared two documents for EPA: t.icroeconoihlc Impacts of the Proposed
Marking and Disposal Regulations for PiBs (A,>ril 1977) and Microcconomlc Impac. s
of the Proposed "PCB Ban Regulations" (Kay 1978). Versar revised these docu-
ments upon the request of EPA priot -o the promulgation of the final rule.
The final report is entitled PEE Manufacturing P-ocesslng. Distribution in
Commerce, and Use Ban Regula'i ..i: Econo-.t' Impact Analysis. March 30, 1979.
Versar concluded thac the proposed narking and disposal regulation would
cost an estimated $62.2 million the first yea" Tie cost would include new
incinerators, new storage faciJJrics, oper~tin_ cvsts, chemical waste landfill
charges, disposal transportatio- 'osts, •-ecjrdkeeping for marking, and mainte-
nance of storage facilities. Ihe ma^or economic impacts would apply to:
utilities owning and using PCB-cor'ainir.g large high voltage capacitors; owners
and users of high intensity discharge lifting apacitors, PCB small capaci-
tors, or PCB large low voltage capacitw ,, or equipment containing such
capacitors; manufacturers of equipment containing PCB articles; and manufac-
turers of large low voltage capacitors, small capacitors and fluorescent light
ballasts.
The analysis of economic impacts for '.he PCB ban regulation was divided
into transitional and long-term cost impacts. The transitional costs arc
those co&ts necessary to eliminate all existing PCB-containing equipment from
service. For example, the total cost of the ban on sales of PCB capacitors
57
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and equipment after July 1, 19V9, including inspection and rework costs,
could easily exceed $1 billion. The long-tern costs will be continuing costs
and will have a long-term economic impact. Examples include the increased cost
of non-PCB transformers and power factor capacitors.
CONCLUSION
The intent of environmental legislative action is to protect the public
health and welfare. This is accomplished by setting standards; establishing
agencies capable of enforcing these standards; and actually implementing
control mechanisms for the effective enforcement of pollution controls.
Another function of statutory law is to establish conservation and develop-
ment programs to enhance the quality of the environment. The promulgation of
these regulations pursuant to Section 6(e) of TSCA exemplifies ehis intent.
The regulations as finally implemented serve as an excellent guide to the
future use, storage and disposal of PCBs. However, the potential for
exposure will remain jntil all PCBs have been adequately contained or de-
stroyed as specified in the regul Eions.
58
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REFERENCES
1. Knieriem, Herman Jr. PCS Emissions From Stationary Sources: A
Theoretical Study. Monsanto Research Corporation, Dayton, Ohio.
Prepared for U.S. Environmental Protection Agency, Washington, D.C.
EPA-600/7-76-028. October 1976.
2. Report on PCB Emissions From Sanford Unit No. 4, Florida Power and
Light Company. Environmental Science and Engineering, Inc.,
Gainesville, Florida. Hay 1976.
3. Emission Testing at Continental Car. Company, Hopewell, Virginia,
July 14-23, 1976. Environmental Protection Agency, Office of
Enforcement. EPA-330/2-76-030. October 1976.
4. Duvall, D.S. and W.A. Rubey. Laboratory Evaluation of High-Temperature
Destruction of PolyclilorinateJ Biphenyls and Related Compounds.
University of Dayton Research Institute, Dayton, Ohio. Prepaicd for
U.S. Environmental Protection Agency, Municipal Environmental Research
Laboratory, Cincinnati, Ohio. EPA-600/2-77-228. December 1977.
5. Haile, C.F. and E. Ealadi. Methods for Determining the Pol/chlorinated
Biphenyl from Incineration and Capacitor and Transformer Filling Plants.
EPA-600/4-77-048. Novenber 1977.
6. MacDonald, L.p D.J. Skinner, F.J. Hopton, and G.H. Thomas. Burning
Waste Chlori •>. '• Hydrocarbons in & Cement Kiln. Report to Fisheries
and Environm- • :anada. Report No. EPS 4-WP-77-2. March 1977.
7. Ahling. B. Destruction of Chlorinated Hydrocarbons in a Cement Kiln.
Environ. Sci. 6 Tech., 13:1377, 1979.
59
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ADDITIONAL READING
Federal Register. Vol. 43, No. 34. Friday, February 17. 1978, pp. 7150-7164.
Federal Register. Vol. 43, No. 149, Wednesday, August 2, 19/8, pp. 33918-33920.
Federal Register, Vol. 44, No. 106, Thursday, May 31, 1977, pp. 31514-31568.
