DATE:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V
NOV 2 1984
subject: Region V Guidance Manual For Permitting PCB
Disposal Facilities
from: Basil G. Constantelos, Direc
Waste Management Division
T0; William H. Sanders, Director
Environmental Services Division
Attached is a copy of "Region V Strategy For Permitting PCB Disposal
Sites" which was developed by my staff in the Technical, Permits and
Compliance Section, Waste Management Branch. I am sure the manual
will be very useful for your Division to launch a successful permitting
program for PCB disposal activities in this Region.
The manual was updated for the last time in January, 1983, approximately
two months before publication of the amended PCB rule which transferred
a portion of authority to approve certain PCB disposal facilities, e.g.,
multi-Regional facilities, from the Regional Administrator to the
Assistant Administrator for Pesticides and Toxic Substances (March 30, 1983).
It is my understanding that the above rule change has not at all affected
the usefulness of this manual. A Lexitron diskette which contains the
entire text of the manual is also attached for your use.
All inquiries concerning this manual should be directed to Y. J. Kim of
my staff who was responsible for its preparation.
Attachment

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\REGION V STRATEGY FOR PERMITTING
PCB DISPOSAL SITES
United States Environmental Protection Agency
Prepared By:
State Technical Unit #3
Technical, Permits and Compliance Section
Waste Management Branch
Waste Management Division
REVISED JANUARY 1983

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CONTENTS
Section I (Burning PCB-contaminated mineral oil 	 2
dielectric fluid (MODEF) in high efficiency boilers)
-Section II (Burning PCB-contaminated liquids 	 8
other than MODEF in high efficiency boilers)
Section III (PCB Incinerators which are	 17
able to destroy all types of PCBs and PCB items)
Section IV (Alternate PCB disposal technology and 	 28
Related R&D Activities; specifically, mobile units
utilizing chemical processing techniques)
Section V (Chemical Waste Landfills) 	 33
Appendix I (Participation program procedures) 	 37
Appendix II (Checklists used in evaluating 	 44
approval applications)

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The United States Environmental Protection Agency (U.S. EPA), Region V, Implementa-
tion Strategy for Approving and Permitting the Disposal of Polychlorinated Bi-
phenyls (PCBs) and PCB items.
Pursuant to Section 6(e) of the Toxic Substances Control Act (TSCA) and 40 Code
of Federal Regulations (CFR) Part 761, any person seeking to destroy PCBs or
PCB items must give written notice to the U.S. EPA Regional Administrator (RA) and
obtain the RA's written approval when required. It has been the policy of
Region V not to solicit notices or applications to destroy PCBs or PCB items,
but to accept applications submitted voluntarily and to respond to them within
thirty (30) days from the date they are received.
I. Notification Procedures for Burning PCB-Contaminated MODEF in High Efficiency
Boi1ers
Persons seeking to burn, in a high efficiency boiler, mineral oil dielectric
fluid (MODEF) from PCB-contaminated tranformers containing a PCB concentra-
tion of 50 ppm or greater, but less than 500 ppm, need only give written
notice to the U.S. EPA RA for the Region in which the boiler is located. Writ-
ten approval is not required, but it is the regional policy to issue a con-
sent letter, an example of which appears on page 4. The following informa-
tion must be included in the notice:
i) the name and address of the owner or operator of the boiler and the
address of the boiler;
ii) the boiler rating in units of BTU/hour; (NOTE: The boiler must be
rated at a minimum of 50 million BTU/hour.);
iii) the carbon monoxide concentration and the excess oxygen percentage in
the stack of the boiler when it is operated in a manner similar to the
manner in which it will be operated when MODEF is burned;

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(Note: The flow of MODEF to the boiler must be stopped immediately,
when gas or oil is the primary fuel, if the carbon monoxide concentra-
tion in the stack exceeds 50 ppm or the excess oxygen is less than
three percent; unless coal is the primary fuel, in which case, the flow
must be stopped whenever the carbon monoxide concentration in the
stack exceeds 100 ppm or the excess oxygen is less than three percent.
The carbon monoxide concentration and excess oxygen percentage in the
stack gas must be continuously monitored and recorded while burning
MODEF, unless the boiler will burn less than 30,000 gallons of MODEF
per year, in which case the measurements shall be made and recorded at
regular intervals of no longer than 60 minutes. These records must be
retained at the boiler location for five years); and
iv) the type of equipment, apparatus, and procedures to be used to control
the feeding of MODEF to the boiler and to monitor and record the carbon
monoxide concentration and excess oxygen percentage in the stack.
(Note: The primary fuel feed rates, MODEF feed rates, and total quan-
tities of both primary fuel and MODEF fed to the boiler must be mea-
sured and recorded at regular intervals of no longer than 15 minutes
while burning MODEF. These records must also be retained at the boiler
location for five years as well as records of the quantity of MODEF
burned in the boiler each month.
In addition, MODEF must not comprise more than ten percent on a volume
basis of the total feed rate or heating valve, nor should MODEF be fed
into the boiler unless the boiler is operating at its normal operating
temperature so that MODEF is not fed into the boiler during either
start-up or shut-down operations.)

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EXAMPLE OF CONSENT LETTER
Dear Applicant:
This letter serves to acknowledge the receipt of your notification dated December
16, 1981, to the U.S. Environmental Protection Agency (U.S. EPA) for the disposal of
polychlorinated biphenyl (PCB) contaminated mineral oil dielectric fluid (MODEF)
by burning in boiler No. 12 at the High Bridge Generating Plant which is located
at 501 Shepard Road, St. Paul, Minnesota.
The notification has been reviewed by njy staff and found to be adequate in
addressing the written notice requirement of 40 Code of Federal Regulations (CFR)
760.60(a)(2)(iii)(B) to burn MODEF containing less than 500 ppm of PCBs.
You have our consent to proceed with the burning of the PCB-contaminated MODEF in
the high efficiency boiler referenced above. The burn shall be conducted in
accordance with the attached conditions of consent any time after January 18,
1981. It should be noted, however, that the consent does not relieve you from
complying with other applicable Federal, State and local regulations and
ordinances.
It is the responsibility of you and your company, Northern States Power Company,
to ascertain that all applicable provisions of Sections 6(e)(1) and 6(e)(2) of
the Toxic Substances Control Act (Public Law No. 94-469) and the Final PCB Rule
(40 CFR Part 761) are fully adhered to in conducting the burn.
Pertinent provisions of 40 CFR Part 761 include, but are not limited to the
fol 1 owi ng:

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Subpart A - General;
Subpart B - Manufacturing, Processing, Distribution in Commerce, and
Use of PCBs and PCB Items;
Subpart C - Marking of PCBs and PCB Items;
Subpart D - Storage and Disposal;
Subpart J - Records and Reports.
U.S. EPA reserves the right to inspect records, the high efficiency boiler and
auxiliary equipment used for the disposal of PCB-contaminated MODEF.
Please be advised that a violation of any condition issued as part of this con-
sent will be subject to enforcement action, which may include termination of
this consent. Furthermore, this consent may be withdrawn or additional conditions
may be added at any time if the U.S. EPA has reason to believe that the operation
of your boiler for disposal of PCB-contaminated MODEF presents an unreasonable
risk of injury to public health or the environment.
Si ncerely,
Basil G. Constantelos, Director
Waste Management Division
Attachment

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ATTACHMENT
Conditions of Consent
1.	The concentration of PCBs in MODEF to be burned in boiler No. 12. shall not
exceed 500 ppm.
2.	When coal is the primary fuel, the carbon monoxide concentration in the
boiler outlet shall not exceed 100 ppm and the excess oxygen shall be at
least three (3) percent when PCBs are being burned.
3.	When oil or natural gas is the primary fuel, the carbon monoxide concentra-
tion in the boiler outlet shall not exceed 50 ppm and the excess oxygen shall
be at least three (3) percent when PCBs are being burned.
4.	PCB-contaminated MODEF shall not comprise more than ten (10) percent (on a
volume or heating value basis) of the total fuel feed rate.
5.	The PCB-contaminated MODEF shall not be fed into the boiler unless the boiler
is operating at its normal operating temperature. This authorization condi-
tion prohibits burning of PCB-contaminated MODEF during either start-up or
shut-down operations.
6.	The owner or operator must:
a)	continuously monitor and record the carbon monoxide concentration and
excess oxygen percentage in the stack gas while burning PCB-contaminated
liquid; or
b)	measure and record the carbon monoxide concentration and excess oxygen
percentage in the stack gas at regular intervals of no longer than 60
minutes, if the boiler will burn less than 30,000 gallons of PCB contam-
inated liquid per year.

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7
7.	The primary fuel feed rates, PCB-contaminated MODEF feed rates, and total
quantities of both primary fuel and PCB-contaminated MODEF fed to the boiler
shall be measured and recorded to regular intervals of no longer than 15
minutes while burning PCB-contaminated MODEF.
8.	The quantity of PCB-contaminated MODEF burned in the boiler each month and
the information required to be collected under conditions (6) and (7) shall
be retained at the boiler location for five (5) years.
9.	The carbon monoxide concentration and the excess oxygen percentage shall be
continuously monitored and recorded while burning PCB-contaminated MODEF.
If either measurement falls below the levels specified in condition (2), if
coal is the primary fuel, or condition (3), if oil or natural gas is the
primary fuel, the flow of the PCB-contaminated MODEF to the boiler shall be
stopped immediately.
10.	The flow of PCB-contaminated MODEF to the boiler shall be immediately stopped
if any of the following occurs: boiler or turbine failure; the steam genera-
tion falls below 825,000 pounds per hour; or the PCB-contaminated MODEF flow
exceeds 20 ppm.
11.	All containers, storage tanks, and other articles which have been in direct
contact with PCB-contami nated MODEF shall not be used or reused for any other
purpose, unless they are decontaminated in accordance with 40 CFR 761.79.
The pumps, pipes and other hardware used for handling the PCB-contaminated
MODEF may be decontaminated by rinsing continuously with an amount of clean
No. 2 grade fuel oil that is approximately ten (10) times the total internal
volume of the contaminated components. The contaminated rinsate may be
disposed of by burning in the No. 12 boiler.
12.	When burning PCB-contaminated MODEF, the boiler operation shall be consistent
with the information and data included in the notification.

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11. Approval Procedure Applicable to Burning PCB-Contaminated Liquids, Other
than MODEF, in a High Efficiency Boiler.
A. Persons seeking to burn, in a high efficiency boiler, liquids other than
MODEF, containing a PCB concentration of 50 ppm or greater, but less
than 500 ppm, must submit an approval request to the RA for the U.S. EPA
Region in which the boiler is located. In addition to the information
required in Section I, the following items must be included in the
approval request:
i) the type of waste to be burned, the concentration of PCBs and
of any other chlorinated hydrocarbons in the waste, and the
results of analyses using the American Society of Testing and
Materials (ASTM) methods as referenced below: carbon and
hydrogen content using ASTM D-3178, nitrogen content using
ASTM D-258, sulfur content using ASTM D-2784, D-1266, or
D-129, chlorine content using ASTM D-808, water and sediment
content using either D-2709 or D-1796, ash content using
D-482, calorific value using ASTM D-240, carbon residue using
either ASTM D-2158 or D-524, and flash point using ASTM D-93;
ii) the quantity of wastes estimated to be burned in a thirty (30) day
period;
iii) an explanation of the procedures to be followed to insure that
burning the waste will not adversely affect the operation of the
boiler such that combustion efficiency will decrease.

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B. Following receipt of the approval request, the RA shall determine if a
trial burn is required and notify the person who submitted the approval
request whether a trial burn of PCBs must be conducted. The RA may re-
quire the submission of any other information* that is reasonably
necessary to determine the need for a trial burn. Such other informa-
tion shall be restricted to the type of information required in the
approval request.
If the RA determines that a trial burn must be held, the person who sub-
mitted the approval request shall submit to the RA a detailed plan for
conducting and monitoring a trial burn. At a minimum, the plan must in-
clude the following information:
(i) the time, date, and location of the trial burn;
(ii) quantity and type of PCBs to be burned;
(iii) parameters to be monitored and location of sampling points;
(iv) sampling frequency, methods and schedules for sample analyses;
and
(v) name, address, and qualifications of persons who will review
analytical results and other pertinent data, and who will
perform a technical evaluation of the effectiveness of the
trial burn.
~Note: All pages containing proprietary information may be labeled "CONFIDENTIAL."
Documents marked accordingly must be treated by the U.S. EPA as Confidential
Business Information, unless a determination to deny the claim of confi-
dentiality has been made by the Regional Counsel.

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Following receipt of the trial burn plan, the RA will approve the plan,
require additions or modifications to the plan, or disapprove the plan.
If the plan is disapproved, the RA will notify the person who submitted
the plan of such disapproval, together with the reasons why it is dis-
approved. That person may thereafter submit a new plan. If the plan is
approved (with any additions or modifications which the RA may pre-
scribe), the RA will notify the person who submitted the plan of the
approval. Thereafter, the trial burn shall take place at a date and
time to be agreed upon between the RA and the person(s) who submitted
the plan. If the trial burn is successful, then the permit writer will
draft a memo to the RA from the Director of the Waste Management Division
recommending approval. The memo must contain a complete line-by-line
analysis of how the applicant satisfied the applicable 40 CFR 761
requirements, including any other pertinent data that justifies the
recommendation of approval and/or approval conditions.
C. The RA will grant or deny approval based on a comprehensive review of
the approval request, trial burn results, and other submitted informa-
tion. Prior to making a final decision, the RA will conduct a public
participation program (See Appendix I titled, Public Hearings) regard-
ing the proposed approval.

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If the public participation program is successful and the RA decides
that this disposal method will provide adequate protection to the public
health and the environment, the RA will issue written approval that will
contain all of the requirements necessary to ensure that operation of
the boiler will not present an unreasonable risk of injury to the public
health or the environment from PCBs. Such requirements may include a
fixed period of time for which the approval is valid. The following
letter and attachment serves as an example of the final written approval
of the RA to dispose of PCBs in a high efficiency boiler.

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Example of Approval by RA to Dispose of PCBs in High Efficiency Boiler
Dear Applicant:
Your application to the United States Environmental Protection Agency (U.S. EPA)
for the disposal of liquids contaminated with polychlorinated biphenyls (PCBs)
in your high efficiency boiler has been reviewed for completeness and adequacy
by the staff of the Technical, Permits, and Compliance Section, Waste Management
Branch, Waste Management Division, U.S. EPA, Region V.
Based on this review, a determination has been made to approve, with conditions,
the disposal of PCB-contaminated liquids in your high efficiency boiler. The
approval conditions are enclosed as an attachment to this letter. It should be
noted that this approval applies only to the Federal regulations titled, PCBs
Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions which
were promulgated on May 31 , 1979, under 40 Code of Federal Regulations (CFR)
Part 761, and the applicable sections of the Toxic Substances Control Act (TSCA),
Public Law Number 94-469. This approval does not affect the responsibility of
your company to fully comply with all other applicable, Federal, State or local
regulations or ordinances. The pertinent provisions of 40 CFR Part 761 include,
but are not limited to, the following:
Subpart A - General
Subpart B - Manufacturing, Processing, Distribution in
Commerce, and Use of PCBs and PCB Items
Subpart C - Marking of PCBs and PCB items
Subpart D - Storage and Disposal
Subpart J - Records and Reports

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13
Please be advised that a violation of any condition issued as part of this ap-
proval will be subject to enforcement action, which may include termination of
the approval. Furthermore, this approval may be withdrawn or additional condi-
tions may be added at any time if the U.S. EPA has reason to believe that the
operation of your boiler presents an unreasonable risk of injury to public
health or the environment. This approval shall become effective on	
19	.
If you have any questions, please contact 	
of my staff at 	.
Sincerely yours,
Valdas V. Adamkus
Regional Administrator
Attachment

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Attachment/Conditions
1.	The boiler is rated at a minimum of 50 million BTU hours.
2.	If the boiler uses natural gas or oil as the primary fuel, the carbon monox-
ide concentration in the stack is 50 ppm or less and the excess oxygen is at
least three (3) percent when PCBs are being burned.
3.	If the boiler uses coal as the primary fuel, the carbon monoxide concentra-
tion in the stack is 100 ppm or less and the excess oxygen is at least three
(3) percent when PCBs are being burned.
4.	The PCB-contaminated liquid does not contain a PCB concentration greater than
500 ppm and does not comprise more than ten (10) percent (on a volume or
heating value basis) of the total fuel feed rate.
5.	The PCB-contaminated liquid is fed into the boiler only when the boiler is
operating at its normal operating teirperature (steady-state operating con-
ditions) so that the fluid is not fed during either start-up or shut-down
operations.
6.	The owner or operator of the boiler must:
a)	continuously monitor and record the carbon monoxide concentration and
excess oxygen percentage in the stack gas while burning PCB-contaminated
liquid; or
b)	measure and record the carbon monoxide concentration and excess oxygen
percentage in the stack gas at regular intervals of no longer than 60
minutes, if the boiler will burn less than 30,000 gallons of PCB-contam-
inated liquid per year.