Federal Register, Vol. 44, No. 183, Wednesday, September 19, 1979, pp.
54296-54297.
Federal Register, Vol. 45, No. 62, Friday, March 28, 1980, pp. 20473-20475.
PCB Marking and Disposal Regulations — Support Document (40 CFR Parr 761).
U.S. Environmental Protection Agency (018-068005), undated.
PCB Marking and Disposal Regulations Final Action — Support Document
(40 CFR Part 761K II. j. Environmental Protection Agency.
Support Document/Voluntary iTnvironraental Impact Statement and PCB Manufacturing,
Processing, Distribution in Commerce, and Use B,=m Regulation: Economic
Impact Analyses. U.S. Environmental Protection Agency, Office of Toxic
Substances, Washington, D.C., April 1979.
Environmental Research Brief, Thermal Degradation of PCBs. U.S. Environmental
Protection Agency, Municipal Environmental Research Laboratory,
Cincinnati, Ohio, October 1978.
Polychlorinated Biphenyls. National Academy of Science, Washington, D.C.,
1979.
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APPENDIX G
PUBLIC MEETING
m \IHVK i_ IOK
KLMJIII I Ml. Si HTCP ( i nlri
Vtv-li-vjn Him i r-ilv
Miilillclou n, ('.limn clii ul
WHAT SHOULD WE BE DOING ABOUT PGB?
Morning J 'retrain
9.00 a.ni — WVkunw
Paul L. \\ u££im uf Science and tngiiirering
MoiliTdlor Karl K. !liin»on. Cliiiiriniiii. bricuci1 in Swiriy Program. Wesle>an Univcrsiiy
9. IS a in. — TII/IH Thr inilu-lnul Use of 1'CIt .nvl AJlc
Kohi;rl C O.ilhuff, fn-ncral l.lrctnc Cu>ii|j.ni\. S( hi-nii l.iciv. N.V
10.00 a n:. — TII/HI • Tlii- I'uMir llcjllli CIII.iinii-nial H> allh Sciences. Krfcjrch Triangle l}ar)>. N. C.
104S-1I 00 a.m. - Coffiv Itr^k
1 1 00 . i in — 7°"/iri Tin- K.'^tiljtion of P(!H l)i-|nnal and itie Kmiroinneiit
(ilt-nii Ktinl/. l> S. tlii^ironnicniiil I'rolcclivn \gt-iKV, ^.i-lnngtun. D.C..
1:15 a ni — 7«/iir I'ulilir Cimccni- lo-al
\\dlljro I'ruifilf. \\e»lr>an UniM-rsity. MiclfilrUmn. (luiin.
12.SO-1 30 p.m. — Lunrh
Afternoon Frogrum
Muijrrutur: i>;iM(l M. \\i-lxluiu-. ^I'lri-lnn. OoniHTtirul Arudi-my uf Sricnn- and En/i
1.30 pni — TI-IHI. FU-ghinjI (iunrriiiN m Handling; !'(!!!.
\\illiar.i (".. i:<-nfrn. Nunlu-.iii Lliiiti.-s, HartfurH, Conn
2.15 p rn. — TII Tin* Kc -|)i>n-iiniilit's nl Mnnu ipaliiirs in ilrltition to 1'CH Di^imsjl.
Tliij !i )iiiirj|i|4- Mifhar) Culn-l.i. Matur. Midd!' lown, (.nun
:iOt)-:».l:i pin. — ( Mtf »r.-al>
3 IS pm. — I'ulilit Forum
'/''•/in • Questions from the jiidirnrv will In- r<'-,]niiuli'.i in liv llit> speaker1;.
61
4»r«H)v |fi.- J .utiitruictit \rd*li>rnt nf St rt n« .mil
trl thr Stfimt* in Stu ir
-------
GCA/TECHNQLQGY DIViSSQN
TOi Paul Fennclly DATE: 12 January 1981
FROM: Bob Mclnnes
SUBJECT i Public Meeting in Middletown, Connecticut - 12 December 1980
"What Should Wt- Bo Doing AbouL PCB?"
PCB-Ucility Boiler Program (1-619-012)
The following is a summary of er.ch presentat ion at the subject meeting.
'Robert C. Osihoff - C.E.. Schcncciady, New York
Topic: The Industrial Use of PCB and Alternatives
Industry has historically used PCI1, for fire safety considerations. Principal
PCB uses: (EPA 560/6-76-005 give:, quantities of PCBs used.)