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7.	The primary fuel feed rates, PCB-contaminated liquid feed rates, and total
quantities of both primary fuel and PCB-contaminated liquid fed to the
boiler are measured and recorded at regular intervals of no longer than 15
minutes while burning PCB-contaminated liquid.
8.	The quantity of PCB-contaminated liquid burned in the boiler each month and
the information required to be collected under conditions (6) and (7) be
retained at the boiler location for five (5) years.
9.	The carbon monoxide concentration and the excess oxygen percentage are
checked at least once every hour that PCB-contaminated liquid is burned. If
either measurement falls below the levels specified in condition (2), if
natural gas or oil is the primary fuel, or condition (3), if coal is the
primary fuel, the flow of the PCB-contaminated liquid to the boiler shall be
stopped immediately.
10.	When burning PCB-contaminated liquid, the boiler must operate at a level of
output no less than the output at which the measurements stated in the ap-
plication for the carbon monoxide concentration and excess oxygen percentage
in the stack of the boiler when it was operated in a manner similar to which
it will be operated when PCB-contaminated liquid is burned.
11.	Each owner or operator of a facility used for the storage or disposal (high
efficiency boiler) of PCBs and PCB items shall, by each July 1 prepare and
maintain a document that includes the following information for PCBs and PCB
items that were handled at the facility during the previous calendar year.
i) the date when any PCBs and PCB items were received by the facility for
storage and disposal, and the identification of the facility from whom
the PCBs were received;

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ii) the date when any PCBs and PCB items were disposed at the disposal
facility or transferred to another disposal or storage facility, in-
cluding the identification of the specific types of PCBs and PCB items
that were stored or disposed;
iii) a summary of the total weight in kilograms of PCBs and PCB articles in
containers and the total weight of PCBs contained in PCB transformers,
that have been handled at the facility during the previous calendar
year;* and
iv) the total number of any PCB articles or PCB equipment not in PCB con-
tainers, received during the calendar year, transferred to other
storage or disposal facilities during the calendar year.**
~This summary shall provide totals of the PCBs and PCB items which have been:
a.	received during the year;
b.	transferred to other facilities during the year; and
c.	retained at the facility at the end of the year. In addition, the contents
of PCB containers shall be identified. When PCB containers and PCBs con-
tained in a transformer are transferred to other storage or disposal facil-
ities, the identification of the facility to which such PCBs and PCB items
were transferred shall be included in the document.
**The identification of the specific types of PCB articles and PCB equipment
received, transferred or remaining on the facility shall be indicated. When
PCB articles and PCB equipment are transferred to other storage and disposal
facilities, the identification of the facility to which the PCB articles and
PCB equipment were transferred must be included.

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III. Approval Procedures to Dispose of PCB items and PCBs in an Incinerator which
Complies with the Standards Delineated in 40 CFR 761.70.
A. Persons seeking approval of an incinerator to incinerate PCBs must
submit, to the RA of the Region in which the incinerator is located,
an initial report which contains the following information:
i) the location of the incinerator;
ii) a detailed description of the incinerator including general site
plans and design drawings of the incinerator;
iii) engineering reports or other information on the anticipated per-
formances of the incinerator;
iv) sampling and monitoring equipment and facilities available;
v) waste volumes expected to be incinerated;
vi) any local, State, or Federal permits or approvals; and
vii) schedules and plans for complying with the approval requirements
of 40 CFR Section 761.70.
Following receipt of the initial report, the RA shall determine if a
trial burn is required and notify the person who submitted the report
whether a trial burn of PCBs and PCB items must be conducted. The RA
may require the submission of any other information* that is reasonably
necessary to determine the need for a trial burn. Such other informa-
tion shall be restricted to the type of information required in the
initial report.
~Note: All pages containing proprietary information may be labeled "CONFIDENTIAL."
Documents marked accordingly must be treated by the U.S. EPA as Confidential
Business Information, unless a determination to deny the claim of confi-
dentiality has been made by the Regional Counsel.

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B.	If the RA determines that a trial must be held, the person who submitted
the initial report shall submit to the RA a detailed plan for conducting
and monitoring the trial burn. At a minimum, the plan must include the
following information:
i) the time, date, and location of the trial burn;
ii) quantity and type of PCBs and PCB items to be incinerated;
iii) parameters to be monitored and location of sampling points;
iv) sampling frequency, methods and schedules for sample analyses;
and
v) name, address, and qualifications of persons who will review
analytical results and other pertinent data, and who will perform
a technical evaluation of the effectiveness of the trial burn.
C.	Following receipt of the trial burn plan, the RA will approve the plan,
require additions or modifications to the plan, or disapprove the plan.
If the plan is disapproved, the RA will notify the person who submitted
the plan of such disapproval, together with the reasons why it is dis-
approved. That person may thereafter submit a new plan. If the plan is
approved (with any additions or modifications which the RA may pre-
scribe), the RA will notify the person who submitted the plan of the
approval. Thereafter, the trial burn shall take place at a date and
time to be agreed upon between the RA and the person(s) who submitted
the plan. If the trial burn is successful, the permit writer will
draft a memo to the RA from the Director of the Waste Management Division
recommending approval.

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The memo must contain a complete line-by-line analysis of how the
applicant satisfies the applicable 40 CFR Part 761 requirements, includ-
ing any other pertinent data that justifies the recommendation of ap-
proval and/or approval conditions.
D. The RA will grant or deny the approval based on a comprehensive review of
the approval request, trial burn results, and other submitted informa-
tion. Prior to making a final decision, the RA will conduct a public
participation program (See Appendix I titled, Public Hearings) regarding
the proposed approval.
If the public participation program is successful and the RA decides
that this disposal method will provide adequate protection to the public
health and the environment, the RA will issue written approval which
will contain all of the requirements necessary to ensure that operation
of the incinerator wi11 not present an unreasonable risk of injury to
the public health or the environment. Such requirements may include a
fixed period of time for which the application is valid.
The following letter and attachment serve as an example of the final
written approval of the RA to dispose of PCBs and PCB items in an
incinerator. The conditions listed in the attachment are the minimum
that an incinerator must satisfy if it is to be successful in obtaining
the RA's approval.

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Example of Approval by RA to Dispose of PCBs in an Incinerator
Dear Applicant:
Your application to the United States Environmental Protection Agency (U.S. EPA)
for approval to dispose of polychlorinated biphenyls (PCBs) in your incinerator
has been reviewed for completeness and adequacy by the staff of the Technical,
Permits, and Compliance Section, Waste Management Branch, Waste Management Divi-
sion, U.S. EPA, Region V.
Based on this review, a determination has been made to approve, with conditions,
the disposal of PCBs in your incinerator. The approval conditions are en-
closed as an attachment to this letter. It should be noted that this approval
applies only to the Federal regulations titled, PCBs Manufacturing, Processing,
Distribution in Commerce, and Use Prohibitions which were promulgated in the
Federal Register on May 31, 1979, 40 Code of Federal Regulations (CFR) Part 761,
and the applicable sections of the Toxic Substances Control Act (TSCA), Public
Law Number 94-469. This approval does not affect the reponsibility of your com-
pany to fully comply with all of the other requirements of the TSCA, the Re-
source Conservation and Recovery Act (RCRA), or any other applicable Federal,
State or local regulations or ordinances.
The pertinent provisions of 40 CFR Part 761 include, but are not limited to the
followi ng:
Subpart A - General
Subpart B - Manufacturing, Processing, Distribution in Commerce,
and Use of PCBs and PCB items
Subpart C - Marking of PCBs and PCB items
Subpart D - Storage and Disposal
Subpart J - Records and Reports

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21
Please be advised that a violation of any condition issued as part of this ap-
proval may be subject to enforcement action, which may include termination of
this approval. Furthermore, this approval may be withdrawn or additional con-
ditions may be added at any time if the U.S. EPA has reason to believe that the
operation of the incinerator presents an unreasonable risk of injury to public
health or the environment. This approval shall become effective on 	
19	.
If you have any questions, please contact 	
of my staff at 	.
Sincerely yours,
Valdas V. Adamkus
Regional Administrator
Attachment

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22
Attachment/Conditions
The owner or operator of a PCB incinerator is subject to the following con-
ditions unless after examining the evidence and other submitted information, the
Regional Administrator waives any of the following conditions in writing because
the condition(s) are not necessary to protect against an unreasonable risk of
injury to health or the environment.
A. An incinerator used for incinerating liquid PCBs shall meet the following
conditions:
1.	Combustion criteria shall be either of the following:
i) maintenance of the introduced liquids for a two (2) second dwell
time at 1200°C (+ 100°C) and three (3) percent excess oxygen in
the stack gas; or
ii) maintenance of the introduced liquids at a one and one half (1.5)
second dwell time at 1600°C (_+ 100°C) and two (2) percent excess
oxygen in the stack gas.
2.	Combustion efficiency shall be at least 99.9 percent computed as follows:
Percent combustion efficiency = 100 x CCO2D/([C023 + [CO])
where = [CO2] = Concentration of carbon dioxide
[CO] = Concentration of carbon monoxide
3.	The rate and quantity of PCBs which are fed into the combustion system
shall be measured and recorded at regular intervals of no longer than
fifteen (15) minutes.
4.	The temperature of the incinerator process shall be continuously measured
and recorded. The combustion temperature of the incineration process
shall be based on either direct (pyrometer) or indirect (wall thermo-
couple-pyrometer correlation) temperature readings.

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5.	The flow of PCBs to the incinerator shall stop automatically whenever the
combustion temperature drops below the temperature specified in condition
A (1) -
6.	Monitoring of stack emission products shall be conducted when an inciner-
ator is first used for the disposal of PCBs under the provisions of this
regulation; or after the incinerator has been modified in any manner which
may affect the characteristics of the stack emission products.
7.	At a minimum the monitoring described in (6) shall be conducted for the
following parameters:
i) oxygen (02);
ii)	carbon monoxide (CO);
iii) carbon dioxide (CO2);
iv)	oxides of nitrogen (N0X);
v)	hydrochloric acid (HC1);
vi)	total chlorinated organic content (RC1);
vii)	PCBs; and
viii) total particulate matter.
8.	At a minimum monitoring and recording of combustion products and incin-
eration operations shall be conducted for the following parameters when-
ever the incinerator is incinerating PCBs:
i) oxygen (O2)
ii) carbon monoxide (CO); and
iii)	carbon dioxide (CO2).
The monitoring for oxygen and carbon monoxide shall be continuous. The
monitoring of carbon dioxide shall be periodic, at a frequency speci-
fied by the Regional Administrator.

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9. The flow of PCBs to the incinerator shall stop automatically when any
one or more of the following conditions occur, unless a contingency plan
is submitted by the incinerator owner or operator and approved by the
Regional Administrator, and the contingency plan indicates what alterna-
tive measures the incinerator owner or operator will take if any of the
following conditions occur:
i) failure of the monitoring operations specified in condition A(8);
ii) failure of the PCB rate and quantity measuring and recording equip-
ment specified in condition A(3); or
iii) excess oxygen falls below the percentage specified in condition
A(l).
10. Water scrubbers shall be used for HC1 control during PCB incineration
and shall meet any of the performance requirements specified by the
Region V Administrator. Scrubber effluent shall be monitored and shall
comply with applicable effluent or pretreatment standards and any other
State and Federal laws and regulations. An alternative method of HC1
control may be used if the alternate method has been approved by the
Regional Administrator.
B. An incinerator used for incinerating nonliquid PCB, PCB articles, PCB equip-
ment, or PCB containers shall meet the following conditions:
1.	mass air emissions from the incinerator shall be no greater than 0.001
gram PCB/kilogram of the PCB into the incinerator;
2.	condition A(2);

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25
3.
condition A(3);
4.
condition A(4);
5.
condition A(6);
6.
condition A(7);
7.
condition A(8);
8.
condition A(9);
9.
condition A(10).
C. Each owner or operator of a PCB incinerator shall collect and maintain for a
period of five (5) years from the date of collection the following informa-
tion:
1.	continuous and short interval data as described below:
i) rate and quantity of PCBs fed to the combustion system as required
by conditions A(3) and/or B(3);
ii) temperature of the combustion process as required by conditions
A(4) and/or B(4);
iii) stack emissions including oxygen, carbon monoxide, and carbon
dioxide as required by conditions A(8) and/or B(7);
2.	data and records on the monitoring of stack emissions as required by
conditions A(6), A(7), and/or B(5) when PCBs are being incinerated; and
3.	the total weight in kilograms of any solid residues generated by the in-
cineration of PCBs and PCB items during the calendar year, the total
weight in kilograms of any solid residues disposed by the facility in
chemical waste landfills, and the total weight in kilograms of ar\y solid
residues remaining on the facility site.

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26
4.	Upon any suspension of the operation of the incinerator pursuant to con-
ditions A(9), and/or B(8), the owner or operator shall prepare a
document which shall include, at a minimum, the date and time of the
suspension and explanation of the circumstances causing the suspension of
operation. The document shall be sent to the Region V Regional Adminis-
trator within thirty (30) days of any such suspension.
5.	Each owner or operator of a facility used for the storage or disposal
(incineration) of PCBs and PCB items shall by July 1 of each year,
prepare and maintain a document that includes the following information
for PCBs and PCB items that were handled at the facility during the
previous calendar year:
i) the date when any PCBs and PCB items were received by the facility
for storage or disposal (incineration), and the identification of
the facility from whom the PCBs were received;
ii) the date when any PCBs and PCB items were disposed (incinerated) at
the disposal facility (incinerator) or transferred to another dis-
posal or storage facility, including the identification of the
specific types of PCBs and PCB items that were stored or disposed;
iii) a summary of the total weight in kilograms	of PCBs and PCB articles
in containers and the total weight of PCBs	contained in PCB trans-
formers, that have been handled at the facility during the previous
calendar year. This summary shall provide	totals of the PCBs and
PCB items which have been:
a.	received during the year;
b.	transferred to other facilities during	the year; and

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27
c. retained at the facility at the end of the year.
(In addition, the contents of PCB containers shall be identi-
fied. When PCB containers and PCBs contained in a transformer
are transferred to other storage or disposal facilities,
the identification of the facility to which such PCBs and
PCB items were transferred shall be included in the document.)
iv) the total number of any PCB articles or PCB equipment not in PCB
containers, received during the calendar year, transferred to
other storage or disposal facilities during the calendar year,
or remaining on the facility site at the end of the calendar
year. (The identification of the specific types of PCB articles
and PCB equipment received, transferred, or remaining on the
facility shall be indicated. When PCB articles and PCB equipment
are transferred to other storage or disposal facilities, the
identification of the facility to which the PCB articles and
PCB equipment were transferred must be included.)

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28
IV. Approval Procedure for Alternate Methods of Destroying Polychlorinated
Biphenyls (PCBs).
Pursuant to 40 Code of Federal Regulations (CFR) Paragraph 761.60(e),. any
person who is required to incinerate any PCBs and PCB items under 40 CFR 761
Subpart D and who can demonstrate that an alternative method of destroying
PCBs and PCB items exists and that this alternative method can achieve a
level of performance equivalent to PCB incinerator or high efficiency
boiler as provided in 40 CFR Paragraphs 761.60(a)(2)(iv) and 761.60(a)(3)
(iv), may submit a written request to the Regional Administrator (RA) for an
exemption from the incineration requirements. The applicant must show that
his method of destroying PCBs will not present an unreasonable risk of
injury to health or the environment. On the basis of such information and
any available information, the RA may, in his discretion, approve the use
of the alternate method, if he finds that the alternate disposal method
provides PCB destruction equivalent to disposal to a PCB incinerator or
high efficiency boiler and will not present an unreasonable risk of
injury to health or the environment. Any approval must be stated in writing
and may contain such conditions and provisions as the RA deems appropriate.
The person to whom such a waiver is issued must comply with all limitations
contained in such determination.
Persons seeking to conduct research and development into alternative methods
of destroying PCBs, on bench or pilot plant scale, must obtain a written
temporary authorization from the U.S. EPA Region in which the testing will take
place.

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29
The duration of this temporary authorization should not exceed six (6)
months. Persons seeking such temporary authorization must provide the
Regional Office with information on their system design, the location of
of facility, amount, concentration, and type of PCBs to be destroyed, the
maximum human exposure which would result if the test were a complete failure
under the worst case conditions, the precautions taken to minimize human
exposure to PCBs, and the testing methodologies to be employed.
The information required will eniable U.S. EPA to evalute the proposed test
conditions to ensure that the test will be conducted in a safe manner.
Furthermore, the submission of information at this time, concerning the
disposal method under development, will facilitate a more expeditious U.S.
EPA action on any subsequent application for approval of a full scale unit.
The Regional Office will grant permission for conducting the testing pro-
vided that the tests will produce data by which the applicant can attempt
to show that his method of destroying PCBs will not present an unreasonable
risk of injury to health or the environment and that the tests themselves
will not present unreasonable risks.
The authorization will be contained in the letter sent acknowledging receipt
of the information. Persons to whom the approval is issued must submit a
summary of the test results within ninety (90) days of completing the tests.
At a minimum, this report should summarize the testing results, quantities
of PCBs used, disposal of residues and leftover PCBs, and procedures used
to decontaminate the testing equipment.

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30
Application Process Applicable to Chemical Processing Mobile Units.
A.	The owner or operator shall submit to the Regional Administrator (RA) an
initial report which contains the following:
(i) the location of the center of organization from which the mobile
unit originates and the location where the mobile unit would be
stored and serviced when not engaged in commercial activity;
(ii) a detailed description of the mobile unit including general plans and
design drawings;
(iii) engineering report or other information on the anticipated performance
of the mobile unit;
(iv) sampling and monitoring equipment and facilities available;
(v) waste volumes expected to be handled, process design capacity, process
control, reagent-to-waste feed ratios, and safety features;
(vi) any local, State or Federal permits or approvals;
(vii) schedules and plans for complying with the approval requirements;
(viii) a contingency plan which describes steps taken in case of process
failure, spill or overflow;
(ix) environmental impact, including process emissions, toxicity and dis-
posal of process products, and steps taken to protect the health of
operators; and
(x) name, address and phone number of the mobile unit contact.
B.	Following receipt of the initial report, the RA shall determine if a process
demonstration is required and notify the person who submitted the report
whether a demonstration of the chemical destruction process for detoxifying
PCBs and PCB items must be conducted.