• Investment Casting
• P}.istics
p Capacitors (Fluorescent Light Ballast.)
• Transformers
o Hydraulics & Lubricants
• Carbonless Carbon Paper
G.E. introduced a substitute Jielectric fluid in 1975. The following items
were criteria for this substitute.
e Tire Safety
e Insulation Valves
- Breakdown
- Impulse (Lighting, Accident)
« Resistivity
0 Thermal Properties
• Choral-".! Compatibility
0 Environment.al Concerns
• Availability
• Factory Handling
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G.E. chose a silicon based substitute whirs lias the following properties.
• Low Vapor Pressure
o Lighter Chan Water
a Adsorbed on Solid
• Not Biodegradeable, but Degrades
-------
• Under lab conditions, the lethal 'one for 50£ of the population
-------
Glenn Kuntz - EPA-OPTS-PCB regulations Te. •. Washington, DC
Topic: The Regulation of PCB Disposal and the Environment
• Latest Developments - EPA has recently lost a court case to the
Environmental Defense Fund (EDF)
- 50 ppn Cutoff for PCB was Ruled Invalid
- Definition of Transformers and Capacitors as Totally Enclosed
Devices was Ruled Invalid
e Status of PCB Disposal Options
- 2 Commercial Incinerators now Completed - ENSCO, I Dorado, Arkansas;
Rollins, Texas; Test Burns conducted in late Aug.°t, EPA awaiting
Results.
- 3 Additional Incinerators (in Tennessee, New York, and Massachusetts)
have applied to Incinerate On-Site Generated Waste
- Vulcarus - Incinerator Ship; recently sold to American firm;
EPA hopes for a PCB Burn in Spring 1981; 2 years of active Incinerator
Life Ic-ft in Ship
- High Efficiency Boilers, Bay City, Michigan - Test has demonstrated
»99.992 destruction efficiency. There Is 10 tines more PCB contam-
inated mineral oil than high concentration PCB materials Co be dis-
posed of; several additional boilers under consideration for PCB
burn, including Middletovn, Connecticut, Potonic, DC, Baltimore Gas
It Electric, Union Electric in St. Louis; in 1976 danford, Florida,
conducted success! ul PCB Burn
e Chemical Means of Disposal
- Sun Ohio Company of Canton, Ohio has a process chat is carried on
a truck; it was recently tested, preliminary results look good;
EPA looking for a January, 1981, Approval
- Goodyear Process; Goodyear will not demonstrate nor use this pro-
cess and it is not GoaBLercLal
- EPA working with the Food & Drug Administration, and the Department
of Agriculture to ban PCBs in Food Feed and Fertilizer Applications;
this action is on hold due to EDF Court Suit
- All alternatives must address the sane Liabilities and Limitations
- Location
- Facility Cost
- Destruction Ability
- Time Schedule
- Transportation
- Handling
- Alternatives to PCB destruction in Northeast Utility (or any utility)
Boiler
A. Storage - 2,000,000 gallons of PCB laden oil now in storage
throughout U.S., estimated cost for delays In adopting a
disposal method if $34,000/6 months.
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B.' Chemical Waste Landfill • This option postpones the problem,
there are 8 landfills In the country now approved for PCJ5
disposal.
C. Chemical Destruction - What is applicability to large batch
loads? SOHIO process only dcstructs low concentration PCBs
now in use - it doe.-, not address stored PCBs. This process
does have the advantages of being mobile, nvaking location
of PCS no problem, it gives good PCB destruction and does
not result in air emissions.
D. Boilers - Uical boiler such as Northeast Utilities offers the
advantages of location, little transportation and handling,
no new cost.
E. Incineration - Existing vs New vs Ship
- Existing - no new facility required; any PCB >500 ppia must
be incinerated
- New - Costly, must be in highly populated, highly industrial
area where waste is generated
- Ship - Staging Area Required; handling may be a problem;
ship can destroy PCB, but there may be an outcry front
cities used as staging areas. Also, since EPA does not
allow PCB storage in flood plains, there are only a few
coastal cities which aieet this criteria. Finally, there
Is the question of ship availability
AUDIENCE QUESTION'S:
Q - now much PCB are left after use of the SOHIO process?
A - <10 ppm left.
Q - Is this O.K. with EOF court suit?
A - Maybe not. Disposal Rules have changed.
Q - What is the definition of a "successful burn"?
A - This depends upon the method used and is left to the Regional EPA Administrator
to define. It should include a consideration of what is coming out, e.g.,
SOHIO process does consider outlet PCB concentration.