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31
The RA may require the submission of any other information that the RA finds
to be reasonably necessary to determine the need for a process deaonstration.
Such other information shall be restricted to the types of information re-
quired in the initial report.*
If the RA determines that a process demonstration must be held, the person who
submitted the initial report shall submit to the RA a detailed plan for con-
ducting and monitoring. The process demonstration plan must include the
following information:
(i) time, date, and location of the process demonstration;
(ii) quantity and type of PCBs and PCB items to be processed;
(iii) parameters to be monitored and location of sampling points;
(iv) sampling frequency and methods and schedules for sample analysis; and
(v) name, address and qualifications of persons who will review analytical
results and other pertinent data, and who will perform a technical
evaluation of the effectiveness of the process demonstration.
C. Following receipt of the process demonstration plan, the RA will approve the
plan, require additions or modifications to the plan, or disapprove the plan.
If the plan is disapproved, the RA will notify the person who submitted the
plan of such disapproval, together with the reasons why it is disapproved.
*Note: All pages containing proprietary information may be labeled "CONFIDENTIAL."
Documents marked accordingly must be treated bv the U.S. EPA as Confidential
Business Information, unless a determination to deny the claim of confi-
dentiality has been made by the Regional Counsel.

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32
That person may, thereafter, submit a new plan in accordance with Part B of
this Section. If the new plan is approved (with any additions or modifica-
tions which the RA may prescribe), the RA will notify the person, who sub-
mitted the plan, of the approval.
Thereafter, the process demonstration shall take place at a date, time,
and location to be agreed upon between the RA and the person(s) who submitted
the plan. If the process demonstration is successful, the permit writer
will draft a memo to the RA from the Director of the Waste Management Division
recommending approval. The letter must contain a complete line-by-line
analysis of how the applicant satisfies the applicable 40 CFR Part 761 re-
quirements, including any other pertinent data that justifies the recommem-
dation of approval and/or approval conditions.
At least thirty (30) days prior to conducting the process demonstration, the
owner or operator of the mobile unit shall give written notice of the demon-
stration to the State and local governments within whose jurisdiction the
demonstration is to take place.
D.	The RA will grant or deny approval based on a comprehensive review of the ap-
plication package, demonstration results, and other submitted information.
E.	Thermal-destruction processes which are equivalent to the PCB incinerator
or high efficiency boiler will also be reviewed under alternative technolo-
gies.

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33
V. Chemical Waste Landfills
All liquid wastes with less than 500 ppm PCBs and nonliquid PCBs at any con-
centration may be disposed in chemical waste landfills that comply with
the requirements of 40 CFR Paragraph 761.75.
Prior to the disposal of any PCBs and PCB items in a chemical waste landfill,
the owner or operator of the landfill shall receive written approval of the
U.S. EPA Regional Administrator (RA) for the Region in which the landfill is
located. The approval shall be obtained in the following manner:
A. The owner or operator shall submit to the RA an initial report which con-
tains the following information:
(i) the location of the landfill;
(ii) a detailed description of the landfill includinq general site
plans and design drawings;
(iii) an engineering report describing the manner in which the landfill
complies with the requirements for chemical waste landfills speci-
fied in 40 CFR Paragraph 761.75(b).
(iv) sampling and monitoring equipment and facilities available;
(v) expected waste volumes of PCBs;
(vi) general description waste materials other than PCBs that are
expected to be disposed in the landfill;
(vii] landfill operations plan as required in 40 CFR Paragraph 761.75(b);
(viii) any local, State or Federal permits or approvals;
(ix) any schedules or plans for complying with the approval requirements
of 40 CFR 761 ; and

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34
(x) any other information that the RA finds to be reasonably
necessary to determine whether a chemical waste landfill should
be approved.
B.	The RA may not approve a chemical waste landfill for the disposal of PCBs
and PCB items, unless he finds that the landfill meets all of the require-
ments of 40 CFR Paragraph 761.75(b) except those waived in writing by the
RA. An owner or operator of a chemical waste landfill may submit evi-
*
dence to the RA that operation of the landfill will not present an unrea-
sonable risk of injury to public health or the environment from PCBs when
one or more of the requirements of Paragraph 761 .75(b) are not met. On
the basis of such evidence and any other available information, the RA
may in his discretion find that one or more of the requirements of Para-
graph 761.75(b) is not necessary to protect against such a risk and may
waive the requirements in any approval for that landfill. Any finding
and waiver must be stated in writing and included as part of the
approval.
C.	Prior to issuing final approval, the RA will conduct a public participa-
tion program (See Appendix I titled, Public Hearings) regarding the pro-
posed approval. If the public participation program is successful and
the RA decides that this disposal method will provide adequate protection
to the public health and the environment, the RA will issue written ap-
proval which will contain all of the requirements necessary to ensure
that operation of the landfill will not present an unreasonable risk of
injury to health or the environment from PCBs.

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35
Such provisions may include a fixed period of time for which the approval
is valid, a stipulation that the operator of the landfill report to the
RA any instance when PCBs are detected during monitoring activities, and
any waiver of the Paragraph 761.75(b) requirements.

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36
Introduction to Appendix I
Interim final and final regulations promulgated pursuant to the Resource Con-
servation and Recovery Act (RCRA) indicate that the PCB regulations will be
incorporated into the Phase II RCRA regulations, (it is not known how the in-
corporation will be accomplished or what changes in the PCB regulations will be
made. It seems likely that when the incorporation is made, most RCRA regulations
will apply to PCB disposal operations, particularly those portions that establish
standards for treatment, storage, and disposal facilities and permits for these
facilities (40 CFR Parts 264 and 265). Thus, after incorporation, a PCB disposal
facility may have to be evaluated for compliance with RCRA requirements for waste
receiving and storage areas, chemical analysis capability, inspection schedules,
security, preparedness for and prevention of hazards, contingency plans, emergen-
cy procedures, manifest systems, and recordkeeping procedures.
The PCB regulations do not explicitly discuss public notification or participa-
tion in the approval process; however, 40 CFR Part 124 of the RCRA does include
this discussion; hence, when the incorporation occurs, PCB facilities will
probably be subject to the RCRA requirements. The Region V policy has been to
provide for public participation activities so that the public may contribute in
the decision-making process of approving facilities for disposal of PCBs and PCB
items. Appendix I, which follows, delineates Region V policies with respect to
public participation. These policies are similar to those for RCRA and disposal
facilities so that when incorporation occurs, minimum disruption should result.

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37
Appendix I
Public Hearings
The Director may hold a public hearing whenever he or she finds, on the basis
of request(s), that there is public interest in the action. The Director may
also hold a public hearing at his or her discretion, whenever, for instance,
such a hearing might clarify one or more issues involved in the (permit) deci-
sion.
The public notice for a hearing will contain at a minimum the date, time, and
location of the public hearing, the purpose of the public hearing, the location
of documents germane to the public hearing, and the name and address of a U.S.
EPA contact person for additional information. In addition, the notice will
state that anyone wishing to give testimony at the hearing should submit his
testimony in writing to the following:
Karl J. Klepitsch, Jr., Chief
Waste Manageaent Branch
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois 60604
Whenever a public hearing is held, the Regional Administrator (RA) will designate
a Presiding Officer for this hearing who shall be responsible for its scheduling
and orderly conduct. The Director of Waste Management Division will make
recommendations to the RA to schedule a hearing. The public notice must be
released at least 45 dcys prior to the date of the hearing. However, where
U.S. EPA determines that there are no substantial documents which must be reviewed
for effective participation and that there are no complex or controversial matters
to be addressed by the hearing, the notice requirements may be reduced to no
less than 30 days.

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38
U.S. EPA may further reduce or waive the hearing notice requirements in an emergency
where U.S. EPA determines that there is an imminent danger to public health.
Hearings will be held at times and places which are convenient for the public to
the maximum extent feasible. Use of evening and weekend hearings and availabil-
ity of public transportation are considered. Suggestions for public hearing
locations include college or university lecture halls or auditoriums, high school
auditoriums, and village hall conference rooms. The meeting room should seat
approximately 150 persons. Signs will be appropriately posted to identify the
location of the public meeting. The following items will be made available by
the facility or by U.S. EPA: placards, head table, registration table, podium,
microphone(s), extension cords, movie screen, projector, overhead projector,
tape recorder, sign-in sheet for hearing attendees, and copies of available
information. A list will be made of those persons who have expressed an interest
in presenting testimony at the hearing and/or who wish to receive a copy of the
transcript of the hearing. An acknowledgement will be sent to these people
expressing their intent to present testimony and notifying them of the time
allowed for their presentation. Some time will be reserved for unscheduled testi-
mony. Presentations will be given in the order in which the comments/requests
to testify were received. In order to schedule a court reporter for a public
hearing, a Court Reporter Services form should be completed and delivered to the
General Services Branch of Planning and Management Division. Upon receipt,
transcripts will be distributed by State Programs and Information Section (SPIS)
to those parties which requested them.

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39
The public has 30 days to comment on proposals referenced in the Public Notice.
Comments will be sent to a U.S. EPA contact person as indicated i.n the Public
Notice. Comments will, be received by Chief, SPIS, and will be subsequently
forwarded to Public Notice Specialist. Incoming comments will be logged in;
copies will be made of the incoming correspondence, and an acknowledgement of
receipt will be sent to the commentors.
Copies of the correspondence will be forwarded to Chief, Technical, Permits, and
Compliance Section (TPCS), who will assign personnel to respond to specific
inquiries as necessary. Copies of the response should be sent to SPIS who will
attach responses to the original letters in files.
At the close of the 30-day comment period, SPIS will prepare a Responsiveness
Summary. A Responsiveness Summary will include the following information:
A.	all relative/significant issues (pro and con) raised by the commentors;
and
B.	a detailing of the Agency's response to various appropriate Public com-
ments, an explanation of whether changes or modifications were made,
and the reason for the Agency's subsequent action.
The Responsiveness Summary should be sent to the following:
A.	applicant;
B.	Regional Administrator;
C.	Division Director;
D.	Branch Chief;
E.	SPIS & TPCS Chiefs;

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40
F.	authors of replies to comments;
G.	commentors;
H.	public upon request; and
I.	official file.
The public notice will be written by a designated person in the State Programs
and Information Section based on information provided by a designated person
from the Technical, Permits, and Compliance Section. At a minimum, the public
notice will contain the following information:
1.	name and address of the office processing the action for which the
notice is being given;
2.	name and address of the applicant;
3.	a brief description of the activity (TSCA approval) which pre-
cipitated the requirement for the public notice;
4.	a brief summary of the basis for approval/denial including references
to applicable statutory or regulatory provisions and appropriate sup-
porting references;
5.	name, address, telephone number of a contact from whom interested per-
sons may obtain further information;
6.	the beginning and ending date of the 30-day comment period;
7.	procedures for commenting or requesting a public hearing;
8.	the date, time, and place of the hearing, if scheduled;

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41
9. the location of the administrative record the times at which the record
will be open for public inspection, and a statement that all data sub-
mitted by the applicant is available as part of the administrative
record; and
10. the date of the public notice to approximate the date of the actual
publication.
A public notice is more than a mechanism to meet certain legal requirements.
It is a mechanism to involve the public in the decision-making process. There-
fore, the public notice must emphasize the reasons the public meeting, or a
hearing is taking place. Such as the economic and environmental issues and deci-
sions of concern to the public. The notice must indicate how participation at
the meeting or hearing will relate to subsequent decisions and the resolution of
i ssues.
Public notices should be sent to the following:
1.	applicant;
2.	any Federal Agency having related interest;
3.	State Pollution Control Agencies;
4.	U.S. EPA Headquarters;
5.	U.S. Congressmen;
6.	selected State Legislators;
7.	persons on a mailing list developed by:
a.	adding the names of persons requesting to be placed on a mailing list;
b.	soliciting persons for "area lists" from participants in past pro-
ceedings in that area; and

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42
c. notifying the public of the opportunity to be put on the mailing
list through periodic publication in the public press and in such
publications as Regional-and State-funded newsletters, environmental
bulletins, or State law journals;
8.	selected environmental organizations; and
9.	Region V Library.
The agencies, organizations or individuals should receive a cover letter written
by a designated person in the SPIS and signed by the Regional Administrator. The
cover letter should include:
1.	notice that the attached is an advance copy of the public notice;
2.	the date the notice is scheduled to appear in the local newspaper;
3.	a brief synopsis of the reason for the public notice; and
4.	the U.S. EPA contact person.
Any technical documents, references or other materials that have been designated
to accompaqy the public notice and cover letter shall be provided to SPIS from
TPCS.

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43
Cost estimates for publishing a public notice in newspapers may be based on the
number of lines appearing on 8 1/2-by-ll inch paper. This estimate can be ob-
tained from the newspaper's legal notice department and should be annotated in
the "account classification" which appears at the bottom of the public voucher
for advertising. The specifications for advertisement shall specify the public
notice that will appear in the legal notice section of the paper. The SPIS
person completing the notice will request the newspaper to confirm the date of
publication, number and specify that the billing be made to the U.S. Enironmen-
tal Protection Agency, Regional Office in Chicago. The original Public Voucher
for advertising shall be retained in SPIS. Three additional copies as well as
three copies of the public notice for each newspaper will be sent to Financial
Management, 14th Floor, 230 South Dearborn. The voucher will be forwarded to
General Services which will send the voucher to the newspaper. Ten days are
allowed for processing once the materials have been submitted to Financial
Management.
The public notices and other documents may be copied in the duplicating room on
the 14th Floor at 230 South Dearborn. Written or verbal approval must be given
by Paul Lee (353-2025). When mailing advance copies of the public notice, the
EPA frank will be copied on the back side of the last sheet of paper to eliminate
the need for envelopes. The return address should be designated as follows:
U.S. Environmental Protection Agency
Waste Management Branch
230 South Dearborn Street
Chicago, Illinois 60604

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44
Appendix II - Checklists for Evaluating PCB Disposal Approval Requests.
The following checklists are used as aids in reviewing approval requests for dis-
posing of PCBs and PCB items. Figure 1 illustrates the disposal requirements for
PCBs and PCB items. Prior to using the checklist, the applicant's waste charact-
eristics are checked with the disposal requirements listed in Figure 1, to verify
that the applicant is requesting approval for the correct type of disposal method.
CONTENTS
Storage at a Disposal Facility 	 46
Burning PCB-Contaminated MODEF in a High 	 52
Efficiency Boiler
Burning PCB-Contaminated Liquids Other Than MODEF, 	 55
in a High Efficiency Boiler
PCB Incinerators 	 60
Chemical Waste Landfills 	 68

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Page 45
Missing from Original

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46
Appendix II - Checklist for Storage at a Disposal Facility
1.	Are the roof and walls adequate to
prevent rain water from reaching
the stored PCBs and PCB items?
2.	Does the floor have continuous
curbing which is a minimun of six
Inches high?
3.	Are the floor and curbing con-
structed of continuous smooth and
impervious materials, such as
Portland cement concrete or steel,
to prevent or minimize penetration
of PCBs?
4.	Are any of the following openings
present, which would permit liquids
to flow from the curbed areas:
a.	drain valves;
b.	floor drains;
c.	expansion joints;
d.	sewer lines; or
e.	other openings (describe)?
YES
ii n
NO REMARKS
YES NO REMARKS
n n 	_
YES NO REMARKS
n n
YES	NO	REMARKS
II	n		
n	n		
n	n		
n	n		
n n		

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47
5.	List the following volumes:
a.	two times the internal volume of
the largest PCB article or PCB con-
tainer stored therein;		
b.	25 percent of the total internal
volume of all PCB articles or PCB
containers stored therein; and		
c.	the containment volume that the
floor and curbing provide.		
YES NO REMARKS
6.	Is the containment volume adequate?	n n 	
(Note: If the volume listed in 5(c)		
is equal to or greater than the		
larger of 5(a) or 5(b), then the con-		
tairment volume is adequate.)		
YES NO REMARKS
7.	Is the storage area located at a site	II EE 	
that is below the 100-year flood water		
elevation?		
YES NO REMARKS
8.	Are spill clean-up equipment and sup-	H II 	
plies provided such as the following		
items: sorbents, portable pumps, and		
empty containers?		

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48
9. Does the storage area contain the
following:
a.	Gloves, respirators, goggles,
etc.
b.„	H - C detectors or sniffers, or
c.	Fence and warning signs?
10.	Is the Spill Prevention, Control, and
Countermeasure Plan adequate?
11.	Does the operator check all PCB
articles and PCB containers for leaks
at least once every 30 days?
12.	Are records available for the storage
containers subject to the 29 CFR
1910.106 OSHA Standards (surface tanks
larger than 660 gallons and under-
ground tanks larger than 42,000 gallons),
that include the following information:
YES NO REMARKS
n n 	
n n
u n
YES NO REMARKS
II EE 	
YES NO REMARKS
n H 	
YES NO REMARKS
a.	PCB batch,	n	n
b.	quantity,	n	n
c.	date batch was added to container,	and n	n
d.	date, quantity, and disposition of	I 1	1 1
PCBs removed?