Q - EPA does not seem concerned?
A - It is not clear what levels of PCBs are a problem. The rule is set up to
allow the Regional Administrator some flexibility.
Q - What about the toxic by-products of incineration?
A - There may be some since nothing is 100% oxidized.
Summary; There are two basic disposal methods, storage vs incineration; both
have liabilities; the public must decide which they want.
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Wallace Pringlc - Wcsleyan University, HtdJ'l'?town, Connecticut
Topic: Public Conccrng Regarding PCB Disposal
• People muse be Interested, knowledgeable and informed.
1.2 billion pounds of PCB have been manufactured in last 50 years
• The List of Environmental Concerns Grows
- Mercury in Sword fish
- Kepones in St. James Kiver
- PCBs in Housatonic and Hudson Rivers
• PCB is a problem because it is indestructable. Unlike SOj, it has
no natural sources and sinks; it is not soluble in water and cannot
be diluted by water. It has a low vapor pressure and will not
become airborne unless emitted from smokestacks
• 51 people have died in Japan from PCBs
e Fatal dose in humans is approximately 2. g
0 Allowable FCB limit in fish is 5 ppn; -..is was derived by using 2 g
fatal dosei applying a safety factor oi 10, and then using average
human fish consumption
• Health affects of PCB are dealt with in length in a volume recently
published by the New York Academy of Sciences
• Bioaccumulation of PCB is a real problem
e There has been no control in past PCB disposal
e How does the public participate?
- Gather all known information on adverse effects
- Add suspected effects; i.e. , paradioxin in Agent Orange is the
suspected toxic problem here
- Consider Synergistic Effects - £parts >total of individual elements
- Public Health Considerations - Do we protect all citizens, including
those with severe problems (e.g., emphysema) as is now the case,
or do we set standards based on healthy citizens, thereby relaxing
standards, as has been proposed
- Public Welfare - Quality of Life - Do you care about dead fish?
The snail darter? Eyes that tear?
- Social - Economic Costs of Reducing Air Pollution - It is not
practical and is extremely expensive to have no pollution - If you
don't like the Regulation, what do you do?
• Specific PCB Regulation
- We musi. get rid of them and not landfill them; an article in
Environmental Scier.ee and Technology two months ago (Note V. 14,
No. 3, 1980) concerned PCB and asked the question - How can you
insure reproductibility in different boilers? - San ford, Florida
and Bay Cicy, Michigan were no problem, but a test conducted in
Hopc.well, Virginia (on a boiler similar to chat in Middletown)
gave PCB destruction efficiencies of 99.2, 99.3, and 99.52. Is
99.3% enough?
67
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- What happens if you don't bur1 PCB completely? The incomplete
combustion product is fur.in . ..l_n is very toxic
- The regulation ought to bu better defined; boiler efficiency
cannot be completely defined by 02 and CO measurements
- What is an acce^..able risk for furans?
William Rcnfro - Northeast litititles, Hartford. Connecticut
Topic: Rc&ion.-il Concern;, in Handling PCB
« There arc 35 million mineral oil transformers in New England. In
addition, there arc 5 million active capacitors with 1'CBs, ^ ate
owned by utilities. Finally, there are 140,000 PCB transformers.
Northest Utilities (N U) has 16,000 capacitors with 2-3 gallons of
PCB-oil in each and 1200,000 pole top transformers with 20-40
palJons of PCB mineral oil in each. Also there are many, large sub-
station transformers
o In April, 1978, the first PCB regulations were issued and N.U.
assembled a corporate toan to address regulations
- Capacitors with Pf'fl »500 ppm were put i-.uo 55 gallon drums (per
DOT Regulations) .ind transported to a special storage area to be
finally buried in an approved Ip.tdfill.
- Mineral oil is malting final disposal options.
o July, 1979 - New PCB Regulations
- Redefined catoff concentration from 500 to 50 ppm of PCB by weight.
- Previously any oil >500 ppm was sold to salvage.
- With new regulations, there are 3 classes
- PCB transformers with >500 ppm PCB
- PCB transformers with <50 ppm PCB
- PCB transformers with 50-500 ppm PCB
• N.U. expects to accumulate 30,000 gallons of PCB oil annually and
foresees handling this quantity for the next 2-3 decades, due to long
transformer life, although the quantities will decrease with tine.