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49
13. Do all containers used for the storage
of liquid PCBs comply with the Shipping
Container Specifications of the Depart-
ment of Transportation (DOT) 49 CFR 178
or the OSHA Standards 29 CFR 1910.106,
whichever applies?
14.	Were the PCB articles and the PCB con-
tainers dated when th^y were placed in
storage?
15.	Can the PCB articles and the PCB con-
tainers be located by the date they
entered storage?
16.	Are the following items established and
maintained in the records of the storage
facility:
A. the date when any PCBs and PCB items were
received by the facility for storage or
disposal and the identification of the
facility from whom the PCBs were received;
and
YES NO
EE H
REMARKS
YES NO
n n
REMARKS
YES NO
n n
REMARKS
YES NO
n n
REMARKS

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50
YES NO REMARKS
B.	the date when any PCBs and PCB items	n n 	
were disposed at the disposal facility or		
transferred to another disposal or		
storage facility, including the identifi-		
cation of the specific types of PCBs and		
PCB items that were stored or disposed?		
C.	A summary of the total weight 1n kilogram
of PCBs and PCB articles in containers and
the total weight of PCBs contained in PCB
transformers, that have been handled at
the facility during the previous calendar
year. This sunmary shall provide totals of
the PCBs and PCB items which have been:
YES NO REMARKS
i. received during the year;	n n 	
ii. transferred to other facilities
during the year; and
YES NO REMARKS
n n 	

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51
YES NO REMARKS
iii. retained at the facility at the end [ | | | 	
of the year. In addition, the con-
tents of PCB containers shall be
identified. When PCB containers and
PCBs contained in a transformer are
transferred to other storage or dis-
posal facilities, the Identification
of the facility to which such PCBs
and PCB items were transferred shall
be included in the document.
YES NO REMARKS
D. The total number any PCB articles or	1 1 1 1 	
PCB equipment not in PCB containers,
received during the calendar year,
transferred to other storage or disposal
facilities during the calendar year, or
remaining on the facility site at the
end of the calendar year. The identifi-
cation of the specific types of PCB
articles and PCB equipment received,
transferred, or remaining on the facil-
ity shall be indicated. When PCB
articles and PCB equipment are trans-
ferred to other storage or disposal
facilities, the identification of the
facility to which the PCB articles and
PCB equipment were transferred must be
included.

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52
Checklist for Burning PCB-Contaminated (less than 500 ppm PCBs) Mineral 011
Dielectric Fluid (MODEF) in a High Efficiency Boiler.
1.	Is the boiler rated at a minimum of 50
million BTU/hours?
2.	If the boiler uses natural gas or oil as
the primary fuel, is the carbon monoxide
concentration in the stack 50 ppm or less
and is the excess oxygen in the stack at
least three percent when PCBs are being
burned?
3.	If the boiler uses coal as the primary
fuel, is the carbon monoxide concentra-
tion in the stack 100 ppm or less and is
the excess oxygen at least three percent
when PCBs are being burned?
4.	Does the mineral oil dielectric fluid com-
prise less than ten percent (on a volume
or heating value basis) of the total
fuel feed rate?
5.	Is the mineral oil dielectric fluid (MODEF)
fed into the boiler only when the boiler
is operating at its normal operating
temperature?
YES
n
YES
n
NO REMARKS
n 	
NO REMARKS
H 	-
YES
n
NO REMARKS
n 	
YES
n
NO REMARKS
n 	
YES
n
NO REMARKS
H 	

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53
6. Does the owner or operator of the boiler:
A.	continuously monitor and record the
carbon monoxide concentration and excess
oxygen percentage in the stack gas while
burning MODEF; or
B.	if the boiler will burn less than
30,000 gallons of MODEF per year, measure
and record the carbon monoxide concentra-
tion and excess oxygen percentage in the
stack gas at regular intervals of no
longer than 60 minutes while burning
MODEF?
YES NO
rr n
REMARKS
YES NO
n H
REMARKS
YES NO REMARKS
7. Are the primary fuel feed rates, MODEF fluid n n 	
feed rates, and total quantities of both
primary fuel and MODEF fed to the boiler
measured and recorded at regular intervals
of no longer than 15 minutes while burning
MODEF?
8. Are the carbon monoxide concentration and
the excess oxygen percentage checked at
least once every hour that MODEF is burned
and if either measurement falls below the
specified levels, is the MODEF flow to the
boiler immediately stopped?
YES NO
n n
REMARKS

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54
9. Has the person who gave written notice,
regarding the burning of MODEF 1n a high
efficiency boiler, made arrangements to
obtain the following information and to
retain it at the boiler location for at
least five years:
A.	the data required to be collected
under 6(A) or 6(B) and 7; and
B.	the quantity of MODEF burned in the
boiler each month?
YES NO REMARKS
n H 	
YES NO REMARKS
n H 	

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55
Checklist for Burning PCB-Contaminated (Less than 500 ppm) Liquids Other Than
MODEF. in a High Efficiency Boiler
YES
II
YES
n
1.	Is the boiler rated at a minimum of 50
million BTU/hour?
2.	If the boiler uses natural gas or oil as
the primary fuel, is the carbon monoxide
concentration in the stack 50 ppm or less
and is the excess oxygen in the stack at
least three percent when the waste fluid
is being burned?
YES
3.	If the boiler uses coal as the primary fuel, 1 I
is the carbon monoxide concentration in the
stack 100 ppm or less and is the excess
oxygen at least three percent when the
waste fluid is being burned?
YES
4.	Does the waste fluid comprise less than ten 1 |
percent (on a volume and heating value basis)
of the total fuel feed rate?
YES
5.	Is the waste fed into the boiler only when n
the boiler is operating at its normal operating
temperature so that the waste fluid is not
fed into the boiler during either start-up or
shut-down operations?
NO
n
NO
n
REMARKS
REMARKS
NO
n
REMARKS
NO
n
REMARKS
NO
H
REMARKS

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56
6.	Does the owner or operator of the boiler:
YES NO REMARKS
A.	continuously monitor and record the	n n 	
carbon monoxide concentration and excess		
oxygen percentage in the stack gas while		
burning the waste fluid; or		
YES NO REMARKS
B.	if the boiler will burn less than	n n 	
30,000 gallons of waste fluid per year,		
measure and record the carbon monoxide		
concentration and excess oxygen percentage		
in the stack gas at regular intervals of			
no longer than 60 minutes while burning		
the waste fluid?		
YES NO REMARKS
7.	Are the primary fuel feed rate, waste fluid 1 1 1 I 	
feed rate, and total quantities of both		
primary fuel and waste fluid fed to the		
boiler measured and recorded at regular in-		
tervals of no longer than 15 minutes while		
burning the waste fluid?		
YES NO REMARKS
8.	Are the carbon monoxide concentration and n n 	
the excess oxygen percentage checked at		
least every hour that the waste fluid is		
burned and if either measurement falls		
below the specified levels, is the waste		
fluid flow to the boiler immediately		
stopped?		

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57
9. Does the request for approval to burn the
waste fluids in the boiler adequately
address the following items:
A.	the name and address of the owner or
operator of the boiler and the address
of the boiler;
B.	the type of equipment, apparatus, and
procedures to be used to control the feed
of the waste fluid to the boiler, and to
monitor and record the carbon monoxide
concentration and excess oxygen in the
stack;
C.	the type of waste to be burned
(e.g., hydraulic fluid, contaminated
fuel oil, heat transfer fluid, etc.);
YES NO REMARKS
n n 	
VES NO REMARKS
n n 	
YES NO REMARKS
n n 	
D. the concentration of PCBs and of ar\y
other chlorinated hydrocarbon in the waste
and the results of analyses using the
American Society of Testing Materials
(ASTM) methods as referenced below:
i) concentration of PCBs;
YES NO
n n
REMARKS

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58
YES NO REMARKS
ii) concentration of other chlorinated | | | | 	
hydrocarbons;
YES NO REMARKS
iii) carbon and hydrogen content using n n 	
ASTM D - 3178;
YES NO REMARKS
iv) nitrogen content using ASTM D - 258; n n 	
YES NO REMARKS
v) sulfur content using ASTM D - 2784, n n 	
D - 1266, or D - 129;
YES NO REMARKS
vi) chlorine content using ASTM D - 808; rr n 	
YES NO REMARKS
vii) water and sediment content using	EE n 	
either ASTM D - 2709 or D - 1796;
YES NO REMARKS
viii) ash content using D - 482;	n n 	
YES NO REMARKS
ix) calorific value using ASTM D - 240; | | | | 	
YES NO REMARKS
x) carbon residue using either ASTM n n 	
D - 2158 or D - 524;
YES NO REMARKS
xi) flash point using ASTM D - 93?	1 1 [ | 	

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59
the quantity of waste fluids estimated
to be burned in a thirty-d«jy period;
an explanation of the procedures to be
followed to insure that burning the waste
fluid will not adversely affect the
operation of the boiler such that combus-
tion efficiency will decrease;
arrangements made to obtain the follow-
ing information and to retain it at the
boiler location for at least five years:
i) the data required to be collected
under 6(A) or 6(B) and 7;
ii) the quantity of low concentration
PCB liquid (waste fluid) burned in
the boiler each month; and
iii) the analysis of the waste fluid as
per item 9(D) which is required to
be taken at least once a month for
each month during which the low con-
centration PCB liquid is burned in
the boiler?
YES NO REMARKS
II EE 	
YES NO REMARKS
n n 	
YES NO REMARKS
ii n 	
YES NO REMARKS
n u 	
YES NO REMARKS
n n 	

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60
Checklist for Annex I Incinerators
1. Does the Initial Report adequately
address the following items:
A. the incinerator location;
YES NO REMARKS
n n 	
B.	a detailed description of the ,
incinerator including general site
plans and design drawings of the
incinerators;
C.	engineering reports or other
information on the anticipated
performance of the incinerator;
D.	sampling and monitoring equipment
and facilities available;
E.	waste volumes expected to be
incinerated;
F.	any local, State, or Federal per-
mits or approvals; and
G.	schedules and plans for complying
with the approval requirements?
YES NO REMARKS
U n 	
YES NO REMARKS
n n 	
YES NO REMARKS
n n 	
YES NO REMARKS
n n 	
YES NO REMARKS
n n 	
YES NO REMARKS
n n 	

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61
Does the Trial Burn Plan adequately
address the following items:
A.	the date the trial burn is to be con-
ducted;
B.	quantity and type of PCBs and PCB
items to be incinerated;
C.	parameters to be monitored and lo-
cation of sampling points;
D.	sampling frequency and methods and
schedules for samples analyses; and
E.	name, address, and qualifications of
persons who will review analytical
results an other pertinent data, and
who will perform a technical evalua-
tion of the effectiveness of the
trial burn?
If liquid PCBs are to be incinerated, have
the following requirements been satisfied:
combustion criteria shall be either of
the following:
YES NO REMARKS
(i) maintenance of the introduced liquids n n 	
for a two second dwell time at 1200°C		
(+ 100°C) and three percent excess		
o^gen in the stack gas; or		
YES NO REMARKS
n n 	
YES NO REMARKS
n H 	
YES NO REMARKS
n n 	
YES NO REMARKS
n n 	
YES NO REMARKS
n n 	

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62
YES NO REMARKS
(ii) maintenance of the introduced liquids n n
for a 1.5 second dwell time at 1600°C
(+_ 100°C) and two percent excess oxygen 1n
the stack gas;
YES NO REMARKS
n n 	
YES NO REMARKS
YES NO REMARKS
B.	combustion efficiency shall be at least
99.9 percent computed as follows:
100 [C02] / ([C02] + [CO]);
C.	the rate and quantity of PCBs which are 1 1 I 1
fed to the combustion system shall be mea-
sured and recorded at regular intervals of
no longer than 15 minutes;
D.	the temperatures of the incineration	n n
process shall be continuously measured and
recorded, and based on either direct
(pyrometer) or Indirect (wall thermocouple-
pyrometer correlation) temperature readings;
E.	the flow of PCBs to the incinerator
shall stop automatically whenever the com-
bustion temperature drops below the appli-
cable temperature specified in either 3(A)(i)
or 3(A)(1i);
YES NO REMARKS
n n 	

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63
F. monitoring of stack emission products when
an incinerator is first used for the disposal
of PCBs or when an incinerator is first used
for the disposal of PCBs after the incinerator
has been modified in a manner which mc*y affect
the characteristics of the following stack
emission products:
(i)	oxygen;
(ii)	carbon monoxide;
(iii) carbon dioxide;
(iv) oxides of nitrogen;
(v)	hydrochloric acid;
(vi)	total chlorinated organi content;
(vii)	PCBs;
(viii)	total particulate matter;
YES	NO	REMARKS
n	n		
ii	n		
n	n		
n	n		
n	n		
n	n		
n	n		
u	n		
G. at a minimum monitoring and recording of
combustion products and incineration opera-
tions shall be conducted for the following
parameters whenever the incinerator is
incinerating PCBs:
(i) oxygen;
(ii)	carbon monoxide;
(iii)	carbon dioxide;
YES NO REMARKS
n n 	
n n
n n

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64
H. the flow of PCBs to the incinerator
shall stop automatically when any one or
more of the following conditions occur:
(i) failure of monitoring operations
specified in 3(G);
YES NO REMARKS
n n 	
(ii1) excess oxygen falls below the per-
centage in 3(A);
YES NO REMARKS
(ii) failure of the PCB rate and quantity I I l I
measuring and recording equipment
specified in 3(C); or
YES NO REMARKS
n n 	
YES NO REMARKS
I. water scrubbers shall be used for HC1 con- n n
trol during PCB incineration and shall meet
any performance requirements specified by the
RA. (Note: Scrubber effluent shall be moni-
tored and shall comply with applicable
effluent or pretreatment standards and any
other State and Federal laws and regulations.
An alternative method of HC1 control may be
used if the alternate method has been
approved by the RA.)

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65
4. If non-liquid PCBs are incinerated, have
the following requirements been satisfied:
A.	the mass air emissions from the in-
cinerator shall be no greater than 0.001 g
PCB/kg of the PCB introduced into the
incinerator;
B.	combustion efficiency shall be at
least 99.9 percent computed as follows:
100 [C02] / ([C02] + [CO]);
C.	the rate and quantity of PCBs which are
fed to the combustion system shall be mea-
sured and recorded at regular intervals of
no longer than 15 minutes;
YES NO REMARKS
n n
YES NO REMARKS
n n 	
YES NO REMARKS
n n 	
YES NO REMARKS
D. the temperature of the incinerator	n n
process shall be continuously measured and
recorded and based on either direct (pyro-
meter) or indirect (wall thermocouple-
pyrometer correlation) temperature readings;

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66
E. monitoring of stack emission products
when an incinerator 1s first used for the
disposal of PCBs or when an incinerator is
first used for the disposal of PCBs after the
incinerator has been modified in a manner
which may affect the characteristics of the
following stack emission products:
YES	NO	REMARKS
(1) oxygen;	H 	
(ii) carbon monoxide;	n	n 	
(ii 1) carbon dioxide;	n	n 	
(1v) oxides of nitrogen;	n	n 	
(v) hydrochloric acid;	.| |	1 1 	
(vi) total chlorinated organic content;	n	n 	
(vi 1 > pcbs;	n	n 	
(viii) total particulate matter;	n	n 	
F. at a minimum monitoring and recording
of combustion products and incineration
operations shall be conducted for the
following parameters whenever the in-
cinerator is incinerating PCBs:
YES NO REMARKS
(i) oxygen;	n n 	
(ii) carbon monoxide;	n n 	
(iii) carbon dioxide;	| | l I 	

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67
G.	the feeding of PCBs to the Incinerator
shall stop automatically when ary one or
more of the following conditions occur:
(i) failure of monitoring operations
specified in 4(F);
(ii) failure of the PCB rate and
quantity measuring and recording
equipment specified in 4(C);
H.	water scrubbers shall be used for
HC1 control during PCB incineration and
shall meet any performance requirements
specified by the RA. (Note: Scrubber
effluent shall be monitored and shall
comply with applicable effluent or pre-
treatment standards and any other State
and Federal laws and regulations. An
alternative method of HCl control may
be used if the alternate method has
been approved by the RA.)
YES NO REMARKS
n n 	
YES NO REMARKS
II n 	
YES NO REMARKS
n n 	

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68
Checklist for Chemical Waste (PCB) Landfills
1. Does the initial report adequately address
the following items:
A. the location of the landfill;
YES NO REMARKS
n n 	
a detailed description of the landfill
including general site plans and design
drawi ngs;
an engineering report describing the
manner in which the landfill complies with
the following items, (Federal Register.
5/31/79, pp. 31553 - 31554):
(i) soils, [761.41(b)(1)]
YES NO REMARKS
n rr
(iii) hydro!ogic conditions,
[761.41(b)(3)];
(ix) supporting facilities,
[761.41(b)(9)]?
YES NO REMARKS
n n 	
VES NO REMARKS
n n 	
(ii) synthetic membranes, [761.41 (b)(2)]; | | 1 |
n n
(iv) flood protection, [761.41(b)(4)];	|	1	| 1
(v) topography, [761.41 (b)(5)];
(vi) monitoring systems, [761.41(b)(6)];	|	|	TT
(vii) leachate collection, [761.41(b)(7)]; |	|	| |
(viii) chemical waste landfill operations,	I	I	TT
[761.41(b)(8)]; and
n n

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