• N.U. sees 3 alternatives to disposal of this oil
- Incinerate in an approved PCB incinerator
- Burnal in a chemical waste landfill
- Burn in a high efficiency boiler
« The disadvantages of each of these methods, as perceived by N.U. are
- PCB incinerator - long distance transportation required; spills
are a possibility; it uses incinerator capacity that is better
used for other toxic substances, including high concentration PCB;
no incinerators are yet approved; given the quantity o£ 50-500 ppm
PCB oils generated throughout the country (18 million gal/yr) some
40-50 incinerators of the size ard type operated by Rollins would
be required.
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- Landfills - long distance transportation required (N.I), currently
transports its PCBs to Alabr-a); energy content of oil is wasted,
potential risk to ground and surface water; good landfills are
hard to come by. Conclusion: this is not a good long terra solution
for a nonblodegradeablo substance
- Boiler - N.U. has elected to use Middletown Station, Boiler fl3
to burn its PCB laden oil. Comparing Unit 03 with the EPA criteria
- Unit 03 is rated at 2000 x 10s Btu/hr (vs 50 x 10s Btu/hr
required minimum)
- No carbon monoxide (CO) has been measured in stack (vs 50 ppm
of CO maximum permitted)
- Oxygen (02) in stack is O.K. (ninimun 32 02 required)
- Fuel feed measured vach 15 tain., PCB oil is not >LO% total oil
feed (meets EPA requirements)
- Boiler operated at full power, never 75% (meets EPA requirements)
• Advantages of N.U. Proposal Include
- A number of automatic, fail-safe stops are incorporated on the
boiler
- Unit 03 is a cycling boiler with the hottest temperatures I>23QO°F)
of any unit in the N.U. system
- Residence Time (Tres) =1.7 seconds
- Plant Elevation ''100 year flood plain
- Unit 03 has high usage factor
- Middletown plant is centrally located in system.
• Sequence of events In a PCB burn
- Oil is transported in a 4000 gal. tanker truck to a dedicated
8,700 gal. storage tank; both have containment systems and spill
control plans
- Oil is pumped to 1 of 5 cyclone burners - all fail-safe systems
will be tested during trial burn
- Flame temperature V3000°F at burner - lX)X of combustion takes placf
in cyclone burner before furnace
- Tres burner "0.2 seconds
Tres furnace = 1.5 seconds
At end of T - 1.7 seconds, Temp = 2000°F (at superheater tubes)
- EPA figures state that for T - 1 second and Temp - 1800"F, PCB
destruction efficiency » 99.9952; with greater time and temp, on
Unit #3, the destruction efficiency should be greater
e To calculate ground level health effects, N.U. ran a dispersion model
with known Unit 03 stack characteristics and assuming:
- 500 ppa PCB oil
- 99.995% PCB destruction efficiency
- Average adult breathing rate = 22.8 liters per day
- Maximum allowable body dose of PCB =0.2 grams (= 2 grams known
health effect T safety factor of 10)
Given these data, N.U. calculated that an individual standing at the
point of maxinura ground level concentration would need 1.5 billion
years to inhale the C.2 gr body dose
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o Dioxins are not Icncwn to be fonned (per TRU Report to EPA)
o Furans can be present as a contaminant in PCB - they should be
quantitatively destroyed and N.U. concluded that they will not
be cultted
Miciutel Cv je.a, Kay< r (Hiddletovn. Connecticut)
Topic: The Responsibilities of Municipalities in Relation to ?CB DtsjiOBal
o In mid-June, 1980, ri.U. presented city with a copy of their proposal
to EPA to dispose of 30,000 gal/yr of 50-500 ppn PCB oil
• Issues raised include - City of Middletoun communication:
- With N.U. - cordial, but less than thorough, e.g., N'.U. stated
there were no landfill sites for this oil, when there are in fact 3
- With Connecticut Department of Environmental Protection (D.E.P.)
- Stanley Pac, D.E.P. Commissioner endorsed proposal without
contacting Town officials. (This lack of contact speaks for
itself.)
- With EPA - good - they delayed approval twice, but were often
reduced to a defenae of their own regulations
- With public - keep them informed
o Existing EPA Regulations are faulty
- They do not address time, temperature, turbulence in boiler
- There are no ambient standards for PCB
- 30 day consideration period is too short
- Public hearing should be held
• At State Level
- Proponent of waste site must demonstrate no adverse health effects
will occur
- D.E.?. permit should be required
- D.E.P. should notify Town
• Towns do not have the technical expertise to review submittale,
especially to evaluate bi-products oC combustion
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